Justice Department: Better Management Oversight and Internal Controls Needed to Ensure Accuracy of Terrorism-Related Statistics
Published: 2003-01-17T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: In accordance with the Government Performance and Results Act of 1993, the Department of Justice (DOJ) provides Congress and the public with an annual performance report. These reports serve as an important measure of DOJ's progress related to its strategic goals and objectives, including statistics on its Fiscal Year 2000 Performance Report. We were asked to review the accuracy of DOJ's terrorism-related conviction statistics. Among other objectives, in this report we (1) identify how DOJ develops its terrorism-related conviction statistics and (2) assess whether DOJ has sufficient management oversight and internal controls in place to ensure the accuracy of terrorism-related statistics included in its annual performance reports.
section_title: What GAO Found
paragraphs: Beginning in fiscal year 2001, DOJ switched from using the FBI's terrorism-related conviction statistics to using those of the Executive Office of U.S. Attorneys (EOUSA) for its annual performance report. This change was in response to concerns raised by a newspaper article's allegation that DOJ had inflated terrorism statistics in its Fiscal Year 2000 Performance report. It was also part of an effort to report conviction statistics that would be less likely to be misinterpreted, according to DOJ officials. The FBI historically classified more convictions than EOUSA as terrorism-related because it used a different classification system and included convictions obtained in international, federal, and state courts. EOUSA only included federal convictions. Our review of a sample of cases investigated and classified by the FBI as terrorism-related, including U.S. Attorney Office (USAO) cases covered by the article, found documentation to support the terrorism-related classification for these cases. As for the accuracy and reliability of EOUSA's terrorism-related statistics included in its annual performance reports, we found that DOJ does not have sufficient management oversight and internal controls in place, as required by federal internal control standards, to ensure the accuracy and reliability of its terrorism-related conviction statistics. At least 132 of the 288 USAO cases (about 46 percent) were misclassified as resulting in terrorism-related convictions in fiscal year 2002. Without the implementation of adequate management oversight and internal controls to ensure accurate and reliable terrorism-related performance outcomes of the U.S. criminal justice system will be limited.

section_title: Letter
paragraphs: In accordance with the Government Performance and Results Act of 1993,  the Department of Justice (DOJ) provides the Congress and the public  with an annual performance report. These annual performance reports  serve as an important mechanism of accountability and measure of DOJ’s  progress related to its strategic goals and objectives, including statistics on  its efforts to investigate and prosecute terrorist acts. A December 2001  Philadelphia Inquirer article alleged that DOJ had inflated terrorism  statistics in its Fiscal Year 2000 Performance Report to the Congress by  labeling cases as terrorism-related that involved crimes not generally  defined as terrorism. This article further alleged that DOJ had overstated  the number of terrorism-related convictions in its annual reports, in part,  to justify its budget request.
You asked us to examine how DOJ reports terrorism-related conviction  statistics. On September 17, 2002, we briefed your office on the results of  our review. This report summarizes and adds to the information presented  during that briefing. Specifically, we are providing information on (1) the  criteria DOJ’s Federal Bureau of Investigation (FBI) and Executive Office  for United States Attorneys (EOUSA) used to classify cases and any  resulting convictions as terrorism-related prior to fiscal year 2002;   (2) what effect, if any, the use of different classification systems had on  the number of convictions classified as terrorism-related prior to fiscal  year 2002; (3) the basis for the number of terrorism-related convictions in  DOJ’s Fiscal Year 2000 Performance Report; (4) whether FBI case files  contained documentation to support its terrorism-related classifications;  (5) the factors contributing to recent increases in terrorism-related  conviction statistics reported by EOUSA; and (6) whether DOJ has  sufficient management oversight and internal controls in place to ensure  the accuracy and reliability of terrorism-related statistics included in its  annual performance report.
subsections: section_title: Scope and Methodology
paragraphs: To address our objectives, among other things, we interviewed DOJ’s  Criminal Division, Justice Management Division, FBI, and EOUSA officials;  reviewed FBI’s and EOUSA’s policies and guidance for classifying cases;  researched terrorism definitions in the United States Code and Code of  Federal Regulations; compared FBI and EOUSA conviction data for fiscal  years 1997 through 2002; and reviewed conviction data included in DOJ’s  Fiscal Years 2000 and 2001 Performance Reports and similar data the 94  USAO districts had reported to EOUSA for fiscal year 2002.
Additionally, to determine whether documentation supported the FBI’s  classification of certain cases as terrorism-related, we reviewed  information in the FBI case files for 28 convictions. This included all 19  convictions that the FBI had classified as terrorism-related for fiscal years  1999 and 2000 in three FBI field offices (Baltimore, Dallas, and  Washington, D.C.). Additionally, concerning the 18 USAO terrorism- related convictions investigated by the FBI that were covered by the scope  of the Philadelphia Inquirer article, as requested by your staff, we  reviewed documentation in the FBI case files for all 9 convictions that  were classified by the FBI as terrorism-related. We did not review  investigative files for the remaining 9 convictions that were not classified  by the FBI as terrorism-related convictions because these cases were  classified under other categories (e.g., violent crime, National  Infrastructure Protection and Computer Intrusions, foreign  counterintelligence, and civil rights).
To determine the scope of USAO’s cases covered by the article, we  compared and analyzed EOUSA, FBI, and Transactional Records Access  Clearinghouse (TRAC) data, which the Philadelphia Inquirer had relied  on. We did not review cases that the FBI did not classify as terrorism- related or cases that were investigated by other law enforcement agencies.  We also did not attempt to review the appropriateness of the FBI’s  investigative activities. Rather, we sought to determine whether  documents in the case files detailing the investigative activities supported  a terrorism-related classification based on the FBI’s classification system.
Because of concerns we had with the significant increase in the total  number of USAO terrorism-related conviction statistics that resulted from  EOUSA’s efforts late in fiscal year 2002 to have USAO districts  retroactively identify cases relating to terrorism, we reviewed data  detailing specific statutory charges in these cases. Discrepancies we found  led to a request that EOUSA follow-up with all USAO districts reporting  four or more domestic or international terrorism-related convictions to  validate the accuracy of the districts’ reclassification efforts. The results of  EOUSA’s follow-up with these districts raise concerns about the accuracy  and reliability of EOUSA’s fiscal year 2002 statistics included in this report.
We conducted our work at FBI headquarters and EOUSA in Washington,  D.C., and at FBI field offices in Baltimore, Dallas, Philadelphia, and  Washington, D.C., between February and December 2002 in accordance  with generally accepted auditing standards.
section_title: Background
paragraphs: Multiple federal agencies have a role in U.S. efforts to combat terrorism.  The DOJ components primarily responsible for investigating and  prosecuting terrorism-related cases are the FBI and the USAOs. The FBI is  the lead federal agency responsible for investigating crimes for which it  has primary or concurrent jurisdiction and which involve terrorist  activities, or acts in preparation of terrorist activities, within the statutory  jurisdiction of the United States. The USAOs prosecute federal criminal  cases, including those related to terrorism.
There is no single, uniform definition of terrorism. Several federal statutes  define terrorism in a variety of contexts. Appendix I provides examples of  various statutory terrorism definitions. In addition to these statutory  definitions, the FBI has a regulatory definition of terrorism, which refers  to the “unlawful use of force and violence against persons or property to  intimidate or coerce a government, the civilian population, or any segment  thereof, in furtherance of political or social objectives.”
Although the FBI’s regulatory definition of terrorism relates to cases  involving the unlawful use of force or violence, this same regulation  designates the FBI as the lead federal agency for investigating both  terrorist activities and acts in preparation of terrorist activities. Thus, the  FBI may investigate cases that do not involve the use of force or violence  that may be terrorism-related (e.g., cases involving money laundering or  drug trafficking in support of a terrorist organization).
section_title: FBI and EOUSA Classification Criteria Differ
paragraphs: Prior to fiscal year 2002, the FBI and EOUSA’s criteria for classifying cases  and any resulting convictions differed. The FBI classified a case as  terrorism-related based on the overall violation being investigated. USAOs,  following EOUSA guidance, classified a case based on the charges in the  indictment or the charges for which the defendant was convicted. For  example, if the FBI arrested an individual for money laundering and, as  part of its investigation, gathered evidence that indicated that the  defendant was laundering money for a terrorist group, the FBI generally  classified such a case as terrorism-related. On the other hand, if a USAO  prosecuted the defendant and obtained a conviction solely on money  laundering charges, USAO generally classified the conviction in the case as  a money laundering conviction and not a terrorism conviction.
Although the FBI’s regulatory definition of terrorism refers to cases  involving force and violence, as previously noted, this same regulation also  designates the FBI as the lead agency responsible for investigating both  terrorist activities, and acts in preparation of terrorist activities, within the  statutory jurisdiction of the United States. Thus, a case need not involve  force or violence to be classified by the FBI as terrorism-related. For  example, the FBI may also classify nonviolent crimes (e.g., money  laundering and fraud) as terrorism-related if they are undertaken to  support terrorism-related activities. To capture and track the volume of its  counterterrorism work, the FBI used the classification criteria contained  in its Manual of Investigative Operations and Guidelines. The Manual,  among other things, set forth multiple classification codes for domestic  and international terrorism investigations and extensive guidance for  agents and squad supervisors to determine the appropriate classification  of an investigation.
As stated previously, at the time of the Philadelphia Inquirer’s allegation,  EOUSA used a classification system that was based on the charges in an  indictment or the charges for which a defendant were convicted. EOUSA’s  classification guidelines are set forth in the Legal Information On-line  System (LIONS) Users Manual. As outlined in the Manual, for an  international terrorism classification, EOUSA used a representative (but  not exhaustive) list of statutes that may relate to an international terrorist  incident, (e.g., 18 U.S.C. 32 relating to destruction of aircraft or aircraft  facilities and 18 U.S.C. 1203 relating to hostage taking). For a domestic  terrorism classification, the case must involve force or violence or the  threat of force or violence undertaken by an individual or group seeking to  further political or social goals.
EOUSA’s classification had no bearing on the FBI’s classification of a  conviction resulting from a terrorism-related investigation, according to an  FBI official. Occasionally, the FBI may reclassify a case when new facts  become available that were not known at the time of the original  classification.
section_title: Number of Reported FBI and EOUSA Terrorism-Related Convictions Differs
paragraphs: The FBI’s number of reported terrorism-related convictions will differ  from EOUSA’s because (1) the FBI and EOUSA had been using different  criteria to classify terrorism-related cases and resulting convictions and  (2) the FBI numbers include federal, state, local, or international court  convictions resulting from its investigative efforts while EOUSA’s numbers  include only federal court convictions. As shown in figure 1, the FBI has  reported a different number of terrorism-related convictions than EOUSA  over the past 6 fiscal years.
section_title: DOJ Used the FBI’s Terrorism-Related Statistics in Its 2000 Performance Report but Has Since Switched to Reporting EOUSA Statistics
paragraphs: In its Fiscal Year 2000 Performance Report provided to the Congress,  DOJ used the FBI’s number of terrorism-related investigations and  convictions. This report highlighted DOJ’s terrorism-related investigation  and prosecution accomplishments. As noted earlier, DOJ used the FBI’s  statistics because they track DOJ’s accomplishments beginning at the  investigative stage through the prosecutive stage.
In response to concerns raised by the Philadelphia Inquirer article and to  avoid any misinterpretation of DOJ’s statistics, beginning with the Fiscal  Year 2001 Performance Report, DOJ switched from using the FBI’s  statistics to using the statistics reported by EOUSA, according to DOJ  officials. EOUSA’s statistics are intended to be representative of the cases  prosecuted in federal courts that result in terrorism-related convictions  and are less likely to be misinterpreted, according to DOJ officials. These  statistics do not include cases for which the FBI had conducted a  terrorism-related investigation that resulted in (1) a conviction in a state,  local, or international court or (2) a federal conviction that was  investigated by the FBI as terrorism-related but not classified by EOUSA  as terrorism-related.
section_title: FBI Case Files Contained Documentation to Support Terrorism- Related Classifications
paragraphs: We reviewed FBI investigative case files to ascertain whether  documentation existed to support the FBI’s classification for 28 FBI  terrorism-related convictions included in our review. We found  documentation to support the FBI’s terrorism-related classifications for all  28 convictions. This included all of the convictions (19) that the FBI had  classified as terrorism-related for fiscal years 1999 and 2000 in three FBI  field offices (Baltimore, Dallas, and Washington, D.C.) and 9 of the 18  USAO terrorism convictions covered by the scope of the Philadelphia  Inquirer article that were investigated by the FBI.
Concerning the 18 USAO terrorism-related convictions investigated by the  FBI that were covered by the scope of the Philadelphia Inquirer article,  we found that the FBI had classified 9 of these cases as terrorism-related  and had documentation in every case file to support these classifications.  The FBI did not classify the remaining 9 convictions as terrorism-related  and as a result, we did not review those investigative case files. These  cases were classified under other categories (e.g., violent crime, National  Infrastructure Protection and Computer Intrusions, foreign  counterintelligence, and civil rights). Appendix II provides a summary of  the case files that we reviewed, including a description of the cases.
section_title: Several Factors Contributed to Recent Increases in EOUSA’s Number of Terrorism- Related Convictions
paragraphs: As figure 1 shows, EOUSA’s number of terrorism-related convictions  increased significantly in fiscal year 2002, going from an average of 35  convictions per fiscal year for the previous 5 years to about 160 in fiscal  year 2002. EOUSA attributed this increase to (1) the Attorney General’s  and the President’s direction to make antiterrorism efforts a priority and  heightened awareness, investigation, and prosecutorial efforts after  September 11, 2001, and (2) the implementation of a new EOUSA  classification system in fiscal year 2002, intended to better capture  terrorism-related efforts.
On November 8, 2001, the Attorney General announced plans to prioritize  the Justice Department and its components to focus on antiterrorism. The  Attorney General noted that the attacks of September 11, 2001, had  redefined the mission of DOJ. He described defending the nation and  defending the citizens of America against terrorist attacks as the  department’s first and overriding priority. On November 29, 2001, in a  speech at a U.S. Attorney’s conference, the President said that terrorist  violence on the home front must be prevented and defeated with vigilance,  aggressive investigation, and certain punishment.
In December 2001, EOUSA issued new procedures for classifying cases as  terrorism-related. Through these new procedures, EOUSA instructed all  USAO district offices to immediately begin using terrorism-related  program codes as the first code to identify and report on criminal and civil  matters and cases arising out of terrorist attacks on the U.S. In addition,  the policy memorandum added a new code to track terrorism-related  hoaxes that had not been previously tracked under the old classification  system. In an August 7, 2002, policy memo, EOUSA added a new code to  track terrorist financing, updated its guidance for classifying  international and domestic terrorism cases, and provided additional  procedures regarding how USAOs are to report terrorism-related cases.  In addition, the August 7, 2002, policy memo, instructed the various  USAOs to retroactively review the classification of cases opened or closed  during fiscal year 2002 to ensure that all cases related to or involving  terrorism-related activities were coded in LIONS and that the most  appropriate terrorism-related or antiterrorism-related criminal program  category code were used. This resulted in the reclassification of  convictions in USAO cases.
The new policy introduced changes to EOUSA’s classification system.   According to EOUSA officials, under the previous system cases were  classified based on the lead charge for which a defendant was indicted or  convicted. For example, if the lead conviction charge was money  laundering, the primary classification of the case would have been  classified as money laundering, even if terrorism-related purposes were  also evident during the investigation. Under the new system, a case of this  nature would result in the case being classified as a terrorism-related  conviction. The new case classification system accounts for evidence that  the crime was committed for terrorism-related purposes, as does the FBI’s  classification system.
section_title: DOJ Lacks Internal Controls to Ensure Reliability of EOUSA Terrorism-Related Statistics
paragraphs: Federal internal control standards require agencies to implement adequate  controls over information processing. A variety of control activities may  be used in information processing such as edit checks of data entered into  information systems, reconciliation of summary information to verify data  completeness, and management review of output reports. However,  during the course of our engagement, we discovered that DOJ does not  have sufficient management oversight and internal controls in place to  ensure the accuracy and reliability of terrorism-related conviction  statistics included in its annual performance reports.
We found that DOJ lacks a formal system, as required by federal internal  control standards, to verify the accuracy or oversee the reliability of case  data entered in LIONS by the various USAO districts and subsequently  included in DOJ’s annual performance reports. Specifically, as table 2  shows, the various USAO districts originally classified 288 convictions as  terrorism-related for fiscal year 2002. However, our subsequent request  that EOUSA follow-up with all USAO districts reporting four or more  domestic or international terrorism-related convictions to validate the  accuracy of the districts’ reclassification efforts revealed that at least 132  of the 288 (about 46 percent) USAO convictions were misclassified. These  132 cases did not result in terrorism-related convictions.  127 of the 132  were subsequently reclassified as anti-terrorism-related convictions. The  remaining 5 were reclassified as related to other types of crimes. These  discrepancies occurred despite a semiannual effort by EOUSA requiring  managers in the various USAO districts to certify the accuracy of case  data.
EOUSA officials attributed the discrepancies we found with the fiscal year  2002 statistics to limited time afforded the various USAOs to thoroughly  reevaluate caseload and investigative data during their efforts to  retroactively reclassify and identify convictions in closed terrorism-related  cases dating back to the beginning of the fiscal year. Because EOUSA did  not validate the accuracy of the terrorism-related conviction data reported  by the remaining USAO districts, we have some concerns about the overall  accuracy of EOUSA conviction statistics to be included in DOJ’s Fiscal  Year 2002 Annual Performance Report.
section_title: Conclusions
paragraphs: Efforts on the part of EOUSA to implement new procedures to better  ensure that DOJ prosecutors fully account for their efforts to combat  terrorism-related activities are commendable. However, because the  Congress and the American public rely on DOJ, in accordance with the  Government Performance and Results Act, to provide annual performance  data on the progress of its efforts to combat terrorism, it is equally  important that the various USAOs accurately account for their efforts and  not misclassify cases as terrorism-related that are not terrorism-related.  Without reliable terrorism-related conviction data, DOJ and the Congress’s  ability to accurately assess terrorism-related performance outcomes of our  criminal justice system and the results of efforts to combat terrorism will  be limited. Discrepancies discovered in the accuracy of fiscal year 2002  terrorism-related conviction statistics that the USAO districts had initially  provided to EOUSA raise concerns about the overall quality and reliability  of EOUSA terrorism-related conviction statistics. In addition, these  discrepancies identify the need for improvements in management  oversight and internal controls to better ensure the accuracy of USAO  terrorism-related performance data.
section_title: Recommendation for Executive Action
paragraphs: To improve the accuracy and reliability of terrorism-related conviction  statistics reported by DOJ in its annual performance reports, we  recommend that the Attorney General, in accordance with federal internal  control standards, implement a formal system to oversee and validate the  accuracy of case classification and conviction data entered in LIONS by  the various USAO districts. This system should entail edit checks of data  entered into information systems, reconciliation of summary information  to verify data completeness, and management review of output reports.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided copies of this report to the Attorney General and the Director  of the FBI. DOJ and the FBI agreed with the report findings and DOJ  agreed to implement our recommendation.
Unless you publicly announce the contents of this report earlier, we plan  no further distribution until 30 days from the issuance date. At that time,  we will send copies of this report to the Attorney General, the Director of  the FBI, and other interested parties. We will also make copies available to  others upon request. In addition, the report will be available at no charge  on the GAO Web site at http://www.gao.gov.
If you or your staff have any questions about this report, please contact  Charles Michael Johnson or me at (202) 512-8777 or at  johnsoncm@gao.gov or ekstrandl@gao.gov. Key contributors to this report  are acknowledged in appendix III.
section_title: Appendix I: Summaries of Selected Statutory Terrorism Definitions
subsections: section_title: U.S. Code Citation 8 U.S.C. 1182(a)(3)(B)(iii),(iv) Generally defines ‘‘terrorist activity’’ as an unlawful activity, undertaken with the intent to endanger
paragraphs: the safety of one or more individuals or to cause substantial damage to property, which involves the  hijacking or sabotaging of any conveyance; hostage-taking; violent attacks upon internationally  protected persons; assassinations; the use of weapons or dangerous devices, including explosives,  firearms, biological, chemical, or nuclear weapons; or a threat, attempt, or conspiracy to do any of  the foregoing. The statute further defines the term “engage in terrorist activity”— conduct that can  render an alien inadmissible to the United States. The term encompasses not only the commission  of terrorist activities, but a broad range of conduct in support of terrorist activities, generally involving  such things as preparation or planning; gathering information on potential targets; soliciting funds or  members, or affording material support.  Generally defines terrorism as unlawful acts that are dangerous to human life and that appear  intended to intimidate or coerce a civilian population; to influence the policy of a government by  intimidation or coercion; or to affect the conduct of a government by mass destruction, assassination,  or kidnapping. Terrorism may be domestic or international under 18 U.S.C. 2331 depending on  whether the crime occurred primarily outside or within the territorial jurisdiction of the United States,  or whether the crime transcended national boundaries in certain respects defined by the statute.  Lists numerous offenses in defining the term “Federal crime of terrorism” where the offense was  calculated to influence or affect the conduct of government by intimidation or coercion or to retaliate  against government conduct.  Defines “terrorism” for purposes of the State Department’s annual country reports as premeditated,  politically motivated violence perpetrated against noncombatant targets by subnational groups or  clandestine agents. Further defines “international terrorism” as terrorism involving citizens or the  territory of more than one country.  Defines an “act of international terrorism” for purposes of the State Department’s rewards program  as any act substantially contributing to the acquisition of unsafeguarded special nuclear material or  any nuclear explosive device by individuals, groups, or non-nuclear weapon states, or any act that  materially supports the conduct of international terrorism, including the counterfeiting of U.S.  currency or the illegal use of other monetary instruments.
section_title: Appendix II: Summary of Case Files GAO Reviewed
paragraphs: The following table provides a summary of Federal Bureau of  Investigation (FBI) field office case files we reviewed for 28 convictions to  determine whether documentation existed to support the FBI’s  classification of these cases.
Summary of case  This case involved a joint FBI and  Immigration and Naturalization Service  task force in which the defendant was  arrested for harboring an illegal alien.  During the investigation, the FBI  uncovered evidence (i.e., telephone  records and wire transfers) linking the  defendant to a known associate of Usama  bin Laden who was connected to the U.S.  Embassy bombings in Kenya and  Tanzania.   This case involved a man who was  deported from the United States in 1997  for counterfeiting, but who had returned to  the United States and owned and  operated convenience stores in Texas.  The FBI investigated him for laundering  money, using stolen and fraudulent credit  cards, and shipping generators to a  Middle Eastern country, in violation of a  U.S. embargo.   The case involved two brothers who were  arrested in a joint FBI/Bureau of Alcohol,  Tobacco and Firearms operation in which  the men were attempting to purchase  automatic weapons and deal guns without  a license. During the investigation, FBI  agents learned that the men were  originally from India and were associated  with a violent Sikh faction.  This case involved a foreign national and  his son who had attempted to enter an  agreement with a Middle Eastern country  to build an electrical power plant in  violation of a U.S. embargo on doing  business with this country. The State  Department had designated this country  as a sponsor of terrorism.  In this case, a juvenile made a threat to  bomb FBI headquarters in Washington,  D.C.
Summary of case  Four defendants were investigated for  purchasing and shipping dozens of  weapons from various U.S. locations to  the United Kingdom and Northern Ireland.  The weapons were purchased at various  gun shows, shops and from individual  person. The defendants were citizens of  the United Kingdom and the Republic of  Ireland, and one of the defendants had  claimed membership in the Irish  Republican Army. Among other items  found by investigators, was literature on  the Irish Republican Army. The Anti- terrorist branch of New Scotland Yard  opened this investigation and contacted  the FBI.  This case involved a defendant that made  bomb threats against a federal  government facility in New Jersey. FBI  agents found that the defendant had  made a pipe bomb.   This case involved a man who made a  biological bomb threat against a U.S.  courthouse in Pennsylvania. A Joint  Terrorism Task Force investigated this  case.  This case involved a man who mailed  letters including the words, “Anthrax,  Anthrax, Anthrax” to his former place of  employment.  This case involved a defendant who fired  20 shots to the Pacific Gas and Electric  power substation in Redwood City. His  actions eliminated power in the immediate  area and caused over $500,000 in  damage. The suspect was described as a  possible terrorist member and to have  protested the Oklahoma City trial.  This case involved a defendant who made  death threats against a U.S. Magistrate  Judge and two other individuals. The  defendant belonged to a group that refers  to themselves as Cypherfunks who  advocate the overthrow of established  governments via crypto-anarchy.
section_title: Appendix III: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contacts
section_title: Acknowledgments
paragraphs: Chan My J. Battcher, Christopher Conrad, Christine F. Davis,  Michele Fejfar, Melissa Hinton, Anne E. Laffoon, and Kay Muse made key  contributions to this report.