Report to the Chairman, Subcommittee

on Aviation, Committee on

Transportation and Infrastructure,

House of Representatives

United States General Accounting Office

GAO

October 2002 AIR TRAFFIC

CONTROL

Impact of Revised

Personnel Relocation

Policies Is Uncertain

GAO-03-141
Page i GAO-03-141 Air Traffic Control

Letter 1

Results in Brief 2

Background 4

Eligibility Policies Are the Same for Air Traffic Controllers and

Managers, but Funding Policies Differ 7

Air Traffic Controllers Were Less Likely than Managers to Receive

Funding for PCS Moves 7

Possible Impacts of FAA’s New PCS Policies 10

Agency Comments and Our Evaluation 13

Appendix I Details on GAO’s Data Analyses 14

Appendix II GAO Contact and Staff Acknowledgments 15

GAO Contact 15

Acknowledgments 15

Figures

Figure 1: Funding of Managers’ and Controllers’ PCS Moves for

Promotions between Field Facilities, Fiscal Years 1999-

2001 8

Figure 2: Funding of Managers’ and Controllers’ PCS Lateral Moves

between Field Facilities, Fiscal Years 1999-2001 9

Figure 3: Air Traffic Services Annual PCS Costs, Fiscal Years 1996-

2001 11

Abbreviations

FAA Federal Aviation Administration

NATCA National Air Traffic Controllers Association

PCS Permanent Change of Station

Contents
Page 1 GAO-03-141 Air Traffic Control

October 31, 2002

The Honorable John L. Mica

Chairman, Subcommittee on Aviation

Committee on Transportation

 and Infrastructure

House of Representatives

Dear Mr. Chairman:

In fiscal year 2001, the Federal Aviation Administration (FAA) spent more

than $15 million to move air traffic controllers (who are responsible for

controlling the takeoff, landing, and ground movement of planes) and their

managers (who oversee and administer the air traffic control program) to

new permanent duty locations. FAA classifies the funds that it spends for

these moves as permanent change of station (PCS) benefits. In 1998, as

part of a broader effort to reform its personnel policies, FAA changed its

policies on PCS benefits. Instead of fully reimbursing the costs of all PCS

moves and prohibiting unfunded PCS moves, as it once did, FAA now

determines the amount of PCS benefits to be offered on a position-byposition basis. Under its new policies, FAA can fully reimburse the costs of

a move if it determines that the move is in the interest of the government,

or it can offer partial (fixed) relocation benefits if it determines that the

agency will derive some benefit from the move. Under the new policy,

employees and managers can now also move at their own expense. We

examined the impact of these changes in PCS policies on FAA’s Air Traffic

Services organization as part of our ongoing work for you on the impact of

FAA’s 1996 personnel reforms. As agreed with your office, we researched

three questions:

• How do FAA’s policies on eligibility for, and the amount of, PCS benefits

differ for air traffic controllers and their managers?

• How did the likelihood of being offered PCS benefits differ for controllers

and managers?

• What has been the impact of PCS policies on Air Traffic Services’ annual

PCS costs and its ability to staff vacant positions?

To address these questions, we obtained and analyzed information on

trends since fiscal year 1996 in PCS policies and funding for air traffic

controllers and air traffic managers. We also analyzed data on the type of

United States General Accounting Office

Washington, DC 20548
Page 2 GAO-03-141 Air Traffic Control

funding for, and purpose of, controllers’ and managers’ PCS moves

between field offices from 1999 through 2001. We also examined available

information regarding moves other than those between field offices. See

appendix I for details about our data analyses. We also met with

representatives of Air Traffic Services and FAA’s Conference Managers

Association to discuss the impact of FAA’s PCS policies. We conducted

our review from March 2002 through August 2002 in accordance with

generally accepted government auditing standards.

FAA’s policies on eligibility for PCS benefits are the same for air traffic

controllers and their managers, but the amounts of the benefits vary.

According to these policies, eligibility depends on a determining official’s

decision about how critical a position is and/or whether FAA will benefit

from the move. Depending on this determination, FAA may fully reimburse

the costs of a move, offer a fixed amount of relocation benefits, or provide

no relocation benefits. Under a memorandum of understanding between

the National Air Traffic Controllers Association (NATCA) and FAA,

controllers can receive a larger fixed relocation payment than managers.

For all moves where fixed relocation payments are provided to

controllers, they receive a payment of $27,000, whereas the amounts of the

fixed relocation payments for managers and other nonunion employees

are determined on a case-by-case basis up to $25,000. The average fixed

relocation payment for managers’ moves between field offices (based on

FAA estimates) was about $19,500 from 1999 through 2001.

Air traffic controllers have been less likely than air traffic managers to be

offered PCS benefits when they move between facilities. Our analysis of

data on moves between field facilities in fiscal years 1999 through 2001

(comprising 1,639 of 2,107, or almost 80 percent of all Air Traffic PCS

moves) showed that Air Traffic Services funded 16 percent of moves

involving a promotion (123 of 774) and 6 percent of lateral moves between

field facilities for controllers (14 of 250), compared with 38 percent of

promotional moves (34 of 90) and 34 percent of lateral moves (14 of 41)

for managers. For other moves (for example, from regional offices to field

facilities or headquarters to regional offices), Air Traffic Services funded 9

percent for controllers (25 of 275 moves), compared with 47 percent for

managers (91 of 193 moves). Although controllers make up about 77

percent of the combined workforce, they are to get 65 percent of available

Air Traffic PCS funding according to a February 2000 Memorandum of

Understanding between FAA and NATCA. Air Traffic Services officials

said that the relatively small number of managers who moved, combined

Results in Brief
Page 3 GAO-03-141 Air Traffic Control

with the fixed allotment of total PCS funding, led to the difference

between managers and controllers in the likelihood for PCS funding.

According to FAA officials, PCS costs have decreased and FAA’s ability to

quickly fill vacant controller positions has improved since the new PCS

policies took effect. Data show that Air Traffic Services’ PCS annual costs

decreased in 1998 when FAA began implementing its new PCS policies—

for example, from $31.8 million in fiscal year 1997 to $17.5 million in fiscal

year 19981

—but FAA does not have the data to determine to what extent

the annual decreases are attributable to the new PCS policies. Lacking the

requisite data, FAA has attributed the reduction to decreases in the

agency’s budget rather than to the new PCS policies. Air Traffic Services’

officials have attributed improvements in FAA’s ability to quickly fill

vacant controller positions at field facilities to broader flexibilities

provided by the new PCS policies, but again, they lacked the data to

support their views. On the other hand, FAA’s Conference Managers

Association has expressed concern that the changes in PCS policies may

result in unintended consequences in filling vacant positions. Specifically,

the Association has suggested that these changes may reduce the pool of

applicants (because fewer applicants may be willing to fund part or all of

their moves), thereby, potentially affecting the qualifications and diversity

of applicants for promotions. Moreover, according to the Association, PCS

benefits paid to fill comparable positions could vary from year to year with

changes in budget funding levels. However, the Association said that there

were no data to determine whether these negative effects have occurred.

Air Traffic Services officials said they were reviewing the concerns

identified by the Association and planned to comment in the near future.

Officials from FAA’s Office of Human Resources said they had agencywide

plans to begin collecting information on the time to fill positions and

survey new recruits on, among other things, the reasons they applied for

the position into which they were hired. This information could help FAA

determine the effects of its new PCS policies. Our ongoing work examines

the extent to which FAA has gathered data to determine the impact of its

personnel reform.

 1

Adjusted for inflation to constant 2001 dollars.
Page 4 GAO-03-141 Air Traffic Control

FAA currently employs almost 20,000 employees to operate and manage

the nation’s air traffic control system.2

 Most of these employees (about

15,250) are air traffic control specialists, or controllers, who are

responsible for controlling the takeoff, landing, and ground movement of

planes and are assigned to field facilities.3 (NATCA represents these

controllers.) In addition, about 4,500 managers, supervisors, and staff

specialists within FAA’s Air Traffic Services work to oversee and

administer the air traffic control program. (About 3,900 of these 4,500

managers, supervisors, and specialists work in the various field facilities

around the country and the other 600 provide management, direction, and

oversight, as well as overall support, of the air traffic control system at

headquarters and regional locations.) For this report, we focused our

analysis on these two groups in FAA’s occupational job series 2152, which

we refer to as controllers and managers, respectively.

In 1994, Congress directed the Secretary of Transportation to undertake a

study of management, regulatory, and legislative reforms that would

enable FAA to provide better air traffic control services.4

 FAA’s resulting

1995 report to Congress stated that existing federal personnel rules and

procedures limited FAA’s ability to attract and retain qualified staff at key

facilities or to reassign employees in response to changing needs. The

report also stated that exemption from federal personnel regulations

would provide FAA with the flexibility to hire, reward, and relocate

employees to better manage the air traffic control system.5

 On November

15, 1995, Congress directed the FAA Administrator to develop and

implement a new personnel management system to provide greater

flexibility in the hiring, training, compensation, and location of personnel.

The 1996 Department of Transportation Appropriations Act exempted

FAA from most provisions of title 5 of the United States Code and other

 2

The Office of Personnel Management classifies civilian air traffic controllers in FAA as

occupational series 2152—civilian air traffic controller. In addition to these employees,

there are about 2,800 flight service station controllers who do not directly control or

separate air traffic but provide pilot briefings, weather reports and emergency services to

pilots before and during flights.

3

Field facilities include FAA towers, terminal radar approach controls, and en route

centers.

4

Pub. L. No. 103-260, 108 Stat. 698 (1994).

5

See Federal Aviation Administration, Background Paper: Personnel Management Reform

for the Federal Aviation Administration, (Washington, D.C.: August 1995).

Background
Page 5 GAO-03-141 Air Traffic Control

federal personnel laws.6 On April 1, 1996, FAA introduced a set of new

personnel policies and procedures that included, among other things,

personnel reforms for locating its workforce more effectively.

Controllers and managers may make PCS moves for promotions,7

downgrades,8 or lateral transfers. To be eligible for promotion within the

controller or manager ranks or from controller to manager, individuals

may be required to make a PCS move. For example, promotion for a

controller may require making a PCS move to a higher-level facility (i.e.,

one with higher levels of operational complexity).9

 Promotion for a

manager may require gaining greater experience with more complex and

diverse air traffic operations. This may involve a PCS move to a regional

office or FAA headquarters for policy and management experience.10 To be

eligible for promotion from controller to manager, an individual may have

to move to a lower-level facility where supervisory positions are available,

to a regional office, or to FAA headquarters. Downgrades and lateral

transfers are generally made for personal reasons but may also benefit the

government.

Under title 5 rules, federal agencies may elect to pay for the expenses of

transportation of immediate family and of household goods and personal

effects to and from the assignment location for a PCS move when it is in

the interest of the federal government.11 According to FAA Air Traffic

Services and Human Resources officials, FAA historically interpreted title

 6

Congress did not exempt FAA from provisions of title 5 pertaining to veterans’ preference;

antidiscrimination; retirement, unemployment and insurance coverage; and limitations on

the right to strike.

7

FAA defines promotion as the movement of an employee to a higher grade or pay band.

8

FAA defines a downgrade as a reduction in grade or pay level, which may be either

voluntary (through assignment to a different position at a lower grade or pay level) or

involuntary (through reclassification or reevaluation of the duties and responsibilities of a

position).

9

FAA’s pay system for air traffic controllers classifies each air traffic control facility into air

traffic control grades with corresponding pay bands based on numerous factors, including

the level of air traffic and complexity of operations at each location. Under this pay system,

increasing levels of pay are associated with increasing levels of air traffic and more

complex operations.

10Federal Aviation Personnel Manual Letter 330-4, SUBJ: Merit Promotion Program,

Appendix 9, “Air Traffic Competitive Career Progression Plan,” effective October 1, 1985.

115 U.S.C. sec. 5724a.
Page 6 GAO-03-141 Air Traffic Control

5 rules as a requirement to fully reimburse all PCS moves, since FAA

considered all such moves to be in the interest of the government. As part

of its personnel reform, FAA delegated the authority to determine

eligibility for and the amount of PCS benefits to each line of business12 and

provided three PCS funding options: (1) full PCS reimbursement, (2) fixed

relocation payments, and (3) unfunded moves. If the move is determined

to be in the interest of the government, FAA will fully reimburse the

individual for costs associated with the move.13 According to FAA, the

average agencywide PCS cost for fully reimbursed PCS moves in fiscal

year 2001 was about $54,000 (based on a sample of 100 fully funded PCS

moves in that fiscal year.)

Under its personnel reform, FAA may offer a fixed relocation payment if it

determines that the agency will derive some benefit from a move, even

though the move is not in the interest of the government.14 For example,

Air Traffic Services may offer a fixed relocation payment as a recruitment

tool, when necessary, to attract enough qualified candidates for a

position.15

If a move is not in the interest of the government and FAA does not

determine that it will derive some benefit from the move, there is no basis

for offering PCS funding. However, as a result of FAA’s personnel reforms,

employees may choose to make unfunded moves at their own expense for

personal reasons, to gain experience needed for professional

advancement, or for promotion. Before 1996, when FAA’s policy did not

allow unfunded moves, many vacancies went unfilled for lack of PCS

funds, according to FAA’s Personnel Reform Executive Committee Task

Force Report. The intent of the change in policy was to (1) improve

employee morale by allowing willing employees to relocate and (2) allow

 12FAA is organized along five lines of business: Airports, Commercial Space Transportation,

Research & Acquisition, Regulation & Certification, and Air Traffic Services.

13Reimbursable expenses include those related to the employee’s home sale and purchase,

travel, and shipment of household goods and may include those for house hunting trips,

subsistence in temporary quarters, and transportation of a privately owned vehicle;

reimbursements are taxable.

14Employees receiving fixed relocation payments do not have to account for moving

expenses and must pay income taxes on the fixed amount received.

15According to Air Traffic Services policy, determining officials state on the vacancy

announcement the type of PCS benefits—full reimbursement or fixed relocation—to be

offered.
Page 7 GAO-03-141 Air Traffic Control

FAA to relocate more employees without increasing the PCS budget. In

February 2000, FAA signed a memorandum of understanding with NATCA

that allowed FAA to offer controllers unfunded PCS moves to higher-level

facilities.16 These moves to higher-level facilities are considered

promotions because controllers’ pay increases with the level of the facility.

FAA’s policies on eligibility for PCS reimbursement, created as a result of

FAA’s 1996 personnel reform and implemented for air traffic controllers in

the agency’s February 2000 memorandum of understanding with NATCA,

do not differentiate between air traffic controllers and managers.

However, the amount of the fixed relocation payment that Air Traffic

Services may offer controllers and managers for PCS moves does differ.

The February 2000 memorandum of understanding established a fixed

relocation payment of $27,000 for controllers as a result of negotiations

between FAA management and NATCA. This amount is set for all fixed

relocation payments provided to controllers. Conversely, the amounts of

fixed relocation payments for air traffic control managers are determined

on a case-by-case basis up to a maximum of $25,000. The average PCS

fixed relocation payment for managers’ moves between field offices during

fiscal years 1999 through 2001 (based on FAA estimates) was about

$19,500.17

Air traffic controllers were less likely than air traffic managers to receive

funding for their moving expenses when moving between facilities.

According to Air Traffic Services data, controllers and managers made

1,466 and 173 PCS moves, respectively, between field facilities from fiscal

year 1999 through fiscal year 2001; these moves comprise 78 percent of all

2,107 Air Traffic PCS moves.18 About half of those moves (864) were for

promotions. As shown in figure 1, 84 percent of controllers’ PCS moves

between field facilities for promotions (651 of 774) were unfunded during

 16The February 2000 memorandum of understanding was a supplemental, midterm

agreement to FAA’s 1998 contract with NATCA.

17Based on estimated costs submitted by FAA regions for all 41 reported fixed relocation

payment PCS moves between field facilities from fiscal year 1999 through fiscal year 2001.

Estimates in the database were not updated to reflect actual costs.

18Data on the funding alternatives for PCS moves were available only for moves between

field facilities for fiscal years 1999 through 2001.

Eligibility Policies Are

the Same for Air

Traffic Controllers

and Managers, but

Funding Policies

Differ

Air Traffic Controllers

Were Less Likely than

Managers to Receive

Funding for PCS

Moves
Page 8 GAO-03-141 Air Traffic Control

fiscal years 1999 through 2001, while 62 percent of managers’ PCS moves

for promotions (56 of 90) were unfunded.

Figure 1: Funding of Managers’ and Controllers’ PCS Moves for Promotions

between Field Facilities, Fiscal Years 1999-2001

Source: GAO’s analysis of data provided by FAA.

Similarly, controllers were less likely than managers to receive funding for

lateral moves. From fiscal year 1999 through fiscal year 2001, controllers

and managers made 291 PCS moves for lateral assignment between field

facilities. As shown in figure 2, 94 percent of controllers’ lateral moves

(236 of 250) were unfunded, compared with 66 percent of managers’

lateral moves (27 of 41).
Page 9 GAO-03-141 Air Traffic Control

Figure 2: Funding of Managers’ and Controllers’ PCS Lateral Moves between Field

Facilities, Fiscal Years 1999-2001

Source: GAO’s analysis of data provided by FAA.

Data were not available on the type of funding alternatives used for other

PCS moves (from headquarters to the field, for example, and from regional

offices to headquarters). However, data on whether any type of funding

was provided for these other moves indicated that 91 percent of those by

controllers were unfunded during fiscal years 1999 through 2001 (250 of

275), compared with 53 percent of those by managers (102 of 193).

According to the February 2000 memorandum of understanding between

FAA and NATCA, 65 percent of PCS funding is to be allocated to

controllers and 35 percent to the rest of air traffic staff. Thus, while they

account for 77 percent of the combined workforce, controllers get a

smaller proportion—65 percent—of air traffic PCS funding. FAA officials

said that this resulted in a higher percentage of managers who received

funding for PCS moves.
Page 10 GAO-03-141 Air Traffic Control

Although managers were more likely than controllers to receive funding

for PCS moves for promotion in the field, they were less likely to make

PCS moves between field locations for promotions. From fiscal year 1999

through fiscal year 2001, about 2 percent of the total population of

managers (4,490) made promotional moves between field facilities,

compared with about 5 percent of the controller workforce (15,248).

Lateral and downgrade moves between field facilities during the same

period accounted for less than 3 percent of managers’ and controllers’

respective workforces. For other PCS moves (between headquarters,

regional offices, and field facilities), managers (4 percent) were more

likely to make moves than controllers (2 percent).

Although FAA officials said that PCS costs have decreased and FAA’s

ability to quickly fill vacant controller positions has improved since the

new PCS policies took effect, they did not have the data to determine to

what extent the annual decreases or improvement in the agency’s ability to

fill vacancies in field facilities are attributable to the new PCS policies

implemented in 1998. For example, from fiscal year 1997, Air Traffic

Services’ PCS costs decreased from $31.8 million to $17.5 million in fiscal

year 1998 (see fig. 3).19 FAA has attributed these decreases to reductions in

its budget rather than to the new PCS policies providing fixed relocation

payments for PCS moves and allowing staff to pay for their own moves.

However, officials noted that they lacked data to support this

determination. FAA officials also said that the new PCS policies have

improved their ability to fill controller vacancies in field facilities, but

again, they lacked data to support their views. Officials from FAA’s Office

of Human Resources said they had agencywide plans to begin collecting

information on the time to fill positions and survey new recruits on, among

other things, the reasons they applied for the position into which they

were hired. This information should help FAA determine the impacts of its

PCS policies.

 19Adjusted for inflation to constant 2001 dollars.

Possible Impacts of

FAA’s New PCS

Policies
Page 11 GAO-03-141 Air Traffic Control

Figure 3: Air Traffic Services Annual PCS Costs, Fiscal Years 1996-2001

Note: Amounts adjusted for inflation to constant 2001 dollars.

Source: GAO’s presentation of data provided by FAA.

FAA also lacks data to respond to questions raised by the FAA Conference

Managers Association about the potential impacts of FAA’s new PCS

policies.20 In the Association’s view, the change from the determination

that a promotional opportunity is in the best interest of the government

(under title 5 rules) to a determination based on general criteria by each of

the lines of business that only some promotional opportunities are in the

best interest of the government (under rules revised as a part of personnel

reform) made the decision-making process too subjective. In March 2002,21

Association representatives expressed concern about the potential for

unintended effects of the change in FAA’s PCS policy including a

reduction in the number of qualified applicants that could weaken FAA’s

leadership and a reduction in the diversity of potential applicant pools that

could result in discrimination in filling positions. The Association also said

 20The Association represents about 1,700 FAA managers and supervisors.

21Federal Aviation Administration Conference Managers Association, Legislative Briefing

Book, 107th Congress, Second Session, March 2002.
Page 12 GAO-03-141 Air Traffic Control

that a disparate provision of PCS benefits due to funding concerns could

have a negative impact on morale.

According to the managers association, some qualified managers may be

reluctant to bid on opportunities for promotion because of the cost of

partially or fully funding their own PCS moves. (As was shown in fig. 1,

almost two-thirds of these moves for managers are unfunded.) The

Association was concerned that, because not all qualified potential

applicants may apply for promotions, less qualified managers may bid on

and be selected for promotion opportunities because they are willing to

make the financial commitment to pay for some or all of the costs

associated with a PCS move. The Association believes this outcome could

weaken the quality of FAA’s leadership.

Another Association concern is that selecting officials may be unable to

determine whether the pool of candidates who bid on unfunded PCS or

fixed-funded PCS positions is representative of FAA managers.

Specifically, the Association has suggested that this pool of candidates

may not be as diverse as the pool of candidates who would bid on a

position with a fully reimbursed PCS move. As a result, the Association

believes the new PCS policies may inadvertently lead to discrimination.

Finally, Association officials expressed concern that FAA’s

implementation of the variable PCS policy would be affected by

fluctuations in FAA’s budget. In their view, the effect of using PCS funding

to create an incentive for filling hard-to-staff positions (as is done under

the new policies) rather than to fully reimburse all PCS moves (as was

done under title 5 rules) was to reduce the funding for PCS moves. With

less PCS funding available, the officials said managers’ decisions to fund

PCS moves could be more sensitive to current funding issues than to

operational staffing needs. As a result, the Association said comparable

positions could be filled in different budget years at the same location

using different levels of PCS benefits. Thus, two managers could receive

disparate PCS benefits for essentially the same type of move.

The Association acknowledged that there were no data that showed these

unintended effects had occurred. Likewise, without information such as

the qualifications of employees and managers who applied for promotions

before and after the change in policies, the qualifications of those who did

not apply, and the funding for comparable positions over time, we could

not determine whether the potential unintended effects identified by the

Association had occurred. Air Traffic Services officials said they were still

reviewing the concerns and planned to comment in the near future.
Page 13 GAO-03-141 Air Traffic Control

We provided a copy of the draft report to Department of Transportation

and FAA officials who agreed with the contents of the report and provided

a technical clarification regarding our description of the allocation of PCS

funding under the 2000 Memorandum of Agreement between FAA and

NATCA. They did not provide written comments on the report.

As agreed with your office, unless you publicly announce the contents of

this report earlier, we plan no further distribution until 10 days from the

report date. At that time, we will send copies of this report to interested

congressional committees and to the Honorable Norman Y. Mineta,

Secretary of Transportation; the Honorable Marion Blakely, Administrator,

FAA; and the Honorable Mitchell E. Daniels, Jr., Director, Office of

Management and Budget. We also will make copies available to others

upon request. In addition, the report will be available at no charge on the

GAO Web site at http://www.gao.gov.

If you or your staff have any questions about this report or would like to

discuss it further, I can be reached at (202) 512-2834. Key contributors to

this report are acknowledged in appendix II.

Sincerely yours,

Gerald L. Dillingham, Ph.D.

Director, Physical Infrastructure

Agency Comments

and Our Evaluation
Appendix I: Details on GAO’s Data Analyses

Page 14 GAO-03-141 Air Traffic Control

We obtained and analyzed data on trends in funding for permanent change

of station (PCS) moves in the Federal Aviation Administration’s (FAA’s)

Air Traffic Services line of business (the FAA line of business for air traffic

controllers and air traffic managers) since fiscal year 1996 and analyzed

data on the type of funding (fully funded, fixed payments, or unfunded)

and purpose (promotion, lateral transfer, or downgrade) of controllers’

and managers’ PCS moves between field offices from 1999 through 2001,

the only years for which these data were available. The PCS moves

between field offices account for about 80 percent of all Air Traffic PCS

moves. The only information available for other moves (for example,

between headquarters and field offices or between regional offices and

headquarters) was the total number of moves and whether they were

funded or unfunded.

To assess the reliability of the data, we (1) discussed the data collection

methods with responsible agency staff and (2) reviewed the information

for reasonableness. We did not independently verify these data.

Appendix I: Details on GAO’s Data Analyses
Appendix II: GAO Contact and Staff

Acknowledgments

Page 15 GAO-03-141 Air Traffic Control

Gerald L. Dillingham, Ph.D. (202) 512-2834

In addition to the individual named above, Elizabeth Eisenstadt, Michele

Fejfar, David Hooper, Chris Keisling, and E. Jerry Seigler made key

contributions to this report.

Appendix II: GAO Contact and Staff

Acknowledgments

GAO Contact

Acknowledgments

(540029)
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