Indian Gaming: Regulation and Oversight by the Federal Government, States, and Tribes
Published: 2015-07-22T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Over the past 25 years, Indian gaming has become a significant source of revenue for many tribes, reaching $28 billion in fiscal year 2013. IGRA, the primary federal statute governing Indian gaming, provides a statutory basis for the regulation of Indian gaming. Tribes, states, Interior, and the Commission have varying roles in Indian gaming.
This testimony highlights the key findings of GAO's June 2015 report ( GAO-15-355 ). Accordingly, it addresses (1) Interior's review process to help ensure that tribal-state compacts comply with IGRA; (2) how states and selected tribes regulate Indian gaming; (3) the Commission's authority to regulate Indian gaming; and (4) the Commission's efforts to ensure tribes' compliance with IGRA and Commission regulations. For the June 2015 report, GAO analyzed compacts and Commission data on training, compliance, and enforcement; and interviewed officials from Interior, the Commission, states with Indian gaming, and 12 tribes in six states GAO visited based on geography and gaming revenues generated.
section_title: What GAO Found
paragraphs: In its June 2015 report, GAO found that the Department of the Interior (Interior) has a multistep review process to help ensure that compacts—agreements between a tribe and state that govern the conduct of the tribe's class III (or casino) gaming—comply with the Indian Gaming Regulatory Act (IGRA). From 1998 through fiscal year 2014, Interior approved 78 percent of compacts; Interior did not act to approve or disapprove 12 percent; and the other 10 percent were disapproved, withdrawn, or returned.
GAO also found that states and selected tribes regulate Indian gaming in accordance with their roles and responsibilities established in tribal-state compacts for class III gaming, and tribal gaming ordinances, which provide the general framework for day-to-day regulation of class II (or bingo) and class III gaming. In addition, the 24 states with class III Indian gaming operations vary in their approaches for regulating Indian gaming, from active (e.g., daily or weekly on-site monitoring) to limited (e.g., no regular monitoring). Further, all 12 selected tribes GAO visited had regulatory agencies responsible for the day-to-day operation of their gaming operations.
In GAO's June 2015 report, GAO found that the National Indian Gaming Commission (Commission)—an independent agency within Interior created by IGRA—has authority to regulate class II gaming, but not class III gaming, by issuing and enforcing gaming standards. The Commission is considering issuing guidance with class III standards that may be used voluntarily by tribes and has held consultation meetings to obtain tribal input. However, in June 2015, GAO found the Commission does not have a clear plan for conducting outreach to affected states on its proposal. Federal internal control standards call for managers to obtain information from external stakeholders that may have a significant impact on the agency achieving its goals. Along with tribes, state input could aid the Commission in making an informed decision.
Even with differences in its authority for class II and class III gaming, GAO found that the Commission helps ensure that tribes comply with IGRA and applicable federal and tribal regulations through various activities, including monitoring gaming operations during site visits to Indian gaming operations and Commission-led audits. In addition, since 2011, the Commission has emphasized efforts that encourage voluntary compliance with regulations, including providing training and technical assistance and alerting tribes of potential compliance issues using letters of concern. However, the effectiveness of these two approaches is unclear. GAO found in June 2015 that the Commission had a limited number of performance measures that assess outcomes achieved. With such additional measures, the Commission would be better positioned to assess the effectiveness of its training and technical assistance. Further, GAO found the Commission does not have documented procedures, consistent with federal internal control standards, about how to complete or track letters of concern to help ensure their effectiveness in encouraging tribal actions to address identified potential compliance issues. Without documented procedures, the Commission cannot ensure consistency or effectiveness of the letters it sends.
section_title: What GAO Recommends
paragraphs: In its June 2015 report, GAO recommended that the Commission: (1) obtain input from states on its plans to issue guidance on class III minimum internal control standards; (2) review and revise, as needed, its performance measures to better assess its training and technical assistance efforts; and (3) develop documented procedures and guidance to improve the use of letters of concern. The Commission generally agreed with GAO's recommendations.

section_title: Letter
paragraphs: I am pleased to be here today to discuss our June 2015 report on the  regulation and oversight of Indian gaming. Over the past 25 years, Indian  gaming has become a significant source of revenue for many tribes. In  fiscal year 2013, the Indian gaming industry included more than  400 gaming operations in 28 states and generated revenues totaling  $28 billion. The Indian Gaming Regulatory Act (IGRA) was enacted in  1988 to provide a statutory basis for the regulation of gaming on Indian  lands. IGRA established three classes of gaming and outlined regulatory  responsibilities for tribes, states, and the federal government. Class I  gaming consists of social games played solely for prizes of minimal value  and traditional gaming played in connection with tribal ceremonies or  celebrations. Class I gaming is within the exclusive jurisdiction of the  tribes. Class II gaming includes bingo, games similar to bingo, and certain  card games. Class III gaming includes all other types of games, including  slot machines, craps, and roulette. Both tribes and the federal  government have a role in class II and class III gaming. Class III gaming  is also subject to state regulation to the extent specified in compacts  between tribes and states that allow such gaming to occur. Compacts are  agreements between a tribe and state that establish the terms for how a  tribe’s class III gaming activities will be operated and regulated, among  other things. The Secretary of the Interior (Secretary) approves compacts  and must publish a notice in the Federal Register before they go into  effect. IGRA also created the National Indian Gaming Commission  (Commission) within the Department of the Interior (Interior) to regulate  class II and oversee class III Indian gaming.
My testimony today highlights the key findings of our June 2015 report on  Indian gaming. Specifically, I will discuss (1) the review process that  Interior uses to help ensure that tribal-state compacts comply with IGRA;  (2) how states and selected tribes regulate Indian gaming; (3) the  Commission’s authority to regulate Indian gaming; and (4) the  Commission’s efforts to ensure tribes’ compliance with IGRA and  Commission regulations.
For our June 2015 report, we examined IGRA and relevant federal  regulations and policies, including Interior regulations and documentation  on its compact review process, as well as Commission regulations,  policies, and guidance on its regulation of Indian gaming. We also  analyzed tribal-state compacts in effect through fiscal year 2014 and  various Commission data corresponding to the Commission’s oversight  activities for fiscal years 2005 and 2014 to the extent these data were  available and reliable based on their sources. For example, for fiscal  years 2011 to 2014, we analyzed Commission data on site visits and  reviewed documentation related to a random, nongeneralizable sample of  50 site visits to Indian gaming operations; for fiscal years 2005 to 2014,  we analyzed publicly available information on enforcement actions taken  by the Commission Chair. We also interviewed Interior and Commission  officials about their roles in regulating and overseeing Indian gaming.  To determine how states and selected tribes regulate Indian gaming,  we contacted all 24 states that have class III gaming operations. We  collected written responses, conducted interviews, and obtained  additional information about how each state oversees Indian gaming,  including information on each state’s regulatory organizations, staffing,  funding, and expenditures, as well as the types of monitoring and  enforcement activities conducted by state agencies. We visited six  states—Arizona, California, Michigan, New York, Oklahoma, and  Washington—selected for geographic representation and having the most  gaming revenues generated. For each of the six states, we met with at  least one federally recognized Indian tribe, interviewing officials from  12 tribes willing and available to meet with us. In addition, we contacted  10 tribal gaming associations including the National Indian Gaming  Association and the National Tribal Gaming Commissioners/Regulators,  to obtain additional information on tribal perspectives on Indian gaming.  See our June 2015 report for additional details of the methods used to  conduct our work.
The work on which this testimony is based was performed in accordance  with generally accepted government auditing standards. Those standards  require that we plan and perform the audit to obtain sufficient, appropriate  evidence to provide a reasonable basis for our findings and conclusions  based on our audit objectives. We believe that the evidence obtained  provides a reasonable basis for our findings and conclusions based on  our audit objectives.
subsections: section_title: Interior Uses a Multistep Review Process to Help Ensure that Tribal- State Compacts Comply with IGRA and Has Approved Most Compacts
paragraphs: In our June 2015 report, we found that Interior uses a multistep review  process to help ensure that tribal-state compacts, and any compact  amendments, comply with IGRA, other federal laws not related to  jurisdiction over gaming on Indian lands, and the trust obligation of the  United States to Indians. Interior’s Office of Indian Gaming is the lead  agency responsible for managing the multistep process for reviewing  compacts submitted by tribes and states. The Office of Indian Gaming  coordinates its compact reviews with Interior’s Office of the Solicitor. The  Office of Indian Gaming submits a final analysis and recommendation  regarding compact approval to the Assistant Secretary of Indian Affairs,  who makes a final decision on whether to approve the compact. Interior  has 45 days to approve or disapprove a compact once it receives a  compact package from a state and tribe. Under IGRA, any compacts  Interior does not approve or disapprove within 45 days of submission are  considered to have been approved (referred to as deemed approved), but  only to the extent they are consistent with IGRA.
From 1998 through fiscal year 2014, Interior reviewed and approved most  of the 516 compacts and compact amendments that states and tribes  submitted. Specifically, 78 percent (405) were approved; 12 percent (60)  were deemed approved; 6 percent (32) were withdrawn or returned; and  about 4 percent (19) were disapproved.
In the decision letters we reviewed for the few disapproved compacts  (19 out of 516), the most common reason for disapproval was that  compacts contained revenue sharing provisions Interior found to be  inconsistent with IGRA. For example, Interior found the revenue sharing  payment to the state in some compacts to be a tax, fee, charge, or  assessment on the tribe, which is prohibited by IGRA. For one compact,  Interior found the state’s offer of support for the tribe’s application to take  land into trust did not provide a quantifiable economic benefit that justified  the proposed revenue sharing payments. Consequently, Interior viewed  the payment to the state as a tax or other assessment in violation of  IGRA. Interior also disapproved compacts for other reasons, including  that compacts were signed by unauthorized state or tribal officials,  included lands to be used for gaming that were not Indian lands as  defined by IGRA, or included provisions that were not directly related to  gaming.
Interior did not approve or disapprove 60 of the 516 compacts submitted  by tribes and states within the 45-day review period. As a result, these  compacts were deemed approved to the extent that they are consistent  with IGRA. According to Interior officials, as a general practice, the agency only sends a decision letter to the tribes and state for deemed  approved compacts to provide guidance on any provisions that raised  concerns or may have potentially violated IGRA. We reviewed the  decision letters for 26 of the 60 deemed approved compacts. In  19 of the 26 letters we reviewed, Interior described concerns about the  compact’s revenue sharing provisions, and most of these letters also  noted concerns about the inclusion of provisions not related to gaming.  The remaining 7 letters we reviewed cited other concerns, such as  ongoing litigation, that could affect the compact.
section_title: States and Selected Tribes Regulate Indian Gaming Based on Compacts and Tribal Ordinances, Depending on Gaming Class
paragraphs: As we found in our June 2015 report, the roles of states and tribes in  regulating Indian gaming are established in two key documents:  (1) compacts for class III gaming and (2) tribal gaming ordinances for  both class II and class III gaming. Compacts lay out the responsibilities of  both tribes and states for regulating class III gaming. For example,  compacts may include provisions allowing states to conduct inspections  of gaming operations, certify employee licenses, review surveillance  records, and impose assessments on tribes to defray the state’s costs of  regulating Indian gaming. Under IGRA, tribal gaming ordinances—which  outline the general framework for tribes’ regulation of class II and class III  gaming—must be adopted by a tribe’s governing body and approved by  the Commission’s Chair before a tribe can conduct class II or class III  gaming, as required under IGRA. Tribal ordinances must contain certain  required provisions that provide, among other things, that the tribe will  have sole proprietary interest and responsibility for the conduct of gaming  activity; that net gaming revenues will only be used for authorized  purposes; and that annual independent audits of gaming operations will  be provided to the Commission.
IGRA allows states and tribes to agree on how each party will regulate  class III gaming, and we found that regulatory roles vary among the  24 states that have class III Indian gaming operations. We identified  states as having either an active, moderate, or limited role to describe  their approaches in regulating class III Indian gaming, primarily based on  information states provided on the extent and frequency of their  monitoring activities. Monitoring activities conducted by states ranged  from basic, informal observation of gaming operations to testing of  gaming machine computer functions and reviews of surveillance systems  and financial records. We also considered state funding and staff  resources allocated for regulation of Indian gaming, among other factors,  in our identification of a state’s role. Based on our analysis of states’  written responses to questions and interviews with states we found the  following:
Seven states have an active regulatory role: Arizona, Connecticut,  Kansas, Louisiana, New York, Oregon, and Wisconsin. These states  monitor gaming operations at least weekly, with most having a daily  on-site presence. Over 17 percent (71 of 406) of class III Indian  gaming operations are located in these seven states, accounting for  about 25 percent of gross gaming revenue in fiscal year 2013.  These states perform the majority of monitoring activities, including  formal and informal inspection or observation of gaming operations;  review of financial report(s); review of compliance with internal control  systems; audit of gaming operation records; verification of gaming  machines computer functions; review of gaming operator’s  surveillance; and observation of money counts.
Eleven states have a moderate regulatory role: California, Florida,  Iowa, Michigan, Minnesota, Nevada, New Mexico, North Dakota,  Oklahoma, South Dakota, and Washington. Most of these states  monitor operations at least annually, and all collect funds from tribes  to support state regulatory activities. About 75 percent (303 of 406) of  class III Indian gaming operations are located in these states and  generated 69 percent of all gross Indian gaming revenue in fiscal year  2013. States with a moderate regulatory role have the broadest range  of regulatory approaches. For example, according to Nevada officials,  Nevada conducts comprehensive inspections of gaming operations  once every 2 to 3 years and performs covert inspections, as needed,  based on risk. In contrast, North Dakota officials told us they conduct  monthly inspections of gaming operations and an annual review of  financial reports.
Six states have a limited regulatory role: Colorado, Idaho,  Mississippi, Montana, North Carolina, and Wyoming. The role of these  states is largely limited to negotiating compacts with tribes, and they  do not incur substantial regulatory costs or regularly perform  monitoring activities of class III Indian gaming operations. Eight  percent (32 of 406) of class III Indian gaming operations are located in  these states, and the operations accounted for about 4 percent of  gross Indian gaming revenue in fiscal year 2013.
Tribes take on the primary day-to-day role of regulating Indian gaming.  For example, each of the 12 tribes that we visited had established tribal  gaming regulatory agencies that perform various regulatory functions to  ensure that their gaming facilities are operated in accordance with tribal  laws and regulations and, for class III operations, compacts. The tribes’  regulatory agencies were similar in their approaches to regulating their  gaming operations. For example, all of the tribes’ regulatory agencies had  established procedures for developing licensing procedures for  employees, obtaining annual independent outside audits, and  establishing and monitoring gaming activities to ensure compliance with  tribal laws and regulations. Among other things, representatives from  tribal associations we contacted emphasized that tribal governments have  worked diligently to develop regulatory systems to protect the integrity of  Indian gaming and have dedicated significant resources to meet their  regulatory responsibilities. For example, according to representatives of  the National Indian Gaming Association, in 2013, tribal governments  dedicated $422 million to regulate Indian gaming, including funding for  tribal government gaming regulatory agencies, state gaming regulation,  and Commission regulation and oversight of Indian gaming collected  through fees required by IGRA.
section_title: The Commission Has Limited Authority for Class III Gaming, but It Provides Some Services, as Requested, Using Standards Last Updated in 2006
paragraphs: In our June 2015 report, a key difference we found between class II and  class III gaming is that IGRA authorizes the Commission to issue and  enforce minimum internal controls standards for class II gaming but not  for class III gaming. Commission regulations require tribes to establish  and implement internal control standards for class II gaming activities— such as requirements for surveillance and handling money—that provide  a level of control that equals or exceeds the Commission’s minimum  internal control standards. But, in 2006, a federal court ruled that IGRA  did not authorize the Commission to issue and enforce regulations  establishing minimum internal control standards for class III gaming.  However, Commission regulations establishing minimum internal control  standards, including standards for class III gaming, that were issued  before the ruling were not struck down by the court or withdrawn by the  Commission. The Commission issued these regulations in 1999 and last  updated the standards in 2006, which we refer to as the 2006  regulations.gaming, the Commission continues to (1) conduct audits using the 2006  regulations at the request of tribes and (2) provide monitoring and  enforcement of these regulations for 15 tribes in California with approved   Since the court decision, for operations with class III  tribal gaming ordinances that call for the Commission to have such a  role.
The Commission plans to issue guidance with updated minimum internal  control standards for class III gaming and withdraw its 2006 regulations.  Commission officials told us they have authority to issue such guidance,  and tribes could voluntarily adopt them as best practices. According to  Commission officials, issuing such guidance would be helpful because  updated standards could be changed to reflect technology introduced  since the standards were last updated. Commission officials told us that  before the agency can make a decision on how to proceed with issuing  guidance for class III minimum internal control standards, it first needs to  consult with tribes. In February 2015, the Commission notified tribes of  plans to seek comments on its proposal to draft guidance for updated  class III minimum internal control standards during meetings in April and  May 2015.
States involved in the regulation of Indian gaming are also impacted by  the Commission’s proposal to draft updated guidance and withdraw its  2006 regulations; however, the Commission’s plans for obtaining state  input on this proposal are unclear. We found that many tribal-state  compacts incorporate by reference the Commission’s 2006 regulations  establishing minimum internal control standards. For example, three  states have tribal-state compacts that require tribes to comply with the  Commission’s 2006 regulations. If the Commission withdraws its 2006  regulations, it is not clear what minimum internal control standards the  compacts would require tribes to meet. In addition, nine states have tribal- state compacts that require tribal internal control standards to be at least  as stringent as the Commission’s 2006 regulations. If the Commission  withdraws its 2006 regulations, these states and tribes would no longer  have a benchmark against which to measure the stringency of tribal  internal control standards. Standards for Internal Control in the Federal  Government call for management to ensure that there are adequate  means of communicating with, and obtaining information from, external  stakeholders that may have a significant impact on the agency achieving  its goals. According to a Commission official, the Commission is  considering conducting outreach to the states on its proposal but did not  have any specific plan for doing so. Consistent with federal internal  control standards, seeking state input is important, as it could aid the  Commission in making an informed decision on how to proceed with  issuing such guidance and whether withdrawal of its 2006 regulations  would cause complications or uncertainty under existing tribal-state  compacts. As a result of this finding, we recommended that the  Commission seek input from states regarding its proposal to draft  updated guidance on class III minimum internal control standards and  withdraw its 2006 regulations. In its comments on our draft report, the  Commission concurred with this recommendation.
section_title: The Commission Performs Various Activities to Help Ensure Tribes’ Compliance with IGRA and Commission Regulations, but the Effectiveness of Some Activities Is Unclear
subsections: section_title: Commission’s Monitoring Activities
paragraphs: To help ensure compliance with IGRA and Commission regulations, the  Commission conducts a broad array of monitoring activities—such as  reviewing independent audit reports submitted annually by tribes,  conducting site visits to tribal gaming operations to examine compliance  with applicable Commission regulations, and assessing tribes’  compliance with minimum internal control standards as part of  Commission-led audits. In addition, as required by IGRA, the  Commission’s Chair reviews and approves various documents related to  both class II and class III gaming operations, including tribal gaming  ordinances or resolutions adopted by a tribe’s governing body.
section_title: Training and Technical Assistance
paragraphs: Under its ACE initiative, the Commission has emphasized providing tribes  with training and technical assistance as a means to build and sustain  their ability to prevent, respond to, and recover from weaknesses in  internal controls and violations of IGRA and Commission regulations.  For instance, the Commission hosts two regular training events in each  region. Commission staff also provide one-on-one training on specific  topics, as needed, during site visits and offer technical assistance in the  form of guidance and advice to tribes on compliance with IGRA;  Commission regulations; and day-to-day regulation of Indian gaming  operations through written advisory opinions and bulletins. Commission  staff also respond to questions by phone and e-mail, among other  activities.
However, the effectiveness of the Commission’s training and technical  assistance efforts remains unclear. The Commission’s strategic plan for  fiscal years 2014 through 2018 includes two goals corresponding to its  focus on training and technical assistance to achieve compliance with  IGRA and Commission regulations: one for continuing its ACE initiative;  and another for improving its technical assistance and training to tribes.  Yet, the Commission’s performance measures for tracking progress  toward achieving these two goals are largely output-oriented rather than  outcome-oriented, and overall do not demonstrate the effectiveness of the  Commission’s training and technical assistance efforts. Specifically, 12 of  the 18 performance measures for these two goals include output-oriented  measures describing the types of products or services delivered by the  Commission. For example, they include the number of audits and site  visits conducted and the number of training events and participants  attending these training events. In prior work, we found that these types  of measures do not fully provide agencies with the kind of information  they need to determine how training and development efforts contribute to  improved performance, reduced costs, or a greater capacity to meet new  and emerging transformation challenges. In that work, we concluded  that it is important for agencies to develop and use outcome-oriented  performance measures to ensure accountability and assess progress  toward achieving results aligned with the agency’s mission and goals.  This is consistent with Office of Management and Budget guidance, which  encourages agencies to use outcome performance measures—those that  indicate progress toward achieving the intended result of a program— where feasible.
The Commission’s remaining 6 measures include outcome-oriented  measures that track tribes’ compliance with specific requirements,  including the percentage of gaming operations that submit audit reports  on time and have a Chair-approved tribal gaming ordinance. They do not,  however, indicate the extent to which minimum internal control standards  are implemented or reflect improvements in the overall management of  Indian gaming operations. In addition, they do not correlate such  compliance with the Commission’s training and technical assistance  efforts. Additional outcome-oriented performance measures would enable  the Commission to better assess the effectiveness of its training and  technical assistance efforts and its ACE initiative. Commission officials  told us that they recognize they have more work to do on performance  measures and are interested in taking steps to ensure that their ACE  initiative is meeting its intended goals. In our June 2015 report,recommended that the Commission review and revise, as needed, its  performance measures to include additional outcome-oriented measures.  In its comments on our draft report, the Commission concurred with our  recommendation.
section_title: Letters of Concern
paragraphs: The Commission amended its regulations in August 2012 to formalize an  existing practice of sending letters of concern to prompt tribes to  voluntarily resolve potential compliance issues. A letter of concern  outlines Commission concerns about a potential compliance issue and,  according to Commission regulations, is not a prerequisite to an  enforcement action.concern specify a time period by which a recipient must respond but do   Commission regulations require that letters of  not address which compliance issues merit a letter of concern or indicate  when a letter should be sent once a potential compliance issue is  discovered. The Commission also has not issued guidance or  documented procedures on how to implement its regulation regarding  letters of concern. In our review of letters of concern sent by the  Commission in fiscal years 2013 and 2014, we found that the  Commission sent 16 letters of concern to 14 tribes. Six of the 16 letters of  concern did not include a time period by which the recipient was to  respond, as required by Commission regulations. In addition, 12 letters  did not specify in the subject line, or elsewhere in the letter, that they  were letters of concern. By not including a time period for a response as  required by Commission regulations and not consistently identifying its  correspondence as a letter of concern, the Commission may not be able  to ensure timely responses, and tribes may find it difficult to discern the  significance of these letters. In addition, the Commission provided us with  documentation to demonstrate whether a tribe took action to address the  issues described in 8 letters of concern, but it did not provide  documentation for the remaining 8 letters. Under federal internal control  standards, federal agencies are to clearly document transactions and  other significant events, and that documentation should be readily  available for examination. Without guidance or documented procedures  to inform its staff about how to complete letters of concern or maintain  documentation tracking tribal actions, the Commission cannot ensure  consistency in the letters that it sends to tribes, and it may be difficult to  measure the effectiveness of the letters in encouraging tribal actions to  address potential issues. As a result of these findings, we recommended   and in its comment letter the Commission  in our June 2015 report,generally agreed, that the Commission should develop documented  procedures and guidance for letters of concern to (1) clearly identify  letters of concern as such and to specify the type of information to be  contained in them, such as time periods for a response; and (2) maintain  and track tribes’ responses to the Commission on potential compliance  issues.
section_title: Enforcement Actions
paragraphs: IGRA authorizes the Commission Chair to take enforcement actions for  violations of IGRA and applicable Commission regulations for both  class II and class III gaming. Specifically, the Commission Chair may  issue a notice of violation or a civil fine assessment for violations of IGRA,  Commission regulations, or tribal ordinances and, for a substantial  violation, a temporary closure order. The most common enforcement  action taken by the Commission Chair in fiscal years 2005 through 2014  was a notice of violation. The Chair issued 107 notices of violations that  cited 119 violations during this period. We found that the Chair issued  100 out of 107 notices of violation prior to fiscal year 2010. Since fiscal  year 2010, fewer enforcement actions may have been taken because  recent Commission chairs have emphasized seeking voluntary  compliance with IGRA.
Chairman Barrasso, Vice Chairman Tester, and Members of the  Committee, this completes my prepared statement. I would be pleased to  answer any questions that you may have at this time.
section_title: GAO Contact and Staff Acknowledgments
paragraphs: If you or your staff members have any questions about this testimony,  please contact me at (202) 512 -3841 or fennella@gao.gov. Contact  points for our Offices of Congressional Relations and Public Affairs may  be found on the last page of this statement. Other individuals who made  key contributions to this testimony include Jeff Malcolm (Assistant  Director), Cheryl Arvidson, Amy Bush, Jillian Cohen, John Delicath, Justin  Fisher, Paul Kazemersky, Dan Royer, Jeanette Soares, Kiki  Theodoropoulos, Swati Sheladia Thomas, and Lisa Turner.
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