?

Department of Health and Human Servces


OFFICE OF


INSPECTOR GENERAL


MEDICAL MAPRACTCE INSURACE
 AN TH


COMMUN HEALTH CENTRS


A MAAGEMNT ADVISORY REPORT 

" 5.RVr('t


Richard P. Kusserow 

INSPECTOR GENERAL 

-l1f"-JIa 

NOVEMBER 1991 
OFFCE OF INSPECfOR GENRA


The mission of the Offce of Inspector General (OIG), as mandated by Public Law 95-452, as 

amended. is to protect the integrity of the Department of Health and Human Servces' (HHS) programs as well as the health and welfare of beneficiaries served by those programs. This 

statutory mission is carried out through a nationwide network of audits, investigations. and 

inspections conducted by three OIG operating components: the Offce of Audit Servces. the 

Office of Investigations, and the Offce of Evaluation and Inspections. The OIG also informs 

the Secretary of HHS of program. and management problems. and recommends courses to 

correct them. 

OFFCE OF AUDIT SERVICE 

The OIG's Offce of Audit Servces (OAS) provides all auditing servces for HHS, either by conducting audits with its own audit resources or by overseeing audit work done by others. 

Audits examine the performance of HHS programs and/or its grantees and contractors in 

carryng out their respective responsibilities and are intended to provide independent 

assessments of HHS programs and operations in order to reduce waste, abuse. and 

mismanagement and to promote economy and efficiency throughout the Department. 

OFFICE OF INTIGATIONS 

The OIG's Offce of Investigations (01) conducts criminal, civil, and administrative 

investigations of allegations of wrongdoing in HHS programs or to HHS beneficiaries and of 

unjust enrichment by providers. The investigative efforts of 01 lead to criminal convictions 

administrative sanctions, or civil money penalties. The 01 also oversees State Medicaid fraud 

control units which investigate and prosecute fraud and patient abuse in the Medicaid program. 

OFFICE OF EVALUATION AN INSPECIONS 

The OIG's Office of Evaluation and Inspections (OEI) conducts short-term management and 

program evaluations (called inspections) that focus on issues of concern to the Department. 

the Congress, and the public. The findings and recommendations contained in these inspection 

reports generate rapid, accurate, and up-to-date information on the efficiem.:y. vulnerability. and effectiveness of departmental programs. 

This report was prepared in the Boston Regional Offce under the direction of Regional Inspector General Mark R. Yessian, Ph. D.. and Deputy Regional Inspector General \-fartha 

K vaal. Project staff included:


Region I IIcadquarters 

Dana L. \'iller. Projecl Leader \'faruta Zitans 

Timothy J. Corbett 
,, 

Department of Health and Human Servces


OFFICE OF


INSPECTOR GENERAL


MEDICAL MAPRACTCE INSURACE
 AN TH


COMMUNITY HEALTH CENTERS


A MAAGEMENT ADVISORY REPORT 

5HV/("ts 

Richard P. Kusserow 

INSPECfOR GENERAL 

.I.-llfi--J1Q OEI01-91-01550 
INTRODUCTION


PUROSE 

The purpose of this report is to summarize current concerns. and available information 

regarding the costs of medical malpractice insurance at federally funded community and 

migrant health centers. 

BACKGROUN 

This report was prepared in response to a request from Kevin E. Moley, Assistant 

Secretary for Management and Budget, for information on medical malpractice insurance 

costs at community and migrant health centers. 

Five hundred and fifty community and migrant health center grantees receive funding 

through Sections 329 and 330 of the Public Health Servce Act. These centers provide 

primary health servces in medically underserved areas throughout the' country. 

Until the early 1980' federally employed National Health Servce Corps (NHSC) 

members comprised a significant portion of the centers' medical staffs. As Federal 

employees, members were covered for liability under the Federal Tort Claims Act. 

Budget cuts and policy changes in the NHSC over the past decade have increased centers 

malpractice insurance expenses in two ways. First, the number of corps providers 

available for service has been cut considerably. Consequently, centers have been forced 

to hire an increasing percentage of non-corps providers. Second, the Public Health


Servce has required that the majority of remaining corps members be employed directly 

by centers, rather than by the Federal government. As a result, the cost of medical 

malpractice insurance--for both directly hired corps members and the increased number 

of non-corps providers--has been shifted to the centers. 

At the same time, medical malpractice insurance costs nationwide have risen substantially. 

Premiums for obstetricians, for example, rose by as much as 300 percent between 1982 

and 1987. In FY 1989, centers spent approximately $50 milion--l0 percent of their total 

Federal grant funding, or 4.4 percent of total revenues--on malpractice insurance 

premiums? Alternative insurance approaches might reduce costs, and thereby result in 

an increase in the amount of funding available for direct services to center clients. 

METHODOLOY 

To gather information for this report, we spoke with staff at several congressional offices 

national and regional primary care associations, Federal agencies, and advocacy groups. 

We reviewed published reports and proposed legislation from these offices, and examined 

data from a recent OIG survey (see appendix A). 
FINDINGS


mE COST OF MEDICA MARAcrCE INSURACE PREMIUS LIIT 

SERVICES AT CENTRS. 

The rising cost of medical malpractice insurance--particularly for obstetrical care--has 

been identified as an increasingly serious financial burden, which limits the provision 

of servces at community and migrant health centers. 

In response to a June 1991 Office of Inspector General survey: 

56 percent of centers cited the high cost of medical malpractice insurance as a 

factor that significantly limits their abilty to provide pregnancy care; 

27 percent of centers indicated that the cost of medical malpractice insurance 

has become a more serious limitation to care since 1988; and 

9 rural centers reported that they have been forced to omit or discontinue 

obstetrical servces entirely because of problems related to malpractice 

insurance. 

Research by the Institute of Medicine supports these findings.s Centers have found 

increasingly difficult to recruit and retain staff, because the limited funds that might 

have been spent on salaries are being spent instead on insurance premiums. Centers 

that contract with providers for care have been unable to meet the rising hourly wages 

that are necessary to support these physicians' personal malpractice insurance 

premiums. Some centers have been unable to obtain coverage at any cost. 

TO DATE, THE PUBLIC HEAm SERVICE HAS NOT ROUINELY COLLECTD 

DATA FROM CENTRS ON mE NUMBER AN DOLLA VALUE OF MEDICA MARAcrCE CLAS AGAINST THEM. 

While the Public Health Service (PHS) has required centers to report data on the 

costs of premiums as part of the annual center grant application process, it has not 

collected information on claims experience. Thus, it has not compiled comprehensive 

data on the centers' claims histories. 

Beginning in fiscal year 1992, the PHS wil require centers to report total claims paid 

in their annual applications. Only current year information will be collected. 

The PHS and the General Accounting Office (GAO) have recently begun a 

comprehensive study of the premiums and claims experience of the centers over the 

past five years. They intend to survey all centers regarding their premiums and claims 
histories. A GAO project update on this effort was published in May 1991; a final 

GAO report is expected in spring 1992. 

MOST CENTRS FOR WHICH DATA HAVE BEEN COLLCT AR PAYING 

DISPROPORTIONATELY HIGH MEDICA MARAcrCE INSURCE 

PREIUS. 

Data from those centers that have been studied indicate that successful medical 

malpractice claims against them represent roughly 10 percent of the costs of premiums 

paid. By contrast, medical malpractice claims paid on behalf of all providers 

nationally represent 56 percent of premiums paid. Exlanations for the smaller 

amount paid on behalf of center providers might include: 

a smaller average number of claims brought against center providers than 

against non-center providers; 7 and/or 

a lower average amount paid in successful claims against center providers. 

Current estimates of the number and dollar value of center claims are based, however 

on limited information. In the past five years, several studies have attempted to 

collect claims data (see appendix B). These studies are limited by small sample sizes 

low response rates, and limited focus. Their findings are outlined below. 

Seera regional priar cae asocations have conducted studies during the past 

year. Although limited in geographic scope, these provide the most recent and most 

comprehensive data currently available on centers' premiums and claims histories. All 

of these studies have demonstrated that centers have paid high premiums relative 

both the low number of claims fied against them and the small size of successful 

claims paid. 

The Northwest Regional Priar Cae ation reported in July 1991 

survey responses from 28 of the 31 community and migrant health centers in 

Alaska, Oregon, Idaho, and Washington. Between 1988 and 1990, $4 milion 

was spent on malpractice insurance premiums. Four claims had been paid in 

the total amount of $15 000, against initial claims of $55 000. Four claims were 

stil pending for $215 500. If all pending claims were ultimately paid in full 

total claims paid would represent 6 percent of annual premiums. 

The Virgia Priar Cae Asocation has reported that the 17 centers in that 

state have paid approximately $1.1 milion in professional liability premiums 

over the past 7 years. Four claims have been filed during that time, and none 

has been paid. 

The Asocation for Utah Community Heath has reported that the 
-5 . 

5 community health centers in that state have spent approximately $100 00 on 

malpractice insurance premiums in 1991. No claims have ever been paid, and 

no claims are pending.


The Rhode Island Heath Center Astion has reported that the 

4 community health centers in that state have spent $351 00 on malpractice 

premiums in 1991. In their entire history, the centers have paid less than 

$25 00 in claims. If the $25 000 had been paid in 1991, it would represent 

7 percent of annual premiums. No claims are pending. 

The Conneccut Prar Cae Astion has reported that 10 of the 

14 centers in that state responded to a recent survey. These have paid 

$590,00 in premiums in 1991. In the history of the centers, only 5 claims have 

ever been fied; only one of these was paid, in the amount of $35 00. This 

claim represents 6 percent of 1991 premiums. 

The National Asation of Community Heath Centers released two reports in the 

mid- 1980's on its members' medical malpractice premiums and claims experience. 

The data they present are both limited and dated. 

The Medical Malpractice Claims Experience of Community and Migrant Health Centers 

A Comparative Stuy, was released in 1986. This report was based on responses from 

41 percent of all centers to a survey on claims experience, and responses from 

32 percent of all centers to a survey on risk management/access to coverage. 

A total of 95 claims had been brought against 67 (26 percent) of the 

respondents during their entire operating histories. Of the resolved cases 

46 percent had been found for the plaintiff. No dollar amounts for the claims 

paid were provided. 

The study compared the rate of claims against center physicians, by specialty, to 

national averages obtained from physician organizations. The data suggested 

that claims were fied against center providers less frequently than against noncenter providers.


Risk Financing Alternatives Study, 
 prepared by Tilinghast, an independent actuarial 

consultant, was released in 1987. This report was based on survey responses from 

18 percent of all centers. 

In 1986, responding centers paid $3.5 milion in professional liability premiums; 

their paid claims amounted to $71 000 (approximately 2 percent of premiums). 

The study concluded that this ratio of claims to premiums was far lower than 

the industry average.

The Heath Resurce and Servce Administrtion (HRSA) published Claims of 

Medical Injur, Filed under the Federal Tort Claims Act against the Indian Health Service 

and the National Health Service Corps, between FY 1980 and FY 1986, in 1987. This 

study reviewed combined data on the claims against federally employed providers in 

both community health center and Indian Health Servce settings. These data were 

available because these providers were covered for malpractice liabilty under the 

Federal Tort Claims Act. This study did not examine the claims histories of nonfederally employed community health center providers. 

The report found that 374 claims had been brought against federally employed 

providers in both settings during the 7 year period. Of these, 12 percent had 

been approved and paid; 72 percent had been denied. Suits had resulted 

from 59 percent of the denied claims. Fort-one percent of the suits were 

either settled or found for the plaintiff. 

Recorded payments for claims and suits totaled $6.8 milion. The report did 

not offer any comparative or contextual background for understanding the 

significance of this sum. 

David Smith Donna Denno, and Dana Hughes of the Bureau of Heath Cae 

Deliery and Asistace; and Saa Rosnbaum of the Chdren s Defens Fund have 

produced a draft report entitled 
 Community-Based Experience with the Federal Tort 

Claims Act and Malpractice. 
 This report presents a comparative analysis of the FY 

1980-1986 data from the HRSA report on NHSC and IHS physician claims data; 1985 

data from the American Medical Association on private physician premiums and 

claims; and data from a GAO report on the costs of private sector medical 

malpractice claims closed in 1984.


The report estimates that the cost of commercial insurance for these federally 

employed providers would have been between five and ten times greater than 

was the cost incurred by covering them under the Federal Tort Claims Act. 

The Intitute of Medicie (10M) published "Obstetrical Care for Low-Income 

Women: The Effects of Medical Malpractice on Community Health Centers " as part of Medical Professional Liabilty and the Delivery of Obstetrcal Care in 1989. This 

report was based on a survey of approximately 10 percent of all centers. 

Fourteen percent of the respondents reported that claims had been filed 

against them at some point in their operating histories. No information was 

provided on either the number of claim paid or pending, or the dollar values 

of claims.


The report concluded that medical malpractice costs adversely affected centers 

provision of obstetrical services. 
These studies consistently indicate that responding centers have paid high malpractice 

premiums, that they have had few claims against them, and that the monetary values 

of these claims have been relatively small. 

The data these studies present, however, may not be representative of premiums and 

claims experiences at all centers. The insurance industry requires comprehensive 

national data as a basis for setting premiums. 

THREE ALTERNTI APPROACHES TO INSURING CENTR PROVIERS 

BEING PURUE. 

Coverage under a risk-purchase group policy 

Establishment of a risk-retention group to self-insure 

Exanded coverage under the Federal Tort Claims Act (flCA) 

COVEGE UNER A RISK-PURCHE GROUP POUCY: 

Centers would band together to obta coerage at reduce rates from 

commercial inurers.


The National Association of Community Health Centers (NACHC) established a riskpurchase group, open to all centers nationally. This group has encountered several 

difficulties: No carriers will provide obstetrical coverage, premium reductions have 

been smaller than expected, and participation has required an increase in 

administrative work for the centers. Partially as a result of these limitations, few 

centers have participated. 

The Virginia Primary Care Association also established a risk-purchase group for the 

17 centers in that state in 1984. The Virginia group reports that its insurance carrier 

granted a 10.8 percent group premium discount, which saved the participating centers 

$15 412 in 1991. 

ESTABLISHMNT OF A RISK-RENTON GROUP TO SELF-INSUR: 

Centers would self-inure by developing a capita out of which succful 

liabilty clai. agait the centers and their provders would be pad. 

Two self-insurance proposals have been introduced during the 101st Congress. 

One bil would establish a federally capitalized and administered risk retention group 

for the community and migrant health centers (S. 815, introduced by Senator Hank 

Brown (R-CO)). This pool would be capitalized at $80 milion through the transfer of 

funds from the centers' Federal grant appropriations. Each center s contribution to 
the capital pool would be based upon its risk exposure (including the numbers of patients served, tyes of providers, and tyes of care provided). 

The Public Health Servce would be required to review the pool at least once every 

two years. If claims payments were lower than expected, the excess funds would be 

returned to the centers as a supplement to their annual grant awards. If claims 

payments were high, and inadequate funds remained to cover potential claims 

additional sums would be transferred to the pool from the centers' grant appropriations. 

Afer five years, three independent evaluations of the fund and the centers' claims 

history would be made. If claims continued to be as low as anticipated, then the 

amount of capital in the fund would be reduced, and the excess sum would be 

returned to the centers as part of their grant appropriation. 

A second bil calls upon the centers to form an independent national risk-retention 

group to provide professional liabilty coverage (S. 489; H.R. 1004, introduced by 

Senator Orrn Hatch and Representative Nancy Johnson)P Funds would be 

appropriated to establish this risk-retention group. If independent insurance experts 

determined that the operation of the group would result in an increase in the amount 

of funds available for use by the centers, then the Department of Health and Human 

Servces would capitalize the group. 

Advocates of self insurance argue that, by holding centers responsible for their 

malpractice claims, this approach gives centers a financial incentive to maintain the 

quality of their care. Further, it is anticipated that self-insurance would result in a 

substantial cost savings to the centers.


Centers have long claimed that a self-insurance program is not feasible because they 

cannot afford to capitalize the pool, and have been prohibited from using Federal 

grant funds for capitalization purposes. 

EXPANED COVERAGE UNER TH FEDERA TORT CLS ACf: 

In ca of litigation, all medica provders offerig servces at federa fuded 

communty and migrant heath centers would be treated as Federa employees. 

They would be defended by the Deparent of Justice, and clai would be 

paid out of the U.S. Treasury. 

A bil to this effect has been introduced in the House (H.R. 2239, the Federally 

Assisted Health Clinics Legal Protection Act of 1991 , sponsored by Representative 

Ron Wyden (D-OR )). 

Supporters contend that tort reform represents a return to the original program policy, 

under which a large percentage of center providers were federally employed National 
Health Servce Corps members, and thereby covered by the Federal Tort Claims Act. 

They further argue that, if the numbers and amounts of claims are as low as 

anticipated, tort reform would create a significant cost savings, not merely a cost shift. 

Federal tort reform is the preferred option of the National Association of Community I4 and has been supported by the Children Health Centers
 s Defense Fund and the

Institute of Medicine. 

Others have described tort reform as a poor strategy for both risk management and 

quality assurance. By shifting liabilty away from the centers, the measure would 

remove the centers' economic incentive to ensure quality of care. It is also argued 

that the data presently available are inadequate to demonstrate the need fore-or 

economy of--this proposed reform in tort liabilty coverage. 

The Deparment of Justice maintains that the Federal Government cannot accept 

liabilty for the actions of individuals who are not Federal employees and therefore are 16 There are further concerns that this not subject to direct Federal supervision.


move would set a precedent whereby other Federal grant recipients might seek 

Federal coverage for their employees. 

Congressional staffers have suggested that this plan is not in the best interests of 

either community health center providers or patients. Providers would object to being 

defended by assigned Justice Department attorneys, who might lack expertise in 

malpractice issues. Community health center patients who have suffered legitimate 

injury might be intimidated by the prospect of suing the Federal Government for 

damages. 
APPENDIX A


MEODOLOY


To gather information for this report, we spoke with representatives of the following 

offces and organizations: Senator Hank Brown (R-CO); Senator Tom Harkin (D-IA); Senator Orrn Hatch (R-UT); Senator Edward Kennedy (D-MA); Representative 

Barney Frank (D-MA); Representative Nancy Johnson (R-Cf); Representative Ron 

Wyden (D-OR); Minority Counsel, House Energy and Commerce Committee; the 

General Accounting Offce; the U.S. Department of Justice; the Bureau of Health 

Care Delivery and Assistance; the National Association of Community Health Centers; 

the New England Community Health Center Association; the Northwest Regional 

Primary Care Association; the Connecticut Primary Care Association; the Rhode 

Island Primary Care Association; the Utah Primary Care Association; the Virginia 

Primary Care Association; the American Insurance Association; and the Children 

Defense Fund. We reviewed published reports and proposed legislation from these 

offices. 

We also reviewed preliminary results of a June 1991 survey of all 330-grant recipients 

that was conducted as part of the Offce of Inspector General study: "The Perinatal 

Servce Capacity of the Community Health Centers" (OEI-Ol-90-02330). We received 

an 84 percent response rate, representing centers in every HHS region, and in every

state and territory in which the Public Health Servce funds centers, with the 

exceptions of the District of Columbia and the U.S. Virgin Islands. Two OIG 

inspection reports on perinatal services at urban and rural centers are forthcoming in 

winter 1991-92. 
APPENDIX 

RERTS ON MEICAL MARACfCE PRE AN 

EXERICE AT COMM HETI 

The Medical Malpractice Claims Experience of Community and Migrant Health Centers:


A Comparative StUy


National Association of Community and Migrant Health Centers, Washington, D.


February 1986.


Claims of Medical Injury, Filed under the Federal Tort Claims Act against the Indian 

Health Service and the National Health Service Corps, between FY 1980 and FY 1986 

Health Resources and Servces Administration, Rockvlle, MD, February 1987. 

Rik Financing Alternatives StUy


National Association of Community and Migrant Health Centers, Washington, D.


June 1, 1987.


Obstetrical Care for Low-Income Women: The Effects of Medical Malpractice on 

Community Health Centers " in Medical Professional Liabilty and the Delivery of 

Obstetrcal Care 

Dana Hughes, Sara Rosenbaum, David Smith, and Cynthia Fader 

Institute of Medicine, Washington, D. , 1989. 

Report on Malpractice


Rhode Island Health Center Association, March 1989. 

Review of Legal Resolution Mechanisms for Claims against State and Local Public 

Employees


Children s Defense Fund, Washington, D. , July 1989.


Statement on Statewide Malpractice Insurance Policy 

Virginia Primary Care Association, 1991. 

Statement on Utah Community Health Center Malpractice Infonnation 

Association for Utah Community Health, 1991. 

The Malpractice Insurance Question for the Community Health Cellers of Connecticut 

Robert S. Burke, available from the Connecticut Primary Care Association, May 1991. 

Medical Malpractice: Data on Claims Needed to Evaluate Health Cellers I11UrallCe 

Alternatives (HRD-91-98) 

S. General Accounting Office, May 1991. 
Statement of Thomas Trompeter, Executive Director, Northwest Regional Prmary Care 

Association, before the House Judiciary Subcommittee on Administrative Law and 

Governmental Relations 

July 17, 1991.


Community-Based Experience with the Federal Tort Claims Act and Malpractice (Draft) 

David Smith, Donna Denno, Dana Hughes, Bureau of Health Care Delivery and 

Assistance; Sara Rosenbaum, Children s Defense Fund 
APPENDIX 

NOTE 

1. The average annual field strength of federally employed corps providers fell from 

696 in 1980 to 412 in 1986. 
 Claims of Medical Injury, Filed under the Federal Tort 

Claims Act against the Indian Health Service and the National Health Service Corps, 

between FY 1980 and FY 1986; Health Resources and Servces Administration 

(HRSA), p. 43. A small percentage of corps providers are stil employed, paid, and 

insured by the Federal government because of special circumstances. These include 

the providers' original employment status , and specific center difficulties in provider 

recruitment. 

2. National Association of Community Health Centers Mothers, Infants, and 

Community and Migrant Health Centers 1989; p. 9. 

3. General Accounting Office Medical Malpractice: Data on Claims Needed to 

Evaluate Health Centers ' Insurance Alternatives 
 (HRD-91-98), May 1991 , p. 1. 

4. Survey of Perinatal Services Office of Inspector General, June 1991. 

Significant" responses are a combination of "Moderate" and "Substantial" responses. 

Numbers indicate the percentage of responding Section 330 grantees. Ten urban and 

45 rural centers reported that they have discontinued or omitted obstetrical servces 

for other reasons. 

5. Institute of Medicine Medical Professional Liabilty and the Delivery of Obstetrical 

Care, 1989. 

6. This is the average adjusted loss ratio for all medical malpractice carriers for 1990. 

Best s Insurance Management Reports " A.M. Best Company; obtained through the 

American Insurance Association. 

7. Although insurance companies view community health center patients as medically 

high risk, these clients may in fact be less likely than private-practice patients to bring 

suit in case of injury. The 1987 HRSA report notes that "the socio-economic and 

educational levels of patients served by community health centers. . . may constitute 

barriers to awareness that the care provided or the outcome achieved does not meet 

acceptable medical standards. Reduced access to alternative sources of care may also 

mitigate against aggressive redress of injury." Moreover, strict Federal riskmanagement and community involvement requirements may promote more positive 

patient-doctor relationships. "The sense of community ownership," one study noted 

has made suits less likely" (Robert S. Burke The Malpractice Insurance Question for 

the Community Health Centers of Connecticut 1991, p. 20). 

C -
8. All 17 centers in Virginia formed a risk purchase group in 1984 to obtain insurance 

at reduced rates (see p. 7 of this report). 

9. Tilinghast recommended that the National Association of Community Health 

Centers establish an insurance risk-purchasing group, and that it evaluate the 

feasibilty of establishing an insurance risk-retention group at some future point. 

10. In the remaining 16 percent of cases, either the claim was stil pending or no 

record of the claim could be found. 

11. The authors recommended extension of coverage under the Federal Tort Claims 

Act to all center obstetrical health care providers (not only federally employed 

National Health Servce Corps members). 

12. Senator Hatch's and Senator Kennedy s offces have discussed plans for legislation 

that would build upon the current Hatch and Brown bils. 

13. Representative Nancy Johnson (R-Cf) has introduced a similar bil (H.R. 1565). 

14. Daniel Hawkins, Director of Policy Analysis, NACHC; Letter to Congressman 

Ron Wyden, April 26, 1991. 

15. Sara Rosenbaum, Director, Health Division, Children s Defense Fund; Testimony 

before the U.S. House Small Business Subcommittee on Regulation, Business 

Opportunities, and Energy, October 12, 1989. The Children s Defense Fund has 

conducted a survey of 33 State policies regarding the liabilty of State-employed 

medical providers. Thirty-one of the 33 States cover State-employed medical 

providers under their respective State tort claims acts. 

16. Stuart Gerson, Assistant Attorney General, U.S. Department of Justice, Civil 

Division, Testimony before the U.S. House Judiciary Subcommittee on Administrative 

Law and Governmental Relations, July 17, 1991. 

C - 2