a

GAO

United States Government Accountability Office

Report to the Chairman, Subcommittee 

on National Security, Emerging Threats 

and International Relations, Committee 

on Government Reform, House of 

Representatives

August 2006 U.S. INTERNATIONAL 

BROADCASTING

Management of Middle 

East Broadcasting 

Services Could Be 

Improved

GAO-06-762
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

August 2006

U.S. INTERNATIONAL BROADCASTING

Management of Middle East Broadcasting 

Highlights of GAO-06-762, a report to the Services Could Be Improved 

Chairman, Subcommittee on National 

Security, Emerging Threats and 

International Relations, Committee on 

Government Reform, House of 

Representatives 

The Broadcasting Board of 

Governors’ (BBG) broadcasting

services, Radio Sawa, and the 

Alhurra satellite television 

networks—collectively known as 

the Middle East Broadcasting 

Networks, Inc. (MBN)—currently 

aim to reach Arabic speakers in 19

countries and areas throughout the

Middle East. Annual spending for 

current activities amounts to about

$78 million. 

GAO reviewed MBN’s (1) strategic 

planning to address competition in

the Middle Eastern media market, 

(2) implementation of internal 

control, (3) procedures MBN has 

developed to ensure compliance

with its journalistic standards, and

(4) performance indicators and

whether targets have been met.

What GAO Recommends

GAO is making several 

recommendations to the chairman 

of the BBG to improve the 

efficiency and operations of MBN. 

These include fully implementing

strategic planning, internal control,

and regular program reviews, as

well as addressing weaknesses in 

the conduct and reporting of its 

audience research. 

The BBG generally concurred with

our recommendations, although it 

disagreed with some of our

analysis. 

MBN faces a number of competitive challenges in carrying out its mission of 

broadcasting in the Middle Eastern media market and has taken some steps 

to address them. However, MBN lacks a comprehensive, long-term strategic 

plan. As MBN emerges from its start-up mode and faces future challenges, a

long-term strategic plan will be important. 

While MBN has developed financial and administrative controls to manage 

and safeguard its financial resources, it could take additional steps to 

strengthen its system of internal control. For example, the MBN has not (1) 

convened a meeting of its internal control board to formally develop its 

controls and coordinate audits, (2) completed an internal control plan, (3) 

completed a risk assessment to address potential risks to its operation, or 

(4) developed a comprehensive training program for its staff. 

MBN has procedures in place to help ensure its programming meets its 

journalistic standards. However, MBN lacks regular editorial training and 

has not fully implemented a comprehensive, regular program review process 

to determine whether its programming complies with those standards or 

with MBN’s mission. While the BBG calls for its broadcasters to undergo an 

annual program review, Radio Sawa has only held one such review, and 

Alhurra has not completed one to date. 

The BBG has developed several performance indicators and targets for 

MBN’s Radio Sawa and Alhurra services, including measures of audience 

size and program credibility. However, it is not clear whether the Radio 

Sawa and Alhurra performance targets have been met because of 

weaknesses in MBN’s survey methodology and documentation. The BBG did 

not take certain steps that could have explained and increased the reliability 

of its estimates, such as by fully documenting its research and estimation 

methods, measuring the level of uncertainty surrounding its estimates, 

disclosing significant limitations, and consistently implementing policies and 

procedures for verifying data. 

Alhurra’s Broadcast Center in Springfield, Virginia 

Source: GAO.

www.gao.gov/cgi-bin/getrpt?GAO-06-762.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Jess T. Ford at 

(202) 512-4128 or fordj@gao.gov. 
Page i GAO-06-762 U.S. International Broadcasting

Contents

Letter 1

Results in Brief 2

Background 5

Lack of Long-term, Comprehensive Planning Could Limit MBN’s 

Ability to Respond to Market Challenges 14

MBN Has Made Progress in Developing Internal Control, but 

Additional Steps Could Improve Its Control Structure 20

MBN Has Developed Editorial Procedures to Support Its 

Journalistic Standards, but Could Improve Monitoring and Some 

Quality Control Measures 26

BBG Has Developed Several Performance Indicators, Although 

Weaknesses in Audience Surveys Call into Question Whether 

MBN Audience Size and Credibility Targets Have Been Met 33

Conclusions 43

Recommendations for Executive Action 44

Agency Comments and Our Evaluation 46

Appendixes

Appendix I: Scope and Methodology 48

Appendix II: Radio Sawa and Alhurra Programming 50

Appendix III: Radio Sawa Program Review 52

Appendix IV: CIBAR Standards 54

Appendix V: Comments from the Broadcasting Board of Governors 56

GAO Comments 64

Appendix VI: GAO Contact and Staff Acknowledgments 68

Tables Table 1: Actions taken by MBN to Address Grant Thornton’s 

Internal Control Recommendations 22

Table 2: Inputs to Program Quality Scores for BBG Broadcasting 

Entities 32

Table 3: BBG’s Standard Performance Indicators and MBN’s 

Status 35

Table 4: BBG’s Reported Audience Size and Credibility Estimates 

for Radio Sawa and Alhurra, Fiscal Year 2005 38

Table 5: Radio Sawa’s Weekly News and Features Programming 50

Table 6: Alhurra’s Weekly Programming Schedule 51

Table 7: Alhurra-Iraq’s Weekly Programming Schedule 51
Contents

Page ii GAO-06-762 U.S. International Broadcasting

Figures Figure 1: Organization of the BBG 5

Figure 2: Timeline Showing Creation and Key Dates of MBN 7

Figure 3: Organization of MBN 8

Figure 4: Appropriations to Radio Sawa, Alhurra, Alhurra-Iraq, and 

Alhurra Europe, Fiscal Years 2002-2006 9

Figure 5: Map of MBN Target Countries and Locations of Overseas 

Offices 11

Figure 6: Radio Sawa’s FM and AM Broadcast Range 12

Abbreviations

BBC British Broadcasting Corporation

BBG Broadcasting Board of Governors

CFO Chief financial officer

CIBAR Conference of International Broadcasters’ Audience 

Research Services

GPRA Government Performance and Results Act of 1993

MBN Middle East Broadcasting Networks, Inc.

MTN Middle East Television Network

OMB Office of Management and Budget

RFA Radio Free Asia

RFE/RL Radio Free Europe/Radio Liberty

UAE United Arab Emirates

VOA Voice of America

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

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other material, permission from the copyright holder may be necessary if you wish to 

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Page 1 GAO-06-762 U.S. International Broadcasting

United States Government Accountability Office

Washington, D.C. 20548

A

August 4, 2006 Letr

The Honorable Christopher Shays

Chairman

Subcommittee on International Security, Emerging Threats

and International Relations

Committee on Government Reform

House of Representatives

Dear Mr. Chairman:

The President’s 2006 National Security Strategy stipulates that public 

diplomacy, which includes U.S. international broadcasting, is an important 

instrument for engaging and informing foreign audiences, creating and 

maintaining a dialogue with Muslim leaders, and confronting 

misinformation about the United States. Under the direction of the 

Broadcasting Board of Governors (BBG), an independent agency, the 

mission of all U.S. international broadcasting services is to promote 

freedom and democracy and enhance understanding through objective 

journalism. The BBG’s priority broadcasting services, Radio Sawa and the 

Alhurra satellite television networks1

—both operated since 2005 by the 

nonprofit grantee Middle East Broadcasting Networks, Inc. (MBN)—

currently aim to reach Arabic speakers in 19 countries and areas 

throughout the Middle East. Spending for MBN’s broadcasting services has 

increased in recent years and currently amounts to about $78 million 

annually. In fiscal year 2005, MBN received additional funding to support a 

new Alhurra satellite television initiative to reach Arabic speakers in 

Europe. MBN has recently requested funding to enhance its radio and 

television programming content. 

This report assesses (1) the extent to which MBN has used strategic 

planning to address its competitive challenges in the Middle Eastern media 

market, (2) the progress MBN has made in developing financial and 

administrative controls to ensure that the organization operates efficiently 

and complies with its grant agreement, (3) the procedures MBN has 

developed to ensure compliance with its journalistic standards, and (4) the 

extent to which BBG has developed performance indicators for MBN’s 

efforts and met its primary performance targets. 

1

The Alhurra networks include Alhurra and Alhurra-Iraq.
Page 2 GAO-06-762 U.S. International Broadcasting

To accomplish our objectives, we reviewed documentation and spoke with 

officials from the BBG and its broadcasting entities, including the grantees 

(MBN, Radio Free Europe/Radio Liberty (RFE/RL), Radio Free Asia 

(RFA)), the Voice of America (VOA), and the International Broadcasting 

Bureau. We also spoke with several outside experts, including 

representatives from the Department of State, National Public Radio, the 

InterMedia research organization, Zogby International, and foreign 

international broadcasters such as the British Broadcasting Corporation 

(BBC) and Deutsche Welle. In addition, we visited MBN’s offices in 

Amman, Jordan, and Dubai, United Arab Emirates (UAE). We held 

telephone interviews with MBN’s current affairs contractor in Beirut, 

Lebanon, and corresponded with the head of the MBN office in Baghdad, 

Iraq. We conducted our evaluation from August 2005 through May 2006 in 

accordance with generally accepted government auditing standards. 

(Appendix I provides a more detailed description of our scope and 

methodology.) 

Results in Brief MBN faces a number of challenges in carrying out its mission of 

broadcasting in the Middle Eastern media market and has taken some steps 

to address them. Although MBN has participated in BBG’s long-term 

planning exercises, it has not yet established a formal long-term strategic 

plan. A formal documented strategic plan could help MBN meet challenges 

in its competitive marketplace. MBN’s challenges include the fact that its 

Alhurra television station is currently competing in a market with over 140 

other stations and also faces operational and programmatic competitive 

disparities, such as having fewer overseas bureaus than its primary 

competitors. In addition, its Radio Sawa service lacks FM radio coverage in 

certain markets. MBN has begun a number of efforts and proposed 

initiatives to address some of its challenges, such as proposals for Alhurra 

to increase its hours of news coverage and current affairs programming 

and for Radio Sawa to increase the amount of local content it broadcasts to 

better compete with local stations. However, MBN lacks a shared vision of 

operations for Radio Sawa and Alhurra as well as detailed implementation 

strategies and related resource requirements for its proposed goals. 

According to GAO guidance,2

 organizations should make decisions in the 

context of a strategic plan. The absence of a long-term plan and 

comprehensive strategic approach for MBN’s operations limits 

2

GAO, Internal Control Management and Evaluation Tool, GAO-01-1008G (Washington, 

D.C.: August 2001).
Page 3 GAO-06-762 U.S. International Broadcasting

opportunities for strategically addressing impediments to the 

organization’s achieving its goals and objectives and identifying 

opportunities for more efficient operations. 

MBN has developed several financial and administrative controls to 

manage and safeguard its financial resources. For example, in the past 

year, MBN has hired additional financial staff, acquired a new financial 

information system, developed administrative and financial policies and 

procedures, provided some training to staff, and received an unqualified 

opinion on its fiscal year 2005 financial statements. However, additional 

steps could be taken to strengthen MBN’s system of internal control,3

including (1) establishing an internal control board to formally develop 

controls and coordinate audits, (2) preparing an internal control plan, (3) 

conducting a risk assessment to address potential risks to its operation, 

and (4) developing a comprehensive training program for its staff. These 

steps could help MBN more effectively manage its operations and improve 

its internal control structure.

MBN has procedures in place to help ensure its programming meets its 

journalistic standards and is consistently accurate, objective, balanced, and 

comprehensive. However, MBN has not fully implemented some editorial 

procedures, or a comprehensive, standardized program review process of 

its broadcast operations. To comply with its standards, MBN has put in 

place a variety of pre- and postbroadcast procedures, such as editorial 

meetings and postbroadcast discussions that enable producers and editors 

to review and provide input to Radio Sawa and Alhurra broadcasts on a 

daily basis. However, MBN could more fully develop some quality control 

measures, such as using listener and viewer feedback to improve program 

quality. In addition, although the BBG calls for its broadcasting services to 

undergo a standardized annual program review, MBN’s Radio Sawa has had 

only one program review, and Alhurra has not had a program review to 

date. Furthermore, unlike reviews of other broadcasting services and 

contrary to BBG guidance, the Radio Sawa program review was less 

comprehensive in that it relied upon several audience panels but did not 

include input from in-house analysts or external expert listeners. The lack 

of annual, comprehensive program reviews hampers BBG’s ability to 

3

Internal control is a major part of managing any organization and comprises the plans, 

methods, and procedures used to meet missions, goals, and objectives. Effective internal 

control helps in managing change to cope with shifting environments and evolving demands 

and priorities. 
Page 4 GAO-06-762 U.S. International Broadcasting

assure its audience, Congress, and the BBG that its services are complying 

with its journalistic standards and mission. 

The BBG has developed performance indicators and targets4 related to 

audience size and program credibility for MBN’s Radio Sawa and Alhurra 

broadcasting services. However, it is not clear whether the Radio Sawa and 

Alhurra performance targets have actually been met because of 

weaknesses in MBN’s methodology and documentation. To develop 

estimates for audience size and credibility, the BBG uses results from 

audience research conducted overseas. Documentation we reviewed 

indicated that the BBG extensively uses nonprobability audience survey 

results that cannot be reliably projected to represent a broader population 

in the region. While it is not always possible to expect the BBG to use 

probability samples in countries where there are security risks, the BBG 

did not take certain steps that could have explained and increased the 

reliability of its estimates, such as fully documenting its research methods, 

measuring the level of uncertainty surrounding its estimates, disclosing 

significant limitations, limiting the scope of its projections to areas actually 

covered by its surveys, and developing and consistently implementing 

policies and procedures for verifying data. 

We are making several recommendations to the chairman of the BBG. First, 

we recommend that the BBG take steps to improve the efficiency of MBN 

and its ability to address challenges by ensuring that MBN develops a 

comprehensive long-term strategic plan. In addition, to improve controls 

and performance monitoring, we recommend that the BBG require MBN to 

implement additional elements of internal control, establish a regular 

mechanism for undertaking annual program reviews, implement 

performance indicators consistent with other BBG entities, and improve 

the transparency and documentation used for audience research to allow 

for assessments of confidence in data used for performance indicators. 

We received written comments on a draft of this report from the BBG. In 

general, the BBG concurred with our recommendations and said that MBN 

has made significant progress in the 2 years of its operation in establishing 

a sound journalistic organization with financial and administrative 

controls. However, the BBG raised a number of concerns about the report’s 

4

The BBG’s reported fiscal year 2005 audience size performance target for Radio Sawa was 

18 million listeners and for Alhurra 12.8 million viewers. In addition, the BBG’s reported 

program credibility target for Radio Sawa was 69 percent and for Alhurra 73 percent.
Page 5 GAO-06-762 U.S. International Broadcasting

criticisms of the audience research conducted by the BBG and its 

contractors.

Background Middle East Broadcasting Networks, Inc. (MBN), which includes the 

services Radio Sawa and Alhurra, is an independent nonprofit grantee 

overseen by the Broadcasting Board of Governors (BBG). The BBG is an 

independent, federal agency responsible for overseeing all U.S. 

government-sponsored, nonmilitary, international broadcasting programs. 

The BBG also manages the operations of the International Broadcasting 

Bureau, the Voice of America (VOA), and the Office of Cuba Broadcasting, 

which are all federal entities. It also provides funding and oversight to three 

independent grantees, MBN, Radio Free Europe/Radio Liberty (RFE/RL), 

and Radio Free Asia (RFA) (see figure 1). 

Figure 1: Organization of the BBG

Broadcasting Board 

of Governors

Broadcasting Board 

of Governors Staff 

Radio Free Europe 

Radio Liberty 

Radio Free Asia

Radio 

Sawa

International 

Broadcasting 

Bureau

Management 

Directorate 

Radio/TV Marti 

Office of Cuba

Broadcasting 

Program

Support

Directorate

Voice of 

America

Engineering and 

Technical Services

Alhurra

MBN 

Grantees

Source: BBG.

Audience Research

Performance Review

Office of 

Performance 

Review 
Page 6 GAO-06-762 U.S. International Broadcasting

Development of MBN In March 2002, due to concerns about the effectiveness of its outreach to 

Arabic speakers in the Middle East, the BBG replaced VOA’s Arabic radio 

service with Radio Sawa, a 24-hour, 7-day a week, Arabic language radio 

station. In April 2003, Congress, at the request of the administration, 

provided $26 million in the fiscal year 2003 Emergency Wartime 

Supplemental Appropriations Act5 to establish a nonprofit corporation, the 

Middle East Television Network (MTN), as a grantee of the BBG to launch 

and operate Alhurra TV. Ten months later, on February 14, 2004, Alhurra, 

MTN’s Arabic-language satellite television station, was launched and 

initially started broadcasting 14 hours a day, expanding to 24 hours a day 2 

months later. In November 2003, the fiscal year 2004 Emergency 

Supplemental Act for Defense and for Reconstruction of Iraq and 

Afghanistan6

 included $40 million to establish a second 24-hour channel, 

Alhurra-Iraq. On April 27, 2004, Alhurra-Iraq was launched. In 2005, MTN 

was renamed the Middle East Broadcasting Networks, Inc. (MBN), and 

Radio Sawa transferred to MBN. See figure 2 for a timeline of these events 

and figure 3 for details on the current organization of MBN.

5

P.L. 108-11.

6

P.L.108-106.
Page 7 GAO-06-762 U.S. International Broadcasting

Figure 2: Timeline Showing Creation and Key Dates of MBN 

Radio Sawa launched

Middle East Television Network (MTN) created pursuant to the 2003 

Emergency Wartime Supplemental Appropriations Act

Alhurra Television launched

MTN renamed Middle East Broadcasting Networks, Inc. (MBN)

Alhurra-Iraq launched

Radio Sawa became part of MBN

March

April

February

April 

April

May

2002

2003

2004

2005

Source: GAO analysis of MBN and BBG data. 
Page 8 GAO-06-762 U.S. International Broadcasting

Figure 3: Organization of MBN

MBN Funding Congress appropriated more than $274 million to fund Radio Sawa, 

Alhurra, and Alhurra-Iraq from fiscal year 2002 through fiscal year 2006.7

 

● Acquired 

program 

evaluation, 

subtitling, and 

management

MBN Board 

of Directors

MBN 

Executive 

Committee 

President 

Executive Vice 

President/Director 

News Alhurra/Sawa

News and 

current affairs

Alhurra

News and 

current affairs

Radio Sawa

Production 

operations

TV program 

acquisition

and 

scheduling

TV on-air 

promotion 

and 

graphics

Overseas

production 

operations

● Alhurra

news

department

● Alhurra

current 

affairs

department

● Alhurra-Iraq 

news and 

current 

affairs

● Studio 

operations

● Engineering

● Information 

Technology

● Program 

scheduling and 

operations

● Baghdad

● Dubai

● Amman

● Beirut

Vice President 

Finance and 

Administration 

Radio Sawa

General Manager

Director of 

Communications

Administration Finance 

and 

Accounting

Human 

Resources

Legal Security

● Contracts and 

purchasing

● Facilities and 

office services

Source: MBN.

7

$2.1 million of this amount was appropriated to support the start-up of Alhurra Europe. The 

administration proposed this effort, which would provide Arabic-speaking audiences in 

Europe with balanced and accurate news and information, as part of its budget request for 

the Fiscal Year 2005 Supplemental. MBN officials told us that they intend Alhurra Europe’s 

24-hour a day broadcast to include a 4-hour repeating cycle of Alhurra’s and Alhurra-Iraq’s 

original current affairs programs and other shows, with fresh news every hour. According to 

MBN officials, the channel will be broadcast on satellite and eventually on cable.
Page 9 GAO-06-762 U.S. International Broadcasting

Each year MBN’s funding level has increased to support additional 24-hour 

television streams and Radio Sawa’s 24-hour radio programming. MBN’s 

grant in fiscal year 2006 is $78.7 million to support Alhurra, Alhurra-Iraq, 

and Radio Sawa, as well as the launch of Alhurra-Europe. See figure 4 for a 

breakdown of funds by fiscal year.

Figure 4: Appropriations to Radio Sawa, Alhurra, Alhurra-Iraq, and Alhurra Europe, 

Fiscal Years 2002-2006

MBN’s Mission and Scope of 

Operations

The Alhurra networks and Radio Sawa are BBG’s priority broadcasting 

services designed to support the BBG’s antiterror broadcasting initiatives 

in the Middle East and counter media campaigns used by terrorists by 

providing accurate reporting and analysis of the news and by explaining 

U.S. policies. Although MBN and its Alhurra broadcasting services postdate 

the BBG’s current 2002-2007 strategic plan, Radio Sawa, in particular, was 

Fiscal year

Dollars in thousands

Sources: MBN and BBG.

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

Supplemental Alhurra-Europe

Radio Sawa

Supplemental Alhurra-Iraq

Alhurra

2002 2003 2004 2005 2006
Page 10 GAO-06-762 U.S. International Broadcasting

singled out as an opportunity in the plan to target Arabic-speaking youth 

and provide them with news that is objective, comprehensive, fresh, and 

relevant and to provide a forum for reasoned discussion of “hot button” 

issues and U.S. policies. MBN’s current mission statement is to broadcast 

factual, timely, and relevant news and information about the Middle East, 

the United States, and the world to people of all ages in order to advance 

the long-term U.S. interests of promoting freedom and democracy and 

enhancing understanding in the Middle East. Radio Sawa and Alhurra aim 

to be among the sources that audiences turn to in the Middle East for news 

and information, to increase the standards of other broadcasters in the 

region, and to offer distinctive and provocative programming unavailable 

on other stations.

MBN’s target audience includes 19 Arabic-speaking countries and 

territories8

 in North Africa, the Near East, and the Gulf region, which are 

home to approximately 250 million people. In addition to its headquarters 

in Springfield, Virginia, MBN has several overseas offices, including a 

production center in Dubai that broadcasts Radio Sawa’s live newscasts 

during 8 hours each day and produces some opinion features for Radio 

Sawa and current affairs programming for Alhurra (see figure 5).9

8

The 19 countries and territories are Algeria, Bahrain, Djibouti, Egypt, Iraq, Jordan, Kuwait, 

Lebanon, Libya, Morocco, Oman, Qatar, Saudi Arabia, Sudan, Syria, Tunisia, United Arab 

Emirates, Yemen, and Palestine.

9

MBN also has an overseas production facility that develops some Alhurra current affairs 

programs in Beirut, Lebanon.
Page 11 GAO-06-762 U.S. International Broadcasting

Figure 5: Map of MBN Target Countries and Locations of Overseas Offices

Radio Sawa’s Operations Radio Sawa’s broadcasts are designed to reach a target audience of 15- to 

29-year olds in the Middle East with Western and Arab popular music, news 

broadcasts, and specialized programming. Radio Sawa broadcasts 24 hours 

of programming every day through a combination of FM, medium wave 

(AM), digital audio satellite, and Internet transmission resources. See 

figure 6 for a map of Radio Sawa’s regional reach. 

Sudan 

Algeria Libya Egypt 

Tunisia 

Morocco

Jordan 

(Amman) 

Lebanon (Beirut) 

Palestine 

Kuwait 

Qatar 

Bahrain 

United Arab

Emirates

(Dubai)

Yemen 

Djibouti 

Syria 

Iraq 

(Baghdad) 

Oman 

Saudi Arabia

Sources: MBN and MapArt.

Nontarget countries and areas

MBN target countries and areas

Television (MBN offices) 

Radio (MBN offices) 
Page 12 GAO-06-762 U.S. International Broadcasting

Figure 6: Radio Sawa’s FM and AM Broadcast Range

Sources: GAO (data); Map Resources (map).

On air FM stations

On air AM stations

Turkey 

Greece 

Cyprus Rhodes

Ethiopia

Eritrea

Sudan 

Egypt 

Somalia 

Libya 

Algeria 

Tunisia 

Morocco 

Djibouti

Jordan 

Israel 

Lebanon 

Kuwait 

Dubai

Abu Dhabi

Bahrain

U.A.E.

Yemen 

Syria 

Iraq Iran 

Oman Saudi Arabia

Rabat

Marrakech

Agadir

Casablanca

Tangier 

Meknes

Fes

As-Sulaymaniyah

Arbil

Al Nasiriyah

Qatar

Arta
Page 13 GAO-06-762 U.S. International Broadcasting

Radio Sawa has developed seven distinct programming streams, including 

(1) Iraq, (2) Jordan and the West Bank, (3) the Gulf, (4) Egypt and the 

Levant, (5) Morocco, (6) Sudan and Yemen, and (7) Lebanon. All of the 

streams generally feature the same major newscasts, current affairs, and 

policy features; however, the Iraq program differs slightly, and the streams 

all offer differentiated music programs.10 Radio Sawa’s streams broadcast 

between 31 and 35 hours of news each week. (See appendix II for more on 

Radio Sawa’s programming.)

Alhurra’s Operations The Alhurra satellite television station is designed to reach a broad 

audience in the Middle East by providing news, current affairs, and 

entertainment programming 24 hours a day, 7 days a week. Alhurra-Iraq is 

designed to provide Iraqi citizens with daily newscasts and talk shows that 

specifically address issues in Iraq. Both Alhurra networks broadcast 

between 36 and 43 hours of news and news updates a week.11 Alhurra 

broadcasts on the Arabsat and Nilesat satellites, which currently allow it to 

cover the entire Middle East. Alhurra-Iraq also broadcasts through these 

satellites and a combination of terrestrial transmitters made available in 

Iraq.12 Alhurra also expects to start broadcasting to Europe on August 1, 

2006.13 (See appendix II for more information on Alhurra and Alhurra-Iraq 

programming.)

10MBN broadcasts additional newscasts and current affairs programs dealing with the 

challenges facing postwar Iraq on the Iraq stream. In addition, the Sawa Chat call-in show is 

currently localized for the Iraq, Gulf, Jordan, and Morocco streams.

11This figure can vary weekly depending on events. 

12Alhurra transmitters are located in Baghdad, Basra, and Mosul.

13In February 2004, Alhurra began broadcasting on the Arabsat and Nilesat satellites, which 

are also used by the major regional Arabic channels. Arabsat and Nilesat cover the entire 

Middle East. Their footprints extend from well into Northern Europe to as far south as 

Angola and Mozambique in Africa. From west to east, the footprints extend from the 

Atlantic Ocean to southern Pakistan. In the future, in order to serve the estimated 10 million 

Arabic speakers in Europe, the Alhurra channel will be distributed via the Hotbird satellite, 

which is popular in Europe. Its footprint spans across Europe and reaches well into Russia 

at its eastern edge. Hotbird satellite coverage also extends to the Middle East and North 

Africa. 
Page 14 GAO-06-762 U.S. International Broadcasting

Lack of Long-term, 

Comprehensive 

Planning Could Limit 

MBN’s Ability to 

Respond to Market 

Challenges

MBN faces a variety of challenges to broadcasting in the Middle East, 

including operating in a competitive satellite television broadcast market, 

operational and programming competitive disparities, and lack of coverage 

for Radio Sawa in certain FM markets. MBN has conducted some planning 

efforts and, by using market research and internal assessments of its 

competitors, has undertaken or proposed some initiatives to address many 

of these challenges, such as increasing its hours of news coverage and 

current affairs programming for Alhurra and increasing the amount of local 

content Radio Sawa broadcasts. However, MBN has not developed a longterm strategic plan that fully addresses its operational and competitive 

challenges.

Radio Sawa and Alhurra 

Face Significant 

Competitive Challenges

MBN faces several significant competitive challenges. These include the 

competitive Middle East satellite television market; operational and 

programming competitive disparities, such as Alhurra’s lack of news 

bureaus compared with its competitors; and lack of coverage in certain FM 

radio markets. 

MBN operates in the competitive Middle Eastern satellite television market 

that has over 140 channels. Pan-Arab satellite television stations–in 

particular, the news stations Al Jazeera and Al Arabiya--are currently the 

primary competitors to Alhurra. According to the BBG’s research firm 

Intermedia, Al Jazeera is currently the top international broadcaster as a 

source of news and information for audiences in many countries 

throughout the Middle East. Moreover, Alhurra will face new competition 

from the BBC’s entry to the Middle Eastern satellite television market in 

2007. BBC officials have indicated that the new station’s overall approach 

in the region will be multimedia in focus, taking advantage of the BBC’s 

more than 60 years experience of broadcasting on the radio to the region as 

well as its award-winning Arabic-language news Web site. For Radio Sawa, 

the primary competitive challenge comes from existing local radio stations 

in its broadcast range and the BBC World Service in Arabic, as well as from 

the generally increasing competitiveness of the Middle East radio market. 
Page 15 GAO-06-762 U.S. International Broadcasting

Alhurra also faces operational and programmatic competitive disparities,14

since both Al Jazeera and Al Arabiya are estimated to receive significant, 

although unknown, levels of funding from their respective supporting 

Qatari and Saudi financiers--allowing them to develop large networks of 

correspondents and bureaus throughout the Middle East and other parts of 

the globe. Al Jazeera, in particular, has bureaus in over 30 locations across 

6 continents, which enable it to respond to breaking news events on a 

timely basis. Alhurra and Radio Sawa, by comparison, only have overseas 

bureaus in Baghdad, Dubai, and Amman. In addition, the BBC has a large 

network of correspondents and bureaus around the globe and, unlike 

Alhurra, has a vast in-house library of desirable BBC-produced content, 

including documentaries and current affairs programming, which can be 

readily translated into Arabic. The BBC also has favorable licensing and coproduction arrangements with many companies.

One of Radio Sawa’s other primary challenges is its lack of broadcast 

coverage in certain countries in the Middle East region. For example, Radio 

Sawa does not have any broadcasting coverage in Tunisia, Libya, and 

Algeria. Moreover, it has faced difficulties expanding its transmission to 

include FM coverage in some countries, such as Egypt, Saudi Arabia, Syria, 

Yemen, and Oman. MBN is attempting to negotiate transmission 

agreements with several of these countries, but still faces significant 

challenges to finalizing agreements. 

MBN Has Taken Some Steps 

to Address Its Competitive 

Challenges

Since its inception, MBN has conducted some planning exercises to 

address its competitive challenges. These have included developing a “2006 

Goals and Strategies” overview document to guide operations for the 

current fiscal year, establishing a 2006 annual performance plan as part of 

the Office of Management and Budget’s Program Assessment Rating Tool 

process, and participating in the development of the BBG’s new long-term 

strategic plan covering fiscal years 2008-2012. In addition, MBN conducts 

ongoing assessments of its competitors and uses various types of market 

research to gain information about its audience and media usage patterns 

in the Middle East. It has used this information to make adjustments to its 

programming within its current budget, and also to develop proposals for 

obtaining additional funding for new efforts. BBG and MBN officials have 

14Al Jazeera claims it reaches over 45 million viewers in the Middle East. However, based on 

lack of additional information about the measure and how the estimates for the figure were 

developed by Al Jazeera, we could not determine this figure’s reliability. 
Page 16 GAO-06-762 U.S. International Broadcasting

explained that they use audience surveys, audience monitoring panels, 

focus groups, in-depth interviews, and Arab television and music station 

monitoring to inform MBN’s current efforts and planning, whenever 

possible. 

For example:

• As a result of market research performed in August 2004, MBN officials 

identified television viewing patterns and made changes to Alhurra 

program schedules, such as by offering programming appealing to 

women (e.g., current affairs and health and fitness programming) during 

the daytime. 

• Through a review of the current competition in the market, MBN 

officials decided that it was important to increase the number of debate 

programs they broadcast on Alhurra. As a result, MBN created a series 

of “town hall meetings” that allowed journalists and experts to discuss 

issues of regional interest with interaction from a live audience. 

• As a result of audience monitoring panels, MBN officials made changes 

to Radio Sawa’s program schedule by adding new features on subjects 

such as social and cultural issues. MBN officials also learned of the 

importance of efforts to localize those features, and made changes to 

tailor programs to the interests of audiences of the various Radio Sawa 

streams. 

MBN has also developed program enhancement proposals for Alhurra and 

Radio Sawa as part of the BBG’s language review and budget request 

processes. Several proposals were included in the President’s fiscal year 

2007 budget request. For example, the budget request includes a proposal 

to increase Alhurra’s newsroom hours to increase on-the-spot and breaking 

news coverage.15 In addition, in fiscal year 2005, the administration 

requested additional funds for providing satellite Alhurra broadcasts to 

Europe. According to planning documents, many of the Alhurra proposals 

were designed to reinforce one another with the goal of improving 

Alhurra’s credibility, as well as building audience size and increasing 

15Additional proposals MBN submitted internally to BBG included expanding purchases of 

acquired programming, as well as in-house production of town hall debates and Arabiclanguage documentaries to provide greater variety of current affairs content of regional 

interest to viewers.
Page 17 GAO-06-762 U.S. International Broadcasting

viewing time of those who already tune in.16 MBN also developed one 

proposal for enhancing Radio Sawa’s operations that calls for increasing 

the amount of localized news content offered on five regional streams,17

which officials say would allow the station to more effectively compete 

with local stations in its broadcast range. MBN’s president said that, given 

the increasing level of competitiveness in radio broadcasting in the Middle 

East and expressed audience interest in news about their home country, 

creating more localized content on Radio Sawa streams is important. 

MBN Has Conducted 

Planning Exercises but 

Lacks a Long-term Strategic 

Plan

Strategic planning is a good management practice for all organizations. 

Although MBN has conducted some planning exercises, it lacks a long-term 

strategic plan and a strategic approach that outlines (1) a shared vision of 

operations for Alhurra and Radio Sawa, (2) detailed implementation 

strategies to achieve measurable outcomes for its goals, and (3) the 

competitive challenges it faces and how it plans to address its key 

challenges to broadcasting in the Middle East. 

Strategic planning, including the development of a strategic plan, is a good 

management practice for all organizations. Additionally, risk assessment is 

an integral part of strategic planning. According to GAO guidance,18

organizations should make management decisions in the context of a 

strategic plan, with clearly articulated goals and objectives that identify 

resource issues and internal and external threats, or challenges, that could 

impede the organization from efficiently and effectively accomplishing its 

objectives. Additionally, Office of Management and Budget (OMB) 

guidance suggests that strategic plans contain, among other things, a 

statement of the organization’s long-term goals and objectives; define 

approaches or strategies to achieve goals and objectives; and identify the 

various resources needed and the key factors, risks, or challenges that 

could significantly affect the achievement of the strategic goals. 

16MBN officials have noted that, according to survey research and evaluative interviews 

conducted in the Middle East, Alhurra’s audience does not currently view it as a top source 

of news and information. MBN officials also noted that their assessments have found that 

Alhurra does not have the same level of credibility as Al Jazeera. 

17The streams identified for this initiative include Morocco, Jordan/West Bank/Syria, Egypt, 

Gulf/Saudi Arabia, and Sudan.

18GAO-01-1008G.
Page 18 GAO-06-762 U.S. International Broadcasting

MBN has yet to create its own long-term strategic plan. MBN’s president 

stated that funding uncertainties and other more pressing organizational 

needs--such as the development of financial and administrative policies and 

procedures--have delayed the development of MBN’s strategic plan and 

related planning policies. In addition, he commented that MBN did not 

emphasize planning in its early stages because it was focusing on making 

its networks broadcast-ready. BBG officials said another reason for the 

delays in planning is that the BBG and MBN are still learning about the 

market, especially for Alhurra, and are taking a close look at the results of 

audience surveys, focus groups, and in-depth interviews to determine the 

best direction for these initiatives. MBN has stated that, to date, it has 

primarily used the BBG strategic plan for organizational guidance. 

Nevertheless, BBG officials said the BBG also has the expectation that all 

broadcasting entities will develop their own strategic plans, particularly to 

guide funding decisions. 

In the absence of a strategic plan of its own, MBN lacks a comprehensive, 

strategic approach that fully outlines (1) a shared vision of operations for 

Alhurra and Radio Sawa, (2) detailed implementation strategies to achieve 

measurable outcomes related to its goals, and (3) the competitive 

challenges it faces and how it plans to address them. 

First, MBN does not have a comprehensive strategic vision for the 

integration of Radio Sawa and Alhurra operations in the organization. For 

example, although MBN’s most recent annual performance plan contains a 

goal to “integrate news operations for more effective television and radio 

news-gathering,” none of MBN’s current plans outline specific, shared 

objectives for Radio Sawa and Alhurra. MBN officials told us that several 

steps toward integration of Alhurra and Sawa have occurred to date, such 

as sharing financial and administrative support staff. However, Radio Sawa 

and overseas bureau staff we talked with said that cooperation between 

Alhurra and Radio Sawa is limited, the identities of the stations are 

separate, and the two stations work largely independently of one another. 

Radio Sawa staff noted several areas for further increasing cooperation, 

including more sharing of interviews, sound bites, field correspondents, 

Web site stories, and copy editors. One staff member in the Baghdad 

bureau said that Radio Sawa and Alhurra operations in Iraq are completely 

independent, including separate offices, and only the financial activities of 

both offices are supervised by the same person. In addition to gaining 

more efficiency in operations, a vision for further integration of Radio 

Sawa and Alhurra may help MBN more effectively identify opportunities to 

address its challenges from increasing competition in the Middle East. 
Page 19 GAO-06-762 U.S. International Broadcasting

Second, MBN has not yet developed detailed implementation and resource 

strategies needed for successful implementation of its goals. For example, 

with regard to MBN’s initiative to localize content on Radio Sawa, we were 

not able to identify a plan directing what types of local news and features 

will be considered on the various streams, to what degree existing program 

schedules might be affected, and how required resources might be divided 

among the various streams. Additionally, although MBN’s most recent 

annual performance plan states a goal of “expanding overseas production 

of news coverage for radio and television,” neither that document nor any 

other plan MBN identified provides details or direction for the overseas 

production of news for Alhurra in existing overseas offices. MBN officials 

have stated that uncertainties in the future commitment of resources to 

Alhurra have affected MBN’s ability to, for example, plan for and use 

existing overseas offices for Alhurra news. Further, BBG officials have said 

MBN is still learning about the Middle Eastern media market. However, 

given MBN’s internal enhancement requests to the BBG to increase the 

number of news bureaus in the region, among others, it should clarify, for 

example, what implementation steps are necessary to maximize the use of 

existing overseas offices.19 

Third, MBN has not yet comprehensively outlined its challenges or 

developed a strategic approach for how it plans to address its key 

challenges to broadcasting in the Middle East. While MBN is planning to 

expand its broadcast operations into Europe, it has not clearly identified 

how its broadcasts will meet competitive challenges in the Middle East. As 

an example, MBN has not indicated how it will address the implications of 

the upcoming BBC Arabic-language television initiative. The BBC could 

gain a significant audience that potentially would interfere with Alhurra’s 

market share, credibility, and use as a source of alternative information.20 

19With the exception of the Baghdad bureau, MBN has not developed an approach for 

maximizing the use of its existing overseas bureaus and offices for Alhurra’s news 

operations. MBN’s Dubai production center, for example, currently only produces a few of 

Alhurra’s current affairs shows.

20Some MBN officials have expressed concern that the BBC’s favorable programming library 

and licensing arrangements could potentially interfere with Alhurra’s ability to secure 

critical acquired programming content. A singificant proportion (or 35 percent) of Alhurra’s 

content is acquired programming.
Page 20 GAO-06-762 U.S. International Broadcasting

MBN Has Made 

Progress in Developing 

Internal Control, but 

Additional Steps Could 

Improve Its Control 

Structure

MBN was initially limited in developing its internal control structure 

because it was focused on quickly starting up its broadcasting operations. 

In response to an external review of its financial operations by Grant 

Thornton LLP in May 2004, MBN strengthened several of its controls, after 

which it received an unqualified opinion on its Fiscal Year 2005 Single 

Audit.21 However, MBN has not fully implemented several of the Grant 

Thornton review’s key recommendations related to its control 

environment,22 including (1) establishing an internal control board to 

formally develop its controls and coordinate audits, (2) preparing an 

internal control plan, (3) conducting a risk assessment to address potential 

risks to its operation, and (4) developing a training program for its staff. 

MBN Faced Initial 

Challenges in Developing Its 

Internal Control Structure

Internal control refers to the policies and procedures that help ensure the 

proper management and application of an organization’s assets. Clear, 

strong controls can provide some assurance that management problems 

are unlikely to occur or will be addressed if they do occur. MBN’s internal 

control is governed by several OMB circulars cited in its grant agreement.23 

21MBN is required to undergo a Single Audit annually to comply with OMB Circular No. A133, which is included as a requirement in MBN’s grant agreement with the BBG. All 

nonfederal entities that expend $500,000 or more of federal awards in a year are required to 

obtain an annual audit in accordance with the Single Audit Act Amendments of 1996. The 

Single Audit provides information on whether MBN’s financial statements fairly present the 

organization’s financial situation; whether MBN is maintaining internal control over its 

federal program; whether MBN is complying with relevant laws, regulations, and provisions 

of its grant agreement; whether there are any audit findings or questioned costs; and 

whether corrective action plans have been established. The A-133 audit has several 

components, including (1) an opinion on the organization’s financial statements; (2) a report 

on internal control; (3) a report on compliance with laws and regulations, and the provisions 

of the grant agreement; and (4) a schedule of findings and questioned costs. It also requires 

a corrective action plan that describes how the auditee will address findings.

22The control environment includes the tone that an organization’s management and 

employees set toward internal control and conscientious management.

23MBN’s grant agreement requires compliance with the following OMB circulars: Circular 

No. A-110, Uniform Administrative Requirements for Grants and Agreements with 

Institutions of Higher Education, Hospitals and Other Non-Profit Organizations, which 

covers administrative requirements for grants to nonprofit organizations; OMB Circular No. 

A-122, Cost Principles for Non-Profit Organizations, which covers cost principles for 

nonprofit organizations; and OMB Circular No. A-133, Audits of States, Local Governments, 

and Non-Profit Organizations, which covers audits of states, local governments, and 

nonprofit organizations.
Page 21 GAO-06-762 U.S. International Broadcasting

The Comptroller General’s Standards for Internal Control in the Federal 

Government24 also provides guidance that is available to MBN. 

MBN faced some initial challenges in establishing its internal control 

structure. According to MBN documents and officials, MBN management 

initially focused on establishing broadcasting operations rather than the 

development of internal control policies and procedures, because the 

organization had only several months to plan the launch of its 24-hour a day 

Alhurra television network. As a result, MBN’s internal control lagged 

behind. The MBN chief financial officer (CFO) told us that problems 

encountered by MBN in hiring and retaining staff added to the delay in 

developing internal controls. 

Due to concern over the slow development of MBN’s internal control 

structure, the BBG commissioned a review by Grant Thornton LLP 

accountants and management consultants, which was completed in spring 

2004, to assess MBN’s internal control and make recommendations for 

improvement. The report by Grant Thornton LLP cited numerous findings, 

such as inadequate financial policies and procedures, understaffing, and 

inadequate training, that impeded MBN’s ability to successfully mitigate 

risks.25 The report, however, also noted that MBN’s controls were 

improving. 

MBN Has Made Progress in 

Developing Its System of 

Internal Control, but Some 

Control Elements Could Be 

Improved

Grant Thornton’s May 2004 report on MBN’s system of internal control 

made recommendations that covered staffing, MBN’s financial system, 

training, administrative policies and procedures, developing a decision 

support structure, improving logs and records, and MBN’s control 

environment. MBN accepted the review’s recommendations and agreed to 

implement them, according to MBN officials, and the BBG concurred with 

these recommendations. Our analysis shows that MBN subsequently 

responded to many of the recommendations, including hiring additional 

financial department staff, developing financial and administrative policies 

and procedures, and completing an annual single audit (see table 1). For 

example, although MBN provided us with copies of its Fiscal Year 2003 and 

24GAO, Standards for Internal Control in the Federal Government,GAO/AIMD-00-21.3.1 

(Washington, D.C.: November 1999).

25Grant Thornton LLP, Status of Funds and Internal Control Report with Analysis and 

Recommendations for Middle East Television Network (MTN), May 28, 2004.
Page 22 GAO-06-762 U.S. International Broadcasting

Fiscal Year 2004 Single Audits well past the deadlines for completing those 

audits,26 MBN’s Fiscal Year 2005 Single Audit was completed on time, 

provided an unqualified opinion, and showed marked improvement over 

previous years.27

Table 1: Actions taken by MBN to Address Grant Thornton’s Internal Control Recommendations

26MBN’s Fiscal Year 2003 and 2004 Single Audits were due June 2004 and 2005, respectively. 

MBN officials stated that the auditors were not able to provide us with the finalized audits 

until May 2006 because they were not yet completed due to staffing and time constraints. 

OMB Circular No. A-133, Subpart C, .320, notes that the audit shall be completed and 

submitted within the earlier of 30 days after receipt of the auditor’s report (s), or 9 months 

after the end of the audit period, unless a longer period is agreed to in advance by the 

federal agency that provided the funding. 

27In particular, (1) the auditors provided an opinion that MBN’s fiscal year 2005 financial 

statements fairly presented MBN’s financial position; (2) in its consideration of MBN’s 

internal control over financial reporting, the auditor did not find any material weaknesses; 

(3) the auditor’s tests did not reveal any instances of noncompliance with relevant laws, 

regulations, contracts, and grant agreements, nor did it find any material weaknesses in 

internal control over compliance with regard to the controls that they tested; and (4) the 

auditor found that all of the findings raised in the Fiscal Year 2004 Single Audit had been 

addressed. These findings included undocumented policies and procedures; inadequate 

training; improperly recorded, accounted, and executed transactions; a lack of assurance 

that assets were safeguarded against loss; a lack of periodic, formal account reconciliation 

and analysis; a failure to review entries in MBN’s financial information system; lack of 

control over payroll; and lack of compliance with equipment and property management 

requirements. 

Recommendation Status of implementation

Hire additional staff for the financial department Completed: New vice president for finance and administration hired in August 2004. 

According to MBN, the organization now has 16 financial staff, compared to the 6 who 

were working there when the assessment was conducted 

Acquire suitable financial information system Completed: MBN acquired a new enterprise resource planning system (DeltekCostpoint) in October 2004 that has enhanced its ability to manage its finance 

department.

Enhance and expand MBN’s financial and 

administrative policies and procedures 

Completed: Developed policies and procedures that lay out roles and responsibilities. 

Improve procurement and travel logs and records Completed: MBN’s CFO told us that MBN improved its procurement logs and 

records. In addition, MBN has hired a travel analyst who keeps a monthly log of travel 

orders and vouchers.

Develop a system for providing timely and 

focused financial information to senior 

management

Completed: The finance department provides MBN high-level management with a 

detailed financial package on a monthly basis..
Page 23 GAO-06-762 U.S. International Broadcasting

Source: GAO analysis of information provided by Grant Thornton LLP and MBN.

Some control elements could be improved in order to better implement 

best management practices based on OMB circulars and GAO internal 

control standards. For example, although MBN is establishing an internal 

control board, the board has not met to establish protocols and outline its 

responsibilities. The organization also has not developed an internal 

control plan. Furthermore, MBN has not established a comprehensive 

process to analyze risks the organization faces from internal and external 

sources. Finally, MBN has provided some training on internal control but 

has not yet developed a regular structured training program for its staff.28

MBN’s Internal Control Board 

Has Not Met to Establish 

Protocols to Develop and 

Monitor Its Internal Control 

Structure

The Grant Thornton review recommended that MBN establish an internal 

control board of key managers and officers to determine the internal 

control risks facing MBN, work towards decreasing these risks, and 

oversee MBN’s efforts to employ strong controls. Moreover, according to 

GAO guidance,29 organizations should have an audit committee or senior 

management council–similar to an internal control board–that reviews the 

internal audit work and coordinates closely with external auditors.

According to the MBN president, MBN is establishing an internal control 

board consisting of three members, including, as recommended, the MBN 

president, general counsel, and CFO. However, the board has not yet 

Undertake and complete an annual audit as 

required by OMB Circular No. A-133

Completed: Completed in late May 2006. MBN’s Fiscal Year 2003 and Fiscal Year 

2004 Single Audits under Circular No. A-133 were not released within established 

deadlines. MBN’s Fiscal Year 2005 Single Audit was completed on time.

Establish an internal control board Partially Addressed: MBN’s internal control board is not yet operational.

Prepare an internal control plan Not Completed: Not done as of May 2006.

Conduct an MBN-wide internal control risk 

assessment

Partially Addressed: Preliminary risk assessment did not identify objectives, identify 

risks, analyze the possible effects of the risks, or propose a strategy to mitigate them. 

This document merely contains a list of completed actions addressing the issues 

raised in the Grant Thornton LLP report.

Provide training on MBN’s internal control 

processes

Manage training by establishing an internal 

control board

Partially Addressed: MBN has provided some training on internal control, but has not 

yet developed a regular training schedule and training is not managed by an internal 

control board.

(Continued From Previous Page)

Recommendation Status of implementation

28GAO-01-1008G.

29GAO-01-1008G.
Page 24 GAO-06-762 U.S. International Broadcasting

formally met to establish protocols and outline responsibilities. In addition, 

according to MBN’s general counsel, MBN has not appointed a member 

from the BBG, as was recommended, to serve on the board. MBN’s 

executive committee, which examines issues affecting MBN and reports 

back to the BBG, has provided some support on management and 

administrative issues, such as approving the construction and expansion of 

MBN’s new facility and providing guidance on hiring high-level staff.30 

However, the committee has not fulfilled the role of an internal control 

board as previously described. Instead, MBN’s CFO has largely taken on the 

sole responsibility of establishing and overseeing MBN’s controls, 

reviewing audits, and coordinating with external auditors. The MBN 

president told us that they have not convened an internal control board 

because the organization is too new and, therefore, is focused on 

developing policies and procedures rather than mechanisms to review 

them. MBN is planning to develop an internal audit function, implemented 

by an external firm, to provide assurance to MBN management that the 

organization is operating appropriately. 

MBN Has Not Completed an 

Internal Control Plan

According to the Grant Thornton review, MBN should develop an internal 

control plan to ensure that effective controls are established and monitored 

regularly. Such a plan should identify the roles and responsibilities of all 

individuals whose work affects internal control, lay out specific control 

areas, cover risk assessment and mitigation planning, and include 

monitoring and remediation procedures. MBN officials told us in January 

2006 that they were in the process of developing such a plan and have 

developed internal control guidelines, but as of the end of May 2006, they 

had not provided us with a finalized plan. 

MBN Has Not Established a 

Comprehensive Process to 

Analyze Risk 

The Grant Thornton review called on MBN to conduct a broad risk 

assessment, led by its internal control board, to evaluate and mitigate 

potential obstacles to efficiently and effectively achieving its operational 

objectives. According to Grant Thornton LLP, failure to conduct an MBNwide risk assessment could result in the loss of resources and could 

decrease confidence of the grantor and of Congress, which could 

ultimately compromise MBN’s achievement of its mission. According to 

GAO guidance, risks should be identified during both short- and long-term 

forecasting and as part of strategic planning. Moreover, after conducting a 

risk assessment, organizations need to develop internal control activities to 

30The BBG Middle East Committee is authorized to approve all actions or expenditures 

requiring the approval of MBN’s board of directors between board of directors’ meetings.
Page 25 GAO-06-762 U.S. International Broadcasting

manage or mitigate the risks that have been identified. For example, Radio 

Free Asia identified avian influenza and signal jamming from China as two 

threats to their operations. As part of their risk assessment, they 

considered how to address and overcome these issues, such as by 

broadcasting from alternate locations.

In February 2005, MBN prepared an initial risk assessment that identified a 

list of actions taken to address the issues raised in the Grant Thornton LLP 

report. However, the document did not identify the organization’s 

objectives or the risks it faces, nor did it analyze the possible effects of the 

risks or propose a strategy to mitigate them, as recommended by GAO 

guidance. MBN officials told us that they assess risk on an ongoing, 

biweekly basis. However, in taking a short-term approach to analyzing risk, 

MBN lacks a comprehensive basis from which to establish a strong internal 

control structure. Some risks identified by MBN include threats to the 

security of its staff and bureaus in the field, particularly in Iraq, and the risk 

of a terrorist attack on its facilities in the United States. There are some 

risks that MBN has not identified or addressed. For example, 

PriceWaterhouseCoopers, MBN’s external auditor, noted that MBN has not 

adequately addressed its risks related to information security. Doing so 

would reduce the risk of security incidents and unauthorized system 

activity, according to the auditor. PriceWaterhouseCoopers also found that 

MBN’s lack of a business continuity plan or an adequate disaster recovery 

plan could result in slower recovery in the case of such an event, as well as 

significant loss of revenue, inability to meet customer needs and third party 

obligations, and potential noncompliance with legal requirements. The 

internal audit function planned by MBN may at some point take on the 

function of assessing risk, but this body is not yet operational. 

MBN Has Not Developed a 

Comprehensive Training 

Program on Internal Controls

MBN has provided some training on internal controls but has not yet 

developed a regular structured training program for its staff of about 240, 

as recommended by the Grant Thornton LLP review and by GAO leading 

practices.31 MBN’s CFO and controller attended a seminar on grants 

management in October 2004 and subsequently shared the information 

with the 16 in-house financial staff. MBN also provided internal control 

compliance training to its managers in December 2004, and the 

organization regularly provides training to staff at its business manager 

meetings. However, other U.S. broadcasting entities, such as Radio Free 

Europe/Radio Liberty (RFE/RL) and Radio Free Asia (RFA), have more 

31GAO-01-1008G.
Page 26 GAO-06-762 U.S. International Broadcasting

organized, ongoing training programs on internal control. The MBN CFO 

concurred that there is a great need for internal training. According to him, 

the underdeveloped training situation is due to a lack of resources, 

including a lack of funds specifically designated for training and limited 

time to plan or implement training. This lack of structured, recurrent 

internal control training can cause problems if staff are unfamiliar with an 

organization’s business processes and controls, and can lead to the 

inefficient or improper use of resources. 

MBN Has Developed 

Editorial Procedures to 

Support Its Journalistic 

Standards, but Could 

Improve Monitoring 

and Some Quality 

Control Measures

MBN has established journalistic standards, as well as procedures to help 

ensure that the organization’s broadcasts comply with these standards. 

However, it has not fully developed some quality control measures, such as 

the use of listener and viewer feedback. Additionally, the BBG has not held 

regular comprehensive program reviews for MBN, thereby making it 

difficult for MBN to assure its audience, Congress, the administration, and 

the BBG that its controls are working and that it is broadcasting quality 

programming.

MBN Has Developed 

Journalistic Standards and 

Implemented a Wide Variety 

of Pre- and Postbroadcast 

Editorial Procedures

The International Broadcasting Act of 199432 calls for U.S. international 

broadcasting to be conducted in accordance with the highest professional 

standards of broadcast journalism, including the production of news that is 

consistently reliable, authoritative, accurate, and objective. The act also 

calls for U.S. international broadcasting to present a balanced and 

comprehensive projection of U.S. thoughts and institutions, as well as clear 

and effective presentation of U.S. government policies and responsible 

discussion of those policies. MBN’s mission statement, which partly draws 

upon the principles and standards contained in the U.S. International 

Broadcasting Act of 1994, calls for MBN to broadcast factual, timely, and 

relevant news and information that promotes freedom and democracy. 

MBN has developed journalistic standards, including a code of ethics, as 

part of its effort to ensure that its news broadcasts are consistently 

accurate, authoritative, objective, balanced, and comprehensive. MBN’s 

general counsel said that the code was also established to ensure that MBN 

32P.L. 103-236.
Page 27 GAO-06-762 U.S. International Broadcasting

fully complies with its mission and the U.S. International Broadcasting Act 

of 1994. MBN’s journalistic standards were drafted by MBN management 

using input from professional journalistic organizations and another 

grantee. According to BBG officials, MBN’s standards appear to be as good 

as those of other U.S. international broadcasters. In our analysis, we found 

that the standards cover areas similar to the codes of other broadcasters--

such as RFE/RL, RFA, Voice of America (VOA), and National Public Radio--

focusing on accuracy, impartiality, establishing context, clearly 

distinguishing analysis from reporting, using a tone of moderation and 

respect, avoiding advocacy, and promoting ethical conduct. The standards 

also include guidelines for conducting interviews, as well as editing and 

production requirements. For example, according to MBN officials, MBN 

strives to present opposing views accurately and achieve a balance among 

the guests on its current affairs shows. According to MBN officials, when 

broadcasting about the war in Iraq, they try to ensure that the program 

incorporates both pro-war and antiwar views. 

To help ensure that staff comply with MBN’s journalistic standards, Radio 

Sawa and Alhurra have established a number of pre- and postbroadcast 

procedures, which are roughly similar to those of other U.S. international 

broadcasting entities. Examples of MBN editorial procedures include daily 

editorial meetings, the use of two or more sources to support a news item, 

checks by editors and producers to determine whether news stories are 

properly written and accurate, a headquarters-level review of all materials 

produced in MBN’s overseas offices before broadcast,33 and postbroadcast 

discussions. In addition, we observed that MBN employs an experienced 

journalist from the Arab world to review all of Alhurra’s and Alhurra-Iraq’s 

weekday newscasts for technical and stylistic errors, a control not 

implemented by other U.S. broadcasting entities. The journalist watches 

the newscasts just before they are aired, then provides MBN management 

with an evaluation of the newscast’s quality. MBN provided us with records 

of these evaluations, which assess whether the newscasts are presentable, 

balanced, and free of technical errors. In some cases, technical mistakes 

can be caught before the piece is aired. However, while MBN management 

follows up on critiques of individual journalists, they do not systematically 

review and assess the journalist’s evaluations. 

33The exception is the Dubai office, which produces 8 hours of Radio Sawa programming 

during the daytime hours in the Middle East.
Page 28 GAO-06-762 U.S. International Broadcasting

MBN officials told us that the organization places a high value on 

journalistic controls, particularly due to the volatility of certain areas in the 

Middle East and the impact news reports can have. In addition, MBN’s 

controls can serve as an assurance to its audiences and others that they are 

broadcasting quality programming. Since Radio Sawa and Alhurra were 

established, MBN has not had to retract a single story or apologize for any 

error, according to MBN officials. 

MBN Could More Fully 

Develop Some Quality 

Control Measures and Lacks 

Regular Editorial Training

There are several areas in which MBN could more fully develop some 

quality control measures for its programming. These areas include using 

listener and viewer feedback to improve program quality, making better use 

of weekly compilations, and ensuring its style guide is distributed to all 

staff. Unlike other U.S. international broadcasters, MBN typically only 

partially utilizes the following measures:

• Although MBN collects feedback from its listeners and viewers, it does 

not rely extensively on this feedback as a program quality control. 

• Although MBN produces weekly compilations that are distributed to 

interested parties summarizing what was broadcast on Radio Sawa and 

Alhurra that week, it does not use these compilations to do any formal, 

long-term analysis of errors and programming. 

• MBN has developed a style guide to provide critical guidance on the use 

of sensitive terms and to help staff avoid grammatical mistakes. 

However, Radio Sawa staff did not receive the guide until early 2006, 

and MBN has not distributed it to all of its overseas offices, inhibiting its 

use by some staff. 

In addition, MBN has not provided regular training to its journalists and 

producers. MBN told us that it does not provide regular training to help its 

editorial staff maintain and increase their professional competence. MBN’s 

level of training for its editorial staff is also not on a par with the training 

offered by other grantees. For example, RFE/RL and RFA both have 

extensive training programs for their employees at their headquarters and 

in their bureaus in different countries, according to RFE/RL and RFA 

officials. While MBN provides some initial technical training to its 

journalists, an informal mentoring program, and sporadic training 

overseas, according to MBN officials, the organization does not have an 

ongoing training program to educate journalists throughout the 

organization about editorial and ethical issues they might encounter on the 
Page 29 GAO-06-762 U.S. International Broadcasting

job. According to the MBN CFO, the organization does not have a wellestablished training program because the network is relatively new and 

lacks training resources. MBN officials have also noted that their most 

important controls are the editors themselves, and that MBN tries to hire 

experienced staff. However, regardless of experience, staff can and do 

make mistakes, and MBN’s lack of regular training increases the risk that 

correspondents and editors will make mistakes. 

MBN Lacks Comprehensive, 

Regular Program Reviews to 

Determine Compliance with 

Mission and Journalistic 

Standards

The BBG’s main mechanism to determine whether its broadcasting services 

comply with its mission and journalistic standards is a regular program 

review, which is designed to improve programming and ensure quality 

control. However, only one review has been conducted for Radio Sawa, and 

none have been conducted for Alhurra. The Radio Sawa review was more 

limited in scope than program reviews conducted by other entities. In 

addition, Radio Sawa’s program quality score is inconsistent with other 

BBG entities, and without a program review to develop a program quality 

score for Alhurra, the BBG will not be able to measure the contribution of 

these efforts to the goals of the organization, or be able to ensure that the 

quality of Alhurra’s broadcasts conforms to applicable standards. Finally, 

many MBN staff were not extensively involved in the Radio Sawa review. 

Annual Program Reviews Have 

Not Been Conducted for MBN’s 

Services 

According to written guidance from the International Broadcasting Bureau, 

which coordinates and supports all VOA program reviews, program review 

is an annual process by which an institution judges itself and solicits the 

judgment of others to make improvements and fulfill its mission with 

regard to U.S. national interests. The process enables the broadcasting 

entity to better connect its mission to the market where it is broadcasting 

and assess whether its editorial procedures are functioning effectively, 

while also allowing the BBG to fulfill its requirements from OMB that it 

conduct regular program evaluations to capture a program’s impact over 

time. In addition, the Senate Committee on Foreign Relations Report on the 

Fiscal Year 2003 Foreign Relations Authorization Act called for significant 

resources to be dedicated to postbroadcast analysis of Radio Sawa 

programming to ensure that broadcasts are consistent with U.S. interests 

and values and with the standards in the U.S. International Broadcasting 

Act. Program review typically includes a study of the target area’s media 

environment, analyses by internal and external reviewers, background 

quantitative research, reports on marketing and transmission, and target 

area profiles compiled by the broadcaster itself. Reviewers rate programs
Page 30 GAO-06-762 U.S. International Broadcasting

based on criteria34 for content--such as accuracy, timeliness, objectivity, 

relevance, and quality of analysis and interviews--and for presentation, 

such as pace and liveliness, presentation style, sound quality, and host 

interaction. These inputs are then discussed at a meeting that includes the 

program review coordinators and the management and staff of the entity 

being reviewed. Following the main program review meeting, key 

participants develop an action plan, and 3 months later the group meets 

again to determine to what extent the action plan has been carried out.

Although the BBG calls for program reviews to be conducted annually, 

MBN has not complied with this guidance. Neither the BBG nor MBN has a 

regular mechanism in place to systematically review MBN programs. In 

December 2004, the BBG convened a program review meeting for Radio 

Sawa, which had begun operating in March 2002. However, there has been 

no Radio Sawa review since then, while Alhurra, which has been operating 

for more than 2 years, has had no program review at all. The BBG is 

planning to initiate a program review of Alhurra by the end of this year, but 

has not set a firm date. 

Radio Sawa’s Program Review 

Was Limited by Its Emphasis on 

Audience Input

BBG officials have stated that program quality should be sampled and 

assessed by both internal and external evaluators.35 This is designed to 

produce a balanced and robust review.36 In 2000, in response to our report 

that found a lack of consistency in how program quality scores were 

developed, the BBG stated that it intended to harmonize and standardize

34These program quality criteria are used in program reviews of VOA and RFE/RL 

broadcasters, while RFA applies broadly similar criteria. The Radio Sawa program review 

applied them as well, with the exception of “length of individual items,” among others. The 

Radio Sawa audience panels also used music quality criteria, including selection of music, 

variety of music, uniqueness of music, balance in types of music, length of individual songs, 

transitions between songs, transitions between music and other segments, and overall 

appeal of music. 

35Internal reviewers, who measure a service’s content and production standards against its 

journalistic standards and the program quality criteria, tend to be International 

Broadcasting Bureau program analysts or grantee staff. External reviewers include 

audience monitoring panels consisting of a number of regular listeners or viewers, as well as 

control listeners. Control listeners are language-qualified and are knowledgeable about 

target country politics and culture, but are usually located in the United States or other 

Western countries and are not affected by politics on the ground. 

36The internal analysts, audience monitoring panels, and external control listeners develop 

their own program quality scores, which feed into the BBG standard program quality score, 

a performance indicator.
Page 31 GAO-06-762 U.S. International Broadcasting

program reviews across broadcasting entities.37 BBG guidance now calls 

for all U.S. international broadcasting entities to be evaluated using the 

same standards, definitions, and scoring methods. 

However, when conducting the Radio Sawa program review, the BBG relied 

only on audience monitoring panels to assess program quality and did not 

utilize internal analysts or external control listeners, as is common practice 

among other U.S. international broadcasters. Using only audience 

monitoring panels gives the audience more weight in the review results 

and, in turn, more potential to influence the strategic direction of the 

organization. In addition, since the audience tends to be unfamiliar with a 

broadcasting service’s journalistic standards and editorial procedures, 

having input only from monitoring panels makes it more difficult for a 

service to provide reasonable assurance that its editorial procedures are 

working and that it is broadcasting quality programming. Also, external 

control listeners are specifically tasked with examining the programming in 

light of the service’s mission, something audience monitoring panels are 

not asked to do. As a result, Radio Sawa’s program review strongly 

emphasized the audience’s perspective and therefore provided a less 

thorough evaluation of Radio Sawa’s mission and standards. (For more 

information on Radio Sawa’s program review, see appendix III.)

Radio Sawa’s Program Quality 

Score Is Inconsistent with Other 

BBG Entities

Furthermore, MBN’s program score for Radio Sawa is not comparable with 

other BBG broadcaster scores for program quality--the percentage of a 

station’s language services judged on both content and presentation criteria 

as being of good-or-better quality. The BBG says that to measure Radio 

Sawa’s program quality, it has developed standardized criteria applicable to 

different media and methods of delivery, while minimizing subjective 

judgments on content and presentation. Although the criteria used to 

measure Radio Sawa’s program quality are similar to those used by other 

broadcasting entities, the BBG did not use as many inputs when calculating 

the program quality scores for Radio Sawa, leading to a less robust result 

(see table 2). 

37In 2000, in response to our report that found a lack of consistency in how program quality 

scores were developed, the BBG stated that it intended to harmonize and standardize 

program reviews across broadcasting entities. See U.S. International Broadcasting: 

Strategic Planning and Performance Management System Could Be Improved,

GAO/NSIAD-00-222 (Washington, D.C.: Sept. 27, 2000).
Page 32 GAO-06-762 U.S. International Broadcasting

Table 2: Inputs to Program Quality Scores for BBG Broadcasting Entities

Sources: BBG, International Broadcasting Bureau, RFE/RL, RFA.

Without a consistent process for broadcaster program reviews, the BBG is 

limited in its ability to assess and compare broadcaster performance. In 

addition, without a program review to develop a program quality score for 

Alhurra, the BBG will not be able to measure the contribution of these 

efforts to the goals of the organization, or be able to ensure that the quality 

of Alhurra’s broadcasts conforms to applicable standards. Currently, the 

BBG is considering how it will conduct the future program reviews for 

Radio Sawa, but officials could not yet provide specifics about the 

approach BBG will use. 

MBN Staff Had Limited 

Awareness of the Radio Sawa 

Program Review and Follow-up

MBN staff in the United States and overseas do not appear to have much 

knowledge of the Radio Sawa review or its follow-up. Program review can 

be a learning experience for staff, who are usually encouraged to sit in on 

their language service’s program review meeting, and the process can also 

bring people together who normally do not interact, which can help 

generate ideas and improvements. However, according to MBN 

management, most Radio Sawa staff did not attend the Radio Sawa 

program review. In addition, there was also not much awareness about the 

program review in MBN’s overseas offices. 

While Radio Sawa staff lacked awareness about their review, some staff 

who had worked at VOA in the past spoke positively of the program review 

process in general. Other broadcasters routinely involve staff in their 

Broadcaster Program review input

Percentage of total 

program quality 

score

MBN (Radio Sawa) Monitoring panels 100

RFE/RL Internal analysis 45

Monitoring panels 35

External experts 20

RFA Internal analysis 45

Monitoring panels 35

External experts 20

VOA Internal analysis 45

Monitoring panels 35

External experts 20
Page 33 GAO-06-762 U.S. International Broadcasting

program reviews. For example, RFA requires all staff from the service that 

is being reviewed to be present at the program review meeting. According 

to an RFA official, program review is one of the few times that all of the key 

players for a service are in one place, and it therefore presents a good 

opportunity for communication. In addition, a BBC official noted that 

program review can be a good way to expose staff to an organization’s 

values. Increasing staff involvement in program review could therefore 

increase chances for communication throughout all levels of the 

organization, as well as provide a forum for discussing potential 

programming improvements.

BBG Has Developed 

Several Performance 

Indicators, Although 

Weaknesses in 

Audience Surveys Call 

into Question Whether 

MBN Audience Size 

and Credibility Targets 

Have Been Met 

The BBG has established several standard performance indicators and 

targets for MBN programs, including measures of audience size and 

credibility; however, it has not implemented some performance indicators 

fully, including a program quality measure. Additionally, we were unable to 

determine the accuracy of MBN’s audience size and program credibility 

estimates due to weaknesses in MBN’s methodology and documentation. 

Therefore, it is not clear whether the Radio Sawa and Alhurra performance 

targets have been met.

MBN Performance 

Indicators and Targets Have 

Been Established, but Some 

Are Not Fully Developed 

The Government Performance and Results Act of 1993 (GPRA) requires 

that all government agencies establish performance indicators, or 

measures, that provide a meaningful reading of how well the organization 

is progressing towards its goals. The BBG has developed a standard set of 

performance indicators for its broadcasting entities, which it says are a 

best effort to measure its level of effectiveness now and where its 

performance is targeted to be in the future. The BBG established common 

indicators for its entities to allow it to better assess overall progress for the 

organization. Although the BBG has made progress in establishing these 

standard performance indicators, as well as targets for MBN’s programs, it
Page 34 GAO-06-762 U.S. International Broadcasting

has not formally established or implemented all of them for Radio Sawa 

and Alhurra.38 

According to BBG, the three most important standard indicators for its 

entities, referred to as primary performance indicators, are (1) audience 

size, or the overall weekly audience of a station; (2) credibility, which 

represents the percentage of viewers in a target area that consider the 

station’s news programs somewhat or very reliable; and (3) program 

quality, or the percentage of a station’s programs judged on standard 

criteria as being of good-or-better quality. These three indicators are tied to 

the current BBG mission and strategic plan for U.S. international 

broadcasting.39 In addition to its standard primary performance indicators, 

the BBG has a number of “secondary” measures that provide management 

with additional information for gauging cost- effectiveness, marketing and 

promotion activities, and transmission efforts, including the number of 

transmitters and affiliates, cost per listener, signal strength (radio only), 

and awareness.

The BBG has established and implemented two primary indicators–

audience size and credibility--for both Radio Sawa and Alhurra.40 The BBG 

has also established performance targets for Radio Sawa and Alhurra for 

these two indicators. For example, MBN’s reported fiscal year 2005 

audience size performance target for Radio Sawa was 18 million listeners 

and for Alhurra was 12.8 million viewers.41 However, the BBG has not yet 

established Alhurra’s program quality indicator, or consistently 

implemented this measure for Radio Sawa. Without a measure of program 

quality for Alhurra and Radio Sawa, the BBG will not be able to 

consistently assess MBN’s performance against that of other grantees, or 

fully assess MBN’s contribution to the overall goals of the BBG 

organization. The BBG has established all of its standard secondary 

performance indicators for MBN’s services except for audience 

38The BBG sets performance indicators and targets for Alhurra and Radio Sawa separately, 

rather than for the MBN organization as a whole.

39The U.S. International Broadcasting Act of 1994 requires that the BBG ensure that the 

quality of the broadcasts conforms to applicable standards and reaches significant 

audiences.

40The performance indicators for Alhurra include Alhurra-Iraq.

41The BBG’s reported program credibility target for fiscal year 2005 for Radio Sawa was 69 

percent and for Alhurra was 73 percent.
Page 35 GAO-06-762 U.S. International Broadcasting

awareness.42 See table 3 for a list of the performance indicators 

implemented for Alhurra and Radio Sawa.

Table 3: BBG’s Standard Performance Indicators and MBN’s Status

42We have previously recommended that the BBG measure awareness and reported that the 

information necessary to generate the measure of audience awareness is already collected 

in national surveys. See GAO, U.S. International Broadcasting: New Strategic Approach 

Focuses on Reaching Large Audiences but Lacks Measurable Program Objectives, GAO-03-

772 (Washington, D.C.: July 15, 2003).

Indicator type

BBG performance 

indicator name Definition

Source of data used to 

calculate measure

Current Alhurra 

performance 

indicator 

Current Sawa 

performance 

indicator 

Primary

indicators

Audience size (also 

called overall weekly 

audience)

Total number of all adults 

listening or viewing a 

service’s programming at 

least once a week in target 

areas

This figure is calculated by 

the office of research and is 

an estimate derived from 

audience surveys and 

estimates of national 

population. 

Yes Yes 

Credibility Percentage of total estimated 

weekly viewers/listeners in 

target areas that determined 

the reliability of news and 

information of the station to 

be somewhat or very reliable

This figure is calculated by 

the office of research and is 

an estimate derived from 

the results of audience 

surveys and estimates of 

overall weekly audience. 

Yes Yes

Program quality Percentage of a station’s 

language services whose 

programming is assessed as 

being of good-or-better 

quality

This figure is calculated by 

the office of strategic 

planning and performance 

management. For Radio 

Sawa, this figure is 

determined by scoring from 

a monitoring panel of 

regular listeners using 

predefined criteria for 

content and presentation. 

No Yes
Page 36 GAO-06-762 U.S. International Broadcasting

Source: GAO and BBG.

BBG Should Increase Steps 

to Ensure Reliability and 

Transparency of Its 

Performance Estimates

We and others have noted that agencies’ performance indicators and data 

should provide a reliable means to assess progress. However, we were 

unable to determine the accuracy of MBN’s reported audience size and 

program credibility estimates due to weaknesses in MBN’s methodology 

and documentation. Therefore, it is not clear whether the Radio Sawa and 

Alhurra performance targets have been met. While BBG has taken several 

important steps to ensure the validity and reliability of its performance 

measurement approach, it has primarily used a methodology that cannot be 

reliably projected to the broader population. Although it is difficult to 

conduct probability sampling in many locations in the Middle East, the 

BBG has not taken steps to explain and increase the reliability of MBN’s 

performance information, such as by maintaining more detailed 

documentation to support its estimates, reporting significant data 

limitations, limiting the scope of its projections to areas actually covered 

by its surveys, and developing BBG policies and procedures for verifying 

performance data. 

Secondary 

indicators

Awareness Percentage of adults in the 

target area that have 

prompted and unprompted 

awareness of the station

This figure is calculated by 

the office of research and is 

an estimate derived from 

the results of audience 

surveys and estimates of 

overall weekly audience.

No No

Affiliations and 

transmitters 

Total number of affiliates that 

regularly rebroadcast 

identified programs on 

competitive media and 

number of owned and 

operated local transmitters

This figure is calculated by 

the office of marketing and 

program placement using 

affiliates data and the office 

of engineering using 

transmitter data

Yes Yes 

Signal strength Quality of radio signal 

monitored and rated on a 

scale of nil to excellent

This figure is calculated by 

the office of engineering 

using data sampled 

periodically from overseas 

monitoring stations.

N/A Yes 

Cost per listener Budget divided by weekly 

audience

This figure is calculated by 

BBG’s office of strategic 

planning and performance 

management using budget 

data and audience size 

figures.

Yes Yes 

(Continued From Previous Page)

Indicator type

BBG performance 

indicator name Definition

Source of data used to 

calculate measure

Current Alhurra 

performance 

indicator 

Current Sawa 

performance 

indicator 
Page 37 GAO-06-762 U.S. International Broadcasting

Measurement and Research 

Methods Should Allow for 

Confidence in Reliability of 

Performance Information

We have previously reported that performance indicators should provide a 

reliable way to assess progress.43 In particular, agencies should implement 

quality control procedures to mitigate errors that can occur at various 

points in the collection, maintenance, processing, and reporting of 

performance data and can impact its reliability. In addition, agencies 

should select sampling methods that ensure representative samples, where 

possible. For example, probability surveys are designed to ensure each 

person in the population has a measurable chance of being selected for the 

survey, enabling the results to be reliably projected to the larger population 

with known levels of precision. Additionally, agency performance reporting 

should provide sources, disclose limitations, and discuss the implications 

of them. Explaining the limitations of performance information--as well as 

actions taken to compensate for low-quality data–can provide context for 

understanding and assessing agencies’ performance and the costs and 

challenges that agencies face in gathering, processing, and analyzing 

needed data.44

The U.S. International Broadcasting Act of 1994 requires the BBG’s use of 

audience research to guide its decisions about its language services. For 

the past 5 years, the BBG has contracted with Intermedia to serve as the 

primary research contractor for the BBG and its broadcasting entities, 

including MBN. Intermedia works with subcontractors, partners, or both 

to gather audience research survey data from citizens in various locations 

overseas. This survey information is used by the BBG to develop estimates 

for MBN and other entities’ audience size and credibility performance 

indictors. For example, for fiscal year 2005, the BBG estimated that Radio 

Sawa and Alhurra had each achieved an audience size of about 21.6 million 

people. Table 4 shows the breakdown of individual survey data reported by 

the BBG.

43GAO, The Results Act: An Evaluator's Guide to Assessing Agency Annual Performance 

Plans, GAO/GGD-10.1.20 (Washington, D.C.: April 1998).

44GAO, Agencies' Annual Performance Plans Under the Results Act: an Assessment Guide 

to Facilitate Congressional Decisionmaking, GAO/GGD/AIMD-10.1.18 (Washington, D.C.: 

February 1998).
Page 38 GAO-06-762 U.S. International Broadcasting

Table 4: BBG’s Reported Audience Size and Credibility Estimates for Radio Sawa and Alhurra, Fiscal Year 2005 

Source: BBG.

a

The BBG originally reported this figure as 55 percent, but later determined that the correct figure was 

79 percent.

b

To develop the regional estimate for audience size, listening/viewing rates are gathered from the 

national surveys and are, in most cases, multiplied by each country’s respective national population 

estimate to obtain a total audience size estimate for each country. For some countries--such as 

Bahrain, Kuwait, Qatar, UAE and Saudi Arabia--the results are projected to nationals and Arab 

expatriate populations only. These estimates are developed for all countries surveyed and then added 

to develop a regional audience figure, which is the service’s overall weekly audience estimate.

c

To develop the regional estimate for credibility, percentage credibility scores are gathered from 

national surveys and multiplied by that country’s audience size estimate to obtain a total number of 

listeners or viewers for a given country that view the station’s news and information as very or 

somewhat reliable. These estimates are developed for all countries surveyed and then used to create a 

weighted average of credibility.

d

The BBG reported in its fiscal year 2007 budget request that its audience size for Alhurra was 21.5 

million.

BBG Has Not Taken Sufficient 

Steps to Ensure Reliability and 

Transparency of Its Performance 

Estimates for MBN

Although the BBG has taken several important steps to enhance the validity 

and reliability of its audience survey designs, several factors call into 

question the accuracy of the data used for BBG’s audience size and 

credibility performance indicators for Radio Sawa and Alhurra. First, we 

observed that, in 12 out of 14 cases, the BBG used nonprobability surveys, 

Country surveyed Year surveyed

Sawa estimated 

audience size

Alhurra estimated 

audience size

Sawa credibility 

rate

Alhurra credibility 

rate

Algeria 2004 N/A 2,466,888 N/A N/A

Bahrain 2005 127,008 132,814 78 86

Djibouti 2003 151,620 N/A N/A N/A

Egypt 2005 4,791,552 2,019,968 82 92

Iraq 2005 8,336,320 6,860,435 63 73

Jordan 2005 965,216 729,120 75 68

Kuwait 2005 299,739 249,612 82 72

Lebanon 2005 68,400 738,720 68 79

Morocco 2005 4,072,455 2,679,367 64 70

Qatar 2004 324,786 N/A 79 N/A

Saudi Arabia 2005 734,928 2,204,784 72 73

Syria 2004 1,468,800 2,661,120 76 60

Tunisia 2005 N/A 676,800 N/A 75

UAE 2005 265,842 138,510 79a 82

Regionwide

fiscal year 2005 

estimateb,c 21.6 milliond 21.6 million 69 73
Page 39 GAO-06-762 U.S. International Broadcasting

which cannot be reliably projected to the broader population, to develop its 

regional estimates for audience size and credibility. While it is difficult to 

conduct probability surveys in hostile environments, such as those in Iraq 

and Saudi Arabia, the BBG did not take certain steps that could have 

increased the accuracy of its estimates and explained their limitations, 

thereby increasing confidence in the data. Therefore, we are unable to 

determine whether MBN actually met its performance targets for fiscal 

year 2005.

BBG has taken several important steps to enhance the validity and 

reliability of its audience survey designs. For example, the BBG’s 

questionnaires are reviewed by multiple parties, and its contractors 

extensively pretest the questionnaires in the field, conduct pilot studies, 

and use throwaway surveys45 for training new subcontractors. In addition, 

the BBG’s contractors exercise quality control when collecting data and 

receiving it from the field, including by conducting preliminary electronic 

testing of the data, among other things. 

However, in 12 of 14 cases, we found the country-level estimates used for 

generating Radio Sawa and Alhurra’s fiscal year 2005 performance 

indicators of audience size and credibility were not based on probability 

survey46 results. Many of the surveys conducted used judgment sampling, a 

form of nonprobability sampling, instead.47 BBG officials told us that its use 

of nonprobability surveys for certain countries is due to either the cultural, 

political, or security situation in those countries, which limits the selection 

of individuals or the geographical areas that can be surveyed.48 In addition, 

the International Broadcasting Bureau director of research stated that in 

45Throwaway surveys are uncounted surveys used in interviews with respondents as a 

training mechanism for the interviewer. The respondents are those individuals who were in 

the population that could have been selected, but were not included in the sample.

46Probability surveys by definition mean that, due to the design of the survey, every person 

in the population has a measurable chance, or probability, of being selected and that, 

subsequently, the survey may be projected to the broader population with known levels of 

precision. 

47ACNielsen typically used sampling techniques where several stages of sampling are 

conducted. In the case of Egypt and Morocco, interviewers used their judgment for 

allocating starting points--the first stage of sampling selection.

48BBG officials acknowledged that social and cultural factors in Saudi Arabia, Kuwait, 

Bahrain, UAE, and Qatar, in particular, place constraints on the ability of any research 

contractor to implement probability sampling.
Page 40 GAO-06-762 U.S. International Broadcasting

many developing countries, existing map and population data is not 

adequate to support pure probability-based sampling. The Conference of 

International Broadcasters’ Audience Research Services, called CIBAR, 

whose standards are specified as a source of guidance for BBG research 

contractors,requires that audience measurement use samples based on the 

principles of random probability and that other sampling methods should 

only be used in cases where, for reasons of practicality or cost, proper 

random samples cannot be used. (See appendix IV for more on the CIBAR 

standards.)

We recognize that many agencies face challenges in collecting credible 

performance data and that, due to security risks and political 

considerations in many Middle Eastern countries, it is not always possible 

to expect BBG to use random samples. However, the BBG did not take 

certain steps that could have explained and increased the reliability of its 

estimates, such as fully documenting its research methods, measuring the 

level of uncertainty surrounding its estimates, disclosing significant 

limitations, limiting the scope of its projections to areas actually covered 

by its surveys, and developing and implementing procedures for verifying 

data. 

First, the BBG and its research contractors were unable to provide us with 

certain documentation commonly required by international broadcasting 

research standards. CIBAR requires that, in all measurement research, the 

sampling methods used and other technical aspects of the survey be both 

fully and accurately described in the project documentation and open to 

independent scrutiny. We asked the BBG and its contractors to provide us 

with detailed documentation–including clear information on sampling 

plans and related assumptions, response rates, and adjustments applied to 

the data to reflect the effects of the survey design–for all 14 of its Middle 

Eastern country surveys used to develop its fiscal year 2005 performance 

indicator estimates. For two cases, the BBG was unable to provide us with 

any survey documentation,49 and for all but one case, the BBG and its 

contractors were unable to provide us all the detailed information we

49Country surveys with no available documentation included Algeria and Djibouti, which 

used data purchased by the BBG from a French commercial source.
Page 41 GAO-06-762 U.S. International Broadcasting

requested.50 BBG officials acknowledged the lack of complete 

documentation in contractor technical reports, and said it was due in part 

to their failure to follow up with the contractors to obtain the details, 

aswell as to the contractors’ general practice of not generating such 

detailed documentation. 

Second, the BBG has not sufficiently measured the level of uncertainty 

surrounding MBN’s performance estimates. CIBAR requires that in all 

measurement research, technical aspects of the survey, including margins 

of error and confidence levels where appropriate, be both fully and 

accurately described in the project documentation. The BBG has not been 

able to measure sampling errors51 for its surveys, in part because it has not 

required contractors to document the information that is needed to 

calculate the sampling errors accurately. Moreover, officials said that it is 

not customary for their contractors to maintain this information. 

Therefore, the BBG only has a rough idea of what the margins of error52

might be for its surveys, further limiting confidence in the reliability of its 

current performance information. One research official told us that he 

believed that the overall margins of error for Radio Sawa and Alhurra’s 

audience size and credibility estimates are large, but said that currently the 

agency cannot accurately calculate them.53 

Third, the BBG lacks transparency in reporting data sources and significant 

limitations affecting MBN’s audience size and credibility performance 

information. In reporting performance data, agencies should provide data 

sources, disclose limitations, and discuss the implications of them. CIBAR 

standards also recommend that proper care be exercised when reporting 

estimates, to ensure that the type of audience covered by the estimate is 

clearly stated and that, at all stages in the calculation and extrapolation 

50We obtained some technical documentation from Intermedia’s subcontractor ACNielsen 

for the following 11 country surveys: Bahrain, Egypt, Lebanon, Qatar, Saudi Arabia, Tunisia, 

Morocco, Jordan, Syria, UAE, and Kuwait. D3 Systems provided us with the requested 

documentation for its research subcontract for Iraq.

51Sampling errors do not reflect the total error of a survey statistic or estimate, which is a 

function of many different features of a given survey.

52The margin of error is a measure, set at a specific confidence level, of the possible 

difference between the sample estimate and the actual population value.

53Officials from the BBG’s research contractor Intermedia said that they have used the 

approach of calculating a rough margin of error of +/- 2.6 percent for all the Middle Eastern 

surveys. 
Page 42 GAO-06-762 U.S. International Broadcasting

process, sources, assumptions, and methods be fully documented and 

available for independent scrutiny. However, the BBG has not sufficiently 

explained the specific methods used for generating estimates for its 

performance indicators, such as the number and names of the countries 

surveyed, methods of sampling used, sources of the population data, and 

basic procedures used to create the estimates. Moreover, the BBG has 

reported only two limitations for MBN performance indicators to date: (1) 

that credibility ratings are highly dependent on volatile political factors; 

and (2) that, depending on political, social, and media conditions, 

measurement of audience size may either be easily attained or impossible. 

However, the BBG has not explained many significant limitations, and their 

resulting implications, on the data reliability of the performance 

information for MBN. The largest identifiable limitations not reported are 

that many of the BBG surveys are not based on probability sampling, cover 

only part of the country, have very low response rates, or have high 

substitution rates; therefore, those results cannot be reliably projected to 

be representative of the larger population.54 In the case of the survey in 

Morocco, we calculated that the survey only covered 35 percent of the 

general population and had a 48 percent substitution rate, but the results 

were projected to represent a broader population. In addition, we 

calculated low response rates for a number of MBN’s surveys; in the case of 

the survey of Egypt, the response rate was about 19 percent. BBG research 

staff explained that their stakeholders to date, including the BBG, have not 

required such a level of detail in reporting, and specifically have not 

required margins of error. However, a discussion on data limitations in 

performance reporting can help decision makers determine their level of 

confidence in the agency’s ability to report on its performance goals and 

indicators and identify actions needed to improve its ability to measure 

performance.

Fourth, we found the BBG has not taken sufficient steps to avoid 

projections to areas outside the population surveyed. For example, the 

elimination of projections to the rural population of Morocco, when only 

urban areas were surveyed, or to those governorates of Jordan not 

contained in the survey, would have resulted in estimates of audience size 

and credibility with fewer limitations for those countries. In addition, BBG 

54CIBAR standards recommend that the proper care be exercised when reporting estimates, 

to ensure that the type of audience covered by the estimate is clearly stated and, at all stages 

in the calculation and extrapolation process, that sources assumptions and methods be fully 

documented and available for independent scrutiny.
Page 43 GAO-06-762 U.S. International Broadcasting

project documentation does not clearly describe what steps have been 

taken to restrict the scope of MBN’s surveys to provinces or areas that have 

sufficient map or population data. Probability sampling projected to those 

areas only would result in more reliable estimates of audience size and 

credibility.

Fifth, we found the lack of verification procedures inhibits assessments of 

BBG’s data quality. Data reliability is increased by the use of verification 

and validation procedures, such as checking performance data for 

significant errors by formal evaluation or audit. However, BBG has not fully 

implemented such procedures or formally documented policies and 

procedures governing its research. BBG officials said they have 

implemented some forms of verification, such as a research director 

review, at various stages of performance data analysis. However, it is not 

clear that the BBG always thoroughly verifies performance indicator 

estimates and calculations used for reporting. For example, we identified 

some errors in internal calculation spreadsheets for performance 

estimates, in official external reporting, and in an informal presentation on 

MBN performance. BBG officials have acknowledged that they need to 

develop policies and procedures and implement more rigorous verification 

of performance data. They said that, as a result of our review, they have 

taken some steps to expand their verification procedures and will 

document those and other research procedures in the BBG’s research 

contract and manual of operations. 

Conclusions MBN was established to broadcast accurate and relevant news and 

information to the Middle East in order to advance freedom, democracy, 

and long-term U.S. interests in the region. MBN’s programs are challenged 

by existing television competitors, such as Al Jazeera and Al Arabiya, and 

planned initiatives such as the BBC’s planned Arabic-language television 

network; by numerous local radio stations across the region; and by limited 

opportunities for increasing coverage of radio transmission. It has 

attempted to address these challenges through some planning efforts, such 

as by developing proposals to increase its news time for Alhurra and 

expand its number of news bureaus in the Middle East. However, MBN has 

not developed a strategic plan or taken a detailed strategic approach to 

addressing certain issues, including identifying opportunities for additional 

gains that could be made from further integrating Radio Sawa and Alhurra 

or fully utilizing MBN’s overseas offices. Developing a strategic plan that 

establishes specific objectives, provides an overall shared vision or 

framework for decision-making, and comprehensively addresses 
Page 44 GAO-06-762 U.S. International Broadcasting

competitive challenges could enable MBN to identify efficiencies or 

opportunities to address its competitors more effectively and increase 

congressional confidence in its operations. 

Although MBN has developed a number of financial and administrative 

controls, it could take additional steps to ensure its system of internal 

control is fully implemented. MBN’s planned internal control board needs 

to establish protocols to oversee and monitor its internal control structure 

and to ensure timely completion of MBN’s financial audits. Additionally, 

MBN should develop an internal control plan, conduct a comprehensive 

risk assessment, and develop an organized training program for its staff. 

Further, MBN has developed journalistic standards for its broadcast 

operations and has put in place a number of editorial procedures. However, 

the network has not conducted annual program reviews called for in BBG 

guidance. These reviews are a key mechanism for improving programming 

and ensuring quality control. 

Finally, the BBG has established performance indicators and targets for 

MBN services related to measures of audience size and program credibility. 

For example, in fiscal year 2005, the BBG reported that Radio Sawa and 

Alhurra had each achieved radio and television audiences of about 21.6 

million. However, limitations in the survey methods and documentation 

used for developing these estimates raise questions about the accuracy of 

MBN’s performance estimates. In addition, the BBG has not put in place 

policies and procedures for verifying the accuracy of its performance 

information. These weaknesses in methodology and documentation inhibit 

an accurate assessment of whether the Radio Sawa and Alhurra 

performance targets have been met. The accuracy of the MBN estimates 

could be improved by more rigorous reliance on probability sampling, 

wherever possible, and avoidance of projections to areas not contained 

within the survey. At the same time, insistence on proper fieldwork 

documentation from contractors, full disclosure of survey methods and 

limitations, and greater transparency in the development of aggregate 

audience estimates would further enhance confidence in MBN 

performance estimates.

Recommendations for 

Executive Action

To improve efforts to monitor performance and the efficiency and 

effectiveness of the broadcasting activities of the Middle East Broadcasting 

Networks, Inc., we recommend that the chairman of the BBG do the 

following:
Page 45 GAO-06-762 U.S. International Broadcasting

• Require that MBN develop a long-term strategic plan, which 

incorporates a shared vision for Alhurra and Radio Sawa operations and 

details specific measurable objectives and implementation strategies for 

the successful implementation of the goals in the plan.

• Require that MBN implement the remaining recommendations from the 

Grant Thornton LLP report and require that its internal control board 

meet on a regular basis to coordinate MBN’s single audits and oversee 

MBN’s ongoing efforts to use sound internal control procedures.

• Develop a process for analyzing risk as part of strategic planning that 

identifies approaches to mitigate the potential obstacles to efficiently 

and effectively achieving MBN’s operational objectives.

• Require MBN to develop a comprehensive training program covering 

both internal controls and editorial procedures to meet the continuing 

needs of all employees.

• Initiate a schedule of annual program reviews for Radio Sawa and 

Alhurra to regularly ensure that the quality of Alhurra’s broadcasts 

conforms to applicable standards. 

• Implement program quality performance indicators for MBN’s broadcast 

services, consistent with other BBG entities, to assess and compare 

their performance and measure the contribution of these efforts to the 

goals of the overall organization.

• Require research contractors to improve the methods used in audience 

research to allow for probability sampling and document the sample 

selection so that survey sampling errors can be calculated, where 

possible. 

• Identify and report significant methodological limitations and the 

implications of them for performance indicators, including, where 

applicable, sampling errors, margins of error, or confidence intervals.

• Develop, document, and report policies and procedures for verification 

and analysis of performance indicator estimates.
Page 46 GAO-06-762 U.S. International Broadcasting

Agency Comments and 

Our Evaluation

The Broadcasting Board of Governors (BBG) provided written comments 

on a draft of this report. The BBG’s comments, along with our response to 

specific points, are reprinted in appendix V. The BBG also provided 

technical comments, which we incorporated where appropriate.

In general, the BBG concurred with all of our recommendations and said it 

looked forward to implementing them. The BBG said that MBN has made 

significant progress in the 2 years of its operations in establishing a sound 

journalistic organization with financial and administrative controls. 

However, the BBG raised a number of concerns about the report’s 

criticisms of the audience research conducted by the BBG and its 

contractors. Specifically, the BBG said that we did not fully understand the 

difficulty in surveying audiences in Middle Eastern countries and that the 

research practices used by the BBG and its contractors follow industry 

standards for commercial and media research.

Our report examines the reliability of the BBG’s fiscal year 2005 

performance information in order to determine whether or not MBN’s 

performance targets have been met. We acknowledge, in our report, that 

BBG has taken positive steps to enhance the validity and reliability of its 

audience survey designs. We also acknowledge that there are challenges to 

conducting audience research in the Middle East, and that there are 

tradeoffs between cost and data reliability when conducting research. In 

conducting our data reliability assessment, as referenced in the draft, we 

largely used the international audience research guidelines published by 

the Conference of International Broadcasters’ Audience Research Services 

(CIBAR), which are specified as a source of guidance for BBG research 

contractors. For example, CIBAR standards recommend that the proper 

care be exercised when reporting estimates to ensure that the type of 

audience covered by the estimate is clearly stated, and that, at all stages in 

the calculation and extrapolation process, sources, assumptions, and 

methods are fully documented and available for independent scrutiny. We 

were unable to determine the accuracy of MBN’s fiscal year 2005 audience 

size and program credibility estimates due to weaknesses in MBN’s 

methodology and documentation. As noted in the report, in several 

instances the BBG and its contractors departed from CIBAR research 

standards. In particular, the BBG did not take certain steps that could have 

explained and increased the reliability of its estimates, such as by fully 

documenting its research methods, measuring the level of uncertainty 

surrounding its estimates, disclosing significant limitations, limiting the 

scope of its projections to areas actually covered by its surveys, and 
Page 47 GAO-06-762 U.S. International Broadcasting

developing and consistently implementing policies and procedures for 

verifying data. For these reasons, it is not clear whether the Radio Sawa 

and Alhurra performance targets have been met.

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution of it until 30 days from 

the date of this letter. We will then send copies to others who are interested 

and make copies available to others who request them.

If you or your staff have any questions about this report, please contact me 

on (202) 512-4128. Contact points for our Offices of Congressional 

Relations and Public Affairs may be found on the last page of this report. 

Key contributors are listed in appendix VI.

Sincerely yours,

Jess T. Ford

Director, International Affairs and Trade
Page 48 GAO-06-762 U.S. International Broadcasting

Appendix I

Scope and Methodology AAppenednxidexiIs

To accomplish our objectives, we reviewed documentation and spoke with 

officials from the Department of State; the Broadcasting Board of 

Governors (BBG) and its grantees; including the Middle East Broadcasting 

Networks; Inc. (MBN); Radio Free Europe/Radio Liberty (RFE/RL); Radio 

Free Asia (RFA); the Voice of America (VOA); and the International 

Broadcasting Bureau. We also spoke with several outside experts, 

including representatives from National Public Radio, the InterMedia 

research organization, Zogby International, and foreign international 

broadcasters such as the British Broadcasting Corporation (BBC) and 

Deutsche Welle. 

In addition to our audit work in the Washington, D.C., area, we visited 

MBN’s offices in Amman, Jordan, and Dubai, United Arab Emirates. We 

held telephone interviews with MBN’s current affairs contractor in Beirut, 

Lebanon, and sent questions to the MBN office in Baghdad, Iraq. 

Because our work was focused on reviewing the BBG’s MBN initiatives--

Alhurra and Radio Sawa–we did not include RFE/RL Arabic-language 

media activities in Iraq in the scope of our work.

Review of MBN Internal 

Controls

To address our objective of assessing MBN’s internal controls, we used 

criteria contained in MBN’s grant agreement, OMB Circulars No. A-110 and 

A-133, GAO published standards on internal controls, and a report on 

MBN’s internal controls completed by Grant Thornton LLP accountants 

and management consultants. We also met with other broadcasters, 

including RFE/RL, RFA, and National Public Radio, to obtain an 

understanding of their internal controls and to make comparisons with 

MBN. We held discussions with MBN officials and reviewed documentation 

provided by them to determine whether the organization was complying 

with appropriate criteria. We spoke with PriceWaterhouseCoopers officials 

responsible for the 2003, 2004, and 2005 single audits to obtain their 

perspectives on the status of problems cited in the Grant Thornton LLP 

report and to learn about any new issues arising from their audit work. We 

did not test MBN’s controls, since doing so would have been beyond the 

scope of our review.

Review of MBN’s Editorial 

Procedures 

To address our objective of assessing the procedures MBN has developed 

to ensure it complies with its journalistic standards, we spoke with other 

broadcasters, including RFE/RL, RFA, VOA, and National Public Radio, to 

compare their editorial standards and procedures with those of MBN. We 
Appendix I

Scope and Methodology 

Page 49 GAO-06-762 U.S. International Broadcasting

also met with the BBG general counsel, as well as MBN producers, editors, 

and journalists. To better understand the program review process, we 

attended several VOA program reviews. We also held detailed discussions 

and obtained documentation on program review from the BBG officials 

who conducted Radio Sawa’s review, the International Broadcasting 

Bureau office of performance review, and the research directors of RFA 

and RFE/RL. We did not test MBN’s editorial procedures. 

Review of MBN Audience 

Survey Methods and 

Performance Indicator 

Estimates

To address our objective of determining the extent to which the BBG met 

or exceeded its fiscal year 2005 performance MBN targets, we reviewed the 

reliability of BBG audience research that was used to generate the 

estimates of credibility and audience size contained in the BBG’s Fiscal 

Year 2007 Budget Request, which was the BBG’s most up-to-date source of 

officially-reported GPRA performance information for MBN for fiscal year 

2005. We did not review the inputs used to generate performance 

information for fiscal years other than 2005, nor did we review the 

reliability of the data used to develop other MBN performance indictors 

reported in the 2007 Budget Request. 

To conduct our assessment of the reliability of BBG estimates of credibility 

and audience size for fiscal year 2005, we reviewed available 

documentation provided as of May 2005 against applicable standards and 

common professional research practices, including Conference of 

International Broadcasters’ Audience Research Services (CIBAR) 

guidelines and the professional standards of the American Association for 

Public Opinion Research. We reviewed relevant surveys, including 

technical reports and printouts of the survey results, as well as 

spreadsheets used to calculate the performance indicator estimates. We 

also conducted a series of interviews and corresponded extensively with 

the BBG’s coordinator for performance planning and research, the head of 

the International Broadcasting Bureau office of research, and officials from 

Intermedia to discuss the survey methods and how performance indicator 

estimates were generated. In addition, we requested information from the 

BBG’s research subcontractors, including AC Nielsen and D3 Systems, to 

obtain details on the survey sampling plans and related assumptions, 

response rates, and adjustments applied to the data to reflect the effects of 

the survey design. As a result of our review, we determined that MBN’s 

reported audience size and credibility estimates are not statistically reliable 

and are rather rough estimates of performance.
Page 50 GAO-06-762 U.S. International Broadcasting

Appendix II

Radio Sawa and Alhurra Programming ApendxiI

Radio Sawa currently has seven programming streams,1 with the Iraq 

programming stream airing more news and features than the other streams. 

We reviewed one week of programming and found that the Iraq stream 

aired about 50 hours of news and features a week, while five other streams 

aired about 40 hours a week (see table 5). 

Table 5: Radio Sawa’s Weekly News and Features Programming 

Source: GAO analysis of sample MBN programming schedule.

Note: The sample programming schedule was provided for the week of October 19, 2005. The exact 

breakdown of programming may differ from week to week.

a

Features programming includes the following Radio Sawa shows: Ask the World Now, Sawa Chat, 

Call Us Answers, Call Us Questions, Health News, What’s New, Free Zone, Challenges, To the Point, A 

Poet’s Story, Window on the Iraqi Constitution, Law and the Citizen, and Heart of the Matter.

Alhurra’s programming focuses on news and information, including hourly 

news updates, daily hour-long newscasts, and current affairs talk shows 

(see table 6). In addition, Alhurra broadcasts current affairs shows on 

subjects including health and fitness, entertainment, sports, and science 

and technology. Alhurra also airs documentaries on a diverse range of 

topics designed to appeal to a broad audience. In a sample week, Alhurra’s 

acquired programming, which mainly includes documentaries, accounted 

for the largest number of hours aired, about 35 percent of the total weekly 

programming hours--or approximately 60 hours in a week. News and news 

updates amounted to 22 percent of weekly programming hours.

1

In February 2006, Radio Sawa launched a seventh stream aimed at Lebanon, which was not 

included in the programming schedule that we received.

Programs Jordan Iraq Persian Gulf Morocco Egypt Sudan

Total news 

programming time

31 hrs 2 min 34 hrs 48 min 31 hrs 2 min 31 hrs 2 min 31 hrs 2 min 31 hrs 2 min

Total features 

programminga time

8 hrs 22.5 min 14 hrs 47 min 8 hrs 22.5 min 7 hrs 57.5 min 8 hrs 29.5 min 7 hrs 57.5 min

Total time for news 

and features

39 hrs 25 min 49 hrs 36 min 39 hrs 25 min 39 hrs 39 hrs 32 min 39 hrs 
Appendix II

Radio Sawa and Alhurra Programming 

Page 51 GAO-06-762 U.S. International Broadcasting

Table 6: Alhurra’s Weekly Programming Schedule 

Source: GAO analysis of sample MBN programming schedule for the week of February 19-25, 2006. 

Note: The breakdown of shows may differ from week to week. 

a

Acquired programming includes documentaries, historical programs, profiles, and travel and 

adventure programs.

b

Change in programming is a deviation from the normal schedule, including broadcasts of National 

Basketball Association games.

In contrast, Alhurra-Iraq’s talk shows accounted for the largest number of 

hours aired--- about 46 hours, or 27 percent of total programming time (see 

table 7). 

Table 7: Alhurra-Iraq’s Weekly Programming Schedule

Source: GAO analysis of sample MBN programming schedule for the week of February 19-25, 2006. 

Note: The breakdown of shows may differ from week to week. 

Programming 

time News Talk shows Current affairs News updates

Economic 

news updates

Acquired 

programminga

Change in 

programmingb

Per week 26 hours 29 hrs, 40 min 32 hrs, 50 min 10 hrs, 21 min 36 min 58 hrs, 20 min 9 hours

Total 166 hours and 47 minutes

Programming

time News Talk shows

Current 

affairs 

News 

updates

Economic 

news updates

Acquired 

programming 

Change in 

programming 

Per week 34 hours 45 hrs, 40 min 31 hrs, 20 min 8 hrs, 24 min 36 min 42 hrs 5 hours

Total 167 hours
Page 52 GAO-06-762 U.S. International Broadcasting

Appendix III

Radio Sawa Program Review ApendxiI

The BBG initiated the Radio Sawa review because MBN did not have the inhouse capacity to do so, according to a BBG official. Moreover, both the 

BBG and MBN wanted to ensure that the review was conducted by an 

entity other than MBN to make it more independent. 

To plan and conduct this review, BBG officials reported that they held 

preliminary discussions with the International Broadcasting Bureau’s office 

of performance review, hired an outside expert to serve as a consultant to 

the project, and contracted with the InterMedia research organization to 

convene panels of regular listeners in Iraq, Morocco, Egypt, and Jordan. 

According to representatives of InterMedia, they recruited a large number 

of panelists because the BBG wanted more input than usual. Panelists 

listened to and evaluated 6 days worth of programming, responded to a 

questionnaire that evaluated all of Radio Sawa’s broadcast criteria, 

answered open-ended questions, provided detailed feedback, and made 

recommendations about the programming. Overall, the results of Radio 

Sawa’s monitoring panels were generally positive, with an overall program 

quality score of 2.9 out of 4, which is considered “good” by the BBG.1

 To 

follow up on the program review, MBN is attempting to implement action 

points drafted by the BBG after the review, such as reducing abrupt 

transitions between music and news and localizing Radio Sawa’s streams.

The BBG told us it placed great emphasis on the audience’s response, 

noting that if there had been any problems, they would have heard about 

them from the listeners. The BBG’s research contractor concurred that it is 

important to obtain the audience’s perspective, since the audience can 

judge programming in the context of the alternatives available to them in 

the local media market. According to a BBG official, it was decided that 

information obtained from the audience monitoring panel would capture 

the issues that would normally be covered by the internal analysts in the 

content and production analyses. 

However, even a detailed, well-thought-out questionnaire does not replace 

the different perspectives internal and external control reviewers bring to 

1

The panelists reported that they liked Radio Sawa’s mixture of music and news, generally 

viewed the news as balanced and credible, and felt the station was culturally sensitive. In 

particular, panelists praised Sawa Chat for posing thought-provoking questions and 

providing interesting discussion. Panelists also found that some of the transitions between 

news and music were too abrupt; that there should be less repetition of songs; and that news 

should be more tailored to specific countries, while including more cultural and other “soft” 

news. 
Appendix III

Radio Sawa Program Review

Page 53 GAO-06-762 U.S. International Broadcasting

the review, according to a grantee official. According to an International 

Broadcasting Bureau official, even though the three components of a 

program review–audience panels and internal and external reviewers–use 

nearly the same criteria, they provide different insights into the program’s 

quality, direction, and context. According to several media experts,2

 while 

audience panelists can evaluate news and information from their own 

perspective, they are less qualified to evaluate a service’s mission or judge 

the extent to which a show complies with journalistic standards. In 

particular, the absence of an internal review meant that Radio Sawa’s 

programming was not evaluated by people familiar with BBG and MBN 

standards and controls. Moreover, the external control listener’s 

evaluation is intended to give the service a sense of what the panel’s 

responses would be like if the environment were freer and more open, 

information that a monitoring panel cannot provide. 

The BBG told us that it did not believe an internal evaluation was necessary 

because the English translations of each of the panel reports enabled them 

to examine and assess MBN’s programming. The BBG also told us that it 

did not use external control listeners in the review for several reasons: (1) 

Radio Sawa’s focus on youth and popular music would make it difficult for 

a typical older control listener to evaluate Sawa’s programs; (2) the BBG 

lacked resources to use control listeners for the multiple countries in Radio 

Sawa’s review; (3) it would have been hard to find impartial listeners; and 

(4) the four in-country panels ensured enough diversity of opinion so that 

there was less need for a control reviewer. However, according to an 

International Broadcasting Bureau official, the VOA is able to successfully 

evaluate youth shows using its regular internal reviewers. Moreover, it may 

be possible to use younger control listeners, or to use the older ones 

selectively. For example, RFE/RL uses a control listener to evaluate the 

news of Radio Farda. In addition, the challenge of finding impartial control 

listeners is not unique to the Middle East, but is potentially present to some 

degree for every language service.

2

The experts included staff from InterMedia, RFE/RL, and RFA.
Page 54 GAO-06-762 U.S. International Broadcasting

Appendix IV

CIBAR Standards ApendxiIV

The Conference of International Broadcasters’ Audience Research Services 

(CIBAR) guidelines were developed by an international group of 

broadcasters – including the BBG’s International Broadcasting Bureau -- to 

encourage, among other things, the appropriate use of audience and 

market data for decision-making within international broadcasting 

organizations, the establishment and maintenance of standards in 

international audience research, and the efficient and responsible use and 

application within member organizations of all forms of audience 

feedback. By providing a context for international audience research and a 

clear statement of the minimum standards required, the guidelines attempt 

to address the challenges faced by international broadcasters, including the 

tension between the needs of proper audience measurement and survey 

practice and the conditions and expertise in many of the countries where 

the research is carried out.

The third edition of the guidelines, published in 2001, covers the nature of 

international audience research measures; survey design, sampling, and 

fieldwork; and data management and reporting.1

 Specific guidelines 

relevant to this report include the following:

4.1: Samples and method:

• The basis for audience measurement should be samples based on the 

principles of random probability.

• The principles of random selection should be applied at all stages of the 

sampling process, from initial sampling point to selection of individuals.

• Quota samples should be used only in cases where, for reasons of 

practicality, cost, or both, proper random samples cannot be used. When 

quota samples are used, this should be clearly labeled in the reporting 

and documentation of the data.

• It should be a requirement of all measurement research that the 

sampling methods used and other technical aspects of the survey, 

including margins of error and confidence levels where appropriate, be 

both fully and accurately described in the project documentation, and 

open to independent scrutiny. 

1

CIBAR, Harmonized Audience Research Measurement for International Broadcasting

(3rd edition, 2001).
Appendix IV

CIBAR Standards

Page 55 GAO-06-762 U.S. International Broadcasting

4.2: Survey coverage:

• Where certain groups are disproportionately sampled and weighting 

techniques are applied at the analysis stage to correct for this, project 

documentation should give full details of the weights applied. 

5.2: Data reporting:

• The research agency should provide the following information to a 

contracting broadcaster: 

• Background information – client for whom the study was conducted; 

purpose of the study; names of subcontractors and consultants 

performing any substantial part of the work.

• Intended and achieved sample -- universe covered; statistics used 

(e.g. census data; size, nature and geographical distribution of the 

sample; sampling method and weighting methods used; response 

rates and possible bias due to non-response).

• Data collection – method of collection; field staff; briefing and field 

quality control; method of recruiting respondents; and fieldwork 

dates.

• Presentation of results – relevant factual findings obtained; bases of 

percentages (weighted and unweighted); margins of error; and 

questionnaire and other documents used.

• Proper care be exercised when reporting such estimates, to ensure that 

the type of audience covered by the estimate is clearly stated.

• At all stages in the calculation and extrapolation process, it is vital that 

sources, assumptions, and methods be fully documented and available 

for independent scrutiny.

• All reporting of worldwide and regional audiences should be 

accompanied by a technical appendix giving details of the sources, 

assumptions, and measures used.
Page 56 GAO-06-762 U.S. International Broadcasting

Appendix V

Comments from the Broadcasting Board of 

Governors ApendxiV

Note: GAO comments 

supplementing those in 

the report text appear 

at the end of this 

appendix.
Appendix V

Comments from the Broadcasting Board of 

Governors

Page 57 GAO-06-762 U.S. International Broadcasting

See comment 1.

See comment 2.
Appendix V

Comments from the Broadcasting Board of 

Governors

Page 58 GAO-06-762 U.S. International Broadcasting

See comment 3.

See comment 4.
Appendix V

Comments from the Broadcasting Board of 

Governors

Page 59 GAO-06-762 U.S. International Broadcasting
Appendix V

Comments from the Broadcasting Board of 

Governors

Page 60 GAO-06-762 U.S. International Broadcasting

See comment 5.

See comment 6.
Appendix V

Comments from the Broadcasting Board of 

Governors

Page 61 GAO-06-762 U.S. International Broadcasting

See comment 7.

See comment 8.
Appendix V

Comments from the Broadcasting Board of 

Governors

Page 62 GAO-06-762 U.S. International Broadcasting

See comment 10.

See comment 9.
Appendix V

Comments from the Broadcasting Board of 

Governors

Page 63 GAO-06-762 U.S. International Broadcasting

See comment 11.
Appendix V

Comments from the Broadcasting Board of 

Governors

Page 64 GAO-06-762 U.S. International Broadcasting

The following are GAO’s comments on the Broadcasting Board of 

Governor’s (BBG) letter dated July 20, 2006.

GAO Comments 1. GAO acknowledges in the report that MBN has participated in longrange planning in coordination with the BBG’s update of its 2008-2012 

strategic plan, and that MBN has developed a 2006 annual performance 

plan as part of the OMB Program Assessment Rating Tool process. 

However, contrary to the BBG’s comments, the fiscal year 2006 

performance plan document for MBN that we obtained did not contain 

all of the elements of a stand-alone strategic plan. In addition, we were 

told by the former executive director of the BBG, who is currently the 

president of MBN, that the Radio Sawa strategic plan drafted in 2002 by 

the BBG–which the BBG stated in its comments contributed to its 

considerable long-term planning for MBN--was never adopted by the 

BBG. We were also told by MBN’s former president that he had never 

received a copy of the draft Radio Sawa strategic plan.

2. The BBG stated that MBN’s Single Audit evaluates the effectiveness of 

its internal control program. However, while MBN’s Single Audits 

address the fair presentation of the organization’s financial statements, 

its compliance with certain laws and regulations, and the organization’s 

internal control as it relates to financial reporting, MBN’s 2005 Single 

Audit as prepared by PriceWaterhouseCoopers does not–contrary to 

what the BBG stated in its comments--offer an opinion on the overall 

effectiveness of MBN’s internal control. Thus, the unqualified opinion 

that MBN received on its fiscal year 2005 Single Audit does not provide 

a broad assessment or opinion of MBN’s internal control system. For 

the purposes of our report, it was therefore necessary to consider other 

assessments of MBN’s financial and administrative controls, including 

the Grant Thornton report. 

3. MBN’s grant agreement states that MBN should make every reasonable 

effort to achieve the purpose of the grant in accordance with OMB 

Circulars A-110, A-122, and A-133. Our report did not attempt to make 

an assessment of MBN’s compliance with its grant agreement, but 

rather focused on the progress MBN has made in developing its system 

of internal control and the ways in which MBN can continue to 

strengthen this system. To that end, we drew upon the work of Grant 

Thornton LLP, which assessed the status of MBN’s controls against 

relevant OMB Circulars and GAO guidance on internal control. 
Appendix V

Comments from the Broadcasting Board of 

Governors

Page 65 GAO-06-762 U.S. International Broadcasting

4. While the Grant Thornton recommendations are not obligatory, they 

are based on best management practices from OMB and GAO. 

According to officials, both the BBG and MBN accepted the results of 

the report, which provides detailed insight into MBN’s financial 

operations, when it was completed in May 2004. Adopting the report’s 

remaining recommendations would help MBN in its efforts to build a 

fully mature internal financial management operation.

5. The BBG stated that it believes its standards yield data of sufficient 

reliability to allow it to estimate MBN’s audiences and credibility. 

However, the BBG offers no evidence for this. BBG’s estimates for MBN 

are based on judgment and not statistics, and its current methods do 

not and cannot estimate the error in its estimates. As noted in the 

report, in several instances the BBG and its contractors departed from 

CIBAR research standards. For example, we analyzed 12 of the 14 

country surveys conducted by BBG contractors for 2005. In the BBG’s 

fiscal year 2007 budget request, the BBG reported the results of each 

country survey and an overall estimate for audience size of 21.5 for 

Alhurra and 21.6 million for Radio Sawa. However, our analysis of the 

12 surveys identified a number of methodological weaknesses, 

including BBG’s failure to fully document research methods, measure 

the level of uncertainty surrounding its estimates, disclose significant 

limitations, limit the scope of its projections to areas actually covered 

by its surveys, and develop and consistently implement policies and 

procedures for verifying data. These limitations were not reported in 

BBG’s audience survey estimates and prevent us from concluding that 

the estimates are accurate and reliable.

6. We acknowledge in the report that there are challenges to conducting 

audience research in the Middle East, and that there are tradeoffs 

between cost and data reliability when conducting research.

7. As we noted in the report, it is difficult to conduct probability sampling 

in many locations in the Middle East. But, it is not impossible. 

Organizations, including the United States Census Bureau, have 

collaborated on probability surveys in the Middle East, including in 

Saudi Arabia and Jordan. The major problem of the BBG estimates is 

their lack of transparency, and the lack of an explanation for the 

methodology behind BBG’s estimates. 

8. In conducting our data reliability assessment, as referenced in the 

report, we largely used the international audience research guidelines 
Appendix V

Comments from the Broadcasting Board of 

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Page 66 GAO-06-762 U.S. International Broadcasting

published by CIBAR. The BBG participated in drafting these standards, 

which are specified as a source of guidance for BBG research 

contractors. CIBAR standards recommend that proper care be 

exercised when reporting estimates to ensure that the type of audience 

covered by the estimate is clearly stated, and that, at all stages in the 

calculation and extrapolation process, sources, assumptions, and 

methods are fully documented and available for independent scrutiny. 

As noted in the report, in several instances the BBG and its contractors 

departed from CIBAR research standards, leading to weaknesses in 

MBN’s methodology and documentation. As a result, we were unable to 

determine the accuracy of MBN’s fiscal year 2005 audience size and 

program credibility estimates. 

9. The BBG stated that it believes the level of methodological detail it has 

provided in public documents is comparable with that typically used by 

other research organizations for studies in the Islamic world; therefore, 

it believes it is consistent with industry practice. However, the Reports 

Consolidation Act of 20001

 requires federal agencies, such as the BBG, 

to assess the completeness and reliability of the performance data in 

their performance reports and to discuss any material inadequacies in 

the completeness and reliability of their performance data, as well as 

actions to address the inadequacies. In performance reporting such as 

the BBG fiscal year 2007 budget request, the BBG reported the results 

of its research for MBN as 21.5 million viewers for Alhurra and 21.6 

million for Radio Sawa. However, the BBG did not sufficiently explain 

the specific methods used for generating estimates for its performance 

indicators, such as the number and names of the countries surveyed 

(including the sizes of its samples), methods of sampling used, sources 

of the population data, and basic procedures used to create the 

estimates. Moreover, the BBG reported only two limitations for MBN 

performance indicators to date: (1) that credibility ratings are highly 

dependent on volatile political factors; and (2) that, depending on 

political, social, and media conditions, measurement of audience size 

may either be easily attained or impossible. Significant limitations not 

reported are that many of the BBG surveys are not based on probability 

sampling, cover only part of the country, have very low response rates, 

or have high substitution rates. Therefore, the BBG does not provide a 

full level of confidence in the credibility of its performance data for 

MBN. In contrast, the Department of Transportation, has a separate 

1

P.L. 106-531.
Appendix V

Comments from the Broadcasting Board of 

Governors

Page 67 GAO-06-762 U.S. International Broadcasting

compendiums available online that provides source and accuracy 

statements, which provide detail on the methods used to collect 

performance data, sources of variation and bias in the data, and 

methods used to verify and validate the data.

10. The BBG cannot calculate the sampling error for the BBG estimates of 

audience size and credibility because the probability of selection is not 

known. Although increased sample size will generally decrease 

sampling error, it is impossible to accurately estimate the sampling 

error of the BBG surveys because they are nonprobability surveys. As 

the BBG has stated, its use of a simple random sampling formula when 

calculating sampling errors for its surveys underestimates the sampling 

error. This formula is not appropriate for the sample designs used by 

MBN. 

11. Although our recommendation asks the BBG to require research 

contractors to improve the methods used in audience research to allow 

for probability sampling and document the sample selection so that 

survey sampling errors can be calculated, where possible, it is the 

responsibility of the BBG to explain and justify the need to conduct 

nonprobability samples.
Page 68 GAO-06-762 U.S. International Broadcasting

Appendix VI

GAO Contact and Staff Acknowledgments ApendxiVI

GAO Contact Jess Ford, (202) 512-4268

Staff 

Acknowledgments

Diana Glod, Melissa Pickworth, Eve Weisberg, Dorian Herring, and Joe 

Carney made key contributions to this report. Chanetta Reed, Jay Smale, 

Karen O’Conor, and Jackie Nowicki provided technical assistance. 

(320376)
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