Debt Collection Improvement Act of 1996: Department of Agriculture's Farm Service Agency Has Not Yet Fully Implemented Certain Key Provisions
Published: 2002-03-29T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Debt Collection Improvement Act of 1996 seeks to maximize the collection of billions of dollars of nontax delinquent debt owed to the federal government. The act requires agencies to refer eligible debts delinquent more than 180 days to the Department of the Treasury for payment offset and to Treasury or a Treasury-designated debt collection center for cross-servicing. The Treasury Offset Program includes the offset of benefit payments, vendor payments, and tax refunds. Cross-servicing involves locating debtors, issuing demand letters, and referring debts to private collection agencies. The Farm Service Agency (FSA) has initiatives to ensure the timely referral of all delinquent debt. However, the agency's failure to make the act a priority has left key provisions of the legislation unimplemented and has severely reduced opportunities for collection. FSA lacks effective procedures and controls to identify and promptly refer eligible delinquent debts to Treasury for collection action. GAO identified several obstacles to FSA's establishment and implementation of an effective and complete debt-referral process. In the four states with the highest dollar amounts of federal debt excluded from the Treasury Offset Program, GAO reviewed FSA's use of exclusions from referral requirements because of bankruptcy, forbearance/appeals, foreclosure and Department of Justice litigation.
section_title: What GAO Found
paragraphs: GAO found that about half of the exclusions in these states were inconsistent with established criteria.

section_title: Letter
paragraphs: On October 10, 2001, we testified before your subcommittee on selected  federal agencies’ implementation of certain key provisions of the Debt  Collection Improvement Act (DCIA) of 1996.  That testimony addressed  requirements to refer older delinquent debts to the Department of the  Treasury for offset against amounts the government might owe the debtors  and for additional collection action at Treasury’s central debt collection  facility, operated by the Financial Management Service (FMS).  Our more  recent testimony, on December 5, 2001, focused on progress in this area by  two Department of Agriculture agencies—the Rural Housing Service and  the Farm Service Agency (FSA).
One of the major purposes of DCIA is to maximize collection of billions of  dollars of nontax delinquent debt owed to the federal government.  Toward  this end, DCIA requires that agencies refer eligible debts delinquent more  than 180 days that they have been unable to collect to Treasury for payment  offset and to Treasury or a Treasury-designated debt collection center for  cross-servicing.  Treasury performs payment offset through its Treasury  Offset Program (TOP), which includes the offset of certain benefit  payments, vendor payments, and tax refunds.  Cross-servicing involves  such actions as locating debtors, issuing demand letters, and referring  debts to private collection agencies.
The purpose of this report is to expand on the information provided in our  December 2001 testimony regarding FSA’s progress and to offer our  recommendations for improving the agency’s implementation of the debt- referral provisions of DCIA.  As you know, our prior reports have shown  that agencies have been slow to implement the referral requirements of  DCIA.  Our testimonies referred to above offered an overview of agencies’  progress during fiscal years 2000 and 2001 to the extent that data were  available and addressed your request for information.  For this report, we  looked at whether (1) FSA was promptly referring eligible farm loan  program loans to Treasury’s FMS for collection action, (2) any obstacles  were hampering FSA from referring eligible farm loan program loans to  FMS, and (3) FSA was appropriately using exclusions from referral  requirements.
subsections: section_title: Background
paragraphs: FSA was established in 1994 during the reorganization of the Department of  Agriculture and operates through a network of field offices located across  the United States.  The agency provides a variety of services, including  providing financial assistance to new or disadvantaged farmers and  ranchers who are unable to obtain commercial credit at reasonable rates  and terms.
FSA loans available to farmers and ranchers include direct or guaranteed  ownership loans and direct or guaranteed operating loans.  Direct  ownership loans are for buying farm real estate and making capital  improvements.  Direct operating loans, which are made to beginning  farmers and ranchers who are unable to qualify for guaranteed operating  loans, are for the purchase of items to help daily farm operations.   Guaranteed farm loan program loans are for the same purposes as direct  farm loan program loans, but they are made by private third-party lenders  and are guaranteed by FSA for up to 95 percent of the principal loan  amount.
section_title: Objectives, Scope, and Methodology
paragraphs: Our objectives were to determine whether (1) FSA was promptly referring  eligible farm loan program loans to FMS for collection action, (2) any  obstacles were hampering FSA from referring farm loan program loans to  FMS, and (3) FSA was appropriately using exclusions from referral  requirements.
To address these objectives, we interviewed officials from FSA to obtain an  understanding of the FSA referral process and any obstacles that were  hampering the referral of eligible debts.  We reviewed FSA’s policies and  procedures on debt referrals and examined the agency’s current and  planned efforts to refer eligible delinquent debts.  We obtained and  analyzed the TROR for the fourth quarter of fiscal year 2000, which was the  most recent year-end report available at the completion of our fieldwork,  and other financial reports prepared by FSA, and held discussions with  FSA officials to determine whether the agency was appropriately using  exclusions from referral requirements.  In addition, we reviewed responses  to questions about FSA’s debt collection practices that you submitted to the  deputy secretary of agriculture in October 2001 and used information from  the responses to clarify or augment our report, where appropriate.
To determine whether FSA’s use of exclusions from referral requirements  was appropriate, we used statistical sampling techniques to select 15 FSA  field offices from the four states with the highest dollar amounts of  reported debt excluded from TOP as of September 30, 2000.  Using  electronic and hard-copy files obtained from Agriculture, we reviewed all  263 loans from the 15 selected offices that were more than 180 days  delinquent and had been reported as excluded from referral to FMS as of  September 30, 2000, for bankruptcy, forbearance/appeals, foreclosure, and  DOJ litigation.  (Appendix I contains additional information on the  sampling method and the results.)  Based on the results of our review, we  estimated the percentage of loans inappropriately excluded as of  September 30, 2000, in the four states from which the sample offices were  drawn.  Because we found numerous errors in the exclusion categories we  tested, we did not test other reported exclusions from referral to FMS for  cross-servicing, such as internal offset.
We did not review FSA’s process for identifying and referring debts to  Treasury for cross-servicing because the agency had suspended all such  referrals in April 2000 pending development of guidelines to implement a  new referral policy.  FSA issued the new guidelines in July 2001 and,  according to an Agriculture official, the first referral to FMS under this new  policy was made in September 2001.  We did not review implementation of  FSA’s new guidelines, since the procedures were implemented near the  completion of our fieldwork.
We conducted our review from November 2000 through October 2001 in  accordance with U.S. generally accepted government auditing standards.   We did not independently verify the reliability of certain information that  FSA provided to us, such as debts more than 180 days delinquent and debts  classified as currently not collectible (CNC) and information in FSA’s loan- accounting and loan-servicing systems.
We requested written comments on a draft of this report from the secretary  of agriculture or her designated representative.  The written response from  the administrator of FSA is reprinted in appendix II.
section_title: FSA Referred a Significant Amount of Direct Farm Loan Program Loan Debt to Treasury for TOP, but Not for Cross-Servicing
paragraphs: As of September 30, 2000, FSA reported having about $8.7 billion in direct  farm loan program loans.  As shown in table 1, the agency reported about  $1.7 billion of direct farm loan program loans more than 180 days  delinquent, including debts classified as CNC, as of September 30, 2000.  Of  this amount, FSA reported referring about $934 million to TOP and  excluding about $732 million from referral to TOP.  FSA reported that it had  referred only $38 million of loans to FMS for cross-servicing as of  September 30, 2000.  It is FSA’s policy to refer delinquent loans for cross- servicing only if collateral has been liquidated and a deficiency remains.  In  addition, as discussed in more detail later in this report, FSA suspended  cross-servicing referrals from April 2000 until September 2001 while it  developed and implemented a new cross-servicing referral policy.
section_title: Several Obstacles Have Impeded FSA’s Implementation of DCIA Referral Requirements
paragraphs: Since DCIA’s enactment, several obstacles have impeded FSA’s  implementation of the act’s referral requirements.  Loan system limitations  have resulted in the automatic exclusion of certain types of debts without  any review for eligibility and the inability to pursue collection from  codebtors through TOP.  FSA’s failure to ensure that field offices routinely  updated the status of delinquent loans has led to inappropriate exclusions  from referral and inaccurate reporting of delinquent and eligible debt  amounts to Treasury.  A change in referral policy led to a suspension of all  delinquent loan referrals to FMS for cross-servicing.  FSA’s policy of  referring delinquent debt to FMS only once a year resulted in delayed  referrals and may have reduced collections.  Finally, FSA did not take  action until recently to recognize losses on guaranteed farm loan program  loans as nontax federal debt.  According to FSA, until certain steps, such as  software implementation, are completed, FSA cannot use the collection  tools provided under DCIA to pursue collection directly from debtors on  guaranteed farm loan program loans.
subsections: section_title: FSA Excluded Deficiency Judgment Debts from Referral Because of System Limitations
paragraphs: Of the $694 million of debt reported by FSA as excluded from referral for  bankruptcy, forbearance/appeals, foreclosure, and DOJ litigation, about  $295 million consists of judgment debts, including deficiency judgments,  which are court judgments requiring payment of a sum certain to the  United States.  According to FSA officials, deficiency judgments—unlike  some other types of judgment debts—are eligible for TOP and should be  referred to FMS.  However, FSA’s Finance Office in St. Louis automatically  excluded all judgment debts for direct farm loan program loans from  referral to FMS because of automated system limitations.  Although the  system does contain information indicating which debts are judgment  debts, it cannot currently accommodate information on subcategories of  judgment debts.  Therefore, FSA staff cannot use the agency’s automated  system to identify deficiency judgments for referral.  On account of our  inquiries, FSA officials initiated a special project in May 2001 to manually  identify all deficiency judgment debts for direct farm loan program loans so  that such debts could be referred to FMS.
section_title: FSA Cannot Report Codebtor Information to FMS Because of System Limitations
paragraphs: Even though FSA reported having referred $934 million of direct farm loan  program loans to FMS for TOP as of September 30, 2000, the agency has  lost and continues to lose opportunities to maximize collections on these  loans because it does not report information on codebtors to FMS.   According to FSA officials, the vast majority of direct farm loan program  loans have codebtors, who are also liable for loan repayment, but FSA’s  automated loan system cannot record more than one taxpayer  identification number for each loan.  Because taxpayer identification  numbers are required for referrals to FMS for TOP, FSA cannot refer  codebtors on farm loan program loans to FMS.  An FSA official said that  the agency first recognized the need to have codebtor information in the  system in 1986 to facilitate debt collection but that higher-priority systems  projects have precluded FSA from completing the necessary enhancements  to allow the system to accept more than one taxpayer identification  number per debt.  FSA was planning to incorporate this modification in the  new Farm Loan Program Information System scheduled for  implementation in fiscal year 2005, but during the December 5, 2001,  testimony before your subcommittee, the agency committed to make the  change by December 2002.
section_title: FSA Did Not Routinely Update Referral Eligibility Status of Direct Farm Loan Program Loans
paragraphs: FSA field offices across the country make determinations as to whether  direct farm loan program loans are in bankruptcy, forbearance/appeals, or  foreclosure and therefore should be excluded from referral to FMS.  The  status of these loans changes over time, and information on the loans must  be updated as changes occur if exclusion determinations are to be  continuously accurate.  Our review of selected excluded loans indicated  that personnel in the FSA field offices we visited did not routinely update  the eligibility status of farm loan program loans in FSA’s Program Loan  Accounting System.  Without up-to-date information on loan status, the  system cannot accurately identify which loans are eligible for referral.
One of the most frequently identified inappropriate exclusions pertained to  amounts that had been discharged in bankruptcy, which should not have  been included in delinquent debt.  Farm loan managers in some of the FSA  field offices we visited said they had not closed out many direct farm loan  program loans discharged in bankruptcy because making new loans has  been a higher-priority use of their resources.  In addition, FSA did not  provide sufficient oversight to help ensure that field office personnel  adequately tracked the status of discharged bankruptcies and updated the  loan files and debt records in the Program Loan Accounting System.
Delays in promptly closing out discharged bankruptcy debts not only  distort the TROR for debt management and credit policy purposes, but also  distort key financial indicators such as receivables, total delinquencies, and  loan loss data.  The information is therefore misleading for budget and  management decisions and oversight.  Aside from erroneously inflating  reported loans receivable and delinquent loan amounts, failure to process  closed-out debts delays the agency’s reporting of those amounts to the  Internal Revenue Service as income to the debtor.
section_title: FSA Temporarily Suspended Cross-Servicing Referrals
paragraphs: FSA suspended cross-servicing referrals in April 2000 pending development  of guidelines implementing a new policy to refer only debts less than 6  years delinquent to FMS for cross-servicing.  According to agency officials,  FSA adopted the new policy in response to discussions they had with  Agriculture’s Office of the General Counsel that addressed a conflict  between Farm Loan Program regulations and FMS policy.  These officials  stated that the Office of the General Counsel decided that FSA must adhere  to Farm Loan Program regulations, which specify a 6-year delinquency  limit for cross-servicing referrals, despite the fact that, according to FMS  officials, FMS accepts debts for cross-servicing that are more than 6 years  delinquent.
In July 2001, FSA issued revised guidelines to implement the new policy  and is now reviewing loans at more than a thousand FSA field offices to  determine the loans’ eligibility for referral under the new policy.  According  to an Agriculture official, FSA made the first referral under the new policy  in September 2001.  Agency officials told us they eventually plan to make  cross-servicing referrals quarterly but will refer delinquent loans more  frequently until the backlog resulting from the referral suspension is  cleared.
section_title: Some Delinquent Loans Were Not Referred Promptly Because FSA Refers Debts to TOP Only Once a Year
paragraphs: According to data provided by FSA officials, about $400 million of new  delinquent debt became eligible for TOP during calendar year 2000.  FSA  officials stated that the debts became eligible relatively evenly throughout  the year, but the agency refers debts eligible for TOP only once annually,  during December.  Consequently, a large portion of the $400 million of debt  likely was not promptly referred when it became eligible.  As we have  previously testified, industry statistics have shown that the likelihood of  recovering amounts owed on delinquent debt decreases dramatically as the  age of the debt increases.  Thus, the old adage that “time is money” is very  relevant for referrals of debts to FMS for collection action.  FSA officials  told us that the agency agrees that quarterly referrals could enhance  collection of delinquent debts and is working on automated system  modifications to refer debts quarterly to TOP.  FSA plans to have a  quarterly referral process ready for implementation in August 2002.
section_title: FSA Did Not Refer Losses on Guaranteed Farm Loan Program Loans to Treasury for Collection Action
paragraphs: Guaranteed farm loan program loans—as well as related losses—have been  significant since the enactment of DCIA in 1996.  The outstanding principal  due on guaranteed farm loan program loans was about $8 billion as of  September 30, 2000; as of that date, FSA had paid out about $293 million in  losses on guaranteed farm loan program loans since fiscal year 1996.
Since DCIA’s enactment, FSA has referred none of its losses on guaranteed  farm loan program loans to FMS for collection action.  According to FSA  officials, the agency could not pursue recovery from guaranteed farm loan  program debtors or use DCIA debt collection tools because under the  guaranteed farm loan program, no contract existed between these debtors  and FSA.  As a result, the agency did not recognize the losses that it paid to  guaranteed lenders as federal debt and did not apply DCIA debt collection  remedies to them.
In June 2000, Agriculture’s Office of Inspector General reported that FSA  was not referring its losses on guaranteed farm loan program loans to FMS  for collection and identified the need for FSA to recognize the losses as  federal debts and begin referring them to FMS for collection action.   However, as of September 30, 2000, FSA still had no policies and  procedures to recognize losses on guaranteed farm loan program loans as  federal debts and to refer such debts to FMS for TOP and cross-servicing.   As a result, FSA has missed opportunities to collect millions of dollars that  the agency has paid to lenders to cover guaranteed losses.
FSA officials told us that the agency has revised the loan application forms  applicable to guaranteed loans made after July 20, 2001, to include a  section specifying that amounts FSA pays to a lender as a result of a loss on  a guaranteed loan constitute a federal debt.  FSA expects that software  needed to implement the revisions to the Guaranteed Loan Accounting  System should be completed around mid-2002 and in place before any loss  claims are paid on guaranteed loans made after July 20, 2001.
section_title: FSA Did Not Appropriately Use Exclusions from Referral Requirements
paragraphs: As of September 30, 2000, FSA had excluded $732 million of delinquent  loans from referral to FMS for TOP.  FSA cited bankruptcy,  forbearance/appeals, foreclosure, and DOJ litigation as the reasons for  about $694 million, or 95 percent, of these exclusions.  About $295 million  of the exclusions were judgment debts.  As we noted earlier, FSA excluded  all judgment debts from referral because of automated system limitations,  despite the fact that deficiency judgment debts are eligible for referral.  We  also noted that we found exclusion errors caused by FSA’s failure to ensure  that loan status was routinely updated.  As a result of inappropriate  exclusions and exclusion errors, FSA failed to maximize its collection of  delinquent loans and provided inaccurate TROR data to federal agencies  that rely on such information for policy and oversight purposes.
Using statistical sampling, we selected 15 FSA field offices in California,  Louisiana, Oklahoma, and Texas—the four states with the highest dollar  amounts of debt excluded from TOP.  We reviewed supporting documents  for all 263 loans from these offices that were more than 180 days delinquent  and had been excluded from referral to FMS as of September 30, 2000, to  determine the extent to which exclusions in the four states were consistent  with established criteria for excluding loans in bankruptcy,  forbearance/appeals, foreclosure, and DOJ litigation.  Based on the  results of our review, we estimate that as of September 30, 2000, FSA had  inappropriately placed about 575 loans, or approximately half the excluded  loans in the four selected states, in exclusion categories.  As part of our  sample, we reviewed supporting documents for 52 bankruptcies that had  been discharged before September 30, 2000.  In fact, many had been  discharged several years before that date.  For example, one loan with a  balance due of about $325,000 was reported as more than 180 days  delinquent and had been excluded from referral because of bankruptcy.   Our review of the loan file at the FSA field office showed that a bankruptcy  court had discharged the debt in 1986.  Therefore, the debt should not have  been included in either the delinquent debt amount or exclusion amount  reported to Treasury as of September 30, 2000.
Because of the large number of errors we found in the bankruptcy,  forbearance/appeals, foreclosure, and DOJ litigation exclusion categories,  we did not test other reported exclusions from referral to FMS for cross- servicing, such as loans being internally offset.
section_title: Conclusions
paragraphs: Although DCIA was enacted in 1996, FSA continues to face major obstacles  to complying fully with the act.  FSA lacks sufficient processes and  controls to adequately identify and promptly refer all direct farm loan  program loans eligible for referral to FMS.  Automated system limitations,  which have existed for years and have delayed FSA’s compliance with the  act, have still not been corrected, even though they have prevented referral  and potential collection of substantial amounts of eligible delinquent debt.   The failure of FSA field offices to routinely update delinquent loan  information has led to erroneous exclusions from referral and inaccurate  reporting of debt to Treasury.  FSA’s policy of referring debts to TOP only  once a year has allowed debts to age unnecessarily and has likely reduced  their collectibility.  FSA has only recently taken action to establish  procedures to refer losses on guaranteed loans to FMS; therefore,  opportunities to collect on losses of about $300 million since DCIA was  enacted may have already been lost.  If FSA is to make significant progress  in collecting on millions of dollars of delinquent farm loan program loans,  the agency must give higher priority to fully complying with the debt  collection provisions of DCIA.
section_title: Recommendations for Executive Action
paragraphs: To improve FSA’s compliance with DCIA, we recommend that the secretary  of agriculture direct the administrator of FSA to take the following actions:  Develop and implement automated system enhancements to make the  Program Loan Accounting System capable of identifying all judgment  debts eligible for referral to FMS for collection action.  In the interim,  continue with the manual project to identify judgment debts eligible for  referral to FMS.
Monitor planned system enhancements to the Program Loan Accounting  System to ensure that capacity to record and use codebtor information  is available and implemented by December 2002.
Develop and implement oversight procedures to ensure that FSA field  offices timely and routinely update the Program Loan Accounting  System to accurately reflect the status of delinquent debts.  Aside from  requirements for database integrity, this is critical to determining  allowable collection action, including whether debts are eligible for  referral to FMS for collection action.
Develop and implement oversight procedures to ensure that all debts  discharged through bankruptcy are promptly closed out and reported to  the Internal Revenue Service as income to the debtor in accordance  with the Federal Claims Collection Standards and Office of Management  and Budget Circular A-129.
Monitor effective completion of the planned automated system  modifications to refer eligible debt to TOP on a quarterly, rather than  annual, basis by August 2002.
Monitor planned system enhancements to the Guaranteed Loan  Accounting System to ensure that the software is completed that is  needed to implement the revisions to the loan application forms to  establish guaranteed loan losses as federal debt.
Once guaranteed loan losses are established as federal debt and are  deemed eligible for referral to FMS, timely refer such debt to FMS for  collection action in accordance with DCIA.
section_title: Agency Comments and Our Evaluation
paragraphs: In written comments on a draft of this report, the administrator of FSA  generally agreed with our findings and recommendations.  The  administrator stated that FSA has developed an aggressive action plan to  implement the remaining DCIA provisions mentioned in our report by  December 31, 2002.  FSA’s letter is reprinted in appendix II.
While FSA agreed with our finding that it had inappropriately placed  several loans in various exclusion categories allowed by DCIA, it disagreed  with our estimated error rate of about 50 percent in the sample population  of 1,187 loans.  FSA stated that its own internal review of 967 loans in the  four states that were included in our review resulted in an error rate of 35.7 percent.
Our sample was statistically selected and resulted in a valid projected error  rate of about 50 percent for the states covered by our test work.  To  substantiate our work for each error identified during our testing, we asked  FSA farm loan managers to sign a statement as to whether they agreed with  the GAO sample results and conclusion that the exclusion was  inappropriate.  In all but 3 of the 113 errors we identified, the managers  agreed with our conclusions and, as a result, said they planned to take  action to correct the errors.
Since the FSA review was performed subsequent to our tests, we cannot  comment on the validity of FSA’s internal assessment of the reported  results.  In addition, since many of the loans in our sample had been  inappropriately excluded for years, corrections made subsequent to our  testing but prior to FSA’s review would likely have resulted in a lower error  rate at the time of FSA’s work.  In any case, it is important to note that the  35.7 percent error rate cited by FSA from its internal assessment is still  unacceptable, and we remain firm in our recommendation that FSA  develop and implement oversight procedures to ensure that FSA field  offices timely and routinely update the Program Loan Accounting System  to accurately reflect the status of delinquent debts.
FSA also took issue with our report’s reference to possible missed  collection opportunities.  It stated we had not given FSA sufficient credit  for collections totaling millions of dollars of delinquent debt using various  collection tools.   Our point is that FSA’s mentioned successes could have  been much greater had it made DCIA a higher priority and thus  implemented certain key provisions much sooner.  Our position remains  unchanged.  The details in the body of our report demonstrate lack of  adequate progress.  Most important, 5 years after the passage of DCIA, FSA  had not yet established an adequate framework or systems capacity to  effectively carry out its responsibilities for collecting large sums of  delinquent debt.
As agreed with your office, unless you announce its contents earlier, we  plan no further distribution of this report until 30 days after its issuance  date.  At that time, we will send copies to the chairmen and ranking  minority members of the Senate Committee on Governmental Affairs and  the House Committee on Government Reform and to the ranking minority  member of your subcommittee.  We will also provide copies to the  secretary of agriculture, the inspector general of the Department of  Agriculture, the administrator of the Farm Service Agency, and the  secretary of the treasury.  We will then make copies available to others  upon request.
If you have any questions about this report, please contact me at (202) 512-3406 or Kenneth R. Rupar, assistant director, at (214) 777-5714.   Key contributors to this report are listed in appendix III.
section_title: Sampling Method and Results
paragraphs: We first identified the four states (Texas, California, Louisiana, and  Oklahoma) with the highest dollar amounts of debt excluded from TOP.   From the four states, we drew a multistage cluster sample of 15 field  offices (population 123) using probability proportionate to size, a sampling  method in which larger clusters (in this case, offices) have a higher  probability of being selected than smaller clusters.  Our debt population  consisted of all FSA debt more than 180 days delinquent that had been  excluded from referral to Treasury as of September 30, 2000. We reviewed  all excluded debt (263) at the 15 sample offices.
Table 2 identifies the four states selected, the number of offices selected in  each state, the number of excluded debts at the selected offices in each  state, and the number of errors found at the selected offices in each state.
Based on our review, we estimate that 48.5 percent ± 15.7 percent of the  population were inappropriately excluded from Treasury referral.  When  projecting these errors to the population of 1,187, we are 95 percent  confident that the errors in the population are from 389 to 761 debts.
Table 3 shows the two-stage probability proportionate to size cluster  sample results.
section_title: Comments from the Farm Service Agency
section_title: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Acknowledgments
paragraphs: Other key contributors to this report were Arthur W. Brouk, Sharon O.  Byrd, Richard T. Cambosos, Michael D. Chambless, Michael S. LaForge,  and Gladys E. Toro.
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