Department of Homeland Security: Challenges in Implementing the Improper Payments Information Act and Recovering Improper Payments
Published: 2007-09-19T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The federal government is accountable for how its agencies and grantees spend more than $2 trillion of taxpayer dollars and is responsible for safeguarding those funds against improper payments as well as for recouping those funds when improper payments occur. The Congress enacted the Improper Payments Information Act of 2002 (IPIA) and the Recovery Auditing Act to address these issues. Fiscal year 2006 marked the third year that agencies were required to report improper payment and recovery audit information in their Performance and Accountability Reports. The Department of Homeland Security (DHS) reported limited information during these 3 years. GAO was asked to (1) determine the extent to which DHS has implemented the requirements of IPIA, (2) identify actions DHS has under way to improve IPIA compliance and reporting, and (3) determine what efforts DHS has in place to recover improper payments. To accomplish this, GAO analyzed DHS's internal guidance and action plans, and reviewed information reported in its Performance and Accountability Reports.
section_title: What GAO Found
paragraphs: DHS has made some progress in implementing IPIA requirements, but much more work remains for the agency to become compliant with IPIA. For example, while DHS has made progress in identifying its programs, for fiscal year 2006, the agency did not perform the required first step--a risk assessment--on approximately $13 billion of its more than $29 billion in disbursements subject to IPIA. Until DHS fully assesses its programs, the potential magnitude of improper payments is unknown. For the remaining $16 billion, DHS determined that two programs-- Individuals and Households Program (IHP) assistance payments and disaster-related vendor payments--were at high risk for issuing improper payments and reported related estimates. For the $13 billion for which no risk assessment was performed, DHS has encountered challenges with IPIA implementation. Of this amount, over $6 billion relates to payments for grant programs. Developing a plan to assess risk and potentially test grant payments is important given that the DHS Office of Inspector General, GAO, and other auditors have identified weaknesses in grant programs. This will allow DHS to gain a better understanding of its risk for improper payments and potentially reduce future improper payments. DHS has actions under way to improve IPIA reporting and compliance, but does not plan to be fully compliant in fiscal year 2007. DHS has prepared a plan to address its noncompliance with IPIA, which included updating its guidance to focus on program identification and risk assessments to build a foundation for a sustainable IPIA program. In addition, DHS has developed plans to reduce improper payments related to its two identified high-risk programs. However, until DHS fully completes the required risk assessments for all of its programs and then estimates for risk-susceptible programs, it is not known whether other programs have significant improper payments that also need to be addressed. In addition, DHS's efforts to recover improper payments could be improved. According to DHS, four of its components meet the criteria for recovery auditing as specified in the Recovery Auditing Act. These four components make at least $4 billion of contractor payments each fiscal year. DHS encountered problems that kept it from reporting on recovery audit efforts during fiscal year 2006 for three of the four components, and did not perform recovery auditing at the fourth component. In March 2007, DHS revised its guidance to clarify what is expected; however, ongoing oversight will be necessary to monitor the components' progress. In addition, DHS has reported limited information on its efforts to recover specific improper payments identified during its testing of high-risk programs. Although DHS is not currently required to do so, reporting this information would provide a more complete picture of the agency's actions to recover payments that it has identified as being improper.

section_title: Letter
paragraphs: Over the past several years, our work has shown that improper payments  continue to be a substantial problem for federal agencies. As the steward  of taxpayer dollars, the federal government is accountable for how its  agencies and grantees spend more than $2 trillion of taxpayer dollars each  year and is responsible for safeguarding those funds against improper  payments. Fiscal year 2004 marked the first year in which agencies were  required to report improper payments information in their Performance  and Accountability Reports (PAR) under the Improper Payments  Information Act of 2002 (IPIA). As a result, federal agencies reported an  estimated $46 billion in improper payments for fiscal year 2004. Although  governmentwide reported amounts of estimated improper payments  decreased between fiscal year 2004 and fiscal year 2006, the reported  amount in fiscal year 2006 included more than $800 million as a result of  improper disaster-related payments made by the Federal Emergency  Management Agency (FEMA) within the Department of Homeland  Security (DHS) in response to the 2005 Gulf Coast hurricanes. Since its  establishment in March 2003, DHS, whose annual budget generally tops  $30 billion, has yet to comply with IPIA. Moreover, during fiscal year 2006,  its independent auditors continued to report significant internal control  weaknesses such as weaknesses in financial management and oversight,  and a weak control environment. A weak internal control environment  increases an agency’s susceptibility to improper payments.
Generally, agencies, including DHS, must perform four key steps to  address the specific improper payment reporting requirements found in  IPIA and related Office of Management and Budget (OMB) guidance—  (1) perform a risk assessment of all programs and activities, (2) estimate  improper payments for risk-susceptible programs and activities,   (3) implement a plan to reduce improper payments for programs with  estimates exceeding $10 million, and (4) annually report improper  payment estimates and actions to reduce them. In addition, agencies that  enter into contracts with a total value exceeding $500 million in a fiscal  year are required under section 831 of the National Defense Authorization  Act for Fiscal Year 2002, commonly known as the Recovery Auditing Act,  to have cost-effective programs for identifying errors in payments to  contractors and for recovering amounts erroneously paid.
Given the reported condition of DHS’s internal controls and reported  noncompliance with IPIA, you asked us to conduct a review of the  department’s implementation of IPIA. Specifically, our objectives were to  (1) determine the extent to which DHS has implemented the requirements  of IPIA, (2) identify actions DHS has under way to improve IPIA  compliance and reporting, and (3) determine what efforts DHS has in  place to recover improper payments. To address these objectives, we  reviewed applicable improper payments legislation, OMB guidance, and  agency Office of Inspector General (OIG) reports. We also reviewed  improper payment information reported in DHS’s PARs over the past   3 fiscal years (2004–2006). In addition, we analyzed DHS’s regulations and  methodology for identifying programs and activities highly susceptible to  improper payments, interviewed officials from the Office of the Chief  Financial Officer (OCFO), reviewed workpapers prepared by DHS’s  independent auditor, and summarized the results of this review. In  addition, we reviewed DHS’s plans to reduce improper payments and  become compliant with IPIA and the Recovery Auditing Act.
To assess the reliability of data reported in DHS’s PARs related to  improper payments and recovery audit efforts, we (1) reviewed existing  information about the data and the system that produced them and   (2) interviewed agency officials knowledgeable about the data. We  determined that the data were sufficiently reliable for the purposes of this  report. We conducted our work from October 2006 through June 2007 in  accordance with generally accepted government auditing standards. See  appendix I for more details on our scope and methodology.
subsections: section_title: Background
paragraphs: Our work over the past several years has demonstrated that improper  payments are a long-standing, widespread, and significant problem in the  federal government. IPIA has increased visibility over improper payments  by requiring executive branch agency heads to identify programs and  activities susceptible to significant improper payments, estimate amounts  improperly paid, and report on the amounts of improper payments and  their actions to reduce them. Similarly, the Recovery Auditing Act  provides an impetus for applicable agencies to systematically identify and  recover contract overpayments. As the steward of taxpayer dollars, the  federal government is accountable for how its agencies and grantees  spend hundreds of billions of taxpayer dollars and is responsible for  safeguarding those funds against improper payments as well as having  mechanisms in place to recoup those funds when improper payments  occur.
subsections: section_title: Improper Payments Information Act of 2002
paragraphs: IPIA was enacted in November 2002 with the major objective of enhancing  the accuracy and integrity of federal payments. IPIA requires executive  branch agency heads to review their programs and activities annually and  identify those that may be susceptible to significant improper payments.  For each program and activity agencies identify as susceptible, the act  requires them to estimate the annual amount of improper payments and to  submit those estimates to the Congress. The act further requires that for  programs for which estimated improper payments exceed $10 million,  agencies are to report annually to the Congress on the actions they are  taking to reduce those payments.
The act also requires the Director of OMB to prescribe guidance for  agencies to use in implementing IPIA. OMB issued implementing guidance  which requires the use of a systematic method for the annual review and  identification of programs and activities that are susceptible to significant  improper payments. The guidance defines significant improper payments  as those in any particular program that exceed both 2.5 percent of  program payments and $10 million annually. It requires agencies to  estimate improper payments annually using statistically valid techniques  for each susceptible program or activity. For those agency programs  determined to be susceptible to significant improper payments and with  estimated annual improper payments greater than $10 million, IPIA and  related OMB guidance require each agency to annually report the results  of its efforts to reduce improper payments. OMB has stated that having  high-quality risk assessments is critical to meeting the objectives of  identifying improper payments and is essential for performing corrective  actions to eliminate payment errors. Figure 1 provides an overview of the  four key steps OMB requires agencies to perform in meeting the improper  payment reporting requirements.
section_title: Recovery Auditing Act
paragraphs: In addition, under certain conditions, applicable agencies are required to  report on their efforts to recover improper payments made to contractors  under section 831 of the National Defense Authorization Act for Fiscal  Year 2002, commonly known as the Recovery Auditing Act. This legislation  contains a provision that requires executive branch agencies entering into  contracts with a total value exceeding $500 million in a fiscal year to have  cost-effective programs for identifying errors in paying contractors and for  recovering amounts erroneously paid. The act further states that a  required element of such a program is the use of recovery audits and  recovery activities. The law authorizes federal agencies to retain recovered  funds to cover actual administrative costs as well as to pay other  contractors, such as collection agencies. Agencies that are required to  undertake recovery audit programs were directed by OMB to provide  annual reports on their recovery audit efforts, along with improper  payment reporting details, in an appendix to their PARs.
section_title: OMB Guidance and Initiatives
paragraphs: In August 2006, OMB revised its IPIA implementing guidance. The revision  consolidates into Appendix C of OMB Circular No. A-123, Management’s  Responsibility for Internal Control, all guidance for improper payments  and recovery auditing reporting. While inconsistent with the language in  IPIA, the revised guidance allows for risk assessments to be conducted  less often than annually for programs where improper payment baselines  are already established, are in the process of being measured, or are  scheduled to be measured by an established date. Although OMB kept its  criteria for defining significant improper payments as those exceeding  both 2.5 percent of program payments and $10 million, OMB added that it  may determine on a case-by-case basis that certain programs that do not  meet the threshold may be subject to the annual reporting requirement.  Additionally, the revised guidance allows agencies to use alternative  sampling methodologies and requires agencies to report on and provide a  justification for using these methodologies in their PARs. This revised  guidance is effective for agencies’ fiscal year 2006 improper payment  estimating and reporting in the PARs or annual reports.
Other OMB guidance states that agencies must describe their corrective  actions for reducing the estimate rate and amount of improper payments.  Related to corrective actions, OMB’s implementing guidance for IPIA  requires that agencies implement a plan to reduce erroneous payments,  including identifying the following.
Root causes—For all programs and activities with erroneous payments  exceeding $10 million, agencies shall identify the reasons their programs  and activities are at risk of erroneous payments and put in place a  corrective action plan to reduce erroneous payments.
Reduction targets—Targets are necessary for future improper payment  levels and a timeline within which the targets will be reached.
Accountability—Ensure that their managers and accountable officers  (including the agency head) are held accountable for reducing improper  payments. Agencies shall assess whether they have the information  systems and other infrastructure needed to reduce improper payments to  minimal cost-effective levels, and identify any statutory or regulatory  barriers that may limit agencies’ corrective actions in reducing improper  payments.
OMB has also established Eliminating Improper Payments as a program- specific initiative under the President’s Management Agenda (PMA). This  separate PMA program initiative began in the first quarter of fiscal year  2005. Previously, agency efforts related to improper payments were  tracked along with other financial management activities as part of the  Improving Financial Performance initiative of the PMA. The objective of  establishing a separate initiative for improper payments was to ensure that  agency managers are held accountable for meeting the goals of IPIA and  are therefore dedicating the necessary attention and resources to meeting  IPIA requirements. This program initiative establishes an accountability  framework for ensuring that federal agencies initiate all necessary  financial management improvements for addressing this significant and  widespread problem. Specifically, agencies are to measure their improper  payments annually, develop improvement targets and corrective actions,  and track the results annually to ensure the corrective actions are  effective.
section_title: DHS Has Made Some Progress in Implementing the Requirements of IPIA, but Remains Noncompliant
paragraphs: While DHS has taken actions over the last 3 fiscal years to implement IPIA  requirements, much more work needs to be done. In each of the last   3 fiscal years, DHS was unable to perform risk assessments for all of its  programs and activities—the first step of IPIA implementation. This and  other issues, such as concerns about program identification and testwork  performed, contributed to DHS’s reported noncompliance with IPIA over  the last 3 fiscal years. Until DHS is able to fully assess its programs, the  potential magnitude of improper payments cannot be estimated.
For fiscal year 2006, DHS did not perform risk assessments on programs  with $13 billion of its $29 billion of payments subject to IPIA. Over   $6 billion of this amount related to payments for grant programs.  Performing risk assessments of grant programs and testing grant payments  can be difficult because of the many layers of grant recipients, as well as  the type of recipients and number of grant programs. However, developing  a plan to assess risk and potentially test grant payments is important  because of financial management weaknesses reported at DHS grantees  and concerns about DHS’s grants management process. Developing a plan  will also allow DHS to gain an understanding of its risk with respect to  grant payments and potentially reduce future improper payments.
subsections: section_title: DHS’s Efforts to Meet IPIA Requirements
paragraphs: To comply with the requirements of IPIA and related guidance from OMB,  DHS initiated a plan in fiscal year 2004 to reduce its susceptibility to  issuing improper payments by having each of its organizational elements  complete a risk assessment of major programs by assigning each one an  overall risk score. Based on this assessment, none of DHS’s programs  were found to be high risk; however, DHS’s independent auditor reported  that the agency was not in compliance with IPIA mainly because it had not  yet instituted a systematic method of reviewing all programs and  identifying those it believed were susceptible to significant erroneous  payments.
In fiscal year 2005, the auditor again reported noncompliance issues  regarding the adequacy of the agency’s risk assessments. Based on DHS’s  guidance, each component selected its largest program and completed  statistical testing. DHS regarded this quantitative selection as its risk  assessment process and did not incorporate qualitative factors. As with  fiscal year 2004, DHS reported that it did not identify any programs or  activities as being susceptible to significant improper payments and its  auditors again reported that DHS was not in compliance with IPIA.
The DHS OCFO worked with components during fiscal year 2006 to  continue to refine the population of improper payment programs by  having the components group Treasury Appropriation Fund Symbols  (TAFS) into logical, recognizable programs. After identifying the  population of disbursements for fiscal year 2006 IPIA testing, DHS  components provided the necessary payment data to a contractor with  expertise in statistical testing. The contractor constructed stratified  sampling plans and samples for DHS components to perform IPIA testing  for DHS’s risk assessment process. This testing was expanded from fiscal  year 2005 to include, based on DHS’s revised guidance, all DHS programs  issuing more than $100 million of IPIA-relevant payments. Two programs  were found to be high risk. However, despite these efforts, DHS’s  independent auditor found that the agency was still not in compliance with  IPIA as reported in its fiscal year 2006 PAR, primarily because not all  programs subject to IPIA were tested, and the population of  disbursements tested for some programs was not complete. Appendix III  contains additional information about DHS’s prior year IPIA PAR reporting  and compliance issues reported by its independent auditor.
section_title: Required Risk Assessments Not Completed for All Programs for Fiscal Year 2006
paragraphs: Although DHS made progress in identifying its programs in fiscal year  2006, the agency did not perform a risk assessment for all programs and  activities—covering approximately $13 billion of its more than $29 billion  in disbursements subject to IPIA. According to DHS, this was primarily  due to a lack of resources, guidance, and experience in performing this  work. This was a major factor in the independent auditors’ finding that  DHS was noncompliant with IPIA for fiscal year 2006. DHS performed risk  assessments (step 1) for programs accounting for approximately   $16 billion of the $29 billion in disbursements subject to IPIA review. Of  this $16 billion covered by risk assessments, approximately $7 billion  related to FEMA’s disaster relief programs that were found to be at high  risk for issuing significant improper payments and therefore steps 2  through 4 were completed to estimate improper payments, develop a plan  to reduce improper payments, and report this information. This testing  resulted in estimated improper payments issued by FEMA from   September 2005 through March 2006 of $450 million (8.56 percent) of IHP  assistance payments and $319 million (7.44 percent) of disaster-related  vendor payments. Although the necessary IPIA work—steps 1 and 2— was completed for the two DHS high-risk programs, the time period  covered for testing and reporting (i.e., September 2005 through   March 2006) was not in accordance with OMB’s implementing guidance,  also contributing to DHS’s reported noncompliance with IPIA. The  remaining programs with disbursements totaling $9 billion in  disbursements were not found to be at risk for issuing significant improper  payments and therefore DHS did not report improper payments for these  programs. For some of its nondisaster programs, DHS performed  statistical sample testing for those programs with disbursements greater  than $100 million, without first performing a qualitative risk assessment  such as an assessment of internal controls, oversight and monitoring  activities, and results from external audits. While this approach is perhaps  better than not doing any assessment, DHS officials concurred that it  could be considered an inefficient use of resources, if a program is not at  high risk.
Table 1 shows DHS’s population of programs identified for IPIA testing  and the status of DHS’s IPIA risk assessment process performed in fiscal  year 2006.
Since DHS did not perform the required first step—a risk assessment—on  programs with approximately $13 billion of its more than $29 billion in  disbursements subject to IPIA, it is unknown whether these programs are  at high risk for issuing improper payments.
section_title: Grant Programs Continue to Present a Challenge for IPIA Implementation
paragraphs: DHS encountered challenges implementing IPIA for the programs with   $13 billion of disbursements for which no risk assessment or testing was  performed in fiscal year 2006. Over $6 billion of this amount related to  payments for grant programs. The remaining $7 billion related primarily to  FEMA nondisaster programs and TSA programs not categorized as grant  or nongrant programs, and USCG operating expenses. DHS’s grant  programs include the NFIP, which had disbursements of over $3 billion  that should have been included in DHS’s IPIA population for review in  fiscal year 2006. As we have previously reported, measuring improper  payments and designing and implementing actions to reduce or eliminate  them are not simple tasks, particularly for grant programs that rely on  quality administration efforts at the state level. DHS has an even greater  challenge in the diversity of recipients for its grants which include state  and local governments, individuals, and other entities. During fiscal year  2006, DHS awarded grants to over 5 million recipients for 70 different  grant programs, including state and local governments, nonprofits, and  other entities and individuals. Although disbursements made related to  these grants are subject to IPIA, as DHS has noted, performing risk  assessments of grant programs and testing grant payments are difficult  because of the many layers of grant recipients, as well as the type of  recipients and number of grant programs.
Developing a plan to assess risk and potentially test grant payments is  important because of noted financial management weaknesses of DHS  grantees. For example, DHS’s independent auditors and the DHS OIG have  reported grants management weaknesses in part because the agency did  not adequately follow up on audit findings pertaining to grantees’ potential  improper payments. In addition, the DHS OIG identified grants  management as a major management challenge facing the department. We  have also identified the NFIP as a high-risk program. A list of DHS’s grant  programs is presented in appendix IV. Appendix IV also shows the primary  types of recipients and fiscal year 2006 award information for each grant  program, as well as the component that administers the program. Given  the identified weaknesses and the high-dollar amount, as well as the  inherent risk associated with grant programs, it is important for DHS to  assess grant programs for susceptibility to significant improper payments  in accordance with IPIA. Assessing and, if necessary, testing these grant  programs will allow DHS to gain an understanding of its risk in this area  related to improper payments and potentially reduce future improper  payments.
During fiscal year 2006, DHS completed a risk assessment by performing  sample testing for grants administered by the Transportation Security  Administration (TSA) with disbursements of about $343 million; however,  the department was unable to perform an assessment of its grants  programs administered by the Office of Grants and Training (GT). Of the  approximately $13 billion for which DHS did not perform a risk  assessment, over $3 billion related to grant programs administered by GT.  In addition to the NFIP, FEMA also administers other grant programs  which, with the exception of IHP, were not tested during fiscal year 2006.  DHS identified three IPIA programs within GT, including Domestic  Preparedness, State and Local Programs, and Firefighter Assistance  Grants, totaling $3.1 billion of fiscal year 2005 disbursements for fiscal  year 2006 IPIA testing; however, GT did not perform an assessment or  complete statistical sample testing on these grants programs. In its fiscal  year 2006 PAR, DHS reported that one complication that was not  overcome was how to extend statistical sample testing to grant recipients.  DHS also had difficulty testing its grant programs because of the large  number of grant programs identified for testing based on DHS’s guidance  for fiscal year 2006 program identification and risk assessment  methodology, which required that all programs with total disbursements  exceeding $100 million be selected and statistically tested. DHS reported  that one of the problems with its fiscal year 2006 IPIA methodology was  that its risk assessments were based on strictly quantitative factors,  instead of both qualitative and quantitative factors. Although OMB has not  yet provided guidance as we have previously recommended, DHS issued  internal guidance recognizing the need to consider qualitative factors.
One such qualitative factor that DHS could consider as part of its risk  assessment process are the results of Single Audit Act, as amended,  reports related to its grantees. During fiscal year 2006, DHS’s independent  auditors reported that the agency was not in compliance with the Single  Audit Act. According to the independent auditors’ report, FEMA and TSA  are required to comply with certain provisions of OMB Circular No. A-133,  which requires agencies awarding grants to ensure they receive grantee  reports timely and to follow-up on grantee single audit findings. Although  certain procedures have been implemented to monitor grantees and their  audit findings, the auditors noted that DHS did not have procedures in  place to comply with these provisions in OMB Circular No. A-133 and  follow up on questioned costs and other matters identified in these  reports. TSA has developed a corrective action plan to establish a new  system and processes to track and review single audit reports, but FEMA  has not completely developed its corrective action plans due to the  previously mentioned organizational changes during fiscal year 2007. We  identified 37 DHS grantees—with awards totaling $2.1 billion—that had  single audit findings related to questioned costs for fiscal year 2005. Some  examples of questioned costs described in audit reports follow.
One single audit report questioned $353,000 in unallowable charges for  salaries and benefits due to a lack of adequate documentation.
One grantee had expenditures that did not have appropriate supporting  documentation, with the questioned amount totaling almost $80,000.
Another grantee had costs of about $72,000 that were improperly charged  to the grant program.
A third grantee over-claimed reimbursement amounts of about $4,000.
The DHS OIG also conducts audits relating to the programs and operations  of DHS, including grant programs. The DHS OIG reviews several factors to  determine which activities to audit, including current or potential dollar  magnitude, and reports or allegations of impropriety or problems in  implementing the programs. The objectives of these grant program audits  include determining whether the grantee accounted for and expended  funds according to federal regulations and DHS guidelines. For certain  grantees, the DHS OIG has found questioned costs such as excessive  charges, duplicate payments, ineligible contractor costs, unsupported  contractor and labor costs, and other expenditures. The following are  examples of DHS OIG findings from fiscal years 2005 through 2007.
The DHS OIG found that one particular grantee had questioned costs of  more than $1.8 million.
The DHS OIG has also found instances where the grantee did not follow all  federal procurement standards or DHS guidelines in awarding contracts,  and needed improvements in procedures to make payments to  subgrantees. One instance involved awarding contracts totaling more than  $14 million and another instance involved more than $8 million in contract  work.
In an effort to address the agency’s noncompliance with the Single Audit  Act, as amended, DHS’s Office of Grant Policy and Oversight (GPO) told  us that it instituted an informal oversight process for single audits during  fiscal year 2007 and is in the process of developing formal procedures.  According to GPO, the development of this process is an attempt to  address some of the grants management concerns that have been  identified at DHS by its auditors and the DHS OIG. This monitoring  process will help DHS to focus on audit findings at grantees and could  help DHS with performing a risk assessment over grant programs for IPIA  purposes by providing qualitative criteria.
section_title: While DHS Has Developed Plans to Address IPIA Requirements and Reduce Improper Payments, Full Implementation Will Be Longer Term
paragraphs: DHS has taken steps to address IPIA requirements, but the agency does  not plan to be compliant in fiscal year 2007 and will likely not be  compliant in fiscal year 2008. During fiscal year 2007, DHS prepared, and  continues to refine, a departmentwide corrective action plan to address  internal control weaknesses and noncompliance issues, including IPIA;  however, the agency continues to encounter challenges in developing a  plan to fully perform a risk assessment process. DHS used this corrective  action plan to update its guidance and, according to DHS officials, the  agency plans to focus on program identification and risk assessments  during fiscal year 2007. Although DHS does not expect to be compliant in  fiscal year 2007, focusing on these areas will help the agency build a solid  foundation for its IPIA program.
In addition to its overall corrective action plan to comply with IPIA, DHS,  as required by IPIA and related OMB implementing guidance, has  developed plans to reduce improper payments related to the two high-risk  programs it has identified thus far. These plans include reducing manual  processing, improving system interfaces, and clarifying roles and  responsibilities. If properly executed, these plans should help reduce  future improper payments in these programs by strengthening internal  controls. With regard to system improvements, as we have previously  recommended, DHS needs to conduct effective testing to provide  reasonable assurance that the system will function in a disaster recovery  environment.
subsections: section_title: DHS Has Developed a Corrective Action Plan for Compliance with IPIA, but Implementation Challenges Remain
paragraphs: DHS has developed a corrective action plan to address the findings of its  independent auditor, including its noncompliance with IPIA. In its most  recent audit report for fiscal year 2006, the auditor recommended that  DHS follow OMB guidance to complete the necessary susceptibility  assessments, perform testwork over all material programs, and institute  sampling techniques to allow for statistical projection of the results of its  improper payments testing.
In its IPIA corrective action plan, DHS documented the root causes that it  believes have resulted in its noncompliance, and analyzed the key success  factors, key performance measures, verification and validation  procedures, risks, impediments, dependencies with other corrective  actions, resources required, and critical milestones needed to become  compliant with IPIA; however, implementation will take significant time  and effort. DHS cited its lack of resources, guidance, and experience with  IPIA to execute risk assessments as root causes for its noncompliance  with IPIA. The corrective action plan identified the following items related  to IPIA, including root causes.
DHS also identified critical milestones in its corrective action plan for IPIA  compliance, including due dates and status. However, these efforts remain  ongoing and DHS has already missed some milestones. For example, while  DHS initially planned for each component to identify its IPIA programs  and disbursement populations by January 2007, this milestone was  delayed until June 2007. As of July 8, 2007, according to DHS, the agency  was waiting for one component to submit its list of programs, and DHS  was in the process of reviewing submissions from the other components.  Because of such delays, DHS does not expect to be in compliance with  IPIA in fiscal year 2007 and will likely be noncompliant in fiscal year 2008.  DHS’s updated critical milestones as of June 7, 2007, related to fiscal year  2007 are presented in table 3.
DHS’s planning and assessment process to develop its IPIA corrective  action plan enabled the agency to update its guidance for its components  and, according to DHS, the agency plans to focus on program  identification and risk assessments during fiscal year 2007. Strengthening  risk assessments and identifying potential improper payments are also  important in order for DHS to begin taking steps to reduce improper  payments and ultimately improve the integrity of the payments it makes.  According to DHS officials, the department has been working in close  consultation with OMB, sharing guidance documents, program test plans  and results, and recovery audit status reports. Regardless of whether DHS  is able to fully complete these efforts in fiscal year 2007, focusing on these  areas will help the agency build a solid foundation for a sustainable IPIA  program.
The updated guidance was issued in May 2007 and is to be in effect for  fiscal year 2007 reporting. In this revised guidance, DHS clarifies how its  components should identify their population of programs. In addition,  DHS requires its components to perform a comprehensive risk assessment  in order to identify programs susceptible to significant improper  payments. DHS has designed a detailed methodology to conduct the IPIA  risk assessment, and this methodology is outlined in the May 2007  guidance. The methodology, which includes qualitative criteria, as we have  previously discussed, involves the creation of a program risk matrix based  upon specific risk elements that affect the likelihood of improper  payments. Further, the guidance states that a program may be selected for  testing even if it does not meet the quantitative or qualitative assessments,  noting that it is entirely possible that the risk assessment process may not  identify a program as high risk, but component management may believe a  program is high risk due to a high-level public profile or known financial  or regulatory issues (such as a high-profile contract). For those programs  found to be at high risk for issuing improper payments, the guidance also  provides instructions for estimating improper payments, implementing a  plan to reduce improper payments, and reporting on this information.  Each of these procedures outlined in the May 2007 guidance includes  instructions to submit information or documentation to the Internal  Controls over Financial Reporting (ICOFR) Program Management Office  (PMO).
DHS’s May 2007 guidance for fiscal year 2007 also outlines possible  alternative approaches for testing grants. One possible alternative is the  complete documentation of the component’s grant management process  and the testing of internal controls. According to DHS, this approach helps  the component identify specific weaknesses within the grant process,  rather than sampling payments at random to determine potential errors. A  second alternative is to perform a risk assessment on the program’s grant  portfolio. This alternative helps the program identify specific grants that  may be more susceptible to improper payments. The identified grants  would then be subject to improper payment sampling. If a component  wishes to consider alternative approaches to grant sampling, an  explanatory memorandum must be submitted to the ICOFR PMO for  review and approval. If approved by the ICOFR PMO, DHS will submit the  alternative approach request to OMB for review and approval. Also, OMB   has reported that the Chief Financial Officers (CFO) Council continues  to play a critical role in efforts to address and reduce improper payments  through its Improper Payments Transformation Team. This group has been  collaborating with nongovernmental entities to consolidate  governmentwide best practices; enumerate legislative and regulatory  barriers that hinder program integrity efforts; and develop forums where  federal and state stakeholders from the program, audit, and financial  communities work together to solve program integrity challenges. These  activities could provide guidance to help DHS determine how to best test  its grant programs.
DHS also plans to hold workshops for its components on statistical sample  testing and reporting to ensure that they have a consistent understanding  of what is expected with regard to IPIA testing and reporting. Although  DHS does not expect to be in compliance with IPIA in fiscal year 2007,  completing a thorough risk assessment process is an important first step.
section_title: DHS Has a Broader Initiative to Resolve Internal Control Weaknesses across the Department
paragraphs: In addition to developing the corrective action plans described, DHS has a  broader initiative to resolve material internal control weaknesses and  build management assurances across the department. During fiscal year  2007, DHS established the ICOFR PMO as a new office within the DHS  OCFO. The ICOFR PMO is responsible for departmentwide  implementation of OMB Circular No. A-123. In March 2007, DHS issued the  ICOFR Playbook, which outlines the department’s strategy and processes  to resolve material weaknesses and build management assurances and  incorporates the departmentwide corrective action plans, which contain  more detailed information. The ICOFR PMO is responsible for the ICOFR  Playbook and, according to DHS, the agency will update the ICOFR  Playbook each year, establishing milestones and focus areas that will be  tracked during the year. One section of the ICOFR Playbook relates to  IPIA testing, and it discusses the actions taken by DHS in fiscal year 2006  to meet IPIA requirements. This section also states that DHS will develop  policies and procedures to integrate the requirements of OMB’s  implementing guidance for IPIA into annual component management  assurances of compliance with significant laws and regulations, as part of  DHS management’s assertion on internal controls over financial reporting  and in an effort to strengthen internal controls to support DHS’s mission.  In addition to management providing an assertion on internal controls  over financial reporting, DHS is required to obtain a related auditor’s  opinion. Incorporating IPIA into this guidance will increase the likelihood  of successful implementation and could also strengthen related internal  controls.
The ICOFR Playbook draws attention to the process of addressing IPIA  requirements across the department. By successfully addressing the  requirements of IPIA, DHS will be in a better position to take steps to  reduce improper payments, as the ultimate goal of IPIA reporting is to  improve the integrity of payments that the agency makes. Further, DHS  has testified that to ensure the long-term effectiveness of the department’s  efforts to reduce improper payments, DHS requested resources in its fiscal  year 2008 budget to hire additional staff so that it can enhance risk  assessment procedures and conduct oversight and review of component  test plans.
section_title: DHS Has Developed Plans to Reduce Improper Payments for FEMA’s Two Disaster-Related Programs, but Effects Remain Unknown
paragraphs: In addition to its overall corrective action plan to comply with IPIA, DHS,  as required by IPIA and related OMB implementing guidance, has  developed plans to reduce improper payments related to the two high-risk  programs it identified in its fiscal year 2006 testing—FEMA’s IHP  assistance payments and disaster-related vendor payment programs. These  plans highlighted improving internal controls to prevent improper  payments in each of these programs.
FEMA’s testing of its two high-risk disaster-related programs identified  several key internal control weaknesses, including ineffective system  controls to review data for potential duplications and inconsistently  applied standards for supporting evidence and documentation. To address  these findings, FEMA initiated corrective action plans aimed at reducing  improper payments by strengthening internal controls. These plans  included validating Social Security numbers during telephone registration,  increasing IT systems capabilities to handle high volume during a  catastrophic disaster, and enhancing post-payment reviews. Our prior  reporting also identified significant internal control deficiencies in the  IHP program.
To address OMB’s reporting requirements on actions for reducing  improper payments, DHS included in its fiscal year 2006 PAR corrective  action plans for IHP assistance payments and disaster-related vendor  payments. For each of the two high-risk programs, DHS prepared a  schedule of corrective action plans with target completion dates. For the  IHP program, DHS included corrective action plans that were already  completed in addition to those in process and planned. DHS has also  established critical milestones for reducing improper, disaster-related  vendor payments. During fiscal year 2007, DHS updated and tracked its  corrective action plan critical milestones. Details of these corrective  action plan critical milestones can be found in appendix V.
Based on DHS’s updated corrective action plan report for IHP, as of   May 14, 2007, DHS had not completed certain critical milestones by the  identified target date. These milestones included system interface  improvements and certain contract awards. Missing these established  critical milestones delays strengthening internal controls that are  necessary to reduce future improper payments, and therefore it is  important that DHS stays on track in implementing its corrective action  plans.
DHS also noted that human capital is the principal requirement to execute  these two corrective action plans; however, according to DHS, exact  requirements are not estimable at this time. With regard to system  improvements, as we have previously recommended, DHS needs to  conduct effective testing to provide reasonable assurance that the system  will function in a disaster recovery environment.
section_title: DHS’s Efforts to Comply with the Recovery Auditing Act and to Recover Improper Payments Need to Be Enhanced
paragraphs: For the last 3 years, DHS has contracted with a recovery auditing firm to  perform recovery audit work to comply with the Recovery Auditing Act;  however, activities in this area could be improved. Specifically, DHS  encountered problems that kept it from reporting on recovery audit efforts  during fiscal year 2006. DHS was not able to report recovery audit results  in fiscal year 2006 for three of the four components it identified as meeting  the criteria for recovery auditing as specified in the Recovery Auditing Act  (i.e., over $500 million in contractor payments) due to problems obtaining  disbursement data and delays in obtaining security clearances for contract  personnel. In addition, DHS did not perform recovery auditing efforts at  the fourth component identified as meeting the criteria. Further, DHS has  not yet reported on its efforts to recover improper payments identified  during its testing of FEMA’s disaster-related vendor payments and has  reported limited information on its efforts to recover identified improper  IHP assistance payments.
In March 2007, DHS revised its internal guidance for recovery auditing for  fiscal year 2007 to discuss the issues encountered in previous years and to  emphasize timelines to help ensure that all applicable components are  able to report. This guidance clarifies what is expected of applicable  components, but ongoing oversight within the OCFO will be necessary to  ensure that components are progressing with their recovery auditing  efforts and will be able to successfully report on the results of these  efforts at year end. In addition, DHS’s updated guidance does not require  components to report on efforts to recover improper payments identified  during IPIA testing. Reporting this information in the annual PAR would  provide a more complete picture of the agency’s actions to recover  payments that it has identified as being improper.
subsections: section_title: Recovery Auditing Efforts at DHS Could Be Improved
paragraphs: As an executive branch agency, DHS is required to perform recovery  audits under certain conditions as specified by the Recovery Auditing Act.  Beginning with fiscal year 2004, OMB required that applicable agencies  publicly report on their recovery auditing efforts as part of their PAR  reporting of improper payment information. Agencies are required to  discuss any contract types excluded from review and justification for  doing so. Agencies are also required to report, in table format, various  amounts related to contracts subject to review and actually reviewed,  contract amounts identified for recovery and actually recovered, and  prior-year amounts.
DHS took steps to identify and recover improperly disbursed funds by  hiring an independent contractor who conducted recovery audit work at  two major components, ICE and CBP. DHS began recovery auditing  efforts during fiscal year 2004 but was not able to report on these efforts  for that year because initial findings were not available in time to be  included in the annual PAR. This recovery audit work continued during  fiscal year 2005 and covered all fiscal year 2004 disbursements to  contractors from these two components, ultimately identifying more than  $2.1 million of improper payments and recovering more than $1.2 million,  as reported in DHS’s fiscal year 2005 PAR. While DHS was able to recover  about 55 percent of improper payments identified through its recovery  audit efforts, based on our review of other agencies, we have previously  questioned whether agency amounts identified for recovery should have  been much higher, which would thereby significantly decrease the agency- specific and overall high rate of recovery.
According to DHS’s fiscal year 2006 PAR reporting, recovery audit  contract work over fiscal year 2005 disbursements began in fiscal year  2005 at CBP and ICE, and DHS extended its recovery audit work to  include USCG in fiscal year 2006. Delays in obtaining security clearances  for contract personnel severely hampered completion of recovery audit  work at CBP and ICE. Delays in supplying needed disbursement  information hindered recovery audit work at USCG. As a result, DHS was  not able to provide conclusive recovery audit summary results for fiscal  year 2006 PAR reporting. According to DHS, four of its components—ICE,  CBP, USCG, and FEMA—meet the criteria for recovery auditing as  specified in the Recovery Auditing Act (i.e., each has over $500 million in  contractor payments). ICE, CBP, and USCG entered into the same  recovery audit contract. FEMA’s recovery audit work in fiscal year 2006  was part of a pilot study on internal controls over improper payments for  IHP assistance and disaster-related vendor payments. In the aftermath of  Hurricane Katrina, DHS and FEMA, with the assistance of a contractor,  conducted an internal controls assessment related to improper IHP  assistance and disaster-related vendor payments. Although this  assessment identified improper payments, DHS has not yet reported on its  efforts to recover improper payments identified during its testing of  FEMA’s disaster-related vendor payments and has reported limited  information, such as the dollar amount of improper payments approved  for recovery and the amount returned to FEMA, related to its efforts to  recover improper IHP payments.
Of the 3 years agencies have been required to report on recovery audits in  table format, DHS was only able to report required recovery audit data in  its fiscal year 2005 PAR. Table 4 presents DHS’s recovery audit efforts  and results for fiscal years 2004 through 2006.
section_title: DHS’s Internal Guidance for Recovering Improper Payments Has Been Revised but Additional Information Could Be Reported
paragraphs: DHS has recently revised and clarified its internal guidance related to  recovery auditing for fiscal year 2007 to discuss prior issues and  emphasize timelines to help ensure that all applicable components are  able to complete recovery audits and report on their efforts. The new  guidance requires that applicable DHS components provide the ICOFR  PMO with a general description and evaluation of the steps taken to carry  out a recovery auditing program. Components are required to include a  discussion of any security clearance requirements and show that there is  sufficient time to allow contractors to complete audit recovery work in  time to meet PAR reporting deadlines. Every update should include the  total amount of contracts subject to review, the actual amount of contracts  reviewed, the amount identified for recovery, and the amounts actually  recovered in the current year. The year-end update should include a  corrective action plan to address the root causes of payment errors. A  general description and evaluation of any management improvements to  address flaws in a component’s internal controls over contractor payments  discovered during the course of implementing a recovery audit program,  or other control activities over contractor payments, is also required. This  guidance applies to the four DHS components—CBP, FEMA, ICE, and  USCG—that meet Recovery Auditing Act criteria. In addition, according to  DHS, the ICOFR PMO may expand recovery audit contracting to other  components as the benefits of this work become clearer. Although DHS’s  guidance clarifies what is expected of components, ongoing oversight  within the OCFO will be necessary to ensure that the components are  progressing with their recovery auditing efforts and will be able to  successfully report on results at year end.
In addition to specific recovery audit work to identify improper payments  made to contractors, DHS also identifies improper payments through its  IPIA testing. For example, as discussed previously, DHS’s testing in fiscal  year 2006 of its two high-risk programs identified improper IHP assistance  payments and disaster-related vendor payments made by FEMA. However,  DHS’s internal guidance does not require components to include  information in its annual PAR related to its efforts to recover improper  payments identified during IPIA testing and, as a result, DHS has not yet  reported on its efforts to recover improper disaster-related vendor  payments identified and has reported limited information on its efforts to  recover identified improper IHP assistance payments. Having components  report this information in the annual PAR would provide a more complete  picture of the agency’s actions to recover payments that it has identified as  being improper.
section_title: Conclusions
paragraphs: Although DHS has made some progress in implementing the requirements  of IPIA, challenges remain in ensuring that all DHS programs and  activities, including grant programs, have been reviewed to determine  their susceptibility to significant improper payments and tested, if  applicable. As DHS continues to improve its IPIA efforts and identify and  test its high-risk programs, the agency should be better able to identify,  and ultimately strengthen controls, to reduce improper payments.
While preventive internal controls should be maintained as the agency’s  front-line defense against making improper payments, recovery auditing  holds promise as a cost-effective means of identifying contractor  overpayments. In addition, reporting on efforts to recover any other  specific improper payments identified would provide a more complete  picture of the agency’s actions to recover payments that it has identified as  being improper. With the ongoing imbalance between revenues and  outlays across the federal government, and the Congress’s and the  American public’s increasing demands for accountability over taxpayer  funds, identifying, reducing, and recovering improper payments become  even more critical.
section_title: Recommendations for Executive Action
paragraphs: To help improve its efforts to implement IPIA and recover improper  payments, we recommend that the Secretary of Homeland Security direct  the Chief Financial Officer to take the following actions.  (1) Maintain oversight and control over critical milestones identified in the  DHS corrective action plan for IPIA compliance so that DHS components  stay on track, specifically in regard to identifying programs and  performing risk assessments and any related testing.  (2) Require all applicable components to determine and document how  they plan to assess their grant programs to determine whether they are at  high risk for issuing significant improper payments, and, if necessary, test  these grant programs.  (3) Provide oversight and monitor the progress of all applicable DHS  components to successfully perform and report on their recovery auditing  efforts.  (4) Similar to the required reporting on efforts to recover improper  payments made to contractors under the Recovery Auditing Act, develop  procedures for reporting in its annual PAR on the results of yearly efforts  to recover any other known improper payments identified under IPIA, by  the DHS OIG, or other external auditors.
section_title: Agency Comments and Our Evaluation
paragraphs: We requested comments on a draft of this report from the Secretary of  Homeland Security. These comments are reprinted in appendix II. DHS  concurred with the recommendations in our report. DHS noted that  significant actions under way include strengthening the department’s  financial management and oversight functions to improve the DHS control  environment and implementing risk assessments to build a foundation for  a sustainable IPIA program.
As agreed with your offices, unless you publicly announce its contents  earlier, we plan no further distribution of this report until 30 days after its  date. At that time, we will send copies of this report to the Secretary of  Homeland Security and other interested parties. Copies will also be made  available to others upon request. In addition, this report will also be  available at no charge on GAO’s Web site at http://www.gao.gov.
If you or your staff have any questions regarding this report, please  contact me at (202) 512-9095 or at williamsm1@gao.gov. Contact points for  our Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. GAO staff who made contributions to this  report are listed in appendix VI.
section_title: Appendix I: Scope and Methodology
paragraphs: To determine to what extent the Department of Homeland Security (DHS)  has implemented the requirements of the Improper Payments Information  Act of 2002 (IPIA), we compared the IPIA legislation, and the related  Office of Management and Budget (OMB) implementing guidance, with  DHS improper payment risk assessment methodologies, and IPIA  Performance and Accountability Report (PAR) information for fiscal years  2004 through 2006. To analyze DHS risk assessment compliance with IPIA,  we obtained and reviewed documents regarding its regulations and  methodology for identifying programs and activities highly susceptible to  improper payments. We reviewed DHS’s PARs, Office of Inspector General  (OIG) semiannual reports to the Congress, and GAO reports for fiscal  years 2004 through 2006 for improper payment information. We also  reviewed procedures performed by DHS’s independent financial statement  auditor related to DHS’s compliance with IPIA.
We reviewed the programs that DHS identified as its IPIA population and  analyzed the risk assessments that were performed during fiscal year 2006.  This allowed us to determine which components did not perform a risk  assessment and which programs were not covered. During our review, we  noted that the Office of Grants and Training (GT), a DHS component, did  not perform an assessment or complete payment statistical sample testing  on its grants programs for fiscal year 2006 as required of all DHS programs  issuing more than $100 million of IPIA relevant payments in fiscal year  2005. To analyze improper payments related to DHS grantees and highlight  the importance of performing IPIA testing in this area, we obtained and  reviewed fiscal year 2005 single audit reports of these entities. We used  fiscal year 2005 reports because that is the most recent year for which  complete audit results have been posted to the Federal Audit  Clearinghouse (FAC). We also reviewed GAO reports and DHS OIG  Financial Assistance (Grants) Reports for fiscal year 2005 through fiscal  year 2007 to identify weaknesses reported at DHS grantees. In addition, we  reviewed DHS OIG Management Reports (audits and inspections) for  fiscal year 2005 through fiscal year 2007 that were related to grants and  DHS OIG semiannual reports to the Congress for fiscal years 2005 and  2006 to identify questioned costs related to DHS grantees.
To identify what actions DHS has under way to improve IPIA compliance  and reporting, we interviewed DHS staff in the Office of the Chief  Financial Officer and reviewed DHS corrective action plans and the  Internal Controls Over Financial Reporting (ICOFR) Playbook. We also  reviewed DHS’s IPIA implementing guidance for fiscal year 2007—revised  in March 2007 and May 2007—and determined whether it was consistent  with IPIA requirements. We discussed these revisions with improper  payment and financial management officials from DHS to inquire about  what is currently being implemented and what will be implemented in the  future to ensure compliance with DHS’s revised internal guidance.
To determine what efforts DHS has in place to recover improper  payments, we compared section 831 of the National Defense Authorization  Act for Fiscal Year 2002, commonly known as the Recovery Auditing Act,  and the related OMB implementing guidance, with DHS recovery auditing  procedures and PAR-reported information for fiscal year 2006. We also  reviewed DHS PARs, OIG semiannual reports to the Congress, and GAO  reports for fiscal years 2004 through 2006 for recovery audit information.
To assess the reliability of data reported in DHS’s PARs related to  improper payments and recovery audit efforts, we (1) reviewed existing  information about the data and the system that produced them and   (2) interviewed agency officials knowledgeable about the data. Based on  these assessments, we determined that the data were sufficiently reliable  for the purposes of this report. We conducted our work from October 2006  through June 2007 in accordance with generally accepted government  auditing standards. We requested comments on a draft of this report from  the Secretary of Homeland Security or his designee. The Director,  Departmental GAO/OIG Liaison Office, provided written comments, which  are presented in the Agency Comments and Our Evaluation section of this  report and are reprinted in appendix II.
section_title: Appendix II: Comments from the Department of Homeland Security
section_title: Appendix III: Prior-Year IPIA Reporting by DHS and Its Independent Auditor
paragraphs: Table 5 presents information on prior-year IPIA reporting by DHS,  including compliance issues reported by the independent auditor.
section_title: Appendix IV: DHS Grant Programs
paragraphs: Table 6 provides a list of DHS grant programs, primary recipients, and  award information for fiscal year 2006.
section_title: Appendix V: Corrective Action Plans for High-Risk Programs
paragraphs: Table 7 describes the details of the open corrective action plan critical  milestones as of May 14, 2007, as reported by DHS, for reducing improper  IHP assistance payments.
Based on DHS’s updated corrective action plan report for IHP, as of   May 14, 2007, DHS had not completed certain critical milestones by the  identified target date. These milestones included system interface  improvements and certain contract awards. Missing these established  critical milestones only delays strengthening internal controls that are  necessary to reduce future improper payments. It is important that DHS  stays on track in implementing its corrective action plans.
DHS has also established critical milestones for reducing improper  disaster-related vendor payments. Table 8 describes the details of the open  corrective action plan critical milestones as of May 14, 2007, as reported  by DHS for reducing improper disaster-related vendor payments.
DHS identified three primary root causes for why these two programs— IHP assistance payments and disaster-related vendor payments—are at  high risk of issuing improper payments. According to DHS, these root  causes include the following.
People—FEMA employees were not properly trained.    Processes—The nature of FEMA’s work responding to disasters explains  the reliance on people that are not trained in finance requirements and are  dispersed throughout areas with limited infrastructure.
Policies—Policies were cited as possibly inadequate for instructing  employees on the proper supporting documentation. There is a need for  clear policy and procedural guidelines that sets standard operating  procedures for all FEMA employees, especially those outside the finance  area.
DHS also noted that human capital is the principal requirement to execute  these two corrective action plans; however, according to DHS, exact  requirements are not estimable at this time. These plans, if properly  executed, should help reduce future improper payments in these programs  by strengthening internal controls. With regard to system improvements,  as we have previously recommended, DHS needs to conduct effective  testing to provide reasonable assurance that the system will function in a  disaster recovery environment.
section_title: Appendix VI: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, the following individuals also  made significant contributions to this report: Casey Keplinger, Assistant  Director; Verginie Amirkhanian; Sharon Byrd; Francine DelVecchio;  Francis Dymond; Gabrielle Fagan; Jacquelyn Hamilton; and Laura  Stoddard.