Testimony of:  
Gary Cantrell 
Deputy Inspector General for Investigations 
Office of Inspector General 
U.S. Department of Health and Human Services 
 
 
 
Hearing: 
Medicare Program Integrity:  Screening Out Errors, Fraud, and 
Abuse 
 
House Committee on Energy and Commerce 
Subcommittee on Oversight and Investigations 
 
June 25, 2014 
2123 Rayburn House Office Building 
10 AM 
 
 
 
 
 
 
 
 
 
 
 
  Testimony of: 
Gary Cantrell 
Deputy Inspector General for Investigations 
Office of Inspector General 
U.S. Department of Health and Human Services 
Hearing Title: Medicare Program Integrity: Screening Out Errors, Fraud, and Abuse 
House Committee on Energy and Commerce 
Subcommittee on Oversight and Investigations 
 
 
Good morning, Mr. Chairman and other distinguished Members of the Subcommittee.  Thank 
you for the opportunity to testify about the U.S. Department of Health and Human Services (the 
Department) Office of Inspector Generals (OIG) efforts to improve Medicare oversight and 
reduce waste, fraud and abuse.  Fighting waste, fraud, and abuse in Medicare and other 
Department programs is a top priority. 
 
We have seen strong results from coordinated Federal and state enforcement efforts across the 
country, including those of the Medicare Fraud Strike Force teams.  Criminal prosecutions and 
monetary recoveries have increased while we have seen a measurable decrease in payments for 
certain health care services targeted by fraud schemes.  Following targeted enforcement and 
other oversight activities, payments for CMHCs nationally decreased from $70 million to under 
$5 million per quarter.1  
 
Coordination between the Strike Force teams and the Centers for Medicare & Medicaid Services 
(CMS) has also contributed to a dramatic decline in payment for home health care in Miami and 
throughout Florida.  After OIG uncovered billing schemes relating to home health outlier 
payments, CMS put into effect a limit on the percentage of outlier payments that each home 
health agency (HHA) can claim.  Since 2010, Medicare payments for home health care 
nationally decreased by more than $300 million per quarter, more than $1 billion annually.2 
 
We have also seen sustained declines in Medicare payments for durable medical equipment 
(DME) and ambulance services in targeted areas following Federal enforcement and oversight 
action.  Total Medicare payments for ambulance services in Houston are down approximately 50 
percent from $32 million to $16 million per quarter since 2010.3  Miami-area DME payments 
have decreased by approximately $100 million annually since launch of the Medicare Fraud 
Strike Force in Miami in 2007.4 
 
These successes are funded through the Health Care Fraud and Abuse Control Program (a joint 
program of the Department, OIG, and the Department of Justice to fight waste, fraud, and abuse 
                                                           
1 See Appendix 1, slide titled Outcomes:  CMHC Payment Trends. 
2 See Appendix 1, slide titled Outcomes:  HHA Payment Trends.  See also Healthcare Fraud and Abuse Control 
Program Annual Report for Fiscal Year 2013, p.13; available at http://oig.hhs.gov/publications/docs/hcfac/FY2013-
hcfac.pdf.   
3 See Appendix 1, slide titled Outcomes: Ambulance Payment Trends. 
4 See Appendix 1, slide titled Outcomes: DME Payment Trends. 
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  in Medicare and Medicaid), which returns more than $8 for every $1 invested.5  However, more 
remains to be done.  In March 2014, OIG issued its Compendium of Priority Recommendations, 
which highlights additional opportunities for cost savings and program and quality 
improvements.6  Implementing these recommendations could result in billions of dollars saved 
and more efficient and effective programs.  My testimony today focuses on a selection of key 
recommendations from the Compendium and other program integrity recommendations 
consistent with OIGs work, provides an overview of current fraud trends, and highlights 
challenges that impede effective oversight of Medicare and Medicaid. 
 
Current Trends in Health Care Fraud 
 
Fraud schemes are constantly evolving.  As enforcement efforts target certain schemes, new 
permutations of those schemes arise.  Not only are fraud schemes mutating, they are migrating  
geographically and even between parts of the Medicare program.  Some of OIGs highest 
priorities and concerns involve the emergence of criminal networks in healthcare fraud, the rise 
in prescription drug abuse and diversion, and the provision of illegitimate home-based care.   
 
Criminal Networks 
 
Over the past several years OIG has seen an increase in organized criminal elements committing 
health care fraud.  This may be attributed to the ease of entry into some sectors of the health care 
industry, the lucrative nature of health care fraud, the belief that it is less violent than other types 
of crime, or a perception of reduced criminal penalties.  Criminal networks have become a 
pervasive problem in DME, home health, outpatient clinics, and pharmacies.  Schemes typically 
involve kickbacks, nominee owners, recruiters, and money laundering.  In one particular Strike 
Force case, an organized criminal network used a fraudulent medical clinic to bill Medicare over 
$77 million for services that were medically unnecessary and never provided.  Co-conspirators 
included clinic owners; a medical director who was rarely on site at the clinic; money laundering 
operatives; and complicit Medicare beneficiaries, who accepted regular cash kickbacks.  Over a 
dozen co-conspirators have been sentenced to an aggregate total of more than 45 years in prison, 
over $50 million in restitution, and millions more in asset forfeiture.  The clinic owner and 
criminal network leader was sentenced to 15 years in prison, excluded from all Federal health 
care programs, and ordered to forfeit over $36 million.  The medical director was sentenced to 
over 12 years in prison and ordered to forfeit more than $500,000.   
 
Federal forfeitures are a valuable tool to help defund and disrupt illegal activities and can serve 
as a powerful fraud deterrent.  However, OIG lacks the authority to execute warrants for seizure 
of property for forfeiture.  We must instead seek assistance from other law enforcement agencies 
in securing and executing relevant warrants  this has resulted in administrative inefficiencies 
                                                           
5 The $8 to $1 return on investment is a 3-year rolling average from fiscal year (FY) 2010-2013.  For more details on 
this and other HCFAC accomplishments, see the FY 2013 Health Care Fraud and Abuse Control Program Report, 
available at http://oig.hhs.gov/reports-and-publications/hcfac/index.asp.  
6 Office of Inspector Generals Compendium of Priority Recommendations, March 2014, available at 
http://oig.hhs.gov/reports-and-publications/compendium/index.asp.  
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  and costly delays.  In one recent case, OIG agents identified an account into which proceeds of 
Medicare fraud were being deposited.  By the time we enlisted another agency to obtain and 
issue seizure warrants, the estimated $1.3 million in the account had been withdrawn.   To ensure 
that the Federal government and taxpayers are made whole for losses due to health care fraud,  it 
is important that Federal law enforcement move immediately after identifying assets that are the 
proceeds or fruits of criminal activity.  Empowering OIG to execute forfeiture warrants would be 
a step in helping ensure this outcome. 
 
Medical identity theft is a prevalent and increasing crime that is closely linked to Medicare fraud 
schemes, especially those involving criminal networks.  Although beneficiaries can be complicit 
in criminal network operations, in one Strike Force case, subjects perpetrated a 100 million 
dollar Medicare fraud scheme that involved stealing the identities of doctors and thousands of 
Medicare beneficiaries for use in phony clinics around the country. 
 
Key OIG recommendations include: 
  Provide OIG with authority to execute Federal warrants for the seizure of assets for 
forfeiture to curb the profitability of healthcare fraud, which will exert a deterrent effect. 
  Remove Social Security numbers (SSN) from Medicare cards to help protect the 
personally identifiable information of Medicare beneficiaries. 
 
Prescription Drug Fraud 
 
Medicare Part D, the prescription drug program, in calendar year 2012 cost $66.9 billion in 
expenditures for 30 million enrolled beneficiaries.  OIG has extensively examined CMSs 
monitoring and oversight of the Part D program and the effectiveness of controls to ensure 
appropriate payment and patient safety.  Our work has found limitations in program safeguards 
that leave Part D vulnerable to improper payments and Medicare patients vulnerable to 
potentially harmful prescribing.  These include extreme outlier provider prescribing patterns and 
questionable billings by numerous retail pharmacies nationwide.7  The prescription fraud 
schemes are complex crimes involving many co-conspirators, including health care 
professionals, patient recruiters, pharmacies, and complicit beneficiaries.  An increasing 
percentage of OIG work involves prescription drug fraud.8  In FY2013 alone, OIG opened 312 
new Part D investigations; this is an 80 percent increase over FY2009. 
 
Overprescribing of controlled substances can lead to patient harm.  Of particular concern are 
cases in which patient deaths occur as a result of prescription drug diversion or doctor 
shopping.  In one example, a physician was arrested for prescribing oxycodone-based products 
to bogus patients who were complicit beneficiaries that received $150 cash per office visit for 
                                                           
7 See, e.g., Medicare Inappropriately Paid for Drugs Ordered by Individuals Without Prescribing Authority, OEI-02-
09-00608, June 2013, available at http://oig.hhs.gov/oei/reports/oei-02-09-00608.asp; Retail Pharmacies With 
Questionable Part D Billing, OEI-02-09-00600, May 2012, available at http://oig.hhs.gov/oei/reports/oei-02-09-
00600.asp; Prescribers With Questionable Patterns In Medicare Part D, OEI-02-09-00603, June 2013, available at 
http://oig.hhs.gov/oei/reports/oei-02-09-00603.asp.    
8 See Spotlight on Drug Diversion, available at http://oig.hhs.gov/newsroom/spotlight/2013/diversion.asp.  
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  their participation in the scheme.  The complicit beneficiaries then used their Medicare, 
Medicaid or private insurance cards and cash to pay for the filled prescriptions at various 
pharmacies and then sold them for $300-$1000 to various drug-trafficking organizations, which 
then resold the drugs on the street.  This scheme resulted in the illegal distribution of more than 
700,000 pills of oxycodone, including one patient death.  The physician was sentenced to 20 
years in prison and forfeited $10 million.  A total of 61 defendants have been sentenced to a 
combined 253 years in prison. 
  
Prescription drug fraud involving non-controlled substances is becoming more common.  The 
billing but not dispensing of non-controlled medications presents a massive financial loss to the 
Medicare program.  Schemes typically involve brand-name, high-cost medications, including 
respiratory, HIV/AIDS, and anti-psychotic medications, along with co-conspirator beneficiaries 
who assist in obtaining the prescriptions in exchange for a kickback.  In one south Florida case, a 
pharmacy was found to be billing but not actually dispensing expensive non-controlled 
medications.  The pharmacy received fake invoices from a wholesaler to cover this shortage.  
OIG special agents infiltrated the wholesale company and arrested the owner.  During the 
investigation it was discovered that the wholesaler had supplied fake invoices to 17 other local 
pharmacies. 
 
Key OIG recommendations include: 
  Strengthen the Medicare contractors monitoring of pharmacies and its ability to identify 
for further review of pharmacies with questionable billing patterns. 
  Require Part D plans to verify that prescribers have the authority to prescribe. 
 
CMS issued a proposed rule that would require all prescribers of Part D drugs to be enrolled in 
the Medicare fee-for-service program (or officially opt out).9  If implemented, this requirement 
could help CMS, Part D plans, and the Medicare program integrity contractor enhance their 
monitoring and better prevent and detect Part D improper payments and potential fraud. 
 
Home-Based Services 
 
Concerns with home-based services include fraud in home health, hospice, and the Personal Care 
Services (PCS) program. 
 
Enforcement efforts, the capping of outlier payments, and imposing moratoria have significantly 
decreased illegal billing for home health services.10  Schemes nonetheless continue to evolve, 
vulnerabilities persist, and home health remains a top oversight priority for OIG.  Home health 
schemes often involve patient recruiters, co-conspirator beneficiaries receiving kickbacks, and 
HHAs billing but providing no care and/or unnecessary services.  In one case, an HHA fraud 
scheme included company owners, health care providers, and patient recruiters conspiring to bill 
Medicare for services that were never rendered and that were for patients who were not 
                                                           
9 Federal Register, Volume 79, Number 7, pages 1982-1987, published January 10, 2014, available at 
http://www.gpo.gov/fdsys/pkg/FR-2014-01-10/pdf/2013-31497.pdf.    
10 See Appendix 1, slide titled Outcomes: HHA Payment Trends. 
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  homebound.  The egregious behavior also included kickbacks to patients that included cash and 
the promise of prescriptions for narcotics.  One of the HHA owners was sentenced to 10 years in 
prison and ordered to pay more than $10 million in restitution with his co-conspirators.  One 
subject is still a fugitive at large.   
 
OIG has also uncovered documentation errors and other vulnerabilities that are of concern in 
home health.  For example, physicians (or certain practitioners working with them) who certify 
beneficiaries as eligible for Medicare home health services must document  as a condition of 
payment for home health services  that face-to-face encounters with those beneficiaries 
occurred.  The face-to-face encounter alone does not satisfy the requirement; the certifying 
physician must also complete documentation that is clearly titled, signed, and dated.  A recent 
OIG review reveals that for 32 percent of home health claims that required face-to-face 
encounters, the documentation did not meet Medicare requirements, resulting in $2 billion in 
payments that should not have been made.11   
 
As of February 29, 2012, 2,004 HHAs still owed CMS a total of approximately $408 million for 
$590 million in overpayments that the agency identified for these HHAs between 2007 and 2011.  
CMS could have recovered at least $39 million between 2007 and 2011 if it had required each 
HHA to obtain a $50,000 surety bond.12  
 
Key OIG recommendations include: 
  Increase monitoring of Medicare claims for home health services. 
  Create a standardized form to ensure better compliance with the face-to-face encounter 
documentation requirements. 
  Implement the surety bond requirement for HHAs.13 
 
Medicares hospice benefit is designed for Part A patients who have been certified as terminally 
ill.   It covers palliative and support services including personal care, medical equipment, 
therapy, and other services.  Fraud in this area includes falsely certifying that patients are eligible 
for hospice services when they are not, and upcoding.  Continuous home care (CHC) is a higher 
level of care meant for patients in crisis.  Hospice fraud schemes involve billing CHC for 
patients who do not need this level of care and do not receive it, even back-dating a deceased 
patients file to include CHC that was never provided.  In one case, a hospice company owner 
billed Medicare over 16 million dollars for patients who were not hospice eligible, and for higher 
level care services than were provided.  Doctors were paid for referrals for ineligible patients 
while nurses and other staff co-conspirators altered patient records to fabricate a decline in 
patient medical conditions.  Sometimes patients receive cash kickbacks and are complicit in 
hospice fraud schemes, while other beneficiaries are unaware that they have been falsely 
                                                           
11 Limited Compliance With Medicare's Home Health Face to Face Documentation Requirements, available at 
http://oig.hhs.gov/oei/reports/oei-01-12-00390.asp.   
12 Surety Bonds Remain an Unused Tool to Protect Medicare from Home Health Overpayments, available at 
http://oig.hhs.gov/oei/reports/oei-03-12-00070.asp.    
13 In January 1998, CMS promulgated a final rule requiring each HHA to obtain a surety bond in the amount of 
$50,000 or 15 percent of the annual amount paid to the HHA by Medicare, whichever is greater.  However, this 
regulation remains unimplemented. 
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  categorized as hospice eligible.  In another case, a hospice company owner conspired with an 
individual who provided names and identifying information of Medicare beneficiaries in 
exchange for cash; the signatures of referring physicians and Medicare beneficiaries were then 
forged on medical documents.  OIG reviews also suggest that Medicares hospice payment 
methodology may lead some hospices to inappropriately seek out beneficiaries in nursing 
facilities.14  
 
Key OIG recommendations include: 
  Monitor hospices that depend heavily on nursing facility residents. 
  Modify the payment system for hospice care in nursing facilities, seeking statutory 
authority if necessary. 
 
The Medicaid Personal Care Services (PCS) program assists the elderly, those with disabilities, 
and those with chronic conditions with health care that they can receive while remaining in their 
homes.  The services are provided by a personal care attendant (PCA).  In 2011 alone, the PCS 
program spent $12.7 billion.  Fraud in this program is increasing and includes schemes where 
PCAs and beneficiaries act as co-conspirators and care isnt needed or isnt provided.  As of the 
first quarter of 2013, the State Medicaid Fraud Control Units had more than 1,000 such 
investigations nationwide.  This fraud is very difficult to detect, often coming to our attention 
through whistleblowers.  In one case, an individual who was on Medicaid disability herself, 
fraudulently signed up as a PCA.  To avoid losing her own Medicaid benefits, the individual first 
misappropriated her daughters name, and then conspired with a neighbor to use his name to 
obtain status as a PCA.  The individual became the PCA to a family friend who was a Medicaid 
beneficiary.  The individual ignored the patients serious medical issues which should have led to 
hospitalization and the patient died from malnutrition and sepsis because of neglect.  The 
individual was sentenced to 4 years of incarceration and the co-conspirator neighbor was 
sentenced to six months in prison. 
 
Key OIG recommendations include: 
  Consider whether additional controls are needed to ensure that the PCS are allowed under 
the program rules and are provided. 
  Take action to provide States with data suitable for identifying overpayments for PCS 
claims when beneficiaries are receiving institutional care being paid for by Medicare or 
Medicaid. 
 
Oversight Challenges 
 
Data challenges and resource constraints pose significant challenges for program integrity 
efforts.   
 
 
 
                                                           
14 Medicare Hospices That Focus on Nursing Facility Residents, available at http://oig.hhs.gov/oei/reports/oei-02-
10-00070.asp.  
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  Technology is Driving Changes in Program Integrity Efforts  
Advances in data analysis and the proliferation of electronic health records (EHR) have changed 
the way OIG detects and investigates health care fraud.  With the proliferation of EHR systems, 
we hope to see an increase in legibility and portability, more accurate billing, and improved 
quality of care.  However, health care fraud itself has become more sophisticated as criminals 
use technology, including EHRs, to facilitate fraud.  This has already been observed in the 
illegitimate use of cut-and-paste record cloning and over-documentation with false and irrelevant 
material to justify upcoding.   
 
Additionally, with the growing use of EHR systems, evidence collection is moving increasingly 
away from paper files to an unprecedented amount of electronic evidence.  As a result, law 
enforcement is developing new investigative techniques to supplement the traditional methods 
used in examining the authenticity and accuracy of records.  We confront additional challenges 
relating to the collection and analysis of unprecedented amounts of electronic evidence.  For 
example, the amount of digital data collected by OIGs Office of Investigations has grown ten-
fold since 2009.  While such advances have the potential to provide OIG and its law enforcement 
partners with more leads to investigate than ever before, the data deluge strains electronic server 
capacity and staff resources.   
  
Additional Safeguards Are Needed to Protect Electronic Health Records 
New digital environments also necessitate new safeguards for patient data.  Yet through a survey 
of hospitals that received EHR incentive payments, OIG learned that not all recommended fraud 
safeguards have been implemented in hospital EHR technology.15  For example, nearly half of 
hospitals indicated they could delete audit logs, and a third of hospitals indicated that they could 
disable their audit logs.  Audit functions, such as audit logs, track access and changes within a 
record chronologically by capturing data elements, such as date, time, and user stamps, for each 
update to an EHR.  An audit log can be used to analyze historical patterns that can identify data 
inconsistencies.  To provide the most benefit in fraud protection, audit logs should always be 
operational while the EHR is being used and be stored as long as clinical records. Users should 
not be able to alter or delete the contents of the audit log.  Deleting or disabling audit logs makes 
it harder to prevent and detect fraud.  Further, most hospitals did not analyze audit logs with the 
intent to try to identify duplicate and fraudulent claims and inflated billing.  In a separate review, 
we discovered that CMS and its contractors had not adjusted their program integrity strategies 
for electronic records versus paper records.16 
 
Key OIG recommendations include: 
  Mandate the use of the audit log feature in all EHRs. 
                                                           
15 Not All Recommended Fraud Safeguards Have Been Implemented in Hospital EHR Technology, available at 
http://oig.hhs.gov/oei/reports/oei-01-11-00570.asp.  
16 CMS and Its Contractors Have Adopted Few Program Integrity Practices To Address Vulnerabilities in EHRs, 
available at http://oig.hhs.gov/oei/reports/oei-01-11-00571.asp.   
7  House Committee on Energy and Commerce 
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    Work with contractors to identify best practices and develop guidance and tools for 
detecting fraud associated with EHRs, with specific guidance to address EHR 
documentation and electronic signatures in EHRs. 
 
Oversight of Medicare and Medicaid is Hampered By Lack of Accurate, Timely, Complete Data 
Data challenges manifest not only with respect to EHRs, but in other parts of Medicare and 
Medicaid.  OIG is combining field intelligence with data mining, predictive analytics, and 
modeling to more efficiently target oversight, support ongoing investigations, and pursue shifts 
in health care fraud patterns.  However, oversight of Medicare Part C (Medicare Advantage, or 
MA) and Medicare Part D is hampered by a lack of accurate, timely, and complete data that 
would facilitate oversight efforts.   For example, MA and Part D plans efforts to identify and 
address potential fraud and abuse are crucial to protecting the integrity of the Parts C and D 
programs.  Since 2008, OIG has repeatedly recommended that CMS require mandatory reporting 
of fraud and abuse data by MA and Part D plans.  CMS has disagreed and therefore does not 
require mandatory reporting of fraud and abuse by these plans.  Under the current voluntary 
reporting system, less than half of Part D plans reported fraud and abuse data to CMS.  Twenty-
eight percent of plans that identified fraud reported initiating no inquiries or corrective actions 
with regard to any of the incidents.17  
 
Further, barriers exist to obtaining Medicare Part C claims data.  CMS contracts with private 
organizations under Part C to provide private health plan managed care options.  There is limited 
data availability and there are difficulties with access to information.  There is no centralized Part 
C data repository, which hinders the ability to identify and investigate Part C fraud.  Also the 
Medicare Drug Integrity Contractor is unable to share specific information with other program 
integrity contractors.   
 
National-level oversight of Medicaid is similarly impeded by the lack of timely, accurate, and 
complete Medicaid data.  OIG has uncovered significant shortcomings in the data available to 
conduct efficient, national Medicaid program integrity oversight through data analysis and data 
mining.  While CMS has taken steps to improve Medicaid data through the Transformed 
Medicaid Statistical Information System, or T-MSIS, our review of early T-MSIS 
implementation outcomes raised questions about the completeness and accuracy of T-MSIS data 
upon national implementation.18   
 
Key OIG recommendations include: 
  Amend regulations to require MA and Part D plans to report to CMS, or its designee, 
their identification of and response to incidents of potential fraud and abuse. 
                                                           
17 Testimony of Robert Vito, Regional Inspector General for Evaluation and Inspections, before House Committee 
on Energy and Commerce, March 4, 2014, available at 
http://oig.hhs.gov/testimony/docs/2014/vito_testimony_03042014.pdf.   
18 Early Outcomes Show Limited Progress for the Transformed Medicaid Statistical Information System, available at 
http://oig.hhs.gov/oei/reports/oei-05-12-00610.asp.  
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    Establish a deadline for when complete, accurate, and timely T-MSIS data will be 
available.   
  
Improvements Are Needed to States Reporting to OIG of Adverse Actions Against Providers 
 
One of the key administrative tools OIG utilizes is the authority to exclude individuals and 
entities from participating in the Federal health care programs.  Like debarment in government 
procurement, the effect of an exclusion is that the excluded individual or entity cannot submit 
claims for services provided to Federal health care program beneficiaries.  OIG receives 
important information from State licensing boards notices of adverse actions, which enable us to 
identify numerous individuals who are subject to exclusion.  However, we do not receive reports 
of all adverse actions from all States.  State licensing boards are not statutorily required to refer 
adverse actions against providers to OIG.  We currently receive this information on a voluntary 
basis from the State boards, general public notices of board actions in various States, or working 
relationships developed by OIG exclusions analysts with staff from various other agencies and 
organizations.  Furthermore, the manner and timing of the notices is entirely dependent on each 
State licensing board.  More reliable and standardized reporting from States would improve 
OIGs ability to exclude problematic providers. 
 
Key OIG recommendations include: 
  Explore requirements to increase and standardize State licensure boards reporting of 
adverse actions to OIG.   
 
Conclusion 
 
OIG is responsible for oversight of about 25 cents of every Federal dollar.  Our oversight 
priorities extend not only to safeguarding Federal dollars but also to quality of care consequences 
for the programs and patients.  As noted throughout my testimony, health care fraud is not just 
about dollars lost  health care fraud can also put patients health at risk.  Unfortunately OIGs 
mission is challenged by declining resources for Medicare and Medicaid oversight at a time 
when these programs and our responsibilities are growing.  Since 2012, we have closed over 
2,200 investigative complaints because of lack of resources.  We expect to reduce our Medicare 
and Medicaid oversight by about 20 percent by the end of this FY.  Yet the Department 
estimated that Medicare and Medicaid outlays would grow by about 20 percent from 2012 to 
2014.  Full funding of our 2015 budget request would enable us to provide more robust oversight 
and advance solutions to protect the Medicare and Medicaid programs, beneficiaries, and 
taxpayers. 
 
Thank you for your interest and support and for the opportunity to discuss some of our work.  I 
am happy to answer any questions you may have. 
 
 
 
 
9  House Committee on Energy and Commerce 
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  APPENDIX I 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
1  House Committee on Energy and Commerce 
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2  House Committee on Energy and Commerce 
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