United States General Accounting Office

GAO Testimony

Before the Subcommittee on Social Security, Committee

on Ways and Means, House of Representatives

For Release on Delivery

Expected at 9:00 a.m.

Thursday, April 24, 1997

SOCIAL SECURITY

DISABILITY

SSA Actions to Reduce

Backlogs and Achieve More

Consistent Decisions

Deserve High Priority

Statement of Jane L. Ross, Director

Income Security Issues

Health, Education, and Human Services Division

GAO/T-HEHS-97-118

Social Security Disability: SSA Actions to

Reduce Backlogs and Achieve More

Consistent Decisions Deserve High Priority

Mr. Chairman and Members of the Subcommittee:

Thank you for inviting me to testify on the Social Security Administration’s

(SSA) management of the Disability Insurance (DI) and Supplemental

Security Income (SSI) programs. In 1995, these programs paid benefits

approaching $60 billion a year and served nearly 7 million working-age

adults. As you are aware, SSA’s process has been overwhelmed with a large

number of appealed cases, which grew from about 225,000 in fiscal year

1986 to about 498,000 in fiscal year 1996.

Today I will discuss actions that SSA undertook, beginning in 1994, to

improve the timeliness, efficiency, and consistency of disability decisions.

Its actions resulted from a realization that the lengthy and complicated

decision-making process and the inconsistency of decisions between

adjudicative levels compromise the integrity of disability determinations.

More specifically, I will describe SSA’s actions to reduce the current

backlog of cases appealed to the agency’s administrative law judges (ALJ).

Then I will discuss how functional assessments, differences in procedures,

and quality review contribute to inconsistent results between different

decisionmakers and describe SSA’s strategy to obtain greater decisional

consistency. My testimony is based on our reports and our ongoing studies

of SSA’s disability programs being conducted for the Chairman of the

Subcommittee. (See the list of related GAO products.)

In summary, our work shows that while SSA has developed broad-based

plans to improve the management of its disability programs, many

initiatives are just beginning and their effectiveness can be assessed only

after a period of full-scale implementation. For example, in the short term,

SSA has taken action to try to deal with the backlog crisis, but it is still

about 116,000 cases over its December 1996 goal of 375,000 cases. In the

longer term, SSA needs to come to grips with the systemic factors causing

inconsistent decisions, which underlie the current high level of appealed

cases and, in turn, the backlog crisis. For example, we found that

differences in assessments of functional capacity, different procedures,

and weaknesses in quality reviews contribute to inconsistent decisions.

Although SSA is on the verge of implementing initiatives to deal with these

factors, we are concerned that other congressionally mandated workload

pressures, such as significantly increasing the number of continuing

disability reviews and readjudicating childhood cases, could jeopardize the

agency’s ability to move ahead with its initiatives to reduce inconsistent

decisions.

Page 1 GAO/T-HEHS-97-118
Social Security Disability: SSA Actions to

Reduce Backlogs and Achieve More

Consistent Decisions Deserve High Priority

Background SSA’s disability programs provide cash benefits to people with long-term

disabilities. The DI program provides monthly cash benefits and Medicare

eligibility to severely disabled workers; SSI is an income assistance

program for blind and disabled people. The law defines disability for both

programs as the inability to engage in substantial gainful activity because

of a severe physical or mental impairment that is expected to last at least 1

year or result in death.

Both DI and SSI are administered by SSA and state disability determination

services (DDS). SSA field offices determine whether applicants meet the

nonmedical criteria for eligibility and at the DDSs, a disability examiner and

a medical consultant (physician or psychologist) make the initial

determination of whether the applicant meets the definition of disability.

Denied claimants may ask the DDS to reconsider its finding and, if denied

again, may appeal to an ALJ within SSA’s Office of Hearings and Appeals

(OHA). The ALJ usually conducts a hearing at which applicants and medical

or vocational experts may testify and submit new evidence. Applicants

whose appeals are denied may request review by SSA’s Appeals Council

and may further appeal the Council’s decision in federal court.

Between fiscal years 1986 and 1996, the increasing number of appealed

cases has caused workload pressures and processing delays. During that

time, appealed cases increased more than 120 percent. In the last 3 years

alone, average processing time for appealed cases rose from 305 days in

fiscal year 1994 to 378 days in fiscal year 1996 and remained essentially the

same for the first quarter of fiscal year 1997. In addition, “aged” cases

(those taking 270 days or more for a decision) increased from 32 percent

to almost 43 percent of the backlog.1

In addition to the backlog, high ALJ allowances (in effect, “reversals” of DDS

decisions to deny benefits2) have been a subject of concern for many

years. Although the current ALJ allowance rate has dropped from

75 percent in fiscal year 1994, ALJs still allow about two-thirds of all

disability claims they decide. Because chances for award at the appeals

level are so favorable, there is an incentive for claimants to appeal. For

several years, about three-quarters of all claimants denied at the DDS

reconsideration level have appealed their claims to the ALJ level.3

1

Processing time represents total OHA workloads, which include appealed Medicare cases.

2

ALJ decisions are said to be de novo, or “afresh.”

3

About one-third of claimants denied at the initial DDS-level appeal, while the rest abandon their cases.

Page 2 GAO/T-HEHS-97-118
Social Security Disability: SSA Actions to

Reduce Backlogs and Achieve More

Consistent Decisions Deserve High Priority

In 1994, SSA adopted a long-term plan to redesign the disability

decision-making process to improve its efficiency and timeliness. As a key

part of this plan, SSA developed initiatives to achieve similar decisions on

similar cases regardless of whether the decisions are made at the DDS or

the ALJ level. In July 1996, several of these initiatives, called “process

unification,” were approved for implementation by SSA’s Commissioner.

SSA expects that process unification will result in correct decisions being

made at the earliest point possible, substantially reducing the proportion

of appealed cases and ALJ allowance rates as well.

Because SSA expects that implementation of its redesigned disability

decision-making process will not be completed until after the year 2000,

SSA developed a Short Term Disability Project Plan (STDP) to reduce the

existing backlog by introducing new procedures and reallocating staff.

STDP is designed to expedite processing of claims in a way that will support

redesign and achieve some near-term results in reducing the backlog. SSA

expects that STDP’s major effect will come primarily from two

initiatives—regional screening unit and prehearing conferencing activities.

In the screening units, DDS staff and OHA attorneys work together to

identify claims that could be allowed earlier in the appeals process.

Prehearing conferencing shortens processing time for appealed cases by

assigning OHA attorneys to perform limited case development and review

cases to identify those that could potentially be allowed without a formal

hearing. The plan called for reducing the backlog to 375,000 appealed

cases by December 31, 1996.

Despite SSA’s Efforts,

SSA Still Faces a High

Backlog

Despite SSA attempts to reduce the backlog through its STDP initiatives, the

agency did not reach its goal of reducing this backlog to 375,000 by

December 1996.4 SSA attributes its difficulties in meeting its backlog target

to start-up delays, overly optimistic projections of the number of appealed

cases that would be processed, and an unexpected increase in the number

of appealed cases. The actual backlog in December was about 486,000

cases and has risen in the last few months to 491,000 cases, still about

116,000 over the goal. Although SSA did not reach its backlog goal, about

98,000 more cases may have been added to the backlog if STDP steps had

not been undertaken. The contribution made by STDP underscores the need

for SSA to continue its short-term effort while moving ahead to address the

disability determination process in a more fundamental way in the long

term.

4

SSA’s goal included Medicare claims, which ALJs also decide. However, the STDP initiatives focused

only on disability claims, which represented about 94 percent of the backlog in fiscal year 1996.

Page 3 GAO/T-HEHS-97-118
Social Security Disability: SSA Actions to

Reduce Backlogs and Achieve More

Consistent Decisions Deserve High Priority

Decision-Making

Process Yields High

Degree of

Inconsistency

Between DDSs and

ALJs

In addition to the backlog problem, SSA’s decision-making process has

produced a high degree of inconsistency between DDS and ALJ awards, as

shown in table 1. Although award rates representing DDS decision-making

vary by impairment, ALJ award rates are high regardless of the type of

impairment. For example, sample data showed that DDS award rates

ranged from 11 percent for back impairments to 54 percent for mental

retardation. In contrast, ALJ award rates averaged 77 percent for all

impairment types with only a smaller amount of variation among

impairment types.

Table 1: Award Rates at DDS and ALJ

Levels by Impairment Type DDS award rates

(percent)

ALJ award rates

(percent)

Physical 29 74

Musculoskeletal 16 75

Back cases 11 75

Other musculoskeletal 23 76

Other physical 36 74

Mental 42 87

Illness 39 87

Retardation 54 84

All impairments 30 77

Note: ALJ data are from an ongoing SSA study. Data include ALJ cases decided from September

1, 1992, through April 30, 1995. Study samples excluded certain types of cases, such as

children’s cases. DDS data for the same period and types of cases were obtained from SSA’s

administrative database.

Disability Determinations

Require Complex

Judgment

SSA’s process requires adjudicators to use a five-step sequential evaluation

process in making their disability decisions (see table 2). Although this

process provides a standard approach to decision-making, determining

disability often requires that a number of complex judgments be made by

adjudicators at both the DDS and ALJ levels.

Page 4 GAO/T-HEHS-97-118
Social Security Disability: SSA Actions to

Reduce Backlogs and Achieve More

Consistent Decisions Deserve High Priority

Table 2: Five-Step Sequential

Evaluation Process for Determining

Disability

Action or decision taken if answer to

question is:

Step

Questions asked in the sequential

process Yes No

1 Is the claimant engaging in

substantial gainful activity?

Stop—claimant is

not disabled

Go to step 2

2 Does the claimant have an

impairment that has more than a

minimal effect on the claimant’s

ability to perform basic work tasks

and is expected to last at least 12

months?

Go to step 3 Stop—claimant is

not disabled

3 Do the medical facts alone show that

the claimant’s impairment meets or

equals the medical criteria for an

impairment in SSA’s Listing of

Impairments?

Stop—claimant is

disabled

Go to step 4

4 Comparing the claimant’s residual

functional capacity with the physical

and mental demands of the

claimant’s past work, can the

claimant perform his or her past

work?

Stop—claimant is

not disabled

Go to step 5

5 Based on the claimant’s residual

functional capacity and any

limitations that may be imposed by

the claimant’s age, education, and

skill level, can the claimant do work

other than his or her past work?

Claimant is not

disabled

Claimant is

disabled

As the application proceeds through the five-step process, claimants may

be denied benefits at any step, ending the process. Steps 1 and 2 ask

questions about the claimant’s work activity and the severity of the

claimant’s impairment. If the reported impairment is judged to be severe,

adjudicators move to step 3. At this step, they compare the claimant’s

condition with a listing of medical impairments developed by SSA.

Claimants whose conditions meet or are medically equivalent to the

listings are presumed by SSA to be unable to work and are awarded

benefits. Claimants whose conditions do not meet or equal the listings are

then assessed at steps 4 and 5, where decisions must be made about the

claimant’s ability to perform prior work and any other work that exists in

the national economy. To do this, adjudicators assess the claimant’s

capacity to function in the workplace.

DDS and ALJ adjudicators exercise considerable judgment when making

these functional assessments. They must consider and weigh all available

Page 5 GAO/T-HEHS-97-118
Social Security Disability: SSA Actions to

Reduce Backlogs and Achieve More

Consistent Decisions Deserve High Priority

evidence, including physician opinions and reported symptoms, such as

pain. Mental impairment assessments include judgments about the

claimant’s ability to understand, remember, and respond appropriately to

supervision and normal work pressures. For physical impairments,

adjudicators judge the claimant’s ability to walk, sit, stand, and lift. To

facilitate this, SSA has defined five levels of physical exertion ranging from

very heavy to sedentary. However, for those claimants unable to perform

even sedentary activities, adjudicators may determine that a claimant can

perform “less than a full range of sedentary” activities, a classification that

often results in a benefit award.

DDSs and ALJs Differ

Primarily Over

Claimants’ Functional

Abilities

Our analysis found that differing functional assessments by DDSs and ALJs

are the primary reason for most ALJ awards. Since most DDS decisions use

all five steps of the sequential evaluation process before denying a claim,

almost all DDS denial decisions appealed to ALJs included such a functional

assessment. On appeal, the ALJ also follows the same sequential evaluation

process as the DDS and also assesses the claimant’s functional abilities in

most awards they make.

Data from SSA’s ongoing ALJ study indicate that ALJs are much more likely

than DDSs to find that claimants have severe limitations in functioning in

the workplace (see table 3).

Table 3: DDS and ALJ Differences in

Functional Assessment Classifications

for Physical Impairment Awards

Percentage of awards

Level of physical exertion determined by

functional assessment

Quality reviewers

using DDS

approach

Original awarding

ALJs

Heavy work (or no limiting effect on physical

effort) 0 0

Medium work 22 1

Light work 56 8

Sedentary work 15 25

Less than the full range of sedentary work 6 66

Note: Data are for ALJ awards made from September 1992 through April 1995.

Most notably, in the view of the awarding ALJs, 66 percent of the cases

merited a functional capacity assessment of “less than the full range of

sedentary” work—a classification that is likely to lead to an award. In

Page 6 GAO/T-HEHS-97-118
Social Security Disability: SSA Actions to

Reduce Backlogs and Achieve More

Consistent Decisions Deserve High Priority

contrast, reviewers using the DDS approach found that less than 6 percent

of the cases merited this classification.

Functional assessment also played a key role in a 1982 SSA study, which

controlled for differences in evidence. This study indicated that DDS and

ALJ decisionmakers reached different results even when presented with the

same evidence.5

 As part of the study, selected cases were reviewed by two

groups of reviewers—one group reviewing the cases as ALJs would and the

other reviewing the cases as DDSs would. Reviewers using the ALJ approach

concluded that 48 percent of the cases should have received awards, while

reviewers using the DDS approach concluded that only 13 percent of those

same cases should have received awards.

The use of medical expertise appears to influence the decisional

differences at the DDS and ALJ levels. At the DDS level, medical consultants

are responsible for making functional assessments. In contrast, ALJs have

the sole authority to determine functional capacity and often rely on

claimant testimony and the opinions of treating physicians. Although ALJs

may call on independent medical experts to testify, our analysis shows

that they do so in only 8 percent of the cases resulting in awards.

To help reduce inconsistency, SSA issued nine rulings on July 2, 1996,

which were written to address pain and other subjective symptoms,

treating source opinions, and assessing functional capacity.6 SSA also plans

to issue a regulation to provide additional guidance on assessing

functional capacity at both the DDS and ALJ levels, specifically clarifying

when a “less than sedentary” classification is appropriate.7

 In addition,

based on the nine rulings, SSA completed nationwide process unification

training of over 15,000 adjudicators and quality reviewers between July 10,

1996, and February 26, 1997. In the training, SSA emphasized that it expects

the “less than sedentary” classification would be used rarely. In the longer

term, SSA plans to develop a simplified decision-making process, which

will expand the role of functional capacity assessments. Because

differences in functional capacity assessments are the primary reason for

inconsistent decisions, SSA should proceed cautiously with its plan to

expand the use of such assessments.

5

Implementation of Section 304 (g) of Public Law 96-265, Social Security Disability Amendments of

1980: Report to the Congress by the Secretary of Health and Human Services, SSA, Department of

Health and Human Services (Jan. 1982). This report is commonly known as the “Bellmon Report.”

6

Federal Register, 61 F.R. 34466-34492 (July 2, 1996).

7

SSA told us that the notice of proposed rulemaking on the “less than sedentary” regulations is ready

for release but did not provide the date when it would be issued.

Page 7 GAO/T-HEHS-97-118
Social Security Disability: SSA Actions to

Reduce Backlogs and Achieve More

Consistent Decisions Deserve High Priority

Procedures Limit Use

of DDS Decisions as a

Foundation for ALJ

Decisions

Procedures at the DDS and ALJ levels limit the usefulness of the DDS

decision as a foundation for the ALJ decision. Often, ALJs are unable to rely

on DDS decisions because they lack supporting evidence and explanations

of the reasons for denial, laying a weak foundation for the ALJ decision if

the case is appealed. Moreover, although SSA requires ALJs to consider the

DDS medical consultant’s assessment of functional capacity, procedures at

the DDS level do not ensure that such assessments are clearly explained. In

a 1994 study, SSA found that written explanations of critical issues at the

DDS level were inadequate in about half of the appealed cases that turned

on complex issues.8

 Without a clear explanation of the DDS decision, the

ALJ could neither effectively consider it nor give it much weight.

At the ALJ level, claimants are allowed to claim new impairments and

submit new or additional evidence, which also affects consistency

between the two levels. Moreover, in about 10 percent of cases appealed

to the ALJ level, claimants switch their primary impairment from a physical

claim to a mental claim. In addition, data from a 1994 SSA study show that

claimants submit additional evidence to the ALJ in about three-quarters of

the sampled cases and that additional evidence was an important factor in

27 percent of ALJ allowances.

To address the documentation issues, SSA plans to take steps to ensure

that DDS decisions are better explained and are based on a more complete

record so that they are more useful if appealed. On the basis of feedback

during the process unification training, SSA plans further instructions and

training in May 1997 for the DDSs on how and where in the case files they

should explain how they reached their decisions. SSA also plans to issue a

regulation clarifying the weight given to the DDS medical consultants’

opinions at the ALJ level.9

To deal with the potential effect of new evidence, SSA plans to return to the

DDSs about 100,000 selected cases a year for further consideration when

new evidence is introduced at the ALJ level. In cases where the DDS would

award benefits, the need for a more time-consuming and costly ALJ

decision would be avoided. SSA plans to implement this project in

May 1997. Moreover, SSA’s decision to limit such returns to about 100,000

cases may need to be reassessed in light of the potential benefits that

could accrue from this initiative.

8

Findings of the Disability Hearings Quality Review Process, Office of Program and Integrity Reviews,

SSA (Sept. 1994).

9

SSA told us that the notice of proposed rulemaking on the DDS medical consultants’ opinions is in

final clearance within SSA.

Page 8 GAO/T-HEHS-97-118
Social Security Disability: SSA Actions to

Reduce Backlogs and Achieve More

Consistent Decisions Deserve High Priority

Quality Reviews Do

Not Focus on

Inconsistency

Between DDSs and

ALJs

Although SSA has several quality review systems to examine disability

decisions, none is designed to identify and reconcile factors that

contribute to differences between DDS and ALJ decisions. For example,

although ALJs are required to consider the opinion of the DDS medical

consultant when making their own assessment of a claimant’s functional

capacity, such written DDS opinions are often lacking in the case files.

Quality reviews at the DDS level do not focus effectively on whether or how

well these opinions are explained in the record, despite the potential

importance of such medical opinion evidence at the ALJ level. Moreover,

SSA reviews too few ALJ awards to ensure that ALJs give appropriate

consideration to the medical consultants’ opinions or to identify means to

make them more useful to the ALJs. Feedback on these issues could help

improve consistency by making the DDS decision a more useful part of the

overall adjudication process.

To improve consistency, SSA is completing work on a notice of proposed

rulemaking, with a target issue date of August 1997 for a final regulation,

to establish the basis for reviewing ALJ awards, which would require ALJs to

take corrective action on remand orders from the Appeals Council before

benefits are paid. SSA has just started conducting preliminary reviews of

ALJ awards, beginning with 200 cases a month. After the regulation is

issued, they plan to increase the number of cases per month. SSA has set a

first-year target of 10,000 cases to be reviewed, but this reflects only about

3 percent of approximately 350,000 award decisions made by ALJs in 1996.

Ultimately, SSA plans to implement quality review measures to provide

consistent feedback on the application of policy. By doing this, the agency

hopes to ensure that the correct decision is made at the earliest point in

the process.

Competing Workloads

Could Jeopardize

Initiatives to Improve

Consistency of

Decisions

At the same time that SSA is trying to begin implementation of its process

unification initiatives, it faces significantly increasing workloads at all

levels of adjudication. In particular, efforts to improve decisional

consistency will compete with specific congressional mandates for time

and resources. For example, the Social Security Independence and

Program Improvements Act of 1994 and the Personal Responsibility and

Work Opportunity Reconciliation Act of 1996 require hundreds of

thousands of more continuing disability reviews (CDR) to ensure that

beneficiaries are still eligible for benefits. By law, SSA will be required to

conduct CDRs for at least 100,000 more SSI beneficiaries annually through

fiscal year 1998. Last year, the Congress increased CDR requirements for

children on SSI, requiring them at least every 3 years for children under age

Page 9 GAO/T-HEHS-97-118
Social Security Disability: SSA Actions to

Reduce Backlogs and Achieve More

Consistent Decisions Deserve High Priority

18 who are likely to improve and for all low-birthweight babies within the

first year of life. In addition, SSA is required to redetermine, using adult

criteria, the eligibility of all 18-year-olds on SSI beginning on their 18th

birthdays and to readjudicate 332,000 childhood disability cases by

August 1997. Finally, thousands of noncitizens and drug addicts and

alcoholics could appeal their benefit terminations, further increasing

workload pressures.

Concluding

Observations

Despite SSA’s Short Term Disability Project Plan, the appealed case

backlog is still high. Nevertheless, because the backlog would have been

even higher without STDP, SSA will need to continue its effort to reduce the

backlog to a manageable level until the agency, as a part of its long-term

redesign effort, institutes a permanent process to ensure timely and

expeditious disposition of appeals.

In addition, SSA is beginning to move ahead with more systemwide changes

in its redesign of the disability claims process. In particular, it is on the

verge of implementing initiatives to redesign the process, including ones

for improving decisional consistency and the timeliness of overall claims

processing. However, competing workload demands could jeopardize SSA’s

ability to make progress in reducing inconsistent decisions.

We urge the agency to follow through on its initiatives to address the

long-standing problem of decisional inconsistency with the sustained

attention required for this difficult task. To do so, SSA, in consultation with

this Subcommittee and others, will need to sort through its many priorities

and do a better job of holding itself accountable for meeting its deadlines.

Otherwise, plans and target dates will remain elusive goals and may never

yield the dual benefits of helping to restore public confidence in the

decision-making process and contributing to permanent reductions in

backlog.

Mr. Chairman, this concludes my prepared statement. At this time, I will be

happy to answer any questions you or the other Subcommittee members

may have.

Page 10 GAO/T-HEHS-97-118
Social Security Disability: SSA Actions to

Reduce Backlogs and Achieve More

Consistent Decisions Deserve High Priority

Contributors For more information on this testimony, please call Cynthia Bascetta,

Assistant Director, at (202) 512-7207. Other major contributors are William

Hutchinson, Senior Evaluator; Carol Dawn Petersen, Senior Economist;

and David Fiske, Ellen Habenicht, and Carlos Evora, Senior Evaluators.

Page 11 GAO/T-HEHS-97-118
Related GAO Products

Appealed Disability Claims: Despite SSA’s Efforts, It Will Not Reach

Backlog Reduction Goal (GAO/HEHS-97-28, Nov. 21, 1996).

Social Security Disability: Backlog Reduction Efforts Under Way;

Significant Challenges Remain (GAO/HEHS-96-87, July 11, 1996).

Social Security Disability: Management Action and Program Redesign

Needed to Address Long-Standing Problems (GAO/T-HEHS-95-233, Aug. 3,

1995).

Disability Insurance: Broader Management Focus Needed to Better

Control Caseload (GAO/T-HEHS-95-233, May 23, 1995).

Social Security: Federal Disability Programs Face Major Issues

(GAO/T-HEHS-95-97, Mar. 2, 1995).

Social Security Disability: SSA Quality Assurance Improvements Can

Produce More Accurate Payments (GAO/HEHS-94-107, June 3, 1994).

Social Security: Most of Gender Difference Explained (GAO/HEHS-94-94,

May 27, 1994).

Social Security: Disability Rolls Keep Growing, While Explanations

Remain Elusive (GAO/HEHS-94-34, Feb. 8, 1994).

Social Security: Increasing Number of Disability Claims and Deteriorating

Service (GAO/HRD-94-11, Nov. 10, 1993).

Social Security: Rising Disability Rolls Raise Questions That Must Be

Answered (GAO/T-HRD-93-15, Apr. 22, 1993).

Social Security Disability: Growing Funding and Administrative Problems

(GAO/T-HRD-92-28, Apr. 27, 1992).

Social Security: Racial Difference in Disability Decisions Warrants Further

Investigation (GAO/HRD-92-56, Apr. 21, 1992).

Social Security: Results of Required Reviews of Administrative Law Judge

Decisions (GAO/HRD-89-48BR, June 13, 1989).

(207005) Page 12 GAO/T-HEHS-97-118
Ordering Information

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

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

following address, accompanied by a check or money order

made out to the Superintendent of Documents, when

necessary. VISA and MasterCard credit cards are accepted, also.

Orders for 100 or more copies to be mailed to a single address

are discounted 25 percent.

Orders by mail:

U.S. General Accounting Office

P.O. Box 6015

Gaithersburg, MD 20884-6015

or visit:

Room 1100

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

U.S. General Accounting Office

Washington, DC

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

or by using fax number (301) 258-4066, or TDD (301) 413-0006.

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

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

list from the past 30 days, please call (202) 512-6000 using a

touchtone phone. A recorded menu will provide information on

how to obtain these lists.

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

send an e-mail message with "info" in the body to:

info@www.gao.gov

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

http://www.gao.gov

PRINTED ON RECYCLED PAPER
United States

General Accounting Office

Washington, D.C. 20548-0001

Official Business

Penalty for Private Use $300

Address Correction Requested

Bulk Rate

Postage & Fees Paid

GAO

Permit No. G100