Buy Indian Act: Bureau of Indian Affairs and Indian Health Service Need Greater Insight into Implementation at Regional Offices
Published: 2015-07-09T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Buy Indian Act of 1910 and agencies' implementing regulations allow Interior's BIA and the Department of Health and Human Services' IHS to award federal contracts to Indian-owned businesses without using the standard competitive process. Among other requirements, eligible firms must be at least 51 percent Indian-owned and give preference to Indians in employment, training, and subcontracting.
GAO was asked to review the implementation of the Buy Indian Act. This report identifies (1) the policies and procedures at BIA and IHS to implement the Act; and (2) the funds obligated by BIA and IHS using the Buy Indian Act procurement authority.
GAO reviewed the Buy Indian Act, the Federal Acquisition Regulation, and agency policies and regulations. GAO also analyzed data from the Federal Procurement Data System-Next Generation on BIA and IHS's contract obligations under the Act between fiscal years 2010 and 2014 and met with agency officials.
section_title: What GAO Found
paragraphs: The Department of the Interior's (Interior) Bureau of Indian Affairs (BIA) and the Department of Health and Human Services' Indian Health Service (IHS) have requirements in place to implement the Buy Indian Act. Through supplements to the Federal Acquisition Regulation, both BIA and IHS have policies and procedures to implement key requirements:
Indian-owned status . Eligible firms must be 51 percent Indian-owned. The agencies rely on firms to self certify that they are Indian-owned and interested parties may challenge a firm's self-certification.
Indian preference . The agencies require that contractors give preference to Indians in employment and training opportunities, and use a contract clause to implement this requirement.
Subcontracting . The agencies require contractors to give preference to Indian firms in the award of any subcontracts.
However, BIA and IHS have limited insight into implementation of the Buy Indian Act at their regional offices, where the contracts are generally awarded. For example, officials at both agencies' headquarters had little knowledge as to how often challenges to self-certifications of Indian-owned status occur on contracts awarded at the regional offices. Neither agency collects data from regional offices on use of the Buy Indian Act, and neither agency includes a specific review of Buy Indian Act contracts in its regular procurement review process. Therefore, the agencies may be missing opportunities to maximize the intended benefits of the Act in terms of growth and development of Indian firms.
Use of the Buy Indian Act comprises a small percentage of the two agencies' annual contract obligations. However, these agencies also award contracts to Indian-owned firms using other authorities, thus increasing the percentage of obligations awarded to Indian-owned firms.
section_title: What GAO Recommends
paragraphs: GAO recommends, among other things, that Interior and Health and Human Services enhance their oversight of execution of the Act at regional offices by collecting additional data on key requirements and including Buy Indian Act contracts in procurement reviews. Interior and Health and Human Services agreed with GAO's recommendations.

section_title: Letter
paragraphs: Because of its unique legal and political relationship with Indian tribes, the  federal government has a number of programs and authorities to support  and expand the economic development of tribal entities and their  individual members. One of these, the Buy Indian Act, allows for the  award of federal contracts to Indian-owned businesses without using the   Specifically, the Buy Indian Act and  standard competitive process.implementing regulations authorize the Department of the Interior’s  (Interior) Bureau of Indian Affairs (BIA) and the Department of Health and  Human Services’ (HHS) Indian Health Service (IHS) to set aside, or  reserve, a particular procurement for competition among Indian-owned  firms. This helps to promote the growth and development of Indian  industries.
You asked us to review the implementation of the Buy Indian Act. This  report identifies (1) the policies and procedures in place at BIA and IHS to  implement the Buy Indian Act and help ensure contractors comply with  key requirements involving eligibility, use of subcontractors, and other  issues; and (2) the amount of funds obligated by BIA and IHS using the  Buy Indian Act procurement authority and the types of goods and  services procured.
To identify policies and procedures related to implementation of the Buy  Indian Act, we reviewed the Buy Indian Act and relevant sections of the  Federal Acquisition Regulation. We also obtained and reviewed policies  and procedures on implementation of the Buy Indian Act from BIA and  IHS, including each agency’s supplement to the Federal Acquisition  Regulation, relevant agency policy manuals, and policy memorandums.
To determine the use of the Buy Indian Act by BIA and IHS and the types  of goods and services procured, we gathered data on contract obligations  under the Buy Indian Act between fiscal years 2010 and 2014—the five  most recent years for which data were available—using the Federal  Procurement Data System-Next Generation (FPDS-NG). To provide  perspective on contracts awarded to Indian-owned firms more broadly,  we analyzed FPDS-NG data on contracts awarded to Indian-owned firms  outside the Buy Indian Act authority during the same five-year period. To  assess the reliability of these data we discussed the FPDS-NG data with  officials at both BIA and IHS who have direct knowledge of the source  information that FPDS-NG is based upon. Additionally, we compared  information provided by BIA and IHS to data we had retrieved from  FPDS-NG. We determined that the data were sufficiently reliable for the  purposes of this report. To understand how both agencies use the Buy  Indian Act we met with procurement officials from BIA’s Office of  Acquisition and Property Management as well as IHS’s Office of  Management Services, Division of Acquisition Policy.
We conducted this performance audit from February 2015 to July 2015 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: Background
paragraphs: The Buy Indian Act of 1910 authorizes the Secretary of the Interior to  employ Indian labor and to purchase the products of Indian-owned firms  without using the normal competitive process. As implemented, Interior’s  BIA may use the Buy Indian Act procurement authority. In addition,  effective in 1955, Congress transferred authority over functions relating to  the maintenance and operation of hospitals and health facilities for  Indians, and the conservation of the health of Indians from Interior to  HHS—formerly the Department of Health, Education, and Welfare. As a  result, HHS’ IHS may use the Buy Indian Act procurement authority for  acquisitions in connection with those functions. BIA and IHS may use the  Buy Indian Act to give preference to Indian-owned businesses when  acquiring supplies and services to meet agency needs and requirements.  The Buy Indian Act itself is brief and contains little detail. The key to  implementing the Act is in both agencies’ regulations. The two agencies  have broad discretion over whether and how to utilize the Buy Indian Act  and have issued agency regulations governing their use of the authority.
BIA provides services to approximately 1.9 million American Indians and  Alaska Natives to enhance quality of life, promote economic opportunity,  and carry out the responsibility to protect and improve the trust assets of  American Indians and Alaska Natives. IHS is responsible for providing  health care for American Indians and Alaska Natives. To provide for these  services, both agencies contract for a variety of items and services such  as administrative and custodial services, maintenance projects, and office  supplies.
BIA and IHS are divided into twelve largely similar geographic areas  across the United States, which they refer to as regional offices and area  offices respectively.director. BIA and IHS headquarters set policies and oversee the regional  offices. Each regional office employs contracting officers responsible for  awarding contracts, including Buy Indian Act contracts. Each agency also  awards some contracts through their headquarters offices. See figures 1  and 2 below for information on the regional structure of each of the  agencies.
section_title: Both BIA and IHS Have Buy Indian Act Policies in Place, but Insight into Implementation by Regional Offices is Limited
paragraphs: BIA and IHS have policies and procedures in place to implement the Buy  Indian Act and to help ensure contractors’ compliance with key  requirements. However, both agencies’ headquarters have limited insight  into implementation of the Act at regional offices. BIA and IHS both  implement the Buy Indian Act authority through a combination of  regulations, agency policy, and guidance. BIA officials told us they  prioritize the use of the Buy Indian Act over other set-aside authorities.  Conversely, IHS officials reported prioritizing awards through other set- asides over the use of the Act so as to meet federally mandated small  business goals. However, these priorities are not documented in  regulations or policies. Both agencies have regulations to help ensure  contractors comply with key requirements, such as maintaining the  minimum proportion of Indian ownership, not subcontracting more than  half of the contracted work to other than Indian firms, and providing a  preference to Indians in employment, training, and subcontracting.  Although these regulations are in place, headquarters officials at both  agencies reported limited insight into implementation of these regulations  at their regional offices because they do not collect data concerning the  Buy Indian Act from regional offices, nor does either agency have a  specific review of Buy Indian Act contracts included in its regular  procurement review process.
subsections: section_title: BIA and IHS Have Regulations and Policy in Place, But Prioritization of the Act is Not Sufficiently Documented
subsections: section_title: Both Agencies Have Regulations and Policies in Place to Implement the Buy Indian Act
paragraphs: Both agencies have regulations and policies in place to implement the  Buy Indian Act, codified in formal rules and agency guidance.
In 2013, Interior finalized regulations implementing the Buy Indian Act  in the Department of the Interior Acquisition Regulation, over 30 years  after they had been initially promulgated. The rule solidified the  processes to be used for implementation and provided a consistent  policy to be used throughout BIA. BIA began promulgation of the  regulations back in October 1982 with proposed rules published in the  Federal Register. BIA made additional efforts to establish regulations  over the next 30 years until the final regulation took effect in 2013. BIA  officials could not identify a specific reason as to why finalization of  the regulations took so long. Prior to issuing a rule, BIA issued an  internal policy manual to govern the program and provided guidance  to its employees through a series of policy memoranda. BIA cited  creating a more uniform process and applying it more consistently as  the main reasons for pursuing a formal regulation.
HHS, which at the time was the Department of Health, Education, and  Welfare, enacted Buy Indian Act regulations in 1975. A modified  version of these regulations was later incorporated into the  Department of Health and Human Services Acquisition Regulation.  IHS also issued the Indian Health Manual to provide additional  guidance to its employees regarding the IHS procurement process,  including specific policies regarding the Buy Indian Act. The chapter of  the Indian Health Manual that contains requirements related to the  Buy Indian Act is currently under revision.
BIA and IHS define the term “Indian” in their regulations somewhat  differently. BIA regulations define “Indian” as a person who is a member  of an Indian Tribe, or “Native” as defined in the Alaska Native Claims  Settlement Act. IHS, however, defines “Indian” as a member of any tribe,  pueblo, band, group, village, or community that is recognized by the  Secretary of the Interior as being Indian or any individual or group of  individuals recognized by the Secretary of the Interior or the Secretary of  HHS.
Both agencies’ implementing regulations impose key requirements on  contractors. First, both agencies require eligible firms to be 51 percent  Indian-owned. Second, firms awarded a contract under the Buy Indian Act  must give preference to Indians in employment and training opportunities  under the contract, and to Indian firms in the award of any subcontracts.  Third, firms awarded a contract under the Buy Indian Act must not  subcontract more than 50 percent of the work to other than Indian firms.
section_title: BIA and IHS Priorities Are Not Sufficiently Documented in Agency Policy
paragraphs: BIA officials stated contracting officers must consider the Buy Indian Act  first when awarding every contract, and if they are unable to award a  contract using the Buy Indian Act, they must provide justification as to  why not. However, this policy is not currently documented. According to  BIA officials, policy documentation was recently rescinded because it was  confusing and not fully in-line with the intent to award Buy Indian first. BIA  is working on revising its policy on the use of the Buy Indian Act. Officials  were uncertain exactly when the new guidance would be issued.
At IHS, use of the Buy Indian Act versus other set-aside programs is  unclear and also not sufficiently documented. IHS officials told us that,  because of difficulties meeting small business goals, the agency  prioritizes awarding contracts to vendors that help the agency meet its  federally mandated small business goals, and that awarding contracts  under the Buy Indian Act is secondary to those goals. They also stated  that since June 2005, there has been an effort within the agency to  encourage Indian-owned firms to seek status under set-asides other than  the Buy Indian Act, such as women-owned or veteran-owned small  businesses. IHS was unable to provide documentation related to this  practice, and was only able to produce a 1995 policy that, contrary to  what we were told, indicated that the Buy Indian Act takes precedence  over other set-asides.
The lack of documented policy at BIA and IHS is not consistent with  federal internal control standards, which provide that formally  documented policies and procedures help to ensure that staff performs   Without documented policies in  activities consistently across an agency.place BIA and IHS are at risk for inconsistent application of the Buy Indian  Act across the agency.
section_title: BIA and IHS Regulations Include Mechanisms to Help Ensure Contractor Compliance with Key Requirements
paragraphs: Both agencies’ regulations provide for mechanisms to help enforce key  requirements of the Buy Indian Act as implemented. Specifically, both  agencies’ regulations require that firms awarded a contract under the Buy  Indian Act be at least 51 percent Indian owned, provide a preference to  Indians in employment, training, and subcontracting, and not subcontract  more than 50 percent of the work to other than Indian firms. These key  requirements are implemented through mechanisms such as self- certification procedures and, in some cases, specific contract clauses.
subsections: section_title: Both BIA and IHS Rely on Self- Certification of Indian-Owned Status
paragraphs: Both agencies rely on firms to self-certify their status as Indian-owned.  BIA requires firms to represent their Indian-owned status by checking a  box when submitting a proposal for a contract that indicates that they  meet the relevant regulatory definitions. are included in all BIA Buy Indian Act contracts that require firms to report  any change in Indian-owned status. According to IHS officials, bidders on  IHS Buy Indian Act contracts must submit a certificate of degree of Indian  blood or other form of tribal membership documentation as part of an  application packet in order to be considered eligible for a Buy Indian  contract. According to agency officials at both BIA and IHS, under self- certification, contracting officers may request more information from a  bidding firm to confirm its Indian-owned status, though officials report this  is rarely done. At BIA, the contracting officer may ask an attorney in the  appropriate regional office to review a firm’s representation. In addition,  after receipt of offers, the contracting officer may question the  representation of any bidder by filing a formal objection with the chief of  the contracting office.
See 48 C.F.R. § 1452.280-4 for the Indian economic enterprise representation provision  included in Buy Indian solicitations. the Buy Indian Act specific challenge process at BIA. IHS handles  challenges according to the protest procedures set out in the Federal  Acquisition Regulation. To deter intentional misrepresentations of Indian- owned status, both agencies rely on the suspension and debarment  process, and prosecution under the federal false statement statute.
section_title: Indian Preference Requirement and Subcontracting Limitations Are Implemented Through Contract Clauses
paragraphs: Both agencies’ regulations require firms that are awarded a contract  under the Buy Indian Act to give preference to Indians in employment,  training, and subcontracting. Contracts awarded under the Buy Indian  Act, and all resulting subcontracts, are required to contain the Indian  Preference Clause, which specifically requires the contractor to provide a  preference to Indians in employment, training, and subcontracting  opportunities under the contract. The clause further requires the  contractor to maintain sufficient records indicating compliance.
Agency officials at both BIA and IHS told us they have regulations limiting  subcontracting with other than Indian-owned firms to no more than 50  percent of the work, although only BIA implements this requirement  through the inclusion of a contract clause. Violations of contract clauses  can have serious consequences such as contract termination. This  approach is similar to how limitations on subcontracting might be handled  for some small business contracts. For example, when awarding an 8(a)  contract, the Federal Acquisition Regulation directs contracting officers to  include the Limitations on Subcontracting clause, under which the  contractor agrees that the 8(a) firm will perform a certain percentage of  the work.
According to BIA and IHS officials, neither agency employs systematic  monitoring or compliance protocols—such as systematic reporting on  specific Buy Indian requirements—to ensure that contractors comply with  key requirements and contract clauses beyond regular contracting officer  oversight. The Buy Indian Act is not necessarily unique in this regard. The  Small Business Administration’s women-owned small business and  economically disadvantaged women-owned small business programs  generally rely on self-certification and oversight by the contracting officer  as well.
Certain contracts or types of work involve more stringent, and more  specific, monitoring requirements. For example, for contracts over  $50,000, BIA requires contractors to appoint a liaison officer in charge of  keeping records for its Indian preference program and to issue semi- annual reports. IHS monitors compliance in a similar fashion, requiring a  liaison officer for non-construction contracts equal to or over $50,000 and  construction contracts equal to or over $100,000.
section_title: BIA and IHS Headquarters Officials have Limited Insight into Implementation of the Act at the Regional Offices
paragraphs: Federal internal control standards state that, for an entity to run and  control its operations, it must have relevant, reliable, and timely  communications, and that information is needed throughout the agency to  achieve all of its objectives. The standards further state that operating  information is needed to determine whether an agency is complying with  various laws and regulations. We found that BIA and IHS headquarters  officials have limited insight into the Buy Indian Act implementation in the  regional offices. Specifically, both BIA’s and IHS’s headquarters-level  procurement managers stated that they had little knowledge about  challenges to a firm’s self-certification of Indian-owned status that might  have occurred in the regional offices. When asked about how frequently  challenges occurred or how they were resolved, BIA and IHS officials told  us they would have to consult with regional offices to provide this  information. Also, officials at both agencies told us they do not aggregate  data relating to challenges. More broadly, these officials reported they do  not require regional offices to collect, retain, or aggregate data about  compliance with Buy Indian requirements in a systematic fashion.
Given this lack of insight, it is difficult for BIA and IHS officials to know  whether the Buy Indian Act is being consistently applied among the  regions, or for the agencies to determine the extent to which mechanisms  to implement key requirements are working as intended.
Both agencies also identified a specific process in place for reviewing  procurements awarded at their regional offices, but these reviews have  not historically included an examination of contracts awarded using the  Buy Indian Act. For example, Interior requires BIA to conduct bi-annual  acquisition reviews at each of its regional offices, but officials told us  these reviews have not previously examined the use of the Buy Indian Act  in particular. Following a series of informal, region-by-region reviews  starting in mid-2015, BIA plans to include Buy Indian Act requirements in  future formal acquisition reviews. Similarly, IHS officials reported that they  recently completed a periodic procurement management review of  contracts awarded at its regional offices, but officials stated they were not  aware of any reviews, past or planned, specifically focused on the use of  the Buy Indian Act. By not reviewing Buy Indian Act contracts as part of  the procurement review process, both agencies are missing opportunities  to ensure effective oversight of these contract awards.
section_title: A Small Percentage of BIA and IHS Obligations Go Towards Acquiring Various Goods and Services through the Act
paragraphs: Use of the Buy Indian Act comprises a small percentage of BIA and IHS  contract obligations. However, both agencies also award contracts to  Indian-owned firms using other authorities, thus increasing the  percentage of obligations awarded to Indian-owned firms. During the  period covered by our review, both agencies awarded contracts using the  Buy Indian Act authority to more than 300 different Indian-owned firms.  The types of goods and services purchased under the Act varied, and  included maintenance, medical, custodial, administrative support, and  office supplies.
subsections: section_title: Use of Buy Indian Act Represents a Small Percentage of Both Agencies’ Contract Obligations
paragraphs: Use of the Buy Indian Act represents a small percentage of both BIA’s  and IHS’s annual contract obligations. However, both agencies can and  do use other procurement authorities to award contracts to Indian-owned  firms, thus increasing the overall percentage of contracts awarded to  such firms. Officials from both agencies noted that it would be difficult to  have all contract obligations be set aside for award under the Buy Indian  Act, noting that some requirements, such as those for utilities, may not be  suitable for award using the Act. Figures 3 and 4 show the annual  percentage of obligations under the Buy Indian Act, Indian-owned  obligations awarded through other procurement authorities, and non  Indian-owned obligations for BIA and IHS respectively.
We also found that BIA and IHS were awarding contracts using the Buy  Indian Act authority to a number of different Indian-owned firms.  Specifically, in fiscal years 2010 through 2014, BIA awarded 732  contracts to 269 vendors and IHS awarded 131 contracts to 84 vendors.
Use of the Buy Indian Act at both agencies’ offices varies. Based on data  from FPDS-NG from fiscal years 2010 through 2014, most of the  agencies’ offices awarded contracts under the Buy Indian Act, although  some used it more than others. For example at BIA, while almost half of  the total Buy Indian Act obligations across this time frame were awarded  by the agency’s central office, a headquarters office, these obligations  decreased from about two-thirds of the agency’s Buy Indian Act  obligations in 2010 to about one-third in 2014. Other offices with relatively  high percentages of use included the Navajo and Western regional  offices. At IHS the majority of the Buy Indian Act obligations were  awarded through its Albuquerque, Phoenix, and California area offices.
See figures 5 and 6 for more details about the offices’ contract obligations  using the Act.
section_title: Types of Goods and Services Purchased Under the Buy Indian Act Vary
paragraphs: BIA and IHS have used the Buy Indian Act to purchase a variety of goods  and services in areas such as maintenance, medical, custodial,  administrative support, and office supplies.and services purchased are more varied, with architecture and   At BIA, the types of goods  engineering related goods and services being the most common (see  figure 7). Based on our analysis, IHS primarily uses the Buy Indian Act to  purchase goods and services in three areas: professional and  administrative support services, medically related goods and services,  and custodial or housekeeping goods and services (see figure 8).
section_title: Conclusions
paragraphs: The use of the Buy Indian Act is intended to promote growth and  development of Indian industries and, like any set-aside program, is  important in helping these businesses in the marketplace. Interior and  HHS issued regulations and other guidance to guide implementation of  the Act, but reported differing priorities in terms of use of the Act. While it  is within each agency’s discretion to establish these priorities, it is  important that these priorities be clearly documented. Both agencies lack  current documentation of these stated priorities. Without clear and  documented guidance on their priorities, BIA and IHS are at risk of  inconsistent implementation. We also found that BIA and IHS have limited  insight into how key requirements, such as self certification and potential  challenges to those certifications, are being implemented at their regional  offices where the contracts are being awarded. Both agencies would  benefit from collecting data on use of the Buy Indian Act from regional  offices as well as including a review of contracts awarded using the Act in  their oversight reviews. Without knowledge of how the regions are  implementing requirements related to the Act, both agencies may be  missing opportunities to improve use of the Act. Information about the  number of challenges, for instance, or detailed reporting on how  contractors are meeting their Indian preference requirements, could point  to issues in need of attention. Conversely, such information might also  highlight regional innovations that, if implemented more broadly, could  improve the use of the Buy Indian Act across each agency. Such  information could help ensure that both agencies are maximizing the  benefits intended in terms of the growth and development of Indian  industries.
section_title: Recommendations for Executive Action
paragraphs: To ensure consistent implementation of the Buy Indian Act procurement  authority across the agencies and to enhance oversight of implementation  of the Act at regional offices, we recommend that the Secretaries of the  Interior and Health and Human Services direct the Bureau of Indian  Affairs and Indian Health Service respectively, to take the following three  actions:  (1) clarify and codify their policies related to the priority for use of the Buy  Indian Act, including whether the Buy Indian Act should be used before  other set-aside programs;  (2) collect data on regional offices’ implementation of key requirements,  such as challenges to self-certification; and  (3) include Buy Indian Act contracts as a part of their regular procurement  review process.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to Interior and HHS for review and  comment. Both agencies concurred with our recommendations and  identified actions they are taking or plan to take to address the  recommendations. HHS also provided technical comments which we  incorporated as appropriate.
Interior indicated it is in the process of updating policy that will more  clearly define the priority of the use of the Buy Indian Act authority.  Interior also indicated it would develop policy and procedure requirements  for collecting data bureau-wide—including from all Indian Affairs offices  that initiate procurement actions–on the Act’s key requirements, including  self-certification, verification, and validation. Additionally, Interior indicated  it plans to incorporate information related to Buy Indian Act contracts into  its checklist for its annual reviews.
HHS plans to clarify and codify policies related to the priority for use of  the Buy Indian Act in the Indian Health Manual. HHS also plans to  conduct a review of contracts awarded under the Buy Indian Act as part  of its internal procurement oversight reviews and to require all acquisition  offices to conduct regular Buy Indian Act procurement reviews.  Additionally, HHS stated it plans to continue oversight to ensure that  contractors comply with key requirements and that the agency will collect  data on contracts defined in FPDS-NG as American Indian/Alaska Native  owned, but did not specify the extent to which data would be collected on  the regional offices’ implementation of key requirements. As HHS  implements our recommendations, we continue to emphasize the  importance of oversight and data collection at the regional office level and  encourage HHS to take the necessary steps in collecting data from these  offices. Interior and HHS’s written comments are reprinted in appendix I  and appendix II, respectively.
We are sending copies of this report to interested congressional  committees; the Secretary of the Interior; and the Secretary of Health and  Human Services. In addition, this report is available at no charge on the  GAO website at http://www.gao.gov.
If you or your staff have questions about this report, please call me at  (202) 512-4841. Contact points for our Offices of Congressional Relations  and Public Affairs may be found on the last page of this report. GAO staff  that made major contributions to this report are listed in appendix III.
section_title: Appendix I: Comments from the Department of the Interior
section_title: Appendix II: Comments from the Department of Health and Human Services
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact:
section_title: Staff Acknowledgments:
paragraphs: In addition to the contact named above, Janet McKelvey, Assistant  Director; Julie C. Hadley, Analyst-in-Charge; Matthew J. Ambrose,  Danielle R. Greene, Kristine R. Hassinger, Julia M. Kennon, Jeffery D.  Malcolm, and Roxanna T. Sun made key contributions to this report.