Influenza Pandemic: Greater Agency Accountability Needed to Protect Federal Workers in the Event of a Pandemic
Published: 2009-06-16T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: As evidenced by the spring 2009 outbreak of the H1N1 virus, an influenza pandemic remains a real threat to the nation and the world and has the potential to shut down work critical to the smooth functioning of society. This testimony addresses (1) the extent to which federal agencies have made pandemic plans to protect workers who cannot work remotely and are not first responders; (2) the pandemic plans selected agencies have for certain occupations performing essential functions other than first response; and (3) the opportunities to improve agencies' workforce pandemic plans. The issues discussed in the testimony are based on the GAO report, Influenza Pandemic: Increased Agency Accountability Could Help Protect Federal Employees Serving the Public in the Event of a Pandemic ( GAO-09-404 , June 12, 2009). In this report, GAO recommended that the Homeland Security Council (HSC) request that the Department of Homeland Security (DHS) monitor and report to the Executive Office of the President on the readiness of agencies to continue operations while protecting their employees in the event of a pandemic. To help carry out its oversight role, the Congress may want to consider requiring a similar report from DHS. The HSC noted that it will give serious consideration to the findings and recommendations in the report, and DHS said the report will contribute to its efforts to ensure government entities are well prepared for what may come next.
section_title: What GAO Found
paragraphs: GAO surveyed the 24 agencies employing nearly all federal workers to gain an overview of governmentwide pandemic influenza preparedness efforts and found that a wide range of pandemic planning activities are under way. However, as of early 2009, several agencies reported that they were still developing their pandemic plans and their measures to protect their workforce. For example, several agencies had yet to identify essential functions during a pandemic that cannot be performed remotely. In addition, although many of the agencies' pandemic plans rely on telework to carry out their functions, five agencies reported testing their information technology capability to little or no extent. To get a more in-depth picture of agency planning, GAO selected three case study agencies that represent essential occupations other than first response that cannot be performed remotely. The three case study occupations--correctional workers, production staff disbursing federal checks, and air traffic controllers--showed differences in the degree to which their individual facilities had operational pandemic plans. For example, the Bureau of Prisons' correctional workers had only recently been required to develop pandemic plans for their correctional facilities. Nevertheless, the Bureau of Prisons has considerable experience limiting the spread of infectious disease within its correctional facilities and had also made arrangements for antiviral medications for a portion of its workers and inmates. The Department of the Treasury's Financial Management Service, which has production staff involved in disbursing federal payments such as Social Security checks, had pandemic plans for its four regional centers and had stockpiled personal protective equipment such as respirators, gloves, and hand sanitizers at the centers. Air traffic control management facilities, where air traffic controllers work, had not yet developed facility pandemic plans or incorporated pandemic plans into their all-hazards contingency plans. The Federal Aviation Administration had recently completed a study to determine the feasibility of the use of respirators by air traffic controllers and concluded that their long-term use during a pandemic appears to be impractical. There is no mechanism in place to monitor and report on agencies' progress in developing workforce pandemic plans. Under the National Strategy for Pandemic Influenza Implementation Plan, DHS was required to monitor and report on the readiness of departments and agencies to continue operations while protecting their employees during an influenza pandemic. The HSC, however, informed DHS in late 2006 or early 2007 that no specific reports on this were required to be submitted. Rather, the HSC requested that agencies certify to the council that they were addressing in their plans the applicable elements of a pandemic checklist in 2006 and again in 2008. This process did not include any assessment or reporting on the status of agency plans. Given agencies' uneven progress in developing their pandemic plans, monitoring and reporting would enhance agencies' accountability for protecting their employees in the event of a pandemic.

section_title: Letter
paragraphs: I am pleased to be here today to discuss our recent study of federal  agencies’ plans to protect their workers in the event of an influenza  pandemic. Our report focused on the protection of federal employees, not  classified as emergency first responders, yet necessary for ensuring the  continuity of the country’s critical operations. Although some of these  employees will be able to perform their agencies’ essential functions  remotely through arrangements such as telework, others, such as federal  correctional workers, production staff involved in disbursing federal  payments such as Social Security checks, and air traffic controllers, will  have to work at assigned locations where there will be an increased  chance of infection due to proximity to others. As we were recently  reminded by the spring 2009 outbreak of the H1N1 virus, an influenza  pandemic remains a real threat to our nation and the world and has the  potential to shut down work critical to the smooth functioning of our  society. Given the important role that the federal government will play in  the national response to a pandemic, planning to ensure the safety and  well-being of federal employees is vital to the success of government  operations.
This statement is based on our June 12, 2009 report and focuses on (1) the  extent to which agencies have made pandemic plans to protect workers  who cannot work remotely and are not first responders; (2) the pandemic  plans selected agencies have for certain occupations performing essential  functions other than first response; and (3) the opportunities to improve  agencies’ workforce pandemic plans.
To address our objectives, we surveyed the pandemic coordinators from  the 24 agencies covered by the Chief Financial Officers Act of 1990, which  we supplemented with a case study approach. We used the survey to get  an overview of governmentwide pandemic influenza preparedness efforts.  The survey questions asked about pandemic plans; essential functions  other than first response that employees cannot perform remotely;  protective measures, such as procuring pharmaceutical interventions;  social distancing strategies; information technology (IT) testing; and  communication of human capital pandemic policies. The survey was  conducted from May through July 2008, and the results were confirmed or  updated in early 2009. To get a more in-depth picture of agency planning,  we selected for case studies three occupations that represent essential  functions (other than first responders): correctional workers employed by  the Department of Justice’s (DOJ) Bureau of Prisons (BOP); production  staff responsible for disbursing federal payments in the Department of the  Treasury’s (Treasury) Financial Management Service (FMS); and air traffic  controllers employed by the Department of Transportation’s (DOT)  Federal Aviation Administration (FAA). We undertook this performance  audit in accordance with generally accepted government auditing  standards. The standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
In summary, our report found the following:    Agency progress in pandemic planning is uneven. Although all of the 24  CFO Act agencies reported being engaged in planning for pandemic  influenza to some degree, several agencies reported that they were still  developing their pandemic plans and their measures to protect their  workforce.
The three case study agencies also showed differences in the degree to  which their individual facilities had operational pandemic plans. BOP’s  correctional workers had only recently been required to develop pandemic  plans for their correctional facilities. Treasury’s FMS had pandemic plans  for its four regional centers and had stockpiled personal protective  equipment. By contrast, air traffic control management facilities, where air  traffic controllers work, had not yet developed facility pandemic plans or  incorporated pandemic plans into their all-hazards contingency plans.
There is no mechanism in place to monitor and report on agencies’  progress in developing workforce pandemic plans. Instead of having the  Department of Homeland Security (DHS) monitor agency readiness to  continue operations while protecting their employees during an influenza  pandemic, as originally envisioned under the National Strategy for  Pandemic Influenza Implementation Plan (Implementation Plan), the  Homeland Security Council (HSC) requested that agencies certify to the  council that they were addressing in their plans the applicable elements of  a pandemic checklist without including any provisions to assess the  progress agencies were making.
subsections: section_title: Background
paragraphs: Approximately 2.6 million federal employees throughout the United States  and abroad execute the responsibilities of the federal government. Federal  employees work in every state, with about 90 percent outside the  Washington, D.C., metropolitan area. They perform functions across a  multitude of sectors, from those vital to the long-term well-being of the  country—such as environmental protection, intelligence, social work, and  financial services—to those directly charged with aspects of public  safety—including corrections, airport and aviation safety, medical  services, border protection, and agricultural safety.
Worker protection strategies are crucial to sustain an adequate workforce  during a pandemic. During the peak of an outbreak of a severe influenza  pandemic in the United States, an estimated 40 percent of the workforce  could be unable to work because of illness, the need to care for ill family  members, or fear of infection. Under the Implementation Plan, all federal  agencies are expected to develop their own pandemic plans that along  with other requirements, describe how each agency will provide for the  safety and health of its employees and support the federal government’s  efforts to prepare for, respond to, and recover from a pandemic. Because  the dynamic nature of pandemic influenza requires that the scope of  federal government continuity of operations (COOP) planning includes  preparing for a catastrophic event that is not geographically or temporally  bounded, the Federal Emergency Management Agency concluded that  planning for a pandemic requires a state of preparedness that is beyond  traditional federal government COOP planning. For example, for pandemic  planning purposes, essential functions may be more inclusive and extend  longer than the 30-day traditional COOP-essential functions.
section_title: Agencies Report Being in Various Stages of Planning for the Protection of Their Employees in the Event of a Pandemic
paragraphs: Our survey questions for the 24 agencies were drawn from pandemic  planning checklists and federal guidance to help agencies plan for  protecting their employees during a pandemic. The 24 agencies we  surveyed reported being in various stages of formulating their pandemic  plans. While most of the agencies had developed plans, several reported  that they were still formulating their plans. For example, in February 2009,  the Small Business Administration (SBA) reported that it had begun to  draft a more complete pandemic influenza annex to its COOP plan with an  estimated completion date of spring 2009. The Department of Defense  (DOD) had completed its overarching departmentwide plan, and DOD  reported that its installations were tailoring their Force Health Protection  Plans to include pandemic influenza considerations.
Identifying essential functions and enumerating the employees who would  perform them is the first step in training those employees, communicating  the risks and expectations of working during a pandemic, and planning  and budgeting for measures that would mitigate those risks. Nineteen  agencies reported that they had identified essential functions at both the  department and component levels that cannot be continued through  telework in the event of pandemic influenza or, in the case of the Office of  Personnel Management (OPM), the U.S. Agency for International  Development (USAID), and the National Science Foundation (NSF),  determined that all of their essential or important government functions  could be performed remotely. Of the remaining 5 agencies, DOJ reported  identifying essential functions at the component level but noted that it was  revising its department-level plan. At the time of our survey, the General  Services Administration (GSA) reported not identifying its essential  functions in the event of a pandemic while three agencies—DOD, SBA,  and the Department of Housing and Urban Development (HUD)—were in  the process of either identifying essential functions or determining which  functions could be continued through telework. The pandemic  coordinators in three agencies did not know whether the employees who  performed essential functions in their agencies had been notified that they  might be expected to continue operations during a pandemic.
We also asked the pandemic coordinators from the 24 agencies whether  they had planned or budgeted for any of seven potential measures to  protect workers whose duties require their on-site presence during a  pandemic. The measures included in our survey included procurement of  personal protective equipment such as masks and gloves; supplemental  cleaning programs for common areas; distribution of hygiene supplies  (hand sanitizers, trash receptacles with hands-free lids, etc.); obtaining  antiviral medications; arrangements to obtain pandemic vaccines to the  extent available; prioritization of employees for vaccinations; and  prioritization of employees for antiviral medications. Federal pandemic  guidance recommends the measures according to risk assessments for  employees, and therefore, based on the agencies’ mission and activities,  not all measures are equally appropriate for all agencies. The most  frequently reported measure was procurement of personal protective  equipment with 19 agencies reporting that they had planned or budgeted  for this measure. For example, DHS reported that it had done fit testing of  employees for N95 respirators and training on the proper use of other  personal protective equipment and had pre-positioned stockpiles of the  equipment for employees in 52 locations. Prioritization of employees for  vaccinations was the measure least frequently reported with 11 agencies  reporting that they had taken this measure.
The survey showed that agencies’ most frequently cited social distancing  strategies involved using telework and flexible schedules for their  workforces. Restrictions on meetings and gatherings and avoiding  unnecessary travel were also part of 18 agencies’ plans. Although many of  the agencies’ pandemic influenza plans rely on social distancing strategies,  primarily telework, to carry out the functions of the federal government in  the event of a pandemic outbreak, only one agency, NSF stated that it  tested its IT infrastructure to a great extent. The agency reported assessing  its telework system formally several times each year and each day through  various means. On the other hand, five agencies reported testing their IT  systems to little or not extent. Table 1 shows the survey responses.
Given the potential severity of a pandemic, it is important that employees  understand the policies and requirements of their agencies and the  alternatives, such as telework, that may be available to them. Many  employees and their supervisors will have questions about their rights,  entitlements, alternative work arrangements, benefits, leave and pay  flexibilities, and hiring flexibilities available during the turmoil created by  a pandemic. Therefore, it is important that each agency implement a  process to communicate its human capital guidance for emergencies to  managers and make staff aware of that guidance. Twenty-one of the 24  pandemic coordinators surveyed reported making information available to  their employees on how human capital policies and flexibilities will  change in the event of a pandemic outbreak. Three agencies—DOC, GSA,  and SSA—reported that they have not. Of the agencies that reported  making information available, two had done so indirectly. HUD stated that  it shared information with unions, and Treasury reported that it briefed its  human capital officers on the human capital policies and flexibilities  available to address pandemic issues.
section_title: Pandemic Preparations for Correctional Workers, Production Staff Responsible for Disbursing Federal Payments, and Air Traffic Controllers Are in Various Stages of Development
subsections: section_title: BOP Has Taken Steps to Protect Correctional Workers in the Event of a Pandemic
paragraphs: BOP, a component of DOJ, has the mission of protecting society by  confining offenders in the controlled environments of prisons and  community-based facilities that are safe, humane, cost-efficient, and  appropriately secure and that provide work and other self-improvement  opportunities to assist offenders in becoming law-abiding citizens.  Approximately 35,000 federal employees ensure the security of federal  prisons and provide inmates with programs and services.
BOP’s pandemic influenza plan was developed through its Office of  Emergency Preparedness and was disseminated to its central office and  six regional offices in May 2008. BOP’s pandemic plan addresses the need  for infection control measures to mitigate influenza transmission and calls  for education of correctional workers and the inmate population.  Accordingly, all facilities are instructed that they should have readily  available and ample supplies of bar soap and liquid soap in the restrooms,  alcohol-based wipes throughout the facility, and hand sanitizers if  approved by the warden. Based on a historical review of the 1918  pandemic influenza and HHS’ pandemic planning assumptions, BOP  intends to supply antiviral medication to 15 percent of correctional  workers and inmates in each facility if the influenza outbreak is  geographically spread throughout the United States.
BOP has some challenges in preparing for pandemic influenza. For  example, social distancing measures to protect correctional workers are  difficult to implement at the facility level. BOP officials said that there are  many situations in which close contact is inevitable between correctional  workers and inmates and where personal protective equipment, such as  gloves and masks, would not be feasible. A unique pandemic planning  challenge facing federal correctional workers is the maintenance of an  effective custodial relationship between them and the inmates in federal  prisons. According to BOP officials, this relationship depends on  communication and mutual trust, as correctional workers in federal  prisons do not carry weapons or batons inside the cellblocks. Rather, they  use verbal methods of communication to keep order. BOP officials at  United States Penitentiary Leavenworth said that they would not allow a  situation where correctional workers wear N95 respirators or surgical  masks but the inmates do not.
Despite the challenges BOP faces with pandemic influenza planning, the  bureau has advantages, which are unique to its facilities. Every  correctional facility is a closed and self-contained system, and each facility  is somewhat self-sufficient, maintaining a 30-day supply of food, water,  and other necessities for any type of contingency. Correctional facilities  also have well-tested experience in emergency and health hazard planning  and management and infection control, which provides them with a solid  foundation to build on for pandemic influenza preparedness. Additionally,  correctional facilities generally have strong ties with their local  communities, important because pandemic influenza will be largely  addressed by the resources available to each community it affects.
section_title: FMS Has Operational Pandemic Plans for Production Staff Responsible for Disbursing Federal Payments
paragraphs: FMS, a component of Treasury, provides central payment services to  federal agencies, operates the federal government’s collections and  deposit systems, provides governmentwide accounting and reporting  services, and manages the collection of delinquent debt owed to the  government. FMS has four regional financial centers that are production  facilities that rely heavily on integrated computer and telecommunications  systems to perform their mission. However, they also rely on light  manufacturing operations to print and enclose checks for releasing at  specific times of the month. Nearly 206 million of FMS’s payments were  disbursed by check in fiscal year 2008.
A regional center Deputy Director said that the organization is aware that  the basis of part of the U.S. economy rests on the regional financial  centers and that they will need to issue payments even during a pandemic.  For the most part, the regional financial centers are planning that in the  event of a pandemic, the nature of their business will be unchanged, but  there will be issues with sickness, absenteeism, communication, and  hygiene that they must address. Employees whose positions require, on a  daily basis, direct handling of materials or on-site activity that cannot be  handled remotely or at an alternative worksite are not eligible for  telework. According to an FMS official, even with a minimum crew on-site  to produce paper checks, there will be instances when employees will  need to be within 3 feet of other employees.
As part of the regional center pandemic plans, officials researched the  types of supplies they would need based on the risks faced in their  facilities. For example, in the Kansas City regional financial center the  janitorial staff now routinely wipes off door handles, tabletops, and other  high-traffic areas. As another part of the Kansas City regional plan, the  center stocks such items as N95 respirators, gloves, hand sanitizers,  disinfectants, and fanny packs that include items such as ready to eat  meals, hand-cranked flashlights, small first-aid kits, and emergency  blankets.
The FMS regional financial centers face some unique pandemic planning  challenges. Since the centers are production facilities with large open  spaces as well as enclosed office areas, pandemic planning requires  different responses for different areas. An FMS official noted that  employees’ response and diligence in following disease containment  measures in the different areas would be what determines the success of  those measures. Scheduling of production personnel is also a challenge.  Since the production of the checks must be done according to a deadline  and internal controls must be maintained, schedules are not flexible. FMS  officials had not made any arrangements for pandemic pharmaceutical  interventions for the regional financial centers in part because the  relatively small number of essential employees required to be on-site, as  well as the large open spaces in the regional facilities, make social  distancing measures more feasible.
section_title: FAA Pandemic Plans to Protect Air Traffic Controllers Are Not Ready for Implementation
paragraphs: FAA, a component of DOT, expects the National Airspace System to  function throughout an influenza pandemic, in accordance with the  preparedness and response goal of sustaining infrastructure and mitigating  impact to the economy and the functioning of society. Maintaining the  functioning of the National Airspace System will require that FAA’s air  traffic controllers, who ensure that aircraft remain safely separated from  other aircraft, vehicles, and terrain, continue to work on-site. While FAA  expects the demand for air traffic control, which manages cargo as well as  passenger travel, to be reduced in the event of a severe pandemic  outbreak, its contingency plans assume full air traffic levels as a starting  baseline. According to an FAA official, although passenger travel may be  diminished, the shipping of cargo may increase.
The Air Traffic Organization, FAA’s line of business responsible for the air  traffic management services that air traffic controllers provide, had not  directed facilities, such as its air route traffic control centers, to develop  pandemic-specific plans or incorporate these pandemic plans into their all- hazards contingency plans. FAA officials said that all-hazards contingency  and continuity plans are adapted to the facility level and are regularly  implemented during natural disasters such as hurricanes. Although these  plans are not specific to a pandemic, FAA officials reported that the all- hazards plans allow the Air Traffic Organization to mitigate the impact of  adverse events, including reduced staffing levels on National Airspace  Systems operations. The Air Traffic Organization plans to direct its  facilities to develop pandemic-specific plans or enhance their preexisting  all-hazards contingency plans at the local field facility level after a number  of actions, such as the development of an FAA workforce protection  policy, are completed.
Protecting air traffic controllers in the event of a pandemic outbreak is  particularly challenging for several reasons. Air traffic controllers work in  proximity to one another; the 6 feet of separation recommended for social  distancing during a pandemic by the Centers for Disease Control and  Prevention and the Occupational Safety and Health Administration is not  possible for them. In addition, air traffic controllers cannot use personal  protective equipment such as N95 respirators or surgical masks, as these  impede the clear verbal communication necessary to maintain aviation  safety. FAA recently completed a study examining the feasibility of air  traffic controllers using powered air purifying respirators. Because of a  number of concerns with using the respirators, such as noise, visibility,  and comfort, FAA officials concluded that their long-term use during a  pandemic appears to be impractical. Moreover, cross-certification of air  traffic controllers is problematic. Attaining full performance levels for the  controllers takes up to 3 years, and air traffic controllers proficient in one  area of airspace cannot replace controllers proficient in another airspace  without training and certification. Finally, FAA regulations on medication  for air traffic controllers are strict because certain medications may impair  an air traffic controller’s performance. The Office of Aviation Medicine’s  policy on the use of antiviral medication for prophylactic use by on-duty  controllers was still in draft as of early 2009.
section_title: Monitoring and Reporting on Agencies’ Pandemic Workforce Protection Plans Could Improve Efforts to Protect Employees in the Event of a Pandemic
paragraphs: The survey results from the 24 CFO Act agency pandemic coordinators, as  well as information from the case study agencies, indicate that a wide  range of pandemic planning activities are under way and that all of the  agencies are taking steps to some degree to protect their workers in the  event of a pandemic. However, agencies’ progress is uneven, and while we  recognize that the pandemic planning process is evolving and is  characterized by uncertainty and constrained resources, some agencies  are clearly in the earlier stages of developing their pandemic plans and  being able to provide the health protection related to the risk of exposure  their essential employees may experience.
Under the HSC’s Implementation Plan, DHS was charged with, among  other things, monitoring and reporting to the Executive Office of the  President on the readiness of departments and agencies to continue their  operations while protecting their workers during an influenza pandemic.  DHS officials reported that in late 2006 or early 2007 they asked HSC  representatives with direct responsibility for the Implementation Plan for  clarification on the issue of reporting agencies’ ability to continue their  operations while protecting their workers during a pandemic. DHS  officials said they were informed that they did not have to prepare a  report. Instead, according to White House counsel representatives, the  HSC planned to take on the monitoring role through its agency pandemic  plan certification process.
In November 2006, the HSC issued Key Elements of Departmental  Pandemic Influenza Operational Plan (Key Elements), which covered  areas such as dealing with the safety and health of department employees  and essential functions and services and how agencies will maintain them  in the event of significant and sustained absenteeism during a pandemic.  The Key Elements document stated that to ensure uniform preparedness  across the U.S. government, the HSC was including a request that by  December 2006 the agencies certify in writing to the HSC that they were  addressing applicable elements of the checklist. Subsequently, in August  2008, the HSC revised the Key Elements to reflect current federal  government guidance on pandemic planning and included a request for  recertification.
However, the HSC’s certification process, as implemented, did not provide  for monitoring and reporting as envisioned in the Implementation Plan  regarding agencies’ abilities to continue operations in the event of a  pandemic while protecting their employees. In addition, as originally  envisioned in the Implementation Plan, the report was to be directed to  the Executive Office of the President, with no provision in the plan for the  report to be made available to the Congress.
section_title: Concluding Observations and Prior Recommendations
paragraphs: The spring 2009 outbreak of H1N1 influenza accentuates the responsibility  of agencies to have pandemic plans that ensure their ability to continue  operations while protecting their workers who serve the American public.  As evidenced by our survey results and case studies, some agencies are  not close to having operational pandemic plans, particularly at the facility  level. In addition, there is no real monitoring mechanism in place to ensure  that agencies’ workforce pandemic plans are complete. A monitoring  process should be in place that would ensure that federal agencies are  making progress in developing their plans to protect their workforce in the  event of a pandemic and that agencies have the information and guidance  they need to develop operational pandemic plans.
To address this issue, our report recommended that the HSC request that  the Secretary of Homeland Security monitor and report to the Executive  Office of the President on the readiness of agencies to continue their  operations while protecting their workers during an influenza pandemic.  The reporting should include an assessment of the agencies’ progress in  developing their plans including any key challenges and gaps in the plans.  The request should also establish a specific time frame for reporting on  these efforts. We also suggested that to help support its oversight  responsibilities, the Congress may want to consider requiring DHS to  report to it on agencies’ progress in developing and implementing their  pandemic plans, including any key challenges and gaps in the plans. The  HSC commented that the report makes useful points regarding  opportunities for enhanced monitoring and reporting within the executive  branch concerning agencies’ progress in developing plans to protect their  workforce. DHS commented that our recommendations would contribute  to its future efforts to ensure that government entities are well prepared  for what may come next.
Mr. Chairman and Members of the Subcommittee, this completes my  statement. I would be pleased to respond to any questions that you might  have.
section_title: Contacts and Acknowledgments
paragraphs: For further information on this testimony, please contact Bernice  Steinhardt, Director, Strategic Issues, at (202) 512-6543 or  steinhardtb@gao.gov. Contact points for our Offices of Congressional  Relations and Public Affairs may be found on the last page of this  testimony. Individuals making key contributions to this testimony include  William J. Doherty, Assistant Director, Judith C. Kordahl, Senior Analyst,  and Karin Fangman, Deputy Assistant General Counsel.
section_title: Appendix I: Chief Financial Officers Act Agencies
paragraphs: This is a work of the U.S. government and is not subject to copyright protection in the  United States. The published product 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.