Federal Bureau of Investigation: Accountability over the HIPAA Funding of Health Care Fraud Investigations Is Inadequate
Published: 2005-04-22T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Health Insurance Portability and Accountability Act of 1996 (HIPAA) provided, among other things, funding by transfer to the Federal Bureau of Investigation (FBI) to carry out specific purposes of the Health Care Fraud and Abuse Control Program. Congress expressed concern about a shift in FBI resources from health care fraud investigations to counterterrorism activities after September 11, 2001. Congress asked GAO to review FBI's accountability for the funds transferred under HIPAA for fiscal years 2000 through 2003. GAO determined (1) whether FBI had an adequate approach for ensuring the proper use of the HIPAA transfers and (2) the extent to which FBI had expended these transferred funds on health care fraud investigations in fiscal years 2000 through 2003.
section_title: What GAO Found
paragraphs: FBI used a limited approach to monitoring its use of HIPAA transfers, which might have been sufficient during times when it clearly used more agent full time equivalents (FTEs) for health care fraud investigations than budgeted but was insufficient when some of the agent FTEs previously devoted to health care fraud investigations were shifted to counterterrorism activities. FBI's budgeted FTEs (agent and other personnel) and related costs (such as rent and utilities) were equivalent to the amount of the HIPAA transfers. However, FBI's approach to monitoring the use of HIPAA transfers considered only agent FTEs, which made up about 42 percent of the budgeted health care fraud costs, but did not consider other personnel FTEs or related costs. According to FBI officials, they did not monitor these other budgeted amounts to determine compliance with HIPAA because the actual agent FTEs were historically far in excess of those budgeted. However, once FBI began to shift agent resources away from health care fraud investigations, agent FTEs charged to health care fraud investigations fell below the budgeted amounts, and FBI could no longer rely on this limited approach to ensure that the transferred HIPAA funds were properly used. Furthermore, FBI did not have a system in place to capture its overall health care fraud investigation costs, and therefore, was not in a position to determine whether or not all transferred HIPAA funds were properly expended. In response to GAO's review, FBI engaged in extensive manual efforts to develop cost estimates related to health care fraud investigations for fiscal years 2000 through 2003. The final estimate provided to GAO showed that FBI spent more on health care fraud investigations than was funded by transfers for each of the 4 years. However, GAO found that, overall, FBI's estimates of its health care fraud investigation costs were based on data that had not been or could not be fully validated. Therefore, even though FBI made a good-faith effort to estimate these costs, because of data limitations, neither GAO nor FBI could reliably determine whether all of the HIPAA transfers were spent solely for health care fraud investigations and related activities for the 4-year period. DOJ is currently planning the implementation of a new DOJ-wide UFMS, but it has yet to develop the specific systems requirements that would enable FBI to accurately capture all of its health care fraud-related costs and therefore to help monitor compliance with HIPAA and other relevant laws and regulations.

section_title: Letter
paragraphs: In 1996 the Congress passed the Health Insurance Portability and  Accountability Act (HIPAA) to, among other things, provide funding  through transfers to the Federal Bureau of Investigation (FBI) to carry out  specific purposes of the Health Care Fraud and Abuse Control Program. In  response to a request from you, the Department of Justice (DOJ) notified  the Committee in October 2003 that after the terrorist attacks of September  11, 2001, and as a result of FBI’s reprioritization of investigations, FBI  shifted some agent resources from health care fraud investigations to  counterterrorism matters. FBI’s notification was based on reports from its  time utilization system showing that fewer full time equivalents (FTEs)  representing agents had been used for health care fraud investigations than  had been budgeted for fiscal years 2002 and 2003.
The Committee expressed concern that this shift in agent resources  might have resulted in FBI’s not spending dedicated health care fraud  investigation funds in accordance with HIPAA. You asked us to review  FBI’s accountability for the HIPAA transfers for fiscal years 2000 through  2003. We determined (1) whether FBI had an adequate approach for  ensuring the proper use of the HIPAA transfers and (2) the extent to which  FBI expended these transferred funds on health care fraud investigations in  fiscal years 2000 through 2003.
To address these objectives, we compared the design of FBI’s existing  financial internal controls and processes related to the HIPAA transfers and  the administration of the funds on health care fraud investigations with our  Standards for Internal Control in the Federal Government. We also  evaluated schedules of health care fraud cost estimates prepared by FBI.  We performed our work in accordance with generally accepted government  auditing standards from February 2004 to January 2005. Our scope and  methodology are discussed in greater detail in appendix I. We requested  comments on a draft of this report from the Director of FBI or his designee.  The joint letter with comments from DOJ and FBI is reprinted in  appendix II.
subsections: section_title: Background
paragraphs: The Health Insurance Portability and Accountability Act of 1996 amended  the Social Security Act (the act) to, among other things, (1) establish a  Health Care Fraud and Abuse Control Program and (2) establish an  expenditure account, designated as the Health Care Fraud and Abuse  Control Account (Account) within the Federal Hospital Insurance Trust  Fund (Trust Fund). The Account is administered by Department of Health  and Human Services’ (HHS) Office of Inspector General and DOJ. The  amendment also makes appropriations for the Account from the general  fund of the U.S. Treasury. The appropriations are in specified amounts for  each fiscal year beginning with fiscal year 1997 for transfer to FBI to carry  out its health care fraud investigations.
In 1997 HHS and FBI entered into an interagency agreement to facilitate the  required annual transfer of funds from the Account to FBI solely for its  health care fraud investigations. FBI receives the transferred funds and  records the funds in its Salaries and Expenses (S&E) appropriation  account at the beginning of each fiscal year. FBI then incurs obligations for  health care fraud investigations and makes payments from the S&E  account, which is also used to make payments for other FBI  mission-related and support activities. The amounts that were transferred  to FBI as required by the act for the years of our review were as follows:  fiscal year 2000: $76 million,  fiscal year 2001: $88 million,  fiscal year 2002: $101 million, and  fiscal year 2003: $114 million (and each subsequent year).
The amendment requires that these funds be used solely to cover the costs  (including equipment, salaries and benefits, and travel and training) of the  administration and operation of the health care fraud and abuse control  program, including the costs of prosecuting health care matters,  investigations, financial and performance audits of health care programs,  and inspections and other evaluations. These health care fraud  investigations are managed nationally by FBI’s Health Care Fraud Unit  (HCFU), which was created in 1992 within the Financial Crimes Section of  the FBI’s Criminal Investigative Division. Health care fraud investigations  include those for fraud against government programs and private  insurance, as well as medical privacy law violations. HCFU is responsible  for health care fraud investigations that are conducted by FBI’s field offices  and, for management and reporting purposes, both HCFU and the related  field investigations are considered a part of its White Collar Crime decision  unit.
section_title: FBI’s Monitoring Approach for HIPAA Transfers Provided Little Assurance of Transfers’ Proper Use
paragraphs: FBI used a limited approach to monitoring its use of HIPAA transfers,  which might have been sufficient when it clearly used more agent FTEs for  health care fraud investigations than it had budgeted. But this approach  was insufficient when some of the agent FTEs previously devoted to health  care fraud investigations were shifted to counterterrorism activities,  causing actual FTEs to fall below budgeted FTEs. At the time of our review,  FBI’s Financial Management System (FMS) was unable to track overall  costs related to health care fraud investigations. As a result, FBI had  minimal assurance that all of the transferred HIPAA funds were properly  spent. DOJ is currently planning to implement the new DOJ-wide Unified  Financial Management System, but it has yet to develop the specific  systems requirements to enable it to accurately capture all of the costs of  its health care fraud investigations and therefore to help monitor  compliance with HIPAA and other relevant laws and regulations.
FBI’s budget for health care fraud investigations was equivalent to the  amount of the HIPAA transfers and included only the direct program costs.  These direct costs consisted of payroll and benefits for agents and certain  other personnel involved in health care fraud investigations, plus related  costs such as rent and supplies. FBI used an approach to monitoring the  use of HIPAA transfers that considered agent FTEs only without  considering the other direct program costs. For the 4 years we reviewed,  the agent FTEs represented about 42 percent of the budgeted amounts for  work on health care fraud investigations, while the other direct program  costs represented about 58 percent of the budgeted amounts. FBI obtained  agent FTEs from reports generated by its time utilization system, which  records the percentage of time that agents worked on each investigative  classification and, if applicable, major cases. FBI officials told us that prior  to September 11, 2001, reported agent FTEs charged to the health care  fraud investigations were historically far in excess of those budgeted and  they were satisfied that the resources expended on health care fraud  investigations exceeded the HIPPA transfers. For example, in fiscal year  2000, FBI reported that health care fraud agent FTEs exceeded the number  budgeted that year by about 19 percent.
However, this limited approach to monitoring the use of the HIPAA  transfers was insufficient when agent FTEs were shifted to  counterterrorism activities after September 11, 2001, because it lacked the  specificity of cost information for both direct and indirect costs.  Furthermore, FBI’s FMS was not capable of providing this specific cost  information. Therefore, in years when reported agent FTEs were close to or  below budgeted FTE amounts, FBI had no effective mechanism in place to  monitor compliance with HIPAA. This was the case when reported agent  FTEs approximated the budgeted amounts in fiscal year 2001 and fell  below budgeted FTEs in fiscal years 2002 and 2003 by 31 percent and  26 percent, respectively.
Reliable information on the costs of federal programs and activities is  crucial for the effective management of government operations and assists  internal and external users in assessing the budget integrity, operating  performance, stewardship, and systems and control of program activities.  In this regard, the Chief Financial Officers Act of 1990 expressly calls on  agencies to provide for the systematic measurement of performance and  the development of cost information. In addition, “Statement of Federal  Financial Accounting Standards Number 4” established for all federal  agencies cost accounting concepts and standards aimed at providing  reliable and timely information on the full cost of federal programs, their  activities, and outputs. Cost information for program activities is  especially crucial in order to properly manage and account for funds that  have been appropriated, or in this case, transferred for certain authorized  purposes.
FBI’s FMS has minimal capability to track health care fraud investigation  and other specific program costs necessary to meet federal guidance. FMS  tracks costs by cost center, of which only headquarters costs are separately  identifiable by program. However, substantially all of the direct costs for  health care fraud investigations are incurred at the individual field offices,  each of which is considered separate cost centers. The specific program  costs within each field location, therefore, are not individually tracked or  separately identifiable. As a result, FBI cannot use FMS to track and report  all health care fraud investigation costs.
DOJ is currently in the process of implementing a new financial  management system. The new UFMS is likely to have the capability to  capture nonpersonnel costs on a program or subprogram basis, if design  specifications are set to do so. However, according to FBI finance officials,  specifications have not been set up for UFMS to capture total payroll costs  at the program level. These costs amounted to about 55 percent of the  budgeted health care fraud investigation costs. Under UFMS as currently  planned, payroll costs are to be processed by the U.S. Department of  Agriculture’s National Finance Center (NFC) starting in 2006 and  recorded at the summary level. As a result, they will be combined with the  payroll costs of other programs and will not be separately identifiable.
NFC officials told us that they recommend that all customers receive  summary and detailed-level data. NFC uses a 27-digit accounting code, of  which 24 digits are available to agencies to establish an account structure  for detailed payroll information such as program, subprogram, and job  code levels. NFC officials also stated that they met informally with FBI  personnel and explained how the accounting codes could be used to  support FBI’s needs. An FBI official told us that because of security  concerns, FBI would have to give consideration to using such codes. The  absence of accounting codes for programs and subprograms or other  control mechanisms for monitoring payroll and other costs will continue to  impede FBI’s ability to assess compliance with HIPAA and other relevant  laws and regulations.
section_title: FBI’s Cost Estimates of Health Care Fraud Investigations Were Not Adequately Supported
paragraphs: In the absence of system-generated program costs and upon our request for  cost schedules, FBI began developing an estimate of its health care fraud  investigation costs incurred for fiscal years 2000 through 2003 in an  attempt to determine the propriety of its use of the HIPAA transfers. FBI  engaged in extensive manual efforts and developed cost estimates that, in  their final form, appropriately considered both direct program costs and  the portion of indirect, FBI-wide support unit costs that related to the  health care fraud program. However, we found that the estimates were  either directly or indirectly based on data from FBI’s time utilization  system, which had not been properly validated, and various other data that  were not adequately supported. As a result, despite a good-faith effort by  FBI to estimate these costs, neither we nor FBI could reliably determine  whether the HIPAA transfers were spent solely on health care fraud  investigations for the 4-year period.
FBI officials told us at the start of our review that they were unable to  provide us with a report of actual costs and had not previously estimated  the costs associated with the transfers for fiscal years 2000 through 2003  primarily because of the financial systems’ weaknesses that we previously  discussed. As an alternative, they proposed to provide us with an estimate  of health care fraud investigation costs and subsequently developed an  estimation methodology. Because cost estimates for this program had  never before been attempted, FBI tried different approaches and revised  the estimates several times during our review. The first three estimates for  the 4-year period were revised to reflect slight changes in the methodology  and to correct an error in the estimates but were quite similar to each other  in method and in results. In essence, FBI estimated the direct costs for each  budgeted line item of the health care fraud program. These were  categorized into four groups: (1) headquarters payroll and benefits;  (2) agent payroll and benefits; (3) other field personnel’s payroll and  benefits; and (4) related nonpersonnel costs such as utilities, equipment,  and supplies. The method for estimating each group is as follows:  Headquarters payroll and benefits, as previously discussed, were  predominantly tracked in FMS.
The agent payroll and benefits costs, accounting for approximately  46 percent of FBI’s estimated program costs for the 4 years, were  estimated directly on the basis of agent FTEs reported in FBI’s Time  Utilization and Record Keeping (TURK) system and average FBI-wide  salaries and benefits for General Schedule 10-13 field agents.
The other field personnel’s payroll and benefits, which represented  about 29 percent of FBI’s estimated program costs for the 4 years,  were estimated from a combination of sources, including investigative  support staff FTEs from its TURK system, that were summarized in two  manual spreadsheets. The spreadsheets were prepared by two staff  members, one of whom no longer works at FBI. The methodology for  this staff member’s spreadsheet is uncertain, and the results could not  be verified.
FBI’s related nonpersonnel cost estimates were generally proportionate  to the budgeted amount on the basis of a ratio of budgeted FTEs versus  the FTEs reported in the TURK system. For example, for fiscal year  2003, the nonpersonnel costs line-item amounts were estimated at about  79 percent of the budgeted amount, since only 664 total FTEs were  reportedly charged to health care fraud investigations, while a total of  844 FTEs were budgeted. However, the budgeted and estimated  amounts for these costs were not subsequently compared with actual  costs for any of the years presented in order to verify the  reasonableness of the amounts.
We determined that the primary source data used either directly or  indirectly to estimate the health care fraud costs, as reported from the  TURK system, had not been properly tested to determine the reliance that  could be placed on the information. Prior to fiscal year 2002, the work  time percentages and related investigative classification information in the  TURK system, which has been operational in its current form since 1991  and is used by FBI for a variety of budgetary and program management  decision making, had never been properly validated. We found that for  fiscal years 2002 and 2003, FBI conducted limited internal testing, including  tests on whether the work hours recorded in the system were correctly  charged to the appropriate investigative case. The tests were performed at  all of the field office locations and produced error rates that varied from  year to year and across field locations but were not conducted on  statistically valid samples. Therefore, the results cannot be applied to the  population beyond the specific items tested. Nonetheless, the identified  errors raise questions about the reliability of the data in TURK and  demonstrate the need for additional data validation work by FBI. In  addition, a key financial official indicated that at least one of the tests  might not have been properly designed to validate the data.
In addition to the lack of validation of the TURK data, certain other  supporting documentation could not be verified or was not adequate.  Examples include the following:  The health care fraud equipment account, approximately 5 percent of  budgeted amounts for the 4 years, funded purchases other than  equipment such as travel and training expenses and was used much like  a discretionary account. FBI officials told us that at year’s end, these  nonequipment costs were adjusted by moving them out of the  equipment account and into the appropriate line item on the basis of the  amounts recorded in a detailed listing of purchases prepared by HCFU.  We were unable to reconcile the amount of purchases recorded in the  detailed equipment listings or the amount of interaccount adjustments  to the FBI cost estimates, and no such reconciliation was provided by  FBI. The amount of interaccount adjustments ranged from $424,000 to  $7.5 million a year for the 4 years under review.
FBI used average salaries of support personnel at year’s end that might  not have accurately represented the mix of salaries of the staff  supporting health care fraud investigations whose duties ranged from  administrative to professional (e.g., medical experts).
FBI surveyed field office managers in an effort to capture other FTEs  that were related to health care fraud investigations. Field managers  estimated the portion of hours or FTEs spent investigating health care  fraud cases that were recorded in TURK under other investigative  classifications. For example, a case dealing with an Internet pharmacy  that was investigated by a Cyber Crimes squad could be considered a  health care fraud investigation and included in the estimate of health  care fraud costs. These other agent FTEs are difficult to verify and, in  some cases, were reported from memory.
On average, the first three FBI cost estimates showed that FBI spent  $33 million more on health care fraud investigations than the amount of the  HIPAA transfers for fiscal years 2000 and 2001 and about $29 million less  than the HIPAA transfers for fiscal years 2002 and 2003. When we were  provided with these cost estimates, FBI officials stated that this shift in  resources away from health care fraud investigations in the latter 2 years  was a result of the increase in the counterterrorism investigative activity  after the September 11 attacks. FBI management prepared a fourth and  final cost estimate that included an allocation of the additional costs of  other FBI units, such as forensic laboratory services and mandatory  training that support various FBI programs, including the health care fraud  program. While it is generally appropriate to include such indirect costs  when determining total program costs, these additional costs were not  previously considered when budgeting the funds transferred by the  Congress to FBI for its health care fraud investigations. Furthermore,  these additional items were not included in DOJ’s October 2003 response to  the Senate Finance Committee regarding FBI’s use of the HIPAA transfers.
FBI estimated the portion of costs for each of the six support units— training, forensics, information management, technical field support,  criminal justice services, and management and administration—that  related to health care fraud investigations and added them to the estimates  of direct costs previously provided to us in the third version. While FBI put  forth a good-faith effort to devise a way to allocate the indirect support unit  costs to health care fraud investigations, its methodology relied, in part, on  layers of unvalidated data. For example, FBI allocated FBI-wide support  unit costs as reported in its audited financial statements first to the DOJ  Strategic Goal that included health care fraud investigations.  The percentages used in this calculation were the same used to allocate  costs for FBI’s Statement of Net Cost; however, FBI’s auditors said they did  not validate the methodology or documentation supporting the  allocation percentages. After FBI allocated the specific support unit costs  to the DOJ Strategic Goals, FBI allocated those costs to health care fraud  investigations using FTE data based primarily on TURK, which, as  previously discussed, has not been validated.
On average, the additional indirect costs represented approximately  $34 million, or 27 percent of total health care fraud costs per year. With the  addition of these indirect costs, FBI ultimately estimated that it spent more  on health care fraud investigations than was funded by the HIPAA transfers  for all 4 years. However, with the magnitude of unverified and inadequately  supported data, neither we nor FBI could reliably determine whether the  HIPAA transfers were spent solely on health care fraud investigations for  the 4-year period.
section_title: Conclusions
paragraphs: FBI’s monitoring approach for determining the proper use of HIPAA  funding was limited and did not provide the level of assurance needed  when agent FTEs devoted to health care fraud investigations were close to  or below budgeted amounts. Absent a financial management system that  could capture the costs of its health care fraud investigations, FBI had to  resort to extensive manual efforts to estimate the costs but did not have the  data needed to do so reliably. Until FBI improves its data reliability and  either develops a financial management system capable of tracking and  reporting health care fraud investigation cost information or some other  effective monitoring approach, it will continue to lack sufficient  accountability over the use of the HIPAA transfers. Inadequate  accountability hinders efforts to budget, manage, and account for program  funds appropriately and will leave FBI at an increased risk of violating  HIPAA and other laws.
section_title: Recommendations for Executive Action
paragraphs: We are making four total recommendations—two enhancing FBI’s  accountability over the HIPAA transfers and the costs related to health care  fraud investigations in the short term and two augmenting the new Unified  Financial Management System’s cost-tracking capabilities in the long term.  We recommend that the Director of the FBI take the following actions:  Develop formal, interim policies and procedures for reporting health  care fraud investigation costs that specify (1) the costs to be estimated  and/or allocated, (2) the supporting documentation to be maintained,  and (3) the method to validate those data used.
Periodically conduct statistically valid testing of the data in the Time  Utilization and Record Keeping system, in particular, the work  time percentages and related investigative classification information to  ensure the TURK system’s reliability. In addition, require field office  managers to follow up on any issues identified in the testing.
Either specify that the UFMS have the capability to allocate payroll  costs provided by the NFC payroll system to specific programs or  develop cost accounting codes at the program and subprogram levels to  enable NFC to provide the necessary detailed payroll reports.
Ensure that the UFMS has the capability and design specifications to  track nonpersonnel costs related to health care fraud investigations.
section_title: Agency Comments and Our Evaluation
paragraphs: In a joint letter with written comments on a draft of this report (reprinted in  appendix II), DOJ and FBI agreed with the four recommendations in this  report and said they have begun to address the two short-term  recommendations. Specifically, FBI is expecting to complete reviews of its  procedures used to track health care fraud investigation costs and the  collection and validation procedures for data entered into the TURK  system by May 31, 2005. Concerning the long-term solution through  financial management system enhancements, FBI acknowledged the need  to establish control mechanisms to monitor both personnel and  nonpersonnel costs related to health care fraud investigations to ensure the  transparent allocation of FBI resources while maintaining appropriate  levels of security. FBI notes that health care fraud investigations funded by  HIPAA have contributed to a number of significant, high-profile case  accomplishments as a result of the FBI’s dedication of HIPAA resources.  FBI and DOJ officials provided oral comments on technical matters, which  we have incorporated as appropriate.
As agreed with your office, unless you publicly announce its contents  earlier, we plan no further distribution of this report until 30 days from its  issue date. At that time, we will send copies of this report to the Ranking  Minority Member, Senate Committee on Finance; the Attorney General of  the United States; the Director, FBI; the Director, Office of Management  and Budget; and other interested parties. We will make copies available to  others upon request. In addition, the report will be available at no charge  on the GAO Web site at http://www.gao.gov.
Should you or your staff have any questions on the matters discussed in  this report, please contact me on (202) 512-9508 or by e-mail at  calboml@gao.gov or contact Steven R. Haughton, Assistant Director, at  (202) 512-5999 or haughtons@gao.gov. Major contributors to this report are  included in appendix III.
section_title: Scope and Methodology
paragraphs: We reviewed the internal controls related to the use of the Health Insurance  Portability and Accountability Act (HIPAA) transfers and the cost estimates  of health care fraud investigations for fiscal years 2000 through 2003.
We requested available documentation of the policies, procedures, and  guidelines relating to the HIPAA transfers and the health care fraud  program. We conducted interviews with Federal Bureau of Investigation  (FBI) officials to obtain an understanding of the internal controls, including  fund controls, in place over transferred funds. We reviewed the sufficiency  of those internal controls in light of GAO’s Standards for Internal Control in  the Federal Government.
Because of the inability of FBI’s existing Financial Management System to  produce program-level cost information as described in this report, FBI  developed an estimate of the costs of health care fraud investigations. FBI  provided us with a schedule of cost estimates for its health care fraud  investigations for each of the 4 fiscal years, a description of the  cost-estimation methodology, and various documentation that supported  some of the headquarters and field office costs. During the course of our  work, FBI modified its original schedule of cost estimates twice because of  slight changes to the cost-estimation methodology. For all three schedules  of costs, we evaluated the overall method of cost estimation to determine  the method’s reasonableness and ability to assure that applicable laws and  regulations were followed. Additionally, we (1) identified the sources of  information used in the methodology; (2) verified, where possible, the  underlying data flow and formulas; and (3) compared the cost estimates  with the amount of funds transferred to FBI for each of the 4 years.  FBI provided us with a fourth and final schedule of cost estimates on  January 5, 2005, which included allocations of FBI-wide administrative and  support costs not originally considered part of health care fraud costs. We  requested supporting documentation for these additional allocations and  reviewed the limited documentation that was available.
FBI’s cost-estimation methodology was based significantly on information  derived from the Time Utilization and Record Keeping system. We were  unable to rely on this system’s data for the purpose of our review because  the data for fiscal years 2000 and 2001 had not been validated and a limited  internal review reported varying error rates for the data for fiscal years  2002 and 2003. The internal review, however, was not statistically valid. We  did not attempt to independently validate the system.
We performed our work from February 2004 through January 2005 in  accordance with generally accepted government auditing standards. We  requested written comments on this report from the Director of the FBI or  his designee. A joint letter with comments from DOJ and FBI was received  and is reprinted in appendix II.
section_title: Comments from the Department of Justice and the Federal Bureau of Investigation
section_title: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contacts
section_title: Acknowledgments
paragraphs: In addition to those named above, Sharon O. Byrd, Richard T. Cambosos,  Tyshawn A. Davis, Lori B. Ryza, and Ruth S. Walk made key contributions  to this report.
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