U.S. Department of Justice: Opportunities Exist to Strengthen the Civil Rights Division's Ability to Manage and Report on Its Enforcement Efforts
Published: 2009-12-03T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Civil Rights Division (Division) of the Department of Justice (DOJ) is the primary federal entity charged with enforcing federal statutes prohibiting discrimination on the basis of race, sex, disability, religion, and national origin (i.e., protected classes). The Government Accountability Office (GAO) was asked to review the Division's enforcement efforts and its Interactive Case Management System (ICM). This testimony addresses (1) the activities the Division undertook from fiscal years 2001 through 2007 to implement its enforcement responsibilities through its Employment Litigation, Housing and Civil Enforcement, Voting, and Special Litigation sections, and (2) additional data that could be collected using ICM to assist in reporting on the four sections' enforcement efforts. This statement is based on GAO products issued in September and October 2009.
section_title: What GAO Found
paragraphs: From fiscal years 2001 through 2007, the Civil Rights Division initiated matters and filed cases to implement its enforcement responsibilities through the four sections. The Employment Litigation Section initiated 3,212 matters and filed 60 cases as plaintiff under federal statutes prohibiting employment discrimination. Most matters (3,087) were referred by other agencies. Of the 11 pattern or practices cases--cases that attempt to show that the defendant systematically engaged in discriminatory activities--9 involved claims of discrimination in hiring and the most common protected class was race (7). The Housing and Civil Enforcement Section initiated 947 matters and participated in 277 cases under federal statutes prohibiting discrimination in housing, credit transactions, and certain places of public accommodation. Most (456 of 517) Fair Housing Act (FHA) matters were initiated under its pattern or practice authority, primarily alleging discrimination on the basis of race or disability and involving land use/zoning/local government or rental issues. Most (250 of 269) cases filed as plaintiff included an FHA claim. The FHA cases primarily involved rental issues (146) and alleged discrimination on the basis of disability (115) or race (70). The Voting Section initiated 442 matters and filed 56 cases to enforce federal statutes that protect the voting rights of racial and language minorities, and disabled and illiterate persons, among others. The Section initiated most matters (367) and filed a majority of cases (39) as plaintiff under the Voting Rights Act, primarily on behalf of language minority groups (246 and 30). The Special Litigation Section initiated 693 matters and filed 31 cases as plaintiff to enforce federal civil rights statutes on institutional conditions (e.g., protecting people in nursing homes), the conduct of law enforcement agencies, access to reproductive health facilities and places of worship, and the exercise of religious freedom of institutionalized persons. The largest number of matters initiated and closed (544 of 693) involved institutional conditions (373), as did the cases filed (27). Information on the specific protected classes and subjects related to matters and cases and the reasons for closing matters were not systematically maintained in ICM because the Division did not require sections to capture these data. As a result, the availability and accuracy of these data varied among the sections. For example, the Employment Litigation Section did not capture protected class and subject data for more than 80 percent of its matters. In contrast, these data were consistently recorded in ICM for the Housing and Civil Enforcement Section, which requires that protected class and subject data be recorded in ICM. In addition, congressional committees have requested information on reasons the Division did not pursue matters, including instances in which Division managers did not approve a section's recommendation to proceed with a case. However, ICM does not include a discrete field for capturing the reasons that matters are closed and Division officials we interviewed could not identify instances in which Division managers did not approve a section's recommendation to proceed with a case. By requiring sections to record such information, the Division could strengthen its ability to account for its enforcement efforts.

section_title: Letter
paragraphs: I am pleased to be here today to discuss the enforcement efforts of the  Civil Rights Division’s (Division) Employment Litigation, Housing and Civil  Enforcement, Voting, and Special Litigation sections from fiscal years  2001 through 2007, as well as the case management system the Division  uses to track and manage these efforts. Established after the passage of  the Civil Rights Act of 1957, the Division of the Department of Justice  (DOJ) is the primary federal entity charged with enforcing federal statutes  prohibiting discrimination on the basis of race, sex, disability, religion, and  national origin. The Division’s mission has expanded to include the  enforcement of laws prohibiting discrimination in employment, housing,  voting, public accommodations, education, and the rights of  institutionalized persons. To carry out these broad enforcement  responsibilities, the Division initiates thousands of matters (e.g., an  investigation of a complaint or an allegation of discrimination referred by  another federal agency) and hundreds of cases each year. In October 2000,  the Division implemented the Interactive Case Management System (ICM)  as its official system to track, count, and capture performance  measurement information for all matters and cases from their inception to  their conclusion and to assist staff in their casework. According to  Division documentation, ICM was also designed to serve as a tool for  senior management to oversee the Division’s work and to assist senior  managers in, among other things, reporting accurate matter and case data  at all levels of the organization, improving accountability, and responding  to congressional inquiries about the work of the Division.
In September 2000, we reported on the reasons that the Division’s  Employment Litigation, Housing and Civil Enforcement, and Voting  sections pursued a selection of cases and closed a selection of matters.  We stated that legal merit (i.e., the strength of evidence in a case) was the  predominant reason in the Sections’ decisions to pursue allegations of  discrimination as cases. We also reported that the reasons generally given  for closing a matter were, among others, insufficient evidence to support  allegations and corrective action was taken by the jurisdiction  investigated. In addition, in February and September 2000, we reported on  how the Division tracked and managed matters and cases using its Case  Management System and described the new system—ICM—that the  Division was implementing at the time of our review. In March 2006, DOJ  began the Litigation Case Management System (LCMS) project, intended  to replace litigating components’ individual case management systems,  including ICM, with a single, integrated case management system for DOJ.  However, as of September 2009, DOJ was uncertain if LCMS would be  implemented in six of the seven litigating components, including the  Division, raising questions as to whether the Division will need to continue  to rely on ICM.
My comments are based on our October and September 2009 reports on  the enforcement efforts of the four sections within the Division and the  case management system the Division uses to track and manage these  efforts. My testimony will discuss the following key issues in our reports:  (1) the activities that the Division undertook from fiscal years 2001  through 2007 to implement its enforcement responsibilities through each  of the four sections and (2) additional data that could be collected using  ICM to assist in reporting on the sections’ enforcement efforts. Our  September 2009 report also includes a discussion on the extent to which  the Division has conducted and documented assessments of ICM’s  performance since its implementation.
For our reports, we analyzed DOJ documents, such as annual reports,  hearing statements, speeches, and budget documents, that described the  Division’s enforcement efforts (including special initiatives and areas of  focus) from fiscal years 2001 through 2007. We also analyzed data from  ICM on the matters initiated and cases pursued by each section for the 7- year period. We assessed the accuracy, completeness, and reliability of  ICM data by analyzing data on matters initiated and closed and cases  pursued by the four sections from fiscal years 2001 through 2007. To  supplement our analysis and further assess the reliability of the data, we  compared ICM data with information contained in documentation, such as  correspondence included in files, for a nongeneralizable sample of closed  matters from ICM data for each of the four sections. Because our samples  were not representative, we were unable to generalize the results to all  closed matters the sections investigated during the period of our review.  Nevertheless, our file reviews provided examples of how the ICM matter  data compared to the same information in the matter files, how the  sections investigated matters, and why the sections closed them. We  interviewed senior officials in DOJ’s Justice Management Division, which  is the management arm of DOJ; the Acting Assistant Attorney General for  the Division; and Division information technology officials, who are the  Division officials responsible for managing and maintaining ICM. We also  interviewed section chiefs, deputy chiefs, and other section staff to obtain  information on the four sections’ enforcement efforts during the 7-year  period and how they used ICM to manage and report on these efforts. We  conducted this work in accordance with generally accepted government  auditing standards. More detail about our scope and methodology is  included in our September 2009 and October 2009 reports.
subsections: section_title: Information on Employment Litigation, Housing and Civil Enforcement, Voting, and Special Litigation Sections’ Enforcement Efforts from Fiscal Years 2001 through 2007
subsections: section_title: Employment Litigation Section
paragraphs: From fiscal years 2001 through 2007, the Employment Litigation Section  initiated more than 3,200 matters and filed 60 cases as plaintiff under  federal statutes prohibiting employment discrimination. About 90 percent  of the matters initiated (2,846 of 3,212) and more than half of the cases  filed (33 of 60) alleged violations of section 706 of Title VII of the Civil  Rights Act, which involves individual claims of employment  discrimination. Much of the Section’s matters are driven by what the  Section receives from other agencies. During the 7-year period, about 96  percent of the matters (3,087 of 3,212) initiated were as a result of referrals  from the Equal Employment Opportunity Commission and the Department  of Labor. The number of matters initiated under section 706 and the  Uniformed Services Employment and Reemployment Rights Act  (USERRA) declined in the latter fiscal years, which a Section Chief  attributed to a decline in referrals from these two agencies. In addition to  addressing discrimination against individuals, the Section also initiated  more than 100 pattern or practice matters at its own discretion. Because  the Section did not require staff to maintain information in ICM on the  subjects (e.g., harassment and retaliation) of the matters or the protected  class (e.g., race and religion) of the individuals who were allegedly  discriminated against, we could not determine this information for more  than 80 percent of the matters the Section closed from fiscal years 2001  through 2007. According to Section officials, staff are not required to do so  because the Section does not view this information as necessary for  management purposes. The Section also does not systematically collect  information in ICM on the reasons matters were closed; therefore, we  were not able to readily determine this information for the approximately  3,300 matters the Section closed over the time period of our review.  Division officials stated that when planning for ICM’s implementation with  Section officials, the Division did not consider requiring sections to  provide protected class and subject data or the need to capture in ICM the  reasons that matters are closed. However, by conducting interviews with  agency officials and reviewing files for a nongeneralizable sample of 49  closed matters, we were able to determine that the reasons the Section  closed these matters included, among others, the facts in the file would  not justify prosecution, the issue was pursued through private litigation,  and the employer provided or offered appropriate relief on its own.
In addition to the matters initiated, the Employment Litigation Section  filed 60 cases in court as plaintiff from fiscal years 2001 through 2007, and  filed more than half (33 of 60) under section 706 of Title VII. According to  a Section Chief and Deputy Section Chief, the primary reason for pursuing  a case was that the case had legal merit. Other priorities, such as those of  the Assistant Attorney General, may also influence the Section’s decision  to pursue particular kinds of cases. For example, according to Section  officials, following the terrorist attacks of September 11, 2001, the  Assistant Attorney General asked the various sections within the Division  to make the development of cases involving religious discrimination a  priority. During the 7-year period, the majority of the section 706 cases (18  of 33) involved sex discrimination against women, and one-third (11 of 33)  involved claims of race discrimination, with six cases filed on behalf of  African Americans and five cases filed on behalf of whites. In addition to  these 33 cases, the Section filed 11 pattern or practice cases. Most of the  11 pattern or practice cases involved claims of discrimination in hiring (9  of 11) and the most common protected class was race (7 of 11), with four  cases filed on behalf of African Americans, two on behalf of whites, and  one on behalf of American Indians or Alaska Natives. In July 2009,  Section officials told us that given that the Assistant Attorneys General  who authorized suits from fiscal years 2001 through 2007 and the Section  Chief who made suit recommendations to the Assistant Attorneys General  during that period are no longer employed by DOJ, it would be  inappropriate for them to speculate as to why the Section focused its  efforts in particular areas.
section_title: Housing and Civil Enforcement Section
paragraphs: From fiscal years 2001 through 2007, the Housing and Civil Enforcement  Section initiated 947 matters and participated in 277 cases under federal  statutes prohibiting discrimination in housing, credit transactions, and  certain places of public accommodation (e.g., hotels). The Section has the  discretion to investigate matters and bring cases under all of the statutes it  enforces, with the exception of certain cases referred under the Fair  Housing Act (FHA) from the Department of Housing and Urban  Development (HUD), which the Section is statutorily required to file. The  Section, however, has discretion about whether to add a pattern or  practice allegation to these HUD-referred election cases, if supported by  the evidence. Furthermore, the Section has the authority and discretion to  independently file pattern or practice cases and to pursue referrals from  other sources. During the 7-year period, the Section initiated more matters  (517 of 947) and participated in more cases (257 of 277) involving  discrimination under the FHA than any other statute or type of matter or  case. The Section initiated nearly 90 percent of the FHA matters (456 of  517) under its pattern or practice authority; these primarily alleged  discrimination on the basis of race or disability and involved land  use/zoning/local government or rental issues. According to Section  officials, the large number of land use/zoning/local government matters it  initiated was due to the Section regularly receiving referrals from HUD  and complaints from other entities on these issues. Additionally, Division  officials identified that a Section priority during the 7-year period was to  ensure that zoning and other regulations concerning land use were not  used to hinder the residential choices of individuals with disabilities.  During this time, the Section experienced a general decline in HUD  election matters, with the Section initiating the fewest number of total  matters, 106, in fiscal year 2007. Section officials attributed the decrease,  in part, to a decline in HUD referrals because state and local fair housing  agencies were handling more complaints of housing discrimination instead  of HUD. The Section initiated the second largest number of matters (252 of  947) under the Equal Credit Opportunity Act (ECOA). About 70 percent  (177 of 252) of these ECOA matters included allegations of discrimination  based on age, marital status, or both.
The majority (250 of 269) of the cases that the Section filed as plaintiff  included a claim under the FHA. Similar to the Employment Litigation  Section, the Housing Section considers legal merit and whether the  plaintiff has the resources to proceed on his or her own should the Section  choose not to get involved, among other reasons, when deciding whether  to pursue a matter as a case. The number of cases filed by the Section each  year generally decreased from fiscal years 2001 through 2007—from 53 to  35—which, similar to matters, Section officials generally attributed to  fewer HUD referrals. The FHA cases primarily involved rental issues  (146). According to Section officials, the number of rental-related issues is  reflective of larger national trends in that discrimination in rental housing  may be more frequently reported or easier to detect than in home sales.  Most of the FHA cases alleged discrimination on the basis of disability  (115) or race (70)—66 of which involved racial discrimination against  African Americans. The Section filed 9 cases under ECOA, of which 5 were  in combination with the FHA. All 9 complaints involved lending issues.  Seven of the 9 complaints included at least one allegation of racial  discrimination and 4 included at least one allegation of discrimination on  the basis of national origin/ethnicity.
section_title: Voting Section
paragraphs: From fiscal years 2001 through 2007, the Voting Section initiated 442  matters and filed 56 cases to enforce federal statutes that protect the  voting rights of racial and language minorities, disabled and illiterate  persons, and overseas and military personnel, among others. The Voting  Section has the discretion to initiate a matter or pursue a case under its  statutes, with the exception of the review of changes in voting practices or  procedures, which it is statutorily required to conduct under section 5 of  the Voting Rights Act (VRA). According to Section officials, the Section  had as its priority the enforcement of all the statutes for which it was  responsible throughout the period covered by our review. However,  Section and Division officials identified shifts in the Section’s priorities  beginning in 2002. For example, the Assistant Attorney General in place  from November 2005 through August 2007 stated that since 2002, the  Section had increased its enforcement of the minority language provisions  of the VRA and instituted the most vigorous outreach efforts to  jurisdictions covered by the minority language provisions of the act.  During the 7-year period, the Section initiated nearly 70 percent of VRA  matters (246 of 367) on behalf of language minority groups, primarily  Spanish speakers (203 of 246). The Section also initiated 162 matters under  section 2 of the VRA. The Section initiated about half of these matters on  behalf of language minority groups (80), primarily Spanish speakers (71),  and about half on behalf of racial minorities (88 of 162), primarily African  American voters (71 of 88).
During the 7-year period, the Voting Section filed 56 cases, primarily under  the VRA (39). The majority of the cases the Section filed in court under  the VRA were on behalf of language minority groups (30 of 39), primarily  Spanish speakers (27). The Acting Assistant Attorney General reported in  September 2008 that the Division had brought more cases under the VRA’s  minority language provisions during the past 7 years—a stated priority— than in all other years combined since 1975. While cases involving  language minority groups were filed under various VRA provisions, the  largest number of cases (24 of 30) involved claims under section 203  alleging that the covered jurisdiction had failed to provide voting-related  materials or information relating to the electoral process in the language  of the applicable minority group. The Section filed 13 cases involving a  claim under section 2 of the VRA––5 on behalf of language minority groups  and 10 on behalf of racial minority groups (6 on behalf of Hispanics, 3 on  behalf of African Americans, and 1 on behalf of whites). In October 2007,  the Section Chief who served from 2005 through late 2007 told us that  while at-large election systems that discriminated against African  Americans remained a priority of the Section, not many of these systems  continued to discriminate, and new tensions over immigration had  emerged; therefore, the Section had been pursuing cases of voting  discrimination against citizens of other minority groups. However, in  September 2009, Voting Section officials stated that while many at-large  election systems that diluted minority voting strength have been  successfully challenged, the Section continued to identify such systems  that discriminate against African American, Hispanic, and Native American  residents in jurisdictions throughout the country and that taking action  against at-large election systems remained a high priority for the Section.  The Section also carried out its responsibilities under section 5 of VRA,  which requires certain jurisdictions covered under the act to “preclear”  changes to voting practices and procedures with DOJ or the United States  District Court for the District of Columbia to determine that the change  has neither the purpose nor the effect of discriminating against protected  minorities in exercising their voting rights. The Section reported that over  the 7-year period it made 42 objections to proposed changes, of which  almost 70 percent (29 of 42) involved changes to redistricting plans. More  than half (17) of the 29 objections were made in fiscal year 2002, following  the 2000 census, and two were made from fiscal years 2005 through 2007.
section_title: Special Litigation Section
paragraphs: From fiscal years 2001 through 2007, the Special Litigation Section  initiated 693 matters and filed 31 cases as plaintiff to enforce federal civil  rights statutes in four areas––institutional conditions (e.g., protecting  persons in nursing homes), conduct of law enforcement agencies (e.g.,  police misconduct), access to reproductive health facilities and places of  worship, and the exercise of religious freedom of institutionalized  persons. Because the Section had discretion to pursue an investigation or  case under all of the statutes it enforced, it considered all of its work to be  self-initiated. Of the matters initiated and closed (544 of 693), most  involved institutional conditions (373) and conduct of law enforcement  agencies (129).
Of the 31 cases that the Section filed as plaintiff, 27 alleged a pattern or  practice of egregious and flagrant conditions that deprived persons  institutionalized in health and social welfare (13), juvenile corrections (7),  and adult corrections (7) facilities of their constitutional or federal  statutory rights, and 3 cases involved the conduct of law enforcement  agencies. According to Section officials, in deciding whether or not to  pursue a case, they considered the conditions in a particular facility or  misconduct of a particular police department and whether the system  (e.g., state correctional or juvenile justice system) or department alleged  to have violated the statute had taken corrective action or instead had  accepted the behavior in question as its way of doing business. However,  they said that even if the system or department were taking corrective  action, the Section might pursue a case depending on the severity of the  situation (e.g., sexual abuse) or if Section officials believed that the facility  or local entity were incapable of addressing the problem. Additionally,  according to Section officials, the Section sought to ensure its work  reflected geographic diversity. Our analysis of the 31 plaintiff cases  showed that the Section had filed cases in 21 states and the District of  Columbia. During the 7-year period, the Section did not file any cases  involving violations of the exercise of religious freedom of  institutionalized persons under the Religious Land Use and  Institutionalized Persons Act (RLUIPA). Section officials stated that there  was a time when the Section’s enforcement of RLUIPA was directed to be  a lower priority than its enforcement of other statutes. However, in April  2009, these officials told us that the Section was reviewing a number of  preliminary inquires under RLUIPA, but had not yet filed any complaints  because it was still investigating these matters.
section_title: By Requiring Sections to Collect Data on Protected Class, Subject, and Reasons for Closing Matters in Its Case Management System, the Division Could Provide Better Accountability to Congress on Its Enforcement Efforts
paragraphs: As previously discussed, information regarding the specific protected  classes and subjects related to matters and cases and the reasons for  closing matters were not systematically maintained in ICM because the  Division did not require Sections to capture these data. As a result, the  availability and accuracy of protected class and subject data—information  that is key to ensuring that the Division executes its charge to enforce  statutes prohibiting discrimination on the basis of protected class—varied  among the sections. Additionally, neither we nor the Sections could  systematically identify the Sections’ reasons for closing matters, including  the number of instances in which the Section recommended to proceed  with a case and Division management did not approve the Section’s  recommendation.
By collecting additional data on protected class and subject in ICM, the  Division could strengthen its ability to account for the four sections’  enforcement efforts. In October 2006, the Principal Deputy Assistant  Attorney General issued a memorandum to section chiefs stating that  Division leadership relies heavily on ICM data to, among other things,  report to Congress and the public about its enforcement efforts, and  should be able to independently extract the data from ICM needed for this  purpose. However, over the years, congressional committees have  consistently requested information for oversight purposes related to data  that the Division does not require Sections to collect in ICM, including  information on the specific protected classes and subjects related to  matters and cases. While ICM includes fields for collecting these data, the  Division has not required sections to capture these data. Some section  officials said that they did not believe it was necessary to maintain this  information in ICM for internal management purposes. As a result, we  found that the availability and accuracy of these data varied among the  sections. For example, when comparing data obtained from the 60  complaints the Employment Litigation Section filed in court with data  maintained in ICM, we identified that the protected class and subject data  in ICM were incomplete or inaccurate for 12 and 29 cases, or about 20 and  48 percent, respectively. Additionally, we found that the Section’s  protected class and subject data were not captured in ICM for 2,808 and  2,855 matters, or about 83 and 85 percent, respectively. In contrast,  according to the Housing and Civil Enforcement Section, it requires that  protected class and subject data be recorded in ICM for all matters and  cases, and we found that these data were consistently recorded in ICM.
To help respond to information inquiries, all four sections maintain data in  ancillary data systems, although some of the data are also recorded in  ICM. For example, the Employment Litigation Section maintains broad  information on protected class and uses this information in conjunction  with data in ICM to report on its enforcement efforts. Section officials  reported using ancillary data systems in part because it was easier to  generate customized reports than using ICM. We previously reported that  agencies with separate, disconnected data systems may be unable to  aggregate data consistently across systems, and are more likely to devote  time and resources to collecting and reporting information than those with  integrated systems. Requiring sections to record these data in ICM would  assist the Division in, among other things, responding to inquiries from  Congress by ensuring access to readily available information and by  reducing reliance on ancillary data systems.
Additionally, congressional committees have requested information  regarding reasons the Division did not pursue matters, including instances  in which Division managers did not approve a section’s recommendation  to proceed with a case. However, ICM does not include a discrete field for  capturing the reasons that matters are closed and Division officials we  interviewed could not identify instances in which Division managers did  not approve a section’s recommendation to proceed with a case.  Moreover, sections do not maintain this information in other section-level  information systems. ICM does have a comment field that sections can use  to identify the reasons matters are closed, although these data are not  required or systematically maintained in ICM and the Division could not  easily aggregate these data using the comment field. According to  Division officials, when Division and section officials were determining  which data were to be captured in ICM, they did not consider the need to  include a discrete field to capture the reasons that matters were closed. As  a result, we had to review Division matter files to determine the reasons  that matters were closed, and in some instances this information was not  contained in the files. For example, for 7 of the 19 section 706 closed  matter files we reviewed for the Employment Litigation Section, the  reason the matter was closed was not contained in the file documentation  we received, and Section officials attributed this to a filing error.  Moreover, Division officials stated that because the Division did not track  the reasons for closing matters in ICM, they have had to review files and  talk with section attorneys and managers to obtain this information. They  said that it was difficult to compile this information because of turnover  among key section officials. Capturing information on the reasons matters  were closed in the Division’s case management system would facilitate the  reporting of this information to Congress and enable the Division to  conduct a systematic analysis of the reasons that matters were closed.  This would also help the Division to determine whether there were issues  that may need to be addressed through actions, such as additional  guidance from the Division on factors it considers in deciding whether to  approve a section’s recommendation to pursue a case.
In our September 2009 report, we recommended that to strengthen the  Division’s ability to manage and report on the four sections’ enforcement  efforts, the Acting Assistant Attorney General of the Division, among other  things, (1) require sections to record data on protected class and subject in  the Division’s case management system in order to facilitate reporting of  this information to Congress, and (2) as the Division considers options to  address its case management system needs, determine how sections  should be required to record data on the reasons for closing matters in the  system in order to be able to systematically assess and take actions to  address issues identified. DOJ concurred with our recommendations and,  according to Division officials, the Division plans to (1) require sections  divisionwide to record data on protected class and subject/issue in its case  management system by the end of calendar year 2009 and (2) upgrade the  system to include a field on reasons for closing matters and require  sections divisionwide to record data in this field.
Mr. Chairman, this concludes my statement. I would be pleased to respond  to any questions that you or other members of the subcommittee may  have.
section_title: Contacts and Acknowledgements
paragraphs: For questions about this statement, please contact Eileen R. Larence at  (202) 512-8777 or larencee@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this statement. Individuals making key contributions to this testimony  are Maria Strudwick, Assistant Director, David Alexander; R. Rochelle  Burns; Lara Kaskie; Barbara Stolz; and Janet Temko.
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