United States Government Accountability Office

GAO Testimony 

Before the Committee on Education and 

Labor, House of Representatives

RESIDENTIAL PROGRAMS

Selected Cases of Death, 

Abuse, and Deceptive 

Marketing 

Statement of Gregory D. Kutz, Managing Director 

Forensic Audits and Special Investigations 

For Release on Delivery

Expected at 10:00 a.m. EDT 

Thursday, April 24, 2008

 

GAO-08-713T 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

April 24, 2008

RESIDENTIAL PROGRAMS 

Selected Cases of Death, Abuse, and Deceptive 

Marketing 

Highlights of GAO-08-713T, a testimony 

before the Committee on Education and 

Labor, House of Representatives 

In October 2007, GAO testified 

before the Committee regarding 

allegations of abuse and death in 

private residential programs across 

the country such as wilderness 

therapy programs, boot camps, and 

boarding schools. GAO also

examined selected closed cases 

where a youth died while enrolled

in one of these private programs.

Many cite positive outcomes 

associated with specific types of 

residential programs. However, due 

to continuing concerns about the 

safety and well-being of youth 

enrolled in private programs, the 

Committee requested that GAO 

(1) identify and examine the facts 

and circumstances surrounding 

additional closed cases where a 

teenager died, was abused, or both, 

while enrolled in a private program; 

and (2) identify cases of deceptive 

marketing or questionable

practices in the private residential

program industry.

To develop case studies of death 

and abuse, GAO conducted 

numerous interviews and examined

documents from eight closed cases

from 1994 to 2006. GAO used 

covert testing along with other

investigative techniques to identify, 

for selected cases, deceptive

marketing or questionable

practices. Specifically, posing as 

fictitious parents with fictitious 

troubled teenagers, GAO called 14

programs and related services.

GAO did not attempt to evaluate 

the benefits of private residential 

programs and its results cannot be

projected beyond the specific 

programs and services that GAO 

reviewed. 

In the eight closed cases GAO examined, ineffective management and 

operating practices, in addition to untrained staff, contributed to the death 

and abuse of youth enrolled in selected programs. The practice of physical 

restraint also figured prominently in three of the cases. The restraint used for 

these cases primarily involved one or more staff members physically holding

down a youth. See the table below for detailed information related to three of 

the case studies. 

Examples of Case Studies GAO Examined

Sex/age Date of

death/abuse 

Case details

Male, 

14–18 

1994 to 1998 • Victim was restrained over 250 times while attending the program; 

in at least two cases, restraint lasted over 12 hours 

• One method of restraint included wrapping the victim in a blanket 

and tying him up

• Was required to attend the program for 4 years and was held 

against his will after his 18th birthday

Male, 16 Mar. 1998 • For several weeks, victim complained of chest pain and difficulty 

breathing 

• Staff forced him to do push-ups and carry cinder blocks as

punishment for refusing an assigned task 

• Victim died from an accumulation of infectious pus in his chest 

• Autopsy found more than 70 injuries on his body, including some

from blunt force 

Male, 16 Feb. 2006 • Three staff members held the victim facedown to restrain him 

• After 10 minutes of restraint, victim said he could not breathe and 

was eventually taken to the hospital 

• School was aware victim suffered from asthma, but staff members 

who restrained him said they were not 

• Victim died of abnormal heartbeat

Source: Records including police reports, legal documents, and state investigative documents. 

Posing as fictitious parents with fictitious troubled teenagers, GAO found 

examples of deceptive marketing and questionable practices in certain 

industry programs and services. For example, one Montana boarding school 

told GAO’s fictitious parents that their child must apply using an application 

form before they are admitted. But after a separate call, a program 

representative e-mailed an acceptance letter for GAO’s fictitious child even 

though an application was never submitted. In another example, the Web site 

for one referral service states: “We will look at your special situation and help 

you select the best school for your teen with individual attention.” However,

GAO called this service three times using three different scenarios related to 

different fictitious children, and each time the referral agent recommended a

Missouri boot camp. Investigative work revealed that the owner of the referral 

service is married to the owner of the boot camp. GAO also called a program 

established as a 501(c)(3) charity that advocated a potentially fraudulent tax 

scheme. The scheme involves the friends and family of a child making taxdeductible “donations” to the charity, which are then credited to an account in 

the program the child is enrolled in. GAO referred this charity to the Internal 

Revenue Service for criminal investigation. 

To view the full product, including the scope 

and methodology, click on GAO-08-713T. 

For more information, contact Gregory Kutz at 

(202) 512-6722 or kutzg@gao.gov. 
Mr. Chairman and Members of the Committee: 

Thank you for the opportunity to continue the discussion of private 

residential programs for troubled youth that we began last fall.1

 In the 

context of this and our prior testimony, we are using the term residential 

program to refer to those private entities across the country and abroad 

that call themselves wilderness therapy programs, therapeutic boarding 

schools, academies, behavioral modification facilities, ranches, and boot 

camps, among other names. Many of these programs are privately owned 

and operated. Private residential programs typically market their services 

to the parents of troubled teenagers—boys and girls with a variety of 

addiction, behavioral, and emotional problems—and provide a range of

services, including drug and alcohol treatment, confidence building, and

psychological counseling for illnesses such as depression and attention 

deficit disorder. Parents trying to help their troubled child may also seek 

help from referral services and educational consultants, which generally 

purport to assess the needs of the child and recommend an appropriate 

program. 

Many cite positive outcomes associated with specific types of residential 

programs. However, in our previous testimony, we identified thousands of 

allegations of abuse, some of which resulted in death, at residential 

programs across the country and in American-owned and Americanoperated facilities abroad. We also examined 10 closed civil or criminal 

cases where a teenager died while enrolled in a private program and found 

significant evidence of ineffective management in most of the 10 cases, 

with program leaders neglecting the needs of program participants and 

staff. This ineffective management compounded the negative 

consequences of (and sometimes directly resulted in) the hiring of 

untrained staff; a lack of adequate nourishment for enrolled children; and 

reckless or negligent operating practices, including a lack of adequate 

equipment. 

Due to your continuing concern about the safety and well-being of youth 

enrolled in private residential programs, and to assist the Committee in its 

consideration of the need for federal legislation in this area, you requested 

that we (1) identify and examine the facts and circumstances surrounding 

additional closed cases where a teenager died, was abused, or both, while 

 1

GAO, Residential Treatment Programs: Concerns Regarding Abuse and Death in

Certain Programs for Troubled Youth, GAO-08-146T (Washington, D.C.: Oct. 10, 2007). 

Page 1 GAO-08-713T 
enrolled in a private program; and (2) identify cases of deceptive 

marketing or other questionable practices in the private residential 

program industry. 

To identify case studies, we reviewed numerous closed criminal or civil 

cases in which a court or state agency was asked to decide whether a 

private residential program was responsible for the death or abuse of an 

enrolled teenager. We also reviewed administrative cases where state 

agencies made rulings regarding the death or abuse of a teenager. When 

identifying cases, we specifically excluded public programs such as statesponsored foster programs, juvenile justice programs for delinquent youth, 

or programs that exclusively treat psychological disorders or substance 

abuse in a hospital setting. We also excluded cases related to the programs 

we examined for our October 10, 2007, testimony. We focused on deaths 

or instances of abuse between the years 1994 and 2006 to illustrate the 

long-standing issues presented by private residential programs. We limited 

our cases to closed criminal cases and, thus, did not include ongoing cases 

from the last several years. We selected eight cases—four cases of death 

and four cases of abuse—based on several factors including the victim’s 

age, the program location, the type of program the victim attended, and

the date of death or abuse. We then examined, in more detail, the facts and 

circumstances of the case. To validate the facts and circumstances, and to

the extent possible, we conducted interviews with related parties, 

including current and former program staff and officials, attorneys and law 

enforcement officials involved in the cases, and the parents of the victims. 

Further, we reviewed available documentation to support the facts of each 

case including, but not limited to, marketing materials, police reports, 

autopsy reports, and state agency oversight reviews and investigations. 

To identify cases of deceptive marketing or other questionable practices in

the private residential program industry, we used a variety of approaches 

and investigative techniques. Posing as fictitious parents with fictitious 

troubled children, our undercover investigators made telephone calls to a 

nonrepresentative selection of 10 private residential programs and 4 

referral services. Like legitimate parents with troubled teenagers, we 

identified these programs and referral services through Internet searches 

and magazine advertisements. To assess the accuracy and reasonableness 

of the information we obtained during each undercover call, we performed 

additional follow-up work that included, but was not limited to, making 

additional undercover calls; comparing the information we received with 

other marketing information provided by the program; reviewing relevant 

laws, regulations, and trade organization statements; performing 

announced, agreed upon site visits (i.e., not undercover); and speaking 

Page 2 GAO-08-713T 
with cognizant state and federal officials, including the Internal Revenue

Service (IRS). 

We performed our work from November 2007 through April 2008 in 

accordance with the quality standards for investigations set forth by the 

President’s Council on Integrity and Efficiency. As we noted in our prior 

testimony, it is important to emphasize that residential programs are 

intended to help youth with serious problems, including life-threatening 

addictions and diseases. We did not attempt to evaluate the benefits of 

residential programs in dealing with these serious problems. In addition, it

is not possible to generalize the results of our investigation as applying to 

all residential programs, whether privately or publicly funded, or referral 

services and educational consultants and others in the residential program 

industry. Moreover, it is difficult to develop a picture of the overall 

industry, its practices, and efforts to oversee it. For example, while states 

often regulate publicly funded programs, a number of states do not license 

or otherwise regulate certain types of private programs. GAO is 

completing a more comprehensive review of state and federal oversight of

residential programs and expects to issue a report soon. 

In the eight closed cases we examined, ineffective management and 

operating practices, in addition to untrained staff, contributed to the death 

and abuse of youth enrolled in selected programs. In the most egregious 

cases of death and abuse, the cases exposed problems with the entire 

operation of the program. The practice of physical restraint also figured 

prominently in three of the cases. The restraint used for these cases 

primarily involved one or more staff members physically holding down a 

youth. Examples of some case studies follow: 

Summary of 

Investigation 

• A 16 year-old male who suffered from asthma and chronic bronchitis 

complained of chest pain and had difficulty breathing for several 

weeks. Staff at the Arizona boot camp he was attending punished him 

for refusing to do an assigned task and forced him to do push-ups and 

carry cinder blocks; meanwhile, a program nurse told him the 

breathing problems were “in your head.” In March 1998, the victim died 

from an accumulation of infectious pus in his chest, and an autopsy 

found more than 70 injuries, including blunt-force injuries, on his 

body—indicating he had been physically abused before his death. 

• A teenage male was required to attend a behavior modification 

program in New Jersey for 4 years, and was held against his will after 

he turned 18. Records show that the victim was restrained more than 

Page 3 GAO-08-713T 
250 times while attending the program. Incident reports filed by 

program staff document that after he had turned 18, the victim was 

restrained on 26 separate days, with at least two restraints lasting more 

than 12 hours. Restraints were imposed any time he showed reluctance 

to participate in the program, and for other reasons; on one occasion, 

he said he was wrapped in a blanket and tied up after attempting to 

escape the program. 

• In February 2006, a 16-year-old male with a history of asthma became 

unresponsive while being restrained at a Pennsylvania treatment 

facility. He died 3 hours later in a hospital. An investigation into the 

death found that the facility had documentation of the victim’s history 

of asthma, and that its training manual for restraint procedures 

cautioned against the risk of decreased oxygen intake during restraints 

for youth with asthma. However, all three staff members involved in 

the restraint that led to the victim’s death told investigators that they 

were unaware of any medical conditions that needed to be considered 

when restraining the victim. 

In three of the eight cases we examined, the victim was placed in the 

program by the state or in consultation with state authorities.

Posing as fictitious parents with fictitious troubled teenagers, we also 

found examples of deceptive marketing and questionable practices in the 

private residential program industry. Deceptive marketing included 

potential fraud, false statements, and misleading representations related to

a range of issues including tax deductions, education, and admissions 

policies. We also found undisclosed conflicts of interest. Examples of 

deceptive marketing included the following: 

• One Montana boarding school told us that parents must submit an 

application form in order for their child to be considered for admission 

in the program. However, after a separate call by a fictitious parent, a 

program representative e-mailed us that our fictitious daughter had 

been approved for admission into the program and subsequently sent 

an acceptance letter. This acceptance into the school was based on a 

30-minute telephone conversation. We did not fill out any application 

form. 

• The Web site for one referral service we called says: “We will look at 

your special situation and help you select the best school for your teen 

with individual attention.” However, we called this service three times 

using three different scenarios related to different fictitious children, 

and each time the referral agent recommended a Missouri boot camp. 

Page 4 GAO-08-713T 
Investigative work revealed that the owner of the referral service is 

married to the owner of the boot camp, but this relationship was never 

disclosed during the call, raising the issue of conflict of interest. 

• The representative for a 501(c)(3) foundation suggested our fictitious 

parents take advantage of a fund-raising approach that is potentially a 

fraudulent tax scheme. The representative said that this “popular” 

option would allow friends, family, business acquaintances, churches, 

and other organizations to make tax-deductible donations that would 

then be credited to our fictitious child’s tuition in a private program. 

After we briefed an IRS official on the representation by this 

foundation, he told us that the foundation is potentially committing tax 

fraud and that those who obtain tax benefits for donations in the 

suggested manner may be responsible for back taxes, as well as 

penalties and interest. 

A link to selected audio clips from these calls is available at:

http://www.gao.gov/media/video/gao-08-713t/ 

Since the early 1990s, state agencies and private companies have set up

hundreds of residential programs and facilities in the United States. Many 

of these programs are intended to provide a less restrictive alternative to 

incarceration or hospitalization for youth who may require intervention to

address emotional or behavioral challenges. A wide array of government 

or private entities, including government agencies and faith-based 

organizations, operate these programs. Some residential programs 

advertise themselves as focusing on a specific client type, such as those 

with substance abuse disorders or suicidal tendencies. 

Background 

As we reported in our October 2007 testimony, no federal laws define what 

constitutes a residential program, nor are there any standard, commonly 

recognized definitions for specific types of programs. For our purposes, 

we define programs based on the characteristics we have identified during 

our work. For example:

• Wilderness therapy programs place youth in different natural 

environments, including forests, mountains, and deserts. According to 

wilderness therapy program material, these settings are intended to 

remove the “distractions” and “temptations” of modern life from teens, 

forcing them to focus on themselves and their relationships. These 

programs are typically 28 days in length at a minimum, but parents can 

continue to enroll their child for longer at an additional cost. 

Page 5 GAO-08-713T 
• Boot camps are residential programs in which strict discipline and 

regime are dominant principles. Many boot camps emphasize 

behavioral modification elements, and some military-style boot camps 

also emphasize uniformity and austere living conditions. Boot camps 

might be included as part of a wilderness therapy school or therapeutic 

boarding, but many boot camps exist independently. These programs 

are offered year-round and some summer programs last up to 3 

months. 

• Boarding schools (also called academies) are generally advertised as 

providing academic education beyond the survival skills a wilderness 

therapy program might teach. These programs frequently enroll youth 

whose parents force them to attend against their will. The schools can 

include fences and other security measures to ensure that youth do not 

leave without permission. While these programs advertise year-round 

education, the length of stay varies for each student; contracts can 

require stays of up to 21 months or more. 

• Ranch programs typically emphasize remoteness and large, open 

spaces available on program property. Many ranch programs advertise 

the therapeutic value of ranch-related work. These programs also 

generally provide an opportunity for youth to help care for horses and 

other animals. Although we could not determine the length of a typical 

stay at ranch programs, they operate year-round and take students for 

as long as 18 months. 

See appendix I for further information about the location of various types 

of residential programs across the United States. In addition to these 

programs, the industry includes a variety of ancillary services. These 

include referral services and educational consultants to assist parents in 

selecting a program, along with transport services to pick up a youth and 

bring him or her to the program location. Parents frequently use a 

transport service if their child is unwilling to attend the program. 

Private programs generally charge high tuition costs. For example, one 

wilderness program stated that their program costs over $13,000 for 28

days. In addition to tuition costs, these programs frequently charge 

additional fees for enrollment, uniforms, medical care, supplemental 

therapy, and other services—all of which vary by program and can add up

to thousands of extra dollars. Costs for ancillary services vary. The cost 

for transport services depends on a number of factors, including distance 

traveled and the means of transportation. Referral services do not charge

parents fees, but educational consultants do and typically charge 

Page 6 GAO-08-713T 
thousands of dollars. Financial and loan services are also available to 

assist parents in covering the expense of residential programs and are 

often advertised by programs and referral services. See appendix II for 

further information about the cost of residential programs across the 

United States. 

There are no federal oversight laws—including reporting requirements—

pertaining specifically to private residential programs, referral services, 

educational consultants, or transportation services, with one limited 

exception. The U.S. Department of Health and Human Services oversees 

psychiatric residential treatment facilities (PRTFs) receiving Medicaid 

funds. In order to be eligible to receive funds under Medicaid, PRTFs must 

abide by regulations that govern the use of restraint and seclusion 

techniques on patients. They are also required to report serious incidents 

to both state Medicaid agencies and, unless prohibited by state law, state 

Protection and Advocacy agencies. In addition, the regulations require 

PRTFs to report patient deaths to the Centers for Medicare and Medicaid

Services Regional Office.

2

In the eight closed cases we examined, ineffective management and 

operating practices, in addition to untrained staff, contributed to the death 

and abuse of youth enrolled in selected programs. Furthermore, two cases 

of death were very similar to cases from our October 2007 testimony, in 

that staff ignored the serious medical complaints of youth until it was too 

late. The practice of physical restraint figured prominently in three of the 

cases. The restraint used for these cases primarily involved one or more 

staff members physically holding down a youth. Ineffective operating 

practices led to the most egregious cases of death and abuse, as the cases

exposed problems with the entire operation of the program. Specifically, 

the failure of program leaders to ensure that appropriate policies and 

procedures were in place to deal with the serious problems of youth; 

ineffective management practices that led to questionable therapeutic or

operational practices; and the failure of the program to share information 

about enrolled youth with the staff members who were attending to them 

created the environments that resulted in abuse and death. Moreover, in 

cases involving abuse, the abuse was systemic in the program and not 

limited to the incident discussed in our case studies. In three of the eight 

Cases of Death and 

Abuse at Selected 

Residential Programs 

 2

42 C.F.R. §§ 483.350 - .376. 

Page 7 GAO-08-713T 
cases we examined, the victim was placed in the program by the state or in

consultation with state authorities.3

See table 1 for a summary of the cases of death we examined.

Table 1: Summary of Eight Closed Cases (Four Deaths) 

Case 

Victim 

information

Program 

Attended 

Date 

of death 

Cause 

of death Case details 

1 Male, 16,

California 

resident 

Arizona boot 

camp 

March 1998 Empyema 

(accumulation of 

infectious pus in the 

chest) 

• Victim suffered from asthma and chronic 

bronchitis 

• For a period of several weeks, victim 

complained of chest pain and difficulty 

breathing, but a program nurse said that his 

breathing problems were in his head 

• Staff punished him for refusing an assigned 

task, and forced him to do push-ups and 

carry cinder blocks 

• Victim eventually became unresponsive, at 

which point staff finally realized that his 

condition required medical attention 

• Victim was declared dead at a hospital

• Autopsy found more than 70 injuries, 

including some from blunt force, on his 

body, indicating that the victim had been 

physically abused before his death 

2 Male, 14, Texas 

resident 

Texas wilderness 

therapy program

Sept. 2004 Cardiopulmonary 

Arrest 

• Victim’s hiking group became lost and spent 

several unforeseen hours in temperatures 

that reached 98 degrees (a reported heat 

index of near 105 degrees) 

• During the hike, victim stopped and 

complained that he was too hot and tired 

and refused to go on, but he was 

encouraged to continue 

• Victim said he didn’t feel well and was dizzy,

then stumbled and fell

• Staff thought he was “faking” 

• When victim began to vomit, staff rolled him 

on his side 

• Victim stopped breathing and was later 

pronounced dead 

• Died on federal land 

 3

For an illustration showing the states where victims resided and the location of the

programs they attended, both for this testimony and our October 2007 testimony, see 

app. I. 

Page 8 GAO-08-713T 
Case 

Victim 

information

Program 

Attended 

Date 

of death 

Cause 

of death Case details 

3 Male, 12, Texas 

resident 

Texas residential 

treatment center 

Dec. 2005 Suffocation • Victim was angry and started banging his 

head against the ground 

• A 5 feet 10 inch, muscular staff member 

placed the 87-pound victim into a facedown 

restraint 

• Several witnesses claimed they saw the 

staff member lying across the back of the 

victim 

• Victim complained he couldn’t breathe and 

eventually became unresponsive, at which 

point the staff member removed the restraint

• After the victim had lain unresponsive for 

about a minute, the staff member rolled him 

over and found that he was pale 

• Attempts to revive victim failed

4 Male, 16,

Pennsylvania 

resident 

Pennsylvania 

psychiatric 

residential 

treatment center 

Feb. 2006 Abnormal heartbeat • Victim was placed under “intense 

observation” for attempting to run away from 

the program 

• Victim was ordered to put the hood of his 

sweatshirt down so that staff could see his 

face, but victim refused 

• Three staff members brought the victim to 

another room and placed him in restraint 

face down 

• After 10 minutes of the restraint, victim 

complained that he couldn’t breathe 

• Despite staff attempts to make the victim 

more comfortable, victim became 

unresponsive 

• Victim died at the hospital 3 hours later from 

an abnormal heartbeat 

• Program was aware victim suffered from 

asthma, but staff members who restrained 

the victim claimed they were not aware of 

this 

Source: Records including police reports, legal documents, and state investigative documents. 

See table 2 for a summary of the cases of abuse we examined. For 

reporting purposes, we continue the numbering of case studies in this 

table, starting with five. 

Page 9 GAO-08-713T 
Table 2: Summary of Eight Closed Cases (Four Abuse) 

Case Victim information Program attended Date(s) of abuse Case details 

5 Male, 14-18, New York 

resident 

New Jersey residential 

behavior modification 

program 

1994 to 1998 • Victim and parents were interviewed

separately by staff during his first visit to the 

program 

• Victim encountered 6 hours of intense 

questioning during which he felt forced to 

confess to activities he says he did not take

part in, such as illegal drug use and sex 

• Victim was restrained more than 250 times 

while attending the program; in at least two 

cases restraint lasted longer than 12 hours 

• One method of restraint included wrapping the 

victim in a blanket and tying him up 

• Victim was required to attend the program for 

4 years and was held against his will after his

18th birthday 

6 Male, 17, Washington 

resident 

Mississippi faith-based 

academy and boot camp 

April 1999 • Victim jumped off a building and broke his left 

arm; the bone of his arm was exposed, but he

was not given medical attention for 2 weeks

• Students and staff harassed the victim, with 

some boys subjecting him to physical abuse 

• On one occasion, victim was beaten

unconscious by staff and other students 

• On another occasion, a staff member’s pit bull 

bit the victim in the crotch 

• Victim had previously attended boarding 

school in case 7 

7 Male, 15, California 

resident 

Utah boarding school Nov. 2004 • Victim was verbally abused and punched, 

kicked, and slapped by other students, under 

direction of one of the school’s owners 

• Victim was hit and pushed down stairs by the 

same school owner 

• On multiple occasions throughout his stay in

the school, victim was locked in a bathroom 

and a closet and forced to sleep on a shelf as

punishment 

8 Male, 14, California 

resident 

Colorado boarding 

school 

May 2006 • Staff member assaulted victim by grabbing 

him by the arm, pushing him into a stairwell, 

and slamming his face into a wall 

• Victim’s face was visibly bruised, including a 

black eye 

• Victim was forced to kneel on the floor for 

hours with his knees at the point where the 

floor meets the wall and his nose touching the 

wall 

Source: Records including police reports, legal documents, and state investigative documents. 

Page 10 GAO-08-713T 
The following three narratives describe selected cases in further detail. 

Case 3 (Death) The victim, who died in 2005, was a 12-year-old male. Documents obtained 

from the Texas Department of Family and Protective Services indicate that 

the victim had a troubled family background. He was taken into state care 

along with his siblings at the age of 6. According to child protective service

workers who visited the family’s home, the victim and his siblings were 

found unsupervised and without electricity, water, or food. Some of the 

children were huddled over a space heater, which was connected to a 

neighbor’s house by extension cord, in order to keep warm. As a ward of 

the state, the victim spent several years in various foster placements and 

youth programs before being placed in a private residential treatment 

center in August 2005. The program advertised itself as a “unique facility” 

that specialized in services for boys with learning disabilities and 

behavioral or emotional issues. The victim’s caretakers chose to place him 

in this program because he was emotionally disturbed. Records indicate 

that he was covered by Medicaid. 

On the evening of his death, the victim refused to take a shower and was 

ordered to sit on an outside porch. According to police reports, the victim 

began to bang his head repeatedly against the concrete floor of the porch, 

leading a staff member to drag him away from the porch and place him in

a “lying basket restraint” for his own protection. During this restraint, the 4 

feet 91⁄2 inch tall, 87-pound boy was forced to lie on his stomach with his 

arms crossed under him as the staff member, a muscular male 5 feet 10 

inches tall, held him still. Some of the children who witnessed the restraint 

said they saw the staff member lying across the victim’s back. During the 

restraint, the victim fought against the staff member and yelled at him to

stop. The staff member told police that the victim complained that he 

could not breathe, but added that children “always say that they cannot 

breathe during a restraint.” According to police reports, after about 10 

minutes of forced restraint, the staff member observed that the victim had

calmed down and was no longer fighting back. The staff member slowly

released the restraint and asked the victim if he wanted a jacket. The 

victim did not respond. The staff member told police he interpreted the 

victim’s silence as an unwillingness to talk due to anger about the 

restraint. He said he waited for a minute while the victim lay silently on 

the ground. When the victim did not respond to his question a second time, 

he tapped the victim on the shoulder and rolled him over. The staff 

member observed that the victim was pale and could not detect a pulse. 

All efforts to revive the victim failed, and he was declared dead at a nearby 

hospital. 

Page 11 GAO-08-713T 
When the staff member demonstrated his restraint technique for the 

police, they found that his technique violated the restraint policies of the 

program. These policies prohibited staff from placing any pressure on the 

back of a person being restrained. The report added that this staff member 

was reprimanded for injuring a youth in 2002 as a result of improper 

restraint. After this incident, program administrators banned the staff 

member from participating in restraints for 1 month. The reprimand issued 

by program administrators over this incident noted that the staff member 

had actually trained other staff members in performing restraints, making 

the matter more serious. The police reports also cite one of the staff 

member’s performance evaluations that noted that he had problems with 

his temper. According to the reports, one of the youth in the program said 

the staff member could become agitated when putting youth in restraint. 

Although the Texas Department of Family and Protective Services alleged 

that the victim’s death was due to physical abuse, the official certificate of

death stated that it was an accident and a grand jury declined to press 

charges against the staff member performing the restraint. However, the 

victim’s siblings obtained a civil settlement against the program and the 

staff member for an undisclosed amount. The program remained open 

until May 2006, when a 12-year-old boy drowned on a bike outing with the

program. According to records from law enforcement, child protection 

workers, and the program, the boy fell into the water of a rain-swollen 

creek and was sucked into a culvert. He died after several weeks on life 

support. The Texas Department of Family and Protective Services cited 

negligent staff supervision in its review of this second death and revoked 

the program’s license to operate as a residential treatment center. 

However, the program’s directors also ran a summer camp for children 

with learning disabilities and social disorders licensed by the Texas 

Department of State Health Services, until they resigned from their 

positions in March 2008.

Case 4 (Death) The victim was 16 years old when he died, in February 2006, at a private 

psychiatric residential treatment facility in Pennsylvania for boys with 

behavioral or emotional problems. He was a large boy—6 feet 1 inch in

height and weighing about 250 pounds—and suffered from bipolar 

disorder and asthma. The cost for placement in this facility was primarily 

paid for by Medicaid. 

According to state investigative documents we obtained, the victim was 

placed in intensive observation after he attempted to run away. As part of 

the intensive observation, he was forced to sit in a chair in the hallway of 

the facility and was restricted from participating in some activities with 

Page 12 GAO-08-713T 
other residents. On the day of his death, staff allowed the victim to 

participate in arts, crafts, and games with the other youth, but would not 

let him leave the living area to attend other recreational activities. Instead, 

staff told the victim that he would have to return to his chair in the 

hallway. In addition, staff told him that he would have to move his chair so 

that he could not see the television in another room. The victim complied, 

moving his chair out of view of the television, but put up the hood of his 

sweatshirt and turned his back toward the staff. The staff ordered him to 

take down his hood but he refused. When one of the staff walked up to 

him and pulled his hood down, the victim jumped out of his chair and 

made a threatening posture with his fists, saying he did not want to be 

touched. The staff member and two coworkers then brought the victim to

another room and held him facedown on the floor with his arms pulled up 

behind his back. The victim struggled against the restraint, yelling and 

trying to kick the three staff members holding him down. After about 10 

minutes, the victim became limp and started breathing heavily. He 

complained that he was having difficulties breathing. One staff member 

unzipped his sweatshirt and loosened the collar of his shirt, but rather 

than improve, the victim became unresponsive. The staff called emergency 

services and began CPR. The victim was taken by ambulance to a hospital, 

where he died a little more than 3 hours later. In the victim’s autopsy 

report his death was ruled accidental, as caused by asphyxia and an 

abnormal heartbeat (cardiac dysrhythmia). 

Following the victim’s death, an investigation by the Pennsylvania 

Department of Health found that the policies and procedures for youth 

under intense observation do not prohibit them from watching television, 

nor do they require that youth keep their face visible to staff at all times. 

The investigation also found that the facility had documentation of the 

victim’s history of asthma, and that its training manual for restraint 

procedures cautioned against the risk of decreased oxygen intake during

restraints for children with asthma. However, all three staff members 

involved in the restraint told investigators that they were unaware of any 

medical conditions that needed to be considered when restraining the

victim. In addition, the investigation found that the facility did not provide 

timely training on the appropriate and safe use of restraint. The state’s 

Protection and Advocacy organization, Pennsylvania Protection & 

Advocacy, Inc. (PP&A), conducted its own investigation of the facility and 

found that staff members inappropriately restrained children in lieu of 

appropriate behavioral interventions, which resulted in neglect and abuse. 

Of the 45 residents interviewed by PP&A investigators, 29 said that staff at 

the facility subjected them to restraints. The residents reported that the 

restraints could last as long as 90 minutes and caused breathing

Page 13 GAO-08-713T 
difficulties. They also stated that staff often placed their knees on 

residents’ backs and necks during restraints. One resident reported that 

the blood vessels in his eyes “popped” during a restraint. Another resident 

said that his nose hit the ground during the restraint, causing him to choke 

on his own blood. Further, some of the residents reported that staff 

provoked them and that staff did not make any effort to de-escalate the 

provocations before implementing a restraint. 

No criminal charges were filed in regard to the victim’s death. The victim’s

mother filed a civil suit over her son’s death against the facility, which is 

currently pending. Her son’s death was not the only fatal incident at this 

facility. Only 2 months before the victim’s death, in December 2005, a 17-

year-old boy collapsed at the facility after a physical education class, and 

later died at a nearby hospital. His death was attributed to an enlarged 

heart. This facility remains open. 

Case 5 (Abuse) This abuse victim was sent to a private drug and addiction treatment 

program in July 1994 at the age of 14. He was attending public school in 

the major metropolitan area where his family lived. The abuse victim told

us that he had problems at school, including poor grades, truancy, a fight 

with other students, and that he had been suspended. After the victim was 

questioned by police about an assault on a girl at his school, a family 

friend with ties to the behavior modification program recommended the 

program to the victim’s parents. According to the victim, his first visit to 

the school turned into an intense intake session where he was interviewed 

by two program patients. Although the victim denied using drugs, the 

interviewers insisted that he was not being honest. After about 6 hours of 

questioning, the victim told the interviewers what he thought they wanted 

to hear—that he was smoking pot, did cocaine, and cut school to get 

high—so that he could end the interview. The interviewers used these 

statements to convince the victim’s parents to sign him into the program 

for immediate intervention and treatment. He ended up staying in the 

program for the next 4 years—even after he turned 18 and was held 

against his will. 

According to program records, the program’s part-time psychiatrist did not 

examine or diagnose him until he had been in the program for 14 days. 

This lack of psychological care continued, as program records indicate he

was examined by the psychiatrist only four times during his entire stay. He 

was restrained more than 250 times while in the program, with at least 46

restraints lasting one hour or longer. The victim said some restraints were 

applied by a group of four or five staff members and fellow patients. 

Page 14 GAO-08-713T 
According to the victim, they held him on his back, with one person 

holding his head and one person holding each limb. These restraints were 

imposed whenever the victim showed any reluctance to do what he was 

told, or, the victim told us, for doing some things without first obtaining 

permission from program staff. On one occasion, while he was staying 

with a host family and other patients, he attempted to escape from the 

program. The victim claims that they restrained him by wrapping him in a 

blanket and tying him up. According to the victim, when he turned 18, he

submitted a request to leave the program but his request was denied 

because he had not followed the proper procedure and was a danger to 

himself. For expressing his desire to leave the program, he was stripped of 

all progress he had made to that point, and was prevented from further 

advancing until the program director decided he was be eligible. Incident

reports filed by program staff document that after he had turned 18, the 

victim was restrained on 26 separate days, with at least two restraints 

lasting more than 12 hours. 

According to program rules, failure of the parents to follow program rules 

and fully support and participate in the program would jeopardize their 

son’s treatment and progress and put him at risk of expulsion. Having been 

led to believe that the program was the only way to help him overcome his 

alleged addictions and problems, his family complied with the program’s 

demands. Moreover, the program required parents and siblings over age 8 

to attend twice weekly group therapy meetings. According to the victim, 

these meetings lasted for many hours, sometimes stretching into the early 

morning. He added that when the victim’s father refused to attend the 

therapy meetings for fear of losing his job, the program told him to quit. 

When he would not quit his job or miss work to attend the meetings, the 

victim said that the program convinced his mother to leave her husband. 

After his parents separated, the program would not allow the victim to 

have contact with his father. The victim said that the program never told 

the victim’s family that all the drug tests they performed on him returned 

negative results, including the initial tests done when he entered the 

program. 

In February 1998, the State of New Jersey terminated the program’s 

participation in the Medicaid program, holding that the program did not 

qualify as a children’s partial care mental health program because of its 

noncompliance with client rights standards and its failure to meet various

staff requirements, such as staff-to-client ratios and requisite education 

and experience levels for staff. The program subsequently closed in 

November 1998, citing financial problems. About a year later, in 

September 1999, an administrative law judge rejected an appeal by the

Page 15 GAO-08-713T 
program to overrule the state’s termination of its Medicaid participation. 

The judge noted in his decision that the program effectively operated as a 

full-time residential facility. Moreover, he noted that all group staff at the 

program were either current or former patients, and only two members of 

the program staff met the educational requirements to qualify as directcare professionals. 

The victim filed a civil lawsuit against the program, director, and a 

psychiatrist, which resulted in a $3.75 million settlement. Other civil suits 

filed by former patients included one patient who was committed to the 

program at the age of 13 and spent 13 years in the program. This patient 

reached a similar settlement against the program, director, and 

psychiatrists for the sum of $6.5 million. In addition, a third former patient 

secured a $4.5 million settlement against the program, director, and 

psychiatrists. 

Posing as fictitious parents with fictitious troubled teenagers, we found 

examples of deceptive marketing and questionable practices related to 10 

private residential programs and 4 referral services. The most egregious 

deceptive marketing practices related to tax incentives and health 

insurance reimbursement, and were intended to make the high price of the 

programs appear more manageable for our fictitious parents. We also 

found examples of false statements and misleading representations related 

to a range of issues including education and admissions, as well as 

undisclosed conflicts of interest. In addition, we identified examples of 

questionable practices related to the health of youth enrolled in programs 

and the method of convincing reluctant parents to enroll their children. 

Although general consumer protection laws apply to these programs and 

services, there are no federal laws or regulations on marketing content 

and practices specific to the residential program industry. 

Deceptive Marketing 

and Questionable 

Practices in Selected 

Programs and 

Services 

A link to selected audio clips from these calls is available at:

http://www.gao.gov/media/video/gao-08-713t/. See table 3 for a selection of

representations made by programs and referral agents. 

Page 16 GAO-08-713T 
Table 3: Cases of Deceptive Marketing and Questionable Practices 

Source Representation Comments

1. 501(c)(3) charity 

foundation 

Foundation representative described a funding

mechanism whereby (1) parents solicit friends, 

relatives, and others to make financial 

donations to the foundation and have them 

specify on their donation checks a numbered

code representing the child; (2) the foundation 

tracks the donation amount on behalf of the 

child, then deducts an administrative fee and 

pays the program the remaining donation 

amount on behalf of that child; and (3) friends

and family deduct the charitable donations on

their tax return

An IRS official told us that the foundation is 

potentially committing tax fraud and that individuals 

who follow the program’s recommendation may be 

responsible for back taxes, as well as penalties and 

interest for taking an improper charitable deduction 

2. Montana boarding school Program representatives told one fictitious 

parent that an application form must be filled 

out before a child is admitted to the boarding 

school 

After a call to this program by a different fictitious 

parent, we received an acceptance letter for our 

fictitious child even though we never applied for 

admission 

3. Texas wilderness program Program representative stated that earth 

science credits earned in the program are “fully 

transferable” and that other institutions “can’t 

deny” the credit 

Education credits can be denied by schools for any 

reason and are not intrinsically transferable 

4. Texas wilderness program 

(same as case 

no. 3) 

Program representative said that the program 

will provide parents with a detailed bill after 

their child completes the program and that 

health insurance companies will reimburse 

expenses 

Representatives for both a health care insurer and a 

behavioral health company told us that parents who 

follow this advice run a real risk of not being 

reimbursed, especially if the health insurance

company requires pre-approval of counseling or other 

mental health services 

5. Texas wilderness program 

(same as case nos. 3 and 4) 

Program representative said a trade 

organization, the National Association of 

Therapeutic Schools and Programs (NATSAP), 

“absolutely” performs inspections of the 

program 

NATSAP does not perform inspections of its member 

programs 

6. Referral service “A” Referral agent stated that behavioral

modification schools are “specialty schools” 

and that tuition costs are tax deductible under

Section 213 of the Internal Revenue Tax code 

The two programs recommended by the referral 

agent do not appear to meet the requirements of IRS 

regulations for special schools; according to an IRS 

authority on Section 213 with whom we spoke, this is 

questionable tax advice and parents should consult a 

tax advisor 

7. Referral service “A” The referral agent warned our fictitious parent

that his wife might “freak out” about sending 

her daughter to a boarding school, and stated: 

“I want you to tell her it’s a college prep 

boarding school... if she thinks that you want to 

send her daughter to a place where there are 

drug addicts and people that are all screwed

up, she will look at you and say ‘no way’” 

In order to secure the business of our fictitious 

parent, the referral agent gave us questionable

ethical advice 

Page 17 GAO-08-713T 
Source Representation Comments

8. Referral service “B” Referral agent stated that the program he 

recommended “feed[s] the child a whole-grain 

diet” and that along with exercise and rest, “the 

bipolar, the depression, those kind of things, 

they just go away after awhile”

Although diet and sleep may be beneficial, there was 

no discussion during the call for a health care

provider to confirm the child’s diagnosis of bipolar 

disorder or depression and whether to continue 

medication 

9. Referral service “B” Web site for this referral service states: “We 

will look at your special situation and help you 

select the best school for your teen with 

individual attention” 

Referral agents recommended the same Missouri 

boot camp to three different fictitious parents with 

three fictitious children having very different 

problems; the referral service is owned by the

husband of the woman who owns the Missouri boot 

camp, but the conflict of interest was not disclosed 

10. Referral services “A” and 

“C” 

When investigators called the phone number of 

referral service “A” the receptionist answered

the call using the name of referral service “C” 

Referral services “A” and “C” represent themselves 

as separate entities, with separate names, Web sites, 

phone numbers, and magazine advertisements, 

suggesting that they provide objective advice

Source: GAO.

Case 1: One of our fictitious parents called this foundation pretending to 

be a parent who could not afford the cost of a residential program for his 

child. A representative of the foundation explained that their “most 

popular” method of fund-raising involved the friends and relatives of the 

enrolled youth making tax-deductible donations to the foundation, which 

in turn credited 90 percent of these “donations” specifically to pay for 

tuition in a program the child was attending. The foundation assigns a 

code number to each child, which parents ensure is listed on the donation 

checks. The representative also provided a fund-raising packet by mail 

that instructs the parents of troubled teens: “You are able to contact 

family, friends, business acquaintances, affiliates, churches, and 

professional/fraternal organizations that you know. Don’t forget corporate 

matching funds opportunities from your employer too.” The packet also 

included two template letters to send in soliciting the funds. According to

an IRS official with the Tax Exempt and Governmental Entities Division, 

this practice is inappropriate and represents potential tax fraud on the part

of the foundation. Furthermore, those who claim inappropriate deductions

in this fashion would be responsible for back taxes, as well as penalties 

and interest. Based on this information, we referred this nonprofit 

foundation to the IRS for criminal investigation. 

Case 2: The program representative at a Montana boarding school told 

our fictitious parent that they must submit an application form before their 

child can be accepted to the school. However, after a separate undercover 

call made to this school by one of our fictitious parents, the program 

representative e-mailed us stating that our fictitious daughter had been 

approved for admission into the program and subsequently sent an 

Page 18 GAO-08-713T 
acceptance letter. The acceptance letter stated that our fictitious child 

“has been approved for our school here in Montana.” This admission was 

based entirely on one 30-minute telephone conversation, in which our 

fictitious parent described his daughter as a 13-year-old who takes the 

psychotropic medication Risperdal, attends weekly therapy sessions, has 

bipolar disorder, and been diagnosed with Reactive Attachment Disorder. 

We did not fill out an application form for the school. Moreover, this 

program had previously recommended that our fictitious parents seek 

advice from the 501(c)(3)foundation discussed in Case 1 to help finance 

the cost of the program. It appears that parents do not have assurance 

about the integrity of the admissions process at this boarding school. 

Case 4: One fictitious parent asked the representative for a Texas 

wilderness therapy program whether there was any possibility that a 

health insurance company would cover the cost of the program. The 

representative replied that, at the completion of the program, the 

bookkeeper for the program would generate an itemized statement of 

billable charges that could be submitted to an insurance company for 

reimbursement. She emphasized that we should not call ahead of time to 

seek pre-approval, because then we would be “up the creek.” She added 

that this was “just the way insurance companies like it” and stated that 

health insurance companies reimburse “quite a bit.” She gave an example 

of one insurance company that reimbursed for over $11,000—almost the 

entire cost of the 28-day wilderness program. Representatives for both a 

health care insurer and a behavioral health company told us that parents 

who follow this advice run a real risk of not being reimbursed, especially if 

the health insurance company requires pre-approval of counseling or other 

mental health services. In this case, our fictitious parent was being led into 

believing that a large portion of the tuition for the program would be 

covered by health insurance even if pre-approval for the charges was not 

obtained in writing in advance of the services. 

Case 6: One referral agent we called stated that behavioral modification 

schools are “specialty schools” and that tuition costs are tax deductible 

under Section 213 of the Internal Revenue Tax code. The referral agent 

also stated that transportation costs related to bringing our fictitious child 

to and from the school were tax deductible under this section. However, 

the two programs recommended by the referral service do not appear to 

meet the requirements of IRS regulations for special schools. Our review 

of Section 213 of the Internal Revenue Tax code shows that it relates to 

medical expenses and specifies that, if medical expenses and 

transportation for treatment exceed 7.5 percent of a taxpayer’s adjusted

gross income, the excess costs can be deducted on Schedule A of IRS 

Page 19 GAO-08-713T 
Form 1040. Even if these expenses were deductible under this section, 

only expenses above 7.5 percent of the adjusted gross income would be 

deductible, rather than the full amount as suggested by the referral agent.

An IRS authority on Section 213 with whom we spoke stated that the 

referral service provided us with questionable tax advice and that parents

should consult a tax advisor before attempting to claim a deduction under 

this section. Parents improperly taking this deduction could be 

responsible for back taxes, as well as penalties and interest. 

Case 9: On its Web site, referral service “B” invites parents to call a tollfree number and states: “We will look at your special situation and help 

you select the best school for your teen with individual attention.” Our 

undercover investigators called this referral service pretending to be three 

separate fictitious parents and described three separate fictitious children

to the agents who answered the phone. Despite these three different 

scenarios, we found the referral service recommended the same 

residential program all three times—a Missouri boot camp. Our 

investigation into this referral service revealed that the owner of the 

referral service is the husband of the boot camp owner. This relationship, 

was not disclosed to our fictitious parents during our telephone calls, 

which raises the issue of a potential conflict of interest. It appears that 

parents who call this referral service will not receive the objective advice 

they expect based on marketing information on the Web site. 

Mr. Chairman and Members of the Committee, this concludes my 

statement. We would be pleased to answer any questions that you may 

have at this time. 

For further information about this testimony, please contact Gregory D. 

Kutz at (202) 512-6722 or kutzg@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this testimony. 

Contacts and 

Acknowledgments 

Page 20 GAO-08-713T 
Page 21 GAO-08-713T 

Appendix I: Private Residential Program 

Locations 

In our examination of case studies for this testimony and our prior 

testimony, we found that the victims of death and abuse came from across 

the country and attended programs that were similarly located in 

numerous states. Figure 1 contains a map indicating where victims lived 

and the location of the program they attended. 

Figure 1: Map of Case Study Victims from October 2007 Testimony and This Testimony

Source: GAO.

State of residence (male/female)

Location of residential program

Note: The icons in figure 1 represent the state of residence for each case study victim and the state in

which each residential program is located. The icons do not reflect specific geographic locations 

within states. 
Private residential programs are located nationwide and rely heavily on 

the Internet for their marketing. Although Web sites list 48 of the 50 states 

where parents can find various types of programs, we found that they do

not list programs in Nebraska and South Dakota, nor do they indicate the 

existence of programs in the District of Columbia. Notably, we did not find

Web sites that list states with boot camps but instead instruct parents to 

call for locations and details. Figure 2 illustrates the types of programs and 

the states in which they are located, excluding boot camps. 

Page 22 GAO-08-713T 
Figure 2: Private Residential Programs Nationwide 

PA

OR

NV

ID

MT

WY

UT

AZ

NM

CO

ND

SD

NE

TX

KS

OK

MN

IA

MO

AR

LA

IL

MS

IN

KY

TN

AL

FL

GA

SC NC

OH

NH

MA

MI

CA

WA

WI NY

AK

HI

RI

CT

NJ

DE

MD

DC

WV

VA

VT

ME

SC

Source: GAO analysis of information available on referral service Web sites.

One or more boarding schools located in state

One or more therapeutic boarding schools located in state

One or more wilderness programs located in state

One or more ranch programs located in state

Page 23 GAO-08-713T 
Page 24 GAO-08-713T 

Appendix II: Cost of Private Residential 

Programs 

Our undercover calls to selected programs revealed that most private 

programs charge a high tuition for their services. Table 4 contains 

information related to the high cost of these programs based these phone 

calls. 

Table 4: Basic Monthly Costs of Programs

No. Type of program Location Source of information Basic monthly cost

1 Boarding school Georgia Referral service $3,166

2 Boot camp Missouri Referral service 4,500

3 Boarding school North Carolina Referral service 4,500

4 Boarding school South Carolina Referral service 3,166

5 Boarding school South Carolina Referral service 2,795

6 Boarding school Colorado Program 2,795 - 2,995

7 Boarding school Georgia Program 8,120a

8 Boarding school Montana Program 3,495

9 Boarding school New York Program 5,160

10 Boarding school Tennessee Program 8,700b

11 Boarding school Utah Program 6,500b

12 Wilderness program Georgia Program 12,600

13 Wilderness program North Carolina Program 13,020

14 Wilderness program Texas Program 13,020

Source: GAO analysis of information obtained during undercover calls to programs and referral services. 

a

This is for the first 90 days; the cost drops afterwards. 

b

This includes therapy. 

According to program and service representatives with whom we spoke, 

the basic cost could be discounted. For example, one program told us if 

parents paid for a full year upfront, they would be given a $200-per-month 

discount. This does not include fees by transport services for taking a 

child to a program. Moreover, although program and service 

representatives quoted these as basic program costs, they also mentioned 

additional one-time charges, such as an enrollment fee that can be as 

much as $4,600, uniform costs, or other items such as supplies. In addition, 

some programs charge extra for therapy, including one-on-one therapy.

(192273) 
This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately. 
GAO’s Mission The Government Accountability Office, the audit, evaluation, and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and policies; 

and provides analyses, recommendations, and other assistance to help

Congress make informed oversight, policy, and funding decisions. GAO’s 

commitment to good government is reflected in its core values of 

accountability, integrity, and reliability. 

The fastest and easiest way to obtain copies of GAO documents at no cost

is through GAO’s Web site (www.gao.gov). Each weekday, GAO posts 

newly released reports, testimony, and correspondence on its Web site. To

have GAO e-mail you a list of newly posted products every afternoon, go 

to www.gao.gov and select “E-mail Updates.” 

The first copy of each printed report is free. Additional copies are $2 each. 

A check or money order should be made out to the Superintendent of 

Documents. GAO also accepts VISA and Mastercard. Orders for 100 or 

more copies mailed to a single address are discounted 25 percent. Orders 

should be sent to: 

U.S. Government Accountability Office 

441 G Street NW, Room LM 

Washington, DC 20548 

To order by Phone: Voice: (202) 512-6000 

TDD: (202) 512-2537 

Fax: (202) 512-6061 

Contact: 

Web site: www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470 

Ralph Dawn, Managing Director, dawnr@gao.gov, (202) 512-4400 

U.S. Government Accountability Office, 441 G Street NW, Room 7125 

Washington, DC 20548 

Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800 

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, DC 20548 

Obtaining Copies of 

GAO Reports and 

Testimony

Order by Mail or Phone 

To Report Fraud,

Waste, and Abuse in 

Federal Programs 

Congressional 

Relations 

Public Affairs 

PRINTED ON RECYCLED PAPER