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



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



Report 2: The LDA requires lobbyists to register with the Secretary of the Senate and the Clerk of the House and to file quarterly reports disclosing their respective lobbying activities  Lobbyists are required to file their registrations and reports electronically with the Secretary of the Senate and the Clerk of the House through a single entry point  Registrations and reports must be publicly available in downloadable, searchable databases from the Secretary of the Senate and the Clerk of the House  No specific statutory requirements exist for lobbyists to generate or maintain documentation in support of the information disclosed in the reports they file  However, guidance issued by the Secretary of the Senate and the Clerk of the House recommends that lobbyists retain copies of their filings and documentation supporting reported income and expenses for at least 6 years after they file their reports  The LDA requires that the Secretary of the Senate and the Clerk of the House guide and assist lobbyists with the registration and reporting requirements and develop common standards, rules, and procedures for LDA compliance  The Secretary of the Senate and the Clerk of the House review the guidance semiannually  It was last revised January 31, 2017, to (among other issues) update the registration threshold to reflect changes in the Consumer Price Index, and clarify the identification of clients and covered officials and issues related to rounding income and expenses  The guidance provides definitions of LDA terms, elaborates on registration and reporting requirements, includes specific examples of different scenarios, and provides explanations of why certain scenarios prompt or do not prompt disclosure under the LDA  The offices of the Secretary of the Senate and the Clerk of the House told us they continue to consider information we report on lobbying disclosure compliance when they periodically update the guidance  In addition, they told us they e-mail registered lobbyists quarterly on common compliance issues and reminders to file reports by the due dates  The LDA defines a lobbyist as an individual who is employed or retained by a client for compensation, who has made more than one lobbying contact (written or oral communication to covered officials, such as a high ranking agency official or a Member of Congress made on behalf of a client), and whose lobbying activities represent at least 20 percent of the time that he or she spends on behalf of the client during the quarter  Lobbying firms are persons or entities that have one or more employees who lobby on behalf of a client other than that person or entity  Figure 1 provides an overview of the registration and filing process  Lobbying firms are required to register with the Secretary of the Senate and the Clerk of the House for each client if the firms receive or expect to receive more than $3,000 in income from that client for lobbying activities  Lobbyists are also required to submit an LD-2 quarterly report for each registration filed  The LD-2s contain information that includes: the name of the lobbyist reporting on quarterly lobbying activities; the name of the client for whom the lobbyist lobbied; a list of individuals who acted as lobbyists on behalf of the client during the reporting period; whether any lobbyists served in covered positions in the executive or legislative branch such as high-ranking agency officials or congressional staff positions, in the previous 20 years; codes describing general issue areas, such as agriculture and education; a description of the specific lobbying issues; houses of Congress and federal agencies lobbied during the reporting reported income (or expenses for organizations with in-house lobbyists) related to lobbying activities during the quarter (rounded to the nearest $10,000)  The LDA also requires lobbyists to report certain political contributions semiannually in the LD-203 report  These reports must be filed 30 days after the end of a semiannual period by each lobbying firm registered to lobby and by each individual listed as a lobbyist on a firm’s lobbying report  The lobbyists or lobbying firms must: list the name of each federal candidate or officeholder, leadership political action committee, or political party committee to which he or she contributed at least $200 in the aggregate during the semiannual period; report contributions made to presidential library foundations and presidential inaugural committees; report funds contributed to pay the cost of an event to honor or recognize an official who was previously in a covered position, funds paid to an entity named for or controlled by a covered official, and contributions to a person or entity in recognition of an official, or to pay the costs of a meeting or other event held by or in the name of a covered official; and certify that they have read and are familiar with the gift and travel rules of the Senate and House and that they have not provided, requested, or directed a gift or travel to a member, officer, or employee of Congress that would violate those rules  The Secretary of the Senate and the Clerk of the House, along with USAO, are responsible for ensuring LDA compliance  The Secretary of the Senate and the Clerk of the House notify lobbyists or lobbying firms in writing that they are not complying with the LDA reporting  Subsequently, they refer those lobbyists who fail to provide an appropriate response to USAO  USAO researches these referrals and sends additional noncompliance notices to the lobbyists or lobbying firms, requesting that they file reports or terminate their registration  If USAO does not receive a response after 60 days, it decides whether to pursue a civil or criminal case against each noncompliant lobbyist  A civil case could lead to penalties up to $200,000 for each violation, while a criminal case—usually pursued if a lobbyist’s noncompliance is found to be knowing and corrupt—could lead to a maximum of 5 years in prison  Generally, under the LDA, within 45 days of being employed or retained to make a lobbying contact on behalf of a client, the lobbyist must register by filing an LD-1 form with the Secretary of the Senate and the Clerk of the House  Thereafter, the lobbyist must file quarterly disclosure (LD-2) reports detailing the lobbying activities  Of the 3,433 new registrations we identified for the third and fourth quarters of 2016 and the first and second quarters of 2017, we matched 2,995 of them (87 2 percent) to corresponding LD-2 reports filed within the same quarter as the registration  These results are consistent with the findings we have reported in prior reviews  We used the House lobbyists’ disclosure database as the source of the reports  We also used an electronic matching algorithm that allows for misspellings and other minor inconsistencies between the registrations and reports  Figure 2 shows lobbyists filed disclosure reports as required for most new lobbying registrations from 2010 through 2017  For selected elements of lobbyists’ LD-2 reports that can be generalized to the population of lobbying reports, our findings have generally been consistent from year to year  Most lobbyists reporting $5,000 or more in income or expenses provided written documentation to varying degrees for the reporting elements in their disclosure reports  Figure 3 shows that for most LD-2 reports, lobbyists provided documentation for income and expenses for sampled reports from 2010 through 2017  However, in recent years our findings showed some variation in the estimated percentage of lobbyists who have reports with documentation for income and expense supporting lobbying activities  Specifically, our estimate for 2017 (99 percent) represents a statistically significant increase from 2016  Figure 4 shows that for some LD-2 reports, lobbyists did not round their income or expenses as the guidance requires  In 2017, we estimate 25 percent of reports did not round reported income or expenses according to the guidance  We have found that rounding difficulties have been a recurring issue on LD-2 reports from 2010 through 2017  As we previously reported, several lobbyists who listed expenses told us that based on their reading of the LD-2 form they believed they were required to report the exact amount  While this is not consistent with the LDA and the guidance, this may be a source of some of the confusion regarding rounding errors  In 2016, the guidance was updated to include an additional example about rounding expenses to the nearest $10,000  In 2017, 11 percent of lobbyists reported $10,000 or more in income or expenses  The LDA requires lobbyists to disclose lobbying contacts made with federal agencies on behalf of the client for the reporting period  This year, of the 98 LD-2 reports in our sample, 51 reports disclosed lobbying activities at federal agencies  Of those, lobbyists provided documentation for all lobbying activities at executive branch agencies for 34 LD-2 reports  Figures 5 through 8 show that lobbyists for most LD-2 reports provided documentation for selected elements of their LD-2 reports from 2010 through 2017  Lobbyists for an estimated 93 percent of LD-2 reports filed year-end 2016 for all lobbyists listed political contributions on the report as required  Figure 9 shows that lobbyists for most lobbying firms filed contribution reports as required in our sample from 2010 through 2017  All individual lobbyists and lobbying firms reporting lobbying activity are required to file LD-203 reports semiannually, even if they have no contributions to report, because they must certify compliance with the gift and travel rules  The LDA requires a lobbyist to disclose previously held covered positions in the executive or legislative branch, such as high ranking agency officials and congressional staff, when first registering as a lobbyist for a new client  This can be done either on a new LD-1 or on the quarterly LD- 2 filing when added as a new lobbyist  This year, we estimate that 15 percent of all LD-2 reports may not have properly disclosed previously held covered positions as required  As in our other reports, some lobbyists were still unclear about the need to disclose certain covered positions, such as paid congressional internships or certain executive agency positions  Figure 10 shows the extent to which lobbyists may not have properly disclosed one or more covered positions as required from 2010 through 2017  Lobbyists amended 15 of the 98 LD-2 disclosure reports in our original sample to change previously reported information after we contacted them  Of the 15 reports, 7 were amended after we notified the lobbyists of our review, but before we met with them  An additional 8 of the 15 reports were amended after we met with the lobbyists to review their documentation  We consistently find a notable number of amended LD-2 reports in our sample each year following notification of our review  This suggests that sometimes our contact spurs lobbyists to more closely scrutinize their reports than they would have without our review  Table 1 lists reasons lobbying firms in our sample amended their LD-1 or LD-2 reports  As part of our review, we compared contributions listed on lobbyists’ and lobbying firms’ LD-203 reports against those political contributions reported in the Federal Election Commission (FEC) database to identify whether political contributions were omitted on LD-203 reports in our sample  The sample of LD-203 reports we reviewed contained 80 reports with contributions and 80 reports without contributions  We estimate that overall for 2017, lobbyists failed to disclose one or more reportable contributions on 12 percent of reports  Additionally, ten LD-203 reports were amended in response to our review  For this element in prior reports, we reported an estimated minimum percentage of reports based on a one-sided 95 percent confidence interval rather than the estimated proportion as shown here  Estimates in the table have a maximum margin of error of 11 percentage points  The year to year differences are not statistically significant  Table 2 illustrates that from 2010 through 2017 most lobbyists disclosed FEC reportable contributions on their LD-203 reports as required  As part of our review, 88 different lobbying firms were included in our 2017 sample of LD-2 disclosure reports  Consistent with prior reviews, most lobbying firms reported that they found it “very easy” or “somewhat easy” to comply with reporting requirements  Of the 88 different lobbying firms in our sample, 34 reported that the disclosure requirements were “very easy,” 40 reported them “somewhat easy,” and 13 reported them “somewhat difficult” or “very difficult” (see figure 11)  Most lobbying firms we surveyed rated the definitions of terms used in LD-2 reporting as “very easy” or “somewhat easy” to understand with regard to meeting their reporting requirements  This is consistent with prior reviews  Figures 12 through 16 show what lobbyists reported as their ease of understanding the terms associated with LD-2 reporting requirements from 2012 through 2017  U S  Attorney’s Office (USAO) officials stated that they continue to have sufficient personnel resources and authority under the LDA to enforce reporting requirements  This includes imposing civil or criminal penalties for noncompliance  Noncompliance refers to a lobbyist’s or lobbying firm’s failure to comply with the LDA  However, USAO noted that the number of assigned personnel has decreased due to attrition  USAO officials stated that lobbyists resolve their noncompliance issues by filing LD-2, LD-203, or LD-2 amendments, or by terminating their registration, depending on the issue  Resolving referrals can take anywhere from a few days to years, depending on the circumstances  During this time, USAO creates summary reports from its database to track the overall number of referrals that are pending or become compliant as a result of the lobbyist receiving an e-mail, phone call, or noncompliance letter  Referrals remain in the pending category until they are resolved  The pending category is divided into the following areas: “initial research for referral,” “responded but not compliant,” “no response/waiting for a response,” “bad address,” and “unable to locate ” The USAO attempts to review and update all pending cases every six months  USAO focuses its enforcement efforts primarily on the “responded but not compliant” and the “no response/waiting for a response” groups  Officials told us that, if the USAO, after several unsuccessful attempts, has been unsuccessful in contacting the non-compliant firm or its lobbyist, USAO confers with both the Secretary of the Senate and the Clerk of the House to determine whether further action is needed  In the cases where the lobbying firm is repeatedly referred for not filing disclosure reports but does not appear to be actively lobbying, USAO suspends enforcement actions  USAO officials reported they will continue to monitor these firms and will resume enforcement actions if required  USAO received 3,213 referrals from both the Secretary of the Senate and the Clerk of the House for failure to comply with LD-2 reporting requirements cumulatively for filing years 2009 through 2015  Table 4 shows the number and status of the referrals received and the number of enforcement actions taken by USAO to bring lobbying firms into compliance  Enforcement actions include USAO attempts to bring lobbyists into compliance through letters, e-mails, and calls  About 45 percent (1,450 of 3,213) of the total referrals received are now compliant because lobbying firms either filed their reports or terminated their registrations  In addition, some of the referrals were found to be compliant when USAO received the referral  Therefore, no action was taken  This may occur when lobbying firms respond to the contact letters from the Secretary of the Senate and the Clerk of the House after USAO received the referrals  About 55 percent (1,752 of 3,213) of referrals are pending further action because USAO could not locate the lobbying firm, did not receive a response from the firm after an enforcement action, or plans to conduct additional research to determine if it can locate the lobbying firm  The remaining 11 referrals did not require action or were suspended because the lobbyist or client was no longer in business or the lobbyist was deceased  LD-203 referrals consist of two types: (1) LD-203(R) referrals represent lobbying firms that have failed to file LD-203 reports for their lobbying firm and (2) LD-203 referrals represent the lobbyists at the lobbying firm who have failed to file their individual LD-203 reports as required  USAO received 2,255 LD-203(R) referrals (cumulatively from 2009 through 2015) and 3,716 LD-203 referrals (cumulatively from 2009 through 2014 from the Secretary of the Senate and the Clerk of the House for lobbying firms and lobbyists for noncompliance with reporting requirements)  LD- 203 referrals are more complicated than LD-2 referrals because both the lobbying firm and the individual lobbyists within the firm are each required to file a LD-203  Lobbyists employed by a lobbying firm typically use the firm’s contact information and not the lobbyists’ personal contact information  This makes it difficult to locate a lobbyist who is not in compliance and may have left the firm  USAO officials reported that, while many firms have assisted USAO by providing contact information for lobbyists, they are not required to do so  According to officials, USAO has difficulty pursuing LD-203 referrals for lobbyists who have departed a firm without leaving forwarding contact information with the firm  While USAO utilizes web searches and online databases, including social media, to find these missing lobbyists, it is not always successful  Table 5 shows the status of LD-203 (R) referrals received and the number of enforcement actions taken by USAO to bring lobbying firms into compliance  A little more than 44 percent (998 of 2,255) of the lobbying firms referred by the Secretary of the Senate and Clerk of the House for noncompliance from calendar years 2009 through 2015 are now considered compliant because firms either filed their reports or terminated their registrations  About 56 percent (1,251 of 2,255) of the referrals are pending further action  Table 6 shows that USAO received 3,716 LD-203 referrals from the Secretary of the Senate and Clerk of the House for lobbyists who failed to comply with LD-203 reporting requirements for calendar years 2009 through 2014  It also shows the status of the referrals received and the number of enforcement actions taken by USAO to bring lobbyists into compliance  In addition, table 6 shows that about 47 percent (1,741 of 3,716) of the lobbyists had come into compliance by filing their reports or are no longer registered as a lobbyist  About 53 percent (1,966 of 3,716) of the referrals are pending further action because USAO could not locate the lobbyist, did not receive a response from the lobbyist, or plans to conduct additional research to determine if it can locate the lobbyist  Table 7 shows that USAO received LD-203 referrals from the Secretary of the Senate and the Clerk of the House for 4,991 lobbyists who failed to comply with LD-203 reporting requirements for any filing year from 2009 through 2014  It also shows the status of compliance for individual lobbyists listed on referrals to USAO  About 51 percent (2,526 of 4,991) of the lobbyists had come into compliance by filing their reports or are no longer registered as a lobbyist  About 50 percent (2,465 of 4,991) of the referrals are pending action because USAO could not locate the lobbyists, did not receive a response from the lobbyists, or plans to conduct additional research to determine if it can locate the lobbyists  USAO officials said that many of the pending LD-203 referrals represent lobbyists who no longer lobby for the lobbying firms affiliated with the referrals, even though these lobbying firms may be listed on the lobbyist’s LD-203 report  According to USAO officials, lobbyists and lobbying firms who repeatedly fail to file reports are labeled chronic offenders and referred to one of the assigned attorneys for follow-up  USAO also receives complaints regarding lobbyists who are allegedly lobbying but never filed an LD-203  USAO officials added that USAO monitors and investigates chronic offenders to ultimately determine the appropriate enforcement actions, which may include settlement or other civil actions  In regards to the four active cases involving chronic offenders they reported to us in 2016, USAO officials noted that the agency is investigating one case, negotiating a resolution that will include a civil penalty in another case, and closing two other investigations without further action  In addition, USAO is reviewing its records to identify additional chronic offenders for further action due to noncompliance  We provided a draft of this report to the Department of Justice for review and comment  The Department of Justice provided technical comments, which we incorporated as appropriate  We are sending copies of this report to the Attorney General, Secretary of the Senate, Clerk of the House of Representatives, and interested congressional committees and members  In addition, this report is 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) 512-2717 or jonesy@gao gov  Contact points for our Offices of Congressional Relations and 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 IV  Our objectives were to determine the extent to which lobbyists are able to demonstrate compliance with the Lobbying Disclosure Act of 1995, as amended (LDA) by providing documentation to support information contained on registrations and reports filed under the LDA; to identify challenges and potential improvements to compliance, if any; and to describe the resources and authorities available to the U S  Attorney’s Office for the District of Columbia (USAO), its role in enforcing LDA compliance, and the efforts it has made to improve LDA enforcement  We used information in the lobbying disclosure database maintained by the Clerk of the House of Representatives (Clerk of the House)  To assess whether these disclosure data were sufficiently reliable for the purposes of this report, we reviewed relevant documentation and consulted with knowledgeable officials
Report 2: S  Radiation Workers and Veterans (Million Person Study)—an ongoing study headed by the National Council on Radiation Protection and Measurements  DOE also provided funding for this study  In fiscal years 2012 through 2016, the seven agencies who provided funding for research on health effects of low-dose radiation collectively decreased their annual funding obligations in this area by 48 percent, from $57 9 million in fiscal year 2012 to $30 4 million in fiscal year 2016  DOE accounted for a large portion of this overall decrease in annual funding  Specifically, over this 5-year period, DOE reduced its annual funding obligations for this area of research by 45 percent—from $32 6 million in fiscal year 2012 to $18 0 million in fiscal year 2016  According to DOE, the decrease was primarily due to DOE’s reduction in funding for its Low Dose Radiation Research Program  According to DOE officials, decreases in funding for the program reflected a shift toward bioenergy and environmental research  Similarly, over the 5-year period, NIH’s funding for low-dose radiation research decreased by 48 percent—from $23 1 million in fiscal year 2012 to $12 0 million in fiscal year 2016  NIH officials explained that funding levels for a particular disease or research area can fluctuate depending on several factors, including the number and quality of research proposals submitted and the outcome of NIH’s peer reviews of the proposals, as well as the overall research budget  The seven agencies that funded research on health effects of low-dose radiation for fiscal years 2012 through 2016 collaborated on particular research projects through various mechanisms, including joint funding of individual projects, but they did not use a collaborative mechanism to address overall research priorities  As previously noted, the 2016 report of DOE’s Biological and Environmental Research Advisory Committee provided information about research needs in low-dose radiation and found that further research could decrease uncertainty in predicting cancer risk from low-dose radiation  The report stated that other agencies—including NRC, NIH, EPA, DOD, and NASA—could benefit from the reduction in uncertainty that could be obtained by this research  In our September 2017 report, we recommended that the Secretary of Energy lead the development of a mechanism for interagency collaboration to determine roles and responsibilities for addressing priorities related to research on the health effects of low-dose radiation  We made this recommendation because our previous work has shown that collaborative mechanisms can serve multiple purposes, such as leading interagency efforts to develop and coordinate sound science and technology policies across the federal government  Although collaborative mechanisms differ in complexity and scope, they all benefit from certain key features, such as leadership  We directed this recommendation to DOE for several reasons  In the past, DOE took a leading role in advocating for greater communication and coordination between the fields of radiation biology and epidemiology  In addition, DOE is the federal agency that currently has primary responsibility under the Atomic Energy Act of 1954 for research related to the protection of health during activities that can result in exposure to radiation  DOE is well positioned to lead an effort to ensure that federal agencies have a mechanism for interagency collaboration to address overall research priorities related to low-dose radiation health effects because of the agency’s past experience as a leader in this area of research  Such an effort could help DOE and the collaborating agencies determine roles and responsibilities, including leadership when addressing shared research priorities  DOE did not agree with our recommendation  In particular, DOE stated that EPA and NRC also have legal mandates to research low-dose radiation exposure and that these agencies establish their research priorities in accordance with their respective budget authorities and recommendations from independent advisory bodies  DOE stated that as a result, it would not be appropriate for DOE to lead the development of a mechanism for interagency collaboration  We believe that DOE’s concerns stem from a misinterpretation of our recommendation, and we made several changes to our report and our recommendation to clarify DOE’s role  We noted that we did not recommend that a mechanism for interagency collaboration serve as a replacement for agencies’ legal mandates, budget authorities, and recommendations from independent advisory bodies  Instead, this mechanism would help agencies address shared research priorities  In making our recommendation, we did not specify the coordinating mechanism that agencies should use and instead left it to DOE to lead the development of an appropriate mechanism  We continue to believe that an interagency coordination mechanism for low-dose research is needed and that DOE is in the best position to lead agencies in developing the most appropriate mechanism  Chairman Weber, Ranking Member Veasey, and Members of the Subcommittee, this concludes my prepared statement  I would be pleased to respond to any questions that you may have at this time  If you or your staff have any questions about this statement, please contact John Neumann at (202) 512-3841 or neumannj@gao gov  In addition, contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this statement  Individuals who made key contributions to the report on which this testimony is based include Allen Chan, Kendall Childers, Joseph Cook, Richard Johnson, Cynthia Norris, Josie Ostrander, Amber Sinclair, and Jack Wang  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: No federal law requires testing of drinking water for lead in schools that receive water from public water systems, although these systems are regulated by the EPA. Lead can leach into water from plumbing materials inside a school. The discovery of toxic levels of lead in water in Flint, Michigan, in 2015 has renewed awareness about the danger lead exposure poses to public health, especially for children. GAO was asked to review school practices for lead testing and remediation. This report examines the extent to which (1) school districts are testing for, finding, and remediating lead in drinking water; (2) states are supporting these efforts; and (3) federal agencies are supporting state and school district efforts. GAO administered a web-based survey to a stratified, random sample of 549 school districts, the results of which are generalizable to all school districts. GAO visited or interviewed officials with 17 school districts with experience in lead testing, spread among 5 states, selected for geographic variation. GAO also interviewed federal and state officials and reviewed relevant laws and documents. An estimated 43 percent of school districts, serving 35 million students, tested for lead in school drinking water in 2016 or 2017, according to GAO's nationwide survey of school districts. An estimated 41 percent of school districts, serving 12 million students, had not tested for lead. GAO's survey showed that, among school districts that did test, an estimated 37 percent found elevated lead (lead at levels above their selected threshold for taking remedial action.) (See figure.) All school districts that found elevated lead in drinking water reported taking steps to reduce or eliminate exposure to lead, including replacing water fountains, installing filters or new fixtures, or providing bottled water. According to the Environmental Protection Agency (EPA), at least 8 states have requirements that schools test for lead in drinking water as of 2017, and at least 13 additional states supported school districts' voluntary efforts with funding or in-kind support for testing and remediation. In addition, the five states GAO visited provided examples of technical assistance to support testing in schools. EPA provides guidance and other resources to states and school districts regarding testing and remediating lead in drinking water, and the Department of Education (Education) provides some of this information on its websites. School district officials that used EPA's written guidance said they generally found it helpful. Although EPA guidance emphasizes the importance of addressing elevated lead levels, GAO found that some aspects of the guidance, such as the threshold for taking remedial action, were potentially misleading and unclear, which can put school districts at risk of making uninformed decisions. In addition, many school districts reported a lack of familiarity with EPA's guidance, and their familiarity varied by region of the country. Education and EPA do not regularly collaborate to support state and school district efforts on lead in drinking water, despite agreeing to do so in a 2005 memorandum of understanding. Such collaboration could encourage testing and ensure that more school districts will have the necessary information to limit student and staff exposure to lead. GAO is making seven recommendations, including that EPA update its guidance on how schools should determine lead levels requiring action and for EPA and Education to collaborate to further disseminate guidance and encourage testing for lead. EPA and Education agreed with the recommendations.

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



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

Report 1: According to Education, 50 3 million students were enrolled in more than 98,000 public elementary and secondary schools nationwide in the 2014- 2015 school year  These individual public schools are overseen by approximately 16,000 local educational agencies (referred to in this report as school districts) which are, in turn, overseen and supported by state educational agencies  School districts can range in size from one school (for example, in rural areas) to hundreds of schools in large urban and suburban areas  For example, the 100 largest districts in the United States together have approximately 16,000 schools and enroll about 11 million students  In addition, charter schools are public schools created to achieve a number of goals, such as encouraging innovation in public education  Oversight of charter schools can vary, with some states establishing charter schools as their own school district and other states allowing charter schools to be either a distinct school district in themselves or part of a larger district  Charter schools are often responsible for their own facilities; these may be located in non-traditional school buildings, and may lease part or all of their space  Typically, state educational agencies are responsible for administering state and federal education laws, disbursing state and federal funds, and providing guidance to school districts and schools across the state  State educational agencies frequently provide funds for capital improvements to school facilities, which school districts may use to address issues related to lead in school drinking water, among other things  Different state agencies, including agencies for education, health, and environmental protection, may provide school districts with guidance on testing and remediation of lead in school drinking water  Within a school district, responsibility for water management may be held by individuals in different positions, such as facilities managers or environmental specialists  Lead is a neurotoxin that can accumulate in the body over time with long- lasting effects, particularly for children  According to the CDC, lead in drinking water can cause health effects if it enters the bloodstream and causes an elevated blood lead level  Lead in a child’s body can slow down growth and development, damage hearing and speech, and lead to learning disabilities  For adults, lead can have detrimental effects on cardiovascular, renal, and reproductive systems and can prompt memory loss  In pregnant women, lead stored in bones (due to lead exposure prior to and during pregnancy) can be released as maternal calcium used to form the bones of the fetus, reduce fetal growth, and increase risk of miscarriage and stillbirth  The presence of lead in the bloodstream can disappear relatively quickly, but bones can retain the toxin for decades  Lead in bones may be released into the blood, re-exposing organ systems long after the original exposure  The concentration of lead, total amount consumed, and duration of exposure influence the severity of health effects  The health consequences of lead exposure can differ from person to person and are affected by the cumulative dose of lead and the vulnerability of the individual person regardless of whether the lead exposure is from food, water, soil, dust, or air  Although there are medical therapies to remove lead from the body, they cannot undo the damage it has already caused  For these reasons, EPA, CDC, and others recommend the prevention of lead exposure to the extent possible, recognizing that lead is widespread in the environment  The SDWA authorizes EPA to set standards for drinking water contaminants in public water systems  For a given contaminant the act requires EPA to first establish a maximum contaminant level goal, which is the level at which no known or anticipated adverse effects on the health of persons occur and which allows an adequate margin of safety  EPA must then set an enforceable maximum contaminant level as close to the maximum contaminant level goal as is feasible, or require water systems to use a treatment technique to prevent known or anticipated adverse effects on the health of persons to the extent feasible  Feasible means the level is achievable using the best available technology or treatment technique  In 1991 EPA issued the LCR, which it revised in 2000 and 2007, establishing regulations for water systems covered by the SDWA  Lead concentration in water is typically measured in micrograms of lead per liter of water (also referred to as “parts per billion” or ppb)  The rule established a maximum contaminant level goal of zero, because EPA concluded that there was no established safe level of lead exposure  EPA decided not to establish an enforceable maximum contaminant level, concluding that any level reasonably close to the goal would result in widespread noncompliance, and therefore was not feasible  Instead, the rule established an “action level” of 15 micrograms of lead per liter (15 ppb) in a one liter sample of tap water, a level that EPA believed was generally representative of what could be feasibly achieved at the tap  The action level is a screening tool for determining when certain follow-up actions are needed, which may include corrosion control treatment, public education, and lead service line replacement  Sample results that exceed the lead action level do not by themselves constitute violations of the rule  If the lead action level is exceeded in more than 10 percent of tap water samples collected during any monitoring period (that is, if the 90th percentile level is greater than the action level), a water system must take actions to reduce exposure  Several amendments to the SDWA are relevant to testing for lead in school drinking water  In 1988, the SDWA was amended by the Lead Contamination Control Act (LCCA), which banned the manufacture and sale of drinking water coolers with lead-lined tanks containing more than 8 percent lead; the statute defined a drinking water cooler as containing 8 percent lead or less as “lead-free ” The LCCA also required states to establish testing and remediation programs for schools  However, in 1996 a federal circuit court held that this requirement was unconstitutional  In 2011, Congress passed the Reduction of Lead in Drinking Water Act, which amended the SDWA by lowering the maximum allowable lead content in “lead-free” plumbing materials such as pipes  This provision became effective on January 4, 2014  In 2016, Congress passed the Water Infrastructure Improvements for the Nation Act which, among other things, amended the SDWA, to establish a grant program for states to assist school districts in voluntary testing for lead contamination in drinking water at schools  As a condition of receiving funds, school districts are required to test for lead using standards that are at least as stringent as those in federal guidance for schools  In March 2018, Congress appropriated $20 million to EPA for this grant program  Lead can enter drinking water when service lines or plumbing fixtures that contain lead corrode, especially where the water has high acidity or low mineral content  According to EPA, lead typically enters school drinking water as a result of interaction with lead-containing plumbing materials and fixtures within the building  Although lead pipes and lead solder were not commonly used after 1986, water fountains and other fixtures were allowed to have up to 8 percent lead until 2014, as previously mentioned  Consequently, both older and newer school buildings can have lead in drinking water  Some water in a school building is not for consumption, such as water from a janitorial sink or garden hose, so lead in these water sources presents less risk to students  (See fig  1 ) The best way to know if a school’s water is contaminated with lead is to test the water after it has gone through a school’s pipes, faucets, and other fixtures  To facilitate testing efforts, EPA suggests that schools implement programs for reducing lead in drinking water and developed the 3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance (3Ts guidance) in 2006, which provides information on: (1) training school officials about the potential causes and health effects of lead in drinking water; (2) testing drinking water in schools to identify potential problems and take corrective actions as necessary; and (3) telling students, parents, staff, and the larger community about monitoring programs, potential risks, the results of testing, and remediation actions  The purpose of the 3Ts guidance is to help schools minimize students’ and staffs’ exposure to lead in drinking water  The guidance provides recommendations and suggestions for how to address lead in school drinking water, but does not establish requirements for schools to follow  According to the guidance, if school districts follow the procedures described in guidance, they will be assured their facilities do not have elevated levels of lead in their drinking water  The guidance recommends taking 250 milliliter samples of water from every drinking water source in a school building and having the samples analyzed by an accredited laboratory  Based on the test results of the samples, the guidance recommends remedial action if the samples are found to have an elevated concentration of lead, which is identified by using an action level  While school districts may have discretion to set their own action level, the 3Ts guidance strongly recommends taking remedial action if a school district finds lead at or above 20 ppb in a 250 milliliter sample of water  School districts can take a variety of actions including replacing pipes, replacing fixtures, running water through the system before consumption (known as flushing), or providing bottled water  However, since the amount of lead in school drinking water may change over time for a variety of reasons—for example, the natural aging of plumbing materials or a disturbance nearby, such as construction—the results obtained by one test are not necessarily indicative of results which may be obtained in the future  With no federal law requiring testing for lead in school drinking water, federal agencies play a limited role: Education’s mission includes fostering educational excellence and promoting student achievement, and the agency disseminates guidance to states and school districts about lead in school drinking water, but does not administer any related grants  EPA’s Office of Ground Water and Drinking Water provides voluntary guidance to schools on how to test for and remediate lead in school drinking water, as part of EPA’s mission to inform the public about environmental risks  In addition, EPA’s Office of Children’s Health Protection is responsible for working with EPA’s 10 regional offices via their healthy schools coordinators, who communicate with schools and help to disseminate the 3Ts guidance  CDC administers the School Health Policies and Practices Study, a periodic survey to monitor national health objectives that pertain to schools and school districts  The 2016 data, the most recent available, provide information on the number of school districts that periodically test for lead in their drinking water  Under the 2005 memorandum signed by these three agencies to encourage lead testing and remediation in schools, Education’s role includes working with EPA and other groups to encourage testing, and disseminating materials to schools  EPA agreed to update guidance for schools, and provide tools to facilitate testing for lead in school drinking water  CDC’s role includes identifying public health organizations to work with and facilitating dissemination of materials to state health organizations  Lead in School Drinking Water Survey Results at a Glance An estimated 43 percent of school districts tested for lead in school drinking water, but 41 percent did not, and 16 percent did not know  o Some districts tested drinking water in all sources of consumable water in all of their schools, while other school districts tested only some sources  o Among the reasons for not testing, school districts said they either did not identify a need to test or were not required to do so  Of those that tested, an estimated 37 percent of school districts found elevated lead levels—levels of lead above the district’s threshold for taking remedial action—in school drinking water  o School districts varied in terms of the threshold they used, with some using 15 ppb or 20 ppb and others using a lower threshold  School districts varied in whether they tested for lead in school drinking water and whether they discovered elevated levels of lead  For example, an estimated 88 percent of the largest 100 school districts tested compared with 42 percent of other school districts  All school districts that found elevated lead reported taking steps to reduce or eliminate the lead, including replacing water fountains or providing bottled water  Nationwide, school districts vary in terms of whether they have tested for lead in school drinking water, with many not testing  According to our survey of school districts, an estimated 43 percent tested for lead in school drinking water in at least one school in the last 12 months, while 41 percent had not tested  An estimated 35 million students were enrolled in districts that tested as compared with 12 million students in districts that did not test  An estimated 16 percent of school districts, enrolling about 6 million students, reported that they did not know whether they had tested or not  (See fig  2 ) Of school districts that tested for lead in school drinking water, some tested all consumable water sources in all of their schools, while others may have only tested some sources in all schools or all sources in some schools  Among the reasons provided by survey respondents for not testing in all schools, some said the age of the building was the primary consideration  For example, an official in one school district we visited told us they began testing in buildings constructed before 1989, but after receiving results that some water sources had elevated lead levels, the district decided to test all of their school buildings  Other reasons reported for testing some, but not all, schools included testing schools only when a complaint about discolored water was received or testing only new schools or schools that were renovated  In addition, school districts varied in whether they sampled from every consumable water source, or just some of the sources, in their schools  For example, one district official told us they took one sample from each type of water fountain in each school, assuming that, if a sampled fountain was found to have an elevated level of lead, then all of the other fountains of that type would also have elevated lead levels  However, EPA’s 3Ts guidance recommends that every water source that is regularly used for drinking or cooking be sampled  Further, stakeholders and environmental and educational officials we interviewed said that results from one water fountain, faucet, or any other consumable water source cannot be used to predict whether lead will be found in other sources  In our survey, the median amount spent by school districts to test for lead in school drinking water during the past 12 months varied substantially, depending on the number of schools in which tests were conducted (see table 1)  School districts may have paid for services such as collecting water samples, analyzing and reporting results, and consultants  For example, an official in a small, rural school district—with three schools housed in one building—told us his district spent $180 to test all eight fixtures  In contrast, officials in a large, urban school district told us they spent about $2 1 million to test over 11,000 fixtures in over 500 schools  Some school districts, especially larger ones, incurred costs to hire consultants to advise them and help design a plan to take samples, among other things  EPA’s 3Ts guidance recommends determining how to communicate information about lead testing programs with parents, governing officials, and other stakeholders before testing  Of school districts that reported testing for lead in school drinking water in our survey, an estimated 76 percent informed their local school board and 59 percent informed parents about their plans to test; similar percentages provided information about the testing results  We identified a range of approaches to communicating testing efforts in the 17 school districts we interviewed  Some school districts reported issuing press releases, putting letters in multiple languages in students’ backpacks, sending emails to parents, holding public meetings, and releasing information through social media  Before testing, one district created a website with a list of dates when it planned to test the drinking water in every one of its schools  In contrast, other school districts communicated with parents and the press only upon request  Officials in one district we visited said they did not post lead testing results on their website, because they wanted to avoid causing undue concern, adding that “more information isn’t necessarily better, especially when tests showed just trace amounts of lead ” School districts generally have discretion to determine how frequently they test for lead in school drinking water except when prescribed in state law, and most school districts responding to our survey had no specific schedule for recurring testing  Specifically, an estimated: 27 percent of school districts plan to test “as needed,” 25 percent have no schedule to conduct recurring tests, and 15 percent do not know  The remaining school districts reported a range of frequencies for conducting additional tests or said they were developing a schedule to conduct tests on a recurring basis  School district officials and stakeholders we interviewed told us that it is important to test for lead in drinking water on a recurring basis, because lead can leach into school drinking water at any time  In our survey, we asked school districts reporting that they had not tested for lead in school drinking water in the last 12 months (41 percent of districts) to provide us with one or more reasons why they had not tested  Of these school districts, an estimated 53 percent reported that they did not identify a need to test and 53 percent reported they were not required to test (see fig  3)  Of school districts that reported testing for lead in school drinking water, an estimated 37 percent of districts found elevated levels of lead in school drinking water, while 57 percent of districts did not find lead (see fig  4)  Of those that found lead in drinking water, most found lead above their selected action level in some of their schools, while some districts found lead above their action level in all of their schools  For example, officials in one large school district told us they tested over 10,000 sources of water, including drinking fountains and food preparation fixtures, and found that over 3,600 water sources had lead at or above the district’s action level of 15 parts per billion (ppb)  The findings resulted in extensive remediation efforts, officials said  Further, district officials reported different action levels they used to determine when to take steps such as replacing a water fountain or installing a filter  School districts generally may select their own action level, resulting in different action levels between districts  Of school districts that reported testing for lead in school drinking water, an estimated 44 percent set an action level between 15 ppb and 19 ppb  The action levels chosen by the rest of the school districts ranged from a low of 1 ppb whereby action would be taken if any lead at all was detected to a high 20 ppb where action would be taken if lead was found at or above 20 ppb  (See appendix II for the estimated percentage of school districts that set other action levels ) Though fewer than half of school districts reported testing for lead in school drinking water, our analysis of school districts’ survey responses shows that these estimates varied depending on the size and population density of the district as well as its geographic location  For example, among the largest 100 school districts, an estimated 88 percent reported they had tested for lead in school drinking water in at least one school in the last 12 months compared with 42 percent of all other districts nationwide  An estimated 59 percent of the largest 100 school districts that tested discovered elevated levels of lead compared to 36 percent of all other districts that tested (see table 2)  In addition, an estimated 86 percent of school districts in the Northeast region of the United States tested for lead in school drinking water, compared to less than half of school districts in other geographic regions  Similarly, about half of school districts in the Northeast and about 8 percent in the South found elevated levels of lead, compared to their selected action level  (See fig  5 ) In our survey, every school district that reported finding lead in school drinking water above their selected action level reported taking steps to reduce or eliminate the lead  For example, an estimated 71 percent said they replaced water fountains, 63 percent took water fountains out of service without replacing them, and 62 percent flushed the school’s water system (see fig  6)  School districts officials we interviewed told us they took a range of remedial actions generally consistent with those reported to us in our survey  For example, an official in one district told us that 129 of the 608 fixtures tested above the district’s action level of “any detectable level ” He said they installed filters on all of the 106 sink faucets with elevated lead and replaced all of the 23 drinking fountains with elevated lead  The district official explained that they re-tested fixtures after the filters and new fountains were installed, and did not detect any lead in their drinking water  Officials in another school district told us that approximately 3,600 of their fixtures were found to have lead above their action level of 15 ppb  They told us the district turned off the water at the affected fixtures as an interim measure and provided bottled water to students and staff  Though they had not yet finalized their plans at the time of our interview, they said they were planning to replace the fixtures and replace old pipes with new pipes  District officials said they plan to pay for their remediation efforts using local capital improvement funds from a recently-approved bond initiative  Similar to the cost of testing, the median amount spent by school districts to remediate lead in school drinking water during the past 12 months varied substantially, depending on the number of schools in which a district took action to remediate lead (see table 3)  The median expenditure for school districts taking action in one to four schools was $4,000 compared to a median expenditure for school districts taking action in 51 or more schools of $278,000  EPA regional officials provided examples of eight states that have requirements for schools to test for lead in drinking water as of September 2017: California, Illinois, Maryland, Minnesota, New Jersey, New York, Virginia, and the District of Columbia  State requirements differ in terms of which schools are included, testing protocols, communicating results, and funding  (See fig  7 ) (For a list of testing components for the eight states, see appendix IV ) According to stakeholders we interviewed, most state legislation on testing for lead in school drinking water has been introduced in the past 2 years  Of the eight states, three states have completed one round of required testing, while other states are in the early stages of implementation or have not yet begun, according to state officials  School districts in Illinois, New Jersey, and New York completed a round of testing for lead in school drinking water by December 2017  Testing in the District of Columbia was in progress as of April 2018  Minnesota requires school districts to develop a plan to test by July 2018 and California requires that water systems sample all covered public schools in their service area by July 2019  According to state officials, schools in Maryland must test by July 2020  In Virginia, no timeline for testing is indicated in the requirement  In addition, requirements in these eight states vary in terms of covered schools and frequency of testing  For example, in Maryland, all schools, including charter and private schools, are required to test their water for lead by July 2020 and must re-test every 3 years  After regulations were approved in July 2016, New Jersey required testing within a year in all traditional public schools, charter schools, and certain private schools, and re-testing every 6 years, according to state officials  Illinois’ requirement is for public and private elementary schools constructed before 2000 to test their drinking water for lead, and does not mandate re- testing  Seven of the eight states include at least some charter schools in their testing requirements (New York does not)  State testing requirements also differ in terms of action level, sample sizes, and number of samples, according to state documents  States can choose their own lead threshold or action level for remediation, and the eight states have chosen levels ranging from any detectable level in Illinois to 20 ppb in Maryland  Six of the eight states have chosen to use 250 milliliter samples of water, while California is using a one liter sample size, and Virginia delegates to school districts to choose their action level and sample size  Some states specify that all drinking water sources in a building must be tested, such as in New York and New Jersey, or allow a smaller number of samples to be tested, such as in California, which recommends that water systems take between one and five samples per school  To implement its testing requirement, the District of Columbia has installed filters in all school drinking water sources, and plans to test the filtered water from each fixture for elevated lead annually  The responsibility for the costs of testing and remediation also differ by state  According to state officials, in Minnesota, the costs of testing may be eligible for reimbursement from the state, and in the District of Columbia, the Department of General Services is responsible for the cost  California requires that public water systems cover the cost of testing for all public schools in their jurisdiction  In all other states we looked at, schools or school districts are at least partially responsible for the costs of testing  Additionally, most schools or school districts are responsible for the costs of remediation, although Minnesota, New York, and the District of Columbia will provide funds to help with the costs of remediation as well  Seven of the eight state requirements have a provision for communicating the results of lead sampling and testing in schools  For example, Minnesota requires all test results be made public and New York requires that results be communicated to students’ families  Maryland and New Jersey require that results above the action level be reported to the responsible state agency, such as the Department of the Environment or the Department of Education, and that sample results that find elevated levels of lead be communicated to students’ families  Illinois requires that all results be made available to families and that individual letters to families also be sent if lead levels over 5 ppb are found  In contrast, Virginia does not include a provision to communicate testing results in its testing requirement for schools  According to stakeholders and state officials we interviewed, states have several other common issues to consider in implementing a state testing and remediation program  First, states need to ensure that their efforts, which can be significant given the thousands of schools that operate in each state, can be completed with limited resources and by a legislated deadline  Second, coordination between relevant state agencies, which will vary by state, may be challenging  Because of the nature of testing for lead in school drinking water, multiple government agencies may be involved, necessitating a balance of responsibilities and information- sharing between these state agencies  Finally, state officials told us that imposing requirements without providing funding to implement them may be a challenge for schools in complying with testing and remediation requirements  Apart from the states with requirements to test for lead in school drinking water discussed in this report, at least 13 additional states had also provided funding or in-kind support to school districts to assist with voluntary lead testing and remediation, according to EPA regional offices  Those states are Arizona, Colorado, Idaho, Indiana, Maine, Massachusetts, Michigan, New Mexico, Ohio, Oregon, Rhode Island, Vermont, and Washington  In Massachusetts, for example, officials told us the state used $2 8 million from the state Clean Water Trust to fund a voluntary program for sampling and testing for all participating public schools in 2016 and 2017  Massachusetts contracted with a state university to assist schools with testing for lead in drinking water  When the program completed its first round of testing in February 2017, 818 schools throughout the state had participated, and the state has begun a second round of sampling with remaining funds from the Clean Water Trust  In Oregon, officials told us the state legislature provided funding for matching grants of up to $8 million to larger school districts for facilities improvements, and made $5 million of emergency funds available to reimburse school districts for laboratory fees associated with drinking water testing as part of the state’s efforts to address student safety  States can also provide technical assistance to support school districts in their efforts to test for and remediate lead in drinking water  The five states we visited provided a range of technical assistance to school districts  For example, to implement the voluntary assistance program in Massachusetts, the contracted university told us they hired 15 additional staff and assisted schools in designing sampling plans, taking samples, and sending them for testing  University officials told us they oversaw the sampling of all drinking water sources in each participating school and sent the sample to state certified laboratories for analysis  State officials encouraged schools to shut off all fixtures in which water tested at or above the action level of 15 ppb and provided guidance on actions to take, such as removing and replacing fixtures, using signage to indicate fixtures not to be used for drinking water, and implementing a flushing program  The state developed an online reporting tool so that all test results could be publicly posted  State officials also supported schools in communicating lead testing results to parents and the community  Other states we visited provided technical assistance to school districts through webinars, guidance documents, in-person presentations, and responding to inquiries  In Oregon, the state Department of Education and the state Health Authority collaborated in 2016 to provide guidance to schools on addressing lead in drinking water  The Governor issued a directive requesting all school districts test for lead in their buildings and the Health Authority requested that districts send them the results  In Texas, officials at the Commission for Environmental Quality have made presentations to schools on water sampling protocols and provided templates for school districts to communicate results  Officials told us that an increased number of school districts have contacted them in the past year seeking guidance, and, in response, they directed districts to EPA’s 3Ts guidance and a list of accredited laboratories  In Illinois, state officials partnered with the state chapter of the American Water Works Association to provide a guidance document for drinking water sampling and testing to assist schools in complying with new testing requirements  In Georgia, officials at the Department of Natural Resources told us they promote the 3Ts guidance on their website and have offered themselves as a resource on school testing at presentations with local water associations  EPA provides several voluntary resources, such as guidance, training, and technical assistance, to states and school districts regarding testing for and remediation of lead in school drinking water, but some school districts we surveyed and officials we interviewed said more information would be helpful  The Lead Contamination Control Act of 1988 (LCCA) required EPA to publish a guidance document and testing protocol to assist schools in their testing and remediation efforts  EPA’s Office of Ground Water and Drinking Water issued its 3Ts guidance which provides information on training school officials, testing drinking water in schools, and telling the school and broader community about these efforts  Of the school districts that reported in our survey using the 3Ts guidance to inform their lead testing efforts, an estimated 68 percent found the guidance extremely or very helpful for conducting tests  The Office of Ground Water and Drinking Water also developed an additional online resource—known as the 3Ts guidance toolkit—to further assist states and school districts with their lead in drinking water prevention programs by providing fact sheets and brochures for community members, among other things  Some states have used the 3Ts guidance as a resource for their state programs, according to EPA officials  For example, a New York regulation directs schools to use the 3Ts guidance as a technical reference when implementing their state- required lead testing and remediation programs  The Office of Ground Water and Drinking Water provides training to support states and school districts with their lead testing and remediation programs  In June 2017, EPA started a quarterly webinar series to highlight school district efforts to test for lead  These webinars include presentations from school officials and key partners that conducted lead testing and remediation  For example, on June 21, 2017, officials from Denver Public Schools and Denver Water presented on their efforts to test for lead in the public school system  EPA’s approach to providing guidance and technical assistance to states and school districts is determined by each of the 10 EPA regional offices  Some EPA regional offices provide the 3Ts guidance to school districts upon request and others conduct outreach to share the guidance, typically through their healthy schools coordinator when discussing other topics, such as indoor air quality and managing chemicals  EPA regional offices also provide technical assistance by request, typically through phone consultations with school districts that have questions regarding the 3Ts guidance, according to EPA headquarters officials  Officials also indicated that the agency has received more requests for technical assistance from schools over the past few years regarding lead in drinking water  Officials in EPA Regions 1 in Boston and 2 in New York City told us they provided technical assistance to school districts by conducting lead testing and analysis in school facilities and Region 9 in San Francisco provided technical assistance by reviewing school district testing protocols  For example, EPA Region 2 officials said between 2002 and 2016 they worked with one to two school districts per year to assist with their lead testing efforts  As part of this effort, the regional office provided funding for sampling and analysis  Officials said they prioritized school districts based on population size and whether the community had elevated blood lead levels  Other EPA regional office approaches included identifying resources and guidance for relevant state agencies and facilitating information sharing by connecting districts that have tested for lead with districts that are interested in doing so  However, most EPA regional offices do not provide technical assistance in the form of testing, analysis, or remediation to school districts, and some do little or no outreach to communicate the importance of testing for and remediating lead in school drinking water  According to federal standards for internal control, management should externally communicate the necessary quality information to achieve the entity’s objectives  Each EPA regional office’s approach to providing resources to states and school districts varies based on differing regional priorities and available resources, according to EPA headquarters officials  Additionally, officials said that this decentralized model of providing support and technical assistance related to lead testing and remediation in schools is appropriate because of the number of schools across the United States  However, based on our survey we found school district familiarity with the 3Ts guidance varied by geographic area (see fig  8)  An estimated 54 percent of school districts in the Northeast reported familiarity with the 3Ts guidance, compared with 17 percent of districts in the South  Furthermore, the Northeast was the only geographic area with more school districts reporting that they were familiar with the 3Ts guidance than not  This awareness corresponds with the efforts made by the state of Massachusetts and EPA’s regional offices in the Northeast to distribute the 3Ts guidance and conduct lead testing and remediation in school districts  By promoting further efforts to communicate the importance of lead testing to schools to help ensure that their lead testing programs are in line with good practices included in the 3Ts guidance, EPA regional offices that have not focused on this issue could leverage the recent efforts of other regional offices to provide technical assistance and guidance, and other forms of support  EPA’s 3Ts guidance emphasizes the importance of taking action to remediate elevated lead in school drinking water, but the agency’s guidance on a recommended action level for states and school districts is not current and contains elements that could be misleading  Although the guidance recommends that school districts prioritize taking action if lead levels from water fountains and other outlets used for consumption exceed 20 ppb (based on a 250 milliliter water sample), EPA officials told us when the guidance was originally developed in response to the 1988 LCCA requirement, the agency did not have information available to recommend an action level specifically designed for schools  Furthermore, EPA officials told us that the action level in the 3Ts guidance is not a health-based standard  However, there are statements in the guidance that appear to suggest otherwise  For example, the guidance states that EPA strongly recommends that all water outlets in all schools that provide water for drinking or cooking meet a “standard” of 20 ppb lead or less and that school officials who follow the steps included in the document, including using a 20 ppb action level, will be “assured” that school facilities do not have elevated lead in the drinking water  The use of the terms “standard” and “assured” are potentially misleading and could suggest that the 20 ppb action level is protective of health  Further, state and school district officials may be familiar with the 15 ppb action level (based on a 1 liter water sample) for public water systems aimed at identifying system-wide problems under the LCR, which may also create confusion around the 20 ppb action level included in the 3Ts guidance  According to our survey, an estimated 67 percent of school districts reported using an action level less than the 20 ppb recommended in the 3Ts guidance  We found that nearly half of school districts used action levels between 15 ppb and 19 ppb  Although these action levels— the 20 ppb from the 3Ts guidance and the 15 ppb from the LCR—are intended for different purposes, the difference creates confusion for some state and school district officials  Also, according to our survey, an estimated 56 percent of school districts reported they would find it helpful to have clearer guidance on what level of lead to use as the action level for deciding to take steps to remediate lead in drinking water  In addition, officials we interviewed in four of the five states we visited said there is a need for clearer guidance on the action level  EPA officials agreed that the difference between the two action levels creates confusion for states and school districts  In addition to wanting clearer guidance on choosing lead action levels, about half of the school districts we surveyed said they would also like additional information to help inform their lead testing and remediation programs  Specifically, school districts reported that they want information on a recommended schedule for lead testing, how to remediate elevated lead levels, and information associated with testing and remediation costs (see fig  9)  For example, an estimated 54 percent of school districts responded that they would like additional information on a testing schedule, as did officials in 10 of the 17 school districts and one of the five states we interviewed  EPA’s 3Ts guidance does not include information to help school districts determine a schedule for retesting their schools  Officials in one school district told us they need information for determining retesting schedules for lead in their school drinking water, and that—without guidance—they chose to retest every 5 years, acknowledging that this decision was made without a clear rationale  Further, an estimated 62 percent of school districts reported wanting additional information on remedial actions to take to address elevated lead  For example, officials from the Massachusetts Department of Environmental Protection told us that they would like additional guidance on evaluating remedial actions to address elevated lead in the fixtures or the plumbing system  Officials with EPA’s Office of Ground Water and Drinking Water hold quarterly meetings with regional officials to obtain input on potential improvements to the 3Ts guidance, but have not made any revisions  EPA has not substantially updated the 3Ts guidance since October 2006 and does not have firm plans or time frames for providing additional information, including on the action level and other key topics such as a recommended schedule for testing  EPA officials said that they may update the 3Ts guidance before the LCR is updated, but did not provide a specific time frame for doing so  EPA has efforts underway to reconsider the action level for the LCR, which may include a change in the action level from one that is based on technical feasibility, to one that also considers lead exposure in vulnerable populations such as infants and young children, which EPA refers to as a health-based benchmark  EPA anticipates issuing comprehensive revisions to the LCR by February 2020  While the 3Ts guidance is not contingent on the LCR, EPA officials told us they would consider updates to the 3Ts guidance, including the 20 ppb action level, as they consider revisions to the LCR  By updating the 3Ts guidance to include an action level for school districts that incorporates available scientific modeling regarding vulnerable population exposures, EPA could have greater assurance that school districts are able to limit children’s exposure to lead  EPA has emphasized the importance of addressing elevated lead levels in school drinking water through its 3Ts guidance, but has not communicated necessary information about action levels and other key topics consistent with the external communication standard under federal standards for internal control  According to EPA, CDC, and others, eliminating sources of lead before exposure can occur is considered the best strategy to protect children from potential adverse health outcomes  EPA officials also told us that clear guidance is important because testing for lead in drinking water requires technical expertise  But without providing interim or updated guidance to help school districts choose an action level for lead remediation EPA will continue to provide schools with confusing information regarding whether to remediate, which may not adequately limit potential lead exposure to students and staff  Furthermore, without important information on key topics, such as a recommended schedule for lead testing, how to remediate elevated lead levels, and information associated with testing and remediation costs school districts are at risk of making misinformed decisions regarding their lead testing and remediation efforts  Education has not played a significant role in supporting state and school districts efforts to test for and remediate lead in school drinking water, and there has been limited collaboration between Education and EPA, according to officials  In 2005, Education, EPA, CDC, and other entities involved with drinking water signed the Memorandum of Understanding on Reducing Lead Levels in Drinking Water in Schools and Child Care Facilities (the memorandum) to encourage and support schools’ efforts to test for lead in drinking water and to support actions to reduce children’s exposure to lead  According to the memorandum, Education’s role is to identify the appropriate school organizations with which to work and facilitate dissemination of materials and tools to schools in collaboration with EPA  In addition, EPA’s role is to update relevant guidance documents for school districts—resulting in the production of the 3Ts guidance in 2006—raising awareness, and collaborating with other federal agencies and associations, among other things  Education officials told us that the agency does not have any ongoing efforts related to implementing the memorandum  However, Education and EPA officials were not aware of the memorandum being terminated by either agency and told us the memorandum remains in effect  Although Education does not have any ongoing efforts related to implementing the memorandum, the agency’s websites, including the Readiness and Emergency Management for Schools Technical Assistance Center (REMS TA Center) website, and the Green Strides portal, provide links to EPA guidance and webinars on lead testing and remediation  The REMS TA Center website, which is largely focused on emergency management planning, includes a link to EPA’s 3Ts guidance and other resources on lead exposure and children, but does not provide information regarding the importance of testing for lead in school drinking water  Education’s Green Strides portal includes a link to a number of EPA’s webinars on lead in school drinking water, but does not include all of the quarterly webinars started in June 2017 to highlight school district efforts to test for lead  An Education official told us that these EPA webinars are identified by Education without coordinating with EPA officials  Further, when searching on Education’s website for lead in school drinking water, the 3Ts guidance does not show up  Education officials acknowledged that information regarding lead testing and remediation is difficult to find on Education’s website and they could take steps to make federal guidance on lead in school drinking water more accessible  The federal government has developed guidelines to help federal agencies improve their experience with customers through websites  One such resource is Guidelines for Improving Digital Services developed by the federal Digital Services Advisory Group  It states that federal agencies should take steps to make guidance easy to find and accessible  Making guidance easy to find and accessible such as by clarifying which links contain guidance; highlighting new or important guidance; improving their websites’ search function; and categorizing guidance on Education’s websites could help raise school district awareness of the guidance, which is currently low in most areas of the country  Many school districts are not familiar with EPA guidance related to lead testing and remediation  Specifically, an estimated 60 percent of school districts reported in our survey that they were not familiar with the EPA’s 3Ts guidance  Most school district officials from our site visits told us they did not have contact with EPA prior to or during their lead testing and some said they would not have thought to go to EPA for guidance  Likewise, EPA officials reported they had received feedback from school district officials indicating that they do not know where to go for information about testing for and remediating lead in drinking water  Rather, school district officials may look to their state educational agency or Education for guidance on lead testing and remediation, as they might do when looking for guidance on other topics  Education and EPA do not regularly collaborate to support state and school districts’ efforts related to lead in school drinking water, according to EPA and Education officials  Education officials said the agency does not have a role in ensuring safe drinking water in schools, and that the mitigation of environmental health concerns in school facilities is a state and local function  Therefore, the agency does not collaborate with EPA to disseminate the 3Ts guidance beyond posting links to related guidance on their websites and newsletters  EPA officials told us they do not know which office they should collaborate with at Education  EPA regional officials also said they do not collaborate with Education to disseminate the guidance to states and school districts  However, in the 2005 memorandum, EPA and Education agreed to work together to encourage school districts to test drinking water for lead; disseminate results to parents, students, staff, and other interested stakeholders; and take appropriate actions to correct elevated lead levels  There are many school districts that have not tested for lead in school drinking water, and some conducted testing without the assistance of federal guidance—although the large majority (68 percent) of school districts who use the guidance reported finding it helpful  Officials in 11 of 17 school districts we interviewed that had conducted lead testing told us they were familiar with the 3Ts guidance and 9 of those districts said they found it helpful for designing their lead testing programs  Increased encouragement and dissemination of EPA resources about lead in school drinking water by Education and EPA could help school districts test for and remediate lead in drinking water using good practices and reduce the potential risk of exposure for students and staff  Children are particularly at risk of experiencing the adverse effects of lead exposure from a variety of sources, including drinking water  While there is no federal law requiring lead testing for drinking water in most schools, some states and school districts have decided to test for lead in the drinking water to help protect students  However, there are a number of school districts that have not tested for lead and some that do not know if they have tested for lead in their drinking water, according to our nationwide survey  Even in states and school districts that have opted to test, officials may choose different action levels to identify elevated lead and may choose different testing protocols that do not test all fixtures in all schools  EPA has developed helpful guidance—3Ts—and webinars for states and school districts to support efforts to test and remediate lead in school drinking water  However, some EPA regional offices have not communicated the importance of testing for and remediating lead to states and school districts  By promoting further efforts to communicate the importance of lead testing to school districts to help ensure that their lead testing programs are in line with good practices, including the 3Ts guidance, regional offices that have not focused on this issue could build on the recent efforts of other regional offices to provide technical assistance and guidance and other forms of support  State and school district officials can use EPA’s 3Ts guidance to help ensure that their drinking water testing and remediation efforts are in line with good practices and said that it has been helpful for establishing their programs  However, statements in the guidance—which has not been updated in over a decade—that suggest the action level described will ensure that school facilities do not have elevated lead in their drinking water are misleading  In addition, state and school district officials told us that additional guidance—including information on a recommended schedule for retesting as well as on costs associated with testing and remediation—could help school districts make more informed decisions regarding their testing and remediation efforts  Without providing interim or updated guidance, EPA is providing schools with confusing and out of date information, which can increase the risk of school districts making uninformed decisions  EPA officials said they would consider updates to the 3Ts action level while the revisions to the LCR are being completed  However, the longer school districts are without the additional information they need to conduct their efforts in line with good practices and continue to rely on confusing and misleading information, the more challenges they will face in trying to limit children’s exposure to lead  After EPA revises the LCR, the agency would have greater assurance that school districts are limiting children’s exposure to lead by considering whether to develop, as part of its guidance, a health-based level for schools that incorporates available scientific modeling regarding vulnerable population exposures  Finally, although Education provides information to states and school districts on lead testing and remediation through the agency’s websites, that information is difficult to find  Further, Education’s website does not include all of EPA’s quarterly webinars to highlight school district efforts to test for lead  By making guidance accessible, Education could improve school district awareness of EPA resources about lead in school drinking water  In addition, EPA and Education should improve their collaboration to encourage and support lead testing and remediation efforts by states and school districts  EPA has the expertise to develop guidance and provide technical assistance to states and school districts, while Education, based on its mission to promote student achievement, should collaborate with EPA to disseminate guidance and raise awareness of lead in drinking water as an issue that could impact student success  Although over one-third of districts that tested found elevated levels of lead, many districts have still not been tested  Unless EPA and Education encourage additional school districts to test for lead, many students and school staff may be at risk of lead exposure  We are making a total of seven recommendations, including five to EPA and two to Education: The Assistant Administrator for Water of EPA’s Office of Water should promote further efforts to communicate the importance of testing for lead in school drinking water to address what has been a varied approach by regional offices  For example, the Assistant Administrator could direct those offices with limited involvement to build on the recent efforts of several regional offices to provide technical assistance and guidance, and other forms of support  (Recommendation 1) The Assistant Administrator for Water of EPA’s Office of Water should provide interim or updated guidance to help schools choose an action level for lead remediation and more clearly explain that the action level currently described in the 3Ts guidance is not a health-based standard  (Recommendation 2) The Assistant Administrator for Water of EPA’s Office of Water should, following the agency’s revisions to the LCR, consider whether to develop a health-based level, to include in its guidance for school districts, that incorporates available scientific modeling regarding vulnerable population exposures and is consistent with the LCR  (Recommendation 3) The Assistant Administrator for Water of EPA’s Office of Water should provide information to states and school districts concerning schedules for testing school drinking water for lead, actions to take if lead is found in the drinking water, and costs of testing and remediation  (Recommendation 4) The Assistant Secretary for Elementary and Secondary Education should improve the usability of Education’s websites to ensure that the states and school districts can more easily find and access federal guidance to address lead in school drinking water, by taking actions such as clarifying which links contain guidance; highlighting new or important guidance; improving their websites’ search function; and categorizing guidance  (Recommendation 5) The Assistant Administrator for Water of EPA’s Office of Water and the Director of the Office of Children’s Health Protection should collaborate with Education to encourage testing for lead in school drinking water  This effort could include further dissemination of EPA guidance related to lead testing and remediation in schools or sending letters to states to encourage testing in all school districts that have not yet done so  (Recommendation 6) The Assistant Secretary for Elementary and Secondary Education should collaborate with EPA to encourage testing for lead in school drinking water  This effort could include disseminating EPA guidance related to lead testing and remediation in schools or sending letters to states to encourage testing in all school districts that have not yet done so  (Recommendation 7) We provided a draft of this report to EPA, Education, and CDC for review and comment  EPA and Education provided written comments that are reproduced in appendixes VII and VIII respectively  EPA also provided technical comments, which we incorporated as appropriate  CDC did not provide comments  We also provided relevant excerpts to selected states and incorporated their technical comments as appropriate  In its written comments, EPA stated that it agreed with our recommendations and noted a number of actions it plans to take to implement them  For example, EPA said its Office of Ground Water and Drinking Water is holding regular meetings with regional offices and other EPA offices to obtain input on improving the 3Ts guidance  Potential revisions include updates to implementation practices, the sampling protocol, and the action level, including clarifying descriptions of different action levels and standards  Also, EPA said that while it has not yet determined the role of a health-based benchmark for lead in drinking water in the revised LCR, it sees value in providing states, drinking water systems, and the public with a greater understanding of the potential health implications for vulnerable populations of specific levels of lead in drinking water  EPA said it would continue to reach out to states and schools to provide information, technical assistance, and training and will continue to make the 3Ts guidance available  EPA also said it would work with Education to ensure that school districts and other stakeholders are aware of additional resources EPA is developing  In its written comments, Education stated that it agreed with our recommendations and noted a number of actions it plans to take to implement them  In response to our recommendation to improve Education’s websites, Education said it would identify and include an information portal dedicated to enhancing the usability of federal resources related to testing for and addressing lead in school drinking water  Also, Education said it is interested in increasing coordination across all levels of government and it shares the view expressed in our report that improved federal coordination, including with EPA, will better enhance collaboration to encourage testing for lead in school drinking water  Education said it would develop a plan for disseminating relevant resources to its key stakeholder groups and explore how best to coordinate with states to disseminate EPA’s guidance on lead testing and remediation to school districts  As agreed with your offices, 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 interested congressional committees, the Administrator of the Environmental Protection Agency, the Secretary of Education, the Director of the Centers for Disease Control and Prevention, 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 us at (617) 788-0580 or nowickij@gao gov or (202) 512-3841 or gomezj@gao gov  Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report  GAO staff who made key contributions to this report are listed in appendix IX  In this report, we examined three objectives: (1) the extent to which school districts are testing for, finding, and remediating lead in school drinking water; (2) the extent to which states require or support testing for and remediating lead in school drinking water by school districts; and (3) the extent to which federal agencies are supporting state and school district efforts to test for and remediate lead  To address these objectives, we conducted a web-based survey of school districts, interviews with selected state and school district officials, a review of applicable requirements in selected states, a review of relevant federal laws and regulations, and interviews with federal agency officials and representatives of stakeholder organizations  We conducted this performance audit from October 2016 through July 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  To examine the extent to which school districts are testing for and remediating lead in school drinking water, we designed and administered a generalizable survey of a stratified random sample of U S  local educational agencies (LEA), which we refer to as school districts throughout the report  The survey included questions about school district efforts to test for lead in school drinking water, such as the number of schools in which tests were conducted, the costs of testing, and whether parents or others were notified about the testing efforts  We also asked questions about remediation efforts, such as whether lead was discovered in school drinking water, the specific remediation efforts that were implemented, and whether parents or others were notified about the remediation efforts  Further, we asked about officials’ familiarity with the Environmental Protection Agency’s (EPA) guidance entitled 3Ts for Reducing Lead in Drinking Water in Schools, (3Ts guidance) whether the guidance was used, and the extent to which it was helpful in conducting tests, remediating lead, and communicating with parents and others  We directed the survey to school district superintendents or other cognizant officials, such as facilities directors  See appendix II which includes the survey questions and estimates  We defined our target population to be all school districts in the 50 U S  states and the District of Columbia that are not under the jurisdiction of the Department of Defense or Bureau of Indian Education  We used the LEA Universe database from Department of Education’s (Education) Common Core of Data (CCD) for the 2014-2015 school year to our sampling frame  For the purpose of our survey, our sample was limited to school districts that: were located in the District of Columbia or the 50 states; had a LEA type code of 1, 2, 4, 5, 7, and 8; had one or more schools and one or more students; and were not closed according to the 2014-2015 School Year  The resulting sample frame included 16,452 school districts and we selected a stratified random sample of 549 school districts  We stratified the sampling frame into 13 mutually exclusive strata based on urban classification and poverty classification  We further stratified the school districts classified as being in a city by charter status  We selected the largest 100 school districts with certainty  We determined the minimum sample size needed to achieve precision levels of plus or minus 12 percentage points or fewer, at the 95 percent confidence level  We then increased the sample size within each stratum for an expected response rate of 70 percent  We defined the three urban classifications based on the National Center for Education Statistics (NCES) urban-centric locale code  To build a general measure of the poverty level for each school district we used the proportion of students eligible for free or reduced-price lunch (FRPL) as indicated in the CCD data and classified these into the following three groups: High-poverty – More than 75 percent of students in the school district were eligible for FRPL; Mid-poverty – Between 25 1 and 75 0 percent of students in the school district were eligible for FRPL; and Low-poverty – 25 percent or fewer students in the school district were eligible for FRPL  We assessed the reliability of the CCD data by reviewing existing documentation about the data and performing electronic testing on required data elements and determined they were sufficiently reliable for the purpose of our report  We administered the survey from July to October 2017 (the survey asked school districts to report information based on the 12 months prior to their completing the survey ) To obtain the maximum number of responses to our survey, we sent reminder emails to nonrespondents and contacted nonrespondents over the telephone  We identified that four of the 549 sampled school districts were closed and one was a “cyber-school” with no building, so these were removed from the sample  Of the remaining 544 eligible sampled school districts, we received valid responses from 373, resulting in an unweighted response rate of 68 percent  We conducted an analysis of our survey results to identify potential sources of nonresponse bias using a multivariate logistic regression model  We examined the response propensity of the sampled school districts by several demographic characteristics  These characteristics included poverty, urbanicity, and charter status  We did not find any other population characteristics significantly affected survey response propensity except those used in stratification (charter schools and the largest 100 school districts)  Based on the response bias analysis and the 68 percent response rate across stratum, we determined that estimates based on adjusted weights reflecting the response rate are generalizable to the population of eligible school districts and are sufficiently reliable for the purposes of this report  We took steps to minimize non-sampling errors, including pretesting draft instruments and using a web-based administration system  As we began to develop the survey, we met with officials from seven school districts to explore the feasibility of responding to the survey questions  We then pretested the draft instrument from April to June 2017 with officials in eight school districts—including one charter school district—in cities and suburbs in different states  In the pretests, we asked about the clarity of the questions and the flow and layout of the survey  The EPA also reviewed and provided us comments on a draft version of the survey  Based on feedback from the pretests and EPA’s review, we made revisions to the survey instrument  To further minimize non-sampling errors, we used a web-based survey, which allowed respondents to enter their responses directly into an electronic instrument  Using this method automatically created a record for each respondent and eliminated the errors associated with a manual data entry process  We express the precision of our particular sample’s results as a 95 percent confidence interval (for example, plus or minus 10 percentage points)  This is the interval that would contain the actual population value for 95 percent of the samples we could have drawn  As a result, we are 95 percent confident that each of the confidence intervals in this report will include the true values in the study population  To analyze differences in the percentages of school districts that reported they tested for lead in school drinking water and those that discovered lead, we compared weighted survey estimates generated for school districts in different levels of the following subgroups: Poverty: low poverty, mid poverty, and high poverty; Racial composition: majority-minority and majority white; Region: Northeast, South, Midwest, and West; Population density: urban, suburban, and rural/town; Urban charter school: in urban areas, charter district and non-charter Largest 100: largest 100 districts (based on student enrollment) and all other districts  For each subgroup, we produced percentage estimates and standard errors for each level and used these results to confirm the significance of the differences between weighted survey estimates  To examine school districts’ testing and remediation efforts and state support of those efforts, we conducted site visits in five states—Georgia, Illinois, Massachusetts, Oregon, and Texas—from February to October 2017  We selected these states because they varied in the extent to which they required testing of school drinking water for lead and they are located in geographic areas covered by different EPA regional offices  Within these states, we selected 17 school districts that had tested for lead in school drinking water and to achieve variation in the size and population density (urban, suburban, and rural) of the district as well as including one charter school district  Site visits generally consisted of interviews with officials in state agencies and school districts and officials in the local EPA regional office: State interviews: We interviewed officials in state environment, education, and health agencies, depending on whether they had information related to school district testing for lead in school drinking water in their state  The topics we discussed were the agencies’ roles and responsibilities related to testing for and remediation of lead in school drinking water, any related state requirements, policies, and guidance, communication and public notification about testing and remediation efforts and, as appropriate, coordination among multiple state agencies  We also discussed similar topics related to lead-based paint  In Massachusetts, we interviewed representatives with the University of Massachusetts, because of their role in implementing the state’s program to support school district efforts to test for lead in school drinking water  School Districts: Within the five site visit states, we interviewed officials in 14 school districts in person and in three school districts by phone (because we were not able to meet with them in person)  We also selected one charter school that functions as its own school district which had conducted tests for lead in school drinking water  Similar to our school district survey, the interview topics we discussed with district officials included testing for and remediation of lead in school drinking water, use of guidance (such as the 3Ts guidance) and efforts to communicate or coordinate with any federal, state, or local agencies, including any other school districts  Within 13 of the school districts, we visited at least one school in which the district had tested for lead in drinking water and, as needed, took remedial action in order to gain an in-depth understanding of their testing and remediation efforts  EPA Regional Offices: We interviewed officials in all 10 EPA Regional offices  We met in-person with officials in the regional offices 1, 4, 5, and 6 and conducted phone interviews with officials in regional offices 2, 3, 7, 8, 9, and 10  We generally discussed EPA officials’ roles and responsibilities related to testing for lead in school drinking water and paint and efforts in states and school districts in their region  Information we gathered from these interviews, while not generalizable, represents the conditions present in the states and school districts at the time of our interviews and may be illustrative of efforts in other states and school districts  As part of our effort to examine school districts’ testing and remediation efforts and state support of those efforts, we reviewed related state requirements  To determine whether states had related requirements, we asked all EPA regional offices if states in their region had requirements related to testing for lead in school drinking water  EPA provided examples of eight states (California, Illinois, Maryland, Minnesota, New Jersey, New York, Virginia, and the District of Columbia that had such requirements  We reviewed relevant laws, regulations, and policy documents for these states  We then confirmed the details of the related requirements with the appropriate state officials via structured questionnaires  Also, we used available documentation to corroborate and verify the testing requirements of the states that EPA identified  GAO did not conduct an independent search of state laws  To examine the extent to which federal agencies have collaborated in supporting state and school district efforts to test for and remediate lead, we reviewed relevant federal laws, including the Water Infrastructure Improvements for the Nation Act of 2016, Reduction of Lead in Drinking Water Act of 2011, the Safe Drinking Water Act of 1974, as amended, and the Lead Contamination Control Act of 1988; regulations, such as the Lead and Copper Rule; and guidance, such as the 3Ts guidance  We also reviewed documentation including the Memorandum of Understanding on Reducing Lead Levels in Drinking Water in Schools and Child Care Facilities signed in 2005 by EPA, Education and the Centers for Disease Control and Prevention (CDC); Federal Partners in School Health Charter; EPA training webinar information; and other relevant guidance including the 3Ts guidance tool kit  We interviewed officials from EPA’s Office of Ground Water and Drinking Water and Office of Children’s Health Protection and officials in all 10 of EPA regional offices regarding their approach to providing support to states and school district on lead testing and remediation  We interviewed officials from Education’s Office of Safe and Healthy Students and officials from the CDC  During these interviews, we interviewed officials about the Memorandum of Understanding and about the Federal Partners in School Health initiative, both of which represent collaborative efforts that address lead in school drinking water, among other topics  We evaluated federal efforts to collaborate and support lead testing and remediation in schools against federal standards for internal control, which call for agencies to communicate quality information to external parties, among other things  We also evaluated federal efforts against the Memorandum of Understanding, in which EPA, Education, and CDC agreed to encourage testing drinking water for lead and communicate with key stakeholders, among other things  To inform all of our research objectives, we interviewed representatives with the National Conference of State Legislatures, National Center for Healthy Housing, National Alliance of Public Charter Schools, the DC Public Charter School Board, and the 21st Century School Fund  We also attended a workshop entitled “Eliminating Lead Risks in Schools and Child Care Facilities” in December 2017  The questions we asked in our survey of local educational agencies (referred to in this report as school districts) are shown below  Our survey was comprised of closed- and open-ended questions  In this appendix, we include all survey questions and aggregate results of responses to the closed-ended questions; we do not provide information on responses provided to the open-ended questions  Estimates noted with superscript “a” are based on 20 or fewer responses and were not included in our findings  For a more detailed discussion of our survey methodology, see appendix I  1  Do any schools in your local educational agency (LEA) obtain drinking water from a public water system such as a city or municipal water plant? (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) No (Skip to 20) Don’t know (Skip to 20) Section B: Testing for Lead in School Drinking Water 2  Is there a requirement that the drinking water in your LEA’s schools be tested for lead? (Please answer “Yes” regardless of whether that requirement comes from your state, municipality, local educational agency or any other governmental entity ) (Check one ) 95 percent confidence interval – lower bound (percentage) 3  Regardless of whether your LEA is required to test for lead in school drinking water, have tests been conducted for lead in the drinking water in at least one of your schools in the past 12 months? (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) If yes to 3: 3A  What is the number of schools in which tests were conducted in the past 12 months? Estimated Number (Mean) 95 percent confidence interval – lower bound (number) 95 percent confidence interval – upper bound (number) (Respondent reported number) 3B  About how many samples were taken from sources of drinking water such as water fountains and sinks in each school? (Check one ) 95 percent confidence interval – lower bound (percentage) 3C  Did any of the following develop the sampling plan, draw the samples of water, and analyze the samples? (Check all that apply ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) 3D  What size samples were taken? (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) If ‘other’ to 3D: What sample size was used? 3E: To the best of your knowledge, did the personnel drawing or analyzing samples follow a testing protocol that offers guidance on developing the sampling plan, drawing samples of water, or analyzing samples? (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) No (Skip to 3F) Don’t know (Skip to 3F) If ‘yes’ to 3E: a  To the best of your knowledge, were any of the following entities involved in developing the protocol? (Check one per row ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) Contractor / water testing company EPA or another federal government agency A local government agency (aside from your LEA) If ‘other’ to 3Eh: What other entities were involved in developing the protocol? 3F  If tests were conducted in some schools in your LEA in the past 12 months—but were not conducted in every school—how was it determined which schools would be tested? (Check one per row ) Not applicable: tests were conducted in every school (Skip to 3G) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) If ‘other’ to 3Fe: In what other ways did your LEA use to determine which schools would be tested? 3G  How much do you estimate your LEA has spent on testing for lead in school drinking water in the past 12 months? (Please answer this question for lead testing only; the survey asks about expenditures to address concerns identified through testing later  Also, please include materials, labor, and any other expenditures related to lead testing in your estimate ) Estimated Number (Median) 95 percent confidence interval – lower bound (number) 95 percent confidence interval – upper bound (number) (Respondent reported number) 3H  Did your LEA use any of the following sources of funding for the testing in the past 12 months? (Check one per row)  95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) If ‘other’ to 3H: What other sources of funding did your LEA use? 3I  In the past 12 months, did your LEA notify the following groups that it was planning to test for lead in school drinking water before conducting the tests? (Check one per row)  95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) General public (e g , media) If ‘other’ to 3I: What other groups did your LEA notify that it was planning to test for lead in school drinking water before conducting the tests? 3J  In the past 12 months, did your LEA report the testing results to the following groups after completing the tests? (Check one per row)  95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) General public (e g , media) If ‘other’ to 3J: To what other groups did your LEA report the testing results? 3K  If ‘no’ to 3: Were any of the following a reason your LEA did not conduct any tests in any schools in the last 12 months? (Check one per row)  95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) If ‘other’ to 3K: For what other reasons did your LEA not conduct any tests in any schools in the last 12 months? 4  Does your LEA have a schedule for recurring tests to determine the amount of lead in the drinking water in your schools within any of the following time frames? (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) Section C: Remediation of Lead in School Drinking Water 5  Has your LEA discovered any level of lead in the drinking water of any of your schools (as a result of testing) in the last 12 months? (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) 5A  What lead concentration (measured in “parts per billion” or “ppb”) did your LEA use to initiate remedial action? (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) If ‘other’ to 5A: What lead concentration did your LEA use to initiate remedial action? 5B  In the last 12 months, how many schools had at least one test result–including as few as one sample in one school–greater than the lead level your LEA used to initiate action? (Please answer regardless of whether these results were discovered in the first of multiple rounds of testing ) 5C To address lead discovered in school drinking water, has your LEA taken any of the following actions in any of your schools in the past 12 months? 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) 5D  If ‘no’ to every item in 5C: What are the reasons why your LEA has not taken actions in any of your schools in the past 12 months? 5E  If ‘yes’ to any item in 5C: How much do you estimate your LEA has spent on taking actions in the past 12 months? (Please include materials, labor, and any other expenditures related to lead remediation in your estimate ) Estimated Number (Median) 95 percent confidence interval – lower bound (number) 95 percent confidence interval – upper bound (number) (Respondent reported number) 5F  Did your LEA use any of the following sources of funding to take actions in the past 12 months? (Check one per row)  95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) If ‘other’ to 5F: What other sources of funding did your LEA use to take actions in the past 12 months? 5G  Did your LEA notify the following groups about its actions in the past 12 months? (Check one per row)  95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) General public (e g , media) If ‘other’ to 5G: What other groups has your LEA notified about its remedial actions in the past 12 months? 6  Does your LEA have a schedule to flush the water system as a result of concerns about lead in drinking water in at least one of your schools within any of the following time frames? (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) 7  Does your LEA have plans to take actions to eliminate or reduce lead in school drinking water (for example, replace drinking water fountains, replace pipes) in at least one of your schools? (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) If ‘according to a schedule’ to 7: how would you describe the schedule that your LEA has developed? Section D: Guidance Regarding Lead Testing and Remediation 8  Prior to receiving this survey, were you familiar with guidance issued by the U S  Environmental Protection Agency entitled “3Ts for Reducing Lead in Drinking Water in Schools”? (Please answer “Yes” if you had read or used the”3Ts” prior to receiving this survey ) (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) If ‘yes’ to 8: did your LEA (or a contractor working on behalf of your LEA) follow or refer to “3Ts” during your efforts to test for or remediate lead in school drinking water? (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) If ‘yes’ to 8A: How helpful was 3Ts for conducting tests for lead in your schools’ drinking water? (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) If ‘yes’ to 8A: How helpful was 3Ts for remediating lead in your schools’ drinking water? (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) If ‘yes’ to 8A: How helpful was 3Ts for communicating with parents and other stakeholders about lead in your schools’ drinking water? (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) What else, if anything, would make 3Ts more helpful? 9  Did your LEA (or a contractor working on behalf of your LEA) use any other guidance (for example, best practices, manuals, protocols, webinars) in your LEA’s efforts to test for lead in your schools’ drinking water, take remedial actions, or for notification purposes? (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) What other guidance was used? 10  Would your LEA find any of the following helpful? (Check one per row)  95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) Clearer guidance on a level of lead in school drinking water at which we should take action Additional guidance on determining a schedule for 41 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) regularly testing for lead in school drinking water Additional guidance on actions to take if lead is found in school drinking water Information on the costs of testing for lead in school drinking water Information on the costs of remediating lead in school drinking water 18 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) If ‘other guidance or information’ to 10: What other guidance or information would be helpful? Section E: Inspecting Schools for Lead Based Paint Section F: Remediation of Lead Based Paint in Schools Section G: Other Questions 16  How many schools are owned or operated by your LEA? Estimated Number (Mean) 95 percent confidence interval – lower bound (number) 95 percent confidence interval – upper bound (number) (Respondent reported number) 17  How many schools in your LEA were built before 1986? (If a building has additions, we mean the original structure/the original part of the building ) Estimated Number (Mean) 95 percent confidence interval – lower bound (number) 95 percent confidence interval – upper bound (number) (Respondent reported number) 18  How many schools in your LEA were built before 1978? (If a building has additions, we mean the original structure/the original part of the building ) Estimated Number (Mean) 95 percent confidence interval – lower bound (number) 95 percent confidence interval – upper bound (number) (Respondent reported number) 19  Is there anything else you would like to share with us regarding lead testing, inspection, or remediation efforts in your school or LEA (drinking water or paint)? 20  What is the name, title, e-mail address, and telephone number of the person responsible for completing this survey? Section H: Completion 21  Please check one of the options below  Clicking on “Completed” indicates that your answers are official and final  Your answers will not be used unless you have done this  (Check one ) 95 percent confidence interval – lower bound (percentage) Charter schools comprise a small but growing group of public schools  In contrast to most traditional public schools, many charter schools are responsible for financing their own buildings and other facilities  As a result, charters schools vary in terms of whether they own their own building or pay rent, and whether they operate in buildings originally designed as a school or in buildings which have been redesigned for educational purposes  Sometimes charter schools may also share space in their building with others, such as non-profit organizations  In addition to differences in facility access and finance, charter school governance also varies  In some states, charter schools function as their own school district, while in other states, charter schools have the option to choose between being a distinct school district or part of a larger school district  To determine the extent to which charter school districts were testing for lead in school drinking water and finding and remediating lead, our survey included charter school districts in two ways: our sampling design included three strata specifically for charter school districts in urban areas; in addition, charter school districts were retained in the sampling population, such that they could be randomly selected in our other strata  While we generally received too few responses from charter school districts to report their data separately, we are able to estimate that about 36 percent of charter school districts tested for lead in school drinking water  To learn more about experiences of charter schools, we visited one charter school district and interviewed representatives of the DC Public Charter School Board (DC PCSB)  The charter school district we visited consisted of one charter school in a building it leased  The school had 10 sources of consumable water, all of which were tested in 2016 and were found to have lead below the district’s selected action level of 15 parts per billion  Before testing, district officials met with the building owner who agreed to cover the cost of any remediation  Officials with the DC PCSB told us that it paid to have tests conducted in every charter school in the District of Columbia  According to DC PCSB officials, between March and June 2016, 95 charter schools were tested, and lead above their action level of 15 parts per billion was discovered in 20 schools  Officials estimated their testing costs to be about $100,000, which was subsequently reimbursed by the District of Columbia’s Office of State Superintendent of Education  They also said that charter schools were responsible for taking steps to remediate the lead and recommended schools flush their water systems and use filters  Communication of results Not specified 5 ppb in a 250 ml sample (from filtered fixture) The Environmental Protection Agency (EPA) provides information on its website for the public on lead in drinking water  EPA’s website includes, among other documents, a December 2005 brochure for the public and school districts entitled “3Ts for Reducing Lead in Drinking Water in Schools” (see fig 10)  In addition to the individuals named above, Diane Raynes (Assistant Director), Scott Spicer (Assistant Director), Jason Palmer (Analyst-in- Charge), Amanda K  Goolden, Rich Johnson, Grant Mallie, Jean McSween, Dae Park, James Rebbe, Sarah M  Sheehan, and Alexandra Squitieri made significant contributions to this report  Also contributing to this report were Susan Aschoff, David Blanding, Mimi Nguyen, Tahra Nichols, Dan C  Royer, Kiki Theodoropoulos, and Kim Yamane  Lead Paint in Housing: HUD Should Strengthen Grant Processes, Compliance Monitoring, and Performance Assessment  GAO-18-394  Washington, D C : June 19, 2018  Drinking Water: Additional Data and Statistical Analysis May Enhance EPA’s Oversight of the Lead and Copper Rule  GAO-17-424  Washington, D C : September 1, 2017  Environmental Health: EPA Has Made Substantial Progress but Could Improve Processes for Considering Children’s Health  GAO-13-254  Washington, D C : August 12, 2013  Lead in Tap Water: CDC Public Health Communications Need Improvement  GAO-11-279  Washington, D C : March 14, 2011  Environmental Health: High-level Strategy and Leadership Needed to Continue Progress toward Protecting Children from Environmental Threats  GAO-10-205  Washington, D C : January 28, 2010  Drinking Water: EPA Should Strengthen Ongoing Efforts to Ensure That Consumers Are Protected from Lead Contamination  GAO-06-148  Washington, D C : January 4, 2006 


Report 2:  Although registrations and reports are filed through a single web portal, each chamber subsequently receives copies of the data and follows different data-cleaning, processing, and editing procedures before storing the data in either individual files (in the House) or databases (in the Senate)  Currently, there is no means of reconciling discrepancies between the two databases caused by the differences in data processing  For example, Senate staff told us during previous reviews they set aside a greater proportion of registration and report submissions than the House for manual review before entering the information into the database  As a result, the Senate database would be slightly less current than the House database on any given day pending review and clearance  House staff told us during previous reviews that they rely heavily on automated processing  In addition, while they manually review reports that do not perfectly match information on file for a given lobbyist or client, staff members approve and upload such reports as originally filed by each lobbyist, even if the reports contain errors or discrepancies (such as a variant on how a name is spelled)  Nevertheless, we do not have reasons to believe that the content of the Senate and House systems would vary substantially  Based on interviews with knowledgeable officials and a review of documentation, we determined that House disclosure data were sufficiently reliable for identifying a sample of quarterly disclosure reports (LD-2) and for assessing whether newly filed lobbyists also filed required reports  We used the House database for sampling LD-2 reports from the third and fourth quarters of 2016 and the first and second quarters of 2017, as well as for sampling year-end 2016 and midyear 2017 political contributions reports (LD-203)  We also used the database for matching quarterly registrations with filed reports  We did not evaluate the Offices of the Secretary of the Senate or the Clerk of the House, both of which have key roles in the lobbying disclosure process  However, we did consult with officials from each office  They provided us with general background information at our request  To assess the extent to which lobbyists could provide evidence of their compliance with reporting requirements, we examined a stratified random sample of 98 LD-2 reports from the third and fourth quarters of 2016 and the first and second quarters of 2017  The sample size of 98 LD-2 reports for this year’s review represents an increase from the sample size selected for the 2015 and 2016 reviews, and is a return to the sample size selected in reviews prior to 2015  We increased the sample size because, in 2016, we observed a change in the estimate of the percentage of reports that had documentation of income and expenses (83 percent down from 92 percent in 2015)  At that time, we were unable to state that this was a statistically significant change because, in part, the reduced sample size of 80 did not give us enough power to detect and report on the change of that size  We excluded reports with no lobbying activity or with income or expenses of less than $5,000 from our sampling frame  We drew our sample from 45,818 activity reports filed for the third and fourth quarters of 2016 and the first and second quarters of 2017 available in the public House database, as of our final download date for each quarter  Our sample of LD-2 reports was not designed to detect differences over time  However, we conducted tests of significance for changes from 2010 to 2017 for the generalizable elements of our review  We found that results were generally consistent from year to year and there were few statistically significant changes after using a Bonferroni adjustment to account for multiple comparisons  For this year’s review, we identified that the estimated change in the percent of LD-2 reports that provided written documentation for the income and expenses from 2016 to 2017 is notable  In recent years, our findings show some variation in the estimate percentage of reports with documentation  Specifically, our estimate for 2017 (99 percent) represents a statistically significant increase from 2016  These changes are identified in the report  The inability to detect significant differences from year to year in our results may be related to sampling error alone or the nature of our sample, which was relatively small and was designed only for cross-sectional analysis  Our sample is based on a stratified random selection and is only one of a large number of samples that we may have drawn  Because each sample could have provided different estimates, we express our confidence in the precision of our particular sample’s results as a 95 percent confidence interval  This interval would contain the actual population value for 95 percent of the samples that we could have drawn  The percentage estimates for LD-2 reports have 95 percent confidence intervals of within plus or minus 12 percentage points or fewer of the estimate itself  We contacted all the lobbyists and lobbying firms in our sample and, using a structured web-based survey, asked them to confirm key elements of the LD-2 and whether they could provide written documentation for key elements in their reports, including the amount of income reported for lobbying activities; the amount of expenses reported on lobbying activities; the names of those lobbyists listed in the report; the houses of Congress and federal agencies that they lobbied, and the issue codes listed to describe their lobbying activity  After reviewing the survey results for completeness, we interviewed lobbyists and lobbying firms to review the documentation they reported as having on their online survey for selected elements of their respective LD- 2 report  Prior to each interview, we conducted a search to determine whether lobbyists properly disclosed their covered position as required by the LDA  We reviewed the lobbyists’ previous work histories by searching lobbying firms’ websites, LinkedIn, Leadership Directories, Legistorm, and Google  Prior to 2008, lobbyists were only required to disclose covered official positions held within 2 years of registering as a lobbyist for the client  The Honest Leadership and Open Government Act of 2007 amended that time frame to require disclosure of positions held 20 years before the date the lobbyists first lobbied on behalf of the client  Lobbyists are required to disclose previously held covered official positions either on the client registration (LD-1) or on an LD-2 report  Consequently, those who held covered official positions may have disclosed the information on the LD-1 or a LD-2 report filed prior to the report we examined as part of our random sample  Therefore, where we found evidence that a lobbyist previously held a covered official position, and that information was not disclosed on the LD-2 report under review, we conducted an additional review of the publicly available Secretary of the Senate or Clerk of the House database to determine whether the lobbyist properly disclosed the covered official position on a prior report or LD-1  Finally, if a lobbyist appeared to hold a covered position that was not disclosed, we asked for an explanation at the interview with the lobbying firm to ensure that our research was accurate  In previous reports, we reported the lower bound of a 90 percent confidence interval to provide a minimum estimate of omitted covered positions and omitted contributions with a 95 percent confidence level  We did so to account for the possibility that our searches may have failed to identify all possible omitted covered positions and contributions  As we have developed our methodology over time, we are more confident in the comprehensiveness of our searches for these items  Accordingly, this report presents the estimated percentages for omitted contributions and omitted covered positions, rather than the minimum estimates  As a result, percentage estimates for these items will differ slightly from the minimum percentage estimates presented in prior reports  In addition to examining the content of the LD-2 reports, we confirmed whether the most recent LD-203 reports had been filed for each firm and lobbyist listed on the LD-2 reports in our random sample  Although this review represents a random selection of lobbyists and firms, it is not a direct probability sample of firms filing LD-2 reports or lobbyists listed on LD-2 reports  As such, we did not estimate the likelihood that LD-203 reports were appropriately filed for the population of firms or lobbyists listed on LD-2 reports  To determine if the LDA’s requirement for lobbyists to file a report in the quarter of registration was met for the third and fourth quarters of 2016 and the first and second quarters of 2017, we used data filed with the Clerk of the House to match newly filed registrations with corresponding disclosure reports  Using an electronic matching algorithm that includes strict and loose text matching procedures, we identified matching disclosure reports for 2,995, or 87 2 percent, of the 3,433 newly filed registrations  We began by standardizing client and lobbyist names in both the report and registration files (including removing punctuation and standardizing words and abbreviations, such as “company” and “CO”)  We then matched reports and registrations using the House identification number (which is linked to a unique lobbyist-client pair), as well as the names of the lobbyist and client  For reports we could not match by identification number and standardized name, we also attempted to match reports and registrations by client and lobbyist name, allowing for variations in the names to accommodate minor misspellings or typos  For these cases, we used professional judgment to determine whether cases with typos were sufficiently similar to consider as matches  We could not readily identify matches in the report database for the remaining registrations using electronic means  To assess the accuracy of the LD-203 reports, we analyzed stratified random samples of LD-203 reports from the 30,594 total LD-203 reports  The first sample contains 80 reports of the 9,474 reports with political contributions and the second contains 80 reports of the 20,335 reports listing no contributions  Each sample contains 40 reports from the year- end 2016 filing period and 40 reports from the midyear 2017 filing period  The samples from 2017 allow us to generalize estimates in this report to either the population of LD-203 reports with contributions or the reports without contributions to within a 95 percent confidence interval of within plus or minus 11 percentage points or fewer  Although our sample of LD- 203 reports was not designed to detect differences over time, we conducted tests of significance for changes from 2010 to 2017 and found no statistically significant differences after adjusting for multiple comparisons  While the results provide some confidence that apparent fluctuations in our results across years are likely attributable to sampling error, the inability to detect significant differences may also be related to the nature of our sample, which was relatively small and designed only for cross- sectional analysis  We analyzed the contents of the LD-203 reports and compared them to contribution data found in the publicly available Federal Elections Commission’s (FEC) political contribution database  We consulted with staff at FEC responsible for administering the database  We determined that the data are sufficiently reliable for the purposes of our reporting objectives  We compared the FEC-reportable contributions on the LD-203 reports with information in the FEC database  The verification process required text and pattern matching procedures so we used professional judgment when assessing whether an individual listed is the same individual filing an LD-203  For contributions reported in the FEC database and not on the LD-203 report, we asked the lobbyists or organizations to explain why the contribution was not listed on the LD-203 report or to provide documentation of those contributions  As with covered positions on LD-2 disclosure reports, we cannot be certain that our review identified all cases of FEC-reportable contributions that were inappropriately omitted from a lobbyist’s LD-203 report  We did not estimate the percentage of other non-FEC political contributions that were omitted because they tend to constitute a small minority of all listed contributions and cannot be verified against an external source  To identify challenges to compliance, we used a structured web-based survey and obtained the views from 88 different lobbying firms included in our sample on any challenges to compliance  The number of different lobbying firms is 88, which is less than our original sample of 98 reports because some lobbying firms had more than one LD-2 report included in our sample  We calculated responses based on the number of different lobbying firms that we contacted rather than the number of interviews  Prior to our calculations, we removed the duplicate lobbying firms based on the most recent date of their responses  For those cases with the same response date, the decision rule was to keep the cases with the smallest assigned case identification number  To obtain their views, we asked them to rate their ease with complying with the LD-2 disclosure requirements using a scale of “very easy,” “somewhat easy,” “somewhat difficult,” or “very difficult ” In addition, using the same scale we asked them to rate the ease of understanding the terms associated with LD-2 reporting requirements  To describe the resources and authorities available to the U S  Attorney’s Office for the District of Columbia (USAO) and its efforts to improve its LDA enforcement, we interviewed USAO officials  We obtained information on the capabilities of the system officials established to track and report compliance trends and referrals and on other practices established to focus resources on LDA enforcement  USAO provided us with reports from the tracking system on the number and status of referrals and chronically noncompliant lobbyists and lobbying firms  The mandate does not require us to identify lobbyists who failed to register and report in accordance with the LDA requirements, or determine for those lobbyists who did register and report whether all lobbying activity or contributions were disclosed  Therefore, this was outside the scope of our audit  We conducted this performance audit from April 2017 to March 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 random sample of lobbying disclosure reports we selected was based on unique combination of House ID, lobbyist, and client names (see table 8)  See table 9 for a list of the lobbyists and lobbying firms from our random sample of lobbying contribution reports with contributions  See table 10 for a list of the lobbyists and lobbying firms from our random sample of lobbying contribution reports without contributions  In addition to the contact named above, Clifton G  Douglas Jr  (Assistant Director), Shirley Jones (Assistant General Counsel) and Ulyana Panchishin (Analyst-In-Charge) supervised the development of this report  James Ashley, Ann Czapiewski, Krista Loose, Kathleen Jones, Amanda Miller, Sharon Miller, Stewart W  Small, and Kayla L  Robinson made key contributions to this report  Assisting with lobbyist file reviews were Justine Augeri, Matthew Bond, James A  Howard, Jesse Jordan, Sherrice Kerns, Dalton Matthew Lauderback, Alexandria Palmer, Alan Rozzi, Shane Spencer, Jessica Walker, Ralanda Winborn, and Kate Wulff  Lobbying Disclosure: Observations on Lobbyists’ Compliance with New Disclosure Requirements  GAO-08-1099  Washington, D C: September 30, 2008  2008 Lobbying Disclosure: Observations on Lobbyists’ Compliance with Disclosure Requirements  GAO-09-487  Washington, D C: April 1, 2009  2009 Lobbying Disclosure: Observations on Lobbyists’ Compliance with Disclosure Requirements  GAO-10-499  Washington, D C: April 1, 2010  2010 Lobbying Disclosure: Observations on Lobbyists’ Compliance with Disclosure Requirements  GAO-11-452  Washington, D C: April 1, 2011  2011 Lobbying Disclosure: Observations on Lobbyists’ Compliance with Disclosure Requirements  GAO-12-492  Washington, D C: March 30, 2012  2012 Lobbying Disclosure: Observations on Lobbyists’ Compliance with Disclosure Requirements  GAO-13-437  Washington, D C: April 1, 2013  2013 Lobbying Disclosure: Observations on Lobbyists’ Compliance with Disclosure Requirements  GAO-14-485  Washington, D C: May 28, 2014  2014 Lobbying Disclosure: Observations on Lobbyists’ Compliance with Disclosure Requirements  GAO-15-310  Washington, D C : March 26, 2015  2015 Lobbying Disclosure: Observations on Lobbyists’ Compliance with Disclosure Requirements  GAO-16-320  Washington, D C : March 24, 2016  2016 Lobbying Disclosure: Observations on Lobbyists’ Compliance with Disclosure Requirements  GAO-17-385  Washington, D C : March 31, 2017 

ground_truth: The LDA, as amended, requires lobbyists to file quarterly disclosure reports and semiannual reports on certain political contributions. The law also includes a provision for GAO to annually audit lobbyists' compliance with the LDA. GAO's objectives were to (1) determine the extent to which lobbyists can demonstrate compliance with disclosure requirements, (2) identify challenges to compliance that lobbyists report, and (3) describe the resources and authorities available to USAO in its role in enforcing LDA compliance, and the efforts USAO has made to improve enforcement. This is GAO's 11th report under the provision. GAO reviewed a stratified random sample of 98 quarterly disclosure LD-2 reports filed for the third and fourth quarters of calendar year 2016 and the first and second quarters of calendar year 2017. GAO also reviewed two random samples totaling 160 LD-203 reports from year-end 2016 and midyear 2017. This methodology allowed GAO to generalize to the population of 45,818 disclosure reports with $5,000 or more in lobbying activity, and 30,594 reports of federal political campaign contributions. GAO also met with officials from USAO to obtain status updates on its efforts to focus resources on lobbyists who fail to comply. GAO is not making any recommendations in this report. GAO provided a draft of this report to the Department of Justice for review and comment. The Department of Justice provided technical comments, which GAO incorporated as appropriate. For the 2017 reporting period, most lobbyists provided documentation for key elements of their disclosure reports to demonstrate compliance with the Lobbying Disclosure Act of 1995, as amended (LDA). For lobbying disclosure (LD-2) reports and political contributions (LD-203) reports filed during the third and fourth quarter of 2016 and the first and second quarter of 2017, GAO estimates that 87 percent of lobbyists filed reports as required for the quarter in which they first registered; the figure below describes the filing process and enforcement; 99 percent of all lobbyists who filed (up from 83 percent in 2016) could provide documentation for income and expenses; and 93 percent filed year-end 2016 LD-203 reports as required. These findings are generally consistent with prior reports GAO issued for the 2010 through 2016 reporting periods. However, in recent years GAO's findings showed some variation in the estimated percentage of reports with supporting documentation. For example, an estimated increase in lobbyists who could document expenses is notable in 2017 and represents a statistically significant increase from 2016. As in GAO's other reports, some lobbyists were still unclear about the need to disclose certain previously held covered positions, such as paid congressional internships or certain executive agency positions. GAO estimates that 15 percent of all LD-2 reports may not have properly disclosed previously held covered positions. On the other hand, over the past several years of reporting on lobbying disclosure, GAO found that most lobbyists in the sample rated the terms associated with LD-2 reporting as “very easy” or “somewhat easy” to understand. The U.S. Attorney's Office for the District of Columbia (USAO) stated it has sufficient resources and authority to enforce compliance with the LDA. USAO continued its efforts to bring lobbyists into compliance by reminding them to file reports or by applying civil penalties.