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53–838 PDF 2010

S. Hrg. 111–575 

NOMINATION OF DANIEL I. WERFEL 

HEARING 

BEFORE THE

COMMITTEE ON 

HOMELAND SECURITY AND 

GOVERNMENTAL AFFAIRS 

UNITED STATES SENATE 

OF THE

ONE HUNDRED ELEVENTH CONGRESS 

FIRST SESSION 

NOMINATION OF DANIEL I. WERFEL TO BE CONTROLLER, OFFICE OF 

FEDERAL FINANCIAL MANAGEMENT, OFFICE OF MANAGEMENT AND 

BUDGET 

SEPTEMBER 16, 2009 

Available via http://www.gpoaccess.gov/congress/index.html 

Printed for the use of the 

Committee on Homeland Security and Governmental Affairs 

( 


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COMMITTEE ON HOMELAND SECURITY AND GOVERNMENTAL AFFAIRS 

JOSEPH I. LIEBERMAN, Connecticut, Chairman 

CARL LEVIN, Michigan 

DANIEL K. AKAKA, Hawaii 

THOMAS R. CARPER, Delaware 

MARK L. PRYOR, Arkansas 

MARY L. LANDRIEU, Louisiana 

CLAIRE MCCASKILL, Missouri 

JON TESTER, Montana 

ROLAND W. BURRIS, Illinois 

MICHAEL F. BENNET, Colorado 

SUSAN M. COLLINS, Maine 

TOM COBURN, Oklahoma 

JOHN MCCAIN, Arizona 

GEORGE V. VOINOVICH, Ohio 

JOHN ENSIGN, Nevada 

LINDSEY GRAHAM, South Carolina 

ROBERT F. BENNETT, Utah 

MICHAEL L. ALEXANDER, Staff Director 

KRISTINE V. LAM, Professional Staff Member 

TROY H. CRIBB, Counsel 

JOHN P. KILVINGTON, Staff Director, Subcommittee on Federal Financial Management, 

Government Information, Federal Services, and International Security 

BRANDON L. MILHORN, Minority Staff Director and Chief Counsel 

JENNIFER L. TARR, Minority Counsel 

LISA M. NIEMAN, Minority Counsel 

TRINA DRIESSNACK TYRER, Chief Clerk 

PATRICIA R. HOGAN, Publications Clerk and GPO Detailee 

LAURA W. KILBRIDE, Hearing Clerk 


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C O N T E N T S 

Opening statement: Page 

Senator Carper ................................................................................................. 1 

Prepared statement: 

Senator Carper ................................................................................................. 21 

WITNESS 

WEDNESDAY, SEPTEMBER 16, 2009 

Daniel I. Werfel to be Controller, Office of Federal Financial Management, 

Office of Management and Budget: 

Testimony .......................................................................................................... 4 

Prepared statement .......................................................................................... 26 

Biographical and financial information .......................................................... 29 

Responses to pre-hearing questions ................................................................ 39 

Letter from the Office of Government Ethics ................................................. 70 

Responses to post-hearing questions for the Record ..................................... 71 


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NOMINATION OF DANIEL I. WERFEL 

WEDNESDAY, SEPTEMBER 16, 2009 

U.S. SENATE, COMMITTEE ON HOMELAND SECURITY

AND GOVERNMENTAL AFFAIRS, Washington, DC. 

The Committee met, pursuant to notice, at 10:04 a.m., in room 

SD–342, Dirksen Senate Office Building, Hon. Thomas R. Carper, 

presiding. 

Present: Senator Carper. 

OPENING STATEMENT OF SENATOR CARPER 

Senator CARPER. Good morning. The Committee will come to 

order. 

Today, we will be considering the nomination of Daniel Werfel to 

be Controller of the Office of Federal Financial Management at the 

Office of Management and Budget (OMB). 

Mr. Werfel is no stranger to this Committee or to the Subcommittee that I am privileged to Chair, the Subcommittee on Federal Financial Management. During his time as Deputy Controller 

and Acting Controller, my staff and I have worked closely with him 

and his team on a number of the most pressing financial management challenges facing our Federal Government. 

I am pleased that the President has sent us such a qualified candidate for this position. As I am sure Mr. Werfel will point out in 

his opening statement, he has extensive experience within the Office of Federal Financial Management. He has also taken the lead 

on a number of key issues, including some of the tough work related to the implementation of the American Recovery and Reinvestment Act, so he knows very well the challenges that lie ahead 

should he be confirmed. And I will touch on just a few of those 

challenges. 

First, there is the issue of improper payments. 

An improper payment occurs when Federal funds go to the wrong 

recipient, when a recipient receives the incorrect amount of funds, 

when funds are used in an inappropriate manner, or when documentation is not available to explain why a payment was made in 

the first place. 

In fiscal year 2008—the most recent year for which data are 

available—agencies made an estimated $72 billion—that is billion 

with a ‘‘b’’—in improper payments, most of them overpayments. 

The actual amount of improper payments made by Federal agencies is actually probably much higher. The $72 billion total reported does not even include estimates from the Medicare PrescripVerDate Nov 24 2008 13:20 Aug 19, 2010 Jkt 053838 PO 00000 Frm 00005 Fmt 6633 Sfmt 6633 P:\DOCS\53838.TXT SAFFAIRS PsN: PAT

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tion Drug Program or several other high-risk programs at the Department of Homeland Security and elsewhere. 

This is unacceptable. The kind of waste and mismanagement 

represented by these improper payments estimates we see each 

year undermines taxpayers’ faith in government. Unfortunately, 

despite the progress that has been made over the years—and 

progress has been made—in highlighting improper payments and 

reducing error rates in some instances, too many agencies continue 

to make avoidable mistakes and, as a result, waste billions of dollars that could have been put to better use. 

I am told that the Social Security Administration—an agency 

that actually makes relatively few improper payments—sent thousands of $250 checks to ineligible recipients after the enactment of 

the Recovery Act. I am certain that very little of that money will 

help us create jobs or get our economy going again. 

We need to get our arms around this problem. We need to help 

agencies improve transparency in this area, to prevent mistakes 

before they happen, and also to more aggressively recover improper 

payments that are made. The Improper Payments Elimination and 

Recovery Act, S. 1508—legislation that I introduced this summer 

with a number of my colleagues and that was reported out of Committee in July—would help in all three of these areas. And I know 

that you are familiar with this legislation, Mr. Werfel, and I am 

pleased to hear from my staff that you plan to make improper payments a priority of yours, if you are confirmed. That is great news. 

The second area I want to touch on is property management. Not 

too long ago, it would have been hard for us to even know how 

many buildings or other structures Federal agencies owned. Tremendous progress has been made in recent years, however, in identifying Federal assets and learning more about their condition. 

What we have learned is that there are a great number of assets— 

some 20,000, I am told—that are actually classified as ‘‘excess.’’ 

This means that we no longer need them but are still paying year 

in and year out to maintain and secure them. In addition, tens of 

thousands more assets are underutilized, meaning we are not getting all that we could out of them. 

Now, this seems like a relatively easy problem to address,. but 

unfortunately, the property disposal process laid out in current law 

is costly, and it takes a significant amount of time. In addition, 

agencies looking to sell a piece of property are not even permitted 

to retain sale proceeds, even when preparing an asset for sale 

might be fairly costly. 

There is probably much that agencies can do now under the current rules to improve property management and offload assets they 

no longer need. But I look forward to working with you if you are 

confirmed to make the common-sense changes necessary to build 

on the progress that has been made to date in this area. 

Finally, I would like to touch on Federal financial reporting. 

Each year, the major Federal agencies issue audited financial 

statements. These documents do not usually receive much attention from the press or the public at large, but those of us with responsibility for paying attention to them have noticed that they 

have improved in quality and timeliness over time, particularly in 

recent years. You and your team at OMB deserve credit for that, 


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Mr. Werfel. But one major challenge ahead of you, if confirmed, is 

getting an opinion on the Federal Government’s consolidated financial statements. 

Over the years, the Government Accountability Office (GAO) has 

never been able to render an opinion on this statement. This essentially means that our books are still such a mess that the GAO 

audit team just cannot make sense of them. That is troubling from 

a transparency perspective, and other perspectives as well. And it 

also shows that we have plenty of work to do in our efforts to professionalize financial management in the Federal Government. Any 

private sector company with annual financial statement audit results like the Federal Government’s would probably not be in business for very long. 

Let me just convey my thanks to you, Mr. Werfel, for the work 

that you have done in all of these areas over the years and for your 

willingness to continue that work. And when we finish swearing 

you in, you will have an opportunity to introduce your family. It 

was a special treat to have a chance to meet your parents and to 

see that they raised at least two sons—I don’t know if there are 

more than you and your brother here. But we want to thank them 

for instilling in you the kinds of values that are demonstrated in 

the work that you do for the people of this country. Thank you 

both. And you sort of turned him over to Beth, his wife, and she 

has continued the training ever since, and we are just delighted 

that you are here today and that you are willing to share your husband with the people of our country. 

And to Sean and Molly, thank you for coming, and it is nice to 

see you both and to meet you, and we are very glad that you could 

join your Dad on this special day. 

To others, to Jeff Zients, who is our Chief Performance Officer 

and just a valuable new member of our team, an important member of this team, we are happy that you are here, along with other 

members of our extended OMB family. 

The fact that there are not a lot of other members here is actually a good sign because if they were here, that would probably 

mean that this is a nomination that is in trouble. And the fact that 

these seats are very empty is probably a positive sign. 

Mr. Werfel has filed responses to a biographical and financial 

questionnaire. He has also answered pre-hearing questions submitted by the Committee. In addition, his financial statements 

have been reviewed by the Office of Government Ethics. Without 

objection, this information will be made part of the record. The financial data, however, will remain on file and available for public 

inspection in the Committee’s offices. 

Committee rules require that all witnesses at nomination hearings give their testimony under oath, and, Mr. Werfel, I am going 

to ask you to please stand and raise your right hand at this time. 

Do you swear that the testimony you will give before this Committee will be the truth, the whole truth, and nothing but the 

truth, so help you, God? 

Mr. WERFEL. I do. 

Senator CARPER. Please be seated. 

When we start with the questions in a few minutes, I am going 

to ask you initially three standard questions, and I think you are 


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1The prepared statement of Mr. Werfel appears in the Appendix on page 26. 

aware of that. But before we get into any questions, I would like 

you to go ahead and make your statement, and if you would like 

to introduce your family further, feel free to do so. We are delighted that you are here and grateful for your willingness to serve. 

Proceed. 

TESTIMONY OF DANIEL I. WERFEL,1 TO BE CONTROLLER, OFFICE OF FEDERAL FINANCIAL MANAGEMENT, OFFICE OF 

MANAGEMENT AND BUDGET 

Mr. WERFEL. Thank you. Chairman Carper, I am honored and 

humbled by the opportunity to come before you as President 

Obama’s nominee for Controller of the Office of Federal Financial 

Management within OMB. I would like to thank OMB’s Deputy Director for Management Jeff Zients for being here today. I also appreciate the support of OMB Director Peter Orszag and Deputy Director Robert Nabors. I have had the distinct privilege of working 

with these three great leaders over the past several months. 

Through their hard work, unyielding demand for results, and belief 

in the importance of strong analytics to support the right public 

policies, they have inspired me and others at OMB to reach deeper 

within ourselves to help deliver a higher performing government. 

I am grateful to each of them for supporting my nomination and 

thus demonstrating their faith in me as a leader and as a public 

servant. 

I am very grateful to have my family with me this morning, supporting me today as they have through every step of my life. I 

would like to introduce my wife of 12 years, Beth; my two children, 

Sean and Molly; my parents, Fred and Barbara; and my brother, 

Steven. I would also like to recognize members of my family not 

here today: My sister, Lori, and her family, as well as my brother 

Steven’s wife and children, who I know are all in New York right 

now cheering me on; also, my mother-in-law, Elaine, and my father-in-law, Dave, doing the same in Ohio. Throughout the years, 

I have relied on my family for strength, and I thank them for their 

continued support during this process. 

For more than 12 years, I have had the honor of working as a 

public servant for the U.S. Government. Over this time, I developed both a penchant and a sustained passion for improving financial management practices across government. Fueling this passion 

is my firm belief that one of the government’s most critical responsibilities is to serve as an effective steward of taxpayer dollars and 

that this responsibility can only be met if the Federal financial 

management community is doing its part: Tracking and accounting 

for taxpayer dollars; initiating internal controls that mitigate the 

risk of fraud and error; publicly reporting reliable information 

about the government’s finances; and strategically integrating financial information into decisionmaking. 

For the past 5 years, I have played a leadership role within OMB 

and in the broader financial management community advancing 

these efforts and have gained important perspectives on the 

strengths, weaknesses, challenges, and opportunities associated 

with these efforts. 


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This experience has led me to the conclusion that although important progress is being made, as you noted, a significant amount 

of work remains to be done. At too many Federal agencies, persistent weaknesses in basic financial management practices lead to 

unreliable reporting, payment errors, and other forms of government waste. Of note, the amount of remaining improper payments 

on the government’s books is staggering and must be corrected. 

Moreover, the sweeping challenges we face in the government 

today require our financial managers to move beyond the basics of 

accounting and reporting. Fortunately, the tools to overcome these 

challenges are either at our disposal or are otherwise obtainable. 

We have detailed inventories of improper payments and unneeded 

real estate. We have a growing number of agencies and professional staff who have successfully overcome financial management 

challenges and who can provide others that road map. We have 

technologies and processes emerging out of the private sector that 

can enable lower risk and cost solutions. And from Congress and 

the public, we have a growing demand for financial information 

and a growing frustration with spending improprieties that are 

serving as a catalyst for action and improvement in financial management shops across government. 

If confirmed, I will work with Congress, OMB leaders, and the 

larger financial management community to leverage these tools to 

forge new and unprecedented results in financial management. 

Success will be measured along the following key areas and priorities: Eliminate inefficient government spending, such as improper 

payments and unneeded real estate; right-size the cost of financial 

management operations across government; drive improvements in 

grants management; effectively implement the transparency requirements of both the Federal Funding Accountability and Transparency Act and the American Recovery and Reinvestment Act; 

and remediate persistent weaknesses in basic financial management practices. 

I am both humbled and energized by the opportunity to play a 

leadership role in these efforts. For as long as I can remember, I 

have felt the call for public service. Since arriving in the Federal 

Government, I have been blessed with supervisors, colleagues, 

staff, and other peers and mentors who have helped me grow as 

a professional and as a leader. In particular, the team of civil servant professionals at the Office of Federal Financial Management at 

OMB has been a family to me for more than 5 years, and together 

we have formed a team that I believe to be as productive and hardworking as any in government. I am thrilled for the opportunity to 

lead the Office of Federal Financial Management as we take on 

these new and growing challenges. Working closely with Peter 

Orszag, Robert Nabors, Jeff Zients, and the leadership team they 

are assembling, I am confident that we can advance financial management to a new and sustainable level of excellence that helps enable the government to meet that most critical of responsibilities: 

Serving as an effective steward of taxpayer dollars. 

Mr. Chairman, I would be pleased to answer any questions you 

may have. 

Senator CARPER. Great. Thank you very much for that statement. 


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As I said earlier, I am going to start by asking you three standard questions that Committee rules require that I ask. 

First, is there anything you are aware of in your background that 

might present a conflict of interest with the duties of the office to 

which you have been nominated? 

Mr. WERFEL. No, I do not. 

Senator CARPER. All right. I am tempted to look at your brother 

over there to see if he has anything he could add to that response. 

[Laughter.] 

But I will not. I think that is outside of the rules. 

Do you know of anything, personal or otherwise, that would in 

any way prevent you from fully and honorably discharging the responsibilities of the office to which you have been nominated? 

Mr. WERFEL. No, I do not. 

Senator CARPER. Do you agree without reservation to respond to 

any reasonable summons to appear and testify before any duly constituted Committee of Congress if you are confirmed? 

Mr. WERFEL. Yes. 

Senator CARPER. So far, so good. I want to come back to improper 

payments for a little bit, if I could. I have spoken, I believe, with 

you before and with Mr. Zients about some work that is going on 

within the Department of Health and Human Services to try to go 

out and recover monies that have been improperly spent, I think 

with respect to Medicare. And as you know, we are going through 

a lot of debate on health care reform, trying to figure out how to 

provide better health care for less money. And we have learned 

that we have misspent, inappropriately spent a lot of money—some 

of it for medical equipment, but a lot of people have set up bogus 

companies and have billed Medicare for services never provided. 

What we started doing is going out to recover some of that 

money. I think we started about 3 years ago, and we just were focusing on three States. And I think we used private sector firms 

to go out and try to do the recoveries. The first year, I am told, 

they did not recover much at all. The second year they recovered 

a little more. Then last year they recovered about $700 million in 

just three States. And I believe the intent is to go out and to try 

to replicate that in the remaining 47 States. 

Are you aware of this initiative? And could you talk about it at 

all? 

Mr. WERFEL. Yes, Senator. I am very aware of this program. The 

Medicare recovery audit program is about hiring contractors on a 

contingency basis to go out and find the errors that are occurring 

in the program, and these errors typically occur when we reimburse hospitals and doctors for procedures that did not occur or for 

the wrong procedure or too much money. A good example of that 

would be our reimbursing a hospital for magnetic resonance imaging (MRI) when only an X-ray occurred. The MRI is much more expensive, so we are reimbursing them for the wrong amount. 

The strength of this program is the incentive that is set up. I 

think you mentioned earlier that agencies made $72 billion in improper payments across government, and one of the lessons 

learned, as we have studied those improper payments and tried to 

figure out what the root causes are and how we can do better, is 

that a promising strategy that can be employed is to make sure 


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that all the stakeholders involved, from the Federal agency down 

to the recipients and the States and everyone involved, have an incentive to both root out and find these improper payments and 

then go recover them on behalf of the taxpayer. And in this case, 

that incentive is very strong because the private contractors being 

hired are paid based on their ability to find those errors and recover those funds. 

And so with that incentive structure in place, we have seen significant results, as you mentioned, close to $1 billion in just three 

States, and now we are in the process of expanding that to all 50 

States with a target completion of January 2010 to have it up and 

running throughout the United States. 

We are very excited about this program. In particular, how can 

we use this example and this model of finding the right incentives 

and getting the right players involved to remediate improper payments in other programs as well? 

Senator CARPER. Would you just think out loud for us and think 

about how we might extend these lessons learned from this demonstration in these three States to Medicaid, where both the State 

and the Federal Government share in the cost of expenditures? 

Mr. WERFEL. Yes. The two programs obviously are both Federal 

programs supporting health care, and they operate somewhat differently. As you mentioned, Medicaid dollars flow through the 

States, and the implementers of the Medicare program are hired 

contractors that are processing these Medicare claims. 

With Medicaid, I think the question then becomes, because of the 

role the States play in implementing the program, finding the right 

incentives for the States to understand where their risks of errors 

are and to be taking the steps that are necessary. Thinking out 

loud as you mentioned, to draw the analogy, if the private contractor is getting a financial benefit from going out and finding the 

error, some of it is coming back to the Medicare trust fund, but 

some of it is going to the contractor. We might want to think about 

similar incentives for States where they are rewarded financially 

for uncovering errors, so that all the money is not necessarily returned to the government, but a portion of the money is returned 

to the State to invest in other activities and priorities. 

So often—and I think we will see this when we talk about real 

property as well—the financial incentive of going out and finding 

the problem and correcting it is a powerful tool, and I would think 

that is one example where the States might end up with a more 

aggressive approach and more resources being spent on these efforts than we would otherwise have seen. 

Senator CARPER. And I would just hope, as we extend the threestate demonstration for Medicare cost recovery to the other 47 

States, that we will begin preparing to extend the same kind of 

cost-recovery approach to Medicaid. 

One of the approaches we use in health care reform to extend 

coverage to people who do not have it is to require States to provide coverage to a higher level of poverty. I think we are going to 

ask them to begin covering childless adults whose income is up to 

maybe 130 percent of poverty. And so that will be more money that 

the Federal taxpayers will be paying, also eventually probably 

some additional contribution from the States. The States are hard 


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pressed, as you know. Medicaid is a big cost driver for them. And 

we need to find ways to relieve that burden from them and also 

relieve the burden on the Federal taxpayers. If we can come up 

with $700 million in Medicare in 1 year from three States, there 

has to be money out there to recover from Medicaid. 

When I think of improper payments, I think of it in three steps. 

The first is to identify the improper payments and have reporting 

occur, identify and report. The second is to take steps to reduce the 

incidence of improper payments. And the third is to recover to the 

extent that we can. So it is actually four: Identify, report, reduce, 

and recover. 

We appreciate the work that has been done. It was not that 

many years ago we were, frankly, doing a lousy job identifying and 

reporting. I think we are doing a much better job of identifying improper payments, although not all agencies are. But we have plenty 

of work to do. We are delighted that this is a priority for you, and 

we hope that the legislation that we are working on will assist not 

just OMB, not just the Federal agencies, but really assist the taxpayers. 

Let us talk a little bit about what I call the stimulus package, 

but some other people call it the American Recovery and Reinvestment Act. I know you have been spending a fair amount of your 

time in recent months helping the Administration to implement the 

American Recovery and Reinvestment Act. As I mentioned in my 

opening statement, at least some of the improper payment problems we see in everyday Federal programs have popped up again 

as we try to get recovery funds out the door, and that is not a complete surprise. 

How effective do you think we have been in avoiding improper 

payments in the Recovery Act programs? And if confirmed, what do 

you plan to do to make certain that the remaining Recovery Act 

funds, which would be over half of them, are used for job creation 

and activities that will grow the economy rather than adding to 

agencies’ improper payment estimates? 

Mr. WERFEL. Senator, the Recovery Act, I would like to say, has 

many tensions in it, and one of the more critical tensions is the 

need to get money out to State and local economies so it can start 

having its stimulative effect and to get that money out quickly. But 

at the same time, we all have an important interest and duty to 

make sure that money is spent wisely and appropriately. And often 

we need to take important steps before the money goes out to make 

sure that the funds that we are sending are the right amount, 

going to the right people, and for the right purpose, and that can 

take time. 

So from the beginning of this process, going back to the day after 

the law was enacted on February 18, 2009, OMB issued guidance 

to the agencies that tried to find the right equilibrium between this 

tension of getting the money out quickly and being diligent in making sure the money was paid out correctly. 

One of the things we did to try to achieve that balance was have 

every agency initiate a risk management process where they were 

looking for what are the potential sources of error and mistakes 

that could be made. And we worked with them to identify certain 

symptoms or issues that could be at play. 


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So, for example, if a program was being funded at 500 or 600 

percent more than it had previously as a result of the Recovery 

Act, more money going out into a standard channel could create 

risks of mispayments because the capacity at the organization 

might not have been built up yet to do all those thorough reviews. 

So we asked them, since there is a risk, can you put in a risk mitigation plan to make sure that you are moving and realigning resources? Do not assume that if you had five people working to review prepayments of a $100 million program, those same five people can do the job of a $600 million program. 

That was a very critical step that we took, and you asked me 

what progress has been made. Right now the best we understand 

is evaluating the steps agencies have taken to do all those prepayment controls and those activities in an accelerated way. And what 

we are seeing from the agencies is those agencies have taken their 

risk management responsibilities very seriously. The agencies have 

risk management plans in place. They are not collecting dust on a 

shelf. They are being implemented and initiated. 

We recently went out to the agencies to ask them about their 

risk management plans, and we got a very enthusiastic response 

in terms of that process itself and how it is working. 

The question of how we are doing I think is something about 

which, if confirmed, I will come back and talk to you when we start 

auditing these payments out in the field and figuring out what our 

error rates are. I know there are some early audits already going 

on. I am not aware of the full results of those audits, but they probably will be coming in the near future. 

I think it is a very good sign that we are aggressively out there 

already auditing and looking for improper payments within months 

after the Recovery Act was passed. So that is a sign of progress. 

But once we figure out what the level of error is, what is going on 

in the field, and why these errors are being made, the most critical 

thing we can do is start changing our approaches around why these 

errors are occurring, modifying our risk management plans, and 

doing something that was in my written responses that I think is 

really critically important to manage that tension that I described, 

and that is, communicating early and often with the auditors about 

what is going on. 

I think a big shame would be if an auditor goes out to the field 

and audits a payment and says, ‘‘Wow, I found a mistake, and this 

seems to be one that could be systemic, but I will wait 6 weeks before my final audit report is due before letting the agency know’’— 

which is something that typically happens in government—we have 

to end that practice. We have to be in a place where, as soon as 

the auditor sees a problem, they are communicating earlier and collaboratively with the financial managers to make those changes. 

And that is one of the things that we are doing in our guidance, 

which is facilitating and encouraging these types of early interventions. And I am thankful that Earl Devaney at the Recovery Board, 

who is leading the Inspectors General on this effort, has really emphasized that in all of his interactions with the audit community 

as well. 

It is time to roll up our sleeves and make sure we are getting 

the information as soon as possible. 


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Senator CARPER. Good. There is actually a corollary with identifying the mistakes in the area of health care. Mistakes are made 

every day. Even while we are having this hearing, mistakes are 

being made in hospitals. Sometimes they cause serious injuries. 

Sometimes they take someone’s life. And, historically, there has not 

been a really good admission that someone has made a mistake because of maybe concerns about malpractice suits or there is just a 

reluctance, maybe it is an embarrassment. But health care providers—doctors, hospitals, nurses—are beginning to come forward 

and say, ‘‘Look, when we make a mistake, let us talk about it. Let 

us not keep it to ourselves. Let us learn from that mistake.’’ Was 

it Richard Nixon who used to say that the only people who do not 

make mistakes are people who do not do anything? And so we all 

make mistakes, but the important thing is for us to, as you suggest, act on those mistakes, make sure that we do not continue to 

make the same mistake. 

Before I turn to property management for a few minutes, let me 

just say again I am encouraged that most agencies are doing a 

much better job now identifying and reporting improper payments. 

And some agencies are doing a good job reducing those improper 

payments. We have plenty of work to do in all three of those areas, 

but I especially am anxious to see us really hit the road running 

on recovering money as much as we can. 

During the last 8 years in this country, we literally incurred as 

much new debt as we did in, I think, the first 208 years of our Nation’s history. That is pretty staggering. In 8 years we ran up as 

much new debt as we did in the first 208 years of our Nation’s history. This year, we are on track to run up the biggest single-year 

deficit ever. It will be over $1 trillion. And we are told, probably 

by OMB or CBO, or both, that if we leave spending and taxing revenues on autopilot, we will rack up about maybe $9 trillion worth 

of debt over the next decade, none of which is acceptable. It would 

not leave much of a future for your kids or for mine or for any of 

our children. So that is not acceptable. 

The work that we are doing here, this is real money. This is real 

money that we are talking about, not spending or not wasting. And 

it is just important that we get it right. I am pleased to hear about 

the enthusiasm that the folks in the field have as they are looking 

for improper payments that flow out of the stimulus package. That 

is great news. 

Another issue that we spent some time together on is property 

management, and as I have noted, we have made strides in recent 

years with respect to, I think, identifying and categorizing the assets that we, as a Nation, own. As a result of that work, we now 

know that there are literally tens of thousands of buildings and 

other structures across our country that are owned by Federal 

agencies and that are either no longer needed or, in some cases, 

are just underutilized. 

Let me just ask you to dwell on this with us for a few minutes. 

What do you think is the root of the problem? What steps do you 

hope that OMB and the Federal agencies and those of us here in 

Congress can take to address it? And I would say included in that 

list are the Inspectors General (IGs). What can they do? What can 

this team do together to address this concern? 


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Mr. WERFEL. I want to start with mentioning that where we are 

today with real property is a place where we have a very strong 

foundation of tools and inventory and information to understand 

what is going on and to understand what those root causes of the 

problems are. We have, as you mentioned in your opening statement, a comprehensive inventory of the 1.2 million separate constructed assets that the Federal Government owns. 

Senator CARPER. Would you just give us a broad array of examples of the constructed assets? 

Mr. WERFEL. The general categories that we place these assets 

in are administrative buildings, warehouses, labs, and hospitals. 

There are also unique assets that we have, like launch pads, and 

the Department of Energy owns many sites that are environmental 

cleanup-related and other types of research that is being done. 

And then we own a lot of land and property as well—roads and, 

the Federal Aviation Administration (FAA) owns a lot of antennas 

and different types of assets that are out there. So it is not 1.2 million different buildings, but I think the important thing is just 

start focusing on where there are communities of assets for opportunity, like administrative buildings and warehouses, labs, hospitals, housing, etc. 

When we collected this information—we did it since 2004—we 

did, I think, a very smart thing in collecting not just where the 

buildings are and what they are used for, but we also asked the 

Federal agencies to describe whether those buildings are mission 

critical or not, what their utilization rate is, what their condition 

is, and what their cost is. And by doing that, we have been able 

to tier our assets between those that are not mission critical, underutilized, operating at an unacceptably high cost, and are in poor 

condition. And we also know on the other side of that spectrum 

where the assets are mission critical, fully utilized, etc. 

And so for the first time, we were able to do data culls and figure 

out where are the assets that need our attention. And as you mentioned, we have 20,000 assets through this process that have been 

currently excessed, but 65,000 additional assets that are underutilized but not excess. And that allows us to bring the agencies before us and ask: Why are your underutilized assets not yet 

excessed? So we can push them on that. 

Why are we in this condition? Why do we have 20,000 excess assets that have been sitting on our books? And why do we have 

65,000 underutilized assets that have not yet been excessed? 

I think there are two key reasons for it. The first goes back to 

our earlier discussion on improper payments with respect to incentives and making sure that the Federal agencies involved and the 

facility managers around government have an incentive to report 

something as excess and then try to get rid of it, that we break a 

culture of, well, if I have it, why would I give it up, and that we 

break a culture of not thinking progressively and proactively about, 

I have an asset, it is functioning, but if I think about it differently, 

maybe it really is excess because maybe I do not need two buildings 10 miles from each other, both half-filled; maybe there could 

be consolidation efforts. 

We have an army of Federal facility managers out there, and we 

need to incentivize them and their leaders to derive benefit from 


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going through this process of identifying their excess and getting 

rid of it. 

The other root cause of why we are where we are is that we are 

operating under a framework from a law that was enacted in 1949 

for how we get rid of our assets, and it is a very bureaucratic process. A lot of steps need to be taken. It takes a long time, and that 

does two things. First of all, it keeps things in the pipeline longer 

than necessary, but it also serves as a disincentive to those very 

same facility managers because not only do they have to now give 

up square footage that they currently have within their domain, 

but now they have to go through a very long and winding process 

to get rid of it. And the incentive structures just are not aligned. 

I think what is appropriate remediation of those two situations 

is to structure the real property environment such that managers 

are getting some financial incentive for disposing of their assets 

and also seeing if we can streamline the disposition process so that 

we can move these properties more quickly. 

Senator CARPER. When you say managers should receive some 

kind of financial incentive, would they be managers, agencies, or 

both? 

Mr. WERFEL. Yes, it is really the agency as a whole. When I have 

historically worked with the senior real property officers at agencies, they present this frustration that they do not have the funds 

or the resources that they need to invest in their mission-critical 

assets and get them into a place where they are functioning better 

so that they are serving the employees so they can do their mission, but also functioning better so their carbon footprint, for example, is smaller. 

There is an obvious connection that can be made there, and that 

is why we call it right-sizing the Federal inventory. If you can get 

rid of the assets that you do not need and get proceeds or derive 

economic benefit from that disposition, it enables you to make capital investments in those assets that you do retain. Overall, it has 

a good impact on budgetary pressure because you do not need as 

much money to invest in our Federal infrastructure, and you are 

getting a better Federal infrastructure. 

One of the sayings we have in the real property community is, 

‘‘You can spend $7,000 today to repair the roof or $7 million 3 

years from now to replace it.’’ And what we need to do is make sure 

that we are getting those funds at the right time and at the right 

place so we are avoiding these types of bad decisions where we are 

allowing the roofs to get to that level of disrepair. 

Senator CARPER. Can you give us an example of an agency or two 

within the Federal Government where they actually have aligned 

the incentives in an appropriate way and they are able to serve as 

a model maybe for other agencies? Any come to mind? 

Mr. WERFEL. Yes, there are several agencies that have their own 

authority to retain proceeds and reinvest them. The U.S. Forest 

Service comes to mind, as well as the U.S. Department of Veterans 

Affairs (VA) is another. 

I will emphasize the VA’s program in particular, and I do not 

mean to indicate that it is perfect, but the benefit, I think, of the 

VA’s program—I know the acronym is CARES, the Capital Asset 

Realignment for Enhanced Services. It is a dedicated initiative 


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around thinking about hospital construction. In a very general 

sense, I have heard it argued that the veterans population is tending to move from the Northeast United States to the Southwest 

United States, which leaves us in a situation where you have overcapacity of hospitals in the Northeast and undercapacity in the 

Southwest. 

And so they have built a program around thinking about how 

you right-size and invest smartly, and with some of the tools that 

they have through the CARES program to do it, there have been 

some successes. 

Now, there have also been issues, and that is where OMB can 

come in and say, are you sure you need new hospital square footage in this area? That is one of the processes of working effectively 

when you are thinking about it strategically and when you have a 

second set of eyes coming in and making sure and saying you have 

these new authorities, but let us not overbuild, let us make sure 

that we acquire new square footage strategically and smartly. 

Senator CARPER. Have you all given some thought and attention 

to another related concern, and that is with respect to agencies 

making decisions to lease property as opposed to purchasing it? In 

the short term, that appears to be the financially smart thing to 

do, but over the life of the property, it turns out not to be so wise. 

Mr. WERFEL. And that is something that needs to be a part of 

a real property improvement initiative going forward. We have to 

do a better job of isolating where poor lease decisions arise, as I 

think I said, before the parameters or the ingredients of a bad leasing decision, and make sure that we are again managing risks such 

that we are not entering into those. 

Some leasing decisions are smart. It depends on the circumstances. But, for sure, if you are about to enter a very large 

facility for many years and it is uniquely suited to your needs, then 

those are the kinds of situations where a lease makes little sense 

because you know you are going in and you know it is a unique 

building, and we should be owning those buildings if we are going 

to be there for the long term and not entering into non-economical 

lease situations. 

But if we need flex space, and we are over capacity, let us say, 

at ‘‘Main Justice’’ downtown and need more space to put more people, and it is thought to be a temporary fix, that is where a lease 

makes sense. So it is figuring that out and doing a better job as 

a Federal Government. 

Senator CARPER. All right. A different question, a different area. 

As you know, progress has been made in recent years in improving 

the quality and, I think, the timeliness of agencies’ financial statements. Plenty of work remains to be done in this area, however, 

including getting an opinion on the Federal Government’s consolidated financial statements. 

Can you take just a few minutes to talk about the progress that 

has been made in agency financial reporting over the years and the 

benefits those improvements have brought, first of all, to individual 

agencies? And after that, could you give us some insight into your 

plans in this particular area, if confirmed? 


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Mr. WERFEL. Absolutely, and this is clearly in the sweet spot of 

the Office of Federal Financial Management and our core responsibilities under the Chief Financial Officers Act of 1990. 

Most recently, we had, I think, a very important strategic push 

in financial management to do a better job on our financial statements. I think there were a lot of issues at play that brought that 

on, but, in particular, the Enron situation and the passage of the 

Sarbanes-Oxley Act really energized the Federal community 

around thinking more aggressively about getting our financial 

statements in order. And since that time, since Sarbanes-Oxley was 

passed and OMB issued OMB Circular A–123, which is the government’s version of Sarbanes-Oxley, I have not done a statistical 

study of it, but there has been a significant improvement across 

government. We went from something like 62 auditor-identified 

material weaknesses down to 32 in a span of 3 or 4 years, and that 

was in large measure because there was more accountability at the 

agencies for achieving these efforts and more integration has started to occur, and that is something that A–123 pushes; that it is not 

just a Chief Financial Officer (CFO) responsibility to fix your fundamental financial management challenges; it is the responsibility 

of program managers and procurement officers. And so what A–123 

does is it establishes these senior teams from different domain 

areas to go out and be accountable for and tackle financial management challenges together. 

We have 21 clean opinions now out of 24 CFO Act agencies, and 

as I mentioned, we have seen steep declines in material weaknesses. 

Another important point—and this is more to just say we have 

a foundation and we have proven we can do it—is we have accelerated financial statement publication from 5 months after the end 

of the fiscal year to 45 days. And that had so many benefits to it, 

but in particular, it forced agencies to be planning much earlier in 

the year, rather than waiting until September or October, the end 

of the fiscal year, to do everything and close down the books. If you 

are going to do it in 45 days, you need to be working throughout 

the year. And what happened is agencies started buildings disciplines around that, and that started to improve the standardization of approaches. 

With financial statement audits, it is always variance that gets 

you in trouble. When things look different every time you do it, 

that is a bad thing. It should always look the same every time you 

do it. These are basic financial transactions, and there needs to be 

consistency and coherence. 

What is interesting is even though we have 21 agencies who all 

have various complex challenges—they all face the same issues, 

they all have human capital issues of trying to make sure they get 

the right people with strong accounting skills, strong analytical 

skills into their shops to help tackle these problems—we still have 

three agencies—the Department of Homeland Security (DHS), the 

National Aeronautics and Space Administration (NASA), and the 

Department of Defense (DOD)—that have yet to cross the finish 

line here. They are each making progress, but not the type of 

progress that I think is acceptable at this point, and we should 

be—— 


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Senator CARPER. How do we better ensure that they make the 

kind of progress that would be acceptable? 

Mr. WERFEL. I think one of the things we have to do with each 

of those agencies is relook at their corrective action plans, and we 

have to try to find, I think, a moment of truth for these agencies. 

November 15, which is the day the financial statements are due, 

is a nerve-racking day for every agency in government. This is the 

day they find out whether they passed or they did not pass, and 

it is a rallying cry for those organizations. And what I have noticed 

with NASA, Homeland Security, and the Defense Department is 

sometimes they do not have that same urgency. I do not get the 

frantic phone calls in October about what is going on from the CFO 

in those agencies the way I do from the others. And that frantic 

phone call is important. It tells me that they are looking at the 

problems and doing everything they can to fix it. 

And so I have talked to each of those agencies in my role as Deputy Controller about building these moments of truth. Even though 

they are not ready yet to produce that financial statement on November 15, can they have those financial managers feel like something has to happen that is positive, that the Secretary cares 

about, that the Administration cares about, and that Congress 

cares about to make sure that they are giving me those frantic 

phone calls that let me know things are happening. 

Senator CARPER. Well, one of the agencies you just mentioned— 

and I would like to drill down on this one just a little bit—is the 

Department of Defense, which has a lot going on these days. I 

think we will all readily acknowledge that. But I think we are 

going to have a tough time getting the government’s overall books 

in order as long as the Department of Defense is an outlier in this. 

What do you think has been holding DOD back? What can, first 

of all, the Department’s leadership do to make improvements? And 

what could you do in your new position, if confirmed, to help them? 

Mr. WERFEL. The Defense Department is the longest pole in the 

tent here for us to get a clean opinion on the consolidated financial 

statements, so we really do need to tackle this problem if we are 

going to be successful on the consolidated financial statements. 

What do I think needs to happen at the Defense Department? I 

have worked very closely with DOD over the past several years trying to analyze and understand the challenge, which is getting the 

Defense Department a clean opinion. And it is a massive challenge. 

It is the largest organization in the world. It is the most complex 

organization in the world by many different parameters. 

I think if I can boil it down, I would boil it down this way: The 

Defense Department will get a clean audit opinion when the key 

program managers throughout the Defense Department believe 

that it is going to help them achieve their mission to get a clean 

audit opinion. And so what I have noticed is a practice that we 

need to get away from at the Defense Department: If you have your 

clean audit action plan and you say, step one, let us do better on 

our depreciation schedules on historical assets, let us really clean 

those up, and if the people sitting across from you who are the people implementing the programs of the Defense Department think, 

you do that but that does not help me, it helps you get a clean 


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opinion, but it does not help me do my job—then if that is your 

starting-off point, you are already behind in the race. 

But if you say, we have 20 different things we need to fix, and 

I am going to start by fixing the five things that are most critical 

to you as a manager, and if we do not fix these things together, 

then you cannot do your job effectively, that is where I think the 

Defense Department needs to be starting. It needs to be working 

with their program managers to say, out of the suite of things that 

we need to do, where are the things that are going to be most critically helpful to you? 

Just to give you an example of where I think they should be 

starting, it is with their cash and their money on hand. The fancy 

term for it is ‘‘fund balance with Treasury.’’ They have a material 

weakness with fund balance with Treasury, which means that they 

do not know how much money they have on hand, or cannot reconcile that, to meet emerging priorities. And I have talked extensively with the Office of the Chief Financial Officer over there in 

recent months, and I have said you can talk to those program managers and say without knowing what cash you have on hand, you 

are compromising your ability to serve your mission most effectively. That can inspire change and improvement, and that is the 

guiding principle, if confirmed, that I would have with the Defense 

Department, which is working very closely with them to be 

prioritizing differently around their initiatives to make sure that 

the things that they are doing are resonating with the larger Defense Department. 

That is going to take some communication with other folks in the 

Defense Department and real understanding of the nature of how 

these financial management improvements integrate into the business of the Defense Department. 

That is the type of momentum kick-start that I think is needed 

to start pushing this process forward because right now progress 

has been made, but it has been incremental. It has not been substantive, from my vantage point, and we need to start making substantive progress if we are going to tackle this issue. 

Senator CARPER. Good. Well, I want you to tackle it, and I thank 

you. Obviously, you have given it a good deal of thought, and let 

us turn that thought into action. 

I have two more questions I want to ask, and then we will wrap 

it up. As I understand it, the main part of the job of controller is 

to ensure that the agencies follow existing financial management 

policies in implementing the President’s financial management improvement priorities across government. 

Considering the small size of the staff at the Office of Federal Financial Management and the various longstanding financial management problems that agencies face, this is, I would guess, a 

daunting challenge. What challenges has the office faced in the 

past? And how would you address them in the future? Is there any 

particular philosophy that you plan to follow in dealing with agencies? 

Mr. WERFEL. Absolutely. I think we have evolved as an organization—the Office of Federal Financial Management (OFFM) was created by the CFO Act in 1990—in a way that recognized early on 

in the process that it was a relatively small size staff given the 


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enormity of the job, all the financial statements in government and 

all the fraud and the error and the waste, to try to implement policies to improve. And because of this reality of the size of the staff, 

practices have emerged in terms of collaborating with the larger 

community, in particular through the CFO Council. 

I would like to say that when OFFM writes a policy that is going 

to impact the government as a whole, we do not write it with the 

door closed and the windows shut. We write it by bringing the 

agencies in through task groups or committees of the CFO Council. 

So often I feel like sometimes I am not just managing the 17 people 

who work in OFFM; I am managing, at any given time, 20 or 25 

working groups that have spawned up around government to deal 

with these different issues. 

You can look at it through different lenses and say, if you had 

more resources at the Office of Federal Financial Management, 

what else could you do? The lens through which I look at it is this 

practice of collaboration and creating working groups has really 

worked effectively. When I think back to the way we accelerated 

financial statements to 45 days and the way we did Sarbanes-Oxley 

for government, that was completely collaborative across Federal 

agencies. And in many ways, those folks out in the agencies doing 

the work were almost like OMB employees because they were shifting between their government-wide hat and their agency hat very 

frequently and saying this is what we need to do as a government 

versus here is what I need to do back at my own agency. 

My philosophy going forward will be to improve on that even 

more. It is a partnership. If confirmed, I plan to lead the CFO 

Council by committee with other key CFO leaders throughout government so that we are a united front toward the things we want 

to get done. 

I think one of the more critical philosophies that I want to embrace to build on the collaboration that we have is best practice 

sharing. I think that one of the areas that I want to be a focal 

point of the CFO Council is the premise that there are a lot of 

amazing things going on in government, that we have CFOs, as I 

mentioned in my statement, who have tackled these problems and 

fixed them; and we have CFOs working with others who have gone 

beyond just financial statements and have taken an approach to 

say what is the business of my agency and how do I improve that 

business, how do I cut costs, how do I prevent fraud and error before it occurs. They are utilizing techniques brought over from the 

private sector, whether it is Lean Six Sigma or others, and they are 

showing great results. 

And I think, as Controller, my job would be to close the education gap and make sure that everybody is aware of the critical 

successes that are going around government so that they know 

about the tools that they may need to do similar things. And that 

is going to be an important philosophy going forward. 

Senator CARPER. Good. Well, I like that philosophy. 

DOD and a handful of other major agencies have, as we discussed, serious financial management problems that they need to 

address. Others are doing a better job. 

Is there anything you want to add about how you would take 

what works and translate it to helping those agencies—DOD is cerVerDate Nov 24 2008 13:20 Aug 19, 2010 Jkt 053838 PO 00000 Frm 00021 Fmt 6633 Sfmt 6633 P:\DOCS\53838.TXT SAFFAIRS PsN: PAT

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tainly one of those—to apply the lessons learned to their specific 

problem? I know you have spoken to this already. Is there anything 

else you want to add? 

Mr. WERFEL. I would just amplify my further response by saying 

that I think one of the things that we have to overcome in particular in financial management is the perspective that agencies 

sometimes share with us, which is that my problems are unique, 

what worked at that agency will not work at my agency. And from 

my experience and my perspective, that is less often the reality, in 

particular with financial management. Accounts payable should be 

accounts payable wherever you do it. Accounts receivable, the 

same. And although agency programs are complex and different, 

the challenges often come back to common themes of not having 

good standard practices, not documenting your procedures appropriately, and not aligning your CFO organization appropriately. 

I will just finish by saying that I think benchmarking is such a 

critical element of these activities. One of the things that I would 

want to do as Controller is make sure that each CFO who is confirmed and comes in has an understanding of how the other organizations of government are aligned and where those alignments are 

having success. I want them to be able to say: We have 17 people 

doing this type of work at the Department of Energy, and the Department of Commerce has 12 people. Why can they do it with 

less? And that would allow some realignment of resources to other 

priorities. 

Those types of benchmarking and communication has not happened to the degree that I think it can, and that is an area that 

I think we can emphasize and where we can start breeding more 

success. 

Senator CARPER. Well, those are my questions. Is there anything 

else that you would just like to offer before we wrap it up? 

Mr. WERFEL. Only that it has been a very distinct honor to have 

worked with you and your team through the years, and the opportunity, as I said in my opening statement, that the new leadership 

at OMB has provided me is just extremely humbling. I am extremely energized and excited about the challenges that we have 

and the tools that we have to take on these challenges. And I feel 

a sense of optimism. In particular, the Recovery Act is providing 

lessons learned and new partnerships. I would like to say that I 

have worked more with State and local governments in the last 5 

months than I did in the previous 5 years combined. And similarly 

with GAO, we are sitting in meetings with GAO right now and 

hammering out what the solutions are rather than us doing the solution and then 3 months later GAO telling us how they would 

have done it differently. 

These types of developments and financial management are extremely exciting, a lot of them brought on by the urgency of the Recovery Act and the challenge. And I think these lessons learned 

will serve us very well and take us to new levels. 

Senator CARPER. Good. I think you mentioned you have 17 people 

within your own office. But there are a lot of working groups that 

are out there that you are spawning and sort of overseeing. 

We are relatively small. We share a lot of the same interests in 

making sure that the taxpayer dollars that we are spending we are 


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spending prudently, wisely, and in a cost-effective way. Given the 

kind of budgetary challenges that we face, it is imperative that we 

do that. 

Jeff Zients just had to leave, but one of the things that he and 

I discussed when he was going through the confirmation process a 

month or two ago was the need for us to collaborate, not just within the Federal Government, not just within OMB and with other 

Federal agencies—that is important—but also with GAO and, as 

you suggest, also, I think, with the IGs and certainly with this 

Committee and our sister committees in the House and in the Senate who really focus on trying to spend taxpayers’ money cost effectively. 

I very much appreciate the enthusiasm that you bring to this job. 

I also appreciate the experience you bring to this job. Occasionally, 

we have folks nominated by any administration, by any President, 

who may be very bright people; they may ultimately turn out to do 

a good job in the position for which they are nominated. But they 

have to go through a period of training and get their sea legs before 

they can actually make much of a contribution. I think we are fortunate with you in that given your experience, enthusiasm, and intellect, we will get great results in a hurry. In fact, we already are 

getting those results. 

Again, we thank you for what you have done today in serving 

this country. We thank you for your willingness to continue that 

service in a new, expanded way. We look forward to working with 

you, and again, it was a real pleasure meeting your parents, your 

big brother, your wife and children, and a number of your colleagues. 

I just want to say, as a father of two children of my own, I remember when our boys were the age of Sean and Molly, and I 

think they were pretty well-behaved kids, but your children win 

the prize today. They have just been extraordinary and should 

make you and Beth, I think, very proud. 

With that having been said, the hearing record will be open until 

12 noon tomorrow for the submission of additional questions, and 

the hearing is now adjourned. Thank you. 

[Whereupon, at 11:06 a.m., the Committee was adjourned.] 


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ph44585 on D330-44585-7600 with DISTILLER53838.033
52 


ph44585 on D330-44585-7600 with DISTILLER53838.034
53 


ph44585 on D330-44585-7600 with DISTILLER53838.035
54 


ph44585 on D330-44585-7600 with DISTILLER53838.036
55 


ph44585 on D330-44585-7600 with DISTILLER53838.037
56 


ph44585 on D330-44585-7600 with DISTILLER53838.038
57 


ph44585 on D330-44585-7600 with DISTILLER53838.039
58 


ph44585 on D330-44585-7600 with DISTILLER53838.040
59 


ph44585 on D330-44585-7600 with DISTILLER53838.041
60 


ph44585 on D330-44585-7600 with DISTILLER53838.042
61 


ph44585 on D330-44585-7600 with DISTILLER53838.043
62 


ph44585 on D330-44585-7600 with DISTILLER53838.044
63 


ph44585 on D330-44585-7600 with DISTILLER53838.045
64 


ph44585 on D330-44585-7600 with DISTILLER53838.046
65 


ph44585 on D330-44585-7600 with DISTILLER53838.047
66 


ph44585 on D330-44585-7600 with DISTILLER53838.048
67 


ph44585 on D330-44585-7600 with DISTILLER53838.049
68 


ph44585 on D330-44585-7600 with DISTILLER53838.050
69 


ph44585 on D330-44585-7600 with DISTILLER53838.051
70 


ph44585 on D330-44585-7600 with DISTILLER53838.052
71 


ph44585 on D330-44585-7600 with DISTILLER53838.053
72 


ph44585 on D330-44585-7600 with DISTILLER53838.054
73 

Æ 


ph44585 on D330-44585-7600 with DISTILLER53838.055