a

GAO

United States General Accounting Office

Report to the Committee on 

Appropriations, U.S. Senate, and the 

Committee on Appropriations, House of 

Representatives

December 2003 FEMA CERRO 

GRANDE CLAIMS

Payments Properly 

Processed, but 

Reporting Could Be 

Improved

GAO-04-129
www.gao.gov/cgi-bin/getrpt?GAO-04-129.

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and methodology, click on the link above. 

For more information, contact 

Linda M. Calbom at (202) 512-9508 or 

calboml@gao.gov. 

Highlights of GAO-04-129, a report to the

Committee on Appropriations, U.S. 

Senate, and the Committee on 

Appropriations, House of Representatives 

December 2003

FEMA CERRO GRANDE CLAIMS

Payments Properly Processed, but 

Reporting Could Be Improved 

FEMA processed and paid its claims in accordance with its policies and 

procedures that were established and in place at the time the claims were 

reviewed and processed. For the period from August 29, 2002, to 

June 30, 2003, FEMA approved $40 million in claims for payment, including 

the initial payment of most of the subrogation claims made by insurance 

companies. 

In response to GAO’s May 2003 report, FEMA established processes to 

address GAO’s recommendations related to reconciling claimed amounts 

approved with actual amounts paid. These processes included comparing 

the individual amounts approved for payment to the amounts actually paid 

from inception through June 30, 2003, by claim, as well as performing 

complete reconciliations of total amounts that were approved and paid for 

the same period and as of August 31, 2003. In addition, in our prior report, 

we noted that FEMA improperly reported unreconciled claim amounts 

approved for payment as amounts actually paid. In its 2003 annual report, 

FEMA properly identified claimed amounts as approved amounts for 

payment rather than actual amounts paid in a schedule that was included in 

its annual report to the Congress. However, FEMA no longer provided 

summary information on amounts claimed, amounts approved, and its 

remaining estimated liabilities in its report to the Congress and did not 

include any information on claims paid as is required by CGFAA. Without 

this information, the report is less useful to the Congress and other 

stakeholders.

The Cerro Grande Fire Assistance 

Act (CGFAA) mandated that GAO 

annually audit all claim payments 

made to compensate the victims of 

the Cerro Grande Fire in northern 

New Mexico. For this third report 

on this topic, GAO determined 

whether the Federal Emergency 

Management Agency (FEMA), 

which is now a part of the 

Emergency Preparedness and 

Response Directorate of the 

Department of Homeland Security, 

(1) paid fire claims in accordance 

with applicable guidance and 

(2) implemented corrective actions 

to address prior GAO 

recommendations, including 

determining if FEMA properly 

reported claim payments to the 

Congress. 

To help FEMA improve the 

usefulness of its reports to the 

Congress, GAO recommends that 

the Secretary of Homeland Security 

require the Emergency 

Preparedness and Response 

Directorate to include summary 

information on amounts claimed, 

approved, and paid and remaining 

estimated program liabilities in its 

annual report to the Congress. 

The Department of Homeland 

Security’s Emergency 

Preparedness and Response 

Directorate concurred with our 

recommendation to include the 

summary-level information in its 

next annual report. 
Page i GAO-04-129 CGFAA Claim Payments

Contents

Letter 1

Results in Brief 2

Background 2

Scope and Methodology 5

Policies and Procedures for Claim Processing Were Followed 7

Progress Made in Addressing Prior Recommendations, but 

Reporting Could Be Improved 9

Conclusions 11

Recommendation for Executive Action 11

Agency Comments 11

Appendixes

Appendix I: Comments from the Department of Homeland Security 13

Table Table 1: Summary of CGFAA Approved and Estimated Claims to Be 

Paid as of September 9, 2003 4

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Page 1 GAO-04-129 CGFAA Claim Payments

United States General Accounting Office

Washington, D.C. 20548

A

December 24, 2003 Letr

The Honorable Ted Stevens

Chairman

The Honorable Robert C. Byrd

Ranking Minority Member

Committee on Appropriations

United States Senate

The Honorable C.W. Bill Young

Chairman

The Honorable David R. Obey

Ranking Minority Member

Committee on Appropriations

House of Representatives

On July 13, 2000, the President signed into law the Cerro Grande Fire 

Assistance Act (CGFAA).1

 CGFAA established the Office of Cerro Grande 

Fire Claims (OCGFC) and directed the Federal Emergency Management 

Agency (FEMA)2 to expeditiously investigate claims, determine damages, 

and compensate the victims of the Cerro Grande fire in northern New 

Mexico. CGFAA also requires FEMA to submit an annual report to the 

Congress by August 28 that provides information on claims submitted and 

amounts paid during the year. CGFAA, as amended,3

 requires that we audit 

all claim payments made under the act, including subrogation claims4 made 

by insurance companies, and report the results of our audit within 120 days 

of the issuance of FEMA’s annual report. In this our third report under 

CGFAA, we determined whether FEMA (1) paid fire claims in accordance 

with applicable policies and procedures and (2) implemented corrective 

actions to address our prior report’s recommendations, including 

determining if FEMA properly reported claim payments to the Congress.

1

Pub. L. No. 106-246, Div. C, Title I, 114 Stat. 511, 583 (2000).

2

As of March 2003, FEMA became part of the Emergency Preparedness and Response 

Directorate of the Department of Homeland Security.

3

Pub. L. No. 107-73, Title IV, § 428, 115 Stat. 651, 697 (2001).

4

A subrogation claim is the right of one who has paid an obligation that another should have 

paid to be indemnified by the other. In this case, insurance companies and possibly others 

paid claims that the federal government is responsible for paying.
Page 2 GAO-04-129 CGFAA Claim Payments

Results in Brief Based on the results of our statistical testing, FEMA processed and paid its 

claims in accordance with its policies and procedures that were established 

and in place at the time the claims were reviewed and processed. These 

procedures included obtaining and reviewing proper documentation of 

claims, approvals, and release forms. For the period from August 29, 2002, 

through June 30, 2003, FEMA approved $40 million in claims for payment, 

including the initial payment of subrogation claims.

FEMA addressed our prior recommendations related to reconciling 

claimed amounts approved with actual amounts paid. In response to our 

May 2003 report,5

 FEMA compared the amounts approved for payment to 

the amounts actually paid for each claim from inception through June 30, 

2003. It also performed complete reconciliations of total amounts 

approved and paid through the same period and as of August 31, 2003. In 

addition, in our prior report, we noted that FEMA improperly reported 

unreconciled claim amounts approved for payment as amounts actually 

paid. In its 2003 annual report, FEMA properly identified claimed amounts 

as approved amounts for payment rather than actual amounts paid in a 

schedule that was included in its annual report to the Congress. However, 

FEMA no longer summarized the amounts claimed, amounts approved, and 

the remaining program liabilities in its report to the Congress and did not 

include any information on claims paid as is required by CGFAA. Without 

this information, the report is less useful to the Congress and other 

stakeholders.

We are making a recommendation that addresses this reporting issue. In 

commenting on a draft of the report, the Director of the Recovery Division 

of the Department of Homeland Security’s Emergency Preparedness and 

Response Directorate agreed with our recommendation to include the 

summary-level information in its next annual report.

Background On May 4, 2000, the National Park Service initiated a prescribed burn on 

federal land at Bandelier National Monument, New Mexico, in an effort to 

reduce the threat of wildfires in the area. The plan was to burn up to 900 

acres. On May 5, 2000, the prescribed burn exceeded the capabilities of the 

5

U.S. General Accounting Office, FEMA Cerro Grande Claims: Payments Properly 

Processed, but Reported Payments Somewhat Overstated, GAO-03-623 (Washington, D.C.: 

May 8, 2003).
Page 3 GAO-04-129 CGFAA Claim Payments

National Park Service, spread to other federal and nonfederal land, and was 

characterized as a wildfire. On May 13, 2000, the President issued a major 

disaster declaration, and subsequently, the Secretary of the Interior and the 

National Park Service assumed responsibility for the fire and the loss of 

federal, state, local, tribal, and private property. The fire, known as the 

Cerro Grande fire, burned approximately 48,000 acres in four counties and 

two Indian pueblos, destroyed over 200 residential structures, and forced 

the evacuation of more than 18,000 residents.

On July 13, 2000, the President signed CGFAA into law. Under CGFAA, 

each claimant is entitled to be compensated by the United States 

government for certain injuries and damages that resulted from the Cerro 

Grande fire. CGFAA required that FEMA promulgate and publish 

implementing regulations for the Cerro Grande program within 45 days of 

enactment of the law. On August 28, 2000, FEMA published Disaster 

Assistance: Cerro Grande Fire Assistance: Interim Final Rule in the 

Federal Register (Interim Rule).6

 FEMA modified the Interim Rule with a 

set of implementing policies and procedures on November 13, 2000. FEMA 

updated these policies and procedures in January and March 2001. After 

reviewing public comments on the Interim Rule, FEMA finalized and 

published Disaster Assistance: Cerro Grande Fire Assistance Final Rule

(Final Rule) on March 21, 2001.7

 

The Congress initially appropriated $455 million to FEMA for the payment 

of such claims and $45 million for the administration of the Cerro Grande 

program.8

 In March 2002, FEMA requested, but did not receive, additional 

appropriated funding of $80 million to cover additional claims and 

administrative costs. In December 2002, FEMA revised its estimate and 

requested additional appropriated funding of $155 million, including 

$5 million for administrative costs. The revised estimate was based on 

more complete claim information since the final date to submit claims had 

passed on August 28, 2002. In February 2003, FEMA was appropriated an 

additional $90 million, of which up to $5 million may be made available for

6

65 Fed. Reg. 52260, 44 C.F.R. Part 295 (2000).

7

66 Fed. Reg. 15948, 44 C.F.R. Part 295 (2001).

8

CGFAA, Sec. 105, 114 Stat. 590.
Page 4 GAO-04-129 CGFAA Claim Payments

administrative purposes.9 FEMA stated that only $2 million was used in 

fiscal year 2003 for administrative purposes. In October 2003, FEMA 

received an additional appropriation of $38.062 million, of which 5 percent 

may be made available for administrative costs.10 After FEMA allocated a 

specific amount for administrative costs, it had a maximum of 

$578.6 million available for the payment of claims under CGFAA. During 

the audit, FEMA provided revised claim data that reflected the amounts 

shown in table 1. 

Table 1: Summary of CGFAA Approved and Estimated Claims to Be Paid as of 

September 9, 2003

Source: FEMA OCGFC.

The claimed amounts that FEMA approved for payment through 

September 9, 2003, included $51.5 million of approved subrogation claims. 

Pending claims included expected payments for individual, business, 

governmental, and pueblo claims, and projected liabilities consisted of 

potential future appeals, potential arbitrations, and contingency for judicial 

review. 

9

Departments of Veterans Affairs and Housing and Urban Development, and Independent 

Agencies Appropriations Act, 2003, Pub. L. No. 108-7, Div. K, Title III, 117 Stat. 474, 516.

10Department of Homeland Security Appropriations Act, 2004, Pub. L. No. 108-90, Title III, 

117 Stat. 1137, 1150 (2003).

Dollars in thousands

Claim amounts

Amounts approved for payment from inception $505,698 

Estimated additional liabilities:

Pending claims 3,705 

Appeals 12,973 

Mitigation 1,138 

Projected liabilities 9,339 

Subrogation claims--approved but unpaid 1,634 

Subrogation claims--unapproved amounts 53,160 

Total estimated additional liabilities $81,949 

Total actual and estimated claims to be paid $587,647 
Page 5 GAO-04-129 CGFAA Claim Payments

CGFAA requires that FEMA submit an annual report to the Congress that 

provides information about claims submitted under the act. This annual 

report is to include the amounts claimed, a description of the nature of the 

claims, and the status or disposition of the claims, including the amounts 

paid. FEMA’s report is to be issued annually by August 28. CGFAA, as 

amended, requires that we conduct annual audits on the payment of all 

claims made and report the results of the audits to the Congress within 120 

days of FEMA’s issuance of its annual report. The act also requires that our 

report include a review of all subrogation claims for which insurance 

companies have been paid. In May 2003, we issued our second report on 

the audit of Cerro Grande claim payments made from inception through 

August 28, 2002. The report stated that FEMA properly processed and paid 

claims but overstated amounts paid in its report to the Congress and made 

two recommendations regarding the reconciliation of the approved and 

paid amounts in its payment approval and accounting systems.11 FEMA 

issued its most recent annual report on August 28, 2003, with claim 

amounts approved for payment through June 30, 2003. 

Scope and 

Methodology

In performing our review, we considered the Standards for Internal 

Control in the Federal Government.

12 To reaffirm our understanding of the 

claim review and payment process established by OCGFC and to follow up 

on the changes made to this process since our last report, we interviewed 

FEMA officials and analyzed data used in FEMA’s annual report to the 

Congress and data used by FEMA to determine the estimated claim liability. 

We also reviewed the following:

• the requirements of CGFAA;

• the final regulations published in the Federal Register;

• FEMA’s policies and procedures manual;

• a summary of FEMA’s unpaid claim liability estimates as of September 9, 

2003;

11GAO-03-623.

12U.S. General Accounting Office, Standards for Internal Control in the Federal 

Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999).
Page 6 GAO-04-129 CGFAA Claim Payments

• FEMA’s fiscal year 2002 audited financial statements; and

• the fiscal year 2003 approvals, payments, and other documentation 

concerning the Cerro Grande program and submitted claims. 

Finally, we selected a statistical sample from the population of all partial 

and final claimed amounts approved for payment from August 28, 2002, 

through June 30, 2003, to determine whether FEMA processed, approved, 

and paid the Cerro Grande fire claims in accordance with its applicable 

policies and procedures. 

We selected a dollar unit (statistical) sample of 99 intervals representing 84 

claims totaling $21,000,928 that were approved for payment from a 

population of 1,868 reported partial and final claim amounts that had been 

approved for payment from August 28, 2002, through June 30, 2003 (FEMA’s 

cutoff date for the annual report to the Congress), to test specific control 

activities, such as adequacy of supporting documentation, evidence of 

claims manager and approving official review, and actual payment by 

FEMA. We obtained and reviewed related supporting documentation for 

the approved claim payments that were selected from OCGFC’s payment 

approval system.

In order to follow up on FEMA’s corrective actions to address our prior 

year recommendations, as well as determine whether FEMA properly 

reported claim payment information to the Congress, we reviewed 

OCGFC’s reconciliations of claimed amounts that were approved by 

OCGFC for payment from its payment approval system and the actual 

claim payments made by FEMA’s Disaster Finance Center (DFC) and 

reported in FEMA’s accounting system. 

Our work was conducted in Denton, Texas,13 and Washington, D.C., from 

September 2003 through October 2003 in accordance with generally 

accepted government auditing standards. We requested agency comments 

on a draft of this report from the Under Secretary of the Department of 

Homeland Security’s Emergency Preparedness and Response Directorate 

or his designee. The Director of the Recovery Division of the Department 

of Homeland Security’s Emergency Preparedness and Response 

13In December 2002, OCGFC closed its headquarters operations in Santa Fe, New Mexico, 

and moved the remaining claims operations to FEMA’s National Processing Center in 

Denton, Texas.
Page 7 GAO-04-129 CGFAA Claim Payments

Directorate provided written comments on our draft, which are reprinted 

in appendix I. We discuss the written comments in the “Agency Comments 

and Our Evaluation” section of this report.

Policies and 

Procedures for Claim 

Processing Were 

Followed

Based on the results of our statistical testing, FEMA processed, approved, 

and paid its claims in accordance with its guidelines that were established 

and in place at the time the claims were reviewed and processed. FEMA’s 

guidelines for the approval and payment of claims specify the following 

steps.

• An injured party submits a Notice of Loss (NOL)14 to OCGFC to initiate 

the claim payment process.

• Upon receipt of the NOL, a claim reviewer contacts the claimant to 

discuss the claim, explain the claims process, and determine the best 

means to substantiate the loss or damages.

• The claim reviewer then assigns a claim number and enters the 

information into OCGFC’s claim-processing database, the Automated 

Claim Information System, and begins the process of verifying the 

victim’s claim.

• Upon completion of its review, the claim reviewer prepares a claim 

payment recommendation package, which specifies that a claimant’s 

injuries or damages occurred as a result of the Cerro Grande fire and 

that claimed amounts are eligible for compensation under CGFAA.

• The claim reviewer also inputs reserve amounts equal to the total 

claimed amounts that he/she expects to be paid into the claimprocessing database.

• A claim supervisor reviews to ensure that a proper investigation of the 

claim occurred and that the proper documentation exists, among other 

things, and approves each recommendation package.

14The NOL describes in general terms the types of injury, damages, or both a claimant has 

incurred as a result of the fire.
Page 8 GAO-04-129 CGFAA Claim Payments

• Upon approval of the claim payment recommendation package, an 

Approval for Payment form is completed and sent to an OCGFC 

authorizing official for review and approval.

• The Comptroller receives a Schedule of Payments, consisting of 

amounts approved for payment, and reviews a sample of requested and 

approved payments.

• The Comptroller then approves the Schedule of Payments, records the 

approved amounts in OCGFC’s payment approval system, and sends the 

schedules to FEMA’s DFC for additional manual processing.

• FEMA records all payments in its accounting system, the Integrated 

Financial Management Information System, which is not linked to 

OCGFC’s payment approval system, before funds are disbursed by 

Treasury.

In addition to the above steps from the claim review process, which is used 

for both partial payments15 and final payments, the claim reviewer prepares 

a Proof of Loss (POL) form prior to processing a final payment. This form 

summarizes all amounts recommended for payment, including those 

amounts previously paid through a partial payment. The POL form must be 

signed by the claimant subject to the provisions of 18 U.S.C. §1001, which 

establishes criminal penalties for false statements. Once a signed POL 

form is received, an OCGFC authorized official sends a Letter of Final 

Determination to tell the claimant the total amount of compensation being 

offered under CGFAA. Accompanying this letter is a Release and 

Certification form that the claimant signs if he or she accepts the OCGFC 

compensation determination, thereby releasing the federal government 

from any additional claims arising from the Cerro Grande fire.16 Upon 

receipt of the signed Release and Certification form, FEMA processes and 

mails a claimant’s final payment.

15In order to get assistance to fire survivors as soon as possible, CGFAA allows for claimants 

to receive partial payments before the start of the rebuilding process. Partial payments may 

be based upon actual receipts or estimates. Final payments are made only after the entire 

claim review process is completed.

16Under certain circumstances, claims may be reopened notwithstanding the submission of 

a Release and Certification form pursuant to 44 C.F.R. Sec. 295.34 (2002).
Page 9 GAO-04-129 CGFAA Claim Payments

Our review of the statistically selected sample of approved claims 

determined that the above steps were performed in accordance with 

FEMA’s established approval and payment process. For the period from 

August 29, 2002, through June 30, 2003, FEMA approved claims in the 

amount of $40 million for payment,17 including the partial payment of 

approved subrogation claims filed by insurance companies.

Progress Made in 

Addressing Prior 

Recommendations, but 

Reporting Could Be 

Improved

FEMA addressed our prior recommendations related to reconciling the 

reported amounts approved for payment to amounts actually paid. FEMA 

reconciled the total amounts approved for payment to the amounts actually 

paid as of June 30, 2003, which was the cutoff date for its annual report, 

and as of August 31, 2003. FEMA officials stated they would continue to 

perform these reconciliations periodically. In reviewing FEMA’s annual 

report to the Congress required by CGFAA, we found that while 

improvements were made in how FEMA represented the detailed claim 

information in its report, claim information was no longer summarized in 

the report, making it less useful and transparent. 

In our May 2003 report, we recommended that FEMA reconcile the 

amounts approved for payment in its payment approval system to amounts 

actually paid in its accounting system and correct all identified errors in its 

payment approval system. We also recommended that FEMA perform 

monthly reconciliations of the approved and paid amounts for as long as 

both systems are used to track and report paid amounts or request 

additional funding. 

In response to our recommendations, OCGFC implemented a detailed 

process that consisted of compiling the claimed amounts by individual 

claims from both the accounting system and the payment approval system 

and matching the amounts approved and paid for each claim. It also 

performed an overall reconciliation of the total amounts approved and paid 

through June 30, 2003.

In performing the detailed matching process, OCGFC compared the 

individual claim approval data and claim payment data from August 28, 

2000, through February 19, 2003, and performed periodic comparisons of 

individual claims from February 20, 2003, to May 31, 2003, and from June 1 

17From inception of CGFAA through June 30, 2003, FEMA reported a total of $462 million in 

claims approved for payment.
Page 10 GAO-04-129 CGFAA Claim Payments

to June 30, 2003. When OCGFC identified differences between amounts 

reported as paid by FEMA’s accounting system and OCGFC’s payment 

approval system, it recorded the adjustments and corrections into its 

payment approval system to eliminate duplication and made note of data 

entry errors, which did not require adjustments. The identified differences 

generally consisted of the following:

• Duplicate approved amounts that represented a claimed amount that 

was approved for payment more than once. For example, in one case 

OCGFC approved a final payment of $934,802. Since the claimant 

appealed, the amount was not paid. While the claim was being 

appealed, OCGFC approved a partial payment of $919,802. Both of 

these amounts appeared as approved payments in its payment approval 

system. After we brought this duplicate approval to OCGFC’s attention 

during our prior review, it subsequently removed the original unpaid 

amount from its system during its claims comparison process later in 

fiscal year 2003. 

• Data entry errors by claim reviewers when entering data into the 

payment approval or accounting systems. For example, if an incorrect 

identification number was used to process a payment, no comparison 

could be made between the approved amount recorded by claim 

number in the approval system and the paid amount recorded by 

claimant’s identification number in the accounting system. To resolve 

the situation, OCGFC listed the approved amount as an unmatched item 

until it located the matching payment that was recorded to a different 

identification number.

In addition to these comparisons of individual claim amounts, FEMA’s 

Financial and Acquisition Management Division (FAMD) performed a 

complete reconciliation of the total amounts that were approved for 

payment and paid as of June 30, 2003. We reviewed this overall 

reconciliation of the total claim amounts approved and paid under CGFAA, 

from inception through June 30, 2003, and found that all corrections and 

adjustments identified during OCGFC’s comparison were made. FAMD 

also performed a similar reconciliation of total approved and paid amounts 

through August 31, 2003, and stated that it plans to perform this overall 

reconciliation more regularly, at least quarterly.

In our prior report, we noted that FEMA improperly reported unreconciled 

amounts that were approved for payment in its prior annual reports to the 

Congress as amounts actually paid. In its 2003 annual report to the 
Page 11 GAO-04-129 CGFAA Claim Payments

Congress, FEMA continued to include claimed amounts approved for 

payment in a detailed schedule of claim information, but it properly 

identified the amounts as such instead of as paid or expended amounts. 

However, FEMA’s report no longer summarized information on the 

amounts claimed, amounts approved, and the estimated liabilities for the 

remainder of the program. In addition, FEMA did not include any 

information on claims paid as is required under CGFAA. Without this 

information, FEMA’s annual report is less useful to the Congress and other 

stakeholders.

Conclusions FEMA strengthened its internal controls over its claim approvals and 

payments by implementing a process to reconcile its detailed approval 

information to its payment information. This helps improve the accuracy 

of claims information included in its systems and reports to the Congress. 

The usefulness and transparency of the report would be further improved if 

it included summary claim activity information.

Recommendation for 

Executive Action

We recommend that the Secretary of Homeland Security direct the Under 

Secretary of the Emergency Preparedness and Response Directorate to 

include summary-level claim information in its annual report to the 

Congress, including amounts claimed, approved, and paid and remaining 

estimated program liabilities.

Agency Comments FEMA, in a letter from the Director of the Recovery Division of the 

Department of Homeland Security’s Emergency Preparedness and 

Response Directorate, agreed with our recommendation to include 

summary-level claim information on amounts claimed, approved, and paid 

and remaining estimated program liabilities, if any, in its next annual report 

to the Congress. The Department of Homeland Security’s comments are 

reprinted in appendix I.

We are sending copies of this report to the congressional committees and 

subcommittees responsible for issues related to FEMA and the Department 

of Homeland Security, the Secretary of the Department of Homeland 

Security, the Under Secretary of the Department of Homeland Security’s 

Emergency Preparedness and Response Directorate, and the Inspector 

General of the Department of Homeland Security. Copies will also be made 
Page 12 GAO-04-129 CGFAA Claim Payments

available to others upon request. In addition, this report is available at no 

charge on GAO’s Web site at http://www.gao.gov.

If you have any questions about this report, please contact me at (202) 512-

9508 or Steven Haughton, Assistant Director, at (202) 512-5999. The other 

key contributors to this assignment were Christine Fant and Estelle Tsay.

Linda M. Calbom

Director, Financial Management and Assurance
Page 13 GAO-04-129 CGFAA Claim Payments

Appendix I

Comments from the Department of Homeland Apendxies

Security ApendxiI

(190109)
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