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



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



Report 2: Since the late 1700s, Congress has expressed public gratitude to individuals and groups by awarding medals and other similar decorations  The first Congressional Gold Medals were issued by the Continental Congress  Since that time, Congress has awarded gold medals to express public gratitude for distinguished contributions, dramatize the virtues of patriotism, and perpetuate the remembrance of great events  This tradition of authorizing individually struck gold medals bearing the portraits or actions of honorees is rich with history  Although Congress has approved legislation stipulating specific requirements for numerous other awards and decorations, there are no permanent statutory provisions specifically relating to the creation of Congressional Gold Medals  When such an award has been deemed appropriate, Congress has, by special action, provided for the creation of a personalized medal to be given in its name  The first Congressional Gold Medals were issued by the Continental Congress  As initially conceived, Congressional Gold Medals were awards "imbued with the conviction that only the very highest achievements [were] entitled to such a distinction, and that the value of a reward is enhanced by its rarity!" At that time, the Continental Congress concluded there was no better way to honor "and preserve the memory of illustrious characters and splendid events than medals—whether we take into consideration the imperishable nature of the substance whence they are formed, the facility of multiplying copies, or the practice of depositing them in the cabinets of the curious " The first gold medals were struck in Paris under the direction of Colonel David Humphrey  Following a long-standing historical practice, Congress commissioned gold medals as tributes for what were considered to be the most distinguished achievements  Silver and bronze medals, and ceremonial swords, were awarded for less eminent, but still notable, accomplishments  However, only the gold medal has been continuously awarded to the present day  The first Congressional Gold Medal was authorized on March 25, 1776, for George Washington, then commander of the Continental Army, for his "wise and spirited conduct" in bringing about British evacuation of Boston  During the next 12 years, the Continental Congress authorized an additional six gold medals for Revolutionary military leaders  Table 1 lists the Congressional Gold Medals issued by the Continental Congress, the year, the awardee, and the reason the medal was authorized  The gold medal conferred upon Major Henry "Light Horse Harry" Lee for his "remarkable prudence" and "bravery" during the surprise raid of Paulus Hook, NJ, was the first to be struck in the United States  Following the ratification of the Constitution, the first two Congressional Gold Medals were given in 1800 to Captain Thomas Truxtun for his gallant effort during the action between the U S  frigate Constellation and the French ship La Vengeance and in 1805 to Commodore Edward Preble for gallantry and good conduct during the War with Tripoli  After those medals were awarded, Congress issued gold medals primarily for military achievements in the War of 1812 and the Mexican War  All told, 27 gold medals were awarded for the War of 1812, and a series of medals were awarded for expeditions led by Major General Zachary Taylor and Major General Winfield Scott in the Mexican War  General Taylor received three Congressional Gold Medals, while General Scott received one  In 1854, Congress began to broaden the scope of activities that merited a Congressional Gold Medal  This change was prompted by Commander Duncan N  Ingraham of the USS St  Louis 's rescue of Martin Koszta from illegal seizure and imprisonment about the Austrian war-brig Hussar   Subsequently, gold medals were issued to several individuals recognized for nonmilitary heroic activities or their work in specific fields  For example, in 1864 Cornelius Vanderbilt was honored for donating a steamship to the United States; in 1867 Cyrus W  Field was praised for his work in the laying of the transatlantic cable; and Private George F  Robinson was awarded for saving Secretary of State William H  Seward from an assassination attempt  At this time, Congress also established the Medal of Honor as a military award and increasingly focused the Congressional Gold Medal as an award for individuals and events  In the 20 th and 21 st centuries, Congress continued to broaden the scope of Congressional Gold Medals to include recognition of excellence in such varied fields as the arts, athletics, aviation, diplomacy, entertainment, exploration, medicine, politics, religion, and science  Several of the following individuals were the first in their specialties to be awarded gold medals: Composer George M  Cohan (1936) was the first entertainer to receive a gold medal, for his patriotic songs "Over There" and "A Grand Old Flag " Wilbur and Orville Wright (1909) were the first aeronautical or space pioneers to receive a gold medal, for their achievements in demonstrating to the world the potential of aerial navigation  Lincoln Ellsworth (1926) was the first explorer honored, for his polar flight in 1925 and transpolar flight in 1926  Major Walter Reed and his associates (1928) were the first scientists honored, for discovering the cause and means of transmission of yellow fever in 1921  Vice President Alben W  Barkley (1949) was the first political honoree  In the late 20 th and early 21 st centuries, numerous other individuals have been honored for a variety of contributions including civil rights activism and humanitarian contributions  For a complete list of Congressional Gold Medal recipients since 1776, see the Appendix   Once a Congressional Gold Medal bill is introduced, it is typically referred to the House Committee on Financial Services or the Senate Committee on Banking, Housing, and Urban Affairs  The process for considering legislation varies between the House and Senate  In the House, there are currently no chamber or committee rules regarding the procedures for gold medal bills  In some past Congresses, the House Financial Services Committee had adopted a committee rule that prohibited its Domestic Monetary Policy and Technology Subcommittee from holding a hearing on commemorative medal legislation—including Congressional Gold Medals—"unless the legislation is cosponsored by at least two-thirds of the members of the House " Informal practices regarding cosponosrship requirements, however, may still exist  In the Senate, the Banking, Housing, and Urban Affairs Committee in the 116 th Congress requires that at least 67 Senators cosponsor any Congressional Gold Medal bill before being considered by the committee  This committee rule presumably does not formally preclude committee consideration of a House bill referred to it  The committee rule also does not prevent the Senate from considering or passing gold medal legislation  Referred bills may be brought to the floor without committee consideration; in other cases, a bill may avoid being referred to committee at all  In current practice, many enacted gold medal bills receive no formal committee consideration  Rather, the Senate often discharges the committee of the bill by unanimous consent; however, it appears that this discharge practice only occurs after the requisite number of cosponsors sign on to a Senate bill  Although Congress has approved legislation stipulating requirements for numerous other awards and decorations, there are no permanent statutory provisions specifically relating to the creation of Congressional Gold Medals  When a Congressional Gold Medal has been deemed appropriate, Congress has, by legislative action, provided for the creation of a medal on an ad hoc basis  Additionally, there is no statutory limit on the number of Congressional Gold Medals that may be struck in a given year  Congressional Gold Medal legislation generally has certain features, including findings that summarize the subject's history and importance; specifications for awarding the medal; instructions, if any, for the medal's design and striking; permission to mint and sell duplicates; and certification that medals are minted pursuant to existing requirements for national medals (5 U S C  §5111)  Congressional Gold Medal legislation typically includes a section of findings  These often include historical facts about the people or groups being awarded the medal  For example, the legislation to authorize the Congressional Gold Medal to the World War II members of the "Doolittle Tokyo Raiders" stated the following: Congressional Gold Medal legislation typically includes a section that provides details on the presentation, design, and striking of the medal  For example, the legislation to authorize the Congressional Gold Medal to the Foot Soldiers who participated in Bloody Sunday, Turnaround Tuesday, or the final Selma to Montgomery Voting Rights March in March of 1965 stated the following: Additionally, this section can contain specific instructions to the Smithsonian, when it is the recipient of the physical gold medal, on its display and availability to be loaned to other institutions  For example, the legislation authorizing the American Fighter Aces Congressional Gold Medal stated the following: Gold medal legislation also generally authorizes the Secretary of the Treasury to strike and sell duplicate medals in bronze  The duplicates are generally sold in two sizes: 1 5 inches and 3 inches  Duplicates are sold at a price which allows the U S  Mint to cover the cost of striking the gold medal  For example, legislation authorizing the 65 th Infantry Regiment, known as the Borinqueneers, Congressional Gold Medal stated the following: Gold medal legislation generally contains a statement that these awards are considered as national medals for the purpose of the U S  Mint's statutory requirements for producing medals  For example, legislation authorizing the Montford Point Marines Congressional Gold Medal stated the following: In some cases, authorizing legislation includes language authorizing appropriations for a Congressional Gold Medal  In these examples, Congress has authorized a specific sum from the United States Mint Public Enterprise Fund to pay for the cost of the medal  In cases where the authorization of appropriations is provided, a provision requiring that proceeds from the sale of duplicates be deposited in the same Fund is generally included  For example, legislation authorizing the Women Airforce Service Pilots Congressional Gold Medal stated the following: Congressional Gold Medal designs vary for each issuance  In general, the authorizing legislation provides that the Secretary of the Treasury "shall strike a gold medal with suitable emblems, devices, and inscriptions, to be determined by the Secretary " When designing a Congressional Gold Medal, the Secretary consults with the Citizens Coinage Advisory Commission (CCAC) and the U S  Commission of Fine Arts (CFA) before determining the final design  Established by P L  108-15 , the CCAC advises the Secretary of the Treasury on theme and design of all U S  coins and medals  For Congressional Gold Medals, the CCAC advises the Secretary "on any theme or design proposals relating to     Congressional Gold Medals " The CCAC consists of 11 members appointed by the Secretary of the Treasury, with four persons appointed upon the recommendation of the congressional leadership (one each by the Speaker of the House, the House minority leader, the Senate majority leader, and the Senate minority leader)  The CCAC meets several times each year to consider design suggestions for coins and medals  For each coin considered, the CCAC provides advice to the Secretary "on thematic, technical, and design issues related to the production of coins " Recommendations are then published to the committee's website, at http://www
Report 2:  The provider emphasized concerns about the long-term viability of caring for those patients at the facility, because their care is paid at lower rates  Our review of Medicare claims data, other information, and interviews with stakeholders indicated the two qualifying hospitals treated Medicare beneficiaries with different conditions than most of those treated at other LTCHs  Our analysis of Medicare claims data indicates Craig Hospital and Shepherd Center treat very few patients in the Medicare diagnosis groups that are most common to other LTCHs  Specifically, for several years, MedPAC has reported that LTCH patient discharges are concentrated in a relatively small number of diagnosis groups  For example, in March 2018, MedPAC reported that 20 diagnosis groups accounted for over 61 percent of LTCH discharges at both for-profit and not-for-profit facilities, in fiscal year 2016  However, in fiscal year 2016, these diagnosis groups accounted for approximately 30 percent of Medicare discharges—26 out of 88—at Shepherd Center, and most of these discharges fell within a single diagnosis group which covers a range of conditions  Craig Hospital did not discharge any Medicare beneficiaries assigned to these 20 diagnosis groups, in fiscal year 2016  The seven diagnosis groups that were used in the statutory criteria to except Craig Hospital and Shepherd Center from site-neutral payments were also not among these 20 diagnosis groups  For more information on the 20 diagnosis groups common to LTCHs in fiscal year 2016, see Appendix III, table 5  Our review of Medicare claims data and other information indicates the two qualifying hospitals also treat a relatively small number of Medicare beneficiaries, a key distinguishing factor from most other LTCHs  In March 2018, MedPAC reported that, on average, Medicare beneficiaries account for about two-thirds of LTCH discharges  However, Medicare claims data and other information provided by the two qualifying hospitals indicate Medicare beneficiaries account for a significantly smaller proportion (about 8 percent) of patients discharged from Craig Hospital and Shepherd Center in 2016  Specifically, 40 of the 486 patients discharged from Craig Hospital in fiscal year 2016 and 75 of the 912 patients discharged from Shepherd Center in calendar year 2016, were Medicare beneficiaries  Officials from the qualifying hospitals told us they treat few Medicare patients primarily because of the younger average age of persons with spinal cord injuries and acquired brain injuries  While patients with spinal cord and brain injuries may receive care in other LTCHs, most stakeholders we interviewed also suggested the two qualifying hospitals treat patients that are different from those treated at most other LTCHs, and can offer specialized care  Officials from the two qualifying hospitals told us that, relative to most other facilities—including most traditional LTCHs—they offer a more complete continuum of care to meet the needs of patients at different stages of spinal cord and brain injury treatment, without the need to transfer to different facilities  Officials also stated that, unlike most traditional LTCHs, they are able to offer more specialized care for patients with spinal cord and brain injuries, including more comprehensive rehabilitation services  Stakeholders we interviewed generally agreed that the two qualifying hospitals have developed expertise in treating spinal cord and brain injury patients and offer intensive rehabilitation services that are not provided in most other LTCHs  In addition, officials from the Colorado Department of Health Care Policy & Financing noted that Craig Hospital treats a patient population that is different from most other LTCHs in the state of Colorado  Specifically, according to officials, in comparison to other LTCHs in the state, Craig Hospital treats: (1) a higher percentage of patients with more severe conditions, (2) more patients from outside the state of Colorado, (3) fewer patients requiring ventilator weaning or requiring wound care— conditions typically characteristic of LTCH patients—and (4) patients that are, on average, younger than most other LTCHs in the state of Colorado  In addition, a 2014 study of LTCHs conducted for the Georgia Department of Community Health found Shepherd Center was “distinctly different” from other LTCHs in the state of Georgia, and most LTCHs nationwide  Most stakeholders we interviewed suggested some IRFs provide specialty care to patients with catastrophic spinal cord, acquired brain injuries, or other paralyzing neuromuscular conditions  Most of the stakeholders we interviewed noted that—like the two qualifying hospitals—some IRFs have the expertise to treat patients with catastrophic spinal cord, acquired brain injuries, or other paralyzing neuromuscular conditions patients and thus, may also treat patients with similar conditions  According to CMS officials, IRFs are specifically designed to provide post-acute rehabilitation services to patients with spinal cord injuries, brain injuries, and other neuromuscular conditions  CMS officials noted that patients with these conditions typically respond well to intensive rehabilitation therapy provided in a resource intensive inpatient hospital environment and to the specific interdisciplinary approach to care that is provided in the IRF setting  Stakeholders also noted that patients with spinal cord injuries, brain injuries, and other neuromuscular conditions may receive care in other settings  However, some stakeholders noted that some of these providers—such as skilled nursing facilities—generally do not offer the specialized care these patients generally require  Differences in payment systems and data limitations make it difficult to directly compare the attributes of Medicare beneficiaries discharged from the two qualifying hospitals and IRFs, including the costs of care they receive  Medicare uses separate payment systems to pay LTCHs and IRFs, for care provided to beneficiaries  LTCHs are paid pre-determined fixed amounts for care provided to Medicare beneficiaries, under the LTCH PPS  Medicare beneficiaries treated in LTCHs are assigned to diagnosis groups (MS-LTC-DRGs) for each stay—based on the patient’s primary and secondary diagnoses, age, gender, discharge status, and procedures performed  IRFs are also paid pre-determined fixed amounts for care provided to Medicare beneficiaries, but under a separate system—IRF PPS  Medicare beneficiaries treated in IRFs are assigned to case-mix groups—based on age, and level of motor and cognitive function—and then further assigned to one of four tiers (within these groups) based on the presence of specific comorbidities that may increase their cost of care  According to CMS officials, because the payment groups and assignments to those groups are different, it is difficult to directly compare LTCH patients, classified in diagnosis groups, with IRF patients, classified in case-mix groups  See Appendix II for more information on these payment systems  MedPAC has previously reported the differences in patient assessment tools used by post-acute care providers undermines Medicare’s ability to compare the patients admitted, costs of care, and outcomes beneficiaries achieve in these settings, on a risk-adjusted basis  MedPAC has also reported that while similar beneficiaries can receive care in each setting, payments can differ considerably for comparable conditions, due to differences in payment systems  It has made recommendations to address these issues  The Improving Medicare Post-Acute Care Transformation Act of 2014 also requires the Secretary of HHS to collect and analyze common patient assessment information and, in consultation with MedPAC, submit a report to Congress recommending a post-acute care PPS  Such efforts may make future comparison of beneficiaries, costs of services, and outcomes of care across these settings possible  While data limitations make a direct comparison difficult, based on our review of other data and information, and interviews with stakeholders, we identified similarities and differences between the qualifying hospitals and certain IRFs that provide specialty treatment for catastrophic spinal cord injuries, acquired brain injuries, or other paralyzing neuromuscular conditions  Key similarities and differences include the following: Volume of services  Our review of Medicare claims data, other information, and interviews with stakeholders indicate that—similar to the two qualifying hospitals—some IRFs treat a high volume (at least 100) of patients with complex spinal cord injury, brain injury, and other related conditions  Officials from the two qualifying hospitals, as well as some other stakeholders we interviewed—including officials from the Christopher & Dana Reeve Foundation and the Brain Injury Association of America—emphasized the importance of facilities treating a high volume of patients with these specialized conditions, which can be an indicator of expertise in treating these patients  Our review of Medicare claims data for 1,148 IRFs in fiscal year 2016 identified 21 IRFs that treated at least 100 Medicare beneficiaries with non-traumatic and traumatic spinal cord injuries and 109 IRFs that treated at least 100 Medicare beneficiaries with non-traumatic and traumatic brain injuries  Our review of Medicare claims data indicated that, similar to the two qualifying hospitals—some IRFs also treat a high volume of patients with “catastrophic” injuries—traumatic brain injury, traumatic spinal cord injury, and major multiple traumas with brain or spinal cord injuries  Specifically, we identified 25 IRFs that treated a high volume (at least 100) of Medicare beneficiaries with catastrophic injuries, in fiscal year 2016  In the absence of patient assessment data from the facilities, we did not independently evaluate the level and severity of these patients’ injuries, which can vary due to the presence of other co-morbid conditions  The Medicare case mix indexes we reviewed for these 25 IRFs indicated that, relative to other IRFs, most of these facilities treat patients who are more resource intensive  Specialty accreditation and designation as model systems  Like Shepherd Center, some IRFs receive CARF-accreditation for specialty programs to treat spinal cord and brain injuries  According to most stakeholders, this accreditation indicates expertise in treating these patients, as CARF International has established standards using evidence-based practices, among other factors  Officials from the two qualifying hospitals also noted CARF International has a specific focus on quality and outcomes  However, officials from Shepherd Center noted similarities in care and services offered at CARF-accredited facilities would depend on the specialties for which they are certified  Most of the stakeholders we interviewed also noted that designation as a NIDILRR model system is an indicator of similar expertise in treating patients with spinal cord and brain injuries  According to the Model Systems Knowledge Translation Center, spinal cord injury and brain injury model systems are recognized as national leaders in medical research and patient care and provide the highest level of comprehensive specialty services from the point of injury through eventual re-entry into full community life  While stakeholders we interviewed from NIDILRR model systems indicated the model system designation is focused primarily on research, rather than clinical care, most noted that model systems’ research often complements the facilities’ clinical efforts to address the unique needs of these patients  Officials from HHS’s Administration for Community Living also noted that all model system grantees must provide a continuum of care—emergency care, acute medical care, acute medical rehabilitation, and post-acute care—and that can happen in various provider types  According to officials from the qualifying hospitals and stakeholders from one other NIDILRR model system we interviewed, Craig Hospital and Shepherd Center are the only two LTCHs currently classified as spinal cord injury model systems; 12 of 14 spinal cord injury model systems are IRFs  Specialized programs and services  Similar to the two qualifying hospitals, some IRFs may also offer specialized programs and services for patients with brain and spinal cord injuries, but the availability of these programs and services may vary by facility  Officials from some of the IRFs that responded to our information request—which included both NIDILRR facilities and IRFs with CARF-accredited programs—told us they provide specialized programs and services for patients with similar conditions as those treated at two qualifying hospitals, and sometimes compete with the two qualifying hospitals for the same patients  For example, each IRF reported having interdisciplinary treatment teams; the capacity to provide medical management of medically complex and high acuity patients with spinal cord injury, traumatic brain injury, or other major multiple traumas associated with a brain or spinal cord injury; family education and training; and skin and wound programs or services, among other services  However, the availability of certain services—including but not limited to ventilator-dependent weaning programs, diaphragmatic pacing, and outpatient programs for spinal cord and traumatic brain injury patients—varied by facility  Staff with specialized training and clinical expertise  Similar to the two qualifying hospitals, most facilities that responded to our information request also reported having physicians, nurses, and physical and occupational therapists with specialty training in medical rehabilitation, spinal cord, and/or brain injury  However, the number of staff with these trainings, varied by facility  In comparison to the other facilities that responded to our information request, the number of nurses and physical and occupational therapists with these specialty trainings were generally higher at Craig Hospital and Shepherd Center  According to an American Spinal Injury Association consumer guideline that the Christopher & Dana Reeve Foundation typically provides to spinal cord injury patients and families, programs should regularly admit persons with spinal cord injury each year, to develop and maintain the necessary skills to manage a person with spinal cord injury, and a substantial portion of those admitted should have traumatic injuries  Out-of-state Admissions  Officials from the two qualifying hospitals emphasized they admit a significant number of patients from out-of-state, and our review of information provided by the qualifying hospitals and a select group of IRFs indicated the qualifying hospitals admit a higher percentage of patients from out-of-state  Specifically, information provided by these IRFs indicates that less than a quarter of patients admitted to these facilities, in 2016, were from out-of-state  Information provided by Craig Hospital and Shepherd Center indicate that about half of their patients were admitted from out-of-state in 2016  Officials from the Colorado Department of Health Care Policy & Financing also noted Craig Hospital treats a higher percentage of out-of-state patients, compared to IRFs in the state  Ability to treat medically complex patients  Officials from the two qualifying hospitals told us they treat more medically complex patients and provide a more complete range of medical services to spinal cord and brain injury patients, not provided by most IRFs  Specifically, officials from the two qualifying hospitals both noted they are able to treat patients much sooner in their recovery process than most IRFs, due to their LTCH status  Officials from the Shepherd Center noted that they have a 10-bed intensive care unit which allows them to take patients with certain injures that some IRFs may not be equipped to admit—such as patients requiring advance medical management and advanced level procedural services and monitoring  Information provided by Shepherd Center indicated that, in calendar year 2017, approximately 20 percent of all inpatients were admitted to this unit and 13 percent of all inpatients were internally transferred to this unit after developing medical complications  According to officials, Craig Hospital does not have an intensive care unit, but noted their ability to similarly care for medically complex patients—including telemetry (e g , specialized heart monitoring) and one-to-one nursing care, if necessary  Most stakeholders we interviewed agreed that both qualifying hospitals’ LTCH status provides certain advantages over IRFs, such as the ability to admit some medically complex patients earlier in the recovery process and longer lengths of stay  Stakeholders from most of the IRFs we interviewed also reported having the flexibility to admit some medically complex patients requiring more advanced level monitoring and resources earlier in the recovery process—such as patients with disorders of consciousness  Officials from the two qualifying hospitals also said they offer a continuum of care that can meet patient’s changing needs, without the need to transfer them to different facilities  Information provided by Craig Hospital indicated that 83 percent of patients treated at its facility, in 2016, were discharged to home, 13 percent were discharged to another post-acute care facility, and 3 percent were discharged to an acute care hospital  In 2016, approximately 91 percent of patients treated at Shepherd Center were discharged to home, 7 percent were discharged to another post- acute care facility, and 2 percent were discharged to an acute care hospital  Information provided by the IRFs that responded to our written request varied by facility, but—similar to the two qualifying hospitals— each facility discharged more than 65 percent of patients to home  IRF payment criteria  CMS and most other stakeholders we interviewed noted that two Medicare payment policies applicable to IRFs, but not LTCHs, may contribute to their different patient populations  Specifically, to be classified for payment under Medicare’s IRF PPS, at least 60 percent of the IRF’s total inpatient population must require intensive rehabilitative treatment for one or more of 13 conditions—which includes both spinal cord and brain injury  To be admitted to an IRF, Medicare beneficiaries must reasonably be expected to actively participate in and benefit from the intensive rehabilitation therapy program, typically provided in IRFs  According to HHS, per industry standard, the intensive rehabilitation therapy program is often demonstrated by providing three hours of rehabilitation services per day for at least five days per week, but this is not the only way such intensity can be demonstrated  Officials from the two qualifying hospitals told us they generally use Medicare’s intensive rehabilitation requirement as a minimum standard for their rehabilitation patients—even though they are not held to this requirement, for the purposes of Medicare payment—but noted that some of their patients may not meet this requirement, due to their medical complexity  Length of stay and site-neutral payment requirements, for LTCHs  As previously noted, LTCHs—including the two qualifying hospitals—must have an average length of stay of greater than 25 days; IRFs are not subject to this requirement  The average length of stay for patients discharged from the Craig Hospital was about 60 days, in fiscal year 2016, and the average length of stay for patients discharged from Shepherd Center was about 53 days, in calendar year 2016  Stakeholders from the IRFs that responded to our information request reported average lengths of stay ranging from 14 to 31 days, for patients discharged in fiscal year 2016; the ranges of lengths of stay were slightly higher for spinal cord injury and traumatic brain injury inpatients for the IRFs, during the same period  LTCHs are also generally subject to site- neutral payment policy that is not applicable to IRFs and may decrease LTCHs payments for certain discharges, under Medicare  Other services provided  In addition to these Medicare specific differences, a few stakeholders we interviewed also noted the two qualifying hospitals receive additional funding from their strong philanthropic donor base that may allow them to provide other services and resources, not covered by Medicare or offered at some IRFs  For example, while a few IRFs that responded to our information request reported offering housing for families of injured patients, the two qualifying hospitals offer up to 30 days of free housing to families of newly injured rehabilitation patients, if both the family and patient live more than 60 miles from the hospital  Officials from Shepherd Center told us their revenues are supplemented by investment income and donor funds  Craig Hospital has also established a foundation that supports the hospital in achieving its goals through philanthropy  We provided a draft of this report to HHS  HHS provided technical comments, which we incorporated as appropriate  We also provided the two qualifying hospitals summaries of information we collected from them, to confirm the accuracy of statements included in our draft report  We incorporated their comments, as appropriate  We are sending copies of this report to the Secretary of Health and Human Services and other interested parties  In addition, the report will be available at no charge on GAO’s website at http://www gao gov  If you or your staff have any questions about this report, please contact me at (202) 512-7114 or at farbj@gao gov  Contact points for our Office of Congressional Relations and Office of Public Affairs can be found on the last page of this report  Other major contributors to this report are listed in appendix IV  This appendix describes our methodology for conducting simulations of payments for the two qualifying hospitals  We used Medicare claims data to conduct simulations of payments for the two qualifying hospitals  We first identified discharges at each hospital in two baseline years—federal fiscal years 2013 and 2016  We selected fiscal year 2016 because it was the year with the most recent data available at the time of our analysis, and we selected a second baseline year because data for 2016 was different than data for other recent years  For example, the number of discharges for one qualifying hospital declined by nearly half between fiscal years 2013 and 2016  We chose fiscal year 2013 because data from that year was used to help determine which hospitals are subject to the temporary exception  To identify how to appropriately calculate the long-term care hospital (LTCH) payment for each of these discharges in future payment years, we reviewed applicable federal regulation and documents from the Centers for Medicare & Medicaid Services (CMS) and the Medicare Payment Advisory Commission (MedPAC), and interviewed officials from both organizations  See table 4 for the relevant components in the formulas, such as Medicare severity long-term care diagnosis related group (MS-LTC-DRG) weights, identified from final rule tables  When conducting these simulations, we made the following assumptions: For simulated payments for payment policies in effect for fiscal years 2017 and 2018, we used the base rates, relative weights (e g , the MS-LTC-DRG weights), geometric mean length of stay, wage index, geographic adjustment factor, fixed-loss amounts, and outlier thresholds that were published in the final rule tables for LTCH and inpatient prospective payment system (IPPS) hospitals—also known as acute care hospitals—for each respective year  At the time we began our analysis, this information was not known for fiscal years 2019 through 2021  We chose to use the fiscal year 2018 rates when conducting simulations for payment policies in those years because historical trends showed that annual changes were minimal—about 1 percent  Therefore, to the extent that these values continue to change over time, our findings may understate or overstate the amount that the qualifying hospitals would have been paid in our baseline years based on these future payment policies  The site-neutral payment policy did not apply to discharges from the fiscal year 2013 baseline year  Therefore, we examined Medicare claims data to determine whether each discharge would have met the criteria to receive the LTCH standard rate in that year  Specifically, we determined whether each discharge had an acute care hospital stay that immediately preceded their LTCH stay  We then determined whether the time at the acute care hospital included three or more days in the intensive care unit or whether there was a code on the LTCH claim that indicated at least 96 hours of mechanical ventilation services were provided  Per Medicare’s payment policy, we assumed any discharge that met these two criteria would qualify for full LTCH payment rate, unless the case was a psychiatric or rehabilitation stay, as identified by the following MS-LTC-DRG codes: 876, 880, 881, 882, 883, 884, 885, 886, 887, 894, 895, 896, 897, 945, or 946  Under statute, unless 50 percent or more of the hospital’s discharges beginning during or after 2020 qualify for the standard rate, no subsequent payments will be made to a hospital at that rate  Therefore, when calculating simulated payments for fiscal year 2021, we applied the 50 percent threshold  At the time of our analysis, CMS had not yet finalized this policy through rule-making  As of November 2018, CMS officials told us that it is unlikely that any payment adjustment under this provision would apply until 2022 because the percentage cannot be determined until after an LTCH’s cost reporting period has ended and data have been submitted  Shepherd Center’s fiscal year is different than the federal fiscal year  Therefore, the variables used to determine whether discharges in federal fiscal year 2016 met criteria to receive the standard rate were not available to use for some of the discharges that year  Of those discharges, we assumed that the same percentage of discharges that met the criteria to receive the standard rate in Shepherd’s fiscal year—30 percent—met the criteria in federal fiscal year 2016  When calculating site-neutral payments, we assumed that each discharge would be paid at a rate comparable to that for acute care hospitals—the IPPS comparable amount rate  Site-neutral payments may also be based on the estimated cost-of-care, if it is lower than the IPPS comparable amount rate  However, over 90 percent of discharges at the qualifying hospitals were paid at the IPPS comparable amount rate in fiscal year 2016  Per CMS’s recommendation, we applied the cost-to-charge ratio that was effective October 1, 2017, for each qualifying hospital, regardless of discharge date  For Craig Hospital this value was 0 442 and for Shepherd Center this value was 0 464  According to CMS officials, in general, these values do not change significantly when they are updated during the fiscal year  Therefore, they believe that using the values effective at the start of the fiscal year is a reasonable assumption  We excluded indirect medical education adjustments and disproportionate share hospital payments that are part of the IPPS comparable amount rate because, according to CMS, they were unlikely to have much impact for these hospitals  CMS reviewed each of these assumptions and agreed they were reasonable for purposes of our analysis  CMS also verified that we were correctly applying the formulas for calculating these payments and using the appropriate values from the final rules  Figures 3 and 4 illustrate the methodology for calculating Medicare payments under the long-term care hospital (LTCH) prospective payment system (PPS) and the inpatient rehabilitation facility (IRF) PPS, respectively, as reported by the Medicare Payment Advisory Commission (MedPAC)  Appendix III: List of Common Diagnosis Groups for Long-Term Care Hospitals (LTCH) In its March 2018 annual report to the Congress, the Medicare Payment Advisory Commission (MedPAC) reported that 20 diagnosis groups accounted for over 61 percent of LTCH discharges at both for-profit and not-for-profit facilities, in fiscal year 2016  Table 5 provides a list of these 20 diagnosis groups  In addition to the contact named above, Will Simerl, Assistant Director; Kathy King; Amy Leone, Analyst-in-Charge; Todd Anderson; Sam Amrhein; LaKendra Beard; Rich Lipinski; Jennifer Rudisill; and Eric Wedum made key contributions to this report  Also contributing were Leia Dickerson, Diona Martyn, Vikki Porter, and Lisa Rogers 

ground_truth: Concerns over efforts by U.S. taxpayers to use offshore accounts to hide income or evade taxes contributed to the passage of FATCA in 2010, which sought to create greater transparency and accountability over offshore assets held by U.S. taxpayers. House Report 114-624 included a provision for GAO to evaluate FATCA implementation and determine the effects of FATCA on U.S. citizens living abroad. GAO—among other things—(1) assessed IRS's efforts to use FATCA-related information to improve taxpayer compliance; (2) examined the extent to which Treasury administers overlapping reporting requirements on financial assets held overseas; and (3) examined the effects of FATCA implementation unique to U.S. persons living abroad. GAO reviewed applicable documentation; analyzed tax data; and interviewed officials from IRS, other federal agencies and organizations, selected tax practitioners, and more than 20 U.S. persons living overseas. Data quality and management issues have limited the effectiveness of the Internal Revenue Service's (IRS) efforts to improve taxpayer compliance using foreign financial asset data collected under the Foreign Account Tax Compliance Act (FATCA). Specifically, IRS has had difficulties matching the information reported by foreign financial institutions (FFI) with U.S. taxpayers' tax filings due to missing or inaccurate Taxpayer Identification Numbers provided by FFIs. Further, IRS lacks access to consistent and complete data on foreign financial assets and other data reported in tax filings by U.S. persons, in part, because some IRS databases do not store foreign asset data reported from paper filings. IRS has also stopped pursuing a comprehensive plan to leverage FATCA data to improve taxpayer compliance because, according to IRS officials, IRS moved away from updating broad strategy documents to focus on individual compliance campaigns. Ensuring access to consistent and complete data collected from U.S. persons—and employing a plan to leverage such data—would help IRS better leverage such campaigns and increase taxpayer compliance. Due to overlapping statutory reporting requirements, IRS and the Financial Crimes Enforcement Network (FinCEN)—both within the Department of the Treasury (Treasury)—collect duplicative foreign financial account and other asset information from U.S. persons. Consequently, in tax years 2015 and 2016, close to 75 percent of U.S. persons who reported information on foreign accounts and other assets on their tax returns also filed a separate form with FinCEN. The overlapping requirements increase the compliance burden on U.S. persons and add complexity that can create confusion, potentially resulting in inaccurate or unnecessary reporting. Modifying the statutes governing the requirements to allow for the sharing of FATCA information for the prevention and detection of financial crimes would eliminate the need for duplicative reporting. This is similar to other statutory allowances for IRS to disclose return information for other purposes, such as for determining Social Security income tax withholding. According to documents GAO reviewed, and focus groups and interviews GAO conducted, FFIs closed some U.S. persons' existing accounts or denied them opportunities to open new accounts after FATCA was enacted due to increased costs, and risks they pose under FATCA reporting requirements. According to Department of State (State) data, annual approvals of renunciations of U.S. citizenship increased from 1,601 to 4,449—or nearly 178 percent—from 2011 through 2016, attributable in part to the difficulties cited above. Treasury previously established joint strategies with State to address challenges U.S. persons faced in accessing foreign financial services. However, it lacks a collaborative mechanism to coordinate efforts with other agencies to address ongoing challenges in accessing such services or obtaining Social Security Numbers. Implementation of a formal means to collaboratively address burdens faced by Americans abroad from FATCA can help federal agencies develop more effective solutions to mitigate such burdens by monitoring and sharing information on such issues, and jointly developing and implementing steps to address them. GAO is making one matter for congressional consideration to address overlap in foreign asset reporting requirements. GAO is making seven recommendations to IRS and other agencies to enhance IRS's ability to leverage FATCA data to enforce compliance, address unnecessary reporting, and better collaborate to mitigate burdens on U.S. persons living abroad. State and Social Security Administration agreed with GAO's recommendations. Treasury and IRS neither agreed nor disagreed with GAO's recommendations.

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



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

Report 1: The United States has many international agreements that require treaty partners to provide certain information to IRS, which can help prevent the use of foreign bank accounts to facilitate tax evasion  FATCA goes much further, requiring FFIs to report more detailed information to IRS about their U S  customers annually  These provisions are important developments in efforts to combat tax evasion by U S  persons holding investments in offshore accounts  FATCA generally requires certain taxpayers to report foreign financial accounts and other specified foreign financial assets whose aggregate value exceeds specified thresholds to IRS on Form 8938  These taxpayers must report these assets and income generated from such assets to IRS with their tax return on Form 8938  These thresholds vary by filing status—such as single or married filing jointly—and by domestic or foreign residency  FATCA also promotes third-party reporting of foreign financial assets by requiring a withholding agent to withhold 30 percent on certain payments to an FFI unless the FFI or the jurisdiction in which the FFI is located has entered into an agreement with the United States to report certain account information of their U S  customers  Under such an agreement, participating FFIs report detailed information to IRS annually about accounts held by their U S  customers using an IRS Form 8966, FATCA Report (Form 8966)  According to IRS, FATCA improves visibility into taxable income from foreign sources, and enhances the agency’s ability to identify and pursue taxpayer noncompliance  For example, FATCA allows IRS to compare information reported by FFIs on Forms 8966 to information reported by U S  persons on Forms 8938  According to IRS, this comparison can be used to ensure taxpayers and FFIs are properly reporting foreign financial assets and income from international investments  This type of comparison is a common IRS enforcement technique  For example, IRS can directly compare information it receives from financial institutions’ IRS Form 1099-INT, Interest Income, against a tax return to determine if the taxpayer reported income generated from interest earned  To facilitate FATCA implementation for FFIs operating in jurisdictions with laws that would prohibit FFIs from complying with the terms of the FFI agreement, Treasury developed two alternative intergovernmental agreements (IGA)—Model 1 and Model 2—to facilitate the effective and efficient implementation of FATCA by removing partner jurisdictions’ legal impediments to comply with FATCA reporting requirements, and reducing burdens on FFIs located in partner jurisdictions  FFIs from countries with Model 1 IGAs report information on U S  persons’ accounts to their respective host country tax authorities (HCTAs)  The HCTAs, in turn, compile the information from FFIs and transmit it to IRS  In contrast, FFIs from countries with Model 2 IGAs, or countries treated as not having an IGA in effect, directly report information on U S  persons’ accounts to IRS  Separate from the FATCA requirements, regulations implementing the Bank Secrecy Act of 1970 (BSA) also impose a separate self-reporting requirement for foreign accounts  Specifically, certain taxpayers and residents are required to file an FBAR with FinCEN annually if they have financial interest or signature or other authority over one or more foreign financial accounts with a total of more than $10,000, regardless of whether they reside within or outside the United States  Federal, state, and local law enforcement agencies can use information from these reports to combat financial crimes, including terrorist financing and tax evasion  Appendix IV provides a comparison of Form 8938 and FBAR reporting requirements  Figure 1 depicts the flow of foreign financial account information from U S  persons and FFIs to IRS and FinCEN through the FATCA and FBAR reporting processes  As part of the FATCA reporting requirements, IRS collects information on financial accounts through forms and reports submitted by both taxpayers and FFIs  As part of this effort, IRS requires taxpayers to identify their TINs on Forms 8938 they submit  IRS also requires participating FFIs to report the TINs of each account holder who is a specified U S  person on Forms 8966  IRS intends to use reported TINs to link Form 8938 data filed by taxpayers to Form 8966 data filed by the FFIs to ensure that taxpayers and FFIs are properly reporting foreign financial assets  However, IRS often could not link account information collected from FFIs to the account’s owner because of incorrect or missing TINs  In July 2018, the Treasury Inspector General for Tax Administration (TIGTA) found that almost half of new Forms 8966 filed by FFIs did not include a TIN or included an invalid TIN  A consulting firm working with FFIs to implement FATCA reporting requirements told us that FFIs encountered significant challenges obtaining accurate TINs from U S  persons as part of the self-certification process  For instance, FFIs encountered situations where U S  persons provided incomplete or inaccurate TINs—such as Social Security Numbers (SSN) with less than nine digits—on forms used to self-certify their status as U S  persons  FFIs also encountered situations where U S  persons may not have obtained TINs or were unwilling to provide them to FFIs  Additionally, banking associations told us that it has taken time, effort, and expense for FFIs to report TINs, as they had to upgrade computer systems to collect and record TINs from U S  customers  Finally, Treasury told us that jurisdictions that have an IGA with the United States but no legal requirement to collect TINs are not in compliance with the requirements of the IGA  Treasury and IRS determined that some FFIs reporting from countries with Model 1 IGAs needed additional time to implement procedures to obtain and report required U S  TINs for preexisting accounts that are U S  reportable accounts  Consequently, IRS provided a transition period, through the end of 2019, for compliance with the TIN requirements for FFIs under Model 1 IGAs  Specifically, in September 2017, IRS issued a notice modifying procedures for FFIs reporting from countries with Model 1 IGAs to become compliant with TIN reporting requirements for preexisting accounts  For calendar years 2017-2019, IRS will not determine that certain FFIs in countries with Model 1 IGAs are significantly noncompliant with their obligations under the IGA solely as a result of a failure to report U S  TINs associated with the FFI’s U S  reportable accounts, providing they (1) obtain and report the date of birth of each account holder and controlling person whose TIN is not reported, (2) make annual requests for missing TINs from each account holder, and (3) search electronically searchable data maintained by such FFIs for missing required U S  TINs before reporting information that relates to calendar year 2017 to a partner jurisdiction  As a result, even without any further extensions, calendar year 2020 is the earliest IRS will be enforcing requirements for FFIs from countries with Model 1 IGAs to provide accurate and complete information on U S  account holders’ TINs to IRS  Without valid TINs on Forms 8966 submitted by FFIs, according to IRS officials, IRS faces significant hurdles in matching accounts reported by FFIs to those reported by individual tax filers on their Forms 8938  As a result, IRS must rely on information such as names, dates of birth, and addresses that the filers and/or FFIs may not consistently report  Without data that can be reliably matched between Forms 8938 and 8966, IRS’s ability to identify taxpayers not reporting accurate or complete information on specified foreign financial assets is hindered, interfering with its ability to enforce compliance with FATCA reporting requirements, and ensure taxpayers are paying taxes on income generated from such assets  In July 2018, TIGTA reported that IRS lacked success in matching FFI and individual taxpayer data because reports FFIs filed did not include or included invalid TINs  This, in turn, affected IRS’s ability to identify and enforce requirements for individual taxpayers  TIGTA recommended, among other things, that IRS initiate compliance efforts to address and correct missing or invalid TINs on Form 8966 filings from FFIs from countries with Model 2 IGAs or without any IGAs with the United States  IRS management said it disagreed with this recommendation because a system to ensure validation of every TIN upon submission of a Form 8966 would be cost prohibitive  However, IRS management said that IRS would address invalid TINs as they are uncovered on other compliance efforts, such as initiating development of a data product to automate risk assessments across the FATCA filing population  IRS also said it continues efforts to systematically match Form 8966 and Form 8938 data to identify nonfilers and underreporting related to U S  holders of foreign accounts  However, IRS management told us they are waiting until they have a full set of data, including TINs, before doing analysis to develop a compliance strategy  According to TIGTA, IRS management believed that having the FFI’s Global Intermediary Identification Number (GIIN) on Form 8938, which is filed by the taxpayer, would help with matching records  However, Form 8938 instructions identify that the field is optional for taxpayers to complete  TIGTA recommended that to reduce taxpayer burden in obtaining GIINs from FFIs, IRS add guidance to Form 8938 instructions to inform taxpayers on how to use the FFI List Search and Download Tool on the IRS’s website to obtain an FFI’s GIIN  IRS agreed with this recommendation  However, even if an individual taxpayer provided GIINs, IRS may continue to have difficulty matching accounts with U S  taxpayers if the TIN and name of the account holder reported on the Form 8966 do not match the TIN and name of the taxpayer on the Form 8938  IRS officials said they are aware of these difficulties and have attempted to match Forms 8938 and 8966 based on other criteria such as dates of birth  In its response to our draft report, IRS said that all financial institutions and foreign tax authorities that file required account information receive a notification listing administrative and other minor errors contained in their reporting  According to IRS, its Large Business and International division follows up with foreign tax authorities regarding these errors to ensure the tax authorities are working with financial institutions to correct these errors in compliance with the countries’ IGAs  IRS added it has initiated a campaign addressing FFIs that do not meet their compliance responsibilities with respect to account opening requirements  Additionally, IRS drafted a risk acceptance form and tool addressing risks in implementing FATCA compliance and business process capabilities  This risk assessment focused on the limitations IRS faces due to budget constraints, but did not address the specific risks it faces from not receiving complete and valid TINs on U S  account holders  We previously reported that risk management could help stakeholders make decisions about assessing risk, allocating resources, and taking actions under conditions of uncertainty  Key management practices for risk management we identified from our prior work include identifying, analyzing, and prioritizing risks; developing a mitigation plan to address identified risks; implementing the plan; and monitoring, reporting, and controlling risks  Without developing a risk mitigation plan to address risks IRS faces from not receiving complete and valid TINs moving forward, IRS may lose opportunities to adjust its compliance programs to better identify U S  persons who are not fully reporting specified foreign financial assets as required under FATCA  Several IRS databases store data collected from individuals’ electronic and paper filings of Form 8938 and/or elements of parent individual tax returns to which the Form 8938 is attached—the filer’s country of residence and filing status—used to determine specified reporting thresholds for Form 8938 filers  Additionally, data from these databases and other sources are transferred downstream to IRS’s Compliance Data Warehouse (CDW)—a database used for research and analytical purposes  We extracted data from copies of Individual Return Transaction File (IRTF) and Modernized Tax Return Database (MTRDB) data copied into CDW to obtain information reported on Forms 8938 and relevant information from parent tax returns, such as filing status and filers’ country of residence  We found that IRTF and MTRDB had inconsistent and incomplete data  For example, neither database had consistent and complete information on foreign financial account and other asset information submitted by Form 8938 filers  While IRS officials told us that IRTF is the authoritative source for filers of Form 8938, it does not store account and other asset information submitted on Forms 8938  Additionally, IRS officials said MTRDB is not designed to store information submitted on paper filings of Forms 8938 and parent tax returns  Officials from IRS’s Research, Applied Analytics and Statistics (RAAS) division also noted that CDW did not have reliable information from Form 8938 paper filings  Because of the lack of foreign financial asset information from such filings, we could not report complete information on assets reported by Form 8938 filers  Further, IRS does not provide instructions to CDW users on how to extract appropriate data from CDW—such as data copied from IRTF and MTRDB—leading to confusion on which databases to use for extracting Form 8938 and relevant parent tax return data  For example, five distinct tables within CDW are required to identify the TIN, parent form, filing status, country of residence, and amount of foreign assets accurately  Without clear explanations of how data in each of these tables relate to each other and to the underlying filings, errors could be introduced into CDW users’ analyses of foreign asset information  Standards for Internal Control in the Federal Government notes that management should use quality information to achieve the entity’s objectives  One attribute of this principle includes processing data into quality information that is appropriate, current, complete, accurate, accessible, and provided on a timely basis  Additionally, the Internal Revenue Manual states that IRS needs to measure taxpayer compliance so that customer-focused programs and services can be enhanced or developed so that compliance information and tools can be improved  According to IRS officials, IRS researchers have been taking additional steps to obtain and review Form 8938 and parent tax return data stored in the Integrated Production Model (IPM) database  They said IPM is the only database that contains complete data from individuals’ electronic and paper filings of Forms 8938 and relevant elements of parent tax returns  IRS officials said that RAAS has been working with IRS’s information technology (IT) division to obtain read-only access to IPM, and import Forms 8938 and 8966 data from IPM into CDW for analysis  However, as of February 2019, this effort has been delayed due to budget constraints  In its response to our draft report, IRS said that obtaining read-only access would require a new technical process and plans to continue working with IT on the feasibility and timeframe for enabling this access  Enabling access to consistent and complete Form 8938 and parent tax return data for compliance staff and researchers from RAAS and other IRS business units would help IRS strengthen its efforts to enforce compliance with FATCA reporting requirements and conduct research to bolster enforcement efforts  However, such efforts may be hampered until IRS can ensure readily available access to such data  We previously recommended that IRS develop a broad strategy, including a timeline and performance measures, for how IRS intends to use FATCA information to improve tax compliance  IRS agreed with this recommendation and developed a strategy for FATCA in July 2013  IRS updated the strategy in 2016 by creating the FATCA Compliance Roadmap as a comprehensive plan to articulate IRS’s priorities to facilitate compliance with FATCA reporting requirements  The roadmap also provided an overview of compliance activities used solely for enforcing FATCA reporting requirements or enhancing existing compliance efforts  However, in July 2018, TIGTA reported that IRS had not updated the FATCA Compliance Roadmap since 2016, and had taken limited or no action on a majority of the planned activities outlined in it  We also found that IRS had not yet evaluated the effects of FATCA, including the effects on voluntary tax compliance  IRS documentation states that only 7 of 31 capabilities outlined in the FATCA Compliance Roadmap were delivered due to funding constraints  As of October 2018, IRS has stopped using the FATCA Compliance Roadmap and has not developed a revised comprehensive plan to manage efforts to leverage FATCA data to improve taxpayer compliance  According to IRS officials, IRS moved away from updating broad strategy documents, such as the FATCA Compliance Roadmap, to focus on individual compliance campaigns  These include a campaign to match individual tax filers to the reports from FFIs, and another campaign to identify FFIs with FATCA reporting requirements who are not meeting all of their obligations  According to what IRS told us, with the passage of time and as FATCA is becoming more integrated into agency operations, it has moved from updating the broad strategy documents focused on FATCA to working on compliance campaigns that incorporate FATCA into overall tax administration  Additionally, IRS and outside researchers plan to study the role of enforcement in driving overall patterns in reporting offshore assets and income generated from such assets  Though IRS maintains that FATCA is more integrated into its operations, TIGTA’s 2018 report concluded that IRS was still unprepared to enforce compliance with FATCA in part because it took limited or no action on the majority of planned activities outlined in the FATCA Compliance Roadmap  Documenting a framework for using FATCA reporting requirements to improve taxpayer compliance and measure their effect is consistent with three steps we found leading public sector organizations take to increase the accountability of their initiatives: (1) define clear missions and desired outcomes; (2) measure performance to gauge progress; and (3) use performance information as a basis for decision-making  We also previously reported that it is important for IRS to use a documented framework that defines a clear strategy, timeline, and plans for assessment  Having such a framework in place can help IRS better allocate resources and avoid unnecessary costs resulting from not having the necessary or appropriate data available to execute its objectives  In light of the challenges IRS faces to collect, manage, and use FATCA data to improve compliance in a resource-constrained environment, employing a comprehensive plan would help IRS maximize the use of collected data and better leverage individual campaigns to increase taxpayer compliance  Without such a plan, IRS’s ability to collect and leverage data collected under FATCA for compliance enforcement and other purposes is constrained  We could not report on total values of foreign financial assets on Forms 8938 in tax years 2015 and 2016  However, we could provide a range of total maximum account values reported on FBARs during the same period  Specifically, we determined that more than 900,000 individuals filed FBARs in calendar years 2015 and 2016, and declared total maximum values of accounts ranging from about $1 5 trillion to more than $2 trillion each year  A little more than one in five—or about 21 7 percent—of the approximately 404,800 Forms 8938 filed with IRS in tax year 2016 were done so from U S  persons living abroad, with the other 78 3 percent living in the United States  Table 1 shows that a higher proportion of Form 8938 filings from U S  persons living abroad for tax year 2016 were filed on paper (43 3 percent) than Form 8938 filings from U S  persons living in the United States during the same period (14 7 percent)  We extracted these data from IRTF, which IRS officials said is the authoritative source for filers of Form 8938  However, we could not report complete information on foreign financial assets reported by Form 8938 filers because such data are incomplete; as noted above, IRS databases we used to extract Form 8938 data—IRTF and MTRDB—do not include asset information reported on paper filings of Forms 8938  Of the approximately 404,800 Forms 8938 filed by individuals for tax year 2016—the most recent data available—we could access information on residency of filers and reported foreign financial assets from about 277,600 Forms 8938 that did not indicate that foreign financial assets and values were declared on other forms besides the Form 8938  Of the subset of these Forms 8938, more than one quarter—or about 73,500— reported foreign financial assets in amounts that indicate the Form 8938 may have been filed unnecessarily, since they reported specified foreign financial assets with aggregate values at or below reporting thresholds as of the last day of the tax year  Based on available Form 8938 data from tax year 2016, table 2 shows that about 61,900 filings from U S  persons living in the United States and about 11,600 filings from U S  persons living abroad during the same tax year reported specified foreign financial assets with aggregate values at or below end of tax year thresholds  These totals likely understate the total number of Forms 8938 that U S  persons may have filed unnecessarily in tax year 2016; due to data limitations, these totals exclude Forms 8938 without asset information stored in IRS’s databases, including most Forms 8938 filed on paper and Forms 8938 where filers identified that they declared foreign financial assets on other forms besides the Form 8938  There is no clear explanation as to why some U S  persons may have filed Forms 8938 unnecessarily  However, we identified a number of potential reasons from focus groups and other interviews with stakeholder groups  In focus groups we conducted, participants expressed confusion about IRS’s instructions for completing the Form 8938 and information provided on IRS’s website  In the instructions for completing Form 8938, IRS described the specific types of foreign financial assets that are to be reported on Form 8938, and the asset value thresholds that must be met for required reporting, depending on the location of residence and filing status of the taxpayer  IRS also posted responses to frequently asked questions on meeting FATCA reporting requirements on its website, and established a separate page on its website comparing foreign financial assets that must be reported on Form 8938 and/or FBAR  Nonetheless, focus group participants reported confusion on whether and how to report investment and retirement accounts and compulsory savings plans managed by their country of residence  In a meeting we convened with an organization representing tax attorneys, they told us taxpayers are unsure about what account values to report on the Form 8938  Tax practitioners participating in another focus group added that they filed Forms 8938 regardless of the aggregate value of the assets because it was too cumbersome for them to identify whether the assets exceeded reporting thresholds as of the end of the year or at any time during the year  IRS officials also cited a number of possible reasons why U S  persons may be filing Forms 8938 unnecessarily  For example, it may be easier for U S  persons to report all specified foreign financial assets they hold on the Form 8938, rather than determine whether the value of such assets met applicable thresholds  IRS officials also said that U S  persons might complete a Form 8938 for reasons besides meeting tax-filing requirements, such as providing evidence of assets for a loan application  IRS’s Taxpayer Bill of Rights states that taxpayers are entitled to clear explanations of the laws and IRS procedures in all tax forms, instructions, publications, notices, and correspondence  Furthermore, one of IRS’s strategic goals is to empower taxpayers by making it easier for them to understand and meet their filing, reporting, and payment obligations  IRS officials said they hosted sessions for tax practitioners at IRS Nationwide Tax Forums to address FATCA reporting requirements  However, they said IRS has not taken direct steps to identify or implement actions to further clarify instructions and related guidance on IRS’s website for completing Form 8938, such as information on which foreign financial assets to report, how to calculate asset values, and determine whether such values exceed required reporting thresholds  Additionally, IRS officials said they have not conducted additional outreach to educate taxpayers on required reporting thresholds under FATCA, or notify Form 8938 filers of instances where aggregate values of specified foreign financial assets reported on Forms 8938 were below reporting thresholds  IRS officials said they have not made efforts to determine whether there is a pattern of unnecessary Form 8938 filings that they could address  Rather, they said they believed resources should be devoted to FATCA implementation in general  However, as shown above, we have identified many tens of thousands of instances where U S  persons may have filed Forms 8938 unnecessarily  Without assessing factors contributing to unnecessary Form 8938 reporting—and identifying or implementing actions to further clarify and educate taxpayers on FATCA reporting requirements—IRS is missing opportunities to help taxpayers understand their filing and reporting obligations and minimize their compliance burdens while properly meeting their tax obligations  Additionally, IRS may be missing opportunities to reduce costs in processing forms that taxpayers did not need to file  Because of overlapping statutory reporting requirements, IRS and FinCEN—both bureaus within Treasury—collect duplicative foreign financial asset data using two different forms (Form 8938 and FBAR)  Our evaluation and management guide for fragmentation, overlap, and duplication states that overlap occurs when multiple agencies or programs have similar goals, engage in similar activities or strategies to achieve them, or target similar beneficiaries  Table 3 shows that individuals required to report foreign financial assets on Form 8938, in many cases, also must meet FBAR reporting requirements  For example, specified individuals with foreign financial accounts exceeding $50,000 in aggregate value on the last day of the tax year must file both Form 8938 and FBAR if such values exceed the minimum Form 8938 thresholds; these thresholds depend on the filing status and address of specified individuals  Table 3 also shows that, in many cases, specified interests in foreign financial assets as defined in Form 8938 instructions are the same as the financial interest in such assets under FBAR  Further, as noted in table 3, the overlapping requirements lead to IRS and FinCEN collecting the same information on certain types of foreign financial assets  For example, both Form 8938 and FBAR collect information on foreign financial accounts for which a person has signature authority and a financial interest in the account  Form 8938 and FBAR also both collect duplicative information on several other types of foreign financial assets, such as foreign mutual funds and accounts at a foreign financial institution that include foreign stock or securities  Overlapping reporting requirements result in most Form 8938 filers also filing an FBAR during the same reporting year  Table 4 shows that close to 75 percent of Form 8938 filers in tax years 2015 and 2016 percent also filed an FBAR for the same year using the same TIN  Overlapping requirements to file both Form 8938 and FBAR increases the compliance burden on U S  persons and adds complexity that can create confusion, potentially resulting in inaccurate or unnecessary reporting  Focus group participants in all five countries included in our study affirmed that U S  persons experienced confusion and frustration with having to report duplicative foreign financial asset information on both forms  Focus group participants and others we interviewed also noted that U S  persons incurred additional financial costs to complete and file both Form 8938 and FBAR  For instance, one tax practitioner in Canada said the charge was about $190 to report four-to-five accounts on an FBAR in addition to charging about $540 for basic tax return packages  An accounting firm based in Japan typically charged between $300 and $800 to complete a Form 8938 and between $150 and $500 to complete an FBAR, depending on the number of accounts reported on the forms  Proposed revisions to regulations implementing BSA proposed by FinCEN may also increase the number of duplicative foreign financial accounts reported on Form 8938 and FBAR  Currently, U S  persons must report detailed information on all foreign financial accounts on Form 8938 if the value of such accounts and other specified foreign financial assets reaches applicable reporting thresholds  In contrast, U S  persons are generally exempted from reporting detailed account information on FBARs if they report having signature or other authority over 25 or more foreign financial accounts  FinCEN’s proposed revisions to BSA regulations would eliminate the exemption, requiring U S  persons to report detailed information on all foreign financial accounts in which he or she has a financial interest if the value of such accounts exceed FBAR’s $10,000 reporting threshold  FinCEN estimated that it will receive account information for the first time on about 5 4 million foreign financial accounts if it finalizes the proposed revisions  In turn, these revisions may lead to increased filings of duplicative asset data on both Form 8938 and FBAR, as U S  persons may have to report detailed information on all foreign financial accounts using both forms  U S  persons also face exposure to two different penalty regimes for any failures in accurately and completely reporting foreign financial asset information to two bureaus within Treasury—IRS and FinCEN  Officials from one organization representing U S  persons living abroad said penalties due to failure to report certain accounts on one or both forms can be significant, even if little or no taxes are owed on those accounts  The duplicative reporting of foreign financial asset data on two different forms also creates additional costs to the government to process and store the same or similar information twice, and enforce reporting compliance with both requirements  In 2012, we recommended that Treasury direct the Office of Tax Policy, IRS, and FinCEN to determine whether the benefits of implementing a less duplicative reporting process exceed the costs and, if so, implement that process  Treasury did not implement our recommendation  While we continue to believe that the agencies should have considered whether less duplicative reporting could have been implemented, we do recognize that FATCA and FBAR were enacted under two different statutes to serve different purposes  As mentioned above, according to IRS, FATCA improves visibility into taxable income from foreign sources and enhances the agency’s ability to identify and pursue taxpayer noncompliance  In contrast, the information reported on the FBAR is collected to identify money laundering and other financial crimes; law enforcement agencies can use BSA information—including information collected from FBARs— to aid regulatory and criminal investigations  Additionally, data collected from Form 8938 and FBAR are used in different systems for use by different bureaus within Treasury  Fully addressing issues stemming from overlapping reporting requirements and the resulting collection of duplicative information—while at the same time ensuring that such information can be used for tax compliance and law enforcement purposes—can only be done by modifying the statutes governing the requirements  Further, IRS and FinCEN have varying degrees of access to foreign financial asset information collected from Form 8938 and FBAR to enforce tax compliance and financial crime laws  FATCA was enacted, in part, to improve visibility into taxable income from foreign sources  However, information provided on Forms 8938 is taxpayer return information protected by section 6103 of the Internal Revenue Code (IRC), which generally prohibits IRS from disclosing information provided on Forms 8938  IRS can share return information with other government agencies and others when it is allowed by statute  For example, under section 6103, IRS may disclose return information related to taxes imposed under the IRC—such as self-employment income tax, Social Security and Medicare tax and income tax withholding—to the Social Security Administration (SSA) as needed to carry out its responsibilities under the Social Security Act  However, according to FinCEN officials, FinCEN, law enforcement, and regulators often cannot access information submitted on Forms 8938  While section 6103 provides other exceptions to disclosure prohibitions—such as allowing IRS to share return information with law enforcement agencies for investigation and prosecution of nontax criminal laws—such information is generally only accessible pursuant to a court order  As noted above, information reported on the FBAR can be used by law enforcement agencies to aid regulatory and criminal investigations  This includes IRS, which has been delegated responsibility from FinCEN to enforce compliance with FBAR reporting requirements  IRS has used FBAR information in addressing taxpayer noncompliance with reporting and paying taxes on foreign assets and income  For example, taxpayers accepted into one of IRS’s offshore voluntary disclosure programs must have filed amended or late FBARs as part of their program applications  Investigators from IRS’s Criminal Investigation division generally reviewed applications to determine if the taxpayer has made a complete and truthful disclosure  IRS examiners can also use information from case files of program participants—such as information disclosed on FBARs— to identify new groups of taxpayers suspected of hiding income offshore  IRS can then choose to continue offering offshore programs and encourage these newly identified groups of taxpayers, as well as all taxpayers with unreported offshore accounts, to disclose their accounts voluntarily  In addition to eliminating overlapping reporting requirements, harmonizing statutes governing foreign financial asset reporting and use of information collected on such assets to make such statutes fully consistent could yield additional benefits to both IRS and the law enforcement community  Specifically, and as shown in appendix IV, there are specified foreign financial assets reported on Form 8938—such as foreign hedge funds and foreign private equity funds—that are not required to be reported on an FBAR  In contrast, there are other specified foreign financial assets reported on an FBAR—such as indirect interests in foreign financial assets through an entity—that are not required to be reported on Form 8938  Without congressional action to address overlap in foreign financial asset reporting requirements, IRS and FinCEN will neither be able to coordinate efforts to collect and use foreign financial asset information, nor reduce unnecessary burdens faced by U S  persons in reporting duplicative foreign financial asset information  Two reporting systems for sharing foreign account information from foreign financial institutions are in operation globally—FATCA and the Common Reporting Standard (CRS)  According to officials from banking associations and a consulting firm, FFIs in the countries where we examined FATCA implementation encountered challenges implementing and now maintaining two overlapping reporting systems for collecting and transmitting account information to other countries for a seemingly similar purpose, and collecting sufficient information from customers to ensure they meet the requirements of both systems  As noted above, we previously identified overlap as occurring when multiple agencies or programs have similar goals, engage in similar activities or strategies to achieve them, or target similar beneficiaries  According to an IRS official, collecting account information under FATCA ushered in an era of greater transparency; as noted above, FATCA’s passage sought to reduce tax evasion by creating greater transparency and accountability with respect to offshore accounts and other assets held by U S  taxpayers  When FATCA was first introduced, there was no international platform to share account information between countries  The United States and other countries worked together to reach an agreement on the electronic formatting that would be used to share the information  Other countries tax authorities’ became more interested in understanding the financial assets held abroad by their residents through an exchange of account information among themselves  In response, the Organisation for Economic Co-operation and Development (OECD) established the CRS reporting system for automatic exchange of information among member countries  According to the OECD, CRS was developed with a view to maximize efficiency and reduce cost for financial institutions  Thus, CRS drew extensively on the intergovernmental approach used to implement FATCA reporting requirements for FFIs  Countries participating in CRS exchange account information with each other using OECD’s Common Transmission System, which was modeled on FATCA’s International Data Exchange System  Figure 2 depicts the flow of account information between countries under FATCA and CRS  CRS reporting requirements are in many ways similar to FATCA, including required reporting of the account holders’ name and address, taxpayer identification number, account number, account balance, and income and sales proceeds  However, the requirements differ in significant ways  The biggest differences in requirements are driven by the nature of the U S  tax system  The United States, like many countries, generally taxes citizens and resident aliens on their worldwide income regardless of where that income is earned  However, the United States differs from other countries because it generally subjects U S  citizens who reside abroad to U S  taxation in the same manner as U S  residents  In contrast to U S  policy, most other countries do not tax their citizens if they reside in a country other than their country of citizenship  Further, IGAs implementing FATCA require FFIs to report the foreign-held accounts of U S  citizens and residents—including resident aliens—while CRS requires financial institutions in jurisdictions participating in CRS to report on almost all accounts held by nonresidents of the reporting country  Appendix V provides more detailed information on differences in reporting requirements, due diligence requirements, and definitions under FATCA and CRS  These differences in tax systems drive variations in due diligence procedures between FATCA and CRS  For example, FATCA aims to identify whether an account holder at a foreign institution is a U S  person based on citizenship and tax residency information  In contrast, CRS aims to identify the tax residency of all account holders of a financial institution, and does not consider citizenship  Due to the multilateral nature of CRS, if an account holder is determined on the basis of the due diligence procedures to have residency in two or more countries, information would be exchanged with all jurisdictions in which the account holder is determined a resident for tax purposes  Under CRS rules, information about foreign accounts held by a U S  citizen with a tax residence abroad would not be reported to IRS, but rather to the jurisdiction in which they were a resident for tax purposes  Because the United States taxes the worldwide income of U S  citizens, CRS rules would need to require identification of account holders’ citizenship in member countries where they are residents if FATCA were to be aligned with CRS  Table 5 shows a comparison of individuals reported to IRS under FATCA and hypothetically under CRS  Treasury and IRS, as part of its 2017-2018 Priority Guidance Plan, are considering modifying certain elements of the existing FATCA regulations  For instance, Treasury and IRS are considering coordinating certain documentation requirements for participating FFIs with the requirements under IGAs  In December 2018, Treasury and IRS also proposed regulations intended, in part, to reduce the burdens of FATCA  The proposed regulations included a clarification of the definition of an investment entity that is similar to the guidance published by OECD interpreting the definition of a “managed by” investment entity under CRS  If the United States wanted to adopt CRS, some of the key differences between FATCA and CRS—as outlined above and in appendix V—could be aligned through regulation while others would require legislation  According to Treasury officials, to align FATCA and CRS, Congress would need to revise statutes to: provide for the collection of information for accounts that residents of partner jurisdictions maintain at U S  financial institutions; require certain U S  financial institutions to report the account balance (including, in the case of a cash value insurance contract or annuity contract, the cash value or surrender value) for all financial accounts maintained at a U S  office and held by foreign residents; expand the current reporting required with respect to U S  source income paid to accounts held by foreign residents to include similar non-U S  source payments; require financial institutions to report the gross proceeds from the sale or redemption of property held in, or with respect to, a financial account; and require financial institutions to report information with respect to financial accounts held by certain passive entities with substantial foreign owners  While better aligning FATCA and CRS to some extent is possible, anything short of the United States fully adopting CRS would not fully eliminate the burdens of overlapping requirements that FFIs must currently meet under the two different systems  While having the United States adopt the CRS reporting system in lieu of FATCA could benefit FFIs that may otherwise have to operate two overlapping reporting systems, it would result in no additional benefit to IRS in terms of obtaining information on U S  accounts  Additionally, it could generate additional costs and reporting burdens to U S  financial institutions that would need to implement systems to meet CRS requirements  The extent of these costs is unknown  Further, adoption of CRS would create the circumstance where foreign accounts held by U S  citizens with a tax residence in partner jurisdiction—including U S  citizens who have a U S  tax obligation—would not be reported to IRS  Tax practitioners and others we interviewed said that U S  persons living abroad—whether or not they are required to complete a Form 8938—risk being denied access to foreign financial services  U S  persons and tax practitioners located in four of the five countries where we conducted focus groups and interviews reported that some U S  persons and U S - owned businesses encountered difficulties opening bank accounts with FFIs after FATCA was enacted, with some FFIs closing U S  persons’ existing accounts or denying them opportunities to open new accounts  One focus group participant, for example, said that the financial institution closed down all accounts including business checking, savings, and money market accounts after FATCA was implemented, requiring this individual to find a local resident who could co-sign on a new account  Costs FFIs would incur from implementing FATCA were cited as a significant factor in increasing barriers faced by U S  persons in accessing foreign financial services  Officials from one organization representing tax attorneys said that as a result of costs associated with FATCA implementation, FFIs have found it less burdensome to close accounts of U S  persons or require the accounts to be moved to a Securities and Exchange Commission registered affiliate than comply with FATCA  Tax practitioners and an official from a bankers association added that because FFIs may gain only small margins of profit from U S  persons, FFIs may believe it is too troublesome to do business with them  Additionally, officials from a foreign government agency told us that because FATCA is expensive for FFIs to continue implementing, banks in their country might charge U S  persons seeking access to financial services additional fees to account for FATCA implementation costs  Tax practitioners, consultants working with FFIs to implement FATCA reporting requirements, and the National Taxpayer Advocate told us that FFIs with smaller asset sizes such as smaller trust companies were more prone to decline business with U S persons  Officials from an advocacy group representing U S  persons living abroad told the National Taxpayer Advocate that some smaller banks declined U S  persons as customers as a business decision, believing it would cost more for them to comply with FATCA reporting requirements than maintain U S  expatriates’ accounts  Banking associations we interviewed said that decisions made by FFIs on whether to accept U S  persons as customers also depends on the overall risks and benefits of taking on individual U S  persons, shaped in part from risks in not meeting FATCA reporting requirements  Representatives of a banking association and an advocacy group told us that some FFIs decided to avoid doing business with U S  persons after they became concerned about potential penalties for failure to comply—either willfully or in error—with FATCA reporting requirements  One banking association added that such errors could affect other aspects of FFIs’ relationships with the U S  government, such as nonprosecution agreements made with the U S  Department of Justice  Officials from one consulting firm that helped FFIs meet FATCA reporting requirements added that FFIs’ determination of risk depends on many layers, such as the value of clients’ assets or the country in which clients reside or possess citizenship  After FATCA’s implementation, according to officials from the consulting firm, FFIs decided to turn away U S  persons in some cases because the benefits of doing business with U S  persons were less than the potential risks  For example, if a U S  person only maintained a payroll account, the FFI may determine it would not make enough money to account for risks in incorrectly identifying the status of the customer as a U S  or non-U S  person  However, focus group participants from two countries said that FFIs may agree to accept U S persons as customers if they have higher account balances that offset risks from FATCA reporting requirements  One focus group participant, for instance, said banks in his country will do business with a U S  person if he or she has more than $500,000 in assets  Additionally, U S  persons and tax practitioners we interviewed said that other factors such as language barriers and U S  regulations designed to prevent money laundering may also inhibit U S  persons’ access to brokerage accounts while overseas  Focus group participants and others we interviewed said that Form 8938 reporting requirements contributed to denials of employment and promotion opportunities for U S  persons living abroad  Treasury officials noted that requirements imposed by FATCA do not directly hinder U S  persons from gaining employment or promotion opportunities overseas  However, focus group participants, a consulting firm, and a foreign government agency noted that foreign-owned companies and nonprofit organizations such as churches did not want to hire or promote U S  persons because they wanted to avoid exposing information to the U S  government on their organizations’ accounts and client trust accounts where the U S  person would have signature authority  As noted above, a U S  person is generally required to report on the Form 8938 foreign financial accounts for which the person has signature authority if he or she has a financial interest in the account  Focus group participants and others noted that such requirements have adversely affected the ability of U S  persons to serve on a corporate board or in a nonprofit organization, or maintain business relationships  Treasury and Department of Commerce officials stationed in one country included in our review added that FATCA implementation has played a role in dissuading foreign-owned corporations in some Asian countries from considering U S  persons for corporate leadership positions such as directorships  This is in part because FATCA has triggered additional paperwork burden and operating costs for onboarding U S  employees since they have had to help them meet Form 8938 reporting requirements  Two advocacy groups representing U S  persons living abroad added that it is also harder for U S -based companies to justify relocating U S  persons overseas and paying for such relocations since they also have had to help their U S  employees meet Form 8938 reporting requirements in addition to meeting other tax filing requirements  U S  embassy documents indicate there was increased demand for Social Security Numbers (SSN) since FATCA’s passage in 2010, driven in part by U S  citizens applying for an SSN to gain access to foreign financial services or resolve outstanding U S  tax obligations before completing renunciation  However, officials from two organizations representing Americans living abroad cited significant challenges faced by some U S  persons living abroad in obtaining SSNs required to meet their U S  tax obligations or obtain financial services  U S  persons living abroad might not possess an SSN because their parents did not obtain one for them as a minor  Often, this may have been due to the parents leaving the United States when the child was young  State officials also said that U S  citizens applying for U S  passports while overseas frequently forget their SSNs or do not know if their parents ever applied for an SSN on their behalf  Officials from organizations representing U S  persons living abroad added that without an SSN, these persons are unable to claim refunds or other tax benefits when filing their tax returns, or participate in IRS programs to voluntarily disclose previously unreported tax liabilities and assets  Additionally, some might be unable to gain or maintain access to financial accounts or other assets in their countries of residence without an SSN  According to these officials and tax practitioners we interviewed, U S  persons living abroad face greater challenges in obtaining SSNs than those living in the United States  For instance, they faced difficulties obtaining documentation from the United States that the Social Security Administration (SSA) requires with SSN applications; traveling to Social Security offices and U S  embassies or consulates to certify documents or submit applications in person; and receiving valid SSNs from SSA in a timely manner to file tax returns or participate in offshore disclosure programs  SSA officials also identified several challenges U S  persons experience when applying for an SSN from abroad  For instance, SSA officials said that efforts to authenticate documents submitted with SSN applications can cause delays for U S  persons living abroad in obtaining an SSN  Additionally, SSN applicants living abroad face significantly longer wait times than applicants living in the United States once their applications are processed  According to SSA officials, after an application is processed, it can take 3 to 6 months–-depending on the country’s mail service–-for an individual to receive a Social Security Card  This is significantly longer than the 2-week period it takes SSN applicants to receive a card after mailing in their applications from within the United States  According to Department of State (State) data, the annual number of approvals of requests for renunciations of U S  citizenships increased nearly 178 percent during a 6-year period, from 1,601 in 2011—the year after FATCA was enacted—to 4,449 in 2016, the most recent year to which full data on renunciations were available  According to U S  embassy documents and information provided by focus group participants and interviewees across all the countries we examined, FATCA was the reason or a contributing factor in some of these decisions and the resulting increase in total renunciations  Specific effects of FATCA implementation contributing to decisions to renounce U S  citizenship included reduced access to foreign financial services and employment or promotion opportunities in a foreign-owned company—as identified above from our document reviews, focus groups, and interviews—and burdens in meeting FATCA reporting requirements  However, the extent to which FATCA implementation contributed to increased renunciations is unclear  State officials said that data are unavailable to determine the extent to which these renunciation decisions were the direct result of FATCA because State has no legal obligation to collect information on the motivation behind renunciation of citizenship  In response to concerns about the availability of foreign financial services, Treasury implemented regulations that allow certain low-risk local FFIs to be deemed compliant with FATCA, but only if the FFIs do not implement policies or practices that discriminate against opening or maintaining accounts for specified U S  persons  Treasury and State also previously established joint strategies to address these challenges  For instance, Treasury and State developed guidance on FATCA that was posted on embassy websites to educate U S  persons and others  Additionally, Treasury and State officials conducted outreach events and workshops through U S  embassies and American chambers of commerce worldwide to provide information on FATCA and other tax filing requirements, According to State officials, the U S  embassies in at least two countries—Switzerland and France—also worked with foreign officials and/or FFIs to increase access to financial services for U S  citizens residing in those countries  For instance, Treasury and State officials reached agreements with FFIs in Switzerland to provide a wider range of financial services to U S  persons  Similarly, in 2017, SSA and State implemented an interagency agreement to streamline processes for providing SSNs to U S  persons living abroad after FATCA’s implementation in 2010  SSA officials said they are also in discussions with State on improving SSA’s website to include more transparent, specific information for SSN overseas applicants about SSA documentation requirements  Tax practitioners, advocacy groups, and Treasury officials we interviewed said FFIs have become more willing to accept U S  persons as customers compared to when FATCA was enacted in 2010  However, U S  persons living abroad continue to face issues gaining access to foreign financial services  For example, in a September 2018 letter sent by the Chair of the Finance Committee of the Netherlands House of Representatives to a member of Congress, U S  citizens born outside the United States and who have never lived, studied, or worked in the United States are effectively being denied access to financial services in the Netherlands  Focus group participants added that some banks will reject U S  clients or charge heavy fees for them to open an account  Agencies have ongoing efforts to address FATCA-related issues, as listed below, but some are ad hoc, fragmented, or otherwise not part of a broader effort between Treasury and other agencies such as State or SSA to use ongoing collaborative mechanisms to monitor and share information on such issues, and jointly develop and implement steps to address them: Treasury officials said they are participating in discussions with FFIs to address residual issues with access to foreign financial services  However, they said they have not involved other agencies in these discussions  IRS officials, in response to concerns from the French government, said they are developing a program to help streamline foreign asset- related tax compliance requirements for a small group of U S  born citizens that have been French residents most of their lives without an SSN, and—according to State officials—did not wish to take the necessary steps to renounce their citizenship  However, no effort has been made to address these issues more broadly  State encouraged U S  citizens to alert the nearest U S  embassy of any practices they encounter with regard to the provision of financial services  State documents noted that some Americans have been turned away by banks or required to meet a higher deposit threshold in part because of FATCA reporting requirements  State documentation also noted that there have been cases of U S  citizens with existing bank accounts who have been asked to close them  However, State documentation we reviewed does not highlight collaborative efforts currently underway with Treasury or other agencies to address banking access issues U S  persons living abroad are presently encountering worldwide  As described above, SSA and State streamlined processes and policies for U S  persons abroad seeking to obtain SSNs  However, SSA officials said they have not been involved in any ongoing efforts involving Treasury to identify systemic issues and related solutions involving SSNs for the purposes of tax compliance and citizenship renunciations  Treasury officials said they spoke with SSA officials about problems U S  persons living abroad face in obtaining SSNs, but SSA believed that cycle times for processing SSN applications submitted by U S  persons living abroad were not significantly greater than for applications submitted by U S  persons living in the United States, although mailing times could vary significantly and take up to 3 to 6 months  We have previously identified key practices to enhance and sustain interagency collaboration, including defining and articulating a common outcome, establishing mutually reinforcing or joint strategies, and developing mechanisms to monitor, evaluate, and report on results  One goal in IRS’s strategic plan is to collaborate with external partners proactively to improve tax administration, while objectives in SSA’s strategic plan include improving service delivery and expanding service delivery options  Additionally, according to State’s Bureau of Consular Affairs website, one of State’s key priorities is to protect the interests of U S  citizens overseas, such as through ensuring responsive and efficient provision of consular services overseas  As noted above, there are a host of ongoing issues and challenges for U S  persons living abroad from implementation of FATCA, such as loss of access to foreign financial services, denial of employment and promotion opportunities overseas, and difficulty obtaining SSNs from abroad  However, Treasury currently lacks a collaborative mechanism to coordinate efforts with other agencies to address these issues, and Treasury officials said they do not plan to establish them  Without effective collaborative mechanisms to monitor and share information and implement cross-agency solutions, future efforts to address such issues will continue to be fragmented and less effective than they otherwise could be  In enacting FATCA, Congress sought to reduce tax evasion by creating greater transparency and accountability over offshore assets held by U S  taxpayers  Because of FATCA, IRS receives information on foreign financial assets from hundreds of thousands of filers annually  IRS could use this information to help ensure taxpayers holding offshore assets report and pay taxes owed on income generated from such assets  However, to take full advantage of the information, IRS must address key challenges  Specifically, Taxpayer Identification Numbers (TIN) reported by FFIs are often inaccurate or incomplete, which makes it difficult for IRS to match information reported by FFIs to individual taxpayers  As such, IRS must develop a plan to mitigate the risks that these data issues pose to agency efforts to identify and combat taxpayer noncompliance  Lack of consistent, complete, and readily available Form 8938 and related parent individual tax return data also affects IRS’s compliance activities, making it more difficult for IRS business units to extract and analyze FATCA data to improve tax compliance efforts and reduce tax revenue loss from income generated from offshore assets  At the same time, IRS has stopped following its FATCA Compliance Roadmap it developed in 2016 because, according to IRS officials, IRS moved away from updating broad strategy documents to focus on individual compliance campaigns  However, in light of the challenges IRS continues to face in fully integrating FATCA information into its compliance programs, it will not maximize use of such information and effectively leverage individual compliance campaigns unless it employs a comprehensive plan that enables IRS to better leverage such campaigns to improve taxpayer compliance  Our analysis of available data indicates that many of the Forms 8938 filed in tax year 2016 may have been filed unnecessarily  Factors that are contributing to this unnecessary reporting are unclear  While IRS has provided instructions and guidance on its website for completing Form 8938, focus group participants and tax practitioners reported confusion on whether and how to report investments in foreign accounts  Taking steps to identify and address factors contributing to unnecessary Form 8938 reporting would help reduce taxpayer burden and reduce processing costs for IRS  Reporting requirements for foreign financial assets under FATCA overlap with reporting requirements under FBAR  These overlapping requirements—implemented under two different statutes—have resulted in most taxpayers filing Forms 8938 also filing FBARs with FinCEN  Duplicative filings on foreign financial assets cause confusion, frustration, and compliance burdens for taxpayers  Duplicative filings also increased costs to the government to process and store the same or similar information  Modifying the statutes governing the requirements can fully address the issues outlined above, and can allow for the use of FATCA information for prevention and detection of financial crimes  This is similar to other statutory allowances for IRS to disclose return information for other purposes, such as for determining Social Security income tax withholding  Lastly, FATCA has created challenges for some U S  persons living abroad that go beyond increasing their tax compliance burdens  Some U S  persons living abroad are still facing issues accessing financial services and employment and obtaining SSNs  Treasury, State, and SSA have taken some steps to address these issues both separately and in coordination with each other  However, Treasury, as the agency ultimately responsible for effective administration of FATCA, currently lacks a collaborative mechanism with State and SSA to address ongoing issues  Establishing a formal means to collaboratively address burdens faced by Americans abroad from FATCA can help agencies develop effective solutions to mitigate such burdens  We are making the following matter for congressional consideration: Congress should consider amending the Internal Revenue Code, Bank Secrecy Act of 1970, and other statutes, as needed, to address overlap in foreign financial asset reporting requirements for the purposes of tax compliance and detection, and prevention of financial crimes, such as by aligning the types of assets to be reported and asset reporting thresholds, and ensuring appropriate access to the reported information  We are making the following four recommendations to IRS: The Commissioner of Internal Revenue should develop a plan to mitigate risks with compliance activities due to the lack of accurate and complete TINs of U S  account holders collected from FFIs  (Recommendation 1) The Commissioner of Internal Revenue should ensure that appropriate business units conducting compliance enforcement and research have access to consistent and complete data collected from individuals’ electronic and paper filings of Form 8938 and elements of parent individual tax returns  As part of this effort, the Commissioner should ensure that IRS provides clear guidance to the business units for accessing such data in IRS’s Compliance Data Warehouse  (Recommendation 2) The Commissioner of Internal Revenue should employ a comprehensive plan for managing efforts to leverage FATCA data in agency compliance efforts  The plan should document and track activities over time to ensure individuals and FFIs comply with FATCA reporting assess and mitigate data quality risks from FFIs; improve the quality, management, and accessibility of FATCA data for compliance, research, and other purposes; and establish, monitor, and evaluate compliance efforts involving FATCA data intended to improve voluntary compliance and address noncompliance with FATCA reporting requirements  (Recommendation 3) The Commissioner of Internal Revenue should assess factors contributing to unnecessary Form 8938 reporting and take steps, as appropriate, to address the issue  Depending on the results of the assessment, potential options may include: identifying and implementing steps to further clarify IRS Form 8938 instructions and related guidance on IRS’s website on determining what foreign financial assets to report, and how to calculate and report asset values subject to reporting thresholds; and conducting additional outreach to educate taxpayers on required reporting thresholds, including notifying taxpayers that may have unnecessarily filed an IRS Form 8938 to reduce such filings  (Recommendation 4) We are also making the following recommendation to Treasury: The Secretary of the Treasury should lead efforts, in coordination with the Secretary of State and Commissioner of Social Security, to establish a formal means to collaboratively address ongoing issues— including issues accessing financial services and employment and obtaining SSNs—that U S  persons living abroad encounter from implementation of FATCA reporting requirements  (Recommendation 5) We are also making the following recommendation to State: The Secretary of State, in coordination with the Secretary of the Treasury and Commissioner of Social Security, should establish a formal means to collaboratively address ongoing issues—including issues accessing financial services and employment and obtaining SSNs—that U S  persons living abroad encounter from implementation of FATCA reporting requirements  (Recommendation 6) We are also making the following recommendation to SSA: The Commissioner of Social Security, in coordination with the Secretaries of State and Treasury, should establish a formal means to collaboratively address ongoing issues—including issues accessing financial services and employment and obtaining SSNs—that U S  persons living abroad encounter from implementation of FATCA reporting requirements  (Recommendation 7) We provided a draft of this report to the Secretaries of State and the Treasury, Commissioner of Internal Revenue, and Acting Commissioner of Social Security  IRS provided written comments that are summarized below and reprinted in appendix VI  IRS did not state whether it agreed or disagreed with our four recommendations but otherwise provided responses  Regarding our recommendation to develop a plan to mitigate risks with compliance activities due to the lack of accurate and complete TINs of U S  account holders collected from FFIs (recommendation 1), IRS reiterated that it provided a transition period, through the end of 2019, for compliance with the TIN requirements for FFIs in countries with Model 1 IGAs with the United States  IRS also said that it continued to make progress on improving FATCA filing compliance, citing efforts such as initiating a campaign addressing FFIs that do not meet their compliance responsibilities  While these efforts may help IRS obtain more accurate and complete information from financial accounts, IRS did not specify how it will mitigate the ongoing hurdles it faces in matching accounts reported by FFIs without valid TINs to accounts reported by individual tax filers and ensure compliance  Regarding our recommendation that appropriate business units have access to consistent and complete data collected from Forms 8938 and tax returns filed by individuals (recommendation 2), IRS reiterated that RAAS has been working to obtain read-only access to the IPM database but that limited budgetary resources are delaying implementation  Enabling access to consistent and complete Form 8938 and tax return data would help IRS better target compliance initiatives and leverage limited available enforcement resources  While IRS continues to work on enabling access to IPM, it could still provide clear guidance to its business units for accessing Form 8938 and tax return data in IRS’s Compliance Data Warehouse, as we recommended  Regarding our recommendation to employ a comprehensive plan for managing efforts to leverage FATCA data in agency compliance efforts (recommendation 3), IRS said the resources that would be required to develop a comprehensive plan would be better spent on enforcement activities  While implementing enforcement activities could increase compliance with FATCA reporting requirements, it risks not maximizing the value of such efforts without a comprehensive plan to manage and address the myriad of challenges discussed in this report  Further, it is our belief that IRS’s failure to execute the FATCA roadmap is not justification for abandoning a strategic approach going forward  Regarding our recommendation to assess factors contributing to unnecessary Form 8938 reporting and take appropriate steps to address the issue (recommendation 4), IRS said it will continue to observe filings of Form 8938 and, to the extent that there are unnecessary filings, assess options to inform account holders to reduce reporting and filing burdens followed by appropriate steps to implement any selected options  Our analysis of available data indicates that many Forms 8938 may have been filed unnecessarily  Implementing our recommendation reduces the risk that taxpayers file—and IRS processes—forms unnecessarily  Treasury provided written comments but did not state whether it agreed or disagreed with our recommendation that it lead efforts, in coordination with State and SSA, to establish a formal means to collaboratively address ongoing issues that U S  persons living abroad encounter from implementation of FATCA reporting requirements (recommendation 5)  Treasury said it will work collaboratively with State and SSA to answer questions that Americans abroad have regarding their tax obligations and, where appropriate, to direct U S  citizens to resources that will help them understand the procedures applied by SSA to apply for an SSN  However, Treasury said it is not the appropriate agency to lead coordination efforts involving foreign employment issues and issues regarding access to foreign financial services and obtaining SSNs  As we noted above, Treasury is ultimately responsible for effective administration of FATCA  As such, it is in a better position than State or SSA to adjust regulations and guidance implementing FATCA to address burdens FFIs and foreign employers face from FATCA implementation while ensuring tax compliance  Additionally, Treasury has an interest in helping U S  persons receive valid SSNs from SSA in a timely manner to meet their tax obligations  Treasury’s written response is reprinted in appendix VII  State and SSA also provided written comments in which they concurred with our recommendations to establish a formal means to address collaboratively together with Treasury ongoing issues that U S  persons living abroad encounter with FATCA (recommendations 6 and 7)  State and SSA’s written comments are reprinted in appendices VIII and IX, respectively  Treasury, State, and SSA provided technical comments, which we incorporated as appropriate  We are sending copies of this report to the appropriate congressional committees, the Secretaries of State and the Treasury, Commissioner of Internal Revenue, Acting Commissioner of Social Security, and other interested parties  In addition, the report will be available at no charge on the GAO website at http://www gao gov  If you or your staff have any questions about this report, please contact me at (202) 512-9110 or mctiguej@gao gov  Contact points for our offices of Congressional Relations and Public Affairs are on the last page of this report  GAO staff who contributed to this report are listed in appendix X  The objectives of this report are to (1) assess the Internal Revenue Service’s (IRS) efforts to use information collected under the Foreign Account Tax Compliance Act (FATCA) to improve taxpayer compliance; (2) examine available foreign financial asset reports submitted by U S  persons, including submissions that were below required filing thresholds; (3) examine the extent to which the Department of the Treasury (Treasury) administers overlapping reporting requirements on foreign financial assets; (4) describe similarities and differences between FATCA and Common Reporting Standard (CRS) reporting requirements; and (5) examine the effects of FATCA implementation that are unique to U S  persons living abroad  For our first objective, we reviewed Treasury Inspector General for Tax Administration reports and collected information from Treasury and IRS to summarize efforts to collect complete and valid Taxpayer Identification Numbers (TIN) from foreign financial institutions (FFI)  We identified criteria from our prior work identifying key practices for risk management  The key practices are derived from the Software Engineering Institute’s Capability Maturity Model® Integration for Development and Office of Management and Budget guidance  We applied these criteria to assess steps IRS has taken to manage risks in not receiving complete and valid TIN information from FFIs  We also applied criteria from our prior work on use of documented frameworks to IRS documentation on FATCA compliance activities to determine the extent to which IRS implemented a comprehensive plan to maximize use of collected data to enforce compliance with FATCA  For our second objective, we identified total maximum account values reported by individual filers of Financial Crimes Enforcement Network (FinCEN) Form 114s (commonly known as the Report of Foreign Bank and Financial Accounts, or FBAR) in calendar years 2015 and 2016  See appendix III for more details on our methodology to evaluate these data  We also summarized the numbers of IRS Forms 8938, Statement of Specified Foreign Financial Assets (Form 8938) filed in tax year 2016, accounting for the data limitations described below  We also identified Forms 8938 filed in tax year 2016—the most recent year for which data were available—with available residency and asset information that reported specified foreign financial assets with aggregate values at or below end-of-year tax thresholds, which vary depending on the location of residence and filing status of such filers  For our third objective, we reviewed IRS and FinCEN documentation, and applied criteria from Fragmentation, Overlap, and Duplication: An Evaluation and Management Guide to identify the extent to which IRS and FinCEN were engaged in overlapping activities, and collecting duplicative information on foreign financial assets held by U S  persons  We assessed the extent to which individual filers who submitted a Form 8938 in 2015 and 2016 also submitted an FBAR for the same year by determining the number and percentage of Forms 8938 with TINs that also match the TIN listed on the corresponding FBAR for the same year  For the three objectives described above, we assessed the reliability of data submitted on Forms 8938 filed by individuals for tax years 2015 and 2016, the most recent data available  These data were extracted from IRS’s Individual Return Transaction File (IRTF) and Modernized Tax Return Database (MTRDB) through IRS’s Compliance Data Warehouse (CDW)  We also assessed the reliability of data from FBARs for calendar years 2015 and 2016 by (1) reviewing documentation about the data and the systems that produced them; (2) conducting electronic tests, such as identifying data with significant numbers of missing Form 8938 or FBAR records, or values of foreign financial assets reported outside an expected range; (3) tracing selections or random samples of data to source documents; and (4) interviewing IRS and FinCEN officials knowledgeable about the data  We also reviewed Form 8938 and relevant parent tax return data stored in IRS databases to determine whether IRS management is using quality information collected from Forms 8938 to achieve its objectives, as defined in our Standards for Internal Control in the Federal Government  We determined that data extracted from IRTF on characteristics of Form 8938 filers and from FBAR filings was sufficiently reliable for our purposes, subject to caveats identified in this report  However, we determined we could not obtain complete data on foreign financial assets reported on Forms 8938 filed on paper  For our fourth objective, we reviewed model international agreements and other documentation, and interviewed officials from Treasury, IRS, and the Organisation for Economic Co-operation and Development to compare and contrast FATCA and CRS reporting requirements  We also used the collected information to identify what changes, if any, the United States and other countries could implement to align FATCA and CRS reporting requirements  For our fifth objective, we collected documentation and conducted focus groups and semi-structured interviews with 21 U S  persons living abroad that were subject to FATCA reporting requirements  We also conducted focus groups and interviews with tax practitioners, banking and CPA organizations, government agencies, advocacy groups representing Americans living abroad, and other organizations from the United States and five other countries (Canada, Japan, Singapore, Switzerland, and the United Kingdom)  We selected these countries based on geography, relatively high numbers of U S  expatriates and Form 8938 filers, tax information sharing agreements, and other tax treaties with the United States  The findings from the focus groups and interviews are not generalizable to other U S  persons, tax practitioners or organizations, but were selected to represent the viewpoints of U S  persons, FFIs, and host country tax authorities required to transmit information on foreign accounts and other specified foreign financial assets to IRS  We conducted a thematic analysis of the focus groups and interviews, and reviewed cables from U S  embassies to identify the unique effects of FATCA implementation on U S  persons living abroad  We collected documentation from and interviewed Treasury, IRS, Department of State, and Social Security Administration officials on steps to monitor and mitigate such effects  We also identified criteria from our prior work on key practices to enhance and sustain interagency collaboration and mechanisms to facilitate coordination  We applied the criteria to agencies’ collaborative efforts addressing issues U S  persons living abroad faced from FATCA’s implementation, and identified the extent to which agencies established effective collaborative mechanisms to identify, assess, and implement cross-agency solutions to such issues  We conducted this performance audit from August 2017 to April 2019 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 following IRS databases store data collected from individuals’ electronic and paper filings of Forms 8938 and/or elements of individual parent tax returns—the filer’s address and filing status—used to determine specified reporting thresholds for Form 8938 filers: Individual Master File (IMF), which serves as IRS’s system for processing individual taxpayer account data  Using this system, accounts are updated, taxes are assessed, and refunds are generated as required during each tax-filing period  Individual Returns Transaction File (IRTF), which stores edited, transcribed, and error-corrected data from the Form 1040 series and related forms for the current processing year and two prior years  Modernized Tax Return Database (MTRDB), which serves as the official repository of all electronic returns processed through IRS’s Modernized e-File system  Tax return data is stored immediately after returns are processed  International Compliance Management Model (ICMM)-FATCA International Returns (ICMM-FIR), which collects, parses, and stores data from incoming form reports–such as Forms 8938 and 8966–into the FATCA Database (FDB), which serves as the repository where ICMM-FIR stores data and from which downstream applications can pull data  Integrated Production Model (IPM), which is a downstream data repository that houses IMF data, information returns, and other data  According to IRS officials, data from IPM are consolidated and made available to a variety of downstream, security certified, systems for use in conducive analysis, case selection, and report preparation  Additionally, data from these and other IRS databases are copied to IRS’s Compliance Data Warehouse (CDW) periodically, which captures data from multiple production systems and organizes the data in a way that is conductive to analysis  Table 6 highlights several problems with the consistency and completeness of Form 8938 and relevant parent tax return data stored across the listed databases  Inconsistent and incomplete data on address and filing status of Form 8938 filers: As noted above, elements of parent tax returns— specifically the filer’s country of residence and filing status—are used to determine specified reporting thresholds for Form 8938 filers  However, IRTF and MTRDB have inconsistent and incomplete data on addresses linked to Form 8938 filers, and report inconsistent numbers of Forms 8938 filed from a U S  residence  For example, the variable identified as containing data on foreign countries of residence in IRTF shows approximately 8,100 foreign filers in tax years 2015 and 2016, whereas a similar variable in MTRDB shows approximately 89,000 foreign filers for those same years  Additionally, FDB does not contain country codes from paper filings of Form 8938  ICCM-FIR stores information from some elements from parent tax returns—such as TINs and document locator numbers  According to IRS officials, however, ICMM-FIR lacks data on country codes and filing status of Form 8938 filers  IRS officials said that ICMM-FIR was not designed or intended to store data on Form 8938 filers; rather, it was designed to be a database for use in comparing Form 8938 and 8966 data  In general, IRS officials indicated that they would like to adjust the way ICMM-FIR stores data, but that would require modifying the way the database was established  Incomplete data on assets reported on Forms 8938: MTRDB contains detailed information on specified foreign financial assets submitted on electronic filings of Form 8938 and the country code from which the Form 8938 was filed  IRS officials said it is not designed to store information submitted on paper filings of Forms 8938 and parent tax returns  IRS officials said that while IMF processes information transcribed from individual income tax returns, there is no requirement to cross-reference information from the tax return with information submitted with an accompanying Form 8938  Additionally, while IRS officials told us that IRTF is the authoritative source for filers of Form 8938, it does not store account and other asset information submitted from Forms 8938  When asked whether there is any move to store account and other asset information collected from Forms 8938 into IRTF, IRS officials said that the decision on what returns or portions of returns are transcribed are subject to resource constraints and are prioritized from year to year  Table 7 shows that more than 900,000 individuals filed Financial Crimes Enforcement Network (FinCEN) Form 114s (commonly known as the Report of Foreign Bank and Financial Accounts, or FBAR) in calendar years 2015 and 2016, and declared total maximum values of accounts ranging from about $1 5 trillion to more than $2 trillion each year  We are providing a range of estimates because we found a large number of filings made potentially in error  In some cases, for instance, FBAR filers reported more than $100 trillion in foreign financial accounts  We assume many of these filings are likely made in error, but have only limited means to determine which filings have errors, and which filings have accurate information  Because we cannot independently verify the accuracy of all self-reported FBAR data, we decided to present a range of data with (1) a lower bound discarding all FBAR filings reporting total values of reported foreign financial accounts at or above $1 billion; and (2) an upper bound discarding all filings reporting total values of such accounts at or above $5 billion  Table 2 excludes amended and duplicated FBAR filings  This table also excludes FBAR filings that reported a financial interest in 25 or more financial accounts, but reported total maximum account values of $0 from parts II and III of the FBAR  Although we identified problems with the data, we determined they were reliable enough to provide an estimated range of asset values to report the scale of foreign financial accounts held by U S  persons  Table 8 shows a detailed breakdown of 2015 and 2016 FBAR filings by residence and categories of total maximum account values reported on the FBARs  Appendix IV: Detailed Comparison of Individual Foreign Financial Asset Reporting Requirements 26 U S C  § 6038D; 26 C F R  §§ 1 6038D-1 to 1 6038D-8  26 C F R  § 1 6038D-2  Filers in this category include those who identify as single, married filing separately, “head of household,” or “qualifying widow(er) ” Includes maximum value of specified foreign financial assets (Form 8938) or maximum value of financial accounts maintained by a financial institution physically located in a foreign country (FBAR)  Under FATCA, any income, gains, losses, deductions, credits, gross proceeds, or distributions from holding or disposing of the account are or would be required to be reported, included, or otherwise reflected on a person’s income tax return  Under FBAR reporting requirements, a person has signature or other authority if he or she has the authority (alone or in conjunction with another) to control the disposition of money, funds or other assets held in a financial account by direct communication (whether in writing or otherwise) to the person with whom the financial account is maintained  The account itself is subject to reporting, but the contents of the account do not have to be separately reported  In addition to the contact named above, Brian James (Assistant Director), Mark Ryan (Analyst-in-Charge), Ariana Graham, George Guttman, Krista Loose, Daniel Mahoney, Cynthia Saunders, A J  Stephens, and Elwood White made key contributions to this report  Michael John Bechetti, Ted Burik, and Jacqueline Chapin also provided assistance 


Report 2: ccac gov   In tandem with recommendations received from the CCAC, the U S  Mint also seeks a recommendation from the U S  Commission of Fine Arts  Established in 1910, the CFA advises "upon the location of statues, fountains, and monuments in the public squares, streets, and parks in the District of Columbia; the selection of models for statues, fountains, and monuments erected under the authority of the Federal Government; the selection of artists; and questions of art generally when required to do so by the President or a committee of Congress " This includes review of commemorative coins when they are presented by the U S  Mint and the issuance of recommendations for a coin's design  For example, in March 2014, the U S  Mint presented several alternative designs for the First Special Service Force Congressional Gold Medal  In a letter to the U S  Mint, the CFA provided recommendations on the design for the gold medal  CFA's letter stated the following: After receiving advice from the CCAC and the CFA, the Secretary of the Treasury, through the U S  Mint, finalizes the coin's design and schedules it for production  Figure 1 shows the final design of two Congressional Gold Medals: the New Frontier Gold Medal for Neil Armstrong, Michael Collins, Buzz Aldrin, and John Glenn; and the Jack Nicklaus Gold Medal  As Members of Congress contemplate introducing legislation, and the House or the Senate potentially consider Congressional Gold Medal measures, there are several issues that could be considered  These can be divided into issues for individual Members of Congress with respect to individual Congressional Gold Medals, and issues for Congress as an institution  Individual issues include choices Members may make about which people or groups might be honored and whether specific design elements might be specified statutorily  Institutional issues might include committee or chamber rules on the consideration of Congressional Gold Medals and creating standards for the issuance of gold medals  Some Congressional Gold Medals have honored individuals (e g , Arnold Palmer, Muhammad Yunus), some discrete groups of individuals (e g , General of the Army George Catlett Marshall and Fleet Admiral Ernest Joseph King, Ruth and Billy Graham), and some larger groups (e g , military units such as Women Airforce Service Pilots ["WASP"], Monuments Men)  In choosing whom or what to recognize, Members of Congress generally evaluate whether they believe that the individual's or group's activities merit recognition by Congress  Congressional Gold Medals are "the highest civilian honor award program     [to] honor national achievement in patriotic, humanitarian, and artistic endeavors " There are no specific criteria to determine whether or not an individual or group meets those lofty goals  Instead, each individual or group is judged on their merits by Congress should the legislation be considered  Congressional Gold Medal authorizations generally do not specify design elements  Instead, they direct the Secretary of the Treasury to "strike a gold medal with suitable emblems, devices, and inscriptions to be determined by the Secretary " Should Congress want to specify particular design elements, they might be included in the authorizing legislation  This would provide the Secretary of the Treasury with congressional intent on what should be incorporated into the gold medal design  Similar statutory specificity is sometimes included in commemorative coin legislation  Such specification, however, could serve to limit design choices for the gold medal and might alter the cost structure of striking the award, if the required element diverges from standard practices  Congressional Gold Medal legislation for groups generally provides that only a single gold medal is struck and specifies where it will be located after it is formally awarded  In many cases, the gold medal is given to the Smithsonian for appropriate display and where it can be made available for research  In other cases, the gold medal is provided to an organization that represents the honored group  Since most gold medal legislation contains a provision on the medal's location, a Member of Congress can help determine where the medal will be located  As discussed above under " Authorizing Congressional Gold Medals ," neither the House nor Senate rules provide any restrictions specifically concerning consideration of Congressional Gold Medal legislation on the House or Senate floor  In the 116 th Congress, the Senate Committee on Banking, Housing, and Urban Affairs requires that at least 67 Senators must cosponsor any Senate Congressional Gold Medal bill before being considered by the committee  Currently, the House Financial Services Committee has not adopted any specific rules concerning committee consideration of Congressional Gold Medal legislation, although it has required a minimum number of cosponsors in past Congresses for committee consideration  As demonstrated by the discontinuation of the House Financial Services Committee rule requiring a minimum number of cosponsors for committee gold medal legislation, committee rules can be changed from Congress to Congress  Should the committee want to place requirements on its consideration of gold medal legislation, the Financial Services Committee could readopt its former rule, or something similar  Adopting committee rules to require a minimum number of cosponsors might encourage bill sponsors to build support among Representatives for gold medal bills  Such a minimum requirement, however, could potentially limit the number or type of gold medal bills the committee considers  Since only the Senate Committee on Banking, Housing, and Urban Affairs has a rule that imposes a formal qualification on the potential committee consideration of gold medal legislation, the possible path forward for a bill can be different within each chamber  Should the House, the Senate, or both want to adopt similar language for committee or chamber consideration of gold medal legislation, such language could be incorporated into future committee rules, into House and Senate Rules, or into law  Taking steps to formally codify the gold medal consideration process might provide sponsors with a single process for award consideration, which could make it easier for gold medal bills to meet minimum requirements for consideration across both the House and Senate  Such codification could also limit congressional flexibility and might result in fewer proposals or authorizations to comply with new standards  Currently, there is no statutory limit to the number of Congressional Gold Medals that can be authorized  Should Congress want to place a limit on the number of gold medals awarded, standards could be adopted to provide a maximum number of gold medals authorized in any year or Congress  Congress has previously adopted similar standards for commemorative coins—only two coins may be minted in any given calendar year  Legislation to place a limit on the number of gold medals authorized has previously been introduced and considered in the House  During the 109 th Congress (2005-2006), H R  54 passed the House and would have restricted the Secretary of the Treasury from striking "more than 2 congressional gold medals for presentation     in any calendar year " Introduced by Representative Michael Castle, the stated purpose of the legislation was to "maintain the prestige of the medal by limiting the number that may be awarded each year," and to "clarify that recipients are individuals and not groups " Passage of the measure, he argued, would "ensure the future integrity and true honor of the award " H R  54 did not receive further consideration in the Senate  While proponents of a limit on the number of gold medals issued might make arguments similar to those made by Representative Castle, opponents believe that Congress should reserve the right to authorize as many gold medals as it deems necessary, without consideration of the number struck in any calendar year  Representative Joseph Crowley in opposing the legislation told his House colleagues, "We are rushing to act on an issue that does not represent a problem " "Who that received this medal in the past," he asked, "was not worthy of it?" Further, Crowley argued that "there are occasions when more than one person is justified to receive the medal for their honorable actions in tandem with others " He continued by emphasizing that had this bill already been law, "Congress would not have been able to issue" a Congressional Gold Medal "to the Little Rock Nine," to "President and Mrs  Reagan," or to "Martin Luther King and Coretta Scott King " Congressional Gold Medals have long been an important way for Congress to express public gratitude for important historical events and achievements  Congressional Gold Medals, which have been issued since the American Revolution, are "the highest civilian honor award program     [to] honor national achievement in patriotic, humanitarian, and artistic endeavors " In recent years, the number of gold medals awarded has "soared from four or five per decade for most of its history to an average of almost twenty in the 1980s, 1990s, and 2000s " Each Congress, legislation to award Congressional Gold Medals is introduced  In the 113 th Congress (2013-2014), 52 bills were introduced, 34 in the House and 18 in the Senate, to award a gold medal  In the 114 th Congress (2015-2016), 52 bills were introduced, 38 in the House and 14 in the Senate  In the 115 th Congress (2017-2018), 55 bills were introduced, 33 in the House and 22 in the Senate  Based on the number of measures offered in both chambers, some Members of Congress clearly feel it is important to recognize individuals and groups for their patriotic, humanitarian, and artistic achievements  Several considerations appear important when Members decide to introduce gold medal legislation  These include who should be honored, how many medals should be awarded in a given Congress, and whether specific design elements should be prescribed for the medal design  As Congress continues to consider legislation to award future gold medals, these considerations and others will likely be important factors for issuing the award 

ground_truth: Senators and Representatives are frequently asked to support or sponsor proposals recognizing historic events and outstanding achievements by individuals or institutions. Among the various forms of recognition that Congress bestows, the Congressional Gold Medal is often considered the most distinguished. Through this venerable tradition—the occasional commissioning of individually struck gold medals in its name—Congress has expressed public gratitude on behalf of the nation for distinguished contributions for more than two centuries. Since 1776, this award, which initially was bestowed on military leaders, has also been given to such diverse individuals as Sir Winston Churchill and Bob Hope, George Washington and Robert Frost, Joe Louis and Mother Teresa of Calcutta. Congressional gold medal legislation generally has a specific format. Once a gold medal is authorized, it follows a specific process for design, minting, and awarding. This process includes consultation and recommendations by the Citizens Coinage Advisory Commission (CCAC) and the U.S. Commission of Fine Arts (CFA), pursuant to any statutory instructions, before the Secretary of the Treasury makes the final decision on a gold medal's design. Once the medal has been struck, a ceremony will often be scheduled to formally award the medal to the recipient. In recent years, the number of gold medals awarded has increased, and some have expressed interest in examining the gold medal awarding process. Should Congress want to make such changes, several individual and institutional options might be available. The individual options include decisions made by Members of Congress as to what individual or groups might be honored; potential specification of gold medal design elements; and where gold medals for groups might be housed once the award is made. The institutional options could include House, Senate, or committee rules for the consideration of gold medal legislation and whether statutory standards on the number of gold medals issued per year or per Congress might be established for gold medals.