CUSTOMS SERVICE

Information on the

Design of the SelfInspection Program

United States General Accounting Office

GAO Report to Congressional Committees

June 2000

GAO/GGD-00-151

United States General Accounting Office General Government Division

Washington, D.C. 20548

Page 1 GAO/GGD-00-151 Customs Self-Inspection Program Design

B-284954

June 23, 2000

The Honorable William V. Roth Jr.

Chairman

Committee on Finance

United States Senate

The Honorable Bill Archer

Chairman

Committee on Ways and Means

House of Representatives

The Honorable Philip M. Crane

Chairman

Subcommittee on Trade

Committee on Ways and Means

House of Representatives

The Commissioner, U.S. Customs Service, testified before the Senate

Finance Committee in May 1999 that he had made significant changes to

the Customs Service in an effort to improve employees’ performance and

accountability. Among these changes was the institution of a SelfInspection Program (SIP) whereby managers are to self-assess how well

their areas were carrying out their responsibilities.

In your October 12, 1999, letter, you requested that we review the design

and implementation of Customs’ SIP. As agreed with your offices, we are

addressing these issues in two reports. This report discusses (1) SIP’s

principal features, (2) the basis for Customs’ design for SIP, (3) how SIP

differs from Customs’ previous management inspection program, and (4)

SIP design issues identified by Customs to date and what Customs is doing

to respond to them.

Our work on the second issue—program implementation—will begin

during summer 2000, after Customs has had a full year to implement and

analyze the program.

Customs’ SIP provides a mechanism for management oversight of

programs and processes that is intended to build accountability and foster

integrity throughout the Customs Service. Under SIP, all Customs

supervisors and managers are responsible for conducting a self-inspection

Results in Brief
 B-284954

Page 2 GAO/GGD-00-151 Customs Self-Inspection Program Design

every 6 months of the activities they oversee, using uniform self-inspection

worksheets that are designed to evaluate financial vulnerability and

corruption, mission performance and resource utilization, and

internal/external relationships. Any worksheet that identifies an area in

need of improvement must also include an addendum stating the

corrective actions to be taken and the time frame for taking them.

In designing SIP, Customs reviewed literature on program design and

contacted several organizations to learn about their programs. From this

research, specific features were selected that the program director thought

could work within the Customs environment. These features, which were

endorsed by the Commissioner and the executive staff, included

• ownership of the program at all levels,

• scope that covers operational and administrative areas,

• use of an independent body to validate self-assessments,

• use of uniform worksheets that contain questions about essential control

points for managers,

• funneling of results up the chain of command, and

• performance of self-inspections according to a set schedule.

Under Customs’ previous management inspection program, Management

Inspections Division (MID) personnel were to perform comprehensive

reviews of each administrative and operational area of an activity (e.g.,

port of entry) about once every 5 years. These reviews took MID about 2

to 3 weeks to complete at each location. Under SIP, all supervisors and

managers are to inspect, assess, and monitor their own activities every 6

months, with MID providing independent verification and validation on a 2-

year cycle. MID’s independent verification and validation reviews are to

be less comprehensive than those performed formerly and are expected to

take about 5 days compared with 2 or 3 weeks. MID is to send a follow-up

memorandum between 6 months to a year after the inspection requesting

information on the status of any corrective actions.

Based on the first SIP cycle, a major program design problem identified by

Customs consisted of worksheet questions and directions that were often

perceived by users to be subjective, unclear, and confusing. To address

these and other issues, Customs revised the worksheets to include (1)

specific directions about who should complete them, (2) detailed sampling

methodology and instructions, (3) citations to references for most

questions, and (4) reworded questions designed to be more specific and

less confusing.
 B-284954

Page 3 GAO/GGD-00-151 Customs Self-Inspection Program Design

Two other program design issues have emerged. The first issue, identified

by Customs, involves the lack of an automated system to analyze SIP

results. Without an automated system, which is under development,

Customs has had difficulty manually tracking voluminous SIP results to

identify national trends or to track whether corrective actions have been

taken. The second issue, noted in our review, involves the degree of

discretion allowed for offices to perform their self-inspections. A 6-month

interval was expected to be the standard with some discretion allowed.

The Assistant Commissioner for the Office of Field Operations (OFO)–the

largest Customs office--decided to exercise this discretion by completing

half the self-inspection worksheets every 6 months so that each worksheet

will be completed on a yearly basis. Although a deviation from the original

plan, a yearly self-inspection cycle is similar to those used by other

organizations we looked at.

It remains to be seen what effect these developments will have on the

program’s ability to promptly identify and resolve problems. We plan to

follow up on these issues in our second report.

The U.S. Customs Service has a diverse mission spanning a large

geographic area. Customs’ responsibilities include (1) collecting revenue

from imports and enforcing Customs and other U.S. laws and regulations;

(2) preventing the smuggling of drugs into the country; and (3) overseeing

export compliance and money-laundering issues. Customs’ workforce

totals almost 20,000 employees at its headquarters, 20 Customs

Management Centers (CMC), 20 Special Agent-in-Charge (SAIC) offices,

301 U.S. ports of entry, 5 strategic trade centers, and over 25 international

offices.

Because of Customs’ diverse responsibilities and geographic dispersion,

the Commissioner wanted a new program that placed the primary

responsibility for reviewing operations and identifying corrective actions

on the supervisors and managers overseeing the activities. In addition, the

Commissioner wanted MID to independently verify and validate the selfinspections and to increase its assessment frequency from about every 5

years to about every 2 years.

To identify (1) the principal features of Customs’ SIP, (2) how SIP differs

from Customs’ previous management inspection program, and (3) SIP

design issues identified by Customs to date and what Customs is doing to

respond to them, we interviewed officials from several Customs activities,

including MID, which oversees SIP and is within the Office of Internal

Affairs. In addition to MID, we interviewed officials from OFO and the

Background

Scope and

Methodology
 B-284954

Page 4 GAO/GGD-00-151 Customs Self-Inspection Program Design

Office of Investigations because these are geographically dispersed

components with the responsibility for completing a large number of selfinspection worksheets. We also reviewed relevant agency documents,

including reports from Customs’ previous management inspection

program.

To obtain information on the basis for Customs’ design for SIP, we

contacted officials from the organizations that Customs used as models—

the Drug Enforcement Administration (DEA), New York Police

Department (NYPD), and Xerox’s North American Services Group. We

also contacted officials from Motorola.1

 In addition, we analyzed how

Customs’ program compares and contrasts with these organizations’ selfinspection programs.

Our work was performed at Customs’ headquarters in Washington, D.C.,

and at field offices in the Los Angeles and New York areas. We performed

our work between October 1999 and May 2000 in accordance with

generally accepted government auditing standards. We requested

comments on a draft of this report from the Customs Commissioner or his

designees. Customs’ written comments are discussed near the end of this

letter and reprinted in appendix III.

Customs’ SIP provides a mechanism for management oversight of

programs and processes, to build accountability and to foster integrity

throughout the Customs Service. As its name denotes, SIP emphasizes

self-assessment, rather than an assessment performed by a different

Customs’ component. Under SIP, every supervisor and manager in

Customs is responsible for conducting a self-inspection of the activities

they oversee, using uniform core area self-inspection worksheets to

evaluate each major area. The intent of the worksheet is to identify the

key internal control points for evaluation in a particular program or

process. The worksheets allow supervisors and managers to assess their

mission/program accomplishments while helping them to better define

their priorities and identify areas needing improvement. The focus is to be

on

• financial vulnerability and corruption,

• mission performance and resource utilization, and

• internal/external relationships.

 1

 While Customs did not use Motorola’s self-inspection program as a model, we contacted it because

Motorola testified about its self-inspection program before the Senate Finance Committee during the

spring of 1999.

Principal Features of

SIP
 B-284954

Page 5 GAO/GGD-00-151 Customs Self-Inspection Program Design

There are two categories of self-inspection worksheets: universal and

operational. Universal worksheets pertain to all Customs’ offices and

contain questions about administrative areas such as labor and employee

relations, including sick-leave usage within the activity (see app. I). Every

Customs activity (e.g., port of entry) is responsible for completing the

universal worksheets. Operational worksheets contain questions about

controls over specific activities. For example, SAIC offices would

complete a worksheet on the handling of seized currency (see app. II).

Customs’ activities are to conduct self-inspections every 6 months, which

are referred to as self-inspection cycles. During the self-inspection cycles,

supervisors and managers are to complete worksheets for all areas and

activities under their control. This involves assessing their operations and

answering questions on the worksheets as “yes,” “no,” or “N/A” (not

initially defined, but subsequently changed to “No Activity” and “Never

Applies”). They are to then rate their areas of responsibility as either

“acceptable” or “needs improvement.”

During the first SIP cycle (covering the period of October 1998 to March

1999), any question on a worksheet that had a “no” response was to be

automatically rated on the worksheet as “needs improvement.” Any

worksheet that had a “needs improvement” rating was required to include

an addendum stating the corrective actions to be taken and the time frame

for taking them.

Self-inspection results are to be funneled up the chain of command. For

example, ports of entry are to send results to the CMC, which in turn is to

send results to the cognizant assistant commissioner. The assistant

commissioners are to report to MID ensuring that self-inspection

worksheets have been completed, are accurate, and have been analyzed;

key issues have been identified; corrective actions have been determined;

and time frames for completion of corrective actions have been

established.

MID is responsible for overseeing SIP, overseeing the development of the

worksheets, and managing the program. MID is also responsible for

publicizing the program implementation strategy and developing the

marketing plan. In addition, MID is to conduct independent verifications

and validations of the completed self-inspection worksheets to ensure that

they are correct and accurate. MID has developed a schedule to verify and

validate a portion of each major Customs activity every 2 years and plans

to analyze areas needing improvement in order to identify trends.
 B-284954

Page 6 GAO/GGD-00-151 Customs Self-Inspection Program Design

MID is to brief the Commissioner on the findings of its analysis. A report

is then to be issued and distributed throughout Customs detailing the

results of the self-inspections. MID is to conduct a follow-up 6 months to a

year after the inspections to ascertain whether corrective actions have

been taken.

Customs officials used two steps in designing the self-inspection program.

First, MID officials searched for and reviewed literature on program

design. MID relied heavily on a book entitled Control Self-Assessment:

Making the Choice2 by Glenda Jordan and published by the Institute of

Internal Auditors for guidance on self-inspection program features and

parameters.

Second, Customs contacted several organizations to learn about their

programs. During 2 weeks in the fall of 1998, MID contacted 22

organizations: 17 public; 5 private. Of the 15 organizations that responded,

5 had self-inspection programs: DEA, NYPD, Trans-Maritime

Administration, the U.S. Army, and Xerox’s North American Services

Group. MID officials visited three of these organizations that they thought

had established viable programs to learn more about them: DEA, NYPD,

and Xerox.

According to the MID Director, SIP incorporated the features from the

literature and these programs that would work within Customs’

environment and were endorsed by the Commissioner and the executive

staff. The features borrowed from DEA’s, NYPD’s, and Xerox’s selfinspection programs were

• ownership at all levels,

• scope that covers operational and administrative areas, and

• use of independent body doing checking.

In addition, Customs incorporated the following features from the DEA

and Xerox programs:

• uniform worksheets,

• self-inspection results to be funneled up the chain of command, and

• self-inspections to be conducted according to a set schedule.

Customs’ design was somewhat different from NYPD’s program design,

however. It also differed from Motorola’s program design, which Customs

 

2

 Control Self-Assessment: Making the Choice, Glenda S. Jordan, Institute of Internal Auditors, 1995.

SIP Design and How It

Compares With Other

Self-inspection

Programs
 B-284954

Page 7 GAO/GGD-00-151 Customs Self-Inspection Program Design

did not consider but which we reviewed for comparison purposes. As

shown in table 1, one difference was that NYPD and Motorola allowed

their activities (e.g., NYPD police precinct and Motorola’s accounts

payable department) to develop their own self-inspection worksheets

instead of requiring uniform worksheets for all activities.

Description Customs DEA NYPD Xerox Motorola

Year self-inspection

program started 1999 1994 mid-1980s 1993 1979

Uniform worksheets? Yes Yes No Yes No

Are results sent up the

chain of command? Yes Yes No Yes No

Who conducts selfinspection?

Lowest-level

supervisor or manager

who oversees the

activity Assistant SAIC

Lowest-level

supervisor or manager

who oversees the

activity

First-line manager of

the process

Determined by each

activity

Are self-inspections

done on a set

schedule? Yes, every 6 months Yes, every year No Yes, every year Yes, every year

How often verified and

validated by outside

entity?

Partial review every 2

years Every 2 years

Partial review every 3

months Every 3-4 years Every 3 to 5 years

Are inspection visits

announced in

advance? Yesa Yes No Yes, 2-week notice Yes

a

MID has the authority to do unannounced inspections but has done so on five occasions and only

regarding the seized property program.

Source: GAO analysis of Customs’ and other organizations’ data.

SIP differs from Customs’ previous management inspection program.

Prior to SIP, the program involved an Office of Finance component and a

MID component. Under the Office of Finance component, managers were

to use checklists to assess their own internal controls, but these checklists

were not widely implemented, according to Customs officials. Under the

MID component, MID personnel were to visit an activity, such as a SAIC

office, about once every 5 years to perform a comprehensive review that

was to examine administrative and operational aspects of the activity. For

example, a comprehensive review of a SAIC office was to include mission

performance, resource utilization, general management, internal/external

relationships, case management, source development, undercover

operations, and other areas. In addition, MID was to inspect these areas at

all the Resident Agent in Charge offices that reported to the SAIC.

According to the MID Director, these comprehensive reviews could take

about 2 to 3 weeks to perform.

Table 1: How Customs’ SIP Compared With Other Self-Inspection Programs

Comparison of SIP

With MID’s Previous

Inspection Program
 B-284954

Page 8 GAO/GGD-00-151 Customs Self-Inspection Program Design

In addition to these comprehensive reviews, MID also performed spotchecks that focused on limited areas, such as controls over the imprest

fund. Follow-up reviews were generally conducted 1 to 2 years after

comprehensive reviews were performed to determine whether corrective

actions had been taken.

Under SIP, the responsibility for reviewing the activities and identifying

corrective actions was placed on the supervisors and managers

themselves. These individuals are to use uniform self-inspection

worksheets to inspect, assess, and monitor their activities. MID is to visit

major activity locations at least every 2 years, for about 5 days, to verify

and validate the self-inspection worksheet results. MID is to send a followup memo between 6 months to a year after the inspection to get a status of

corrective actions under way. While MID is to visit every major activity

location more frequently than under the previous program, it does not plan

to visit every subordinate location. However, MID plans to review the

reports for those locations it does not visit. For example, under the CMC

Tucson, AZ, are the Ports of San Luis and Lukeville. MID visited the CMC

Tucson and the Port of San Luis but did not visit the Port of Lukeville.

However, according to MID officials, they did conduct a document review

of the Port of Lukeville, which consisted of obtaining and reviewing the

self-inspection worksheets.

After the first SIP cycle, according to the MID Director, its visits consisted

of reviewing worksheets, verifying self-inspections, and providing

feedback on how well self-inspections were performed. After the second

SIP cycle (covering April 1999 to December 1999), MID’s focus shifted to

moving beyond mostly verifying what managers and supervisors did to

actually conducting additional review work on its own. MID reviewers had

the option of adding interviews and surveys of employees working at the

activities under review and were also to conduct an in-depth review of a

selected number of core areas. In addition to the mandatory core areas,

each inspection team can, at their discretion, review additional core areas.

These additional core areas may be suggestions from administrative

program areas, requests from local and headquarters management, or

random selections from MID. The reviews were also to include

assessments of resource utilization and internal and external relations and

were also slated to last 5 days.

According to MID and other Customs officials, a major design issue with

the first SIP cycle was that worksheets were perceived to have subjective,

unclear, and confusing questions or directions. For example, a question on

the imprest fund worksheet asked, “Are prohibited items being

Customs Is Addressing

Design Issues
 B-284954

Page 9 GAO/GGD-00-151 Customs Self-Inspection Program Design

purchased?” The directions on the worksheet instructed that a “no”

response had to have an addendum attached stating what corrective

actions would be taken and the time frames for taking them. In addition, a

“no” response would immediately give the imprest fund worksheet a

“needs improvement” rating. However, in this case, the desirable answer

was a “no” response. In addition to the unclear questions, other issues

with the worksheets Customs identified included unspecified sampling

methodologies and a lack of criteria, such as applicable regulations.

MID extended the second SIP cycle by 3 months to allow time to revise the

worksheets. The new worksheets contain many changes, including

directions on who should complete the worksheet, methodology

instructions (e.g., specifying what size sample to take and how to take it),

citations to references for most questions, and reworded questions

designed to be more specific and less confusing. For example, the above

“prohibited item” question was reworded as, “Are only allowable items

purchased?”

Another design issue was that the worksheet ratings were not meaningful.

During the first SIP cycle, MID directed that a single “no” answer on a

worksheet would result in a “needs improvement” rating for the entire

worksheet. This resulted in officials being unable to determine whether a

“needs improvement” in an area indicated a major problem or a minor

issue. To make the ratings more meaningful, MID developed a “qualified”

acceptable rating. If a top-level manager, such as a port director,

determined that a “needs improvement” rating is for minor issues, he/she

could amend that rating to a “qualified” acceptable rating. However, the

official must explain the reasoning for overriding the original rating.

Customs CMC and SAIC officials we spoke with stated that the second SIP

cycle was much easier to implement and less burdensome. They stated

that the worksheet questions were much easier to understand and answer

and that they liked the “qualified” acceptable rating. However, several of

these officials stated that some of these questions could still be improved.

Two other program design issues have emerged. The first issue, identified

by Customs, involves the lack of an automated system to analyze SIP

results. The second issue, noted in our review, involves the degree of

discretion allowed for offices to perform their self-inspections.

Without an automated system, which is under development, it has been

difficult for Customs officials to manually track self-inspection results to

identify national trends or to track whether corrective actions have been
 B-284954

Page 10 GAO/GGD-00-151 Customs Self-Inspection Program Design

taken. According to MID and OFO officials, the results from the first SIP

cycle resulted in a large amount of data, which made manual analysis

difficult.

MID is currently working on an automated system called the SelfInspection Reporting System (SIRS) that should make it easier to analyze

data and track corrective actions. According to the MID Director, portions

of SIRS should be operational by Summer 2000, including automating the

worksheet questions. By January 2001, supervisors and managers should

be able to input the worksheet data directly into SIRS. The Customs Office

of Information and Technology officials responsible for developing SIRS

stated that it would not be fully operational until about December 2001.

The component that will take the additional time is intended to allow MID

staff to compare SIP data with MID’s inspection data to track whether

corrective actions have been taken. In the meantime, OFO—the largest

Customs office—has developed an Excel spreadsheet that may be used to

record and analyze self-inspection results.

During the second SIP cycle the OFO Assistant Commissioner decided that

it was too cumbersome for each of his activities to complete all of the

worksheets every 6 months. The Assistant Commissioner developed a

schedule so that about half the worksheets would be completed every 6

months so that each worksheet would be completed yearly, rather than

every 6 months. Although a deviation from the original plan, a yearly selfinspection cycle is similar to those used by other organizations we looked

at.

According to the MID Director, the program can permit this discretion.

The Director stated that assistant commissioners are ultimately held

accountable for the performance of the self-inspections of their activities,

so they were given the latitude to make the worksheets—and consequently

the self-inspections themselves—mandatory or discretionary. South

Pacific and New York CMC—activities within OFO—officials we spoke

with after the second SIP cycle stated that it was less disruptive to their

operations to complete fewer worksheets. As of April 2000, other major

Customs offices besides OFO (e.g., Office of Investigations, Internal

Affairs, Strategic Trade), had completed all of their worksheets for the

second SIP cycle, according to the MID Director.

It remains to be seen what effects these developments will have on the

program’s ability to promptly identify and resolve problems. MID officials

noted that SIP is a program under continuous change and improvement
 B-284954

Page 11 GAO/GGD-00-151 Customs Self-Inspection Program Design

and that such developments described above are and will continue to be

necessary. We plan to follow up on these issues in our second report.

We requested comments on a draft of this report from the Commissioner

of Customs or his designee. On May 31, 2000, the Director, Office of

Planning, provided us with written comments, which are reprinted in

appendix III. The Director said that most of Customs’ concerns had been

addressed through discussions with our audit team during the assignment.

His letter also provided additional perspective on the progress of the

program.

As agreed with your offices, unless you publicly announce its contents

earlier, we plan no additional distribution of this report until 10 days from

its issue date. At that time, we will send copies of this report to Senator

Daniel Patrick Moynihan, Ranking Minority Member of the Committee on

Finance; Representative Charles Rangel, Ranking Minority Member of the

Ways and Means Committee; and Representative Sander Levin, Ranking

Minority Member of the Ways and Means Subcommittee on Trade. In

addition, we are providing copies to the Honorable Lawrence Summers,

the Secretary of the Treasury; the Honorable Raymond W. Kelly, the

Commissioner of Customs; and other interested parties. Copies of this

report also will be made available to others upon request.

The major contributors to this report are acknowledged in appendix IV. If

you or your staff have any questions about the information in this report,

please contact me on (202) 512-8777 or Darryl Dutton, Assistant Director,

on (213) 830-1000.

Richard M. Stana

Associate Director, Administration

of Justice Issues

Agency Comments
Page 12 GAO/GGD-00-151 Customs Self-Inspection Program Design

Contents

1 Letter

Appendix I 14

Example of an

Universal Worksheet

Appendix II 18

Example of an

Operational Worksheet

Appendix III 22

Comments From the

Customs Service

Appendix IV 24

GAO Contacts and

Staff

Acknowledgments

Table 1: How Customs’ SIP Compared With Other SelfInspection Programs7 Tables

Abbreviations

CMC Customs Management Center

DEA Drug Enforcement Administration

MID Management Inspections Division

NYPD New York Police Department

OFO Office of Field Operations

SAIC Special Agent-in-Charge

SIP Self-Inspection Program

SIRS Self-Inspection Reporting System
Page 13 GAO/GGD-00-151 Customs Self-Inspection Program Design
Appendix I

Example of an Universal Worksheet

Page 14 GAO/GGD-00-151 Customs Self-Inspection Program Design
Appendix I

Example of an Universal Worksheet

Page 15 GAO/GGD-00-151 Customs Self-Inspection Program Design
Appendix I

Example of an Universal Worksheet

Page 16 GAO/GGD-00-151 Customs Self-Inspection Program Design
Appendix I

Example of an Universal Worksheet

Page 17 GAO/GGD-00-151 Customs Self-Inspection Program Design
Appendix II

Example of an Operational Worksheet

Page 18 GAO/GGD-00-151 Customs Self-Inspection Program Design
Appendix II

Example of an Operational Worksheet

Page 19 GAO/GGD-00-151 Customs Self-Inspection Program Design
Appendix II

Example of an Operational Worksheet

Page 20 GAO/GGD-00-151 Customs Self-Inspection Program Design
Appendix II

Example of an Operational Worksheet

Page 21 GAO/GGD-00-151 Customs Self-Inspection Program Design
Appendix III

Comments From the Customs Service

Page 22 GAO/GGD-00-151 Customs Self-Inspection Program Design
Appendix III

Comments From the Customs Service

Page 23 GAO/GGD-00-151 Customs Self-Inspection Program Design
Appendix IV

GAO Contacts and Staff Acknowledgments

Page 24 GAO/GGD-00-151 Customs Self-Inspection Program Design

Richard M. Stana, (202) 512-8777

Darryl W. Dutton, (213) 830-1000

Samuel S. Van Wagner

Cheryl L. Gordon

GAO Contacts

Acknowledgments
Page 25 GAO/GGD-00-151 Customs Self-Inspection Program Design
Page 26 GAO/GGD-00-151 Customs Self-Inspection Program Design
Page 27 GAO/GGD-00-151 Customs Self-Inspection Program Design
Ordering Copies of GAO Reports

The first copy of each GAO report and testimony is free.

Additional copies are $2 each. Orders should be sent to the

following address, accompanied by a check or money order made

out to the Superintendent of Documents, when necessary. VISA

and MasterCard credit cards are accepted, also. Orders for 100 or

more copies to be mailed to a single address are discounted 25

percent.

Order by mail:

U.S. General Accounting Office

P.O. Box 37050

Washington, DC 20013

or visit:

Room 1100

700 4th St. NW (corner of 4th and G Sts. NW)

U.S. General Accounting Office

Washington, DC

Orders may also be placed by calling (202) 512-6000 or by using

fax number (202) 512-6061, or TDD (202) 512-2537.

Each day, GAO issues a list of newly available reports and

testimony. To receive facsimile copies of the daily list or any list

from the past 30 days, please call (202) 512-6000 using a touchtone phone. A recorded menu will provide information on how to

obtain these lists.

Viewing GAO Reports on the Internet

For information on how to access GAO reports on the INTERNET,

send e-mail message with “info” in the body to:

info@www.gao.gov

or visit GAO’s World Wide Web Home Page at:

http://www.gao.gov

Reporting Fraud, Waste, and Abuse in Federal Programs

To contact GAO FraudNET use:

Web site: http://www.gao.gov/fraudnet/fraudnet.htm

E-Mail: fraudnet@gao.gov

Telephone: 1-800-424-5454 (automated answering system)

United States

General Accounting Office

Washington, D.C. 20548-0001

Official Business

Penalty for Private Use $300

Address Correction Requested

Bulk Rate

Postage & Fees Paid

GAO

Permit No. G100

(264457)