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



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



Report 2: The rise of e-commerce has contributed to a fundamental change in the market for counterfeit goods, according to our analysis of documents from CBP, ICE, and international organizations and our interviews with CBP and ICE officials  U S  agencies and international organizations have observed a shift in the sale of counterfeit goods from “underground” or secondary markets, such as flea markets or sidewalk vendors, to primary markets, including e-commerce websites, corporate and government supply chains, and traditional retail stores  Whereas secondary markets are often characterized by consumers who are knowingly purchasing counterfeits, primary markets involve counterfeiters who try to deceive consumers into purchasing goods they believe are authentic  This shift has been accompanied by changes in the ways in which counterfeit goods are sold  In the past, consumers could often rely on indicators such as the location of sale or the goods’ appearance or price to identify counterfeit goods in the marketplace  However, counterfeiters have now adopted new ways to deceive consumers  For example, as consumers increasingly purchase goods online, counterfeiters may exploit third-party online marketplaces to gain an appearance of legitimacy and access to consumers  When selling online, counterfeiters may post pictures of authentic goods on the websites where they are selling counterfeits and may post pseudonymous reviews of their products or businesses in order to appear legitimate  Additionally, by setting the price of a counterfeit at, or close to, the retail price of a genuine good, counterfeiters may deceive consumers, who will pay the higher price because they believe the goods are real or who believe that they are getting a slight bargain on genuine goods  According to CBP seizure data and CBP officials, the volume, variety, and methods of shipment of counterfeit goods seized by CBP and ICE have changed in recent years  CBP reports indicate that the number of IPR seizures increased by 38 percent in fiscal years 2012 through 2016  According to CBP data, approximately 88 percent of IPR seizures made during this period were shipped from China and Hong Kong  The variety of products being counterfeited has also increased, according to CBP officials  CBP and ICE officials noted that, while many consumers may think of luxury handbags or watches as the most commonly counterfeited goods, counterfeiting occurs in nearly every industry and across a broad range of products  In addition, according to CBP data we reviewed and officials we spoke to, the methods of importing counterfeit goods into the United States have changed in recent years  Specifically, express carriers and international mail have become the predominant form of transportation for IPR-infringing goods entering the United States, constituting approximately 90 percent of all IPR seizures in fiscal years 2015 and 2016, according to CBP data  In an attempt to illustrate the risk that consumers may unknowingly encounter counterfeit products online, we purchased a nongeneralizable sample of four types of consumer products—shoes, travel mugs, cosmetics, and phone chargers—from third-party sellers on five popular e-commerce websites  According to CBP data we reviewed and officials we spoke to, CBP often seizes IPR-infringing counterfeits of these types of products  As table 1 shows, the rights holders for the four selected products we purchased determined that 20 of the 47 items were counterfeit  We did not identify any clear reasons for the variation among the counterfeit and authentic items that we purchased based on the products that they represented, the e-commerce websites where we bought the items, or the third-party sellers from whom we bought them  For three of the four product types, at least one item we purchased was determined to be counterfeit, with results varying considerably by product  Representatives of the rights holders also could not provide a specific explanation for the variation among authentic and counterfeit goods that we received  They noted that the results of covert test purchases can fluctuate depending on enforcement activities and the variety of goods and sellers on a particular website on a given day  Rights-holder testing also showed that we purchased at least one counterfeit item and one authentic item from each of the five e-commerce websites  In addition, our analysis of the customer ratings of third-party sellers from whom we bought the items did not provide any clear indications that could warn consumers that a product marketed online may be counterfeit  For example, we received both counterfeit and authentic items from third- party sellers with ratings that were less than 70 percent positive as well as sellers with ratings that were up to 100 percent positive  Rights holders were able to determine that items we purchased were not authentic on the basis of inferior quality, incorrect markings or construction, and incorrect labeling  Some counterfeit items we purchased were easily identifiable as likely counterfeit once we received them  For example, one item contained misspellings of “Austin, TX” and “Made in China ” Other items could be more difficult for a typical consumer to identify as counterfeit  For example, the rights holder for a cosmetic product we purchased identified one counterfeit item on the basis of discrepancies in the color, composition, and design of the authentic and counterfeit items’ packaging  Counterfeit goods may also lack key elements of certification markings and other identifiers  For example, on a counterfeit phone charger we purchased, the UL certification mark did not include all components of the authentic mark  Figure 1 shows examples of these counterfeit items  The risks associated with the types of counterfeit goods we purchased can extend beyond the infringement of a company’s IPR  For example, a UL investigation of counterfeit iPhone adapters found a 99 percent failure rate in 400 counterfeit adapters tested for safety, fire, and shock hazards and found that 12 of the adapters tested posed a risk of lethal electrocution to the user  Similarly, according to a rights holder representative, counterfeits of common consumer goods, such as Yeti travel mugs, may contain higher-than-approved concentrations of dangerous chemicals such as lead, posing health risks to consumers  According to ICE, seized counterfeit cosmetics have been found to contain hazardous substances, including cyanide, arsenic, mercury, lead, urine, and rat droppings  Representatives of rights holders and e-commerce websites whom we interviewed reported taking independent action to try to protect IPR within their areas of responsibility  For example, both rights holders and e- commerce websites maintain IPR protection teams that work with one another and with law enforcement to address infringement issues  E- commerce websites may also take a variety of steps to block and remove counterfeit items listed by third-party sellers  These efforts rely on data collected through a variety of means, including consumer reporting of counterfeits, rights-holder notifications of IPR infringement, and corporate efforts to vet potential third-party sellers, according to private sector representatives  Our January 2018 report includes information on steps that consumer protection organizations and government agencies recommend consumers take to limit the risk of purchasing counterfeits online  These steps include, for example, buying only from authorized retailers online, avoiding prices that look “too good to be true,” and reporting counterfeit purchases  We identified a number of key challenges that the changes in the market for counterfeit goods can pose to CBP and ICE as well as to the private sector  First, the increasing sophistication of counterfeits can make it difficult for law enforcement officers to distinguish between legitimate and counterfeit goods  Second, as the range of counterfeit goods expands, CBP has a wider variety of goods to screen, which requires CBP officials to have in-depth knowledge of a broad range of products and of how to identify counterfeits  Third, counterfeiters may break up large shipments into multiple smaller express carrier or mail packages to decrease the risk of losing significant quantities of merchandise to a single seizure  This shift toward smaller express shipments of counterfeit goods to the United States poses challenges to CBP and ICE because, according to CBP officials, seizure processing requires roughly the same amount of time and resources regardless of shipment size or value  The changing marketplace also presents challenges to the private sector, according to representatives from rights holders and e-commerce websites  For example, it is more difficult for rights holders and e- commerce websites to identify and investigate individual counterfeit cases, because e-commerce websites face a growing inventory from a larger registry of sellers  Tracking goods from known counterfeiters through various website fulfillment and delivery mechanisms is also a significant challenge for the private sector  Furthermore, the growth of e- commerce has accelerated the pace at which counterfeiters can gain access to consumers or reinvent themselves if shut down  CBP and ICE engage in a number of activities to enhance IPR enforcement; however, while ICE has assessed some of its efforts, CBP has taken limited steps to do so  CBP’s and ICE’s IPR enforcement activities broadly include detecting imports of potentially IPR-infringing goods, conducting special operations at U S  ports, engaging with international partners, and undertaking localized pilot programs or port- led initiatives  CBP and ICE have collected some performance data on activities we reviewed, and ICE has taken some steps to better understand the impact of its efforts, such as creating a process to track cases it deems significant  However, we found that CBP has conducted limited evaluation of its efforts to enhance IPR enforcement  Consequently, we concluded that CBP may lack information needed to ensure it is investing its resources in the most efficient and effective activities  We recommended in our report that CBP take steps to evaluate the effectiveness of its IPR enforcement efforts; CBP concurred with this recommendation  Our analysis showed that CBP and ICE interagency collaboration on IPR enforcement is generally consistent with the following selected key practices for effective interagency collaboration: (1) define and articulate a common outcome; (2) establish mutually reinforcing or joint strategies; (3) identify and address needs by leveraging resources; (4) agree on roles and responsibilities; and (5) establish compatible policies, procedures, and other means to operate across agency boundaries  For example, the agencies may leverage resources by collocating staff or sharing their expertise  CBP and ICE have also issued guidance and developed standard operating procedures to clarify roles and responsibilities  CBP and ICE also coordinate with the private sector in a variety of ways, such as obtaining private sector assistance to determine whether detained goods are authentic and to conduct training  Representatives of rights holders and e-commerce websites noted that information shared by law enforcement entities is critical to private sector IPR enforcement, such as pursuing civil action against a counterfeiter or removing counterfeit items from websites  In the Trade Facilitation and Trade Enforcement Act of 2015, Congress provided CBP with explicit authority to share certain information with trademark and copyright owners before completing a seizure  CBP officials stated that they share information about identified counterfeits with e-commerce websites and rights holders to the extent possible under current regulations  However, according to private sector representatives we spoke to, restrictions on the amount and type of information about seized items shared by CBP limit the ability of rights holders and e-commerce websites to protect IPR  CBP officials noted that there are legal limitations to the amount and type of information they can share, particularly if the e-commerce website is not listed as the importer on forms submitted to CBP  Several private sector representatives stated that receiving additional information from CBP would enhance their ability to protect IPR  Representatives of one website noted that information on the exterior of seized packages, such as business identifiers on packages destined for distribution centers, would be helpful for identifying groups of counterfeit merchandise from the same seller  However, according to CBP officials, CBP cannot provide such information to e-commerce websites  Representatives of one e-commerce website noted that ICE sometimes shares information related to an investigation, but that ICE’s involvement in the enforcement process begins only after CBP has identified and seized counterfeit items  Representatives of two e-commerce websites stated that, because of the limited information shared by CBP, they may not be aware of IPR-infringing goods offered for sale on their websites, even if CBP has seized related items from the same seller  According to CBP officials, CBP is reviewing options for sharing additional information with rights holders and e-commerce websites and is assessing what, if any, additional information would be beneficial to share with private sector entities  CBP officials stated that they have not yet determined whether changes to the amount and types of information provided to e-commerce websites would require regulatory changes or additional legal authorities  These officials also said that they have discussed differences in CBP’s and ICE’s information sharing with ICE officials  In our report, we recommended that CBP, in consultation with ICE, assess what, if any, additional information would be beneficial to share with the private sector and, as appropriate, take action to enhance information sharing where possible  CBP concurred with this recommendation  Chairman Hatch, Ranking Member Wyden, and Members of the Committee, this concludes my prepared statement  I would be pleased to answer any questions that you may have at this time  If you or your staff have any questions about this testimony, please contact Kimberly Gianopoulos, Director, International Affairs and Trade, at (202) 512-8612 or gianopoulosk@gao gov  Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this statement  GAO staff who made key contributions to this testimony are Joyee Dasgupta, Kara Marshall, Katie Bassion, Kristen Timko, Reid Lowe, Sarah Collins, Neil Doherty, Ramon Rodriguez, Helina Wong, Julie Spetz, Kevin Loh, Wayne McElrath, Grace Lui, James Murphy, Mary Moutsos, Justin Fisher, Rachel Stoiko, and Sarah Veale  This is a work of the U S  government and is not subject to copyright protection in the United States  The published product may be reproduced and distributed in its entirety without further permission from GAO  However, because this work may contain copyrighted images or other material, permission from the copyright holder may be necessary if you wish to reproduce this material separately 
Report 2:  Federal internal control standards state that management should share quality information throughout an organization to enable personnel to perform key roles, and we have previously reported that by regularly sharing useful performance information with leaders at multiple levels of an organization, agencies can help leaders make informed decisions  Without this information, individual unit commanders or the commanders’ supervisors cannot determine whether Coast Guard servicemembers under their command completed TAP or identify whether there is a need for corrective actions to ensure they do so  As we mention earlier in this report, the Coast Guard plans to adopt DOD’s TAP-IT Enterprise System, which according to officials, could help the Coast Guard ensure eligible servicemembers participate in the program  According to a Coast Guard official, once the system is fully implemented by the Coast Guard, commanders will be required to verify and document whether Coast Guard servicemembers under their command completed TAP, potentially making commanders more vested in the process  We previously reported that a senior DOD official said that the TAP-IT Enterprise System may be able to generate unit- and installation-level reports for the four DOD-led military services by October 2018, and a Coast Guard official said he would work with DOD to identify whether this capability could also extend to the Coast Guard  Once data reliability improves, sharing installation and unit-level TAP performance information with Coast Guard commanders could support monitoring efforts  The performance measures tracked by the TAP interagency working group do not reflect TAP implementation broadly across all five military services, according to a Coast Guard official we interviewed  The Coast Guard does not currently share TAP data it collects with DOD or other members of the interagency performance working group  While the benefits of interagency data sharing cannot be realized without the Coast Guard first improving the quality and completeness of its TAP data, we have identified leading practices for interagency collaboration, including that members of interagency working groups identify and share relevant agency performance data  Moreover, federal internal control standards call for management to communicate quality information to external parties  Because the Coast Guard does not share TAP data, the performance measures tracked by the interagency group do not reflect Coast Guard servicemembers’ experiences and thus do not provide a complete picture of TAP implementation across the five military services  More specifically for the Coast Guard, without such data sharing, future TAP evaluations may not be able to assess the effectiveness of TAP delivery, hindering the Coast Guard’s ability to make program adjustments to better prepare its servicemembers to successfully transition to life after military service  Coast Guard officials said migrating to DOD’s TAP-IT Enterprise System will facilitate information sharing with interagency partners and that improving data completeness and reliability is a top priority for 2018  Given the sacrifices servicemembers have made to serve their country, it is imperative they are afforded every chance to adequately prepare for civilian life before leaving military service  In order to make a successful transition, servicemembers need to be well-positioned to get a job or make an informed decision about whether to pursue additional education or start a small business  As such, the Transition Assistance Program (TAP) serves a critically important function—to give servicemembers the tools and information they need to successfully transition to life outside the military  Federal law requires that the Coast Guard ensure all eligible servicemembers participate in the program, but thousands of Coast Guard servicemembers may have transitioned without the support provided by TAP  Reliably tracking participation has proven to be a challenge for the Coast Guard, in part because it lacks a current Commandant Instruction that defines the roles and responsibilities of staff responsible for implementing TAP and ensuring complete and reliable data are collected  In preparing to issue an updated Commandant Instruction, the Coast Guard has taken a positive step toward addressing the limitations of its current TAP data, and will be better positioned to ensure compliance with VOW Act requirements using reliable data  In addition to collecting reliable data, the Coast Guard could further demonstrate its commitment to meeting TAP requirements by establishing formal performance goals that measure the extent to which Coast Guard servicemembers participate in TAP  By establishing interim performance goals, the agency would be able to show its progress towards achieving full compliance  Moreover, communicating performance goals to unit and installation commanders could enhance accountability and might spur progress toward meeting federal program requirements  By expanding its monitoring efforts beyond tracking participation in TAP’s required classes, the Coast Guard could enhance its ability to ensure other TAP requirements are met and that its servicemembers are able to access additional transition resources  Monitoring the timeliness of participation would help ensure Coast Guard servicemembers have adequate time to complete TAP before leaving the military  Further, by monitoring requests to participate in additional 2-day classes and 2-day class attendance, the Coast Guard would be in a better position to identify whether servicemembers who wish to attend the classes are able to do so, to determine whether more classes are needed, and to communicate this information to the interagency partners responsible for delivering these classes  Commanders can also play a key role in bolstering TAP participation  Having an up-to-date written Commandant Instruction that explicitly describes commanders’ roles and responsibilities could enhance commanders’ ability to ensure TAP’s proper implementation and compliance with VOW Act requirements  Moreover, once data quality improves, providing commanders a mechanism to readily determine whether servicemembers under their command have completed TAP could help them monitor the program to ensure that all TAP-eligible servicemembers receive the resources they need to successfully transition to civilian life  Finally, once more reliable data on Coast Guard servicemember participation are available, sharing this information with interagency partners could improve TAP implementation on a broader scale  Sharing reliable data, such as participation figures for the Coast Guard, would give TAP interagency partners a more complete picture of implementation across all five military services  Sharing such information would also enhance the interagency group’s ability to evaluate how well TAP serves the entire population of servicemembers  Improving the reliability of the Coast Guard’s TAP data will be essential for the benefits of data sharing to be realized  To ensure that all eligible Coast Guard servicemembers are provided the opportunity to complete the Transition Assistance Program (TAP), we recommend the Commandant of the Coast Guard take the following seven actions: Issue an updated Commandant Instruction that establishes policies and procedures to improve the reliability and completeness of TAP data by including when and by whom data should be recorded and updated  (Recommendation 1) Establish a formal performance goal with a measurable target for participation rates in VOW Act-mandated portions of TAP  (Recommendation 2) Monitor the extent to which Coast Guard servicemembers participate in TAP within prescribed time frames  (Recommendation 3) Monitor the extent to which Coast Guard servicemembers who elect to participate in additional 2-day classes are afforded the opportunity to attend  (Recommendation 4) Issue an updated Commandant Instruction that defines the roles and responsibilities of the personnel who administer the program and ensure servicemembers’ participation  (Recommendation 5) Once reliable data are available by installation or unit, enable unit commanders and the higher-level commanders to whom they report to access TAP performance information specifically for the units they oversee so that they can monitor compliance with all TAP requirements  (Recommendation 6) Once reliable data are available, share TAP information with DOD and other interagency partners, such as data on participation in required TAP courses and additional 2-day classes  (Recommendation 7) We provided a draft of this report to the Departments of Homeland Security, Defense, Education, Labor, and Veterans Affairs, the Office of Personnel Management, and the Small Business Administration for their review and comment  The formal written response of the Department of Homeland Security (DHS) is reproduced in appendix II  In addition, DHS provided technical comments from Coast Guard officials that we incorporated into the report as appropriate  The other agencies did not provide any comments  In its written comments, DHS agreed with all seven of our recommendations  If you or your staff have any questions about this report, please contact me at (202) 512-7215 or brownbarnesc@gao gov  Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report  GAO staff who made key contributions to this report are listed in appendix III  This report examines (1) what is known about the reliability of Transition Assistance Program (TAP) data on participation levels and the factors that affect Coast Guard servicemembers’ participation, and (2) the extent to which the Coast Guard measures TAP performance and monitors key areas of TAP implementation  To address these questions, we surveyed Coast Guard installations with full-time TAP operations; reviewed Coast Guard data on TAP participation for fiscal years 2012 to 2017; visited one Coast Guard installation and interviewed TAP managers from two additional Coast Guard installations selected for diversity in location, among other reasons; and interviewed Coast Guard officials responsible for overseeing TAP implementation for the Coast Guard  We also reviewed relevant federal laws, regulations, policies, documents, and publications  Information in this report is current as of the date GAO received formal agency comments from DHS  Our survey of Coast Guard installations with full-time TAP operations asked about how TAP was being implemented  The survey included questions about the accessibility of TAP components, challenges Coast Guard servicemembers faced in attending the components, and the level of commander support for participation  Our survey targeted front-line TAP managers, who could draw on the expertise of TAP course facilitators, transition counselors, career counselors, and other key TAP staff as necessary  After drafting the survey questions, we pretested them with a TAP manager to ensure (1) the questions were clear and unambiguous, (2) terminology was used correctly, (3) the survey did not place an undue burden on agency officials, (4) the information could feasibly be obtained, and (5) the survey was comprehensive and unbiased  We revised the content and format of the survey based on the feedback we received  We initially sent the survey to TAP managers at all 13 Coast Guard installations at which TAP staff were located  We removed one installation when we later found that the TAP manager position was vacant and revised the total to 12 Coast Guard installations  The survey was accessible online from October 31, 2016, through January 18, 2017, through a secure server that recipients were able to access using unique usernames and passwords  We sent an email announcement to TAP staff at all 13 Coast Guard installations at which TAP staff are located on October 24, 2016  We sent a second email on October 31, 2016 to notify participants the survey was available online, and provided their unique passwords and usernames  We sent two follow-up e-mails (November 14, 2016 and November 28, 2016) to those who had not responded  Finally, we contacted all remaining nonrespondents by telephone starting December 5, 2016  The survey was available online until we reached a 100 percent response rate  To increase our understanding into how TAP was being implemented at installations and supplement our survey findings, we visited one Coast Guard installation and interviewed TAP managers from two additional installations  We selected the installations based on several factors, including the size of the installation, proximity to Department of Defense (DOD) installations, and diverse locations in the United States  (See table 1 ) At Coast Guard Base Elizabeth City in North Carolina, the installation we visited, we interviewed the TAP manager, uniformed career counselors, and senior installation leadership  During our interviews with TAP managers at all three installations, we asked about the extent to which Coast Guard servicemembers participate in TAP’s required and additional 2-day classes, including whether the servicemembers attended classes online or in a classroom setting, challenges to ensuring Coast Guard servicemembers participate in TAP, and the extent to which they monitor Coast Guard servicemembers’ participation in TAP  At Coast Guard Base Elizabeth City, we also interviewed 25 Coast Guard servicemembers (both officers and enlisted personnel) to get their perspective on how well TAP worked and any challenges they had participating  To help guide the interviews with the Coast Guard servicemembers, we asked them to complete a short questionnaire that asked about their experiences with the TAP program  We also interviewed TAP staff at Coast Guard headquarters to learn about TAP policy, monitoring efforts, and performance measures for the service overall  For example, we asked what policies and procedures guide installations’ TAP implementation; what performance measures the Coast Guard uses to monitor TAP; how performance results are reported and shared with different levels of Coast Guard leadership; and to what extent the Coast Guard uses results from TAP participant satisfaction assessments  We also asked whether the Coast Guard plans to shift to DOD’s new TAP-IT Enterprise System and how using the new system could affect its monitoring efforts in the future  In evaluating the Coast Guard’s performance measures, we focused on measures related to servicemembers’ transition experiences before leaving the military  We did not gather information on post-program evaluations and outcomes because they were determined to be outside the scope of this review  We reviewed DHS data on TAP participation for fiscal years 2012 to 2017  To assess the reliability of the Coast Guard’s TAP participation data, we interviewed agency officials knowledgeable about the data  We determined these data were not sufficiently reliable due to limitations with the Coast Guard’s data collection system  Specifically, the system lacks adequate controls to ensure TAP data are complete and accurate  We conducted this performance audit from February 2016 to April 2018 in accordance with generally accepted government auditing standards  Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives  We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives  In addition to the contact named above, Meeta Engle (Assistant Director), Amy MacDonald (Analyst-in-Charge), James Bennett, Holly Dye, David Forgosh, Ying Long, Jonathan McMurray, Jean McSween, Andrew Sherrill, Benjamin Sinoff, and Timothy Young, made significant contributions to this report  Also contributing to this report were Susan Aschoff, Jessie Battle, Ramona Burton, Melinda Cordero, Elizabeth Curda, Dawn Hoff, Ben Licht, Serena Lo, Sheila McCoy, Almeta Spencer, Christopher Schmitt, James Whitcomb, and Jill Yost  Transitioning Veterans: DOD Needs to Improve Performance Reporting and Monitoring for the Transition Assistance Program, GAO-18-23  Washington, D C : November, 8, 2017  Transitioning Veterans: Improvements Needed in DOD’s Performance Reporting and Monitoring of the Transition Assistance Program, GAO-18-225T  Washington, D C : November 8, 2017  Department of Defense: Transition Assistance Program (TAP) for Military Personnel, GAO-16-302R  Washington, D C : December 17, 2015  Veterans’ Employment: Need for Further Workshops Should Be Considered before Making Decisions on Their Future, GAO-15-518  Washington, D C : July 16, 2015  Military and Veteran Support: DOD and VA Programs That Address the Effects of Combat and Transition to Civilian Life, GAO-15-24  Washington, D C : November 7, 2014  Veterans Affairs: Better Understanding Needed to Enhance Services to Veterans Readjusting to Civilian Life, GAO-14-676  Washington, D C : September 10, 2014  Transitioning Veterans: Improved Oversight Needed to Enhance Implementation of Transition Assistance Program, GAO-14-144  Washington, D C : March 5, 2014  Military and Veterans’ Benefits: Enhanced Services Could Improve Transition Assistance for Reserves and National Guard, GAO-05-544  Washington, D C : May 20, 2005  Military and Veterans’ Benefits: Observations on the Transition Assistance Program, GAO-02-914T (July 18, 2002) 

ground_truth: The VA is responsible for ensuring that veterans have reasonable access to burial options in a national or state veterans' cemetery. In fiscal year 2018 VA estimated that about 92 percent of veterans had reasonable access to burial options, which was an increase from 90 percent in fiscal year 2014 but short of its goal of 96 percent by the end of fiscal year 2017. The House Appropriations Committee has expressed concerns that there are geographic pockets where veterans remain unserved by burial options. House Report 115-188 accompanying a bill for the Military Construction, Veterans Affairs, and Related Agencies Appropriations Act, 2018, includes a provision for GAO to examine veterans' access to burial options. This report (1) describes VA's plan for increasing reasonable access to burial options for veterans and (2) assesses VA's progress in implementing its plan and any challenges experienced. GAO reviewed applicable VA and NCA documents, compared NCA's cost-estimating practices with GAO's cost-estimating 12 steps, and met with cognizant officials regarding NCA's efforts to provide reasonable access to burial options. Within the Department of Veterans Affairs (VA), the National Cemetery Administration (NCA) has a plan to establish 18 new national cemeteries to increase reasonable access to burial options for veterans. NCA defines reasonable access as a national or state veterans' cemetery being located within 75 miles of veterans' homes. Key parts of NCA's plan include establishing 13 urban and rural initiative national cemeteries and awarding grant funds to state applicants for establishing new state veterans' cemeteries. NCA has made limited progress in implementing its plan to increase burial access and is years behind its original schedule for opening new cemeteries. For example, NCA has opened only two of its planned urban and rural initiative sites and is behind its original schedule for the other 11 (see fig. below). The primary factor delaying NCA's completion of these cemeteries has been challenges in acquiring suitable land. NCA has also been challenged in producing accurate estimates of construction costs for most of its rural initiative sites. Cost estimates have increased more than 200 percent (from about $7 million to $24 million) for these sites, and NCA's guidance for developing cost estimates for the cemeteries does not fully incorporate the 12 steps identified in cost-estimating leading practices—such as conducting a risk and uncertainty analysis or a sensitivity analysis. As a result, NCA is not well positioned to provide reliable and valid cost estimates to better inform decisions to enhance veterans' cemetery access. GAO recommends that NCA fully adopt cost-estimating leading practices into its procedures to assist in improving its cost estimates for establishing cemeteries. NCA concurred with our recommendation.

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



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

Report 1: The National Cemeteries Act of 1973 created the modern veterans’ cemetery system  NCA, within VA, manages a majority of veterans’ cemeteries in the United States  In that role NCA maintains existing national cemeteries and builds new national cemeteries for the nation’s veterans and their family members  Since 1978 NCA has also provided funding through VA’s Veterans Cemetery Grants Program (Grants Program) to help establish, expand, or improve state and tribal veterans’ cemeteries  States and tribal governments seeking funding from the Grants Program must apply to the VA  Any cemetery established, expanded, or improved through funding from VA’s Grants Program must be maintained and operated in accordance with NCA’s operational standards  Veterans from all 50 states, the District of Columbia, Puerto Rico, and some U S  territories are served by national, state, or tribal cemeteries  In addition, over time NCA has changed its policies and procedures to better fulfill its mission to serve and honor veterans and their family members  For example, in 2011 NCA lowered its policy threshold for establishing new national cemeteries from an area having at least 170,000 veterans who are unserved by burial options to an area having 80,000 unserved veterans  NCA established this revised policy threshold in recognition that many highly populated areas still lacked reasonable access to a burial option, and based on data and analysis provided by an independent review of VA’s burial benefits program in 2008  This revised minimum veteran population threshold was chosen based on data showing that state veterans’ cemeteries funded through VA’s Grants Program were located in areas that typically served a maximum of 80,000 veterans within a 75-mile service area  According to VA documentation, moving to this lower threshold has enabled the agency to establish new national cemeteries in areas where states may not have been willing to place them because of the size and cost of operating a larger state veterans’ cemetery  NCA offers a variety of facilities to meet the burial needs of veterans, including various cemetery configurations that either provide burial options to eligible veterans or improve their access to burial options, as shown in table 1  NCA uses county-level population data to determine whether veterans currently have reasonable access to burial options and uses county-level population projections to support decisions about future cemetery locations  NCA makes its decisions regarding whether a veteran is served or unserved based on the county in which the veteran resided, without reference to the location of the veteran’s actual residence  NCA’s methodology uses a veteran’s county of residence as a proxy for being within 75 miles of a veterans’ cemetery  NCA’s plan entails establishing 18 new national cemeteries—comprised of five traditional national cemeteries and 13 urban and rural initiative national cemeteries—and awarding funds for new state veterans’ cemeteries  In 2014, we reported that NCA estimated approximately 90 percent of the veteran population had reasonable access to burial options, and that it expected to reach its strategic goal of providing reasonable access to 96 percent of veterans by the end of fiscal year 2017  Since 2014, NCA has revised its strategic goal to provide reasonable access to 95 percent of the veteran population, and NCA’s current long-range plan to achieve this goal covers fiscal years 2018- 2022  NCA’s 2014 plan to increase veterans’ access to burial options included building 18 new national cemeteries as follows: Five traditional national cemeteries, to be located in Western New York; Central East Florida; Southern Colorado; Tallahassee, Florida; and Omaha, Nebraska  Taken together, according to NCA, these cemeteries are intended to provide a burial option to an additional 550,000 veterans and their families  Five urban initiative cemeteries, to be located in Los Angeles, California; the San Francisco Bay Area, California; Chicago, Illinois; Indianapolis, Indiana; and New York, New York  Taken together, according to NCA, the urban initiative is intended to expand burial options for approximately 2 4 million additional veterans in certain urban areas  NCA announced this initiative in 2011 with the purpose of expanding burial options in urban areas through building columbaria-only (facilities for cremated remains) national cemeteries close to the urban core  Eight rural initiative cemeteries, to be located in Idaho, Maine, Montana, Nevada, North Dakota, Utah, Wisconsin, and Wyoming  Taken together, according to NCA, the intent of the rural initiative is to increase the burial options for approximately 106,000 additional veterans in certain rural areas  NCA announced this initiative in 2012 with the purpose of increasing access by establishing new national cemeteries for states with no open national cemetery and a population of 25,000 or fewer veterans  In addition, since 1978, NCA has used the Grants Program to help increase veterans’ cemetery access  The Grants Program was established to complement national cemeteries by assisting state, territory, and tribal government applicants to establish, expand, or improve veterans’ cemeteries in order to provide gravesites for veterans in those areas where NCA cannot fully satisfy their burial needs  As noted earlier, states and tribal governments seeking grant funding must apply to the VA  States, funded by the Grants Program, often build in areas with veteran populations that are too small to qualify for a national cemetery  NCA prioritizes pending grant applications by giving the highest priority to cemetery construction projects in geographic locations with the greatest projected number of veterans who will benefit from the project, as determined by NCA based on county-level population projections  In 2018, NCA provided funding for a total of 15 grants for the expansion, improvement, or establishment of state and tribal government veterans’ cemeteries  This includes the establishment of two new state and tribal government veterans’ cemeteries  In 2019, NCA expects to provide funding for 17 state and tribal government veterans’ cemetery projects, three of which would be for new cemeteries  While NCA has made some progress in implementing its plan to increase burial access for veterans, that progress has been limited, as it is years behind its original schedule for opening new cemeteries  In its efforts, NCA has experienced three key challenges: (1) acquiring suitable land for new national cemeteries, (2) estimating the costs associated with establishing new national cemeteries, and (3) using all available data to inform how its Grants Program targets unserved veteran populations  In 2014, NCA planned to open 18 new sites by the end of fiscal year 2017 to better serve the burial needs of the veteran population  As of September 2019, NCA has opened four new traditional national cemeteries—Tallahassee National Cemetery in Tallahassee, Florida; Cape Canaveral National Cemetery in Mims, Florida; Omaha National Cemetery in Omaha, Nebraska; and Pikes Peak National Cemetery in Colorado Springs, Colorado  NCA also opened two of its eight planned rural initiative cemeteries—Yellowstone National Cemetery in Laurel, Montana, and Fargo National Cemetery in Harwood, North Dakota  As a result, according to NCA, by the end of fiscal year 2018 the percentage of veterans with reasonable access had increased from 90 percent to about 92 percent  As previously discussed, NCA’s goal is to provide 95 percent of veterans with reasonable access to burial options  As we reported in 2014, NCA had initially planned to open all of its 13 urban and rural initiative sites by the end of fiscal year 2017  As shown in figure 1, NCA had originally estimated completing all five of its urban initiative sites by the end of fiscal year 2015  However, the completion dates for all of these sites have slipped multiple times  In July 2019, NCA officials stated that the planned completion dates for the urban initiative sites were as follows: October 2019 for Los Angeles, sometime in 2020 for New York and Indianapolis, September 2021 for Chicago, and sometime in 2027 for San Francisco  As shown in figure 2, NCA has opened two of its rural initiative sites, in Laurel, Montana, and Fargo, North Dakota  However, the completion dates for the other six rural initiative sites have slipped multiple times  In September 2019, NCA officials stated that the planned completion dates for the rural initiative sites were currently Fall 2019 for Twin Falls, Idaho, Machias, Maine, and Rhinelander, Wisconsin; sometime in 2020 for Cheyenne, Wyoming; and Summer 2021 for Cedar City, Utah  NCA did not provide a specific estimated completion date for the site in Elko, Nevada, affirming that it would be completed “in a future year ” When we asked NCA officials why the rural and urban initiative sites were currently projected to take years longer to complete than originally planned, they replied that they might have overstated their 2014 expectations for having all initiative sites completed by the end of fiscal year 2017  NCA officials also stated that it takes at least 12 months for the land acquisition phase of cemetery construction projects; 9 to 12 months for the design phase; and 12 to 15 months—sometimes up to 30—for the construction phase  According to NCA officials, as of September 2019, five of the 11 initiative sites had reached the construction phase, and one of the sites no longer had an estimated completion date  There were still some outstanding or unresolved issues that had complicated NCA’s ability to estimate a completion date for the site in Elko, Nevada  See figure 3 for a timeline of each of NCA’s urban and rural initiative sites as of September 2019  In executing its plans to increase access to burial options for veterans, NCA has experienced three key challenges: (1) acquiring suitable land for new national cemeteries; (2) estimating the costs associated with establishing new national cemeteries; and (3) using all available data to inform how its Grants Program targets unserved veteran populations  The primary factor that has led NCA to adjust its timelines for completing these cemeteries concerns challenges in acquiring suitable land  Such challenges include difficulty in finding viable land for development, legal issues related to the acquisitions process, and resistance from the local community, among others  Four examples are described below, including two instances in which, as of July 2019, NCA had not yet acquired suitable land, which may further delay the opening of those specific urban and rural sites  Chicago, Illinois  NCA officials stated that they are on their fifth attempt to acquire land for the urban initiative site in Chicago, Illinois  In addition, they said that the environmental assessment process for the Chicago site is currently underway, and that a site viability decision will not occur until the environmental assessment process is completed later in 2019  According to NCA documentation we reviewed, NCA initiated the land acquisition process for the Chicago site in June 2011 and planned to complete the process by July 2018  If the fifth attempt to acquire land is not successful, then NCA will attempt—for the sixth time—to acquire land  According to NCA officials, this would result in an additional 12 to 18 months to identify and evaluate new property for potential acquisition, likely further delaying the opening of this site  See figure 4 for more details on NCA’s attempts to acquire land for the urban initiative site in Chicago  Elko, Nevada  NCA officials stated that they have identified a top- rated site for the rural initiative site in Elko, Nevada, on land currently owned by the Bureau of Land Management  However, according to NCA officials, Congress would need to enact legislation transferring this land from the Bureau of Land Management to VA before NCA could begin construction  As of June 2019, Congress had not done so  According to NCA officials, VA has opened dialogue with local officials about drafting a utility agreement for the city to construct infrastructure needed to supply water to the site  Implementation of a utility agreement would be dependent upon whether future legislation may potentially be introduced and subsequently passed authorizing the Bureau of Land Management to permanently transfer property to VA for national cemetery use  Also, according to NCA officials, once legislation has passed to allow the transfer of land from the Bureau of Land Management to VA, they estimate it will take 12 to 18 months for the land transfer to be completed  Indianapolis, Indiana  In a written response, NCA officials stated that construction for the urban initiative site in Indianapolis, Indiana, has been delayed by about a year due to a public protest of NCA’s acquisition of the site because of environmental concerns, which resulted in a land transfer with the previous landowner in January 2019  In addition, NCA had to conduct a partial project re-design for the exchanged property  According to NCA’s May 2018 plan of actions and milestones, it had expected to have acquired the land for the Indianapolis site by August 2018 and to have completed construction in December 2019  However, officials told us in September 2018 that, due to the delays in acquiring the land, NCA had revised its planned construction completion date to August 2020  Los Angeles, California  According to officials, NCA is partnering with the Veterans Health Administration, which transferred property for the proposed columbarium at the Los Angeles, California, urban initiative site  Officials stated that this project was delayed initially due to the need to remove existing encumbrances on the land (for example, leases with tenants), among other things  In July 2019, officials stated that the project is scheduled for completion in October 2019  According to NCA officials, unforeseen site conditions can also contribute to delays in cemetery construction projects  During the design phase, soil and geotechnical samples are taken but do not cover the entire site  After excavation begins, issues such as rock formations or hazardous waste not identified during the geotechnical investigation may create challenges to developing land for cemetery use  For example, in July 2019 NCA officials stated that the urban initiative site in San Francisco had encountered major geotechnical and soil issues, causing the project completion to slip to 2027  Also, according to NCA’s 2017 annual status report to Congress on new national cemeteries, the cemetery construction contract for a new cemetery construction project in Western New York could not begin solicitation until additional parcels of land had been acquired  Those parcels of land have a gas well and a gas pipeline that must be relocated  According to NCA officials, as of September 2019, six of the 11 urban and rural initiative sites had not yet begun to be excavated, and any issues that arise during the excavation process at these sites could pose further scheduling delays  NCA’s Cost Estimates for Most of Its Rural Initiative Sites Have Increased Significantly We found that NCA’s cost estimates for seven rural initiative sites have increased significantly above what NCA officials had initially estimated  In its strategy, NCA had estimated that the construction cost estimate for each of the seven rural initiative sites would be approximately $1 million (totaling approximately $7 million)  However, NCA officials told us in August 2018 that the construction cost estimates for these sites had increased to more than $3 million each (totaling almost $24 million)  This amounts to a cost increase of more than 200 percent  Further, the information they provided was not always consistent  For example, in July 2018 NCA officials provided us the average land acquisition and construction costs for the urban and rural initiatives  According to the document they provided, the average construction cost for each urban initiative cemetery is $7 5 million  However, in August 2018 NCA stated in a written response that the construction cost estimates for each of the urban initiatives ranged from approximately $9 million to more than $22 million, reflecting an average cost of $13 6 million  NCA’s cost-estimating guidance used to prepare construction cost estimates does not fully incorporate the 12 steps identified in our Cost Guide that should result in reliable and valid estimates that management can use to make informed decisions, as shown in table 2  Appendix I provides a detailed summary of our assessment of NCA’s cost-estimating guidance  Specifically, NCA’s cost-estimating guidance fully met one step, substantially met four steps, partially met four steps, minimally met two steps, and did not meet one step  For example: NCA’s cost-estimating guidance fully met the step of “obtaining the data” in that it requires a market survey that explores all factors that will affect the bid cost and collects valid and useful historical data to develop a sound cost estimate  NCA’s cost-estimating guidance substantially met the step of “updating the estimate” in that it requires cost estimates to be regularly updated  For instance, it requires an updated cost-estimating report at each stage of the design of the construction project  NCA’s cost-estimating guidance minimally met the step of “conducting a risk and uncertainty analysis” in that, while it mentions the inclusion of a risk analysis, it does not describe what a risk analysis is and how it relates to cost  Additionally, none of the guidance we reviewed contains any discussion of risk management  NCA’s cost-estimating guidance did not meet the step of “conducting a sensitivity analysis ” According to our Cost Guide, a sensitivity analysis should be included in all cost estimates because it examines the effects of changing assumptions and ground rules  Because uncertainty cannot be avoided, it is necessary to identify the cost elements that represent the most risk, and cost estimators should if possible quantify the risk  NCA uses multiple guidance documents on cost estimation and requires that managers and contractors use all of these documents in implementing their projects  Specifically, NCA uses VA’s 2011 Manual for Preparation of Cost Estimates and Related Documents for VA Facilities (Manual); VA’s 2011 Architect/Engineer (A/E) Submission Requirements for National Cemetery Projects Program Guide PG 18-15 Volume D (Guide); and NCA’s Construction Program Conceptual Estimate Worksheet  We refer to these documents collectively as “NCA’s cost- estimating guidance ” We previously reported on VA’s management of minor construction projects and made several recommendations, including that the Veterans Health Administration revise its cost-estimating guidance to incorporate the 12 steps presented in the Cost Guide, to help VA have greater assurance that its cost estimates for minor construction projects are reliable  VA concurred and stated that it would ensure that the Veterans Health Administration update its cost-estimating guidance by incorporating the 12 steps outlined in the Cost Guide, as applicable  As of August 2019, VA had not taken any action to implement this recommendation  The guidance document it plans to update, the VA Manual, is also used by NCA  Further, NCA uses additional guidance documents to develop cost estimates for its cemetery construction projects—including the urban and rural initiatives—that do not fully incorporate the 12 steps presented in the Cost Guide  Without NCA’s revising its cost-estimating guidance to more fully reflect the 12 steps in the Cost Guide, including “conducting a risk and uncertainty analysis,” NCA will not be well-positioned to provide reliable cost estimates to VA and enable it to make informed decisions regarding the management of cemetery construction projects  As noted earlier, the Grants Program is part of NCA’s plan to increase veterans’ reasonable access to burial options  According to NCA officials, their plan to meet their strategic goal of 95 percent of veterans being served by burial options relies, in part, on the state and tribal government efforts funded by the Grants Program  The Grants Program, in turn, relies on states and tribal governments applying for funding to build new cemeteries or expand existing cemeteries  An NCA official told us that NCA does not have the authority to formally request that a state seek grant funding to expand access in an unserved area  However, according to VA officials, the Grants Program has had informal discussions with states that it believes have larger concentrations of unserved veterans, in order to encourage grant applications to provide increased burial access for unserved veteran populations  When reviewing grant applications, NCA considers a number of factors, including how the grant would enhance access for unserved veterans  NCA officials stated that they use the VA’s county-level population data to identify veteran population areas unserved by national, state, or tribal government veterans’ cemeteries  This analysis also allows NCA to project where additional state and tribal government veterans’ cemeteries may be most needed  Specifically, NCA has ranked what it identified as the 40 largest currently unserved veteran population areas  NCA performs this ranking at the county level, not the more precise census tract level, although as we have previously reported it has the technical ability to use census tract data  In September 2014, we reported that NCA was using population data at the county level to identify veterans not served by burial options, and that using population data at the census tract level would enhance NCA’s management of the national cemetery program  Specifically, we recommended that NCA use its existing capabilities to estimate the served and unserved veteran populations using census tract data  This would have allowed them to make better-informed decisions concerning where to locate new national cemeteries, as well as identify which state and tribal government cemetery grant applications would provide reasonable burial access to the greatest number of veterans  However, VA did not concur with that recommendation  In its comments on our draft report, VA agreed that census tract data may yield more precise information than county-level population data, but it disagreed with our conclusion that the use of census tract data would have helped VA to make better-informed decisions regarding the location of burial options  For this review, we performed an analysis using census tract data to examine the 40 prospective sites that NCA has identified as the currently largest unserved areas, using current veteran population data  Our analysis yielded estimates for veterans in the service areas for these prospective sites that differed substantially in some instances from the numbers used by NCA (see figure 5)  For example, NCA ranked Erie, Pennsylvania, as 4th on its list of prospective sites, based on its estimate that an additional 45,154 veterans could be served by a cemetery at this location  However, using census tract data we estimate that only about 10,000 veterans could be served there, resulting in a lower priority for Erie, Pennsylvania, on this list of prospective sites  Similarly, the county- based methodology used by NCA ranked Decatur, Alabama, as 25th on the list of prospective sites, while our methodology based upon nearby census tracts placed it 2nd on the list by estimated number of veterans in the service area  Thus, even though it could serve many additional veterans, Decatur, Alabama, would not be ranked highly on the list for funding using NCA’s methodology  By using the more precise census tract data to help inform its grant- making decisions, NCA could enhance its ability to implement its plan to provide burial options to unserved veterans  Comparing estimates of unserved veterans based on current census tract data with such estimates based on current county-level data can be a useful supplement to NCA’s current reliance on long-term projected county-level population data  Comparing census tract data with county-level data could also identify areas where the county-level projections might be overridden or require additional scrutiny  This could position NCA to better identify those areas of the country that will have the most significant unserved veteran populations  Additionally, this could help NCA refine its current plans or develop new ones, as it deems appropriate  We therefore continue to maintain the validity of our 2014 recommendation for VA to use census tract data to estimate the served and unserved veteran populations to help inform its plans for providing reasonable access to burial options  By NCA’s estimates, more than 2 1 million veterans—about 10 percent of the veterans in the United States—did not have reasonable access to burial options at the end of fiscal year 2013  According to NCA, its plan had helped increase the percentage served by burial options to about 92 percent of the veteran population by the end of fiscal year 2018  However, completion of some of the urban and rural sites that are part of NCA’s plan is currently estimated to take 5 years or longer than planned at significantly higher cost, in part because construction cost estimates for the remaining sites may be unreliable  Without NCA’s revising its cost- estimating guidance to more fully reflect the 12 steps in the Cost Guide, including “conducting a risk and uncertainty analysis,” NCA will not be well-positioned to provide reliable cost estimates to VA and enable it to make informed decisions regarding the funding and oversight of NCA’s ongoing minor construction projects to enhance veterans’ burial options  The Secretary of Veterans Affairs should ensure that the Under Secretary for Memorial Affairs update its cost-estimating procedures for cemetery construction projects to fully incorporate the 12 steps identified in the GAO Cost Estimating and Assessment Guide: Best Practices for Developing and Managing Capital Program Costs  We provided a draft of this report to VA for review and comment  In written comments, VA concurred with our recommendation  VA also provided technical comments, which we incorporated as appropriate  VA’s comments are printed in their entirety in appendix II  In its technical comments, VA disagreed with our finding that NCA had made limited progress implementing its plan for increasing burial access for veterans and stated that NCA had instead made significant progress  As we note in this report, in 2014, NCA planned to open 18 new sites by the end of fiscal year 2017 to better serve the burial needs of the veteran population  However, as of September 2019, only six of the planned sites were open, with NCA years behind its original schedule  For this reason, we characterized the progress as “limited ” While the progress has been limited, it is important to note that the opening of the six sites has increased accessibility of burial options to veterans  VA also stated that it continues to disagree with our 2014 recommendation that VA use census tract data to estimate the current served and unserved veteran populations to inform its plans for providing reasonable access to burial options  In its written response, VA stated that we recommended NCA use census tract rather than county-level data  However, that is not what we recommended  As we stated in this report, comparing estimates of unserved veterans based on current census tract data with estimates based on current county-level data would provide a useful supplement to NCA’s current reliance on long-term projected county-level population data  Specifically, NCA would be better positioned to identify those areas of the country that will have the most significant unserved veteran populations and refine its current plans or develop new ones, as it deems appropriate  We are sending copies of this report to interested congressional committees and the Secretary of Veterans Affairs  In addition, the report is available at no charge on the GAO website at http://www gao gov  If you or your staff have any questions about this report, please contact me at (202) 512-9627 or maurerd@gao gov  Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report  GAO staff members who made key contributions to this report are listed in appendix III  We compared NCA’s cost-estimating guidance with the 12 steps identified in the GAO Cost Estimating and Assessment Guide: Best Practices for Developing and Managing Capital Program Costs (Cost Guide)  We found that NCA’s cost-estimating guidance on preparing cost estimates for cemetery construction projects—specifically Department of Veterans Affairs’ (VA) Manual for Preparation of Cost Estimates & Related Documents for VA Facilities (Manual), VA’s Architect/Engineer Submission Requirements for National Cemetery Projects, Program Guide 18-15 Volume D (Guide), and NCA’s Construction Program Conceptual Estimate Worksheet (Worksheet)—does not fully incorporate these 12 steps, as shown in table 3  The guidance incorporates some of the 12 steps to some degree, but not others, raising the possibility of unreliable cost estimates for NCA’s urban and rural initiatives  Specifically, NCA’s guidance on preparing cost estimates: fully or substantially met five of the 12 steps, partially met four of the 12 steps, and minimally met or did not meet three of the 12 steps  Diana Maurer, (202) 512-9627 or maurerd@gao gov  In addition to the contact named above, Brian Lepore, Director (Retired); Maria Storts, Assistant Director; Pamela Nicole Harris, Analyst-in-Charge; Brian Bothwell, Jennifer Echard, Alexandra Gonzalez, Jason Lee, Amie Lesser, Serena Lo, John Mingus, Brenda Mittelbuscher, Maria Staunton, Frank Todisco, Cheryl Weissman, and John Wren made significant contributions to this report 


Report 2:  Federal internal control standards state that management should share quality information throughout an organization to enable personnel to perform key roles, and we have previously reported that by regularly sharing useful performance information with leaders at multiple levels of an organization, agencies can help leaders make informed decisions  Without this information, individual unit commanders or the commanders’ supervisors cannot determine whether Coast Guard servicemembers under their command completed TAP or identify whether there is a need for corrective actions to ensure they do so  As we mention earlier in this report, the Coast Guard plans to adopt DOD’s TAP-IT Enterprise System, which according to officials, could help the Coast Guard ensure eligible servicemembers participate in the program  According to a Coast Guard official, once the system is fully implemented by the Coast Guard, commanders will be required to verify and document whether Coast Guard servicemembers under their command completed TAP, potentially making commanders more vested in the process  We previously reported that a senior DOD official said that the TAP-IT Enterprise System may be able to generate unit- and installation-level reports for the four DOD-led military services by October 2018, and a Coast Guard official said he would work with DOD to identify whether this capability could also extend to the Coast Guard  Once data reliability improves, sharing installation and unit-level TAP performance information with Coast Guard commanders could support monitoring efforts  The performance measures tracked by the TAP interagency working group do not reflect TAP implementation broadly across all five military services, according to a Coast Guard official we interviewed  The Coast Guard does not currently share TAP data it collects with DOD or other members of the interagency performance working group  While the benefits of interagency data sharing cannot be realized without the Coast Guard first improving the quality and completeness of its TAP data, we have identified leading practices for interagency collaboration, including that members of interagency working groups identify and share relevant agency performance data  Moreover, federal internal control standards call for management to communicate quality information to external parties  Because the Coast Guard does not share TAP data, the performance measures tracked by the interagency group do not reflect Coast Guard servicemembers’ experiences and thus do not provide a complete picture of TAP implementation across the five military services  More specifically for the Coast Guard, without such data sharing, future TAP evaluations may not be able to assess the effectiveness of TAP delivery, hindering the Coast Guard’s ability to make program adjustments to better prepare its servicemembers to successfully transition to life after military service  Coast Guard officials said migrating to DOD’s TAP-IT Enterprise System will facilitate information sharing with interagency partners and that improving data completeness and reliability is a top priority for 2018  Given the sacrifices servicemembers have made to serve their country, it is imperative they are afforded every chance to adequately prepare for civilian life before leaving military service  In order to make a successful transition, servicemembers need to be well-positioned to get a job or make an informed decision about whether to pursue additional education or start a small business  As such, the Transition Assistance Program (TAP) serves a critically important function—to give servicemembers the tools and information they need to successfully transition to life outside the military  Federal law requires that the Coast Guard ensure all eligible servicemembers participate in the program, but thousands of Coast Guard servicemembers may have transitioned without the support provided by TAP  Reliably tracking participation has proven to be a challenge for the Coast Guard, in part because it lacks a current Commandant Instruction that defines the roles and responsibilities of staff responsible for implementing TAP and ensuring complete and reliable data are collected  In preparing to issue an updated Commandant Instruction, the Coast Guard has taken a positive step toward addressing the limitations of its current TAP data, and will be better positioned to ensure compliance with VOW Act requirements using reliable data  In addition to collecting reliable data, the Coast Guard could further demonstrate its commitment to meeting TAP requirements by establishing formal performance goals that measure the extent to which Coast Guard servicemembers participate in TAP  By establishing interim performance goals, the agency would be able to show its progress towards achieving full compliance  Moreover, communicating performance goals to unit and installation commanders could enhance accountability and might spur progress toward meeting federal program requirements  By expanding its monitoring efforts beyond tracking participation in TAP’s required classes, the Coast Guard could enhance its ability to ensure other TAP requirements are met and that its servicemembers are able to access additional transition resources  Monitoring the timeliness of participation would help ensure Coast Guard servicemembers have adequate time to complete TAP before leaving the military  Further, by monitoring requests to participate in additional 2-day classes and 2-day class attendance, the Coast Guard would be in a better position to identify whether servicemembers who wish to attend the classes are able to do so, to determine whether more classes are needed, and to communicate this information to the interagency partners responsible for delivering these classes  Commanders can also play a key role in bolstering TAP participation  Having an up-to-date written Commandant Instruction that explicitly describes commanders’ roles and responsibilities could enhance commanders’ ability to ensure TAP’s proper implementation and compliance with VOW Act requirements  Moreover, once data quality improves, providing commanders a mechanism to readily determine whether servicemembers under their command have completed TAP could help them monitor the program to ensure that all TAP-eligible servicemembers receive the resources they need to successfully transition to civilian life  Finally, once more reliable data on Coast Guard servicemember participation are available, sharing this information with interagency partners could improve TAP implementation on a broader scale  Sharing reliable data, such as participation figures for the Coast Guard, would give TAP interagency partners a more complete picture of implementation across all five military services  Sharing such information would also enhance the interagency group’s ability to evaluate how well TAP serves the entire population of servicemembers  Improving the reliability of the Coast Guard’s TAP data will be essential for the benefits of data sharing to be realized  To ensure that all eligible Coast Guard servicemembers are provided the opportunity to complete the Transition Assistance Program (TAP), we recommend the Commandant of the Coast Guard take the following seven actions: Issue an updated Commandant Instruction that establishes policies and procedures to improve the reliability and completeness of TAP data by including when and by whom data should be recorded and updated  (Recommendation 1) Establish a formal performance goal with a measurable target for participation rates in VOW Act-mandated portions of TAP  (Recommendation 2) Monitor the extent to which Coast Guard servicemembers participate in TAP within prescribed time frames  (Recommendation 3) Monitor the extent to which Coast Guard servicemembers who elect to participate in additional 2-day classes are afforded the opportunity to attend  (Recommendation 4) Issue an updated Commandant Instruction that defines the roles and responsibilities of the personnel who administer the program and ensure servicemembers’ participation  (Recommendation 5) Once reliable data are available by installation or unit, enable unit commanders and the higher-level commanders to whom they report to access TAP performance information specifically for the units they oversee so that they can monitor compliance with all TAP requirements  (Recommendation 6) Once reliable data are available, share TAP information with DOD and other interagency partners, such as data on participation in required TAP courses and additional 2-day classes  (Recommendation 7) We provided a draft of this report to the Departments of Homeland Security, Defense, Education, Labor, and Veterans Affairs, the Office of Personnel Management, and the Small Business Administration for their review and comment  The formal written response of the Department of Homeland Security (DHS) is reproduced in appendix II  In addition, DHS provided technical comments from Coast Guard officials that we incorporated into the report as appropriate  The other agencies did not provide any comments  In its written comments, DHS agreed with all seven of our recommendations  If you or your staff have any questions about this report, please contact me at (202) 512-7215 or brownbarnesc@gao gov  Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report  GAO staff who made key contributions to this report are listed in appendix III  This report examines (1) what is known about the reliability of Transition Assistance Program (TAP) data on participation levels and the factors that affect Coast Guard servicemembers’ participation, and (2) the extent to which the Coast Guard measures TAP performance and monitors key areas of TAP implementation  To address these questions, we surveyed Coast Guard installations with full-time TAP operations; reviewed Coast Guard data on TAP participation for fiscal years 2012 to 2017; visited one Coast Guard installation and interviewed TAP managers from two additional Coast Guard installations selected for diversity in location, among other reasons; and interviewed Coast Guard officials responsible for overseeing TAP implementation for the Coast Guard  We also reviewed relevant federal laws, regulations, policies, documents, and publications  Information in this report is current as of the date GAO received formal agency comments from DHS  Our survey of Coast Guard installations with full-time TAP operations asked about how TAP was being implemented  The survey included questions about the accessibility of TAP components, challenges Coast Guard servicemembers faced in attending the components, and the level of commander support for participation  Our survey targeted front-line TAP managers, who could draw on the expertise of TAP course facilitators, transition counselors, career counselors, and other key TAP staff as necessary  After drafting the survey questions, we pretested them with a TAP manager to ensure (1) the questions were clear and unambiguous, (2) terminology was used correctly, (3) the survey did not place an undue burden on agency officials, (4) the information could feasibly be obtained, and (5) the survey was comprehensive and unbiased  We revised the content and format of the survey based on the feedback we received  We initially sent the survey to TAP managers at all 13 Coast Guard installations at which TAP staff were located  We removed one installation when we later found that the TAP manager position was vacant and revised the total to 12 Coast Guard installations  The survey was accessible online from October 31, 2016, through January 18, 2017, through a secure server that recipients were able to access using unique usernames and passwords  We sent an email announcement to TAP staff at all 13 Coast Guard installations at which TAP staff are located on October 24, 2016  We sent a second email on October 31, 2016 to notify participants the survey was available online, and provided their unique passwords and usernames  We sent two follow-up e-mails (November 14, 2016 and November 28, 2016) to those who had not responded  Finally, we contacted all remaining nonrespondents by telephone starting December 5, 2016  The survey was available online until we reached a 100 percent response rate  To increase our understanding into how TAP was being implemented at installations and supplement our survey findings, we visited one Coast Guard installation and interviewed TAP managers from two additional installations  We selected the installations based on several factors, including the size of the installation, proximity to Department of Defense (DOD) installations, and diverse locations in the United States  (See table 1 ) At Coast Guard Base Elizabeth City in North Carolina, the installation we visited, we interviewed the TAP manager, uniformed career counselors, and senior installation leadership  During our interviews with TAP managers at all three installations, we asked about the extent to which Coast Guard servicemembers participate in TAP’s required and additional 2-day classes, including whether the servicemembers attended classes online or in a classroom setting, challenges to ensuring Coast Guard servicemembers participate in TAP, and the extent to which they monitor Coast Guard servicemembers’ participation in TAP  At Coast Guard Base Elizabeth City, we also interviewed 25 Coast Guard servicemembers (both officers and enlisted personnel) to get their perspective on how well TAP worked and any challenges they had participating  To help guide the interviews with the Coast Guard servicemembers, we asked them to complete a short questionnaire that asked about their experiences with the TAP program  We also interviewed TAP staff at Coast Guard headquarters to learn about TAP policy, monitoring efforts, and performance measures for the service overall  For example, we asked what policies and procedures guide installations’ TAP implementation; what performance measures the Coast Guard uses to monitor TAP; how performance results are reported and shared with different levels of Coast Guard leadership; and to what extent the Coast Guard uses results from TAP participant satisfaction assessments  We also asked whether the Coast Guard plans to shift to DOD’s new TAP-IT Enterprise System and how using the new system could affect its monitoring efforts in the future  In evaluating the Coast Guard’s performance measures, we focused on measures related to servicemembers’ transition experiences before leaving the military  We did not gather information on post-program evaluations and outcomes because they were determined to be outside the scope of this review  We reviewed DHS data on TAP participation for fiscal years 2012 to 2017  To assess the reliability of the Coast Guard’s TAP participation data, we interviewed agency officials knowledgeable about the data  We determined these data were not sufficiently reliable due to limitations with the Coast Guard’s data collection system  Specifically, the system lacks adequate controls to ensure TAP data are complete and accurate  We conducted this performance audit from February 2016 to April 2018 in accordance with generally accepted government auditing standards  Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives  We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives  In addition to the contact named above, Meeta Engle (Assistant Director), Amy MacDonald (Analyst-in-Charge), James Bennett, Holly Dye, David Forgosh, Ying Long, Jonathan McMurray, Jean McSween, Andrew Sherrill, Benjamin Sinoff, and Timothy Young, made significant contributions to this report  Also contributing to this report were Susan Aschoff, Jessie Battle, Ramona Burton, Melinda Cordero, Elizabeth Curda, Dawn Hoff, Ben Licht, Serena Lo, Sheila McCoy, Almeta Spencer, Christopher Schmitt, James Whitcomb, and Jill Yost  Transitioning Veterans: DOD Needs to Improve Performance Reporting and Monitoring for the Transition Assistance Program, GAO-18-23  Washington, D C : November, 8, 2017  Transitioning Veterans: Improvements Needed in DOD’s Performance Reporting and Monitoring of the Transition Assistance Program, GAO-18-225T  Washington, D C : November 8, 2017  Department of Defense: Transition Assistance Program (TAP) for Military Personnel, GAO-16-302R  Washington, D C : December 17, 2015  Veterans’ Employment: Need for Further Workshops Should Be Considered before Making Decisions on Their Future, GAO-15-518  Washington, D C : July 16, 2015  Military and Veteran Support: DOD and VA Programs That Address the Effects of Combat and Transition to Civilian Life, GAO-15-24  Washington, D C : November 7, 2014  Veterans Affairs: Better Understanding Needed to Enhance Services to Veterans Readjusting to Civilian Life, GAO-14-676  Washington, D C : September 10, 2014  Transitioning Veterans: Improved Oversight Needed to Enhance Implementation of Transition Assistance Program, GAO-14-144  Washington, D C : March 5, 2014  Military and Veterans’ Benefits: Enhanced Services Could Improve Transition Assistance for Reserves and National Guard, GAO-05-544  Washington, D C : May 20, 2005  Military and Veterans’ Benefits: Observations on the Transition Assistance Program, GAO-02-914T (July 18, 2002) 

ground_truth: This testimony summarizes the information contained in GAO's January 2018 report, entitled Intellectual Property: Agencies Can Improve Efforts to Address Risks Posed by Changing Counterfeits Market , ( GAO-18-216 ). Changes in the market for counterfeit goods entering the United States pose new challenges for consumers, the private sector, and U.S. agencies that enforce intellectual property rights (IPR). Specifically, growth in e-commerce has contributed to a shift in the sale of counterfeit goods in the United States, with consumers increasingly purchasing goods online and counterfeiters producing a wider variety of goods that may be sold on websites alongside authentic products. For example, 20 of 47 items GAO purchased from third-party sellers on popular consumer websites were counterfeit, according to testing by the products' rights holders (see table), highlighting potential risks to consumers. The changes in the market for counterfeit goods can also pose challenges to the private sector—for example, the challenge of distinguishing counterfeit from authentic goods listed for sale online—and complicate the enforcement efforts of U.S. Customs and Border Protection (CBP) and U.S. Immigration and Customs Enforcement (ICE). CBP and ICE engage in a number of activities to enhance IPR enforcement; however, while ICE has assessed some of its efforts, CBP has taken limited steps to do so. CBP's and ICE's IPR enforcement activities broadly include detecting imports of potentially IPR-infringing goods, conducting special operations at U.S. ports, engaging with international partners, and undertaking localized pilot programs or port-led initiatives. CBP and ICE have collected some performance data for each of the eight activities GAO reviewed, and ICE has taken some steps to understand the impact of its efforts. However, CBP has conducted limited evaluation of its efforts to enhance IPR enforcement. Consequently, CBP may lack information needed to ensure it is investing its resources in the most efficient and effective activities. CBP and ICE generally collaborate on IPR enforcement, but according to private sector representatives, restrictions on CBP's information sharing limit private sector enforcement efforts. GAO found that CBP and ICE have undertaken efforts that align with selected key practices for interagency collaboration, such as participating in developing a national IPR enforcement strategy and agreeing on roles and responsibilities. However, sharing additional information about seized items with rights-holding companies and e-commerce websites could improve enforcement, according to private sector representatives. CBP officials said they share information to the extent allowed under current regulations, but CBP has not completed an assessment of what, if any, additional information would be beneficial to share with private sector entities. Without such an assessment, CBP will not know if sharing additional information requires regulatory or legal changes.