a

GAO

United States General Accounting Office

Report to Congressional Requesters

August 2003 FOREST SERVICE 

PURCHASE CARDS

Internal Control 

Weaknesses Resulted 

in Instances of 

Improper, Wasteful, 

and Questionable 

Purchases

GAO-03-786
Internal control weaknesses in the Forest Service’s purchase card program 

leave the agency vulnerable to, and in some cases, resulted in, improper, 

wasteful, and questionable purchases. These weaknesses included 

inadequate segregation of duties over purchases, supervisory review and 

approval of purchases, monitoring activities, and control over property used 

in Forest Service activities. For example, GAO found instances where items 

highly susceptible to theft, such as all terrain vehicles, digital cameras, and 

snowmobiles, were purchased and retained by cardholders, but no records 

of the items were created in Forest Service systems. 

These weaknesses likely contributed to approximately $2.7 million in 

improper, wasteful, and questionable purchases identified in our review. 

GAO identified purchases that totaled over $1.6 million that were improper 

because they violated law, regulation, or agency policy. These included 

purchases that had been split into two or more segments to avoid the 

cardholder’s single purchase limit, purchases that had been paid for twice, 

purchases that exceeded single transaction limits, purchases for which 

required approvals were not obtained, purchases of unauthorized items, 

transactions on accounts of former employees, and instances where 

cardholders wrote convenience checks to themselves. 

GAO also found purchases totaling $212,104 that it considered wasteful 

because they were excessive in cost relative to available alternatives or were 

for a questionable government need. Further, GAO found purchases 

totaling $869,825 that it considered to be questionable because the Forest 

Service either could not provide supporting documentation for them, or 

supporting documentation was incomplete or incorrect and GAO was unable 

to determine whether the purchases were proper. Some examples of these 

are shown in the table below. 

Examples of Wasteful and Questionable Purchases

Item descriptions Examples of vendors Amount 

Cancellation fees Doubletree Hotel, and Rain Country 

Bed & Breakfast $34,950 

Specialty costumes and a 

decorative tent 

Carol Flemming Costume Design 

Studio, and Evelyn Roth Festival 

Arts 16,050 

Awards and gifts Warner Bros., Eddie Bauer, and 

Mori Luggage and Gifts 14,134 

Casinos, party items Have Party Will Travel, 

Party Time, and Tribal Bingo 

Casino 10, 414 

DVD player for fitness room, 

TV/VCR combination in vehicles, 

and billiard table for a bunkhouse 

Ultimate Electronics, Best Buy, and 

Quality Billiards 

5,089 

Aquarium for regional office Hair of the Dog 2,929 

Source: GAO’s analysis of Forest Service purchase card transactions selected for fiscal year 2001. 

Since 1999, GAO has designated 

Forest Service’s financial 

management as a high-risk area 

because of internal control and 

accounting weaknesses that have 

been identified by the Inspector 

General and GAO. Given these 

known risks and the hundreds of 

millions of dollars in credit card 

purchases made by the agency 

each year, GAO was asked to 

review the Forest Service’s fiscal 

year 2001 purchase card 

transactions to determine whether 

(1) existing internal controls were 

designed to provide reasonable 

assurance that improper purchases 

would be prevented or detected, 

(2) purchases were made in 

accordance with established 

policies and procedures, and 

(3) purchases were made for a 

reasonable cost and reflected a 

legitimate government need. 

GAO is making a number of 

recommendations to strengthen the 

Forest Service’s internal controls 

and compliance in its purchase 

card program, decrease wasteful 

purchases, and improve 

accountability for assets. In 

responding to our draft report, the 

Forest Service did not specifically 

discuss GAO’s recommendations, 

but it outlined actions taken or 

planned to strengthen management 

of the purchase card program. 

However, the actions outlined will 

not address many of the 

weaknesses identified in the report 

that GAO’s recommendations are 

intended to address. 

www.gao.gov/cgi-bin/getrpt?GAO-03-786.

To view the full report, including the scope 

and methodology, click on the link above. 

For more information, contact Linda Calbom 

at (202) 512-9508 or calboml@gao.gov. 

Highlights of GAO-03-786, a report to the 

Honorable Charles Grassley, Chairman, 

Senate Committee on Finance, and the 

Honorable Janice Schakowsky, House of 

Representatives 

August 2003 

FOREST SERVICE PURCHASE CARDS 

Internal Control Weaknesses Resulted in 

Instances of Improper, Wasteful, and 

Questionable Purchases 
Page i GAO-03-786 Forest Service Purchase Cards

Contents

Letter 1

Results in Brief 3

Background 5

Scope and Methodology 8

Critical Internal Control Activities Were Lacking or Inadequate 12

Poor Controls over Purchasing Practices Resulted in Certain 

Wasteful and Questionable Transactions 29

Conclusions 38

Recommendations for Executive Action 38

Agency Comments and Our Evaluation 40

Appendixes

Appendix I: Comments from the Forest Service 45

GAO Comments 49

Appendix II: GAO Contacts and Staff Acknowledgments 51

GAO Contacts 51

Acknowledgments 51

Tables Table 1: Nonaccountable Items Purchased 21

Table 2: Revised USDA Purchase Card Policies 23

Table 3: Categories of Improper Purchases 25

Table 4: Purchases Determined to Be Wasteful or Questionable 30

Abbreviations

APC Agency Program Coordinator

COCO Chief of the Contracting Office

EAGLS Electronic Access Government Ledger System

FAR Federal Acquisition Regulation

GSA General Services Administration

LAPC Local Agency Program Coordinator

MCC Merchant Category Code

OPPM Office of Procurement and Property Management

PCMS Purchase Card Management System

PDA Personal Digital Assistant

USDA U.S. Department of Agriculture
Page ii GAO-03-786 Forest Service Purchase Cards

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Page 1 GAO-03-786 Forest Service Purchase Cards

United States General Accounting Office

Washington, D.C. 20548

A

August 11, 2003 Letr

The Honorable Charles Grassley

Chairman

Committee on Finance

United States Senate

The Honorable Janice Schakowsky

House of Representatives

The use of purchase cards in the federal government has dramatically 

increased in past years as agencies have sought to streamline the 

administrative procedures long associated with making small purchases. 

The benefits of using purchase cards can be lower costs and less 

paperwork for both the government and the vendor community. However, 

given the nature, scale, and increasing use of purchase cards, it is 

important for agencies to have adequate internal controls in place to help 

ensure their proper use and thus help protect the government from fraud, 

waste, and abuse.

The Forest Service has a history of financial management problems, 

including serious accounting and financial reporting weaknesses and an 

organizational structure that has hampered efforts to correct these 

weaknesses. The Department of Agriculture’s (USDA) Office of Inspector 

General (IG) and GAO have issued many reports over the last several years 

on the financial challenges facing the agency and the need to correct 

internal control weaknesses.1

 In fiscal year 2002, the Forest Service made 

significant progress toward achieving financial accountability, receiving its 

first unqualified or “clean” audit opinion on its financial statements. 

However, the Forest Service continues to face several major challenges for 

which it has corrective actions underway or planned. Since 1999, we have 

designated Forest Service’s financial management as a high-risk area on the 

basis of serious financial and accounting weaknesses that we and the IG

1

 U.S. General Accounting Office, Financial Management: Forest Service's Efforts to 

Achieve Financial Accountability, GAO/AIMD-99-68R (Washington, D.C.: Feb. 8, 1999), 

Forest Service: A Framework for Improving Accountability, GAO/RCED/AIMD-00-2

(Washington, D.C.: Oct. 13, 1999), and Financial Management: USDA Continues to Face 

Major Financial Management Challenges, GAO/T-AIMD-00-334 (Washington, D.C.: 

Sept. 27, 2000).
Page 2 GAO-03-786 Forest Service Purchase Cards

have identified.2 In August 2001, the IG issued a report3 on USDA’s 

purchase card program that identified several internal control weaknesses. 

That review examined 400 fiscal year 1999 and 2000 purchase card and 

convenience check transactions made by four of USDA’s agencies, 

including the Forest Service. Based on its review of this limited sample, the 

IG reported that purchases generally were valid and reasonable. However 

the report also noted the (1) lack of supervisory review and approval of 

cardholder transactions, (2) delays by cardholders in validating purchase 

transactions that have been paid, and (3) inadequate monitoring by agency 

management. 

Given the hundreds of millions of dollars in purchase card purchases made 

by the Forest Service each year, these known financial management 

deficiencies raise the risk that fraudulent or improper purchases could be 

made by its employees and not detected. Because of these risks, you 

requested that we review the Forest Service’s fiscal year 2001 purchase 

card and convenience check4

 transactions to determine their validity. 

In response to your request, we initiated a body of work designed to 

determine whether (1) existing internal controls at the Forest Service were 

designed to provide reasonable assurance that improper purchases would 

be prevented or detected in the normal course of business, (2) the Forest 

Service’s fiscal year 2001 purchase card transactions were made in 

accordance with established policies and procedures, and (3) purchases 

were made for a reasonable cost and reflected a legitimate government 

need. Our review focused on the $320 million of disbursements that the 

Forest Service made for purchase card transactions during fiscal year 2001, 

the most recent fiscal year for which complete data were available when 

we conducted our review. 

2

 U.S. General Accounting Office, Major Management Challenges and Program Risks: 

Department of Agriculture, GAO-03-96 (Washington, D.C.: Jan. 1, 2003).

3

 U.S. Department of Agriculture Office of Inspector General Financial and IT Operations 

Audit Report, Some Changes Would Further Enhance Purchase Card Management System 

Internal Controls, 50099-26-FM (Washington, D.C.: August 2001).

4

 Convenience checks are issued to authorized cardholders. Agency management 

determines to whom checks are issued. The checks are similar in appearance to personal 

checks and are written against the cardholder’s purchase card account. The total amount 

that may be written cannot exceed the cardholder’s single transaction limit. Convenience 

checks are used when a merchant does not accept purchase cards.
Page 3 GAO-03-786 Forest Service Purchase Cards

Results in Brief Significant internal control weaknesses in the Forest Service’s purchase 

card program leave the agency vulnerable to, and in some cases resulted in, 

improper, wasteful, and questionable purchases, some of which were 

potentially fraudulent. These weaknesses included a lack of or inadequate 

segregation of duties over purchases, supervisory review and approval of 

purchases, monitoring activities, and control over property used in Forest 

Service activities. For example, we found instances of unauthorized 

transactions by vendors and former employees that occurred because the 

Forest Service did not adequately monitor activity to ensure that disputed 

transactions were resolved or that cardholders’ accounts were closed upon 

separation. We also found instances where items that are highly 

susceptible to theft, such as digital cameras, binoculars, or camcorders, 

were purchased by cardholders, but no records of the items were created 

in the Forest Service property systems. In response to a prior IG audit 

report as well as an outside contractor study that reported some of these 

weaknesses, USDA and Forest Service management have strengthened 

purchase card policies and procedures. However, these actions have not 

fully addressed and corrected these weaknesses. These internal control 

deficiencies, combined with the inherent risk of fraud and abuse associated 

with purchase cards, created an environment in which improper or 

fraudulent purchases could occur without being detected in the normal 

course of business.

Internal control weaknesses likely contributed to approximately 

$2.7 million in improper, wasteful, and questionable purchases identified 

during our review. Improper transactions were identified using statistical 

and nonstatistical methods. Based on the results of our statistical sample, 

we estimate that purchases totaling over $1.5 million violated Forest 

Service policies or regulations. These included purchases that had been 

split into two or more segments to avoid the cardholder’s single transaction 

limit and purchases that had been paid for twice. In addition, we identified 

purchases in our nonstatistical sample totaling over $165,000 that violated 

law, regulation, or agency policy. These included purchases that exceeded 

single transaction limits, purchases for which required approvals were not 

obtained, purchases of unauthorized items, transactions charged to 

accounts of former employees, and instances where cardholders wrote 

convenience checks to themselves, which violated Forest Service policy.

We also found 135 purchase transactions totaling $212,104 that we 

considered wasteful because they were excessive in cost relative to 

available alternatives, or they were for a questionable government need. 
Page 4 GAO-03-786 Forest Service Purchase Cards

These included $16,250 for specialty costumes and a decorative tent. In 

addition, we identified 644 transactions totaling $869,825 that we 

considered to be questionable because the Forest Service either could not 

provide supporting documentation for them, or supporting documentation 

was incomplete or incorrect and we were unable to determine whether the 

purchases were proper. These included $2,929 for an aquarium for a 

regional visitor information center; $2,295 for a billiard table for a bunk 

house; $5,803 at Have Party Will Travel; and $4,100 at Party Time Inc. 

Certain of these questionable transactions were considered to be 

potentially fraudulent because they appeared to represent unauthorized 

purchases for personal use or unauthorized purchases made by persons 

using stolen cards or merchants using cardholder account numbers. In 

addition, we identified three potentially fraudulent transactions for one 

cardholder who, after an IG investigation, pleaded guilty to making over 

$31,000 in fraudulent charges over a 2-year period.

While the approximately $2.7 million of improper, wasteful, and 

questionable purchase card and convenience check purchases we 

identified is relatively small compared to the over $320 million in total 

Forest Service purchase card and convenience check activity in fiscal year 

2001, it demonstrates vulnerabilities from weak controls that could be 

exploited to a greater extent. In addition, because we tested only a small 

portion of the transactions we identified that appeared to have a higher risk 

of fraud, waste, or abuse, there may be other improper, wasteful, and 

questionable purchases in the remaining untested transactions.

Without significant improvements in its internal controls, the Forest 

Service’s ability to detect and prevent improper or fraudulent purchase 

card use or to safeguard vulnerable assets will continue to be hampered. 

We make recommendations in this report to address the internal control, 

compliance, and property accountability issues we identified.

In commenting on a draft of this report, the Forest Service did not 

specifically address our recommendations. Rather, the response outlined 

actions taken or planned since June 2001 to strengthen the overall 

management of the purchase card program, which the Forest Service 

described as having been taken, notwithstanding our report. We 

acknowledged many of these actual and planned actions in our report. 

While we believe that these actions, if fully implemented, will help to 

address the vulnerabilities that we and the IG identified, many weaknesses 

still remain that continue to expose the Forest Service to improper, 
Page 5 GAO-03-786 Forest Service Purchase Cards

wasteful, and fraudulent purchase card activity. We address these 

remaining weaknesses in our recommendations.

Background The General Services Administration (GSA) administers the federal 

government’s contracts in support of agencies’ purchase card programs. 

GSA contracts with commercial banks to issue purchase cards to federal 

employees to make official government purchases. The Bank of America 

issues purchase cards to USDA agencies, including the Forest Service.5

 

The purchase card, unless otherwise directed by regulation, is intended to 

be the primary purchasing method for purchases from vendors that accept 

purchase cards for payment. This payment method is intended to 

streamline procurement and payment procedures by reducing the number 

of procurement requests, purchase orders, and vendor payments issued. 

USDA’s purchase card program, including the Forest Service, also includes 

the use of convenience checks to pay vendors that do not accept purchase 

cards as payment. In fiscal year 2001, the Forest Service used purchase 

cards and convenience checks to make 1.1 million purchases totaling 

$320 million. 

The USDA procurement process is subject to the Federal Acquisition 

Regulation (FAR), the primary set of regulations governing acquisition of 

supplies and services by federal executive agencies with appropriated 

funds. The FAR also incorporates U. S. Department of Treasury’s Treasury 

Financial Manual (TFM) requirements6

 for the governmentwide purchase 

card program. To implement and supplement these regulations, USDA 

issues the Agriculture Acquisition Regulations (AGAR), which prescribe 

USDA procurement policies and procedures. 

5

 The government also uses commercial purchase cards for government-related travel 

expenditures (travel cards) and for expenditures related to the maintenance and operation 

of government-owned vehicles (fleet cards). 

6

 Agencies using the governmentwide commercial purchase card must establish procedures 

for use and control of the card that comply with TFM Chapter 4-4500 and that are consistent 

with the terms and conditions of the GSA Federal Supply Service Contract Guide for 

Governmentwide Commercial Purchase Card Service. 48 C.F.R. Sec. 13.301 (2002).
Page 6 GAO-03-786 Forest Service Purchase Cards

To implement and supplement the AGAR, the Forest Service issues 

directives,7

 which contain Forest Service procurement policies and 

procedures. The Forest Service Handbook, FSH 6309.32 Part 4G13 

Simplified Acquisition Procedures, provides specific guidance on 

procurement for the Forest Service, including the use of the government 

purchase card. The handbook contains policies and procedures that define 

the responsibilities of regional and local program coordinators for 

managing the purchase card program, including establishing cardholder 

data in the Purchase Card Management System (PCMS) and monitoring 

activities for the purchase card program. 

GSA and Bank of America also provide purchase card guidance, and GSA 

provides training to cardholders and program coordinators. For example, 

GSA’s Blueprint for Success: Purchase Card Oversight was prepared by a 

working group of agency program coordinators (APC) and provides 

general program guidance to APCs in performing their responsibilities. 

Beginning in fiscal year 2003, GSA made available to APCs a Web-based online training course covering such topics as APC responsibilities, reporting 

tools, and preventive measures to use in monitoring the purchase card 

program.

According to USDA policy, APCs and local area program coordinators 

(LAPC) are appointed by the head of the agency contracting office. APCs 

are primarily responsible for managing the purchase card program in their 

agency. In addition, they establish agency-unique purchase card policies 

and procedures, provide training and guidance to LAPCs, and conduct 

agencywide oversight of the purchase card program. LAPCs are 

responsible for the day-to-day operations of the purchase card program 

within their respective location. In addition, LAPCs are responsible for 

updating cardholder information in PCMS; providing training to 

cardholders; and monitoring purchases and reporting fraud, waste, and 

abuse in accordance with agency procedures. Currently, there are 137 

Forest Service LAPCs.

In the Forest Service, cardholders are responsible for understanding and 

complying with purchasing policies and procedures; maintaining records 

7

 Forest Service Manuals (FSM) contain legal authorities, objectives, policies, 

responsibilities, instructions, and guidance needed on a continuing basis by Forest Service 

line officers and primary staff. Forest Service Handbooks (FSH) are the principal source of 

specialized guidance and instruction for carrying out the direction issued in the FSMs.
Page 7 GAO-03-786 Forest Service Purchase Cards

and receipts of all purchases; validating their purchases against PCMS 

online data; disputing unauthorized charges, and obtaining all necessary 

prepurchase approvals for certain items, such as information technology 

(IT) costing $1,000 or more and other purchases costing $2,501 or more. 

For all other purchases costing $2,500 or less, the Forest Service 

cardholder is not required to obtain pre- or post-approval. During fiscal 

year 2001, approximately 14,000 of the approximately 30,000 employees, or 

over one-third of the Forest Service workforce, had purchase cards and 

most of them had a single purchase limit ranging from $2,500 to $25,000. 

The single transaction limit applies to both the purchase card and 

convenience checks issued to the cardholder.

In 1995, the Forest Service’s use of the purchase card was limited to 

procurement personnel. However, with implementation of the President’s 

National Performance Review recommendations, the Forest Service 

reduced its procurement staff by 27 percent by 1998. At the same time, 

USDA put together a task force to look at the procurement process and 

make recommendations to improve it. The task force recommended 

increasing the use of purchase cards within USDA, including the Forest 

Service, to streamline the procurement process. USDA rapidly expanded 

purchase card use, authorizing operations personnel as well as 

procurement personnel to use them.

USDA’s Office of Procurement and Property Management (OPPM) and the 

National Finance Center (NFC) developed PCMS in 1995 to reduce 

administrative costs and to allow agencies faster procurement of goods and 

services. The system allowed USDA, including the Forest Service, to track, 

reconcile, and monitor purchases made using the USDA purchase cards 

and convenience checks. PCMS is used by program coordinators to 

establish and manage cardholder accounts and by cardholders to reconcile 

and dispute their transactions from their desktop computers.

In 1998, USDA switched card issuers and issued a task order under the GSA 

contract to Bank of America. The Bank of America purchase card system, 

developed under the GSA contract and called the Electronic Access 

Government Ledger System (EAGLS), includes various tools available to 

manage purchase card transactions. EAGLS is able to generate account 

activity reports, which identify trends such as purchases from merchants 

that would not be expected to be traditional suppliers or unusually high 

spending patterns; dispute reports, which identify cardholders with 

excessive disputes that may indicate cardholder misuse or fraudulent 

activity; and various other exception reports. Bank of America 
Page 8 GAO-03-786 Forest Service Purchase Cards

recommended that USDA also use EAGLS to manage its purchase card 

program. However, as PCMS was developed by USDA prior to its 

changeover to Bank of America, USDA officials chose to continue using 

PCMS because they believed that it offered functionality similar to EAGLS. 

Bank of America processes purchase card transaction data received from 

vendors using EAGLS, which records the data, then sends it electronically 

to NFC. NFC uploads the data into PCMS and processes payments. 

In August 2001, the IG issued a report on its review of PCMS, which 

identified several internal control weaknesses. The report noted the 

(1) lack of supervisory review and approval of cardholder transactions, 

(2) untimely validation of purchases against PCMS data, and (3) inadequate 

monitoring by agency management. In addition, a private firm was 

contracted to perform an Independent Verification and Validation8

 (IV&V) 

assessment of PCMS, an assessment which also reported weaknesses in 

accounting process controls and internal controls over purchase card 

transactions. Both the IG and contractor reports noted that cardholders 

were authorized to buy a majority of items they wanted at any time. The IG 

made several recommendations, which included

• instituting a requirement that supervisors periodically review and 

approve their subordinates’ purchase card transactions to confirm they 

are appropriate, for official purposes, and validated against PCMS data 

in a timely manner; 

• developing and implementing appropriate internal control procedures 

over the custody, control, accountability, and issuance operations for 

convenience checks to ensure they are not misused; and

• instructing USDA agencies to review their controls for ensuring they 

always properly record property purchases valued at $5,000 or more 

(called accountable purchases) in the Office of the Chief Financial 

Officer (OCFO)/NFC Property Management Information System.

Scope and 

Methodology

To obtain an understanding of the Forest Service’s purchase card and 

convenience check policies and procedures, and the related internal 

controls, we

8

 Independent Verification and Validation (IV&V) of the Purchase Card Management System 

(PCMS), Assessment Final Report: “Future Directions for PCMS,” October 2001.
Page 9 GAO-03-786 Forest Service Purchase Cards

• reviewed USDA and Forest Service procurement policy, USDA PCMS 

guidance, Forest Service regional purchase card program policy, U.S. 

Department of the Treasury purchase card program policy, and previous 

GAO reports, as well as reports issued by USDA’s IG and an independent 

contractor; and

• observed and documented purchase card procedures and conducted 

telephone interviews with USDA and Forest Service management and 

staff to identify key purchase card, convenience check, and accountable 

property policies, procedures, and initiatives. 

Because of known weaknesses in the design of internal controls at the 

Forest Service, we did not perform detailed tests to assess the 

effectiveness of these controls. However, we reviewed the internal control 

findings reported by the IG and the contractor in reports issued on the 

purchase card program and PCMS. In addition, we assessed the adequacy 

of the internal controls as designed, using our Standards for Internal 

Control in the Federal Government,9

 Internal Control Management and 

Evaluation Tool,10 Guide for Evaluating and Testing Controls Over 

Sensitive Payments,11 and Executive Guide: Strategies to Manage 

Improper Payments.12

To determine whether the Forest Service’s fiscal year 2001 purchase card 

transactions were made in accordance with established policies and 

procedures, were reasonable, and reflected a legitimate government need, 

we selected transactions using three different methods. For each method 

of selection, we provided the Forest Service with the transactions selected 

and obtained and reviewed related supporting documentation. The three 

methods are as follows: 

9

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

Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: November 2000).

10 U.S. General Accounting Office, Internal Control Management and Evaluation Tool, 

GAO-01-1008G (Washington, D.C.: August 2001).

11 U.S. General Accounting Office, Guide for Evaluating and Testing Controls Over 

Sensitive Payments, GAO/AFMD-8.1.2 (Washington, D.C.: May 1993).

12 U.S. General Accounting Office, Executive Guide: Strategies to Manage Improper 

Payments, GAO-02-69G (Washington, D.C.: October 2001).
Page 10 GAO-03-786 Forest Service Purchase Cards

• Data mining.

13 We performed data mining on Bank of America’s 

database of the Forest Service’s fiscal year 2001 purchase card and 

convenience check transactions for indicators of potential 

noncompliance with established policies and procedures. Specifically, 

we looked for transactions that exceeded cardholder or convenience 

check spending limits, split purchases or duplicate transactions, 

cardholders with multiple cards, transactions on purchase card 

accounts after the separation dates of the employees, and cardholders 

who wrote convenience checks to themselves or for cash. Except for 

potential split and duplicate transactions, we forwarded all selected 

transactions to the Forest Service APC to request supporting 

documentation from cardholders, which we used to assess whether in 

fact these were violations of policy. For split and duplicate transactions, 

we selected a statistical sample of transactions as discussed below.

• Statistical sampling. To test for split transactions, we first performed 

data mining to identify possible split transactions from the population of 

purchase card transactions paid from October 1, 2000, through 

September 30, 2001. We then selected a stratified14 random (statistical) 

sample of 213 of 1,854 potential split transactions totaling $3.5 million. 

Similarly, to test for duplicate transactions, we first performed data 

mining to identify possible duplicate transactions from the population of 

purchase card transactions paid from October 1, 2000, through 

September 30, 2001. We then selected a stratified15 random (statistical) 

sample of 230 of the 8,659 possible duplicate transactions totaling 

$1.6 million. We requested supporting documentation for these 

transactions from the APC. Actual findings from both statistical 

samples were projected separately to total fiscal year 2001 Forest 

Service purchase card and convenience check transactions.

13 Data mining applies a search process to a data set, analyzing for trends, relationships, and 

unusual associations. For instance, it can be used to efficiently query transaction data for 

characteristics that may indicate potentially improper activity.

14 We stratified each population into seven groups on the basis of the dollar value for each 

transaction. Each sample element was subsequently weighted in the analysis to account 

statistically for all the members of the population, including those that were not selected.

15 See footnote 14.
Page 11 GAO-03-786 Forest Service Purchase Cards

• Nonstatistical sampling. We selected transactions nonstatistically to 

allow us to identify those that appeared to have a higher risk of fraud, 

waste, or abuse, although the results cannot be projected to the overall 

population of purchases. We identified merchant category codes 

(MCC)16 or vendor names that appeared more likely to represent 

unauthorized or personal use items. We chose a nonstatistical sample of 

high-risk transactions from the total population of transactions 

identified for each vendor or MCC selected. We then requested 

supporting documentation from the APC for over 5,000 transactions 

totaling $8.7 million that we identified as meeting the criteria mentioned 

above to test for improper purchases. In addition, we requested the 

records for more than 1,000 transactions totaling over $690,000, which 

were disputed by cardholders during fiscal year 2001. We reviewed 

these transactions to determine whether the cardholders properly 

complied with applicable purchasing policies and procedures for 

disputed transactions.

To determine if controls over purchase card and convenience check 

equipment acquisitions were adequate to properly record and safeguard 

assets, we

• reviewed policies and procedures over the management and control of 

accountable property and sensitive items; and

• tested accountable property selected in the nonstatistical sample 

discussed above to determine whether these assets had been recorded 

in the Forest Service’s property management system prior to our review.

While we identified some improper purchases, our work was not designed 

to identify all fraudulent or otherwise improper purchases made by the

Forest Service. We conducted our review from April 2002 through March 

2003 at the Forest Service Washington Office in Rosslyn, Virginia, and 

USDA headquarters in Washington, D.C., in accordance with generally 

accepted government auditing standards. We requested written comments 

on a draft of this report from the Chief of the Forest Service. Written 

comments were received from the Chief of the Forest Service and are 

reprinted in appendix I.

16 Merchant Category Codes are four digit numbers associated with every transaction that 

identify the general category of products sold by a vendor (e.g., 5941 – Sporting Goods, 5944 

– Watch, Clock, and Jewelry Stores).
Page 12 GAO-03-786 Forest Service Purchase Cards

Critical Internal 

Control Activities Were 

Lacking or Inadequate

The Forest Service’s internal controls did not provide reasonable assurance 

that improper purchase card and convenience check purchases would not 

occur or would be detected in the normal course of business. Effective 

internal controls are the first line of defense in safeguarding assets and 

preventing and detecting fraud. In addition, they help to ensure that 

actions are taken to address risks, and are an integral part of an entity’s 

accountability for stewardship of government resources. Our Standards 

for Internal Control in the Federal Government contains the specific 

internal control standards to be followed. Specifically, these standards 

require, among other things, that (1) key duties and responsibilities be 

divided or segregated among different people to reduce the risk of error or 

fraud, (2) transactions and other significant events be authorized and 

executed only by persons acting within the scope of their authority, 

(3) internal control monitoring be performed to assess the quality of 

performance over time and ensure that audit findings are promptly 

resolved, and (4) physical control must be established to secure and 

safeguard assets vulnerable to risk of loss or unauthorized use. 

The IG report, issued in August 2001, covered purchases made during fiscal 

years 1999 and 2000. The report noted several internal control weaknesses 

in USDA’s purchase card program, including that of the Forest Service. 

These included (1) lack of supervisory review of purchase card 

transactions, (2) untimely reconciliation of purchases, and (3) inadequate 

monitoring by agency management. Because the IG report addressed 

significant internal control weaknesses and made several 

recommendations to address them, we did not conduct detailed tests of 

internal controls. However, through discussions with USDA and Forest 

Service officials and our reviews of purchase card policies and procedures, 

we confirmed that the Forest Service still did not have an adequate 

supervisory review process or sufficient program monitoring activities. 

Most importantly, we determined that the Forest Service continued not to 

have adequate segregation of duties, and property susceptible to theft or 

misuse was not adequately safeguarded. Our data mining of specific 

purchase card and convenience check transactions revealed numerous 

improper and wasteful purchases that could have been prevented or 

detected if these basic internal controls were in place. Without effective 

internal controls, the Forest Service does not have reasonable assurance 

that purchases are proper or that items purchased are safeguarded against 

loss or theft. 
Page 13 GAO-03-786 Forest Service Purchase Cards

The Forest Service Did Not 

Adequately Segregate 

Purchasing Duties

Our Standards for Internal Control in the Federal Government requires 

that key duties and responsibilities, including authorizing, processing, 

recording, and reviewing transactions and handling related assets, be 

divided or segregated among different people in order to reduce the risk of 

error or fraud. Simply put, no one individual should control all the key 

aspects of a transaction or event. The processing and recording duties for 

purchase card and convenience check transactions were automated and 

not performed by the cardholder. However, under Forest Service 

regulations, the majority of purchase card transactions do not require a 

segregation of duties. Cardholders are allowed to perform the key duties of 

authorizing purchases, receiving related assets, and validating the 

purchases subsequent to payment. 

Although Forest Service guidance required that a requisition be prepared 

for all procurements as a method to determine that the requestor had the 

authority for the purchase, a procurement request was not required for 

acquisitions below $2,500 when using a purchase card or convenience 

check. In fiscal year 2001, 96 percent of purchase card transactions were 

for amounts less than $2,500. Further, as purchase card purchases usually 

involved face-to-face transactions between the cardholder and the vendor, 

the cardholder received the assets. 

Lastly, Forest Service guidance required that cardholders reconcile their 

transactions in PCMS at least once a month using the documentation 

retained from each transaction. After reconciling a transaction, 

cardholders validate the transaction by marking an “approved” cell in 

PCMS. Therefore, for the majority of Forest Service purchase card 

transactions made by individual cardholders, there is no separate 

authorization of the purchases, possession of the items, or independent 

validation of the transactions. 

In discussions with USDA OPPM management and our review of purchase 

card policies and procedures, we noted that generally, segregation of duties 

was not adequately considered in the implementation of the purchase card 

program. When USDA, including the Forest Service, adopted PCMS, the 

revised procurement process allowed a much larger population of Forest 

Service employees to authorize purchasing decisions to buy goods and 

services as well as the responsibility for validating these purchases, up to 

their single transaction limit. This new process did away with the need for 

procurement requests and approving officials for the majority of purchase 

transactions below $2,500 initiated by Forest Service employees. 
Page 14 GAO-03-786 Forest Service Purchase Cards

As noted above, Forest Service purchase card program policies and 

procedures were written to support the increased authority given 

cardholders in purchase decisions. The lack of proper segregation of 

duties increased the Forest Service’s vulnerability to theft or misuse since 

there was limited oversight or control to ensure that purchased items or 

services were for a legitimate government need and were being used for 

those purposes.

Supervisory Review and 

Approval Process Was 

Inadequate

Supervisory approval of transactions is a principal means of assuring that 

only valid transactions are initiated or entered into by persons acting 

within the scope of their authority. A supervisory review of purchase 

transactions is particularly important where there is a lack of segregation 

of duties, because a supervisor or approving official17 may be the only 

person other than the purchaser who would be in a position to identify an 

inappropriate purchase. Therefore, the supervisor or approving official’s 

review is a critical internal control for ensuring that purchases are 

appropriate and comply with agency regulations. 

The August 2001 IG report recommended that USDA institute a 

requirement that supervisors periodically review and approve their 

subordinates’ purchase card transactions to confirm they are appropriate 

and revise departmental regulations and purchase card program 

instructions accordingly. USDA did not concur with this recommendation 

because the IG audit did not find any material problems with the purchase 

card transactions that they tested. Further, in commenting on the report, 

USDA management stated that they believe the existing management 

structure is effective in ensuring that purchase card transactions are 

appropriate. 

During our review of the Forest Service purchase card program for fiscal 

year 2001, we also noted that supervisory review and approval of purchase 

card transactions was inadequate. The Forest Service did not require 

approval of purchase transactions under $2,500, except for certain IT items 

such as computer hardware, software, and cellular phones. The Forest 

Service trusts cardholders to make appropriate purchasing decisions for 

17 The U.S. Department of the Treasury’s Treasury Financial Manual defines an approving 

official as an individual who reviews cardholder statement(s), is responsible for authorizing 

cardholder purchases (for official use only), and ensures that the statement is reconciled 

and submitted to the designated billing office.
Page 15 GAO-03-786 Forest Service Purchase Cards

transactions under this amount. During fiscal year 2001, purchases less 

than $2,500 totaled $226 million and accounted for 96 percent of all 

purchase card transactions in the Forest Service. 

While Forest Service guidance requires prior approval for all purchase 

transactions exceeding $2,500 and for specific IT items, we noted that this 

requirement was not consistently followed. We identified 11 transactions 

totaling $25,452 that required prior approval, but were initiated and 

completed by cardholders without obtaining such approval. For example, 

we identified a $1,260 purchase for a printer from ComputerLand Center. 

Prior approval for the purchase was not obtained as required by Forest 

Service policy. The cardholder stated that she did not obtain the proper 

approval because she was unaware of the requirement. 

USDA issued its revised procurement regulation, Use of the Purchase Card 

and Convenience Check (DR-5013-6), in February 2003. The revised 

regulation added the cardholder supervisor to the list of responsible 

persons in the purchase card program. Supervisors are described as the 

first line of control over the purchasing activity of cardholders in their 

units. In addition, it states that supervisors will require cardholders to 

generate periodic reports of purchase card and convenience check 

transactions, and that supervisors review these reports at least quarterly, or 

more often if agency procedures require. However, OPPM officials told us 

that this new regulation does not require supervisors to review each and 

every transaction nor does it require them to review supporting 

documentation.18 Rather, these reviews are completed using data that has 

been entered into PCMS and do not require the cardholders to submit the 

original documentation for their purchases. Both USDA and Forest Service 

officials told us that supervisory review of all transactions is not practical 

because of the Forest Service’s decentralized organization. However, this 

very decentralization makes it even more imperative that a supervisor or 

other approving official validate purchases.

Without an independent validation of transactions via supervisory review 

of supporting documentation, the Forest Service is at significant risk of 

misappropriation of funds due to fraudulent or improper charges. For 

example, as mentioned earlier, cardholders are required to “reconcile” or 

validate their transactions at least once a month. During this process the 

18 Section 4500 of the U.S. Department of the Treasury’s Treasury Financial Manual (TFM) 

also requires monthly review of transactions prior to submission for payment.
Page 16 GAO-03-786 Forest Service Purchase Cards

cardholders view each individual transaction for their account in PCMS 

and agree the vendor name, the date of the transaction, and the amount of 

the transaction to the original documentation maintained by the 

cardholder. In addition, the cardholders enter the description of the items 

purchased because this information is not initially included in PCMS. 

While following up on questionable purchases that we identified, our 

investigators learned that three of these purchases, for $1,031 in jewelry 

and china from Meier & Frank, had been made by a Forest Service 

employee who had been under investigation by the IG since January 2002. 

In reviewing the IG Report on Investigation we noted that the cardholder, 

when reconciling her purchases, had entered fictitious items into the item 

description field in PCMS. For example, the purchases from Meier & Frank 

were described as nonmonetary awards and length-of-service awards. In 

addition, purchases of CD players, computers, computer games, and other 

miscellaneous items at one vendor were entered into the PCMS description 

field as cartridges, chair mats, folders, binders, paper, pencils, and other 

supplies. A comparison of the receipt to information in the PCMS database 

would have detected these purchases as potentially fraudulent.

Program Monitoring Was 

Inadequate

The Forest Service did not adequately monitor its purchase card program 

during fiscal year 2001 to ensure that Forest Service employees were 

following established policies and procedures. Program oversight through 

monitoring activities is important even when strong preventive controls are 

in place, and is especially critical in the Forest Service case where there is a 

lack of supervisory review and segregation of duties. USDA regulations19 in 

place during fiscal year 2001 required that APCs and LAPCs monitor 

purchase card transactions through PCMS’s alert subsystem,20 statistical 

sampling, and query tool software. In August 2001, the IG reported 

deficiencies in USDA’s (including Forest Service) use of oversight tools for 

monitoring purchase card usage during fiscal years 1999 and 2000. 

Specifically, the IG reported that the department had not effectively 

implemented the alert subsystem of PCMS or implemented reviews of 

statistically sampled transactions, as required by USDA regulations. 

During our review of the Forest Service program for fiscal year 2001, we 

19 USDA regulation 5013-6, Use of the Purchase Card and Convenience Check.

20 The alert system is a subsystem of PCMS that was designed to reduce fraud, waste, and 

abuse by providing user messages to local coordinators regarding questionable 

transactions.
Page 17 GAO-03-786 Forest Service Purchase Cards

noted that it was still not using these tools for monitoring transactions for 

compliance with program requirements or for improper purchases. 

In our discussions with OPPM officials in May 2002, they stated that they 

were not using the alert subsystem because it was generating too many 

alerts that did not represent true errors or abuse. They expect to correct 

the alert process by June 30, 2003, 6 months ahead of the original 

implementation date included in their corrective action plan to address the 

IG’s findings. In addition, they informed us that they had not begun 

performing reviews of statistically selected samples during fiscal year 2001 

but that they had begun performing these reviews during fiscal year 2002, 

distributing the results to the specific agencies, including the Forest 

Service, for follow-up on the identified transactions. The Forest Service 

APC confirmed that she received the transactions from OPPM and had 

distributed them to the specific field offices for investigation. 

Lack of timely and consistent monitoring activities increases the risk that 

inappropriate purchase card transactions and improper cardholder 

activities will go undetected. In addition, without adequate monitoring 

activities, systematic problems will not be identified and addressed. In our 

review of support for transactions identified using data mining techniques, 

we found that local coordinators were not always (1) canceling accounts of 

permanent and temporary employees when they left the Forest Service, 

(2) informed by cardholders that cards had been lost or stolen, or 

(3) monitoring disputed transactions to ensure they were completely 

resolved and to identify unauthorized activity. 

Canceling purchase card accounts. Purchase card accounts were not 

consistently being canceled when cards were reported as lost or stolen, or 

when a cardholder left the Forest Service. Forest Service guidance 

requires, in the case of a lost or stolen card, that the cardholder contact 

Bank of America to have a block placed on the account and a new card 

issued. The guidance also requires that cardholders, prior to leaving the 

Forest Service, surrender their cards and, if issued, unused convenience 

checks, to the LAPC who will destroy them and close the account. 

We reviewed employee separation procedures at 16 Forest Service regional 

and field offices and noted that the written procedures at 3 offices did not 

include steps to physically collect the purchase card from the employee. 

Further, Forest Service program officials told us that the personnel forms 

used in this process are out of date at one office, they differ from region to 

region, and are inconsistently filled out. 
Page 18 GAO-03-786 Forest Service Purchase Cards

In addition, we noted that purchase cards were issued to temporary 

employees hired during fire season when there is an increased need for 

manpower. According to the Forest Service APC, these cards are collected 

when the temporary employees leave the Forest Service. However, one of 

the officials we spoke with stated that the cards are not always retrieved. 

Instead the purchase limits are reduced to $1 at that time. Our internal 

control standards require that an agency must establish physical control to 

secure and safeguard assets that might be vulnerable to risk of loss or 

unauthorized use. Failure to collect purchase cards due to outdated and 

inconsistently applied policies and procedures creates a significant risk of 

unauthorized use of purchase cards. 

USDA purchase card policy states that cardholders are required to inform 

their LAPC immediately of lost or stolen purchase cards or convenience 

checks and contact the card issuer in order to have the accounts blocked. 

However, we found instances where LAPCs had not been notified that 

cards had been lost by cardholders or stolen and the cards had not been 

canceled. For example, we identified three instances where cardholders 

lost their cards but did not inform their LAPCs. Instead, in each case, the 

cardholder canceled the lost card and ordered a new card through Bank of 

America without the LAPC’s knowledge.

Monitoring disputed transactions. We found that cardholders were not 

always disputing transactions within 60 days of the transaction dates as 

required by Forest Service policy and the GSA contract, and disputes were 

not being monitored to ensure they were completely investigated and 

resolved. Forest Service policy requires that cardholders reconcile their 

purchase card transactions in PCMS every 30 days to ensure the recorded 

charges are appropriate and correct, and that they dispute21 any charges 

identified as inappropriate or erroneous. GSA’s Blueprint for Success: 

Purchase Card Oversight, states that agency officials should consistently 

monitor disputes filed by cardholders and watch for unusual trends, such 

as a high number of disputes for specific merchants. In addition, the GSA 

master contract with card issuers of government purchase cards states that 

charges disputed within 60 days of the transaction date will be investigated

21 In order to dispute an unauthorized or erroneous transaction, data are entered into the 

PCMS disputes screen by the cardholder and sent to NFC. NFC prints the screen and faxes 

it to Bank of America to be investigated and appropriate credit given. No supervisory 

review or approval is needed for a dispute to be processed.
Page 19 GAO-03-786 Forest Service Purchase Cards

by the card issuer and appropriate credits issued. After 60 days22 the 

cardholder is responsible for investigating the disputed charge. In fiscal 

year 2001, Forest Service cardholders disputed over 1,000 transactions 

totaling $690,157. Of these, we noted 62 transactions totaling over $51,000 

that had not been disputed by cardholders within 60 days of the transaction 

date. 

Forest Service regulations do not require that cardholders inform their 

LAPC of transactions to be disputed before they are submitted to Bank of 

America. As a result, LAPCs and other management officials may be 

unaware of disputed transactions that may indicate potentially fraudulent 

or improper purchase card use, and therefore are not ensuring that 

unauthorized activity is identified, compromised accounts are canceled, 

and appropriate credits are issued. We noted that 76 transactions had been 

identified by 51 cardholders as potentially fraudulent, but the transactions 

still had not been resolved (i.e., credits issued) and the accounts were still 

open as of the end of our fieldwork. For example, a cardholder disputed a 

$600 charge at Dillards department store stating that this was one of 

several charges against his account for this vendor and that none of the 

charges were legitimate. In addition, cardholders disputed a total of 22 

charges totaling $2,791 for a vendor named Productivity Plus. In all but 2 of 

these 22 transactions the cardholders state that they had attempted to 

reach the vendor but were unable to. However, there was no explanation 

given as to why the cardholder accounts had not been closed. 

The Forest Service issued revised policies and procedures for monitoring 

purchase card usage in June 2001. The revised guidance required that for 

each Forest Service region, field office, and the Washington office, the 

Chief of Contracting Office (COCO) and LAPC perform monthly, quarterly, 

and annual reviews of cardholder purchases. The guidance also gave the 

COCOs the authority to revoke cardholder purchase card and convenience 

check privileges for inappropriate use. However, the revised regulations do 

not address the need for monitoring disputed transactions to help ensure 

that the purchase cards that have been lost, stolen, or otherwise 

compromised are canceled and that disputed transactions are resolved. 

Inadequate monitoring is yet another gap in internal controls that leaves 

the Forest Service purchase card program open to waste, fraud, and abuse.

22 Per the GSA master contract for the government purchase card program.
Page 20 GAO-03-786 Forest Service Purchase Cards

Property Was Not Properly 

Tracked

Since 1999, we have designated financial management at the Forest Service 

as high risk on the basis of serious financial and accounting weaknesses. 

An area of particular concern has been the Forest Service’s internal 

controls related to property. Internal controls are essential to safeguarding 

assets vulnerable to risk of loss or unauthorized use. However, we found 

that the Forest Service did not adequately track property bought with 

purchase cards. 

Forest Service policy requires that property costing more than $5,000 be 

entered into its personal property management system. Such property is 

also referred to as accountable property. USDA’s property management 

regulations state that all accountable property acquired by purchase, 

transfer, construction, manufacture, or donation will be recorded in the 

property records at the time it is accepted by the receiving agency. We 

reviewed supporting documentation for 108 accountable property items 

purchased in 64 separate transactions during fiscal year 2001, selected on a 

nonstatistical basis. 

In our review, we noted that 54 of these transactions were entered in the 

property system more than 60 days after the purchase transaction or not at 

all. Specifically, 34 of these items, totaling $266,074, or approximately 31 

percent, had been recorded in the USDA property system more than 60 

days after the purchase transaction. In many of those cases, it was several 

months before the property was recorded. For example, 8 of the items 

were not entered into the system for more than a year. In addition, we 

noted 20 property items, totaling $166,803, which the Forest Service could 

not determine had ever been entered into the property system. These items 

included 10 all-terrain vehicles, 3 copiers, 2 projectors, 2 generators, and 3 

plasma monitors. This lack of accountability makes these assets 

particularly susceptible to loss or theft without detection.

The Forest Service does not require that property costing under $5,000 be 

tracked unless the items are designated as “sensitive.”23 Each USDA 

agency defines its own list of sensitive property and is responsible for 

providing this list to the cardholders. The Forest Service designates all 

23 USDA defines sensitive property as any item of accountable property valued at less than 

$5,000 which is highly susceptible to loss or theft as defined by the Agency Property 

Management Officer. The Forest Service defines sensitive property as nonconsumable 

equipment having an original acquisition cost from $500 to $4,999 that, due to its personal 

desirability or other considerations, warrants a higher level of monitoring and control.
Page 21 GAO-03-786 Forest Service Purchase Cards

firearms, frequency modulated land-mobile radios, precise positioning 

service Global Positioning Satellite (GPS) receivers, IT equipment, and 

radiological equipment having a radioactive source as sensitive property, 

agencywide. Further, Forest Service guidance allows each of its regions 

and field offices to designate other items as sensitive. While the Forest 

Service allows field offices to categorize items under $5,000 as sensitive 

and thereby track them in inventory, there is no consistent definition of 

sensitive property across regions. For example, one Forest Service region 

considers VCRs, TVs, and CD players costing more than $500 to be 

sensitive property. Another regional office designates video and audio 

equipment costing more than $100 as sensitive. That particular region also 

considers survival equipment and clothing sensitive while other regions do 

not. 

USDA regulations state that agencies shall be responsible for maintaining 

reasonable controls over their nonaccountable property to safeguard it 

against improper use, theft, and undue deterioration. In our review, we 

identified transactions totaling $439,789 for purchases of items that were 

not recorded in the Forest Service’s inventory that, while not specifically 

designated as sensitive, appear to meet both USDA and Forest Service’s 

overall definition of sensitive property. The cost of many of these items fell 

just under the $5,000 accountable property threshold. As shown in table 1, 

these items included all-terrain vehicles, cameras, GPS units, snowmobiles, 

and night-vision goggles. 

Table 1: Nonaccountable Items Purchased

Source: GAO analysis of Forest Service purchase card and convenience check transactions selected for fiscal year 2001.

Item type Number purchased Dollar amount

All-terrain vehicles 17 $74,648

LCD projectors 25 130,057

Cameras (digital and standard) 120 129,073

Snowmobiles 9 38,787

Global Positioning Satellite Units (GPS) 52 14,200

Camcorders 7 14,098

Binoculars 9 11,624

Motorcycles 2 9,689

Personal digital assistants 14 8,394

Night-vision goggles 4 9,219

Total 259 $439,789
Page 22 GAO-03-786 Forest Service Purchase Cards

Without proper recording and accounting for these vulnerable assets, there 

is an increased risk of misappropriation of these items. For example, 

without tracking of these items a supervisor may be unaware that a 

cardholder leaving the Forest Service purchased one of these items, and 

therefore could not ensure that the item remained in the possession of the 

Forest Service. In some Forest Service regions, employee checkout 

procedures attempt to mitigate this by requiring that an official certify that 

the employee has accounted for all property. An inventory listing of these 

items would enable the supervisor to ensure that all vulnerable assets are 

properly accounted for when employees leave. 

USDA’s revised regulations, issued in June 2001, prohibit the purchase of 

accountable and sensitive property except by warranted cardholders.24 

However, the revised regulations did not mitigate the issues we identified 

regarding proper accounting for vulnerable assets. Therefore, these items 

continue to be at an increased risk of misappropriation. 

Table 2 summarizes the actions USDA and the Forest Service have taken to 

address many of the internal control weaknesses identified by the IG 

and/or us. We did not test the effectiveness of these actions because they 

were implemented subsequent to our review time frame. On reviewing the 

proposed actions, however, we found that in certain cases, even if properly 

implemented, they will still not fully remedy known vulnerabilities in 

internal controls. These cases are noted in the table.

24 A warranted cardholder is an employee who has contracting authority delegated to him or 

her by a duly authorized appointing official in accordance with federal and USDA 

regulations. The warrant, SF-1402, states the level of contracting authority delegated to an 

individual, including any limitations on that authority. Above the micropurchase threshold, 

only warranted individuals may bind USDA contractually.
Page 23 GAO-03-786 Forest Service Purchase Cards

Table 2: Revised USDA Purchase Card Policies

Policies in place during fiscal 

year 2001

Audit findings for fiscal year 

2001

USDA/Forest Service actions 

to strengthen control Continued vulnerabilities

Cardholder’s authorize 

purchases, receive related 

assets, and validate the 

purchases subsequent to 

payment for purchases under 

$2,500.

Forest Service regulations do 

not support a segregation of 

duties in purchase card 

transactions under $2,500.

None No requirement of independent 

review by the LAPC or 

supervisor to validate 

transactions or independent 

verification of receipt of goods or 

service leaves the Forest 

Service purchase card program 

vulnerable to fraud, waste, and 

abuse.

Transactions under $2,500 do 

not require preapproval unless 

they are for specific IT items.

No requirement of independent 

review by LAPC or supervisor to 

validate transactions, or 

independent verification of 

receipt of goods or service.

LAPCs and COCOs are required 

to audit a percentage of 

transactions on a monthly, 

quarterly, and annual basis to 

ensure micro-purchase rules 

have been followed using PCMS 

screens and reporting, including 

review of description fields 

completed by cardholders. Also, 

LAPCs are to audit 3 percent of 

transactions annually, by 

reviewing all supporting 

documentation for the 

transactions.

(FS 6309.32 revised 6/01) 

Supervisors were added to list of 

responsible parties for 

monitoring USDA’s regulation on 

purchase card usage. In 

addition, supervisors will require 

cardholders to generate periodic 

reports of purchase card and 

convenience check transactions. 

Supervisors shall review 

cardholder transaction reports at 

least quarterly, or more often if 

agency procedures require. 

(USDA 5013-6 issued 2/03)

These limited post-reviews are 

not sufficient oversight given the 

decentralization of the 

organization and the lack of 

segregation of duties. As 

supervisors would be expected 

to be more knowledgeable of a 

cardholder’s daily activities and 

responsibilities, the review of 

actual documentation should 

also be at the supervisor level. 

Cardholders are able to enter 

fictitious descriptions of item or 

service purchased in PCMS. 

Therefore, without a review of 

original supporting 

documentation at all levels the 

Forest Service cannot ensure 

that the purchase was 

appropriate and reflected a valid 

government need.
Page 24 GAO-03-786 Forest Service Purchase Cards

Source: GAO analysis of Forest Service documentation.

Noncompliance with 

Purchasing Requirements 

Resulted in Instances of 

Improper Purchases

The lack of adequate internal controls resulted in violations of numerous 

federal acquisition requirements and USDA/Forest Service purchase card 

policies that we classified as improper purchases. These included 

(1) purchases that were split into two or more transactions to circumvent 

single transaction limits, (2) purchase transactions that were paid for 

twice, (3) purchases of unauthorized items, (4) purchases that exceeded 

single purchase limits, (5) unapproved information technology (IT) 

purchases, (6) transactions charged to purchase card accounts of former 

employees, and (7) convenience checks written by cardholders to 

USDA-OPPM and Forest 

Service APCs and LAPCs are 

required to monitor purchase 

card transactions using the 

PCMS alert subsystem, 

statistical sampling, and query 

tool.

Alert subsystem not being used 

due to problems. 

Statistical sampling not being 

performed during 2001.

Alert subsystem expected to be 

running by June 30, 2003. New 

system will also include some 

data on disputed transactions for 

review by LAPCs.

OPPM has begun producing 

random queries of PCMS data to 

identify transactions having a 

higher than normal potential for 

abuse and sending them to the 

respective agencies for 

investigation.

Cardholders are to validate their 

transactions periodically and to 

dispute any erroneous or 

unauthorized transactions within 

60 days of the transaction date.

Disputed transactions are not 

always submitted within 60 days 

of transaction date.

Cardholders are not required to 

communicate disputed items to 

supervisors and supervisors are 

not required to monitor disputed 

transactions.

Potentially fraudulent 

transactions were still 

unresolved as of the end of our 

fieldwork.

Forest Service began 

deactivating purchase card 

accounts for which transactions 

were unreconciled more than 30 

days after transaction date.

The agency expects to have the 

Alert subsystem running by 

June 30, 2003. New system will 

also include some data on 

disputed transactions for review 

by LAPCs.

Cardholders will still be able to 

use convenience checks to 

make purchases.

It is not known whether the data 

provided will ensure that 

purchases that may be improper 

or potentially fraudulent are 

brought to management’s 

attention for investigation and 

resolution.

Accountable and sensitive 

property is to be recorded 

immediately after purchase.

Accountable property is not 

entered in the property system. 

Certain vulnerable items are not 

considered sensitive and 

included in property system.

Only warranted cardholders may 

purchase accountable or 

sensitive property.

(FS 6309.32 revised 6/01)

Property items that appear to 

meet the overall USDA and 

Forest Service definition of 

sensitive are still not included in 

the agency-level list of items to 

be entered into the property 

system. 

(Continued From Previous Page)

Policies in place during fiscal 

year 2001

Audit findings for fiscal year 

2001

USDA/Forest Service actions 

to strengthen control Continued vulnerabilities
Page 25 GAO-03-786 Forest Service Purchase Cards

reimburse themselves. Table 3 shows the total dollar amounts for 

exceptions we identified for each category.

Table 3: Categories of Improper Purchases

Source: GAO analysis of Forest Service purchase card and convenience check transactions selected for fiscal year 2001.

a

This amount includes split transactions for which we selected a statistical sample of 213 transactions. 

Based on the results of our review we estimate that almost $1.3 million of the total fiscal year 2001 

purchase card transactions identified as potential splits were actual split transactions. We are 95 

percent confident that the total dollar value for actual split transactions was between $.9 million and 

$1.6 million.

b

This amount includes duplicate transactions for which we selected a statistical sample of 230 

transactions. Based on the results of our review we estimate that almost $177,187 of the total fiscal 

year 2001 purchase card transactions identified as potential duplicates were actual duplicate 

transactions. We are 95 percent confident that the total dollar value for actual duplicate transactions 

was between $43,458 and $310,916.

While the total amount of improper purchases we identified is relatively 

small compared to the more than $320 million in annual purchase card and 

convenience check transactions, it demonstrates vulnerabilities from weak 

controls that could easily be exploited to a greater extent. The above 

policy violations are discussed in more detail below.

Split purchases. Using data mining techniques, we identified purchases 

that appeared to have been split into two or more transactions by 

cardholders to circumvent their single transaction limit. We requested 

supporting documentation for a statistically determined sample of 213 out 

of 1,854 potentially split purchases we identified. Of these 213, we 

identified 29 actual split purchases for which we received and examined 

documentation that confirmed that the purchases were split into two or 

more transactions. Based on these results, we estimate that almost

Policy violation

 Dollar amount of 

transactions 

Split purchases $1,285,252a

Duplicate transactions 177,187b

Purchases of unauthorized items 53,324

Purchases that exceeded single transaction limit 41,445

Information technology purchases that were not approved 25,452

Transactions on accounts of former employees 43,625

Convenience checks written for cash reimbursement 2,014

Total $1,628,299
Page 26 GAO-03-786 Forest Service Purchase Cards

$1.3 million25 of the total fiscal year 2001 purchase card transactions were 

split transactions. For example, a cardholder with a single purchase limit 

of $2,500 purchased 13 toner cartridges totaling $3,918. The cardholder 

had the vendor split the purchase between two invoices to avoid exceeding 

her single purchase limit. In another example, the cardholder purchased 

$36,984 of safety equipment for rescue workers. The cardholder had the 

vendor separate the total charge into three charges to circumvent her 

single transaction limit of $25,000. The projected amount of split 

transactions may have been higher had we received all documentation 

requested. However, for 59 of the 213 sampled transactions, we could not 

determine whether they were split transactions because cardholders did 

not provide documentation through the APC to enable us to assess them. 

The purpose of the single purchase limit is to require that purchases above 

established limits be subject to additional controls to ensure that they are 

properly reviewed and approved before the agency obligates funds. By 

failing to monitor transactions, these limits may be circumvented and the 

Forest Service will have less control over the expenditure of its resources.

Duplicate transactions. Using data mining techniques, we identified 

individual purchases that appeared to have been charged twice to 

cardholder’s accounts. We requested supporting documentation for a 

statistically determined sample of 230 of the 8,659 potentially duplicate 

transactions we identified. Of these 230, we identified 6 actual duplicate 

transactions. Based on these results, we estimate that $177,18726 of the 

total fiscal year 2001 purchase card transactions were duplicate 

transactions. The projected amount of duplicate transactions may have 

been higher had we received all documentation requested. However, for 

30 of the 230 sampled transactions, we could not determine whether they 

were duplicate transactions because cardholders did not provide 

documentation through the APC to enable us to assess them. Supervisory 

review of the documentation supporting the cardholder’s transactions 

reduces the risk that duplicate charges would go undetected and result in 

financial losses to the government. In addition, an effective monitoring 

program at the APC/LAPC level would help flag these types of improper 

transactions.

25 We are 95 percent confident that the total dollar value of actual split transactions was 

between $.9 million and $1.6 million.

26 We are 95 percent confident that the total dollar value of actual duplicate transactions was 

between $43,458 and $310,916.
Page 27 GAO-03-786 Forest Service Purchase Cards

Purchases of unauthorized items. USDA purchase card policy states that 

the purchase card and convenience checks will not be used for the 

purchase of hazardous items such as firearms, ammunition, explosives, or 

hazardous biological and radioactive substances. However, we identified 

10 transactions totaling $53,324 for the purchase of ammunition, rifles, and 

explosives. For example, we identified two transactions for the purchase 

of rifles, which are used for animal control and other Forest Service 

activities. When we informed the cardholders that these transactions were 

improper, one cardholder stated that he was unaware that purchase card 

policy prohibited this purchase. The other cardholder stated that as a 

warranted cardholder, she was allowed to purchase the rifle. This is not 

the case under Forest Service policy, and when we brought this to the 

attention of the Forest Service APC, she contacted the employee to inform 

her that the purchase was improper. Further, we identified a $500 purchase 

of ammunition, which was given to the local sheriff's department under a 

cooperative agreement. Under the agreement, the sheriff's department 

would patrol campgrounds because of manpower shortages within the 

Forest Service. The cardholder told our investigator that it is a common 

occurrence in his region to have cooperative agreements with local law 

enforcement agencies. When we discussed this transaction with the Forest 

Service APC she expressed some concern as to whether the intent of the 

cooperative agreement program was being properly administered in the 

cardholder’s region. 

Purchases that exceeded single transaction limits established by USDA 

policy. Through our data mining efforts, we identified 12 purchases 

totaling $41,445 that exceeded the cardholder’s single transaction limit by 

10 percent or more. Of the purchases we identified, we noted that none of 

them were made using the purchase card; instead they were made using 

convenience checks that had been issued to the cardholder. According to 

the Forest Service APC, when an individual cardholder uses a purchase 

card and the amount of the purchase is in excess of the limit, electronic 

controls established by Bank of America deny the transaction and it cannot 

be completed. However, these controls do not exist for convenience 

checks. The cardholder’s single transaction limit is printed on the face of 

his/her convenience checks. Yet when a cardholder writes a check in 

excess of their transaction limit, only scrutiny by the vendor would identify 

this. According to the Forest Service APC, the Bank of America honors all 

convenience checks. Therefore, when vendors submit checks written for 

amounts in excess of the cardholder’s limit to Bank of America, the checks 

are accepted and processed for payment. This lack of control allows a 

cardholder to circumvent the single transaction limit, even in the case 
Page 28 GAO-03-786 Forest Service Purchase Cards

where the Forest Service has reduced a cardholder’s single transaction 

limit to $0 or $1 for abusing the purchase card program or due to separation 

from the agency, increasing the risk of unauthorized or improper purchases 

by cardholders. 

No preapproval of IT purchases. While the Forest Service generally does 

not require preapproval of purchases under $2,500, there are some specific 

categories of items for which prior independent approval must be obtained. 

According to Forest Service policy, cell phones, fax machines, scanners, 

and other IT equipment are not to be purchased without first obtaining 

approval from the appropriate IT personnel. However, we found 11 

transactions totaling $25,452 for equipment, including cell phones, 

scanners, printers, and fax machines, that did not have this required 

preapproval. 

Transactions by cardholders separated from the Forest Service. Using 

data mining techniques, we identified purchase card accounts that had 

transactions totaling approximately $43,625 charged to them with 

transaction dates that appeared to be after the cardholders left the Forest 

Service.27 In discussions with the Forest Service APC, she agreed that, 

based on the available data, $4,385 of these transactions could be 

confirmed to be improper, having been made after the employees had left 

the Forest Service. For example, one former employee left the Forest 

Service on November 4, 2000, but PCMS records indicated that six 

purchases, totaling $1,632, were charged to the employee’s purchase card 

account over the next 2 months at Ames and Kmart department stores. The 

Forest Service was unable to provide documentation to support the 

appropriateness of the remaining transactions totaling $39,240.

Cardholders wrote convenience checks to themselves. We found 26 

instances, totaling $2,014 where cardholders wrote checks to themselves, 

contrary to Forest Service policies that prohibit this practice. Writing 

checks for cash is also an unauthorized transaction, according to USDA’s 

micropurchase guide. In addition, the guide states that cardholders may 

issue checks to reimburse other employees for local travel expenses, such 

27 We compared cardholder names from Bank of America data to the Forest Service list of 

employees who had left the Forest Service during fiscal year 2001, including their dates of 

separation. However, in some cases we found that the full name of the employee who left 

the Forest Service was the same as the cardholder, but was actually a different person. 

Therefore, it was necessary for us to obtain verification from the Forest Service before 

concluding on these transactions.
Page 29 GAO-03-786 Forest Service Purchase Cards

as mileage, parking, and taxis, authorized by their agency while on official 

business, or miscellaneous expenditures (e.g., supplies, services, 

registration fees, and telephone use for official business) that were cleared 

with the cardholder before the purchase was made. However, the proper 

documentation must be completed and the expenditures must be approved 

by an authorized official other than the cardholder. In most of the cases we 

identified, the cardholders stated that they were unaware of the prohibition 

against writing checks to themselves for cash. The remaining cardholders 

stated that they were aware of the restriction, but did it anyway to expedite 

their reimbursement as no other cardholders with checks were available at 

the time, or in one case, the employee who reimbursed himself was the 

only one with checks at that location. 

The above examples not only illustrate a lack of adequate oversight, but 

also the need for better training. According to USDA and Forest Service 

regulations, each cardholder is required to obtain some type of training 

before being issued a card. Each agency within USDA is responsible for 

training participants in accordance with USDA or agency-specific 

regulations and is allowed to determine the method of certification. 

Poor Controls over 

Purchasing Practices 

Resulted in Certain 

Wasteful and 

Questionable 

Transactions

The inadequacies and ineffectiveness of internal controls were also evident 

in the 779 wasteful and questionable transactions we identified that totaled 

over $1 million. Transactions we classified as wasteful were for items or 

services that were (1) excessive in cost compared to other available 

alternatives, (2) for a questionable government need, or both. We also 

identified other transactions that we classified as questionable because 

there was insufficient documentation to determine what was purchased. 

Lacking key purchase documentation, we could not determine what was 

actually purchased, how many items were purchased, the cost of each of 

the items purchased, and whether there was a legitimate government need 

for such items. 

Table 4 indicates the number of transactions and dollar amounts that we 

determined to be wasteful or questionable. These transactions are 

indicative of what can occur when purchase card use is not properly 

controlled. We tested only a portion28 of the transactions that we identified 

28 Out of a total population of over 800,000 transactions, we identified approximately 68,000 

transactions that appeared at higher risk of being inappropriate, of which we selected about 

5,000 for our review.
Page 30 GAO-03-786 Forest Service Purchase Cards

that appeared to have a higher risk of fraud, waste, or abuse; there may be 

other improper, wasteful, and questionable purchases in the remaining 

untested transactions.

Table 4: Purchases Determined to Be Wasteful or Questionable

Source: GAO.

Wasteful Purchases We identified 135 purchases totaling $212,104 that we determined to be 

wasteful because they were excessive in cost relative to available 

alternatives, of questionable government need, or both. We considered 

items to be excessive in cost when less expensive alternatives would meet 

the same basic needs. We defined items as being of questionable 

government need when they appeared to be a matter of personal 

preference or personal convenience, were not reasonably required as part 

of the usual and necessary equipment for the work the employees were 

engaged in, or did not appear to be for the principal benefit of the 

government. Specifically, we identified 93 purchases totaling $127,319 that 

we considered excessive in cost, including purchases for digital cameras, 

premium satellite and cable TV packages, awards and gifts, and 

cancellation fees. In addition, we identified 42 purchases totaling $84,785 

for which we questioned the government need. Such purchases included 

specialty costumes, PDAs, and PDA accessories.

Forest Service policy requires that purchasers buy equipment, supplies, or 

materials that economically meet the needs of the government, avoid 

deluxe items when the requirements are satisfactorily met by less costly 

standard articles, and take into account the perspective of the user of the 

Transaction category

Number of

transactions

Dollar amount of 

transactions

Wasteful transactions:

Excessive cost 93 $127,319

Questionable government need 42 84,785

Total wasteful purchases 135 $212,104

Questionable transactions:

Inadequate/incomplete documentation 317 253,388

No documentation 327 616,437

Total questionable purchases 644 $869,825

Grand total 779 $1,081,929
Page 31 GAO-03-786 Forest Service Purchase Cards

product. When we reviewed the supporting documentation for many of the 

purchases we identified, we noted that the cardholders frequently did not 

document their determination that the item purchased economically met 

the needs of the government based on an evaluation of price and other 

factors, thus avoiding deluxe items as required by Forest Service 

purchasing policy. When we requested additional information from 

cardholders, they either did not provide the requested information or the 

documentation provided was inadequate to support that the specific 

purchase was in compliance with this policy. 

Items purchased at a price higher than that of available alternatives that 

would have met the same basic needs included: 

• Digital cameras. During our detailed testing, we identified 66 digital 

cameras and accessories purchased in 37 separate transactions totaling 

$61,243 that appeared to have been purchased based on the personal 

preference of the cardholder, not on the minimum specifications to 

support the anticipated use. Digital cameras are available at many price 

levels, with the price usually reflecting the technical specifications of 

the cameras and the options included. The Forest Service uses digital 

cameras for various purposes in its operations, such as taking digital 

images of nursery and reforestation activities throughout the nation. 

These images are used for publications, presentations, workshops, and 

placed on the RNGR web site as part of the technology transfer and 

technical assistance missions of certain teams. Depending on the 

intended use of the images, cameras must have certain capabilities of 

which the users should be knowledgeable or at a minimum have readily 

available guidance on. This helps to ensure that cameras purchased 

meet and not exceed the needs of the user. In our review of the 

supporting documentation and cardholder statements we noted that 

some of the cardholders knew how the cameras were going to be used. 

However, they did not know what minimum technical capabilities the 

cameras had to have. Cardholders purchased cameras ranging from 1 

megapixel to 4 megapixels of data resolution, ranging in price from 

around $350 to over $1,900, that appeared to be based on personal 

preference, not Forest Service need. Forest Service policy states that 

the requirements of an item must be taken into account in its purchase 

to ensure that it economically meets the needs of the government and to 

prevent the purchase of deluxe items when the requirements are 

satisfactorily met by less costly standard articles. However, the Forest 

Service had not developed guidelines on the purchase of high-tech items 

such as digital cameras. In addition, the individual transactions by 
Page 32 GAO-03-786 Forest Service Purchase Cards

cardholders at various vendors involved the purchase of usually only 

one or two cameras at a time. This does not allow the Forest Service to 

achieve possible economies of scale by purchasing them from a single 

vendor at a discount. 

• Premium satellite and cable TV packages. We identified 21 transactions 

totaling $4,843 for monthly satellite television programming. The 

Forest Service is authorized to provide minimum recreation facilities 

and opportunities for its employees consistent with the degree of 

isolation and permanence of the individual work centers. However, in 

each television entertainment purchase we identified, the cardholder 

had not contracted for the basic service offered by the vendor but 

instead for a premium package, such as HBO, Cinemax, NFL or NBA 

games, or for pay-per-view movies. In one instance the invoice included 

charges for pornographic movies. In addition, we noted one $833 

transaction for Direct TV service that the cardholder stated was needed 

in order to allow the office to track weather conditions in that part of 

the country. We questioned the need for this capability given that 

detailed weather tracking is accessible on the Internet, which, according 

to a Forest Service telecommunications manager, is available in all 

offices. In addition, we reviewed the invoice supporting this transaction 

noting that the cardholder had also subscribed to 2001 NFL Sunday 

Ticket ($199), a subscription to view NFL games on Sunday during the 

NFL season, through the vendor. 

• Awards and gifts. We noted several purchases for awards and 

retirement and farewell gifts for which adequate supporting 

documentation was not provided or the award items purchased were 

not in compliance with USDA policy. USDA policy provides for a 

number of performance award categories and criteria for each, and 

requires that the purpose and type of award given should be 

documented. Nonmonetary awards, according to USDA policy, are time 

off awards, keepsakes,29 letters of appreciation, and honorary awards. 

We identified purchases for which the Forest Service was unable to 

identify the purpose of the award or provide supporting documentation. 

For example, we identified eight transactions, totaling $13,694 in award 

purchases, which included hats, mugs, backpacks, and blankets 

29 Keepsakes are defined as medals, certificates, plaques, citations, badges, pen-and-pencil 

sets, pins, and coffee cups as long as the item displays the department's name and is suitable 

for display.
Page 33 GAO-03-786 Forest Service Purchase Cards

purchased from vendors such as Warner Bros., Eddie Bauer, and Mori 

Luggage and Gifts, in which the cardholder either gave no or inadequate 

justification for the purchase of these items. In addition, USDA’s 

regulation on career service recognition states that awards are intended 

to recognize employees for their special efforts, and motivate others 

who witness the presentation. According to the regulation, employees 

should not be recognized monetarily when they leave USDA either 

through retirement or separation. However, USDA agencies may 

consider providing some form of honorary or nonmonetary recognition 

of an employee’s efforts in support of USDA’s mission. Items such as 

plaques or pins are considered appropriate and may be presented. 

However, we identified one transaction for the purchase of a golf bag as 

a farewell gift and another for the purchase of a rifle as a retirement gift 

for an employee. 

• Cancellation fees. We found two transactions totaling $34,950 for 

cancellation fees for rooms not used by Forest Service employees for a 

conference and housing for a seasonal work crew. Specifically, the 

Forest Service paid a $30,000 cancelation fee to Doubletree Hotel in 

Denver, Colo.. The Contracting Officer did not recall the specific facts 

related to this transaction except that the program office rescheduled 

this conference several times with the hotel and then finally canceled, 

but not in time to avoid the fee. The Forest Service also paid a $4,950 

cancellation fee to the Rain Country Bed and Breakfast for late 

cancellation of its reservation to house seasonal workers.

We also found government expenditures that appeared to be for items that 

were a matter of personal preference or convenience, were not reasonably 

required as part of the usual and necessary equipment for the work the 

employees were engaged in, or did not appear to be for the principal 

benefit of the government, which included the following.

• Specialty costumes and decorative tent. Forest Service policy provides 

for purchases to promote programs related to Smokey the Bear and 

Woodsy the Owl. We noted three transactions totaling $8,750 for 

costumes not related to these two programs. For example, the Forest 

Service purchased two fish costumes, Frank and Franny Fish, from the 

Carol Flemming Costume Design Studio at $2,500 each, used for aquatic 

education in the Pacific forest regions. The cardholder explained that 

these personalities are to the fisheries program what Smokey Bear is to 

the fire program. We also identified a transaction totaling $3,750 for 39 

“web of life” costumes, including animals and nature themes, to be used 
Page 34 GAO-03-786 Forest Service Purchase Cards

in education programs. However, Forest Service policy does not 

support the purchase of these costumes and the cardholder’s statement 

does not establish sufficient government need for the costumes to 

support regional programs. In addition, we identified a $7,500 purchase 

of a hand-stitched “salmon tent” from Evelyn Roth Festival Arts. The 

supporting documentation did not provide a purpose for the purchase of 

the tent, only a note that the Forest Service has purchased several of 

these tents over the last 5 years or so. 

• Personal Digital Assistants (PDA). During our review, we identified 11 

transactions for the purchase of 14 PDAs and accessories totaling $8,768 

from vendors such as Palm Computing, Casio, Amazon.com, and Best 

Buy. The Forest Service does not have a policy on the purchase of 

PDAs, handheld electronic devices that function as calendars, address 

books, and other personal administrative aids. Calendars and daily 

planners cost from $6 to $56 with refills for the daily planner costing 

about $20. We noted that some cardholders had purchased high-end 

items such as the Palm VTM and Palm M505TM with costs ranging from 

$350 to $450. By comparison, alternatives such as Palm’s M105TM model 

retailed for approximately $200 at the time of these transactions. In our 

review of the supporting documentation for these purchases, we found 

nothing to show how the cardholders determined that the PDAs were 

necessary to fulfill a valid government need, rather than the personal 

preference of the cardholders. For example, one cardholder purchased 

a single IBM workpad with hotsync cradle for $829 to use as a calendar, 

address book, and to check e-mail messages. Another cardholder 

purchased six new PDAs from Casio Electronics by trading in six Forest 

Service PDAs plus $199 each. When asked to explain the need for the 

newer PDAs, his response was that the newer ones were faster and had 

more memory to support e-mail. Lastly, the Forest Service incurred 

other expenses for items to support the PDAs, such as keyboards and 

carrying cases. In one instance we identified a purchase of PDA 

keyboards, totaling $374, which, according to the cardholder, would be 

used for taking notes in meetings. 

• Cordless phones and headsets. We noted several purchases of cordless 

phones or headsets for Forest Service employees where cardholders 

were unable to provide documentation supporting the necessity for the 

item in performing their duties. Instead, the purchases have the 

appearance of having been made for personal convenience. For 

example, a Forest Service cardholder purchased cordless phones and 

handsets totaling $2,242. When we asked why the phones were needed, 
Page 35 GAO-03-786 Forest Service Purchase Cards

the cardholder responded that they were purchased for the ease of use 

and to enhance the workplace for certain employees. 

We also identified numerous other individual purchases that we considered 

to be wasteful due to excessive cost or questionable government need. 

Such purchases included $9,219 for six pairs of night vision goggles ($1,536 

average), that we found available at prices ranging from $379 to $1,949; 

$2,701 for sound masking equipment, which the cardholder stated was 

needed to reduce the level of noise coming from the cubicles in the regional 

office where she worked; $2,929 paid to Hair of the Dog for an aquarium in 

an Alaska regional visitor information center; $2,295 paid to Quality 

Billiards for a billiard table for a Forest Service bunk house; $2,204 paid to 

Best Buy for TV/VCR combinations and their installation into Forest 

Service vehicles; $589 paid to Ultimate Electronics for a DVD player to be 

used by employees to watch exercise videos in the fitness room; and $200 

for a leather briefcase.

Until the Forest Service provides adequate management oversight of its 

purchase card program, including a more thorough, systematic review and 

monitoring of expenditures with appropriate disciplinary action when 

warranted, the types of wasteful and abusive purchases we identified are 

likely to continue.

Questionable Purchases Forest Service policy requires that cardholders maintain adequate 

documentation of all purchase card and convenience check transactions. 

As discussed earlier in this report, we requested supporting documentation 

for a nonstatistical sample of over 5,000 transactions. Of these, we 

identified 644 transactions totaling over $869,825 that appeared to be 

improper, wasteful, or potentially fraudulent, but for which the Forest 

Service either provided insufficient or no documentation to determine the 

propriety of the transactions. 

For 104 transactions, totaling $184,682, that appeared to be either improper 

or wasteful, the documentation we received was inadequate or was not the 

correct supporting documentation, and we were unable to make a 

determination of the propriety of the transactions. For example, we 

requested supporting documentation for a $2,315 transaction charged by 

Unisys Corporation. Supporting documentation was not provided to us. 

The Forest Service explained that the employee knowledgeable about this 

charge had left the Forest Service and the documentation related to the 

purchase could not be located. The remaining transactions represented 
Page 36 GAO-03-786 Forest Service Purchase Cards

purchases made at various vendors such as $5,803 at Have Party Will 

Travel; $4,940 at Spencer’s TV & Appliance; $2,400 at Grand Home 

Furnishings; $2,828 at Lowder’s Home Entertainment; $1,729 at Mick’s 

Scuba Inc.; and $3,430 at Samson Tours.

We also identified 213 transactions totaling over $68,706, which appeared 

to be either unauthorized and for personal use, made using compromised 

accounts or unauthorized transactions by merchants, but adequate 

documentation was unavailable to allow us to determine the propriety of 

the purchases. We were subsequently able to determine that several of the 

transactions were in fact fraudulent. These fraudulent and potentially 

fraudulent transactions included the following. 

• Transactions made by cardholders that appeared to be unauthorized 

and intended for personal use. For example, we identified three 

transactions totaling $1,031 in jewelry and china for one cardholder that 

appeared to be unauthorized or for personal use. In the course of our 

follow-up inquiries, we found that the cardholder had been under 

investigation by the IG since January 2002 when an employee at a local 

vendor expressed concerns to a Forest Service employee about some 

purchases by another Forest Service employee. In our review of the 

USDA IG Report of Investigation on this cardholder, we noted that the 

fraudulent activity identified by the IG spanned from May 1999 through 

January 2002. During this period the cardholder purchased five digital 

cameras totaling $2,960, six computers totaling $6,019, three palm pilots 

totaling $736, jewelry totaling $1,967 and various other items including 

cordless telephones, figurines, and Sony Playstations totaling $6,101. On 

December 2, 2002, the employee pleaded guilty to one felony count of 

theft of government money and property in the amount of $31,342. In 

addition, we identified one transaction totaling $511, at a Tribal Bingo 

Casino, for another cardholder who, according to the IG, is also 

currently under investigation.

• Transactions made using compromised accounts in which a purchase 

card or account number was stolen and used to make unauthorized 

purchases. For example, we identified unauthorized transactions for 

$692 at Kmart, Circuit City, and other vendors by a person other than the 

cardholder using the cardholder’s account number. The cardholder 

contacted one of the merchants about the charges and was told that the 

merchant’s security personnel requested personal identification from 

the individual after the purchase, but the individual left the store and did 

not return. The cardholder’s account was canceled. In addition, we 
Page 37 GAO-03-786 Forest Service Purchase Cards

identified a transaction that had been disputed by a cardholder and 

upon investigation the cardholder determined that the charge was 

incurred by an employee of a local vendor for calls made to a phone-sex 

line.

• Unauthorized transactions charged by merchants to cardholder 

accounts. For example, we identified 20 disputed transactions, totaling 

over $2,700, for one merchant, Productivity Plus. On the basis of 

cardholder explanations we reviewed in PCMS’s dispute screen, it 

appeared that the merchant had obtained several cardholder account 

numbers and charged amounts to them without the authorization of the 

cardholders.

For the remaining 327 transactions,30 totaling $616,437, the cardholders 

provided no documentation to the APC. Lacking key purchase 

documentation, we could not determine what was actually purchased, how 

many items were purchased, the cost of individual items purchased, and 

whether there was a legitimate government need for the items. Based on 

the vendor names and MCCs which identified the types of products or 

services sold by these vendors, we believe at least some of these items may 

have been determined to be improper or wasteful had the documentation 

been provided or available. These transactions included $2,178 in 

purchases from Best Buy, $2,500 from BUY.COM, $6,840 at 

HPSHOPPING.com, $4,100 from Party Time Inc. and $3,185 from USA 

Tours. 

The majority of these transactions represent single transactions for 

individual cardholders. However, we noted that there were several 

cardholders with multiple transactions who did not provide us with 

supporting documentation for their purchases. For example, one 

cardholder in the pacific southwest region did not provide documentation 

for five transactions of electronic purchases totaling $3,349 that appeared 

to be either improper or wasteful. Another cardholder in the pacific 

southwest region did not provide documentation for six transactions, 

totaling $11,267, for on-line services, electronics, and one payment by 

convenience check. 

30 Subsequent to the end of our fieldwork, the Forest Service had obtained documentation 

for approximately 200 of these transactions. However, due to the lateness of the 

documentation, we were unable to review them. 
Page 38 GAO-03-786 Forest Service Purchase Cards

Conclusions The Forest Service lacks certain basic internal controls over its purchase 

card program, and thus is susceptible to waste, fraud, and abuse. The IG in 

its August 2001 report also identified many of the same control weaknesses 

that we did. The Forest Service took several steps to address these 

problems when it issued revised purchase card regulations in June 2001, 

December 2002, and most recently, in conjunction with USDA, in February 

2003. However, the revised regulations did not fully address the critical 

issues reported by the IG and confirmed by us as continuing weaknesses 

during our audit, such as supervisory review, effective monitoring of 

purchase card transactions, and property accountability. Until these 

weaknesses in fundamental internal controls are addressed, the types of 

improper, wasteful, and potentially fraudulent purchases we identified are 

likely to continue and certain assets will remain vulnerable to theft. The 

Forest Service will have to thoroughly reassess and strengthen its current 

policies and procedures to address the weaknesses identified, develop a 

strong commitment at all levels of the agency to carryout these policies and 

procedures, and implement appropriate oversight to continually assess 

their effectiveness. 

Recommendations for 

Executive Action

We recommend that the Chief of the Forest Service take the following 

actions to strengthen internal controls and compliance in its purchase card 

program, decrease improper and wasteful purchases, and improve the 

accountability over assets.

Internal Controls With regard to improving the Forest Service’s internal controls over 

purchasing, we recommend that the Chief of the Forest Service do the 

following.

Segregation of Duties • Establish policies and procedures that segregate duties for at least some 

phases of the purchasing process when using the purchase card. The 

Forest Service program should ensure that no one individual is able to 

take all the steps needed to request, purchase, receive, maintain, and 

validate goods and services.

Supervisory Review • Establish policies and procedures requiring that supervisors review and 

validate all of their subordinates’ purchase card transactions, including 

review of original supporting documentation to confirm they are 

appropriate, for official purposes, and reconciled in a timely manner. 
Page 39 GAO-03-786 Forest Service Purchase Cards

Monitoring • Strengthen policies and procedures to ensure that the appropriate LAPC 

is notified and the LAPC cancels cardholder accounts immediately when 

a purchase card is lost or stolen or a cardholder leaves Forest Service 

employment.

• Establish a systematic process that the APC can use to track and 

monitor training for cardholders and program coordinators to help 

ensure that they receive (1) training before being granted purchase 

cards or approval authority and (2) timely, periodic refresher training in 

areas such as proper segregation of duties, purchasing policies and 

procedures, supervisor and program coordinator responsibilities for 

reviewing and approving individual purchases, and reporting potential 

purchase card fraud and abuse.

• Revise and strengthen policies and procedures for cardholders who 

have had their purchase card use suspended or limited to ensure that 

similar action is taken on the use of convenience checks.

• Revise and strengthen policies and procedures over disputed 

transactions to ensure that all disputed transactions are identified in a 

timely manner and completely resolved.

• Establish policies and procedures to ensure that original documentation 

is maintained in central locations, such as regional offices, so that it is 

readily available for periodic monitoring reviews by supervisors, LAPCs, 

and COCOs.

Property • Revise and strengthen policies and procedures for designating property 

costing under $5,000 as “sensitive” to include all equipment susceptible 

to theft. Also, ensure that the revised policies and procedures are 

applied consistently across all Forest Service regions.

• Establish policies and procedures to ensure that all sensitive and 

accountable personal property used in Forest Service operations is 

promptly entered into the PROP system or other comparable system 

and that a periodic inventory of the items is taken.

Compliance with 

Purchasing Requirements

With regard to improving and enforcing compliance with purchasing 

requirements at the Forest Service, we recommend that the Chief of the 

Forest Service do the following.
Page 40 GAO-03-786 Forest Service Purchase Cards

• Implement monitoring techniques to identify improper transactions 

such as cardholders making split purchases, cardholders writing checks 

payable to themselves, purchases exceeding established dollar 

thresholds, or purchasing unauthorized items.

• Revoke or suspend purchasing authority of cardholders who are found 

to be frequently or flagrantly noncompliant with policies and 

procedures.

Wasteful and Questionable 

Purchases

With regard to purchases that may be at an excessive cost or for 

questionable government need, we recommend that the Chief of the Forest 

Service do the following.

• Require purchases of certain assets, such as computer equipment, 

PDAs, and other electronics to be coordinated centrally to take 

advantage of economies of scale, standardize types of equipment 

purchased, and better ensure bona fide government need for each 

purchase.

• Develop and implement purchasing guidelines, based on specific Forest 

Service uses, for equipment such as digital cameras and projectors.

• Require that cardholders document their determination that purchased 

items economically met the needs of the government based on an 

evaluation of price, consideration of the item’s expected use, and other 

factors. 

• Follow up on transactions we identified for which no supporting 

documentation was provided to determine that the items purchased 

were for a legitimate government need, and take appropriate 

disciplinary or corrective action as warranted. 

Agency Comments and 

Our Evaluation

The Forest Service provided written comments on a draft of this report. In 

its response, the Forest Service did not specifically comment on our 

recommendations. However, the response acknowledged that some of the 

internal control weaknesses identified in our report existed both prior to 

and during our review. The response further outlined actions taken or 

planned since June 2001 to strengthen the overall management of the 

purchase card program, which the Forest Service described as having been 
Page 41 GAO-03-786 Forest Service Purchase Cards

taken, not withstanding our report. We acknowledged many of these actual 

and planned actions in our report and believe that these actions, if fully 

implemented, will help to address some of the vulnerabilities that the IG 

and we identified. However, as shown in Table 2 on page 30 of our report, 

many weaknesses will still remain that continue to expose the Forest 

Service to improper, wasteful, and fraudulent purchase card activity. Our 

15 recommendations address remaining weaknesses identified in the table 

and elsewhere in our report.

Specific actions taken as outlined in the Forest Service’s response 

included, among other things, requiring definitive levels of auditing of 

purchase card transactions, performing data mining queries of transaction 

data to identify potential questionable purchases, and conducting training 

for regional and local agency program coordinators.

In its response, the Forest Service also stated that in fiscal year 2003 USDA 

issued an Internal Control Blue Print to decrease risks and improve 

internal controls over the purchase card program. In response, the Forest 

Service developed a Plan for Improving Internal Controls (Plan) that 

included improvements such as significantly decreasing the use of 

convenience checks beginning in fiscal year 2003 with the goal of totally 

eliminating them in the future, reducing the number of cardholders by 10 

percent, developing additional data mining queries including PCMS alerts 

and statistical sampling, ensuring that the ratio of LAPCs to cardholders is 

appropriate, and requiring supervisors to review cardholder purchases 

including backup documentation. 

If fully institutionalized and enforced, the actions included in the Forest 

Service’s Plan, along with those actions previously taken, will go a long way 

in identifying improper purchases. However, it will be important that these 

actions be carried out in a systematic manner. Further, even if these 

actions are implemented systematically, they still fall short in mitigating 

certain internal control weaknesses that are addressed by the 15 

recommendations in our report. 

Specifically, the Forest Service letter outlined actions to strengthen 

monitoring such as the monthly, quarterly, and annual transaction reviews 

by LAPCs and COCOs, data mining queries developed and furnished to 

coordinators, and reviews by regional offices of audits performed by local 

offices. While these revised policies will provide much needed oversight at 

a macro level, these actions do not specifically address our 

recommendations regarding controls over cancellation of stolen cards, 
Page 42 GAO-03-786 Forest Service Purchase Cards

disputed transactions, training, and the maintenance of documentation in a 

central location. 

The Forest Service letter stated that its Plan requires supervisors to review 

cardholder purchases, including backup documentation. Upon review of 

the Forest Service’s Plan, we noted that it does not require supervisors to 

review backup documentation, as stated in the response letter. The Plan 

only states that the Forest Service will communicate, by July 15, 2003, the 

requirement for cardholder’s supervisors to review transactions quarterly 

in accordance with DR 5013-6, which also does not require that supervisors 

review backup documentation. We confirmed our understanding of this in 

discussions with USDA OPPM officials. We continue to believe that limited 

post-reviews are not sufficient, given the lack of segregation of duties, the 

decentralization of the organization, and the ratio of cardholders to LAPCs 

in the organization to detect or prevent inappropriate transactions. As 

recommended in our report, we believe that the Forest Service should 

establish policies and procedures requiring a front-line review by 

supervisors to validate all of their subordinates’ purchase card 

transactions, including review of original supporting documentation to 

confirm that they are appropriate, for official purposes, and reconciled in a 

timely manner.

The Forest Service response also did not discuss any actions taken to 

reduce purchases that are of excessive cost or for questionable government 

need. In our report, we recommended that the Forest Service purchase 

certain assets centrally, develop purchasing guidelines, and require that 

cardholders document that items meet the needs of the government. We 

believe that our recommendations, if implemented, will assist in reducing 

waste in the purchase card program.

In the area of property accountability, the Forest Service responded that 

unwarranted cardholders are no longer permitted to acquire accountable 

property with purchase cards. Further, the letter stated that the Forest 

Service plans to issue guidance requiring that all property be labeled as 

Forest Service property and prohibiting regions from individually 

determining what property is considered sensitive. However, these new 

policies will not require the tracking of items costing under $5,000, such as 

PDAs, cameras, ATVs, and snowmobiles that we consider to be at high risk 

for theft or misuse. USDA has determined that the $5,000 accountability 

threshold is the level of acceptable risk for tracking property in the 

property system. USDA has further determined that items such as PDAs 

and digital cameras rapidly lose their value and usefulness and therefore, 
Page 43 GAO-03-786 Forest Service Purchase Cards

the cost of tracking and maintaining property records for these types of 

items exceeds their value. We disagree with this position. None of the 

documentation we have reviewed or individuals we have spoken to 

indicated that uses for which these items were purchased will change 

dramatically or cease altogether in the near term, thus these items will 

continue to be useful for some time to come. We are not suggesting that 

items costing less than $5,000 be capitalized for financial reporting 

purposes, however, we continue to believe that the Forest Service should 

track these items to help ensure accountability over them to mitigate the 

risk of misappropriation.

The Forest Service response also characterized the $2.7 million of alleged 

improper, wasteful, and questionable purchases that we identified as 

relatively small compared to the $320 million in purchases during fiscal 

year 2001. While we acknowledge this in the report, we also note that these 

improper transactions demonstrate vulnerabilities from weak controls that 

could be exploited to a greater extent. Further, in performing our review, 

we identified approximately 68,000 transactions that appeared to be at a 

higher risk of being improper or wasteful. However, we selected only 5,000 

of these transactions for detailed review, therefore the actual amount of 

improper payments at the Forest Service is likely higher that what we 

identified. 

The Forest Service response further stated that it appears that “GAO’s goal 

is a risk free micro-purchase program that would include approval and/or 

review of each and every micro-purchase transaction.” While no purchase 

card program can be risk free, the goal of our recommendations is to 

reduce the level of risk in the Forest Service program to an acceptable 

level. Currently, we believe that the risk of waste, fraud, and abuse in the 

program is unacceptably high. A micro-purchase program should and can 

be designed with certain basic internal controls that need not be costly or 

onerous to implement to help ensure that improper transactions are 

detected or prevented in the normal course of business and therefore that 

taxpayer funds are effectively used toward the achievement of agency 

goals and objectives. 

The Forest Service’s written comments and our evaluation of certain of 

those comments not addressed above are presented in appendix I.

As arranged with your offices, unless you announce the contents of this 

report earlier, we will not distribute it until 30 days from its date. Then we 
Page 44 GAO-03-786 Forest Service Purchase Cards

will send copies of this report to the Ranking Minority Member of the 

Senate Committee on Finance, congressional committees with jurisdiction 

over the Forest Service and its activities, the Secretary of Agriculture, the 

Chief of the Forest Service, and the Director of the Office of Management 

and Budget. We will also make copies available to others upon request. In 

addition, this report will be available at no charge on GAO’s Web site at 

http://www.gao.gov.

Should you or your staff have any questions on matters discussed in this 

report, please contact me at (202) 512-8341 or calboml@gao.gov or Alana 

Stanfield, Assistant Director, at (202) 512-3197 or stanfielda@gao.gov. 

Major contributors to this report are acknowledged in appendix II.

Linda Calbom 

Director, Financial Management 

and Assurance
Page 45 GAO-03-786 Forest Service Purchase Cards

Appendix I

Comments from the Forest Service AAppenednxidexiIs

Note: GAO comments 

supplementing those in 

the report text appear 

at the end of this 

appendix.

See comment 1.

See comment 2.
Appendix I

Comments from the Forest Service

Page 46 GAO-03-786 Forest Service Purchase Cards
Appendix I

Comments from the Forest Service

Page 47 GAO-03-786 Forest Service Purchase Cards

See comment 3.

See comment 4.

See comment 5.

See comment 6.
Appendix I

Comments from the Forest Service

Page 48 GAO-03-786 Forest Service Purchase Cards
Appendix I

Comments from the Forest Service

Page 49 GAO-03-786 Forest Service Purchase Cards

The following are GAO’s comments on the Forest Service’s letter dated 

July 7, 2003.

GAO Comments 1. We received summary documentation for the number of cardholders 

from USDA’s Office of Procurement and Property Management and the 

Forest Service that supported approximately 14,000 and 11,000 

cardholders respectively. Since USDA’s Office of Procurement and 

Property Management is responsible for the oversight of the purchase 

card program for all of USDA’s agencies, we used the number of 

cardholders that they provided for fiscal year 2001 in our report. 

2. Discussed in the “Agency Comments and Our Evaluation” section of the 

report.

3. Of the 29 split purchases identified in the draft report provided to 

Forest Service for comment, 4 were made by cardholders who were 

also warranted employees, employees who can enter into, administer, 

or terminate contracts to the extent of the authority delegated to them. 

The contracting authority limit for a warranted Forest Service 

employee is separate and distinct from the single transaction limit for 

purchase card transactions. The Forest Service response stated that 

USDA regulations allowed a single purchase limit of $2 million or the 

cardholder’s warrant level. According to USDA purchase card 

regulations, warranted cardholders may conduct transactions up to the 

lesser of their purchase card single transaction limit or warrant 

authority. For all 4 purchases mentioned above, the total invoice 

amounts exceeded the single transaction limits of the cardholders. 

Therefore, the cardholders violated USDA regulations by splitting the 

invoice amount into separate purchase card transactions to circumvent 

their single transaction limits. Further, the Forest Service requires that 

cardholders submit requisition forms for all purchases exceeding 

$2,500, to ensure that they are properly reviewed and approved. 

However, requisition forms were not submitted by the cardholders for 

these 4 purchases, violating policies and procedures. In addition, none 

of the 29 split purchases identified in our report reflected transactions 

with GSA Advantage.

4. As stated in our report, the Forest Service was unable to provide us 

with documentation to support the appropriateness of $39,240 of the 

$43,625 in transactions that appeared to have occurred after the 

cardholders left the Forest Service. The Forest Service confirmed the 
Appendix I

Comments from the Forest Service

Page 50 GAO-03-786 Forest Service Purchase Cards

remaining $4,385 as having been charged after the cardholder left the 

agency.

5. As part of our review, we tested compliance with existing Forest 

Service policies and procedures that were meant to prevent or detect 

improper payments, including the policy that cardholders are 

prohibited from writing checks to themselves. We identified 23 

transactions that were in clear violation of this policy, indicating that 

this control was not functioning effectively. Although the purchases 

related to these particular transactions were not determined to be 

improper, this control weakness leaves the Forest Service vulnerable to 

improper purchases. The Forest Service’s internal control plan 

supports eliminating the use of convenience checks for non-emergency 

purchases, as well as other measures that should reduce the risk of 

improper use of convenience checks. However, as these steps have not 

yet been fully implemented, we are unable to assess their effectiveness.

6. The original requests for supporting documentation were made 

between June 20 and July 26, 2002. We asked the Forest Service to 

provide documentation on the last request by August 16, 2002. 

Subsequently, we extended the deadline until November 30, 2002, more 

than four months after our last request for information. In a status 

meeting held December 4, 2002, we informed OPPM and Forest Service 

officials that we had not received any supporting documentation for 

327 transactions included in our requests and that these transactions 

would be categorized as questionable transactions in our report. We 

explained that continuing to accept this documentation would require 

us to significantly delay issuance of our report due to the time required 

to adequately review and assess any new documentation. OPPM and 

Forest Service officials both concurred with our position. Subsequently, 

the Forest Service offered to provide us with supporting 

documentation for 200 of the 327 transactions and we declined per the 

agreement reached during the December meeting. 
Page 51 GAO-03-786 Forest Service Purchase Cards

Appendix II

GAO Contacts and Staff Acknowledgments ApendxiI

GAO Contacts Linda Calbom, (202) 512-8341

Alana Stanfield, (202) 512-3197

Acknowledgments In addition to those named above, the following individuals made 

important contributions to this report: William Brown, Sharon Byrd, Cary 

Chappell, Lisa Crye, Francis Dymond, Jeffrey Jacobson, Jason Strange, and 

Ed Tanaka.

(190053)
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