Department of Health and Human Services 
OFFICE OF 
INSPECTOR GENERAL 
International Merchant Purchase 
Authorization Card Program: 
Review of Calendar Year 
2001 Transactions 
JANET REHNQUIST 
Inspector General 
MARCH 2003 
OEI-07-02-00510  O I G
FFICE OF  NSPECTOR  ENERAL

http://www.oig.hhs.gov/ 
The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, as amended 
by Public Law 100-504, is to protect the integrity of the Department of Health and Human Services 
(HHS) programs, as well as the health and welfare of beneficiaries served by those programs.  This 
statutory mission is carried out through a nationwide network of audits, investigations, and inspections 
conducted by the following operating components: 
Office of Audit Services 
The OIG's Office of Audit Services (OAS) provides all auditing services for HHS, either by conducting 
audits with its own audit resources or by overseeing audit work done by others.  Audits examine the 
performance of HHS programs and/or its grantees and contractors in carrying out their respective 
responsibilities and are intended to provide independent assessments of HHS programs and operations in 
order to reduce waste, abuse, and mismanagement and to promote economy and efficiency throughout the 
Department. 
Office of Evaluation and Inspections 
The OIG's Office of Evaluation and Inspections (OEI) conducts short-term management and program 
evaluations (called inspections) that focus on issues of concern to the Department, the Congress, and the 
public.  The findings and recommendations contained in the inspections reports generate rapid, accurate, 
and up-to-date information on the efficiency, vulnerability, and effectiveness of departmental programs. 
Office of Investigations 
The OIG's Office of Investigations (OI) conducts criminal, civil, and administrative investigations of 
allegations of wrongdoing in HHS programs or to HHS beneficiaries and of unjust enrichment by 
providers.  The investigative efforts of OI lead to criminal convictions, administrative sanctions, or civil 
monetary penalties.  The OI also oversees State Medicaid fraud control units which investigate and 
prosecute fraud and patient abuse in the Medicaid program. 
Office of Counsel to the Inspector General 
The Office of Counsel to the Inspector General (OCIG) provides general legal services to OIG, rendering 
advice and opinions on HHS programs and operations and providing all legal support in OIGs internal 
operations.  The OCIG imposes program exclusions and civil monetary penalties on health care providers 
and litigates those actions within the Department.  The OCIG also represents OIG in the global settlement 
of cases arising under the Civil False Claims Act, develops and monitors corporate integrity agreements, 
develops model compliance plans, renders advisory opinions on OIG sanctions to the health care 
community, and issues fraud alerts and other industry guidance.  E X E C U T I V E  S U M M A R Y  
PURPOSE 
To determine whether Department of Health and Human Services (HHS) employees properly 
used the International Merchant Purchase Authorization Card (IMPAC), and whether 
employees properly followed the HHS guidelines and agency procedures. 
BACKGROUND 
The IMPAC program was introduced to save the government money by avoiding costly 
paperwork and to speed the process of making purchases. In June 2002, HHS had 
8,909 open IMPAC purchase card accounts. Cardholders made 654,322 purchases in 
calendar year (CY) 2001, spending more than $321 million. 
When the IMPAC program came into effect, the HHS issued guidelines for the respective 
agencies to use in developing their individual operating procedures. Core areas within the HHS 
guidelines include card issuance, card limits, training, written procedures, card security, record 
keeping, and acquisition.  Agency procedures should be no less restrictive than the HHS 
guidelines. 
The Inspector General for HHS testified on April 30, 2002, before the House Energy and 
Commerce Committee, Subcommittee on Oversight and Investigations.  In that testimony, the 
Inspector General noted concerns with the IMPAC program and card usage, and identified 
current and future work on the part of the Office of Inspector General (OIG) designed to 
protect HHS against misuse. 
We selected a stratified random sample of 400 transactions from all transactions that occurred 
during CY 2001.  We requested and reviewed agency-specific procedures to identify key 
internal controls, and used these procedures to determine compliance based on documentation 
collected from cardholders and approving officials for the sampled transactions. We received a 
file of all cardholders and approving officials as of June 2002, and analyzed this file to identify 
vulnerabilities related to cards, cardholders, and approving officials. 
FINDINGS 
Although We Did Not Identify Any Transactions That Clearly Indicated Misuse or 
Purchases Converted to Personal Use, 44 Percent of Transactions Did Not Fully 
Comply With Requirements for Using the IMPAC Purchase Card 
Based on our stratified random sample of 400 transactions, we did not identify any that clearly 
indicated misuse on the part of cardholders and approving officials, or purchases 
i 
IMPAC: Review of 2001 Transactions  OEI-07-02-00510  converted to personal use. However, 166 transactions did not fully comply with the HHS 
guidelines and agency procedures for using the IMPAC purchase card. This number projects 
to 44 percent of all transactions, accounting for $127 million of the $321 million purchased in 
CY 2001.  Because some of these transactions contain more than 1 problem, the sum of 
percentages for these 3 types do not total 44 percent. Approximately 38 percent lacked 
documentation of approving official review, 8 percent lacked sufficient purchase 
documentation, and 7 percent did not document the associated object class code. 
Additional Control Weaknesses Increase the Risk of Improprieties 
Although internal agency procedures are in place governing card usage, issues related to the 
cards themselves came to light through an examination of the file of all IMPAC accounts 
open, as of June 2002. 
These issues, along with selected examples, include: 
	 open accounts that should be closed  1,390 cards were reported lost or had expired, 
yet these accounts remained open on U.S. Banks file; 
  infrequent card usage  790 of 6,823 accounts had no activity during CY 2001; 
	 agencies failing to set reasonable card limits  the HHS had at least $2.4 billion in 
available credit during CY 2001, yet made only $321 million in purchases; 
	 relationships of cardholders to approving officials  7 accounts have the cardholder and 
approving official listed as the same person; 
	 span of control of approving officials  19 percent of approving officials have 
responsibility for 5 or more accounts; and 
	 approving officials and cardholders not collocated  17 percent of accounts have 
approving officials with different zip codes in their mailing addresses than the 
corresponding cardholders. 
As these concerns persist, the IMPAC program remains vulnerable to misuse. 
Cardholder and Approving Official Actions Demonstrate a Lack of Understanding 
of Agency Procedures and the Need for Updated and Enhanced Training 
Although the HHS guidelines and agency-specific procedures require training, cardholders and 
approving officials actions demonstrate a lack of understanding in properly controlling and 
safeguarding cards. Specific examples from our sample of 400 transactions include: 
ii 
IMPAC: Review of 2001 Transactions  OEI-07-02-00510  	 31 percent of cardholders produced their cards from their personal wallets, despite the 
HHS guidelines, which recommend that cardholders keep cards in locked locations 
when not in use, and 1 cardholder could not find his card; 
	 23 percent of cardholders had not signed their cards, increasing the ease with which 
another person could use the card, if lost or stolen; and 
	 1 office maintained a listing of card numbers in an electronic file so that any cardholder 
in the office could use any other card if he or she reached the 30-day limit on his/her 
card, and 1 cardholder had given the card to another individual, despite the HHS 
guidelines and agency procedures, which specifically prohibit use of a card by anyone 
other than the authorized cardholder. 
CONCLUSION AND RECOMMENDATIONS 
Although we did not identify any transactions that clearly indicated misuse on the part of 
cardholders and approving officials, or purchases converted to personal use, issues related to 
documentation, or the lack thereof, and the failure to follow internal controls did raise concerns. 
Our review of the cardholder file from U.S. Bank raised issues with cards and cardholders, 
such as unused accounts and questionable card limits. Finally, cardholders and approving 
officials actions demonstrate a lack of understanding of agency procedures and the need for 
updated and enhanced training. 
Therefore, we recommend that the Office of the Assistant Secretary for Administration and 
Management, working through agency program coordinators: 
	 Ensure that cardholders, approving officials, and agencies are in full compliance with the 
guidelines established, 
  Develop guidance where none currently exists, and 
  Provide periodic targeted training for current cardholders and approving officials. 
AGENCY COMMENTS 
The draft of this report was reviewed by the Office of the Assistant Secretary for 
Administration and Management (ASAM). In its response, ASAM noted that it received input 
from the General Accounting Office and the Office of Management and Budget (OMB) that 
emphasized findings in our report. The ASAM noted that it will work with OMB to improve 
internal controls highlighted in our report. 
The ASAM did state that the OIG may have drawn an incorrect inference from the vendors 
(US Bank) use of non-standard terminology. More specifically, the OIG failed to note that 
open accounts reported lost or stolen do not create a risk because they have been 
deactivated. Although it is true that we did not identify purchases associated with the cards we 
identified as lost or stolen, we chose to include the information because we had requested a file 
of open accounts, expecting to receive only open, active accounts. 
iii 
IMPAC: Review of 2001 Transactions  OEI-07-02-00510  Instead, we received a file containing large numbers of inactive accounts. We believe this could 
create difficulties in successfully managing the IMPAC program within HHS. Agency program 
coordinators, with whom we spoke, expressed frustration with their attempts to clean up their 
cardholder accounts, only to see accounts they attempted to get closed continue to show up on 
open account reports. We have revised the report to help clarify this point. The full text of 
ASAMs comments can be found in Appendix D. 
iv 
IMPAC: Review of 2001 Transactions  OEI-07-02-00510  T A B L E  O F  C O N T E N T S  
PAGE

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

INTRODUCTION .............................................................1

FINDINGS  ..................................................................5

Documentation and Internal Control Problems  ...................................5

Additional Control Weaknesses ..............................................8

Lack of Understanding of Procedures ......................................... 12

CONCLUSION AND RECOMMENDATIONS ................................... 13

AGENCY COMMENTS  ...................................................... 14

APPENDICES

A: Confidence Intervals for Key Estimates  .....................................15

B: Matrix of Transactions with Problems .......................................16

C: Overview of Guidelines and Procedures .....................................20

D: Agency Comments  ....................................................26

ACKNOWLEDGMENTS ..................................................... 27
 I N T R O D U C T I O N  
PURPOSE 
To determine whether Department of Health and Human Services (HHS) employees properly 
used the International Merchant Purchase Authorization Card (IMPAC), and whether 
employees properly followed the HHS guidelines and agency procedures. 
BACKGROUND 
The IMPAC program was introduced to save the government money by avoiding costly 
paperwork and to speed the process of making purchases.  In June 2002, the HHS had 8,909 
open IMPAC purchase card accounts.  Cardholders used the IMPAC purchase cards and 
checks (a feature of the program that allows cardholders to write a check against the IMPAC 
purchase card account when individuals or entities do not accept purchase cards) to make 
654,322 purchases in calendar year (CY) 2001, spending more than $321 million. 
To protect against unauthorized or fraudulent use of purchase cards, the Treasury Financial 
Manual, Vol. 1, Part 4, Section 4525 requires that each agency has its own internal 
procedures for using purchase cards.  When the IMPAC program came into effect, the HHS 
issued guidelines for the respective agencies to use in developing their individual operating 
procedures. Core areas within the HHS guidelines included card issuance, card limits, training, 
written procedures, card security, record keeping, and acquisition. Agency procedures should 
be no less restrictive than the HHS guidelines. 
Nine agencies within the HHS have IMPAC program coordinators and have issued procedures 
governing card usage.  These agencies are the Agency for Healthcare Research and Quality, 
Centers for Disease Control and Prevention, Centers for Medicare & Medicaid Services, Food 
and Drug Administration, Health Resources and Services Administration, Indian Health 
Service, National Institutes of Health, Program Support Center (PSC), and the Substance 
Abuse and Mental Health Services Administration. Smaller agencies or offices that do not have 
their own program coordinators, such as the Office of Inspector General (OIG), receive their 
cards through the PSC. 
The Inspector General for HHS testified on April 30, 2002, before the House Energy and 
Commerce Committee, Subcommittee on Oversight and Investigations.  In that testimony, the 
Inspector General noted concerns with the IMPAC program and card usage, and identified 
current and future work on the part of the OIG designed to protect the HHS against 
unauthorized or questionable activity. As part of the current work, the OIGs Office of 
Investigations (OI) has received from U.S. Bank (the vendor for the HHS IMPAC purchase 
card program) information for all transactions dating back to 
IMPAC: Review of 2001 Transactions  1  OEI-07-02-00510  November 1999. The OI electronically reviews the data to identify potentially questionable 
purchases. These purchases are forwarded to the cognizant agency for their review; the 
agencies return the results to OI for appropriate action. 
METHODOLOGY 
The OIGs Office of Evaluation and Inspections (OEI) obtained data from OIG/OI for all HHS 
IMPAC card transactions occurring between November 1999 and April 2002. Using this file, 
we identified all transactions that occurred during CY 2001. There were 654,322 transactions 
that met this criteria. We excluded from the population transactions of $5 or less, due to the 
low risk to the HHS associated with these purchases (8,426 transactions in CY 2001 totaling 
$28,748). We also attempted to exclude all New York-based hotel expenditures (34 
transactions totaling $2.8 million) that were used for continuity of operations following 
September 11, 2001, due to the potential sensitivity related to these transactions and because 
normal restrictions for use of credit cards were temporarily not in effect to accommodate these 
types of transactions.  We did not exclude transactions for other types of purchases (e.g., 
security services, communication equipment) that occurred because of operational changes 
after September 11, 2001. From the remaining transactions, we selected a stratified random 
sample of 400. A description of the 5 strata with their population, corresponding dollar 
amounts, and sample size are shown in Table 1 below. 
Table 1: Stratified Sample of Transactions 
Number of 
Dollar Amount of 
Purchase Amount  Transactions  Sample Size 
Transactions 
(CY 2001) 
$25,000 or more  159  $7,873,071  50 
$10,000 to less than  $18,363,580  50 
1,163 
$25,000 
$2,500 to less than  $45,284,615  100 
10,112 
$10,000 
$500 to less than  $167,850,785  100 
151,206 
$2,500 
Greater than $5 to less  $79,361,431  100 
483,222 
than $500 
Totals  645,862*  $318,733,482  400 
*Total excludes transactions of $5 or less and hotels related to continuity of operations 
post September 11, 2001. 
IMPAC: Review of 2001 Transactions  2  OEI-07-02-00510  For 375 of the 400 transactions, we met with the cardholder, approving official, and/or acting 
or designated officials.1 We collected from them all documentation supporting the transaction 
that was maintained in the cardholder or approving officials files.  For the remaining 25 
transactions, we requested that documentation be submitted via mail or fax because the 
locations of the cardholders and approving officials were remote, making the costs associated 
with travel to the locations greater than the risk associated with not making on-site visits. 
For each transaction, information that we requested included, but was not limited to, receipts, 
orders, invoices, or packing slips; the object class code associated with the item; proof of 
approving official review and approval; inventory control and transferred/excessed forms (if 
appropriate); and evidence of bids, sole source, or the existence of a master contract for 
purchases exceeding $2,500. Whenever possible and appropriate, we matched equipment 
(e.g., computers, fax machines) against the inventory control forms. We also checked where 
cardholders maintained their cards and whether the cards were signed, the training status of 
cardholders and approving officials, and whether cardholders or approving officials had in their 
possession their agencys IMPAC procedures. Finally, we had the cardholder, approving 
official, and/or acting or designated officials sign an attestation verifying that the information we 
received was complete and accurate. 
We sought to collect only those documents maintained in the cardholder and approving official 
files, based on agency procedures that require cardholders and approving officials to maintain 
documents to support each individual transaction. Therefore, we did not seek documents at 
off-site locations, although we did allow approving officials and cardholders to fax 
documentation to us for one week following on-site fieldwork. Documents were faxed to us for 
10 percent (37 of 375) of the sampled transactions. Fieldwork was conducted between July 
17 and August 23, 2002. 
We requested and received from the nine aforementioned agencies their current IMPAC 
procedures. We reviewed these procedures to identify key internal controls, and compared 
these procedures against the HHS guidelines and across agencies. We used the identified 
controls as the basis of reviewing the sampled transactions. For each transaction, we made a 
determination of whether documentation was maintained to support the purchase and whether 
there was a failure to comply with internal controls (e.g., no proof of approving official review, 
object class code not maintained).  Confidence intervals for key estimates can be found in 
Appendix A of this report. 
We requested from U.S. Bank a listing of all open accounts as of June 2002.  This file 
contained 8,909 records, with fields identifying the cardholder and address; approving official 
and address; dates issued, returned, and expired (if appropriate); and limits on 
1
Some cardholders and approving officials were not available when we were scheduled to visit their 
location. We made arrangements for someone to act on the cardholder or approving officials behalf and to provide 
access to and certify the information we required. 
IMPAC: Review of 2001 Transactions  3  OEI-07-02-00510  card usage, including single-purchase and 30-day limits. We used this file to review various 
aspects related to the cards, and the cardholders and approving officials. We also matched the 
file to our transaction file to determine card usage as well as to determine the cardholder and 
approving official associated with each sampled transaction. 
This inspection was conducted in accordance with the Quality Standards for Inspections 
issued by the Presidents Council on Integrity and Efficiency. 
IMPAC: Review of 2001 Transactions  4  OEI-07-02-00510  F I N D I N G S  
Based on our stratified random sample of 400 transactions and the documentation we received 
from cardholders and approving officials supporting these transactions, we did not identify any 
transactions that clearly indicated misuse on the part of cardholders and approving officials, or 
purchases converted to personal use.  However, we did find significant noncompliance with the 
HHS guidelines and agency procedures regarding (1) approving official review, (2) purchase 
documentation, and (3) object class codes. In addition, our review of the cardholder file from 
U.S. Bank disclosed internal control weaknesses, such as unused accounts and questionable 
card limits, which increase the risk of improprieties. Finally, although guidelines and procedures 
require cardholders and approving officials to receive training, cardholder and approving official 
noncompliance with the HHS guidelines and agency procedures demonstrate a lack of 
understanding of these policies and the need for updated and enhanced training. 
Although We Did Not Identify Any Transactions That Clearly 
Indicated Misuse or Purchases Converted to Personal Use, 44 
Percent of Transactions Did Not Fully Comply With 
Requirements for Using the IMPAC Purchase Card 
One hundred sixty-six of the 400 sampled transactions did not fully comply with requirements 
for using the IMPAC purchase card, as described in the HHS guidelines and agency 
procedures. This number projects to 44 percent of all transactions, accounting for $127 million 
of the $321 million purchased in CY 2001. Three types of problems comprise the 44 percent 
projection, including (1) no evidence of approving official review, (2) lack of purchase 
documentation, and (3) failure to record object class codes.  Because some of these 
transactions contain more than 1 problem, the sum of percentages for these 3 types do not total 
44 percent. Table 2 on the following page summarizes these problems, while Appendix B 
provides breakdowns of problem types for each transaction. 
IMPAC: Review of 2001 Transactions  5  OEI-07-02-00510  Table 2: Breakdowns of Transactions with Problems 
Projected 
Number of 
Percent of  Purchase 
Reason  Transactions/ 
Universe  Amount 
Problems 
(Millions) 
No evidence of approving official 
125  38%  $97 
review 
Insufficient purchase documentation  65  8%  $46 
Failure to record object class code  28  7%  $22 
218 problems 
Total of transactions which do not 
across 166  44%  $127 
fully comply with requirements 
transactions 
Agency procedures require cardholders and approving officials to maintain documents to 
support purchases and demonstrate compliance with internal controls. We gathered available 
documents (mostly through on-site visits) and reviewed these documents to determine whether 
procedures were followed.  An overview of guidelines and procedures for IMPAC transactions 
can be found in Appendix C. 
Approximately 38 percent of transactions had no evidence of approving official 
review 
The HHS guidelines describe the need for approving officials to review accounts prior to 
forwarding information to their respective finance offices for payment. Agency procedures 
provide greater specificity on (1) what approving officials must do  reviewing invoices, 
packing slips, or other appropriate purchase documentation  and (2) how they must do it  
signing the bottom of card statements or, more recently, using electronic automated systems to 
document review. 
Cardholders or approving officials either did not obtain or maintain evidence of approving 
official review for 125 of the 400 transactions.  This number projects to 38 percent of all 
transactions, accounting for $97 million in purchases.  Some cardholders claimed approving 
official review had occurred, but we could not find anything to support these claims within the 
cardholder or approving official files, and cardholders and approving officials did not supply 
any additional documentation via fax after completion of our site visits. Cardholders and/or 
approving officials did sign attestations indicating that the information we received at the 
completion of our fieldwork was complete and accurate. 
IMPAC: Review of 2001 Transactions  6  OEI-07-02-00510  Approximately 8 percent of transactions had insufficient purchase documentation 
The HHS guidelines indicate the need to maintain a paper trail  . . . that will support all 
purchases and be available to anyone auditing the process. Agency procedures support this 
guideline by requiring cardholders or approving officials to obtain charge slips, cash register 
receipts, packing slips, or invoices, or to include a statement in the files as to why such 
documentation does not exist and what steps were taken to collect the missing documentation. 
Sixty-five of the 400 transactions had insufficient purchase documentation.  This number 
projects to 8 percent of all transactions, accounting for $46 million in purchases. For 51 of 
these transactions, there was no invoice or receipt.  For 12 transactions, the invoice amount did 
not equal the transaction amount. For 2 transactions, we could not determine if credits for 
disputed transactions were ever received. 
Due to the seriousness of problems for 30 of the transactions with documentation problems, we 
re-contacted the cardholders and approving officials and requested additional documentation. 
More than half could not or did not supply any additional documentation. Of those that did, 
some still could not fully support the transaction, and one supplied information indicating that the 
purchase was split between two cardholders to circumvent single-purchase limits.2 We have 
referred several transactions for further development and/or investigation. 
Approximately 7 percent of transactions did not have a recorded object class 
code 
The HHS guidelines state that The individual card holder must write the CAN [Common 
Accounting Number] and object class on the Statement of Account as appropriate, and the 
approving official must also verify this information. All agency procedures echoed the need to 
document the object class code. 
Cardholders did not maintain the object class code for 28 of the 400 sampled transactions, or 7 
percent when projected to the universe, accounting for $22 million in purchases. The object 
class code is an accounting code, which is used to classify expenditures to maintain budgetary 
control and report expenditures to the Office of Management and Budget.  We did not trace 
these transactions to final accounting records to determine whether the transactions were 
properly classified.  Our objective was to determine whether the 
2 
Agency procedures clearly prohibit cardholders from splitting purchases to avoid purchase limits. We 
purposively selected 16 attempted transactions that would have exceeded the accounts single-purchase limit as 
further evidence of efforts to circumvent limits. We identified all transactions that each of the 16 cardholders made, 
and then, for each cardholder, searched for purchases on the same day or within a few days of the declined 
transaction. Six of the 16 had 2 or 3 purchases that, when added, matched the amount of the declined transaction. 
One cardholder, with a $25,000 single-purchase limit, split a $36,450 transaction into two transactions  $18,225 each 
 after having the original transaction declined. 
IMPAC: Review of 2001 Transactions  7  OEI-07-02-00510  cardholder documented the object class code as the HHS guidelines and agency procedures 
require. 
Additional Control Weaknesses Increase the Risk of 
Improprieties 
In addition to our work on the sampled transactions, we expanded our review to include 
analyses of accounts listed as open to identify additional vulnerabilities. Because agencies could 
not adequately provide us with a listing of all open IMPAC accounts, we requested such a 
listing from U.S. Bank. The file we received contained all the HHS accounts with the status 
listed as open as of June 2002.  Additional vulnerabilities that could place the HHS at risk of 
misuse include the following: 
  coding 1,390 accounts as open that should be closed, 
  maintaining infrequently used cards, 
  setting extreme 30-day limits, ranging up to $2 million, and 
	 having approving officials responsible for an excessive number of accounts and allowing 
circumstances that compromise the independence of approving official review. 
As these concerns persist, the IMPAC program remains vulnerable to questionable, fraudulent, 
and unsupported purchases, and overall misuse. 
Approximately 16 percent of open accounts should be closed 
A review of the file from U.S. Bank revealed that 1,374 cards were reported lost, although the 
account status remained open.  An additional 16 accounts had expiration dates that made the 
accounts inactive, yet, again, the status on the accounts remained open. 
Although no account activity was associated with any of these 1,390 accounts, they do increase 
the administrative burden associated with managing the IMPAC program. Several of the 
program coordinators throughout the HHS indicated they report to U.S. Bank when  accounts 
should be closed.  However, the coordinators claim that these accounts frequently remained in 
an open status when the coordinators received updated statements of open accounts.  They 
were left to make additional contacts to U.S. Bank to attempt to resolve the matter. 
More than one-fifth of cards are being used infrequently 
Using the U.S. Bank file, we identified 6,823 accounts that were active throughout 

CY 2001. We arrived at this number by taking the file of open accounts from U.S. Bank and

excluding all cards reported lost or with expiration dates prior to 2001, or with dates indicating

accounts opened in 2002.

IMPAC: Review of 2001 Transactions  8  OEI-07-02-00510  Of the 6,823 accounts active throughout CY 2001, 790 had no transaction activity during the 
entire year.  Approximately 22 percent (1,491) of all accounts had fewer than 6 total 
transactions  less than 1 transaction every 2 months  during 2001.  Cardholders may be less 
likely to notice that a card is lost or stolen if it is used infrequently. 
At the other extreme, 3 percent (179) had more than 500 transactions during the year.  The 
highest number of transactions was 2,650, which averages out to more than 7 transactions a 
day for every day of CY 2001.  Table 3 below summarizes transactional activity for all 
accounts open throughout CY 2001. 
Table 3: Number of Transactions Associated with 
Accounts Active Throughout CY 2001 
Number of 
Transactions per  Number of 
Percent 
Account During  Accounts 
CY 2001 
0  790  11.6% 
1  194  2.8% 
2-6  627  9.2% 
7-12  555  8.1% 
13-24  901  13.2% 
25-48  1,228  18.0% 
49-100  1,252  18.4% 
101-1,000  1,218  17.8% 
1,001-2,000  52  0.8% 
Greater Than 2,000  6  0.1% 
Total  6,823  100.0% 
Agencies fail to set reasonable card limits 
The HHS guidelines instruct agencies to establish card limits in relation to the bona fide needs of 
the office involved, consistent with sound management and oversight. In addition, limits should 
be as realistic as possible and tied into the offices budget and operating plan.  Limits help 
protect the office or agency against financial loss if the cardholder or another individual uses the 
card improperly. 
In CY 2001, the HHS had at least $2.4 billion in available credit to make purchases with the 
IMPAC cards. We computed this figure by multiplying all available 30-day 
IMPAC: Review of 2001 Transactions  9  OEI-07-02-00510  limits for the 6,823 accounts open throughout CY 2001 by 12 months. The extreme 30-day 
limit was $2 million, with two cardholders having this limit. It bears repeating that the HHS 
used cards to make approximately $321 million in purchases in CY 2001, meaning that 
cardholders used less than 14 percent of available limits for purchases. Table 4 on the next 
page summarizes 30-day limits for cards active throughout CY 2001. 
Table 4: Summary of 30-day Limits 
for Accounts Active Throughout CY 2001 
Number of 
30-day Limit  Percent 
Accounts 
$100 to $2,500  819  12.0% 
Greater than $2,500 
1,168  17.1% 
to $5,000 
Greater than $5,000 
2,067  30.3% 
to $10,000 
Greater than $10,000 
1,719  25.2% 
to $25,000 
Greater than $25,000 
491  7.2% 
to $50,000 
Greater than $50,000 
321  4.7% 
to $100,000 
Greater than 
238  3.5% 
$100,000 
Total  6,823  100.0% 
As further evidence that agencies set questionable limits: 
	 54 accounts (0.8 percent) active throughout CY 2001 had single-purchase limits that 
were greater than the 30-day limits;3 
	 Cardholders for 133 accounts (1.9 percent) would need to make 50 or more 
purchases a month to reach the 30-day limit, assuming each purchase was the maximum 
allowable single-purchase amount; and 
3
A program coordinator informed us that the agency uses default single-purchase limits and sets 30-day 
limits, based on office needs. This explanation may explain why some single-purchase limits fall below the 30-day 
limit. 
IMPAC: Review of 2001 Transactions  10  OEI-07-02-00510  	 28 accounts had a single-purchase limit of $1.4 The cardholder for one such account 
attempted to make 66 purchases during the first quarter (January through March) of 
2002, all of which were denied. The limit remained at $1 at the time we received the 
cardholder file in June 2002. 
Specific guidelines and procedures do not address potential vulnerabilities 
related to cardholders and approving officials 
The HHS guidelines and agency procedures do not specifically address many situations related 
to cardholders and approving officials, including who can act as an approving official for whom, 
the span of control for approving officials, and the location of cardholders relative to approving 
officials. Our review of the file of accounts active throughout CY 2001 revealed the following 
situations: 
	 7 accounts list the same individual as cardholder and approving official  since none of 
these accounts were in our sample, we cannot say whether these cardholders are 
actually approving their own transactions; 
	 For 29 accounts, cardholders and approving officials have reversed relationships on 
another 29 accounts (i.e., individual A is the cardholder and individual B is the 
approving official on one account, while individual A is the approving official and 
individual B is the cardholder on another account)  the nature of reversed relationships 
on accounts may present an environment for misuse; 
	 378 approving officials have responsibility for 5 or more accounts, while the extreme is 
1 approving official responsible for 72 accounts  we question the extent of transaction 
approvals for approving officials with many accounts to manage; and 
	 1,193 cardholders had mailing addresses in ZIP codes different from the ZIP codes 
listed for the approving official, with the extreme being 2,770 miles between the address 
for the cardholder and the approving official  this situation potentially limits 
communication and sharing of purchase documentation between cardholders and 
approving officials. 
4
A program coordinator informed us that the agency sets single-purchase limits at $1 when cardholders fail 
to properly comply with requirements governing the IMPAC purchase card. This limit effectively prevents the 
cardholders from using the cards until matters have been resolved. 
IMPAC: Review of 2001 Transactions  11  OEI-07-02-00510  Cardholder and Approving Official Actions Demonstrate a 
Lack of Understanding of Agency Procedures and the Need 
for Updated and Enhanced Training 
According to the IMPAC procedure manuals for all nine agencies, training is required for 
cardholders and approving officials. Seven agencies specifically require completion of training 
before a card is issued. Nonetheless, our findings show cardholders and approving officials 
lack an understanding of IMPAC procedures. 
In addition to previously identified failures to obtain or maintain evidence of approving official 
review, retain sufficient purchase documentation, and/or properly record the object class code, 
we offer the following examples from our random sample of 400 transactions where 
cardholders and approving officials are not properly following procedures: 
	 31 percent of cardholders produced their cards from their personal wallets, despite the 
HHS guidelines, which recommend that cardholders keep cards in locked locations 
when not in use, and 1 cardholder could not find his card; 
	 23 percent of cardholders had not signed their cards, increasing the ease with which 
another person could use the card if lost or stolen; and 
	 1 office maintained a listing of card numbers in an electronic file so that any cardholder 
in the office could use any other card if he or she reached the 30-day limit on his/her 
card, and one cardholder had given the card to another individual, despite the HHS 
guidelines and agency procedures that specifically prohibit use of a card by anyone 
other than the authorized cardholder. 
Potentially compounding this lack of understanding is the fact that procedure manuals for two 
agencies are currently in draft status.  During the on-site visits, approving officials and 
cardholders for one of the agencies told us that their agency had never released a final 
procedures manual, while the other agency recently updated procedures to reflect changes in 
transaction review and approval. 
IMPAC: Review of 2001 Transactions  12  OEI-07-02-00510  C O N C L U S I O N  A N D  
R E C O M M E N D A T I O N S  
The IMPAC card purchase program was intended to save the government money by reducing 
the burden of completing excessive paperwork and to expedite the process of making 
purchases. We did not identify any transactions that, based on the documentation we were 
able to obtain, clearly indicated misuse on the part of cardholders and approving officials, or 
purchases converted to personal use. In addition, where controls exist, they appear to provide 
protection against abuse, if properly followed. Yet 44 percent of transactions had no evidence 
of approving official review, insufficient purchase documentation, and/or no recorded object 
class code. We recognize that, for efficient operation of the IMPAC program, some situations 
(e.g., lack of approving official and cardholder collocation) may be necessary.  However, 
control weaknesses, such as unreasonable limits and a lack of specific controls, increase the 
risk of improprieties.  Finally, although guidelines and procedures require cardholders and 
approving officials to receive training, questionable cardholder and approving official actions 
demonstrate a lack of understanding of agency procedures and the need for updated and 
enhanced training. 
As the IMPAC purchase card program continues to evolve, internal controls and procedures 
may fail to provide adequate protection against misuse.  Therefore, we recommend that the 
Office of the Assistant Secretary for Administration and Management, working through agency 
program coordinators: 
	 As soon as possible, ensure that agencies are in full compliance with the established 
guidelines, including the following areas: (1) maintaining documents to support all 
transactions, (2) closing unnecessary accounts, (3) establishing appropriate card limits, 
(4) issuing final procedure manuals, and (5) maintaining physical security of the card. 
	 Develop guidance specifically targeting: (1) location of cardholders and approving 
officials, (2) role of approving officials and cardholders and the implications of those 
roles being interchangeable, and (3) breadth of approving official span of control. 
	 Provide periodic targeted training for cardholders and approving officials with particular 
emphasis given to: (1) maintenance of supporting documentation, 
(2) responsibilities of approving officials, (3) agency-specific card limits, and 
(4) card security and designated authorized users. 
IMPAC: Review of 2001 Transactions  13  OEI-07-02-00510  A G E N C Y  C O M M E N T S  
The draft of this report was reviewed by the Office of the Assistant Secretary for 
Administration and Management (ASAM). In its response, ASAM noted that it received input 
from the General Accounting Office and the Office of Management and Budget (OMB) that 
emphasized findings in our report. The ASAM noted that it will work with OMB to improve 
internal controls highlighted in our report. 
The ASAM did state that the OIG may have drawn an incorrect inference from the vendors 
(US Bank) use of non-standard terminology. More specifically, the OIG failed to note that 
open accounts reported lost or stolen do not create a risk because they have been 
deactivated. Although it is true that we did not identify purchases associated with the cards we 
identified as lost or stolen, we chose to include the information because we had requested a file 
of open accounts expecting to receive only open, active accounts. Instead we received a file 
containing large numbers of inactive accounts.  We believe this could create difficulties in 
successfully managing the IMPAC program within HHS. Agency program coordinators, with 
whom we spoke, expressed frustration with their attempts to clean up their cardholder 
accounts, only to see accounts they attempted to get closed continue to show up on open 
account reports. We have revised the report to help clarify this point. The full text of ASAMs 
comments can be found in Appendix D. 
IMPAC: Review of 2001 Transactions  14  OEI-07-02-00510  APPENDIX A 
Confidence Intervals for Key Estimates 
We calculated confidence intervals for five key estimates. The estimates are given at 90 
percent confidence level. 
Point  Confidence  Point  Confidence 
Key Estimate  Estimate  Interval  Estimate  Interval 
Percent  Percent  Dollar Amount  Dollar Amount 
Transactions which do 
not fully comply with  43.503%  +/-6.439%  $126,655,676  +/-$19,770,302 
requirements 
Transactions which lack 
evidence of approving  38.435%  +/-6.347%  $97,266,068  +/-$17,646,406 
official review 
Transactions which have 
insufficient purchase  8.111%  +/-3.231%  $45,918,740  +/-$13,239,430 
documentation 
Transactions which lack a 
recorded object class  6.543%  +/-3.267%  $21,762,200  +/-$9,796,178 
code 
IMPAC: Review of 2001 Transactions  15  OEI-07-02-00510  APPENDIX B 
Matrix of Transactions with Problems

One hundred sixty-six of 400 sampled transactions have one or more problems, as indicated in 
the table below. 
No evidence of  Insufficient  Lack of 
Sample 
approving  purchase  recorded object 
Number 
official review  documentation  class code 
6  x 
7  x 
8  x 
9  x 
10  x 
15  x 
16  x 
17  x 
18  x 
21  x 
22  x 
27  x 
32  x  x 
34  x 
35  x  x 
39  x 
40  x 
41  x 
42  x

44  x

52  x

53  x

54  x

55  x

71  x

72  x

73 x  x x

75  x

82 x  x

93 x  x x

96  x

97  x

98  x

102  x

104 x  x

105  x  x  x 
IMPAC: Review of 2001 Transactions  16  OEI-07-02-00510  No evidence of  Insufficient  Lack of 
Sample 
approving  purchase  recorded object 
Number 
official review  documentation  class code 
106  x 
108  x 
112  x 
114  x  x 
116  x 
117  x 
118  x  x  x 
119  x 
123  x 
135  x 
140  x 
141  x 
143  x 
144  x 
145  x  x  x 
150  x 
151  x 
153  x 
155  x  x  x 
156  x  x 
159 x  x

165  x

167  x

168  x

170  x

172  x

175 x  x

179 x  x

180  x

181  x

184  x

186 x  x x

187 x  x

188  x

189  x

190 x  x

191 x  x

192  x

193  x

194  x

195 x  x

196 x  x

197  x  x 
198  x 
IMPAC: Review of 2001 Transactions  17  OEI-07-02-00510  No evidence of  Insufficient  Lack of 
Sample 
approving  purchase  recorded object 
Number 
official review  documentation  class code 
199  x 
201  x  x 
202  x  x 
203  x  x 
204  x  x 
206  x 
207  x 
208  x 
210  x 
211  x 
215  x  x 
217  x 
218  x 
222  x 
224  x 
225  x  x 
226  x 
227  x 
228  x 
229  x 
230  x

231  x

232  x

233  x

234  x

235 x  x

240  x

241  x

245  x

248  x

252 x  x

253 x  x

255  x

256 x  x x

261  x

263  x

264  x

265  x

266  x

267 x  x

268  x

269  x

270  x 
271  x 
IMPAC: Review of 2001 Transactions  18  OEI-07-02-00510  No evidence of  Insufficient  Lack of 
Sample 
approving  purchase  recorded object 
Number 
official review  documentation  class code 
277  x 
278  x 
281  x 
282  x  x 
284  x  x 
285  x  x 
288  x 
289  x 
290  x 
291  x 
292  x  x  x 
293  x  x 
294  x  x  x 
295  x  x 
296  x  x 
300  x  x 
308  x 
313  x 
322  x 
325  x 
327  x

329  x

330  x

331  x

338  x

339  x

347  x

350  x

351  x

357  x

368  x

370  x

374  x

375  x

379  x

380  x

381  x

382  x

384  x

393  x

395  x

397  x

Totals *  125  65  28 
* 166 transactions 
IMPAC: Review of 2001 Transactions  19  OEI-07-02-00510  APPENDIX C 
Overview of Guidelines and Procedures

The following is an overview of guidelines and procedures governing IMPAC card usage, 
corresponding to areas reviewed in the body of the report. For each section, we provide the 
HHS guideline, if appropriate, and offer examples drawn from one or more of the agency 
procedures to illustrate how agencies have implemented or added to the HHS guideline or how 
agencies have addressed the need for a given internal control.  We did make some minor 
revisions to the guidelines and procedures presented below to aid in readability and flow, 
although we did preserve the emphasis that the HHS or agencies added. 
Overall, from the HHS: 
These guidelines apply to all components of the HHS.  Each operating component must 
develop written internal operating procedures regarding the use of cards. These procedures 
should detail the internal controls and processing steps that the operating component will follow 
in implementing this program. 
Approving Official Review: 
From the HHS: 
After verification by the cardholders and approving official, the Statements of Account are sent 
to the serving finance office. 
From the agencies: 
The cardholder must register their transactions during the billing cycle in the automated 
Managing/Accounting Credit Card System (MACCS), ensuring that the object class code and 
Common Accounting Number (CAN) for the purchases are included in the data. The 
transaction is forwarded to the approving officials for his/her approval. When the approving 
official approves the transaction, the process status changes from Registered to Approved. 
The cardholder must document certain information on the statement of account and attach all 
supporting documentation, such as charge slips, packing slips, and purchase log, and forward 
the signed statement to the approving official.  After signing the statement of account, approving 
officials will return a signed copy along with back-up documentation to the cardholder to be 
maintained as part of their monthly purchase file. 
IMPAC: Review of 2001 Transactions  20  OEI-07-02-00510  Approving officials monitor the proper use of the purchase card by cardholders assigned to 
them. Approving officials are responsible for reviewing their monthly cardholders statements 
and verifying that all transactions are for necessary government purchases in accordance with 
regulations and agency manuals. Approving officials shall: 
  Ensure that established limits are not exceeded; 
  Ensure that cardholders receive training; 
	 Receive, review, and reconcile the banks monthly billing statement against the 
cardholders statements of account, ensuring that receipts and documentation are in 
order; 
  Certify the monthly bill statement for payment processing; 
	 File and maintain the cardholders original statements of account, receipts, and charge 
slips, along with copies of the monthly billing statements for 6 years and 3 months. 
Purchase Documentation: 
From the HHS: 
A paper trail must be maintained that will support all purchases and be available to anyone 
auditing this process. At a minimum, this paper trail must include an identification of the items 
bought, who requested the items, date of purchase, amount of purchase, vendor, and funds 
charged. 
It is the responsibility of each individual card holder to keep copies of each charge slip and to 
quickly reconcile each monthly statement and forward the information on to the approving 
official. 
From the agencies: 
All charge slips and other documentation (including cash register receipts, packing slips, 
Cardholders Statement of Questioned Items forms  if necessary) should be retained in a 
permanent file and will be required for submission to the Administrative Office when the 
cardholder accounts are audited. If no documentation is available, the cardholder should 
indicate the word lost under the date of purchase on the purchase log and attach a written 
explanation.  Check to see if duplicate copies can be obtained from the merchant. 
Attach all documentation (e.g., charge slips, packing slips, and any Cardholders Statement of 
Questioned Item  CSQI  forms) to the log, sign and date the log, and retain in the 
cardholders file. 
Any time a purchase is made, whether it is done over the counter or by telephone, a monthly 
cumulative purchase log must be annotated and retained in the purchase file. Each cardholder 
must set up a purchase file for all proof of purchase documents associated with purchase card 
orders. 
IMPAC: Review of 2001 Transactions  21  OEI-07-02-00510  Recording of Object Class Code: 
From the HHS: 
The individual card holder must write the CAN and object class on the Statement of Account 
as appropriate, and the approving official must also verify this information. 
From the agencies: 
The cardholder must register their transactions/purchases during the billing cycle in the MACCS 
automated system, ensuring that the object class code and CAN number for the purchases are 
included in the data. The transaction is forwarded to the approving officials for his/her 
approval. 
Accounting needs the cardholders to list on the monthly statement the 4 digit object class code 
for each item purchased. This information is needed to report to the Office of Management and 
Budget on how the HHS appropriations are spent. 
Closing Accounts: 
From the HHS: 
Since the cards are issued to individual employees, they must be destroyed when the 
cardholder leaves the organization. The contracting officer who delegated authority and 
distributed the cards has the primary responsibility for recovering the cards from terminating 
employees and for following instructions for card termination issued by the contractor (U.S. 
Bank). 
From an agency: 
If cards need to be canceled, the cardholder must turn the card in to the approving official, who 
must notify the administrative officer and return the purchase card (cut in half). 
Card Activity: 
From the HHS: 
The HHS guidelines do not specifically reference this issue, although recent scrutiny of the 
purchase card program has brought attention to the number of open accounts across 
government. 
IMPAC: Review of 2001 Transactions  22  OEI-07-02-00510  Card Limits: 
From the HHS: 
For those cardholders who have not previously exercised procurement authority, the dollar 
limits for card use should be set in relation to the bona fide purchasing needs of the office 
involved, consistent with sound management and oversight.  These limits should be set as 
realistically as possible and the monthly purchase limit . . . should be tied into the budget and 
operating plan. 
From the agencies: 
An email is sent to request that a card be issued to the named cardholder (with the appropriate 
approving officials name, title, and organization), which indicates the monthly and single-
purchase limits desired. The standard single-purchase dollar limit is $2,500. 
Each purchase card is subject to a single-purchase limit, a billing cycle limit, and a billing cycle 
office limit. Neither cardholders nor merchants are allowed to exceed single-purchase limit or 
split the purchase in order to accommodate the purchase card limit. 
When a card is presented for purchase, and the merchant slides it through the electronic 
verification machine (or telephonically requests approval), the limits are compared against the 
proposed purchase and the transaction will not be approved if either limit is exceeded. 
Cardholder and Approving Official Relationships: 
From the HHS: 
The HHS guidelines do not specifically reference this issue. 
Approving Official Span of Control: 
From the HHS: 
The HHS guidelines do not specifically reference this issue, although an official with 
responsibility for the purchase card program noted that it is assumed a supervisor will be the 
approving official for any employees whom he or she supervises, with the result that an 
approving official would not have a larger span of control than a typical supervisor. 
From an agency: 
The recommended ratio of cardholders to approving official is 5 to 1.  Under certain rare and 
extenuating circumstances, up to 10 cardholders per approving official may be 
IMPAC: Review of 2001 Transactions  23  OEI-07-02-00510  allowed. The monthly transaction volume of the cardholder will be taken into consideration. 
Location of Approving Official and Cardholder: 
From the HHS: 
The HHS guidelines do not specifically reference this issue. 
Training: 
From the HHS: 
All cardholders who have not previously held a warrant for procurement authority must be 
provided training by the issuing agency, preferably before the card is issued, but in any case 
within 6 months of issuance.  The training must cover, as a minimum, the following topics: 
	 Required sources of supply, including Federal Prison Industries, blind and handicapped 
workshops, mandatory General Services Administration schedules and printing 
services. 
	 Applicable requirements of the Federal Acquisition Regulation Section 13, including 
small business set asides, thresholds for competition, price reasonableness, and rotation 
of sources. 
	 Allowable and non-allowable purchases, as determined by statute, regulation, and 
Comptroller General decision. 
	 Requirements for payment of monthly statements, such as:  identifying each item 
purchased, indicating object class and fiscal data for each item, and noting credits not 
shown. 
Approving officials should make sure all prospective cardholders fully understand all policies 
and procedures regarding card usage and have signed a statement to this effect before they 
receive a card. 
From the agencies: 
Prospective cardholders and approving officials must attend a training course or review the

U.S. Bank Purchasing Program videotape and complete certifications (as required) prior to

their account set up forms being submitted to U.S. Bank.  The cardholder and approving official

will sign a statement that he/she has been fully trained and understands all policies and

procedures regarding the card usage prior to receiving a card.

IMPAC: Review of 2001 Transactions  24  OEI-07-02-00510  All purchase card users must receive their cards and their authorization to use them from an 
agency contracting officer, via a letter of limited procurement authority. Training is also 
required. 
Safeguarding Cards: 
From the HHS: 
The card is for official use only! The cardholder is responsible for the security of the card and 
can be personally liable for its misuse.  Cardholders should take precautions to prevent others 
from gaining access to their cards and should not give out their card number, since this could 
lead to misuse and personal liability.  It is recommended that cardholders keep their cards 
locked up when not in use. 
From the agencies: 
The cardholder is the only person authorized to use his/her purchase card, is responsible for the 
security of the purchase card, should not give anyone their card number, and can be personally 
liable for its misuse. It is recommended that the card be kept in a locked cabinet when not in 
use. 
Use of IMPAC by a cardholder for a personal purchase and/or a purchase of supplies or 
services which the cardholder had no authority to make, and/or use of the card by a person 
other than the cardholder, is unauthorized. 
No member of the cardholders staff, the cardholders supervisor, or anyone else may use the 
card. 
Splitting Purchases: 
From the HHS: 
The HHS guidelines do not specifically reference this issue, although all agency procedures 
address split purchases. 
From the agencies: 
The cardholder cannot split orders to stay within the dollar limitations. 
The temptation may arise to break up a $2,800 acquisition into one $2,500 purchase and one 
$300 purchase, so that the purchase card may be used.  This proposed action would be wrong 
and not in the best interest of the government. 
IMPAC: Review of 2001 Transactions  25  OEI-07-02-00510    A C K N O W L E D G M E N T S  
This report was prepared under the direction of Brian T. Pattison, Regional Inspector General for 
Evaluation and Inspections in the Kansas City Regional Office. Other principal Office of Evaluation 
and Inspections staff who contributed include: 
Tricia Fields, Project Leader  Elise Stein, Director, 
Mike Craig, Program Analyst  Public Health and Human Services Branch 
Linda L. Hall, Program Specialist 
Barbara R. Tedesco, Mathematical Statistician 
We would like to acknowledge the following OIG staff for their assistance in this project: 
Michael P. Barrett, OEI, Region VII
 Stephanie Lattin, OEI, Headquarters

Erin Bliss, OEI, Region V
 Kevin Lawrence, OEI, Region IV

Diana S. Clark, OEI, Region VII
 Alan S. Levine, OEI, Headquarters

A. Blaine Collins, OEI, Region VI
 William C. Moran, OEI, Region V

Jason Coopey, OI, Region III
 Genevieve Nowolinski, OEI, Headquarters

Carnitta DeVaughn, OEI, Headquarters
 Elander J. Phillips, OEI, Region VII

Tanaz Dutia, OEI, Region III
 Joan Richardson, OEI, Headquarters

Linda A. Frisch, OEI, Headquarters
 Brian P. Ritchie, OEI, Headquarters

Paul A. Gottlober, OEI, Region IX
 Bambi Straw, OEI, Headquarters

Michael Grasso, OI, Region VII
 Dennis J. Tharp, OEI, Region VII

Erin Guay, OEI, Region V
 Joe Townsel, OEI, Region IV

Norman Han, OEI, Region I
 Lisa Vasquez, OEI, Headquarters

Steven Hanson, OI, Region VII
 Brian T. Whitley, OEI, Region VII

Michael Henry, OEI, Region IX
 Steven Zerebecki, OEI, Region IX

Scott Horning, OEI, Headquarters
 Thomas Zimmermann, OEI, Region II

For information or copies of this report, please contact

the Office of Inspector Generals

Public Affairs office at (202) 619-1343.

Reports are also available on the World Wide Web at our home page address:

http://www.oig.hhs.gov/ 
IMPAC: Review of 2001 Transactions  27  OEI-07-02-00510