Statement for the Record for the 

Subcommittee on Veteran’s Affairs, 

Housing and Urban Development, and 

Independent Agencies, Committee on 

Appropriations, U.S. Senate 

United States General Accounting Office 

GAO

For Release on Delivery 

Expected at 10:00 a.m. EDT 

Thursday, April 10, 2003 CORPORATION FOR 

NATIONAL AND 

COMMUNITY SERVICE 

Preliminary Observations 

on the National Service 

Trust And AmeriCorps 

Statement for the Record by Cornelia M. Ashby, Director, 

Education, Workforce and Income Security Issues, and 

Susan A. Poling, Associate General Counsel 

GAO-03-642T 
As shown in the figure below, the number of participants enrolled in 

AmeriCorps increased by about 20,000 from program year 1998 to program 

year 2001. However, the number of AmeriCorps participants was not 

reconciled with the number of education awards that the National Service 

Trust could support. 

GAO identified several factors that led the Corporation to suspend 

enrollments. The factors included inappropriate obligation practices, little 

or no communication among key Corporation executives, too much 

flexibility given to grantees regarding enrollments, and unreliable data on the 

number of AmeriCorps participants. 

The Corporation has established new policies that may improve the overall 

management of the National Service Trust if the policies are fully 

implemented. However, the Corporation has not made policy changes to 

correct a key factor—how it obligates funds for education awards. 

Note: Participants shown are for AmeriCorps*State and National programs only. Participants for 

AmeriCorps*National Civilian Community Corps and its VISTA programs are not included. Data for 

program years 1998 through 2001 represents actual participants. Program year 2002 data represent 

awarded positions. Program year varies by grantee.

CORPORATION FOR NATIONAL AND 

COMMUNITY SERVICE 

Preliminary Observations on the National 

Service Trust and AmeriCorps 

www.gao.gov/cgi-bin/getrpt?GAO-03-642T.

To view the full report, including the scope 

and methodology, click on the link above. 

For more information, contact Cornelia M. 

Ashby at (202) 512-8403 (ashbyc@gao.gov) 

or Susan A. Poling at 202-512-2667 

Highlights of GAO-03-642T, statement for 

the record for the Chairman, 

Subcommittee on VA, HUD, and 

Independent Agencies, Committee on 

Appropriations, U.S. Senate 

April 10, 2003 

In November 2002, the Corporation 

for National and Community 

Service suspended enrollments in 

the AmeriCorps program due to 

concern that the National Service 

Trust may not contain enough 

funds to meet the education award 

obligations resulting from 

AmeriCorps enrollments. This 

testimony reflects GAO’s 

preliminary review of the factors 

that contributed to the need to 

suspend enrollments and GAO’s 

preliminary assessment of the 

Corporation’s proposed changes 
Page 1 GAO-03-642T 

Mr. Chairman and Members of the Subcommittee: 

We are pleased to have the opportunity to comment on the preliminary 

findings from our ongoing study of the Corporation for National and 

Community Service’s (the Corporation) management and oversight of the 

National Service Trust (the Trust). The National Service Trust is a 

dedicated fund within the Corporation that is to maintain sufficient funds 

to pay national service educational awards to participants in the 

Corporation’s AmeriCorps program. In November 2002, AmeriCorps 

suspended enrollment of program participants. This statement will identify 

some of the factors that contributed to this suspension and related policy 

changes the Corporation has made since then. 

These comments are primarily based on our preliminary analysis of 

documents and information obtained through interviews with Corporation 

staff. In addition, this statement reflects the April 9, 2003, opinion we 

provided the Committee concluding that the Corporation incurs an 

obligation for education benefits when it enters into a grant agreement for 

the approved number of new participants and therefore it must record the 

obligation against the budget authority available in the Trust. See appendix 

I for the opinion. In summary, the factors we identified, to date, that led 

the Corporation to suspend enrollments include inappropriate practices 

for obligating funds, little or no communication among key Corporation 

executives, and too much flexibility given to grantees—they were allowed 

to adjust authorized positions and were not required to provide timely 

information about the number of participants. While the Corporation has 

established new policies that may improve the overall management of 

AmeriCorps if the policies are fully implemented, the Corporation has not 

made policy changes to correct a key factor—how it obligates funds. 

The Corporation for National and Community Service was created to help 

meet community needs in education, the environment, and public safety 

and to expand educational opportunity by rewarding individuals who 

participate in national service1

. The Corporation is part of USA Freedom 

Corps, a White House initiative to foster a culture of citizenship, service, 

and responsibility and help all Americans answer the President’s call to 

service. The Corporation receives appropriations to fund program 

operations and the National Service Trust. The Corporation makes grants 

 1

The National and Community Service Act of 1990 created the Corporation. 

Background 
Page 2 GAO-03-642T 

from its program appropriations to help grant recipients carry out national 

service programs. 

AmeriCorps is one of three national service programs the Corporation 

oversees.2

 Most of the grant funding from the Corporation for AmeriCorps 

programs goes to state service commissions, which award subgrants to 

nonprofit groups and agencies that enroll the AmeriCorps’ participants. 

Participants in the AmeriCorps program can receive a stipend as well as 

health benefits and childcare coverage. For example, about one-half of 

AmeriCorps’ participants received an annual living allowance of $9,300 

and health benefits. Those participants who successfully complete a 

required term of service earn an education award that can be used to pay 

for undergraduate school, or graduate school, or to pay back qualified 

student loans. In exchange for a term of service, full-time AmeriCorps 

participants earned an education award of $4,725 in program year 2002. 

Participants have up to 7 years from the date of completion of service to 

use the education award. AmeriCorps also enrolls participants on a parttime basis and as “education awards only” participants. Part-time 

participants who serve 900 or fewer hours annually earn education awards 

proportional to those earned by full-time participants. Under the 

“education awards only” program, AmeriCorps does not pay the 

participant a living allowance or other benefits, but provides grant funding 

for administrative purposes only, about $400 per full-time participant 

annually. However, each participant receives an education award 

equivalent to that earned by a paid AmeriCorps participant. The number of 

AmeriCorps participants increased by nearly 20,000 from 1998 to 2001. The 

program year 2002 data indicate the number of positions awarded will 

decrease by about 8,000. (See figure 1.) 

 2

The Corporation oversees the Senior Corps, AmeriCorps, and Learn and Serve America. 

AmeriCorps consists of three programs: AmeriCorps*State and National, 

AmeriCorps*VISTA, and AmeriCorps*National Civilian Community Corps. 
Page 3 GAO-03-642T 

Figure 1. AmeriCorps Participants from 1998 to 2002 

Note: Participants shown are for AmeriCorps*State and National programs only. Participants for 

AmeriCorps*National Civilian Community Corps and its VISTA programs are not included. Data for 

program years 1998 through 2001 represents actual participants. Program year 2002 data represent 

awarded positions. Program year varies by grantee. 

In November 2002, the Corporation suspended enrollments in AmeriCorps 

because total enrollments were potentially higher than the Corporation 

had expected. No new funds had been requested by and appropriated to 

the Trust for fiscal year 2002, and under the continuing resolution at the 

start of fiscal year 2003, no new funds would be deposited into the Trust 

until the Corporation’s fiscal year 2003 appropriations were enacted. The 

Corporation concluded that if its grantees and subgrantees were to fully 

enroll new participants up to the maximum number of enrollments the 

Corporation had approved in its grants, the Trust would not have a 

sufficient amount to provide the educational awards to those participants. 

Enrollments in AmeriCorps were frozen from November 2002 through 

March 2003. 
Page 4 GAO-03-642T 

Three factors contributed to the Corporation’s need to suspend 

enrollments in AmeriCorps. Although the Corporation specified the 

maximum number of new participants in the grants it awarded, the 

Corporation did not recognize its obligation to fund participant education 

awards until it actually paid the benefits. Had the Corporation properly 

tracked and recorded its obligations in the Trust at the time of grant award 

when it approved new enrollments, it likely would not have needed to 

suspend enrollments. In addition, there was little, if any, communication 

among the AmeriCorps program office, the grants management office, and 

the Trust about the number of positions that the Trust could support. 

Furthermore, by allowing grantees various flexibilities and not requiring 

them to provide timely enrollment information, the Corporation and 

AmeriCorps managers could not be certain about the number of 

participants. 

The Corporation did not appropriately record or track its obligations for 

education awards to program participants. Generally, an agency incurs an 

obligation for the amount of the grant award with the execution of a grant 

agreement. The Corporation enters into grant agreements with state 

service commissions in which it specifies the budget and project period of 

the award, the total number of positions approved, the total amount 

awarded for program costs for the approved positions, and the terms of 

acceptance. The award for the program costs is used to pay participants’ 

stipends and health and child care coverage. The Corporation incurs an 

obligation for these program costs at the time of grant award.3

 While the 

costs of education awards for the new participants are not specified in the 

grants, in the grant agreements the Corporation commits to funding 

education awards for all of the qualified positions initially approved in a 

grant if the subgrantee enrolls all of the participants before the 

Corporation modifies the terms or conditions of the grant. In other words, 

upon award of the grant, the Corporation, at a minimum, has accepted “[a] 

legal duty ... which could mature into a legal liability by virtue of actions 

on the part of the other party beyond the control of the United States.” 

However, the Corporation has concluded that it is not necessary to 

obligate funds until an individual actually enrolls in AmeriCorps. 

Therefore, the Corporation recorded education award obligations on an 

 3

We have not examined and accordingly express no opinion on whether the Corporation is 

appropriately obligating program costs in the applicable appropriation account. 

Three Factors 

Contributed to the 

Need to Suspend 

AmeriCorps 

Enrollments 

Inappropriate Obligation 

Practices 
Page 5 GAO-03-642T 

outlay basis. That is, obligations were recorded at the time of the quarterly 

drawdown of amounts for education awards from the Trust. 

By failing to recognize and record its obligations at the time of grant 

award, the Corporation had no assurance that the number of positions 

approved in grant awards did not exceed the amount of educational 

awards the Trust could support. Proper recording of obligations serves to 

protect the government by ensuring that it has adequate budget authority 

to cover all of its commitments and prevent agencies from over-obligating 

its budget authority. 

Corporation executives we interviewed said that there was little if any 

coordination between the AmeriCorps program office and officials 

responsible for the management of the Trust about the number of 

positions that the Trust could support. The AmeriCorps director said that 

she considered the grant budget independent from the Trust and she 

neither consulted with nor received direction from the Trust director 

when making decisions about the grants. In addition, in recent years, 

AmeriCorps has tried to increase the number of participants by enrolling 

them in the “education awards only” program. Under this program, which 

was an effort to lower the per participant program cost, AmeriCorps 

provides funding to grantees for administrative purposes only, currently 

about $400 per full-time participant annually. Increasing the number of 

participants in this way is at a low cost to the AmeriCorps program 

appropriation, but at full cost to the Trust, which funds the education 

awards, because each participant receives an education award equivalent 

to that earned by a paid AmeriCorps participant. Consequently, the 

number of positions funded by AmeriCorps grants was not reconciled with 

the number supportable by the Trust. According to Corporation officials 

we spoke with, the Trust’s funding needs were based on an expected 

enrollment of 50,000, while the AmeriCorps program office approved 

grants for about 75,000 participants. 

Corporation officials also said that prior to suspending enrollments in 

AmeriCorps, the Trust was so well funded it did not warrant their 

attention. They told us that early in the AmeriCorps program, a goal of 

50,000 participants annually was used for Trust budgeting purposes. 

However, it was found that fewer than that number of participants 

enrolled, and not all of those who participated earned education awards. 

Additionally, a Corporation budget official said that in the past those who 

earned education awards were not using them as quickly as expected. 

Even as the number of AmeriCorps participants grew, the Trust’s 

Lack of Communication 
Page 6 GAO-03-642T 

accounting records showed an unobligated balance that was high enough 

for Congress to rescind $111 million over fiscal years 2000 and 2001, 

resulting in the deobligation of the Trust by this amount. Given this 

history, Corporation managers did not see the need to reconcile the 

number of positions created by grant funding with the number the Trust 

could support. The Trust balance was not viewed as a constraining factor. 

Because the number of positions approved in the grants was not 

reconciled with the Trust before grants were awarded, there was the 

potential for grantees to enroll more participants than the Trust could 

support. 

Two program management policies affected the number and type of 

participants and, therefore, the use of Trust funds. One policy permitted 

grantees to over enroll participants under certain circumstances with 

approval from their AmeriCorps program officer. Specifically, the policy 

allowed grantees to over enroll up to 20 percent. The program year 2002-03 

data indicate that while only a few of the grantees increased their 

enrollment, some increased theirs by more than 20 percent. Another policy 

allowed grantees to convert positions from full-time to part-time as long as 

the total number of full-time equivalents supported by the grant did not 

change. While this practice did not affect the program funds, it did affect 

the Trust. After the enrollments were suspended, Corporation officials 

determined that part-time participants used their education awards at a 

higher rate than full-time participants and therefore the number of parttime participants resulted in a relatively higher level of use for the 

education award. 

The Corporation did not have reliable data on the number of AmeriCorps 

participants during the period leading up to the suspension. Enrollments 

are recorded by grantees through the Corporation’s Web-Based Reporting 

System (WBRS). While the enrollment information in WBRS was uploaded 

into the Corporation’s database and used to track education award 

obligations on a weekly basis, Corporation officials said that discrepancies 

existed between the number of participants enrolled and the number the 

Corporation was aware of, because of the length of time between when a 

participant started to serve and when the grantee entered information into 

WBRS. A Corporation official said that it was not unheard of for some 

grantees to be 60 to 90 days late in entering an enrollment into WBRS. 

By allowing grantees the flexibility to change the number and type of 

participants coupled with delays in receiving information on enrollments, 

the Corporation and AmeriCorps managers could not be certain about the 

Grantees Allowed to 

Adjust Authorized 

Positions and Not 

Required to Provide 

Timely Participant 

Information 
Page 7 GAO-03-642T 

number of participants. Corporation officials said that this resulting lack 

of confidence in the data was a contributing factor to the decision to 

suspend enrollments. 

In response to concerns that the AmeriCorps program may have enrolled 

participants without adequately providing for their education awards, the 

Corporation has developed several new policies. While the Corporation is 

modifying its practice of when it records obligations, the Corporation 

overlooks the legal duty it incurs at the time of grant award. Other policy 

changes are directed to improving communication among key executives, 

limiting grantees’ flexibilities and requiring more timely information on 

participants. While these policies were only recently introduced, they 

could, if implemented, help the Corporation keep track of the day-to-day 

aspects of the AmeriCorps program and provide information needed to 

monitor the use of the Trust in order to determine whether the 

Corporation should make adjustments, such as deobligating excess funds. 

However, data integration problems between WBRS and the program the 

Corporation uses to track the education awards earned by AmeriCorps 

participants may hamper the effectiveness of the new procedures. 

The Corporation is in the process of modifying its practices regarding 

when it will record obligations. The Corporation’s General Counsel 

explained that the Corporation will record obligations at the time of 

enrollment, instead of on a quarterly drawdown basis and that the 

obligations will be based on estimates of what these enrolled members 

will draw down in the future. The Corporation is of the opinion that it does 

not incur an obligation for an education award until the time of enrollment 

because it may modify the terms and conditions of a grant, including a 

reduction in the number of new participants the grantee may enroll, prior 

to the enrollment of all positions initially approved in a grant, to prevent a 

shortfall in the Trust. The General Counsel also said “...a binding 

agreement between the Government and an AmeriCorps member 

[participant] exists only upon the member’s [participant’s] authorized 

enrollment in the Trust.” 

While it may be true that the Corporation has no binding agreement with a 

participant until the participant enrolls in AmeriCorps, this is not the 

controlling consideration for fund control purposes. In our opinion, this 

view overlooks the legal duty the Corporation incurs at the time of grant 

award when it commits to funding a specified number of participants and 

the constraint imposed on the Corporation by the National and 

New Policies 

Established, but 

Additional Changes 

May be Needed 

New Policies for 

Obligating Funds 
Page 8 GAO-03-642T 

Community Service Act. Specifically, the act says “...[t]he Corporation 

may not approve positions as national service positions...for a fiscal year 

in excess of the number of positions for which the Corporation has 

sufficient available funds in the National Service Trust for that fiscal 

year...”. The Corporation, by its own admission, may modify the number 

of approved participants only if it amends the grant agreement to reduce 

the number of enrolled positions prior to enrollment. When a grant is 

awarded, the number of new participants approved in the grant establishes 

a legal duty that can mature into a legal liability for education awards by 

virtue of actions of the grantee, unless the Corporation modifies the grant 

prior to participant enrollment. While the Corporation may unilaterally 

reduce the number of authorized positions awarded to a grantee prior to 

participant enrollment, from the time of grant award until the Corporation 

acts to reduce the approved number of positions, the grantee and its 

subgrantee, not the Corporation, will control the number of participants 

who may enroll, up to the maximum number of participants the 

Corporation has approved in the grant agreement. 

It is also significant to note that the grantee and subgrantee, by their 

actions in enrolling participants, not the Corporation, control the amount, 

ultimately, of the Corporation’s liability. If the amount of liability to the 

government is under the control of the grantee, not the Corporation, the 

government should obligate funds to cover the maximum amount of the 

liability. As more information is known, the Corporation should adjust the 

obligation—deobligate funds or increase the obligation level—as needed. 

The Corporation also said that at the time a member enrolls it would 

record its “...best estimate of the Government’s ultimate liability of 

education awards provided to members [participants] enrolled in the 

National Service Trust.” According to the Corporation’s General Counsel, 

the Corporation’s estimates of the amount that enrolled members 

[participants] will draw down is based on historical information, such as 

attrition rate and actual usage by participants who complete a term of 

service and earn an education award. It appears to us that the Corporation 

is confusing its accounting liability—projections booked in its accounting 

systems for financial statement purposes, with its legal liability—amounts 

to be recorded in its obligational accounting systems and tracked in order 

to ensure compliance with fiscal laws. One of the federal financial 

accounting standards states that a liability for proprietary accounting 

purposes is a probable and measurable future outflow or other sacrifice of 

resources as a result of past transactions or events. Traditionally, 

projections of accounting liability consider the same factors, such as 

historical trends, that are considered in the Corporation’s model. To track 
Page 9 GAO-03-642T 

its obligations, the Corporation should be recording its unmatured legal 

liability for the education awards, which is the total cost associated with 

the enrollment of all approved positions. The Corporation’s obligation 

should be recorded as it is incurred and should be calculated by 

multiplying the number of approved positions in a grant by the total cost 

of a national service educational award. 

Policy changes at Corporation headquarters are designed to improve 

communication between several key offices and officials. A major change 

is that the Trust balance is to be a limiting factor on grant awards and, 

therefore, enrollment levels. In addition, beginning with the 2003 grant 

cycle4

, one new policy calls for the AmeriCorps director to work with the 

grants director, the Chief Financial Officer (CFO), and the Trust director 

to compare projections of positions to be approved in grants with those 

supported by actual appropriations, and the Chief Executive Officer 

(CEO) will only approve the number of positions the Trust can support. 

Additionally, the CEO will approve all AmeriCorps grants after 

consultation with the CFO on the number of education awards that can be 

supported by the Trust. Also, the policy states that the CEO, CFO, the 

Trust director, and the AmeriCorps director will meet at least monthly to 

review and reconcile enrollment data and Trust data. Through bi-weekly 

reports, the AmeriCorps director and the Trust director are to keep the 

CEO and CFO informed of the number of approved and filled positions. 

The Trust director is to monitor factors relevant to forecasting Trust 

liabilities and report regularly to the CFO, highlighting deviations from 

assumptions in the model. Each month the CFO is to use actual enrollment 

data to re-evaluate the model for forecasting Trust liabilities. If the 

revision results in a need to change enrollment targets, the CFO will notify 

the CEO and AmeriCorps director immediately. The CEO will take 

appropriate action and report any such action to Congress, the 

Corporation’s Board, and the Office of Management and Budget. 

Regular meetings and attention to the enrollment data should help the 

Corporation keep track of the day-to-day aspects of the AmeriCorps 

program. Such updated information is an important step in monitoring the 

use of the Trust in order to determine whether the Corporation should 

make adjustments. For example, if the Corporation obligated the full cost 

for each of the positions approved at the time of grant award, and later 

 4

The Corporation’s 2003 grant review cycle began in the spring of 2003. 

More Communication 

Planned among Key 

Corporation Managers 
Page 10 GAO-03-642T 

determined that many of the positions will not be filled, it could reduce the 

number of approved positions and deobligate some of the funds. The 

policy changes and new procedures were announced in January. We will 

continue to monitor the implementation of these policy changes. 

The Corporation has changed policies regarding its grantees ability to over 

enroll participants, replace participants who leave with new enrollees and 

change positions from full-time to part-time. In a January 22, 2003, 

memorandum, the director of AmeriCorps cancelled the policy that 

allowed grantees to over enroll members by up to 20 percent over the 

ceiling established in the grant award in order to take account of attrition. 

Furthermore, an official said AmeriCorps now considers a position to be 

filled for the term of the grant once the grantee enrolls a participant, even 

if the participant later drops out of the program, whether or not an 

education award was earned. The official said that in the past, grantees 

could enroll a new member to serve out the balance of the term if grant 

funds were available. A Corporation official also said that there is a new 

policy that restricts grantees from converting full-time positions to parttime positions. Grantees must now request and receive approval from the 

Corporation before such changes can be made. 

Since grantees will not be permitted to modify the number and type of 

authorized positions, the Corporation’s ability to manage the AmeriCorps 

program should improve. Most 2003 grant positions have not yet been 

awarded; therefore, it is too early to tell whether these new policies will be 

effective. We will monitor these policies and assess the extent to which 

they have been implemented as we complete our work. 

In January 2003 the Corporation informed all grantees that AmeriCorps 

will require timely reporting of participant information to ensure that the 

Trust database receives current information on the number of participants 

eligible for an education award. Grantees will be required to keep 

AmeriCorps informed of the number of participants offered positions and 

the number who accept and enroll and to document enrollment through 

WBRS no later than 30 days after participants start working. The 

memorandum warns grantees that failure to comply with this requirement 

could result in reductions in the number of positions or termination of the 

grant. Additionally, the memorandum directs state commissions and other 

AmeriCorps grantees—the organizations responsible for the oversight of 

subgrantees—to implement procedures to ensure that timely notification 

Grantees No Longer 

Permitted to Change 

Authorized Positions 

Grantees Will Be Required 

to Report Participant 

Information within 30 

days, but Data 

Reconciliation Problems 

May Need To Be 

Addressed 
Page 11 GAO-03-642T 

of participant commitments and enrollments is part of their review and 

oversight functions. 

Furthermore, the Corporation has made changes to WBRS, which is used 

to track participant, grant, and budget information. First, controls have 

been put in place to limit the number of positions listed in WBRS to no 

more than the number of approved positions. The Corporation’s Biweekly 

Trust Enrollment Summary, as of March 2003, shows that award totals are 

being tracked and compared with the data estimates in the Trust. 

However, officials told us that there are some data reconciliation problems 

between WBRS and the program used by the Corporation to track the 

education awards earned by AmeriCorps participants. Corporation staff 

have had to make manual adjustments to reconcile the data. 

Accurate and timely information about enrollments should help the 

Corporation and AmeriCorps manage the program. As grants are awarded, 

we will be able to assess whether the policies have been fully 

implemented. 

The Corporation’s new policies, if fully implemented, should help the 

Corporation manage the AmeriCorps program by providing better 

information on day-to-day operations. However, without obligating the full 

amount associated with all of the positions authorized in the grants, the 

Corporation remains at risk of having the actual number of enrollments 

exceed the estimated number the Trust can support. We will monitor the 

implementation of the Corporation’s new policies as we continue our 

review. 

For further information regarding this statement, please call Cornelia M. 

Ashby at (202) 512-8403 or Susan A. Poling at 202-512-5644. Individuals 

making key contributions to this testimony included Carolyn M. Taylor, 

Tom Armstrong, Anthony DeFrank, Joel Marus, and Hannah Laufe. 

Conclusion 

GAO Contact and 

Acknowledgments 
Appendix I: Obligational Practices of the 

Corporation for National and Community 

Service 

Page 12 GAO-03-642T 

Appendix I: Obligational Practices of the 

Corporation for National and Community 

Service 
Appendix I: Obligational Practices of the 

Corporation for National and Community 

Service 

Page 13 GAO-03-642T 
Appendix I: Obligational Practices of the 

Corporation for National and Community 

Service 

Page 14 GAO-03-642T 
Appendix I: Obligational Practices of the 

Corporation for National and Community 

Service 

Page 15 GAO-03-642T 
Appendix I: Obligational Practices of the 

Corporation for National and Community 

Service 

Page 16 GAO-03-642T 
Appendix I: Obligational Practices of the 

Corporation for National and Community 

Service 

Page 17 GAO-03-642T 
Appendix I: Obligational Practices of the 

Corporation for National and Community 

Service 

Page 18 GAO-03-642T 
Page 19 GAO-03-642T (130265) 
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