prompt_front: You are given two reports by the government agency.



Question: Write a one-page summary of the report 1.



Report 2: As reported by the United Nations, the International Criminal Police Organization, and other organizations, wildlife trafficking networks span the globe  These organizations have attempted to measure the value of illegally traded wildlife, but available estimates are subject to uncertainty  In 2016, for example, the United Nations Environment Programme (UNEP) reported that various sources estimated the global scale of illegal wildlife trade to be from $7 billion to $23 billion annually  UNEP also estimated that the scale of wildlife crime has increased in recent years in part based on a rise in environmental crime  U S  trade in wildlife and related products includes a variety of species, such as live reptiles, birds, and mammals, as well as elephant ivory, according to law enforcement reports and government and nongovernmental officials  FWS and NOAA data on wildlife products seized at U S  ports provide examples of the diversity of illegally traded plants, fish, and wildlife imported into or exported from the United States  For example, from 2007 to 2016, the top 10 plant, fish, and wildlife shipments seized nationally by FWS were coral, crocodiles, conchs, deer, pythons, sea turtles, mollusks, ginseng, clams, and seahorses  During that time, FWS reported that more than one-third of the wildlife shipments it seized were confiscated while being imported from or exported to Mexico (14 percent), China (13 percent), or Canada (9 percent)  FWS and NOAA law enforcement offices are responsible for enforcing certain laws and treaties prohibiting wildlife trafficking  FWS Office of Law Enforcement  This office enforces certain U S  laws and regulations as well as treaties prohibiting the trafficking of terrestrial wildlife, freshwater species, and birds  Among other things, the office aims to prevent the unlawful import, export, and interstate commerce of foreign fish and wildlife, as well as to protect U S  plants, fish, and wildlife from unlawful exploitation  As of fiscal year 2016, the office had a budget of $74 7 million and employed 205 special agents to investigate wildlife crime, including international and domestic wildlife trafficking rings  Most of these special agents report to one of eight regional offices, which receive national oversight, support, training, and policy guidance from the FWS Office of Law Enforcement headquarters  The office’s headquarters houses a special investigative unit focused on conducting complex, large- scale criminal investigations of wildlife traffickers  In addition, the FWS Office of Law Enforcement has deployed special agents to serve as international attachés at seven U S  embassies  These attachés provide countertrafficking expertise to embassy staff, work with host government officials to build law enforcement capacity, and contribute directly to casework or criminal investigations of wildlife traffickers  According to FWS data, the FWS Office of Law Enforcement opened more than 7,000 investigations on wildlife trafficking and other illegal activities in fiscal year 2016, including nearly 5,000 cases involving Endangered Species Act violations and nearly 1,500 cases involving Lacey Act violations  FWS Office of Law Enforcement investigations have disrupted wildlife trafficking operations  For example, Operation Crash—an ongoing rhino horn and elephant ivory-trafficking investigation launched in 2011—has led to over 30 convictions and more than $2 million in fines  NOAA Office of Law Enforcement  This office enforces certain U S  laws and regulations as well as treaties prohibiting the trafficking of marine wildlife, including fish, as well as anadromous fish  Among other things, the office aims to prevent the illegal, unregulated, and unreported harvesting and trade of fish as well as the trafficking of protected marine wildlife  As of fiscal year 2016, the office had a budget of $68 6 million and employed 77 special agents to investigate wildlife crimes within its jurisdiction  These agents report to one of five regional offices, and those offices receive national oversight, support, and policy guidance from the NOAA Office of Law Enforcement headquarters  According to NOAA data, the NOAA Office of Law Enforcement initiated more than 5,000 investigations in fiscal year 2016  About half of those investigations involved violations of the Magnuson-Stevens Fishery Conservation and Management Act, as amended, and some of the 5,000 investigations involved violations of the Endangered Species Act or the Lacey Act  NOAA Office of Law Enforcement investigations have disrupted wildlife trafficking operations  For example, in fiscal year 2016, a NOAA Office of Law Enforcement investigation led to the conviction of a company and five individuals for illegally trafficking whale bone carvings, walrus ivory carvings, black coral carvings, and other products derived from protected species into the United States  The FWS and NOAA law enforcement offices collaborate with other government agencies and organizations to combat wildlife trafficking  Both agencies work with other federal, state, and tribal law enforcement officers as well as their international counterparts as needed during wildlife trafficking investigations  For example, FWS and NOAA work with U S  Customs and Border Protection, U S  Immigration and Customs Enforcement, and the U S  Department of Agriculture to maintain import and export controls and interdict smuggled wildlife and related products at U S  ports of entry  In addition, FWS and NOAA collaborate with Department of Justice prosecutors on criminal cases that result from agency investigations  Both agencies also collaborate with nongovernmental organizations to combat wildlife trafficking  For example, FWS and NOAA officials said that nongovernmental organizations have, in some cases, offered financial rewards (in addition to rewards offered by FWS and NOAA) for information on a wildlife crime  In addition, some nongovernmental organizations proactively provide information to FWS and NOAA on wildlife trafficking activities in the United States or foreign countries that violate U S  laws  For example, in 2017, a nongovernmental organization created a website to collect tips on wildlife crime and to connect the sources of those tips with relevant U S  authorities for potential financial rewards  FWS may pay financial rewards from moneys in two accounts  Law Enforcement Reward Account  FWS may pay rewards under the Endangered Species Act, the Lacey Act, and the Rhinoceros and Tiger Conservation Act from moneys in the agency’s Law Enforcement Reward Account  The moneys in this account come from fines, penalties, and proceeds from forfeited property for violations of these three laws  According to FWS officials, these moneys are available until expended  These moneys can be used to (1) pay financial rewards to those who provide information that leads to an arrest, criminal conviction, civil penalty assessment, or forfeiture of property for any violation of the Endangered Species Act, the Lacey Act, or the Rhinoceros and Tiger Conservation Act or (2) provide temporary care for plants, fish, or wildlife that are the subject of a civil or criminal proceeding under the Endangered Species Act, Lacey Act, or the Rhinoceros and Tiger Conservation Act  As of the beginning of fiscal year 2017, the balance of the Law Enforcement Reward Account was about $7 million  Law Enforcement Special Funds Account  FWS may also pay rewards from moneys in its law enforcement office’s Special Funds Account  The moneys in this account come from an annual line item appropriation and are available until expended  Since fiscal year 1988, this appropriation has provided FWS up to $400,000 each year to pay for information, rewards, or evidence concerning violations of laws FWS administers, as well as miscellaneous and emergency expenses of enforcement activity that the Secretary of the Interior authorized or approved  NOAA generally pays rewards from moneys available in the Fisheries Enforcement Asset Forfeiture Fund  The moneys in this account come from fines, penalties, and proceeds from forfeited property for violations of marine resource laws that NOAA enforces, including the Magnuson- Stevens Fishery Conservation and Management Act, the Endangered Species Act, and the Lacey Act  According to NOAA officials, moneys are available until expended and can be used to pay certain enforcement- related expenses, including travel expenses, equipment purchases, and the payment of financial rewards  As of the beginning of fiscal year 2017, the Fisheries Enforcement Asset Forfeiture Fund had a balance of about $18 million  Academic literature on the use of financial rewards to combat illegal activities and stakeholders we interviewed identified several advantages and disadvantages of using financial rewards to obtain information on wildlife trafficking  Potential advantages of using financial rewards include the following: Providing incentives  The potential for a financial reward can motivate people with information to come forward when they otherwise might not do so  Increasing public awareness  Financial rewards may bring greater public attention to the problem of wildlife trafficking, including federal efforts to combat wildlife trafficking  Saving resources  Using financial rewards may save agency resources by enabling agents to get information sooner and at a lower cost than they could have through their own efforts  Potential disadvantages of using financial rewards include the following: Eliciting false or unproductive leads  Financial rewards may generate false or unproductive leads  Affecting witness credibility  Financial rewards may lead to a source’s credibility being challenged at trial by defense attorneys since sources receive compensation for the information they provide  Consuming resources  The potential for a financial reward may create a flood of tips that take agency time and resources to follow up on or corroborate  Outside of wildlife trafficking, multiple federal agencies and federal courts are authorized to pay financial rewards for information on illegal activities under certain circumstances  For example, U S  Customs and Border Protection—which controls, regulates, and facilitates the import and export of goods through U S  ports of entry—is authorized, under certain circumstances, to pay rewards for original information about violations of any laws that it enforces  The Department of State may also pay rewards under certain circumstances, including for information leading to the disruption of financial mechanisms of a transnational criminal group  Similarly, the U S  Securities and Exchange Commission (SEC) and Internal Revenue Service (IRS) may pay rewards for information about violations of federal securities laws and the underpayment of taxes, respectively, if certain conditions are met  Federal judges may award money to persons who give information leading to convictions for violating treaties, laws, and regulations that prohibit certain pollution from ships, including oil and garbage discharges  FWS and NOAA officials identified multiple laws, such as the Endangered Species Act and the Lacey Act, that authorize the payment of financial rewards to people who provide information on wildlife trafficking  FWS and NOAA reported paying few financial rewards under these laws from fiscal years 2007 through 2017  However, agency officials could not provide sufficient assurance that the reward information they provided to us represented all of their reward payments for this period  FWS and NOAA officials identified over 10 laws prohibiting wildlife trafficking—including the Endangered Species Act, Lacey Act, and Bald and Golden Eagle Protection Act—that specifically authorize the payment of financial rewards in certain circumstances to people who provide information on violations of the law (see app  II for a complete list of the laws)  These laws provide discretion to the agencies to choose whether to pay rewards but have varying requirements for who is eligible to receive a reward and the payment amounts  For example, the Bald and Golden Eagle Protection Act caps rewards at $2,500 for information that leads to a conviction  In contrast, the Endangered Species Act does not cap reward amounts and authorizes rewards for information that leads to a conviction as well as to an arrest, civil penalty, or forfeiture of property  Table 1 identifies the laws that FWS and NOAA officials indicated they have used to pay financial rewards for information on wildlife trafficking from fiscal years 2007 through 2017, along with information on these laws’ requirements for payment of rewards  FWS and NOAA reported paying few financial rewards for information on wildlife trafficking from fiscal years 2007 through 2017, but agency officials could not provide sufficient assurance that this information was complete  Officials from both agencies said that their agencies have not prioritized the use of rewards, and they believed that the reward information they identified—such as the number, dollar amount, and year that rewards were paid—appropriately captured the few reward payments they made during this time frame  Based on the agencies’ reviews of their records, FWS reported paying 25 rewards for a total of $184,500 from fiscal years 2007 through 2017, and NOAA reported paying 2 rewards for a total of $21,000 during that same period (see table 2)  See appendix III for additional details on the cases where financial rewards were paid  FWS reported paying rewards in trafficking cases involving a variety of wildlife species, such as eagles, bears, reptiles, and mollusks, across the 11-year period  FWS officials said they generally paid rewards to thank sources who proactively provided information  For example, based on our review of a reward case, FWS paid a reward in 2010 because the source provided information that was crucial in uncovering an attempt to illegally traffic leopards into the United States from South Africa  FWS would not have known about this illegal activity if the source had not come forward with the information  In several cases we reviewed, FWS officials said that the sources did not know about the possibility of receiving a reward when they contacted the agency with information  The two rewards NOAA reported paying from fiscal years 2007 through 2017 involved the illegal trafficking of sea scallops and a green sea turtle  NOAA officials said that in both cases they paid a reward to thank the source who proactively provided information to law enforcement agents  For example, the agent who investigated the sea scallop case reported requesting the reward because the information the source proactively provided was timely, credible, and led to the criminal conviction of several individuals  FWS and NOAA officials could not provide sufficient assurance that the reward information they reported to us represented all of the rewards their agencies had paid from fiscal years 2007 through 2017, but they said the information was complete to the best of their knowledge  Specifically, FWS and NOAA officials said they track all their expenditures, including reward payments, in their financial databases  However, they are not able to readily identify reward payments because their financial systems do not include a unique identifier for such payments and their reward information is located in multiple databases and formats  As a result, FWS and NOAA officials said they identified the rewards they reported to us by manually reviewing their financial and law enforcement records  In particular, FWS officials said they reviewed their paper records to identify instances when the agency paid rewards and then retrieved additional information from their financial and law enforcement databases, such as final payment amounts  NOAA officials said they identified instances when the agency paid rewards by using a combination of paper and electronic records located at NOAA’s headquarters office  NOAA officials also contacted their regions to obtain additional information located at the regional offices to confirm information about the rewards NOAA had paid  Seventeen stakeholders we interviewed who had experience investigating wildlife trafficking or expertise in using financial rewards as a law enforcement tool said that it would be useful for FWS and NOAA to maintain comprehensive information on the rewards they paid  For example, two stakeholders said that maintaining comprehensive information and making that information available to law enforcement agents could motivate agents to make greater use of rewards as a law enforcement tool  Two other stakeholders said that maintaining information on and monitoring reward use would allow the agencies to make ongoing adjustments, such as adjusting payment amounts, to make the most effective use of rewards in combating wildlife trafficking  Federal internal control standards say that management should clearly document internal control and all transactions and other significant events in a manner that allows the documentation to be readily available for examination  Control activities can be implemented in either an automated or a manual manner, but automated control activities tend to be more reliable because they are less susceptible to human error and are typically more efficient  FWS and NOAA officials agreed that maintaining reward information so that complete information is easily retrievable may be beneficial  FWS officials said having clearly documented and readily available reward information could improve how they manage rewards and enable them to monitor and examine their use of rewards more holistically  The officials said they may analyze options for creating a single repository for reward information but did not commit to doing so  They said that creating a single repository for reward information may involve some drawbacks, such as duplicating some data entry in separate databases  Similarly, NOAA officials said having clearly documented and readily available reward information would provide agency management with easier and more consistent access to that information  As a result, they said that they are exploring modifications to their financial and law enforcement databases to better identify and track rewards  For example, NOAA officials said they may be able to create a unique identifier to flag payments that are for rewards in their financial system to enable them to identify payment amounts more easily  NOAA officials did not provide a time frame for completing modifications to their financial system  By tracking reward information so that it is clearly documented and readily available for examination, FWS and NOAA can better ensure that they have complete information on the rewards they have paid to help manage their use of rewards as a law enforcement tool  FWS and NOAA have policies to guide their law enforcement agents on the process for preparing and submitting a request to pay a financial reward  Specifically, both agencies’ policies call for agents to include a description of the case, the nature of the information that the source provided, a justification for providing a reward, and an explanation of how a proposed reward amount was developed  These policies also outline the general review and approval process, how payments are to be made upon approval of a request, and eligibility criteria to receive a reward  For example, FWS and NOAA policies prohibit paying rewards to foreign government officials as well as paying rewards to any person whose receipt of a reward would create a conflict of interest or the appearance of impropriety  NOAA’s policy explicitly states that the NOAA Office of Law Enforcement is to use statutorily authorized rewards as a tool to obtain information from the public on resource violations and that rewards can help promote compliance with marine resource laws  NOAA’s policy suggests that agents consider advertising reward offers to assist investigations, encourages press releases, and describes the process agents should follow to do so  Moreover, NOAA’s policy specifies factors that agents might include in their reward requests to support the proposed reward, such as (1) the benefit to the marine resources that was furthered by the information provided; (2) the risk, if any, the individual took in collecting and providing the information; (3) the probability that the investigation would have been successfully concluded without the information provided; and (4) the relationship between any fines or other collections and the information provided  FWS’s policy specifies that rewards may be provided in situations in which an individual furnishes essential information leading to an arrest, conviction, civil penalty, or forfeiture of property  However, it does not discuss the usefulness of financial rewards as a law enforcement tool or the types of circumstances when rewards should be used or advertised to the public  Further, FWS’s policy does not communicate necessary quality information internally that agents may need when deciding to request the payment of rewards  In particular, it does not specify factors for agents to consider when developing proposed reward amounts  Instead, the policy leaves it to the discretion of field and regional agents to develop proposed reward amounts within any limitations specified in law  Some FWS agents we interviewed said that they developed proposed reward amounts on a case-by-case basis and did not know whether their proposed amounts were enough, too little, or too much  In addition, some agents said that because FWS’s policy does not specify factors for agents to consider, the reward approval process is subjective and unclear and this has made it challenging for the agents to develop proposed reward amounts  For example, one agent we interviewed said he submitted a request to his supervisor to pay a $10,000 reward to a source who provided information on a major wildlife trafficker  But, for reasons unknown to the agent, his supervisor reduced the amount to $1,000  FWS headquarters officials said field agents submit reward requests to headquarters for approval, and these officials were not aware of instances of proposed reward amounts being changed or denied during the review process  Seven of the 20 stakeholders we interviewed suggested that FWS augment its reward policy to specify factors for agents to consider when developing proposed reward amounts
Report 2:  We also estimated that, given the additional time needed to do compliance inspections, the CFATS program would likely be implemented in 8 to 10 years  We did not make any recommendations for DHS to improve its procedures for reviewing facilities’ security plans because DHS officials reported that they were exploring ways to expedite the process, such as reprioritizing resources and streamlining inspection requirements  In July 2015, we reported that DHS had made substantial progress in addressing the backlog—estimating that it could take between 9 and 12 months for DHS to review and approve security plans for the approximately 900 remaining facilities  DHS officials attributed the increased approval rate to efficiencies in DHS’s review process, updated guidance, and a new case management system  Subsequently, DHS reported in its December 2016 semi-annual report to Congress that it had eliminated its approval backlog  Finally, we found in our 2017review that DHS also took action to implement an Expedited Approval Program (EAP)  The CFATS Act of 2014 required that DHS create the EAP as another option that tier 3 and tier 4 chemical facilities may use to develop and submit security plans to DHS  Under the program, facilities may develop a security plan based on specific standards published by DHS (as opposed to the more flexible performance standards using the standard, non-expedited process)  DHS issued guidance intended to help facilities prepare and submit their EAP security plans to DHS, which includes an example that identifies prescriptive security measures that facilities are to have in place  According to committee report language, the EAP was expected to reduce the regulatory burden on smaller chemical companies, which may lack the compliance infrastructure and the resources of large chemical facilities, and help DHS to process security plans more quickly  If a tier 3 or 4 facility chooses to use the expedited option, DHS is to review the plan to determine if it is facially deficient, pursuant to the reporting requirements of the CFATS Act of 2014  If DHS approves the EAP site security plan, it is to subsequently conduct a compliance inspection  In 2017, we found that DHS had implemented the EAP and had reported to Congress on the program, as required by the CFATS Act of 2014  In addition, as of June 2018 according to DHS officials, only 18 of the 3,152 facilities eligible to use the EAP opted to use it  DHS officials we interviewed attributed the low participation to several possible factors including: DHS had implemented the expedited program after most eligible facilities already submitted standard (non-expedited) security plans to DHS; facilities may consider the expedited program’s security measures to be too strict and prescriptive, not providing facilities the flexibility of the standard process; and the lack of an authorization inspection may discourage some facilities from using the expedited program because this inspection provides useful information about a facility’s security  We also found in 2017 that recent changes made to the CFATS program could affect the future use of the expedited program  As discussed previously, DHS has revised its methodology for determining the level of each facility’s security risk, which could affect a facility’s eligibility to participate in the EAP  DHS continues to apply the revised methodology to facilities regulated under the CFATS program and but it is too early to assess the impact on participation in the EAP  In our July 2015 report, we found that DHS began conducting compliance inspections in September 2013, and by April 2015, had conducted inspections of 83 of the 1,727 facilities that had approved security plans  Our analysis showed that nearly half of the facilities were not fully compliant with their approved site security plans and that DHS had not used its authority to issue penalties because DHS officials found it more productive to work with facilities to bring them in compliance  We also found that DHS did not have documented processes and procedures for managing the compliance of facilities that had not implemented planned measures by the deadlines outlined in the plans  We recommended that DHS document processes and procedures for managing compliance to provide more reasonable assurance that facilities implement planned measures and address security gaps  DHS agreed and has taken steps toward implementing this recommendation  DHS updated its CFATS Enforcement Standard Operating Procedure (SOP) and has made progress on the new CFATS Inspections SOP  Once completed these two documents collectively are expected to formally document the processes and procedures currently being used to track noncompliant facilities and ensure they implement planned measures as outlined in their approved site security plans, according to ISCD officials  DHS officials stated they expect to finalize these procedures by the end of fiscal year 2018  We are examining compliance inspections as part of our ongoing work and will report on the results of our work in our report later this summer  In April 2013, we reported that DHS took various actions to work with facility owners and operators, including increasing the number of visits to facilities to discuss enhancing security plans, but that some trade associations had mixed views on the effectiveness of DHS’s outreach  We found that DHS solicited informal feedback from facility owners and operators in its efforts to communicate and work with them, but did not have an approach for obtaining systematic feedback on its outreach activities  We recommended that DHS take action to solicit and document feedback on facility outreach consistent with DHS efforts to develop a strategic communication plan  DHS agreed and implemented this recommendation by developing a questionnaire to solicit feedback on outreach with industry stakeholders and began using the questionnaire in October 2016  Chairman Shimkus, Ranking Member Tonko, and Members of the Subcommittee, this completes my prepared statement  I would be pleased to respond to any questions that you may have at this time  If you or your staff members have any questions about this testimony, please contact me at (404) 679-1875 or curriec@gao gov  Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this statement  Other individuals making key contributions to this work include John Mortin, Assistant Director; and Brandon Jones, Analyst-in-Charge; Michael Lennington, Ben Emmel, and Hugh Paquette  This is a work of the U S  government and is not subject to copyright protection in the United States  The published product may be reproduced and distributed in its entirety without further permission from GAO  However, because this work may contain copyrighted images or other material, permission from the copyright holder may be necessary if you wish to reproduce this material separately 

ground_truth: Article II, Section 2, of the Constitution provides that the President shall appoint officers of the United States "by and with the Advice and Consent of the Senate." This report describes the process by which the Senate provides advice and consent on presidential nominations, including receipt and referral of nominations, committee practices, and floor procedure. Committees play the central role in the process through investigations and hearings. Senate Rule XXXI provides that nominations shall be referred to appropriate committees "unless otherwise ordered." Most nominations are referred, although a Senate standing order provides that some "privileged" nominations to specified positions will not be referred unless requested by a Senator. The Senate rule concerning committee jurisdictions (Rule XXV) broadly defines issue areas for committees, and the same jurisdictional statements generally apply to nominations as well as legislation. A committee often gathers information about a nominee either before or instead of a formal hearing. A committee considering a nomination has four options. It can report the nomination to the Senate favorably, unfavorably, or without recommendation, or it can choose to take no action. It is more common for a committee to take no action on a nomination than to reject a nominee outright. The Senate handles executive business, which includes both nominations and treaties, separately from its legislative business. All nominations reported from committee are listed on the Executive Calendar, a separate document from the Calendar of Business, which lists pending bills and resolutions. Generally speaking, the majority leader schedules floor consideration of nominations on the Calendar. Nominations are considered in "executive session," a parliamentary form of the Senate in session that has its own journal and, to some extent, its own rules of procedure. The Senate can call up a nomination expeditiously, because a motion to enter executive session to consider a specific nomination on the Calendar is not debatable. This motion requires a majority of Senators present and voting, a quorum being present, for approval. After a nomination has been called up, the question before the Senate is "will the Senate advise and consent to this nomination?" A majority of Senators voting is required to approve a nomination. However, Senate rules place no limit on how long a nomination may be debated, and ending consideration could require invoking cloture. On April 6, 2017, the Senate reinterpreted Rule XXII in order to allow cloture to be invoked on nominations to the Supreme Court by a majority of Senators voting. This expanded the results of similar actions taken by the Senate in November 2013, which changed the cloture vote requirement to a majority for nominations other than to the Supreme Court. After the 2013 decision, the number of nominations subjected to a cloture process increased. On April 3, 2019, the Senate reinterpreted Rule XXII again. The Senate reduced, from 30 hours to 2 hours, the maximum time nominations can be considered after cloture has been invoked. This change applied to all executive branch nominations except to high-level positions such as heads of departments, and it applied to all judicial nominations except to the Supreme Court and the U.S. Circuit Court of Appeals. The full impact of this change is difficult to assess at this time, but it is likely to shorten the time between a cloture vote and a vote on the nomination. If Senators respond as they did to the last reinterpretation of the cloture rule, it might also increase the number of nominations subjected to a cloture process. Nominations that are pending when the Senate adjourns sine die at the end of a session or recesses for more than 30 days are returned to the President unless the Senate, by unanimous consent, waives the rule requiring their return (Senate Rule XXXI, clause 6). If a nomination is returned, and the President still desires Senate consideration, he must submit a new nomination.

prompt_front: You are given two reports by the government agency.



Question: Write a one-page summary of the report 2.

Report 1: Article II, Section 2, of the Constitution provides that the President shall appoint officers of the United States "by and with the Advice and Consent of the Senate " The method by which the Senate provides advice and consent on presidential nominations, referred to broadly as the confirmation process, serves several purposes  First, largely through committee investigations and hearings, the confirmation process allows the Senate to examine the qualifications of nominees and any potential conflicts of interest  Second, Senators can influence policy through the confirmation process, either by rejecting nominees or by extracting promises from nominees before granting consent  Also, the Senate sometimes has delayed the confirmation process in order to increase its influence with the executive branch on unrelated matters  Senate confirmation is required for several categories of government officials  Military appointments and promotions make up the majority of nominations, approximately 65,000 per two-year Congress, and most are confirmed routinely  Each Congress, the Senate also considers approximately 2,000 civilian nominations, and, again, many of them, such as appointments to or promotions in the Foreign Service, are routine  Civilian nominations considered by the Senate also include federal judges and specified officers in executive departments, independent agencies, and regulatory boards and commissions  Many presidential appointees are confirmed routinely by the Senate  With tens of thousands of nominations each Congress, the Senate cannot possibly consider them all in detail  A regularized process facilitates quick action on thousands of government positions  The Senate may approve en bloc hundreds of nominations at a time, especially military appointments and promotions  The process also allows for close scrutiny of candidates when necessary  Each year, a few hundred nominees to high-level positions are regularly subject to Senate investigations and public hearings  Most of these are routinely approved, while a small number of nominations are disputed and receive more attention from the media and Congress  Judicial nominations, particularly Supreme Court appointees, are generally subject to greater scrutiny than nominations to executive posts, partly because judges may serve for life  Among the executive branch positions, nominees for policymaking positions are more likely to be examined closely, and are slightly less likely to be confirmed, than nominees for non-policy positions  There are several reasons that the Senate confirms a high percentage of nominations  Most nominations and promotions are not to policymaking positions and are of less interest to the Senate  In addition, some sentiment exists in the Senate that the selection of persons to fill executive branch positions is largely a presidential prerogative  Historically, the President has been granted wide latitude in the selection of his Cabinet and other high-ranking executive branch officials  Another important reason for the high percentage of confirmations is that Senators are often involved in the nomination stage  The President would prefer a smooth and fast confirmation process, so he may decide to consult with Senators prior to choosing a nominee  Senators most likely to be consulted, typically by White House congressional relations staff, are Senators from a nominee's home state, leaders of the committee of jurisdiction, and leaders of the President's party in the Senate  Senators of the President's party are sometimes invited to express opinions or even propose candidates for federal appointments in their own states  There is a long-standing custom of "senatorial courtesy," whereby the Senate will sometimes decline to proceed on a nomination if a home-state Senator expresses opposition  Positions subject to senatorial courtesy include U S  attorneys, U S  marshals, and U S  district judges  Over the past decade, Senators have expressed concerns over various aspects of the confirmation process, including the rate of confirmation for high-ranking executive branch positions and judgeships, as well as the speed of Senate action on routine nominations  When the Senate is controlled by the party of the President, this concern has often been raised as a complaint that minority party Senators are disputing a higher number of nominations, and have increasingly used their leverage under Senate proceedings to delay or even block their consideration  These concerns have led the Senate to make several changes to the confirmation process since 2011  The changes are taken into account in the following description of the process and are described in detail in other CRS Reports  The President customarily sends nomination messages to the Senate in writing  Once received, nominations are numbered by the executive clerk and read on the floor  The clerk actually assigns numbers to the presidential messages, not to individual nominations, so a message listing several nominations would receive a single number  Except by unanimous consent, the Senate cannot vote on nominations the day they are received, and most are referred immediately to committees  Senate Rule XXXI provides that nominations shall be referred to appropriate committees "unless otherwise ordered " A standing order of the Senate provides that some nominations to specified positions will not be referred unless a Senator requests referral  Instead of being immediately referred, the nominations are instead listed in a special section of the Executive Calendar , a document distributed daily to congressional offices and available online  This section of the Calendar is titled "Privileged Nominations " After the chair of the committee with jurisdiction over a nomination has notified the executive clerk that biographical and financial information on the nominee has been received, this is indicated in the Calendar  After 10 days, the nomination is moved from the "Privileged Nominations" section of the Calendar and placed on the "Nominations" section with the same status as a nomination that had been reported by a committee  (See " Executive Calendar " below ) Importantly, at any time that the nomination is listed in the new section of the Executive Calendar , any Senator can request that a nomination be referred, and it is then sent to the appropriate committee of jurisdiction  Formally the presiding officer, but administratively the executive clerk's office, refers the nominations to committees according to the Senate's rules and precedents  The Senate rule concerning committee jurisdictions (Rule XXV) broadly defines issue areas for committees, and the same jurisdictional statements generally apply to nominations as well as legislation  An executive department nomination can be expected to be referred to the committee with jurisdiction over legislation concerning that department or to the committee that handled the legislation creating the position  Judicial branch nominations, including judges, U S  attorneys, and U S  marshals, are under the jurisdiction of the Judiciary Committee  In some instances, the committee of jurisdiction for a nomination has been set in statute  The number of nominations referred to various committees differs considerably  The Committee on Armed Services, which handles all military appointments and promotions, receives the most  The two other committees with major confirmation responsibilities are the Committee on the Judiciary, with its jurisdiction over nominations in the judicial branch, and the Committee on Foreign Relations, which considers ambassadorial and other diplomatic appointments  Occasionally, nominations are referred to more than one committee, either jointly or sequentially  A joint referral might occur when the jurisdictional claim of two committees is essentially equal  In such cases, both committees must report on the nomination before the whole Senate can act on it, unless the Senate discharges one or both committees  If two committees have unequal jurisdictional claims, then the nomination is more likely to be sequentially referred  In this case, the first committee must report the nomination before it is sequentially referred to the second committee  The second referral often is subject to a requirement that the committee report within a certain number of days  Typically, nominations are jointly or sequentially referred by unanimous consent  Sometimes the unanimous consent agreement applies to all future nominations to a position or category of positions  Most Senate committees that consider nominations have written rules concerning the process  Although committee rules vary, most contain standards concerning information to be gathered from a nominee  Many committees expect a biographical resumé and some kind of financial statement listing assets and liabilities  Some specify the terms under which financial statements will or will not be made public  Committee rules also frequently contain timetables outlining the minimum layover required between committee actions  A common timing provision is a requirement that nominations be held for one or two weeks before the committee proceeds to a hearing or a vote, permitting Senators time to review a nomination before committee consideration  Other committee rules specifically mandate a delay between steps of the process, such as the receipt of pre-hearing information and the date of the hearing, or the distribution of hearing transcripts and the committee vote on the nomination  Some of the written rules also contain provisions for the rules to be waived by majority vote, by unanimous consent, or by the chair and the ranking minority Member  Committees often gather and review information about a nominee either before or instead of a formal hearing  Because the executive branch acts first in selecting a nominee, congressional committees are sometimes able to rely partially on any field investigations and reports conducted by the Federal Bureau of Investigation (FBI)  Records of FBI investigations are provided only to the White House, although a report or a summary of a report may be shared, with the President's authorization, with Senators on the relevant committee  The practices of the committees with regard to FBI materials vary  Some rarely if ever request them  On other committees, the chair and ranking Member review any FBI report or summary, but on some committees these materials are available to any Senator upon request  Committee staff usually do not review FBI materials  Almost all nominees are also asked by the Office of the Counsel to the President to complete an "Executive Personnel Financial Disclosure Report, SF-278," which is reviewed and certified by the relevant agency as well as the Director of the Office of Government Ethics  The documents are then forwarded to the relevant committee, along with opinion letters from ethics officers in the relevant agency and the director of the Office of Government Ethics  In contrast to FBI reports, financial disclosure forms are made public  All committees review financial disclosure reports and some make them available in committee offices to Members, staff, and the public  To varying degrees, committees also conduct their own information-gathering exercises  Some committees, after reviewing responses to their standard questionnaire, might ask a nominee to complete a second questionnaire  Committees frequently require that written responses to these questionnaires be submitted before a hearing is scheduled  The Committee on the Judiciary sends form letters, sometimes called "blue slips," to Senators from a nominee's home state to determine whether they support the nomination  The Committee on the Judiciary also has its own investigative staff  The Committee on Rules and Administration handles relatively few nominations and conducts its own investigations, sometimes with the assistance of the FBI or the Government Accountability Office (GAO)  It is not unusual for nominees to meet with committee staff prior to a hearing  High-level nominees may meet privately with Senators  Generally speaking, these meetings, sometimes initiated by the nominee, serve basically to acquaint the nominee with the Members and committee staff, and vice versa  They occasionally address substantive matters as well  A nominee also might meet with the committee's chief counsel to discuss the financial disclosure report and any potential conflict-of-interest issues  Historically, approximately half of all civilian appointees were confirmed without a hearing  All committees that receive nominations do hold hearings on some nominations, and the likelihood of hearings varies with the importance of the position and the workload of the committee  The Committee on the Judiciary, for example, which receives a large number of nominations, does not usually hold hearings for U S  attorneys, U S  marshals, or members of part-time commissions  The Committee on Agriculture, Nutrition, and Forestry and the Committee on Energy and Natural Resources, on the other hand, typically hold hearings on most nominations that are referred to them  Committees often combine related nominations into a single hearing  The length and nature of hearings varies  One or both home-state Senators will often introduce a nominee at a hearing  The nominee typically testifies at the hearing, and occasionally the committee will invite other witnesses, including Members of the House of Representatives, to testify as well  Some hearings function as routine welcomes, while others are directed at influencing the policy program of an appointee  In addition to policy views, hearings might address the nominee's qualifications and potential conflicts of interest  Senators also might take the opportunity to ask questions of particular concern to them or their constituents  Committees sometimes send questions to nominees in advance of a hearing and ask for written responses  Nominees also might be asked to respond in writing to additional questions after a hearing  Especially for high-level positions, the nomination hearing may be only the first of many times an individual will be asked to testify before a committee  Therefore, the committee often gains a commitment from the nominee to be cooperative with future oversight activities of the committee  Hearings, under Senate Rule XXVI, are open to the public unless closed by majority vote for one of the reasons specified in the rule  Witness testimony is sometimes made available online through the website of the relevant committee and also through several commercial services, including Congressional Quarterly  Most committees print the hearings, although no rule requires it  The number of Senators necessary to constitute a quorum for the purpose of taking testimony varies from committee to committee, but it is usually smaller than a majority of the membership  A committee considering a nomination has four options  It may report the nomination to the Senate favorably, unfavorably, or without recommendation, or it may choose to take no action at all  It is more common for a committee to take no action on a nomination than to report unfavorably  Particularly for policymaking positions, committees sometimes report a nomination favorably, subject to the commitment of the nominee to testify before a Senate committee  Sometimes, committees choose to report a nomination without recommendation  Even if a majority of Senators on a committee do not agree that a nomination should be reported favorably, a majority might agree to report a nomination without a recommendation in order to permit a vote by the whole Senate  The timing of a vote to report a nomination varies in accordance with committee rules and practice  Most committees do not vote to report a nomination on the same day that they hold a hearing, but instead wait until the next meeting of the committee  Senate Rule XXVI, clause 7(a)(1) requires that a quorum for making a recommendation on a nomination consist of a majority of the membership of the committee  In most cases, the number of Senators necessary to constitute a quorum for making a recommendation on a nomination to the Senate is the same that the committee requires for reporting a measure  Every committee reports a majority of nominations favorably  Most of the time, committees do not formally present reports on nominations on the floor of the Senate  Instead, committee staff prepare the appropriate paperwork on behalf of the committee chair and file it with the clerk  The executive clerk then arranges for the nomination to be printed in the Congressional Record and placed on the Executive Calendar   If a report were presented on the floor, it would have to be done in executive session  Executive session and the Executive Calendar will be discussed in the next section  According to Senate Rule XXXI, the Senate cannot vote on a nomination the same day it is reported except by unanimous consent  It is fairly common for the Senate to discharge a committee from consideration of an unreported nomination by unanimous consent  This removes the nomination from the committee in order to allow the full Senate to consider it  When the Senate discharges a committee by unanimous consent, it is doing so with the support of the committee for the purposes of simplifying the process  It is unusual for Senators to attempt to discharge a committee by motion or resolution, instead of by unanimous consent, and only a few attempts have ever been successful  Senate Rule XVII does permit any Senator to submit a motion or resolution that a committee be discharged from the consideration of a subject referred to it  The discharge process, however, does not allow a simple majority to quickly initiate consideration of a nomination still in committee  It requires several steps and, most notably, a motion or resolution to discharge is debatable  This means that a cloture process may be necessary to discharge a committee  Cloture on a discharge motion or resolution requires the support of three-fifths of the Senate, usually 60 Senators, and several days  The Senate handles executive business, which includes both nominations and treaties, separately from its legislative business  All nominations reported from committee, regardless of whether they were reported favorably, unfavorably, or without recommendation, are listed on the Executive Calendar , a separate document from the Calendar of Business , which lists pending bills and resolutions  Usually, the majority leader schedules the consideration of nominations on the Calendar  Nominations are considered in executive session, a parliamentary form of the Senate in session that has its own journal and, to some extent, its own rules of procedure  After a committee reports a nomination or is discharged from considering it, the nomination is assigned a number by the executive clerk and placed on the Executive Calendar   Under a standing order of the Senate, certain nominations might also be placed in this status on the Executive Calendar after certain informational and time requirements are met  The list of nominations in the Executive Calendar includes basic information such as the name and office of the nominee, the name of the previous holder of the office, and whether the committee reported the nomination favorably, unfavorably, or without recommendation  Long lists of routine nominations are printed in the Congressional Record and identified only by a short title in the Executive Calendar , such as "Foreign Service nominations (84) beginning John F  Aloia, and ending Paul G  Churchill " In addition to reported nominations and treaties, the Executive Calendar contains the text of any unanimous consent agreements concerning executive business  The Executive Calendar is distributed to Senate personal offices and committee offices when there is business on it  It is also available online by following the link to "Calendars and Schedules" on the Virtual Reference Desk under the Reference tab of the Senate website (www Senate gov)   Business on the Executive Calendar , which consists of nominations and treaties, is considered in executive session  In contrast, all measures and matters associated with lawmaking are considered in legislative session  Until 1929 executive sessions were also closed to the public, but now they are open unless ordered otherwise by the Senate  The Senate usually begins the day in legislative session and enters executive session either by a non-debatable motion or, far more often, by unanimous consent  Only if the Senate adjourned or recessed while in executive session would the next meeting automatically open in executive session  The motion to go into executive session can be offered at any time, is not debatable, and cannot be laid upon the table  All business concerning nominations, including seemingly routine matters such as requests for joint referral or motions to print hearings, must be done in executive session  In practice, Senators often make such motions or unanimous consent requests "as if in executive session " These usually brief proceedings during a legislative session do not constitute an official executive session  In addition, at the start of each Congress, the Senate adopts a standing order, by unanimous consent, that allows the Senate to receive nominations from the President and for them to be referred to committees even on days when the Senate does not meet in executive session  The majority leader, by custom, makes most motions and requests that determine when or whether a nomination will be called up for consideration  For example, the majority leader may move or ask unanimous consent to "immediately proceed to executive session to consider the following nomination on the Executive Calendar     " By precedent, the motion to go into executive session to take up a specified nomination is not debatable  The nomination itself, however, is debatable  It is not in order for a Senator to move to consider a nomination that is not on the Calendar, and, except by unanimous consent, a nomination on the Calendar cannot be taken up until it has been on the Calendar at least one day (Rule XXXI, clause 1)  A day for this purpose is a calendar day  In other words, a nomination reported and placed on the Calendar on a Monday can be considered on Tuesday, even if it is the same legislative day  If the Senate simply resolved into executive session, the business immediately pending would be the first item on the Executive Calendar   A motion to proceed to another matter on the Calendar would be debatable and subject to a filibuster  For this reason, the Senate does not begin consideration of executive business this way  Instead, the motion made to call up a nomination is a motion to proceed to executive session to consider that specific nomination  If the Senate is already in executive session, and the Leader wishes to call up a nomination, the Leader will first move that the Senate enter legislative session and then that the Senate enter executive session to take up the nomination  Both motions (to enter legislative session and to enter executive session) are not subject to debate and are decided by a simple majority  Typically they are approved by voice vote  The question before the Senate when a nomination is taken up is "will the Senate advise and consent to this nomination?" The Senate can approve or reject a nomination  A majority of Senators present and voting, a quorum being present, is required to approve a nomination  According to Senate Rule XXXI, any Senator who voted with the majority on the nomination has the option of moving to reconsider a vote on the day of the vote or the next two days the Senate meets in executive session  Only one motion to reconsider is in order on each nomination, and often the motion to reconsider is laid upon the table, by unanimous consent, shortly after the vote on the nomination  This action prevents any subsequent attempt to reconsider  After the Senate acts on a nomination, the Secretary of the Senate attests to a resolution of confirmation or disapproval and transmits it to the White House  Many nominations are brought up by unanimous consent and approved without objection; routine nominations often are grouped by unanimous consent in order to be brought up and approved together, or en bloc   A small proportion of nominations, generally to higher-level positions, may need more consideration  When there is debate on a nomination, the chair of the committee usually makes an opening speech  For positions within a state, Senators from the state may wish to speak on the nominee, particularly if they were involved in the selection process  Under Senate rules, there are no time limits on debate except when conducted under cloture or a unanimous consent agreement  Senate Rule XXII provides a means to bring debate on a nomination to a close, if necessary  Under the terms of Rule XXII, at least 16 Senators sign a cloture motion to end debate on a pending nomination  The motion proposed is "to bring to a close the debate upon [the pending nomination] " A Senator can interrupt a Senator who is speaking to present a cloture motion  Cloture may be moved only on a question that is pending before the Senate; therefore, absent unanimous consent, the Senate must be in executive session and considering the nomination when the motion is filed  After the clerk reads the motion, the Senate returns to the business it was considering before the presentation of the motion  Unless a unanimous consent agreement provides otherwise, the Senate does not vote on the cloture motion until the second day of session after the day it is presented; for example, if the motion was presented on a Monday, the Senate would act on it on Wednesday  One hour after the Senate has convened on the day the motion "ripened," the presiding officer can interrupt the proceedings during an executive session to present a cloture motion for a vote  If the Senate is in legislative session when the time arrives for voting on the cloture motion, it proceeds into executive session prior to taking action on the cloture petition  According to Rule XXII, the presiding officer first directs the clerk to call the roll to ascertain that a quorum is present, although this requirement is often waived by unanimous consent  Senators then vote either yea or nay on the question: "Is it the sense of the Senate that the debate shall be brought to a close?" In April 2017, the Senate reinterpreted Rule XXII in order to allow cloture to be invoked on all nominations by a majority of Senators voting (a quorum being present), including Supreme Court justice nominations  This expanded the results of similar actions taken by the Senate in November 2013, which changed the cloture vote requirement to a majority for nominations except to the Supreme Court  Once cloture is invoked, for most nominations there can be a maximum of two hours of post-cloture consideration  The two hour maximum includes debate as well as any actions taken while the nomination is formally pending, including quorum calls  If cloture is invoked on nominations to the highest ranking executive branch positions, or on nominations to the Supreme Court or the U S  Circuit Court of Appeals, then the maximum time for consideration after cloture is invoked is 30 hours (see Table 1 )  Under the rule, the 2 or 30 hours is floor time spent considering the nomination in the Senate, not simply the passage of time  Thus, for time to count against the 2 or 30-hour maximum, the Senate must be in session and the question must be pending  Time spent in recess or adjournment does not count, and if the Senate were to take up other business by unanimous consent, the time spent on that other business also would not count against the post-cloture time  A hold is a request by a Senator to his or her party leader to prevent or delay action on a nomination or a bill  Holds are not mentioned in the rules or precedents of the Senate, and they are enforced only through the agenda decisions of party leaders  A standing order of the Senate aims to ensure that any Senator who places a hold on any matter (including a nomination) make public his or her objection to the matter  Senators have placed holds on nominations for a number of reasons  One common purpose is to give a Senator more time to review a nomination or to consult with the nominee  Senators may also place holds because they disagree with the policy positions of the nominee  Senators have also admitted to using holds in order to gain concessions from the executive branch on matters not directly related to the nomination  The Senate precedents reducing the threshold necessary to invoke cloture on nominations, and the recent precedent reducing the time necessary for a cloture process, could affect the practice of holds  In some sense, holds are connected to the Senate traditions of mutual deference, since they may have originated as requests for more time to examine a pending nomination or bill  The effectiveness of a hold, however, ultimately has been grounded in the power of the Senator placing the hold to filibuster the nomination and the difficulty of invoking cloture to overcome a filibuster  Invoking cloture is now easier because the support of fewer Senators is necessary, and in most cases, the floor time required for a cloture process is less  The large number of nominations submitted by the President for Senate consideration, however, might still lead Senators to seek unanimous consent to quickly approve nominations  On April 3, 2019, the Senate reinterpreted Senate Rule XXII to reduce, from 30 hours to 2 hours, the maximum time allowed for consideration of most nominations after cloture is invoked  The Senate took this step by reversing two rulings by the Presiding Officer  The first vote established that "postcloture time under rule XXII for all executive branch nominations other than a position at level 1 of the Executive Schedule under section 5312 of title 5 of the United States Code is 2 hours " On the second vote, the Senate established that "postcloture time under rule XXII for all judicial nominations, other than circuit courts or Supreme Court of the United States, is 2 hours" (see Table 1 )  It is uncommon for the Senate to reverse a decision by the Presiding Officer  Any Senator can attempt to reverse a ruling by making an appeal, and except in specific cases, appeals are decided by majority vote  In most circumstances, however, appeals are debatable, and therefore supermajority support (through a cloture process) is typically necessary to reach a vote to reverse a decision of the Presiding Officer  In the April 3 proceedings, however, the appeal was raised after cloture had been invoked  Senate Rule XXII states that after a successful cloture vote, "appeals from the decision of the Presiding Officer, shall be decided without debate " Therefore, when the Majority Leader appealed the rulings of the Presiding Officer, the questions on whether the ruling should stand as the judgment of the Senate received a vote without an opportunity for extended debate  The Senate voted that the ruling should not stand, and thereby upheld instead the position of the Majority Leader  The future impact of these decisions on the nominations process is difficult to assess  The immediate and obvious expected impact is that the time between a cloture vote and a confirmation vote will decrease  In recent years, a vote to confirm a nominee has typically occurred the day after cloture was invoked (or on the next day of Senate session)  Usually, Senators did not spend all of the time between the votes debating the nomination  Instead, Senators typically debated the nomination for some time post-cloture, but also usually entered into unanimous consent agreements that affected when the vote would occur  For example, it became common in recent Congresses for the Senate to agree, by unanimous consent, to consider the time the Senate spent in adjournment or recesses (e g , overnight) to count as post-cloture time  The cloture rule affected the time of the vote set by unanimous consent: the rule provided for up to 30 hours of consideration of the nomination, and the Senate would agree to vote on the nomination a day later—reflecting the approximate time that the Senate could have debated the nomination under the rule  Assuming the Senate continues to establish times for voting on nominations by unanimous consent, those negotiations will be affected by the reinterpretation of the rule  In the absence of a unanimous consent agreement, most nominations can now receive a vote two hours after a vote to invoke cloture  The two hours is not formally divided between the parties pursuant to the rule (or pursuant to the reinterpretation of the rule), but it might be divided, by unanimous consent, between the Majority and Minority Leader  Even without an explicit unanimous consent agreement, the Majority and Minority Leaders are recognized before any other Senators  In addition, a Senator can speak for a maximum of one hour post-cloture  As a result, the Majority Leader could claim the first hour, and the Minority Leader the second, or vice versa  (Of course, Senators could speak on a nomination at times other than after cloture has been invoked, even when the nomination is not formally pending before the Senate  ) It is also possible that the recent reinterpretation of the rule will affect how often the Senate relies on the cloture process to approve nominations  After the first reinterpretation of the cloture rule in 2013, the number of nominations subjected to cloture motions increased significantly in both of the Congresses when the Senate was controlled by the same party as the President (113 th (2013-2014) and 115 th (2017-2018) Congresses)  Nominations that are not confirmed or rejected are returned to the President at the end of a session or when the Senate adjourns or recesses for more than 30 days (Senate Rule XXXI, paragraph 6)  If the President still wants a nominee considered, he must submit a new nomination to the Senate  The Senate can, however, waive this rule by unanimous consent, and it often does to allow nominations to remain "in status quo" between the first and second sessions of a Congress or during a long recess  The majority leader or his designee also may exempt specific nominees by name from the unanimous consent agreement, allowing them to be returned during the recess or adjournment  The Constitution, in Article II, Section 2, grants the President the authority to fill temporarily vacancies that "may happen during the Recess of the Senate " These appointments do not require the advice and consent of the Senate; the appointees temporarily fill the vacancies without Senate confirmation  In most cases, recess appointees have also been nominated to the positions to which they were appointed  Furthermore, when a recess appointment is made of an individual previously nominated to the position, the President usually submits a new nomination to the Senate in order to comply with a provision of law affecting the pay of recess appointees (5 U S C  5503(a))  Recess appointments have sometimes been controversial and have occasionally led to inter-branch conflict 


Report 2:  For example, helpful factors to consider when developing a proposed reward amount may include (1) the number of hours the source dedicated to the case, (2) the risk the source took in providing the information, (3) the significance of the information provided by the source, and (4) the amount of fines or other penalties collected as a result of the information  Two stakeholders expressed concern that some of FWS’s reward payments were insufficient, especially when comparing the amount of time and effort or the risk a source faced in providing the information  A couple of stakeholders also said that without a policy that specifies factors for agents to consider, reward amounts may be subjective and could vary depending on which agent develops the reward proposal  Another stakeholder said that it was important to specify factors for agents to consider when developing proposed reward amounts so that the agency has a reasonable and defensible basis for the reward amounts it pays across cases  According to federal standards for internal control, management should internally communicate the necessary quality information to achieve an agency’s objectives  For example, management communicates quality information down and across reporting lines to enable personnel to make key decisions  FWS officials said they believe that their reward policy is sound, indicating they believe that law enforcement agents have the information they need to develop proposals for reward amounts in cases where rewards are warranted  However, they also agreed that it may be helpful to review their policy but did not commit to doing so  By augmenting its policy to specify factors for agents to consider when developing proposed reward amounts, FWS can better ensure that its agents have the necessary quality information to prepare defensible reward proposals  Based on our review of the agencies’ websites and other communications, we found that FWS and NOAA communicate little information to the public on financial rewards for reporting information on wildlife trafficking, such as the potential availability of rewards and eligibility criteria  Specifically, some FWS and NOAA law enforcement websites provided information to the public on ways to report violations of the laws that the agencies are responsible for enforcing, such as via tip lines  Some of the websites also provided examples of the types of information the public can report, such as photos or other documentation of illegal activities  However, most of the agencies’ websites did not indicate that providing information on illegal activities could result in a reward  In contrast, the FWS Alaska regional office’s website provided information on the potential availability of rewards and ways the public may submit information for a potential reward  For example, this website provided phone numbers and an e-mail address for the public to use when submitting information  Figure 1 shows the information available on FWS’s and NOAA’s national and regional websites relevant to reporting violations of the laws the agencies enforce in general and on receiving rewards in particular  In addition, FWS and NOAA headquarters officials said their field agents have used other means to communicate the potential availability of rewards in specific cases when the agents had no other information that could help solve those cases  For example, a FWS field official said that the agency advertised a reward offer for information on a case of bald eagle killings by distributing reward posters and posting news releases in the vicinity where the killings occurred  Similarly, NOAA officials said they have advertised reward offers through various means, including circulating reward posters in specific geographic areas after an illegal activity has occurred  Figure 2 shows a reward poster that NOAA distributed in Guam in 2017 advertising a $1,000 reward for information leading to the arrest and conviction of sea turtle poachers  Instead of having a plan for communicating general information to the public on rewards, FWS and NOAA grant discretion to their regional offices and law enforcement agents to determine the type and level of communication to provide, according to FWS and NOAA policies  FWS officials explained that because they typically use financial rewards to thank individuals who come forward on their own accord—rather than using rewards to incentivize individuals with information to come forward—they have not seen the need to communicate more information to the public on the potential availability of rewards  NOAA officials said they have targeted their communications on rewards by publicizing reward offers for specific cases where they do not have leads  They added that they want to receive quality information and already receive a substantial amount of information from sources who reach out to them proactively, so NOAA has not seen the need to communicate more information to the public on the potential availability of rewards  Sixteen of the 20 stakeholders we interviewed said that it would be useful for FWS and NOAA to advertise the potential availability of financial rewards  Several stakeholders said that if the public does not know about the possibility for rewards, then some people with information may not be incentivized to come forward  Two stakeholders added that agencies should carefully consider how and which reward information to communicate to the public so that people who are most likely to have information on illegal wildlife trafficking learn about the potential for rewards  For example, one stakeholder suggested advertising rewards at ports where international shipments are offloaded or placing advertisements at wildlife trafficking nodes, such as entrances to African wildlife refuges  This stakeholder suggested advertising rewards along with wildlife trafficking awareness-raising posters that nongovernment organizations place in some airports  In addition, 14 stakeholders suggested that it would be useful for FWS and NOAA to provide information to the public on the process for submitting information to potentially receive rewards  Several other stakeholders said that it is important for the public to understand whether they may be eligible for a reward, how to submit information, and whether or to what extent their confidentiality will be protected  Another stakeholder provided examples of how other agencies provide information about their reward programs on their websites  SEC and IRS, for instance, use their websites to communicate information to the public on the process for reporting illegal activity for financial rewards  This information includes the types of information to report, confidentiality rules, eligibility criteria, and the process for submitting information to obtain a reward  In addition, the Department of State posts instructions on its websites on how to submit information on an illegal activity and potentially receive a reward  Federal internal control standards say that management should externally communicate the necessary quality information to achieve an agency’s objectives  For example, using appropriate methods to communicate, management communicates quality information so that external parties, such as the public, can help the agency achieve its objectives  This could include communicating information to the public on the types of information and eligibility requirements for potentially receiving rewards for reporting information on wildlife trafficking  FWS officials said that making more reward information available could lead to a significant increase in the amount of information the agency receives, which, in turn, could strain FWS’s resources in following up on that information  However, FWS officials also agreed that it was reasonable to consider making more reward information available to relevant members of the public, particularly in targeted circumstances, but did not commit to doing so  Similarly, NOAA officials said they had some concerns about the additional resources it might take to investigate potentially unreliable or false tips that may result if they make reward information broadly available to the public, but they agreed that it would be reasonable for the agency to consider doing so  NOAA officials also said they may consider making more reward information publicly available at the conclusion of our audit but provided no plans for doing so  By determining the types of additional information to communicate to the public on rewards—such as providing information on the agency’s website on the potential availability of rewards—and then developing and implementing plans to do so, FWS and NOAA can improve their chances of obtaining information on wildlife trafficking activities that they otherwise might not receive  FWS and NOAA have not reviewed the effectiveness of their use of financial rewards or considered whether any changes might improve the usefulness of rewards as a tool for combating wildlife trafficking  FWS officials said their agency has not reviewed or considered changes to its use of rewards because the agency has not prioritized the use of rewards  NOAA officials said their agency has not focused on using rewards or identified the need to review its use of this tool, particularly in light of other, higher mission priorities  Nine of the 20 stakeholders we interviewed said that FWS and NOAA should review the effectiveness of their use of rewards and consider potential improvements  Several stakeholders said that it would be useful for FWS and NOAA to compare their respective approaches to those of federal agencies that use rewards in contexts outside of wildlife trafficking to identify best practices or lessons learned that might be applicable in the context of combating wildlife trafficking  For example, one stakeholder said that SEC has an effective whistleblower program and may have lessons learned that are relevant for FWS and NOAA to consider  Another stakeholder we interviewed separately indicated that in 2010, before SEC had a whistleblower program that publicized rewards and provided detailed instructions on how members of the public could report information on illegal activities, SEC received few tips  Once SEC implemented a whistleblower program that publicized rewards and provided detailed instructions on its public website, the agency’s use of the program grew substantially, according to the stakeholder  Other stakeholders said it would be useful for the agencies to consider potential improvements to their use of rewards, such as making a standing reward offer for information on wildlife trafficking targeted at high-priority endangered species or particular criminal networks  Two of these stakeholders said such an offer might improve FWS’s and NOAA’s use of rewards by generating more tips than reward offers focused on individual cases  At the same time, they said such an offer would likely filter out some of the false or unproductive tips that the agencies might receive if they made an untargeted standing reward offer  Federal internal control standards state that management should design control activities to achieve objectives and respond to risks by, for example, conducting reviews at the functional or activity level by comparing actual performance to planned or expected results and analyzing significant differences  Further, under the standards, management should periodically review policies, procedures, and related control activities for continued relevance and effectiveness in achieving an agency’s objectives or addressing related risks  FWS and NOAA officials agreed that reviewing the effectiveness of their use of rewards would be worthwhile  Specifically, FWS officials said that it would be useful to compare their approach to those of other federal agencies that use rewards in investigating crimes that involve interstate and foreign smuggling of goods  Similarly, NOAA officials said that reviewing the agency’s use of financial rewards would be worthwhile but cautioned that such a review would need to be balanced against the agency’s constrained resources and many mission requirements  FWS and NOAA officials said they may consider conducting such a review at the conclusion of our audit but provided no plans for doing so  By reviewing the effectiveness of their use of rewards, FWS and NOAA can identify opportunities to improve the usefulness of rewards as a tool for combating wildlife trafficking  Wildlife trafficking is a large and growing transnational criminal activity, with global environmental, security, and economic consequences  The federal government has emphasized strengthening law enforcement efforts to combat wildlife trafficking, and using financial rewards to obtain information on illegal activities is one tool that some federal agencies have used  However, to date, FWS and NOAA have not prioritized the use of rewards and were unable to provide sufficient assurance that the 27 rewards they paid during fiscal years 2007 through 2017 represented all of the rewards they provided during that period  By tracking reward information so that it is clearly documented and readily available for examination, FWS and NOAA can better ensure that they have complete information on the rewards they have paid to help manage their use of rewards as a law enforcement tool  Additionally, FWS and NOAA have policies outlining the processes their law enforcement agents are to use in making reward payments, and NOAA’s policy specifies factors for its agents to consider in developing proposed reward amounts, such as the risk the individual took in collecting the information  FWS’s policy does not specify such factors that could inform agents in achieving the agency’s objectives, which is not consistent with federal internal control standards  By augmenting its policy to specify factors for its agents to consider when developing proposed reward amounts, FWS can better ensure that its agents have the necessary quality information to prepare defensible reward proposals  Both agencies have also advertised the potential for rewards in specific cases when agents had no other information, but FWS and NOAA have otherwise communicated little information to the public on the potential availability of rewards  If the public does not know about the possibility of rewards, then some people with information may not be incentivized to come forward  By determining the types of additional information to communicate to the public on rewards—such as providing information on the agency’s website about the potential availability of rewards—and then developing and implementing plans to do so, FWS and NOAA can improve their chances of obtaining information on wildlife trafficking activities that they otherwise might not receive  Finally, FWS and NOAA have not reviewed the effectiveness of their use of financial rewards or considered whether any changes might improve the usefulness of rewards as a law enforcement tool  By undertaking such reviews, the agencies can identify opportunities to improve the usefulness of rewards as a tool for combating wildlife trafficking  We are making a total of seven recommendations, including four to FWS and three to NOAA  Specifically: The Assistant Director of the FWS Office of Law Enforcement should track financial reward information so that it is clearly documented and readily available for examination  (Recommendation 1) The Director of the NOAA Office of Law Enforcement should track financial reward information so that it is clearly documented and readily available for examination  (Recommendation 2) The Assistant Director of the FWS Office of Law Enforcement should augment FWS’s financial reward policy to specify factors law enforcement agents are to consider when developing proposed reward amounts  (Recommendation 3) The Assistant Director of the FWS Office of Law Enforcement should determine the types of additional information to communicate to the public on financial rewards and then develop and implement a plan for communicating that information  (Recommendation 4) The Director of the NOAA Office of Law Enforcement should determine the types of additional information to communicate to the public on financial rewards and then develop and implement a plan for communicating that information  (Recommendation 5) The Assistant Director of the FWS Office of Law Enforcement should review the effectiveness of the agency’s use of financial rewards and implement any changes that the agency determines would improve the usefulness of financial rewards as a law enforcement tool  (Recommendation 6) The Director of the NOAA Office of Law Enforcement should review the effectiveness of the agency’s use of financial rewards and implement any changes that the agency determines would improve the usefulness of financial rewards as a law enforcement tool  (Recommendation 7) We provided a draft of this report for review and comment to the Departments of Commerce and the Interior  The departments transmitted written comments, which are reproduced in appendixes IV and V of this report  The Department of Commerce concurred with the three recommendations directed to NOAA and stated that NOAA is developing procedures to ensure that its rewards are closely tracked, clearly documented, and better communicated  In written comments from NOAA, NOAA stated the report fairly and thoroughly reviews NOAA’s use of financial rewards  NOAA outlined the steps it plans to take in response to our recommendations, including developing a procedure to track financial reward information, reviewing information currently disseminated to the public and evaluating whether additional information may be useful, and reviewing the agency’s reward policy to determine whether changes are needed to enhance reward effectiveness  In its written comments, the Department of the Interior concurred with the four recommendations directed to FWS  Interior stated that it appreciated our review of the challenges faced by FWS’s Office of Law Enforcement in combating wildlife trafficking and identifying areas where FWS and NOAA can improve the use of financial rewards as a tool for combating wildlife trafficking  Interior also provided technical comments, which we incorporated as appropriate  As agreed with your office, unless you publicly announce the contents of this report earlier, we plan no further distribution until 30 days from the report date  At that time, we will send copies to the appropriate congressional committees, the Secretaries of Commerce and the Interior, and other interested parties  In addition, the report will be available at no charge on the GAO website at http://www gao gov  If you or your staff have any questions about this report, please contact me at (202) 512-3841 or fennella@gao gov  Contact points for our Offices of Congressional Relations and of Public Affairs may be found on the last page of this report  GAO staff who made major contributions to this report are listed in appendix VI  The objectives of our review were to (1) identify laws that authorize the U S  Fish and Wildlife Service (FWS) and the National Oceanic and Atmospheric Administration (NOAA) to pay financial rewards for information on wildlife trafficking and the extent to which these agencies paid such rewards from fiscal years 2007 through 2017, (2) evaluate FWS’s and NOAA’s policies on financial rewards, (3) evaluate the information available to the public on financial rewards, and (4) determine the extent to which FWS and NOAA reviewed the effectiveness of their use of financial rewards in combating wildlife trafficking  To address these objectives, we reviewed academic literature on the use of financial rewards to combat illegal activities and United Nations Environment Programme reports on the scope and scale of wildlife trafficking  We also interviewed officials from federal agencies that play a role in combating wildlife trafficking or manage programs that pay financial rewards for information on illegal activities  Specifically, we interviewed officials from the Departments of Agriculture, Commerce, Homeland Security, the Interior, Justice, and State, as well as officials from the Internal Revenue Service, the U S  Securities and Exchange Commission, and the U S  Agency for International Development  In addition, we reviewed documentation that the Department of the Treasury provided on its role in paying financial rewards  We did not compare FWS’s and NOAA’s use of financial rewards in combating wildlife trafficking to federal agencies’ use of financial rewards in other contexts because the different contexts are not directly comparable  However, we reviewed information on other federal agencies’ use of financial rewards as examples of how financial rewards are used in contexts outside of wildlife trafficking  In addition, we interviewed representatives of six nongovernmental organizations that we selected based on those organizations’ knowledge or experience in combating wildlife trafficking  Specifically, we interviewed representatives from the Elephant Action League, the Environmental Investigation Agency, the National Association of Conservation Law Enforcement Chiefs, the National Whistleblower Center, TRAFFIC, and the World Wildlife Fund  To identify laws that authorize FWS and NOAA to pay financial rewards for information on wildlife trafficking, we asked FWS and NOAA attorneys to compile a list of laws that each of their agencies implements or enforces that prohibit wildlife trafficking and authorize the agency to pay rewards for providing information about trafficking  We then compared that list to the results of our search of the United States Code for such laws  We also reviewed FWS and NOAA documentation for accounts where the fines, penalties, and proceeds from forfeited property that are used to pay rewards are deposited as well as the accounts where appropriations available to pay rewards were deposited  To identify the extent to which FWS and NOAA have paid financial rewards for information on wildlife trafficking, we analyzed FWS and NOAA data on financial rewards the agencies reported paying from fiscal years 2007 through 2017  The data included information on, among other things, the fiscal years in which rewards were paid, laws under which rewards were paid, types of wildlife involved in those cases, the amounts of civil penalties or criminal fines imposed in those cases, the numbers of arrests and convictions as a result of those cases, and whether reward recipients were individuals or groups and U S  or foreign citizens  To assess the reliability of the data FWS and NOAA provided on financial rewards, we interviewed agency officials knowledgeable about the data and compared the data to case records the agencies provided  Specifically, FWS and NOAA officials said they track all expenditures, including reward payments, in their financial databases, but they are not able to readily identify reward payments because their financial systems do not include a unique identifier for such payments and their reward information is located in multiple databases and formats  As a result, FWS and NOAA officials said they identified the rewards that they reported to us by manually reviewing their financial and law enforcement records, and officials said the information was complete to the best of their knowledge  Based on these steps, we found the data that the agencies provided to us to be sufficiently reliable for reporting information on the rewards the agencies reported paying  However, as we discuss in the report, FWS and NOAA officials could not provide sufficient assurance that the data included all the financial rewards that they had paid from fiscal years 2007 through 2017  To obtain additional detail about cases where financial rewards were paid, we reviewed a nongeneralizable sample of 10 wildlife trafficking cases  We selected these cases based on the agency that investigated the case (to include both FWS and NOAA cases), the amount of the reward paid in the case (to reflect both low and high amounts), the year in which the reward was paid (to include rewards paid more recently), and the type of wildlife trafficked in the case (to include both fish and wildlife cases—there were no plant trafficking cases to select)  While the findings from our review cannot be generalized to cases we did not select and review, they illustrate how FWS and NOAA have used financial rewards in wildlife trafficking cases  To evaluate FWS and NOAA policies on financial rewards, we reviewed relevant FWS and NOAA policies and compared them to each other; interviewed FWS and NOAA officials about those policies; and compared the information in the policies with federal internal control standards on information and communication  To evaluate information available to the public on rewards, we reviewed relevant FWS and NOAA publications and examples of communications to the public on the availability of rewards in specific cases and interviewed FWS and NOAA officials  We also reviewed information available on FWS’s and NOAA’s national and regional websites as of December 2017 and January 2018, respectively, relevant to reporting violations of the laws that the agencies enforce in general and on receiving rewards in particular  We compared the agencies’ public communications on rewards with federal internal control standards on information and communication  To evaluate the extent to which FWS and NOAA reviewed the effectiveness of their use of financial rewards in combating wildlife trafficking, we interviewed FWS and NOAA officials and requested any reviews the agencies had conducted regarding their use of financial rewards to compare with federal internal control standards on control activities  FWS and NOAA did not have any such reviews to provide  In addition, for all four objectives, we interviewed a nongeneralizable sample of 20 stakeholders who had experience investigating wildlife trafficking or expertise in the use of financial rewards as a law enforcement tool  To select stakeholders to interview, we first identified a list of stakeholders by reviewing (1) FWS and NOAA data on law enforcement agents with at least 5 years of experience who had investigated wildlife trafficking cases and used financial rewards, (2) Department of Justice data on federal prosecutors who had prosecuted wildlife trafficking cases since fiscal year 2014, (3) literature search results identifying academics with expertise in the use of financial rewards as a law enforcement tool and federal programs that use financial rewards to combat illegal activities in contexts outside of wildlife trafficking, (4) the biographies of members of the federal Advisory Council on Wildlife Trafficking, and (5) recommendations from stakeholders we interviewed  From this list, we then used a multistep process to select the 20 stakeholders to interview  To ensure coverage and a range of perspectives, we selected stakeholders from the following groups: FWS and NOAA law enforcement agents, including field and federal prosecutors responsible for prosecuting wildlife trafficking cases; federal officials responsible for programs that use financial rewards to combat illegal activities in contexts outside of wildlife trafficking; academics with expertise in the use of financial rewards as a law members of the federal Advisory Council on Wildlife Trafficking; and representatives of nongovernmental organizations that investigate wildlife trafficking  We conducted semistructured interviews with the 20 selected stakeholders using a standard set of questions  We asked questions about stakeholder views on the usefulness of financial rewards in combating wildlife trafficking; the strength and weaknesses of the statutory provisions that authorize federal agencies to pay financial rewards for information on wildlife trafficking; FWS’s and NOAA’s use of financial rewards to combat wildlife trafficking; and how, if at all, the two agencies could improve their use of financial rewards to combat wildlife trafficking  We analyzed the stakeholders’ responses to our questions, grouping the responses into overall themes  We summarized the results of our analysis and then shared the summary with relevant FWS and NOAA officials to obtain their views  Views from these stakeholders cannot be generalized to those whom we did not select and interview  We conducted this performance audit from February 2017 to April 2018 in accordance with generally accepted government auditing standards  Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives  We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives  The Department of the Interior’s U S  Fish and Wildlife Service (FWS) and the Department of Commerce’s National Oceanic and Atmospheric Administration (NOAA) implement or enforce multiple laws that specifically authorize the payment, under specified circumstances, of financial rewards to persons for information about violations of laws that prohibit wildlife trafficking  The laws that FWS officials identified are listed and summarized in table 3, and the laws that NOAA officials identified are listed and summarized in table 4  In addition, as noted above, the reward provisions in the Magnuson- Stevens Fishery Conservation and Management Act as amended and the Fish and Wildlife Improvement Act as amended authorize the payment of rewards for information about violations of multiple laws  Specifically, the Magnuson-Stevens Fishery Conservation and Management Act as amended authorizes the payment of rewards for information about violations of the act as well as any other marine resource law that the Secretary of Commerce enforces  Further, the Fish and Wildlife Improvement Act as amended authorizes the payment of rewards for information about violations of any law administered by NOAA’s National Marine Fisheries Service relating to plants, fish, or wildlife  NOAA officials identified 14 such laws that prohibit wildlife trafficking (see table 5)  If a violation of the laws listed in table 5 occurs, NOAA officials said they could use the Magnuson-Stevens Fishery Conservation and Management Act or Fish and Wildlife Improvement Act reward provision to pay a reward for information on the violation  None of the laws listed in table 5 specifically authorize the payment of financial rewards  Table 6 provides information on U S  Fish and Wildlife Service and National Oceanic and Atmospheric Administration cases where these agencies reported paying rewards for information on wildlife trafficking from fiscal years 2007 through 2017  In addition to the contact named above, Alyssa M  Hundrup (Assistant Director), David Marroni (Analyst-in-Charge), Cindy Gilbert, Keesha Luebke, Jeanette Soares, Sheryl Stein, Sara Sullivan, and Judith Williams made key contributions to this report 

ground_truth: Wildlife trafficking—the poaching and illegal trade of plants, fish, and wildlife—is a multibillion-dollar, global criminal activity that imperils thousands of species. FWS and NOAA enforce laws prohibiting wildlife trafficking that authorize the agencies to pay financial rewards for information about such illegal activities. GAO was asked to review FWS's and NOAA's use of financial rewards to combat wildlife trafficking. This report examines (1) laws that authorize FWS and NOAA to pay rewards for information on wildlife trafficking and the extent to which the agencies paid such rewards from fiscal years 2007 through 2017, (2) the agencies' reward policies, (3) information available to the public on rewards, and (4) the extent to which the agencies reviewed the effectiveness of their use of rewards. GAO reviewed laws, examined FWS and NOAA policies and public communications on rewards, analyzed agency reward data for fiscal years 2007 through 2017 and assessed their reliability, interviewed FWS and NOAA officials, and compared agency policies and public communications on rewards to federal internal control standards. Multiple laws—such as the Endangered Species Act and Lacey Act—authorize the Departments of the Interior's U.S. Fish and Wildlife Service (FWS) and Commerce's National Oceanic and Atmospheric Administration (NOAA) to pay rewards for information on wildlife trafficking. FWS and NOAA reported paying few rewards from fiscal years 2007 through 2017. Specifically, the agencies collectively reported paying 27 rewards, totaling $205,500. Agency officials said that the information was complete to the best of their knowledge but could not sufficiently assure that this information represented all of their reward payments. FWS and NOAA have reward policies that outline the general process for preparing reward proposals, but FWS's policy does not specify factors for its agents to consider when developing proposed reward amounts. Some FWS agents GAO interviewed said that in developing proposals, they did not know whether their proposed reward amounts were enough, too little, or too much. By augmenting its policy to specify factors for agents to consider, FWS can better ensure that its agents have the necessary quality information to prepare proposed reward amounts, consistent with federal internal control standards. FWS and NOAA communicate little information to the public on rewards. For example, most agency websites did not indicate that providing information on wildlife trafficking could qualify for a reward. This is inconsistent with federal standards that call for management to communicate quality information so that external parties can help achieve agency objectives. FWS and NOAA officials said they have not communicated general reward information because of workload concerns, but they said it may be reasonable to provide more information in some instances. By developing plans to communicate more reward information to the public, the agencies can improve their chances of obtaining information on wildlife trafficking that they otherwise might not receive. FWS and NOAA have not reviewed the effectiveness of their use of rewards. The agencies have not done so because using rewards has generally not been a priority. FWS and NOAA officials agreed that such a review would be worthwhile but provided no plans for doing so. By reviewing the effectiveness of their use of rewards, FWS and NOAA can identify opportunities to improve the usefulness of rewards as a tool for combating wildlife trafficking. GAO is making seven recommendations, including that FWS and NOAA track reward information, FWS augment its reward policy to specify factors for agents to consider when developing proposed reward amounts, FWS and NOAA develop plans to communicate more reward information to the public, and FWS and NOAA review the effectiveness of their reward use. Both agencies concurred with these recommendations.