Superfund: Status of EPA's Efforts to Improve Its Management and Oversight of Special Accounts
Published: 2012-01-18T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Under the Superfund program, EPA has the authority to enter into agreements with potentially responsible parties for them to conduct a cleanup at hazardous waste sites or compel potentially responsible parties to do so. EPA can also conduct cleanups itself and then seek reimbursement. EPA is authorized to retain and use funds received from settlements with these parties in interest-earning, site-specific special accounts within the Trust Fund. These accounts provide resources in addition to annual appropriations to clean up sites. The number of accounts grew slowly until 1995 when EPA encouraged their greater use. After 1995, their number and dollar value increased. EPA headquarters is responsible for overseeing its regions management of special accounts. In two reports issued in 2006 and 2009, the EPA IG made recommendations to EPA to better manage these accounts.
As requested, this report examines the (1) statusthat is, balances, locations, and recent and planned usesof Superfund special accounts, and (2) extent to which EPAs headquarters and regions have implemented processes and policies to improve the monitoring and management of these accounts. GAO analyzed EPA Superfund program data, guidance, and strategies, and interviewed EPA officials.
GAO is not making recommendations in this report. GAO provided a draft of this report to EPA for review and comment. EPA provided technical comments that were incorporated into the report, as appropriate.
section_title: What GAO Found
paragraphs: From fiscal year 1990 through October 2010, the Environmental Protection Agencys (EPA) 10 regions collected from potentially responsible parties almost $4 billion in funds that were placed in special accounts. Nearly half of these funds are still available to be obligated for future Superfund cleanup; the remaining funds have already been obligated, but not all of these obligated funds have been disbursed. According to GAOs analysis of EPA data, EPA has plans to obligate almost all of the available funds in special accounts over the next 10 years. However, EPA regional officials told GAO that special account funds that are planned to be obligated are estimates rather than commitments, and the planned use of funds often changes as site circumstances warrant. As of October 2010, of the $1.9 billion funds that EPA had obligated for Superfund cleanup expenses, $1.6 billion had been disbursed.
According to GAOs review of EPA documents and interviews with agency officials, EPA has taken steps, including implementing strategies and guidance, in the last few years to better monitor and manage special accounts. EPA took these steps in response to the EPA Inspector Generals (IG) findings and recommendations, as well as EPA officials own recognition that the agency needed to provide better oversight of the special accounts process. These steps include the following:
processes to better plan for the use of special account funds by adding a screen in the agencys Superfund database that enables EPA regions to enter special account planning data into specific data fields and create reports, so that officials can monitor the special account balances against planned obligations for ongoing and future site-specific response activities;
increased oversight of special accounts, including designating a national special accounts coordinator who, among other things, conducts annual and midyear reviews and holds discussions with regional staff to evaluate their plans to allocate special account funds, and establishing a Special Accounts Senior Management Committee that meets semiannually to provide overall management oversight and monitor the status of special accounts; and
strategies and guidance on how to plan for using special accounts, including an agencywide strategic plan, overall guidance for the regions on the proper use and planning of special accounts funds throughout the cleanup process, detailed guidance on the reclassification process, and a model memorandum for transferring funds from a special account to the Hazardous Substance Superfund Trust Fund (Trust Fund) and closing out a special account.

section_title: Letter
paragraphs: The Comprehensive Environmental Response, Compensation, and  Liability Act (CERCLA) of 1980, commonly referred to as “Superfund,”  was enacted to protect human health and the environment from the  effects of hazardous substances. Under CERCLA, the Environmental  Protection Agency (EPA) has the authority to enter into agreements with  potentially responsible parties (PRP) for them to conduct the cleanup at  hazardous waste sites, or compel PRPs to clean up sites. In addition,  EPA can clean up the sites itself and then seek reimbursement from the  PRPs. EPA’s primary source of funds for EPA-led cleanups of Superfund  sites is its annual appropriations by Congress from the Hazardous  Substance Superfund Trust Fund (Trust Fund), which receives a transfer  from the general fund of the Treasury.
EPA is also authorized by CERCLA to retain and use funds received from  settlements with a PRP, and EPA may hold these funds in interest- earning, site-specific accounts called “special accounts.”accounts are interest-bearing subaccounts within the Trust Fund that are  generally used for future cleanup actions at the sites associated with a  specific settlement or to reimburse appropriated funds that EPA had  previously used for response activities at these sites. These accounts  help EPA respond to and clean up sites by providing resources in addition  to EPA’s annual appropriations. In 1990, EPA had five special accounts  totaling about $1.9 million. Over the next few years, the number of special  accounts increased slowly. However, beginning in 1995, EPA issued   These special  memorandums and guidance encouraging greater use of special  accounts. Since that time the number and dollar value of these accounts  has steadily increased. EPA’s regional offices are primarily responsible  for establishing and managing special accounts for the Superfund sites  located in their region, and EPA headquarters offices are responsible for  overseeing the regional offices’ management of these accounts.
In two reports, issued in 2006 and 2009, the EPA Inspector General (IG)  made recommendations to improve the management of Superfund  special accounts. In 2009, for example, the IG stated that EPA needed to  assign a central management official to be responsible for developing an  action plan to ensure that the management accountability and related  issues regarding special accounts that the IG had identified were  addressed. The IG recommended that this action plan include, among  other things, (1) an annual planning process to aid in monitoring special  accounts, (2) more guidance or a policy that addresses how special  accounts should be implemented and used, and (3) plans for developing  complete reports with accurate special accounts data from EPA’s  Comprehensive Environmental Response, Compensation, and Liability  Information System (CERCLIS) database to manage the program and  improve its performance.
In this context, you asked us to examine EPA’s Superfund special  accounts. Specifically, our objectives were to (1) describe the status— including balances, locations, and recent and planned uses—of  Superfund special accounts and (2) examine the extent to which EPA’s  headquarters and regions have implemented processes and policies to  improve the monitoring and management of Superfund special accounts.
To conduct this work, we reviewed relevant law and EPA guidance and  interviewed senior officials at EPA’s headquarters and regional offices.  Specifically, to describe the status of special accounts, we obtained and  analyzed data regarding all special accounts from EPA’s CERCLIS  database, as of October 2010. To assess the reliability of the CERCLIS  data, we reviewed relevant documentation, examined the data to identify  obvious errors and inconsistencies, and interviewed knowledgeable  agency officials to see if there were any known problems with the data  and to learn more about their procedures for maintaining the data. We  determined that the data were sufficiently reliable for the purposes of this  report. To examine the extent to which EPA’s headquarters and regions  are implementing processes and policies to improve the monitoring and  management of Superfund special accounts, we analyzed documents  and interviewed officials from EPA headquarters offices, including the  Office of Superfund Remediation and Technology Innovation, the Office  of Site Remediation Enforcement, and the Office of the Chief Financial  Officer. We also interviewed EPA’s IG officials regarding their 2006 and  2009 reports on EPA’s management of special accounts. According to  these officials, all recommendations from these two reports were closed  out based on EPA’s response. In addition, we conducted interviews with  officials in EPA’s 10 regional offices to determine how each region  managed and monitored its special accounts and coordinated with EPA  headquarters. We also obtained from the regional offices relevant  supporting documentation, including detailed information on 20 of 285  special accounts. We selected 20 accounts on the basis that EPA  headquarters had either raised questions about them with the regions or  recommended that the regions take further actions on issues relating to  them that arose during EPA’s fiscal year 2010 annual review of the  regions’ planning data for special accounts. We reviewed data on these  20 accounts to determine how and to what extent regional offices had  addressed these issues. These 20 special accounts were chosen from a  random nonprobability sample of the 285 accounts and therefore cannot  be generalized to all special accounts. A more detailed discussion of our  scope and methodology is presented in appendix I.
We conducted this performance audit from October 2010 to January 2012  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: CERCLA, often referred to as the “Superfund” law, gave the federal  government the authority to respond to actual and threatened releases of  hazardous substances, pollutants, and contaminants that may endanger  public health and the environment. EPA established the Superfund  program to carry out these responsibilities. Data as of September 2011—  the most current data available—show that there were 13,856 sites in  EPA’s CERCLIS active site inventory, which may require attention under  EPA’s Superfund program. Management of these sites, including the  special accounts associated with them, has historically been the  responsibility of the EPA region in which a site is located. EPA has 10  regional offices, each one responsible for the execution of EPA programs  within several states and, in some regions, territories. Figure 1 shows the  states included in each of the 10 regions.
This section discusses (1) EPA’s process for cleaning up Superfund sites,  (2) EPA’s enforcement process for site cleanup, (3) the Trust Fund  established under CERCLA, (4) EPA’s use of special accounts for  Superfund cleanup, and (5) the EPA IG’s recommendations for better  management of these special accounts.
subsections: section_title: EPA’s Process for Cleaning Up Superfund Sites
paragraphs: EPA’s Superfund cleanup process can be lengthy, sometimes taking  decades to clean up contamination to the standards selected for a site.  The cleanup process involves a series of steps during which specific  activities take place or decisions are made. The first step occurs when the  Superfund program is notified of a potential site through various  mechanisms, including receipt of citizens’ petitions, and referrals or  notifications from states, tribes, and other federal agencies. Following  notification, a site undergoes a minimal screening process, called a pre- CERCLIS screening, to determine whether a site assessment process is  appropriate. Sites deemed appropriate are added to the CERCLIS active  site inventory. During the site assessment process, EPA and states  collect data to identify, evaluate, and rank hazardous waste sites based  on Hazard Ranking System criteria. Using these criteria, EPA and/or its  state and tribal partners conduct a preliminary assessment and, if  warranted, a site inspection or other more in-depth assessment to  determine whether the site warrants short- or long-term cleanup attention.  Sites that EPA determines are among the nation’s most seriously  contaminated hazardous waste sites are placed on the National Priorities  List (NPL) for attention under the federal Superfund program. Cleanup  work under CERCLA generally involves two categories of actions: short- term removal actions that address immediate threats to human health and  the environment, and long-term remedial actions that aim to permanently  or significantly reduce contamination. Only sites on the NPL are eligible  for Trust Fund-financed remedial actions, but sites not listed on the NPL  may be remediated with private funds, in some instances with EPA  oversight. EPA conducts removal actions at both NPL and non-NPL sites.
EPA or a PRP will begin the remedial process by conducting a two-part  study of the site: (1) a remedial investigation to characterize site  conditions and assess the risks to human health and the environment,  among other actions and (2) a feasibility study to evaluate various options  to address the problems identified through the remedial investigation. The  culmination of these studies is a record of decision, which identifies the  selected remedy for addressing the site’s contamination and a cost  estimate for implementing the remedy. EPA or the PRP may develop  preliminary estimates of construction costs and, as the site moves from  the study phase into the remedial action phase, a more accurate cost  estimate may be developed. The method of implementation for the  selected remedy is then developed during remedial design and  implemented during the remedial action phase, when actual cleanup of  the site occurs.
When all construction of the cleanup remedy at a site is finished, all  immediate threats have been addressed, and all long-term threats are  under control, EPA generally considers the site to be “construction  complete.” Sites where additional work is required after construction is  completed then enter into the postconstruction phase, which includes  actions such as operation and maintenance and conducting 5-year  reviews. When EPA in consultation with the state determines that no  further site response is appropriate, then EPA may delete the site from  the NPL. Figure 2 illustrates the typical Superfund process for cleaning up  a site.
Thus, EPA may incur a variety of costs in implementing the Superfund  program at particular sites. EPA may spend funds to investigate and  clean up sites, including short-term removals at any site, and long-term  remedial actions at NPL sites. EPA may also incur costs for oversight  associated with a site cleanup where a private party is conducting and  funding the cleanup.
section_title: EPA’s Enforcement Process for Superfund Site Cleanup
paragraphs: EPA may enter into agreements with PRPs for those parties to conduct  cleanups, compel site cleanups by PRPs, or conduct cleanups itself and  seek reimbursement for its costs from those parties. EPA’s enforcement  of environmental cleanup at Superfund sites begins with the identification  of the PRPs, usually early in the cleanup process; continues throughout  site cleanup; and often does not conclude until after the site is declared  construction complete. EPA identifies PRPs by, among other actions,  reviewing documentation related to the site; conducting interviews with  government officials or other knowledgeable parties; performing historical  research on the site; sampling soil or groundwater at the site; and  requesting additional information from relevant parties. In addition to  identifying PRPs, EPA attempts to obtain information on the type and  amount of hazardous substances shipped to a site by each party and any  financial constraints faced by the identified parties.
EPA may begin a cleanup process before it has identified PRPs.  However, once it identifies PRPs, it typically seeks to reach a settlement  with them on their cleanup responsibilities and/or their payment for  cleanup costs that EPA incurs. These negotiations generally may take  place at any time throughout the site cleanup process. We have  previously found that in reaching these settlements, EPA’s and the PRPs’  decisions are influenced by site-specific characteristics and other key  considerations, such as the expected cost of site cleanup, the strength of  EPA’s evidence of PRP liability, and the number and type of other PRPs.
section_title: The Trust Fund Established Under CERCLA
paragraphs: CERCLA established the Trust Fund to support Superfund program  activities. EPA generally can use appropriated monies from the Trust  Fund for short-term cleanups and for long-term cleanups of NPL sites.  For example, EPA may elect to use such funds at sites for which the  parties responsible for site contamination cannot be found or are unwilling  or unable to clean up a site, to initiate work pending settlement, or in an  emergency. Historically, the Trust Fund received revenue from four  major sources: taxes on crude oil and certain chemicals, as well as an  environmental tax assessed on corporations based on their taxable   transfers via appropriations from the general fund of the   income;Treasury; fines, penalties, and recoveries from PRPs; and interest earned  on the balance of the Trust Fund. In 1995, the authority for the taxes  expired and, as of November 2011, had not been reinstated. As of 2011,  the Trust Fund’s primary source of revenue is the transfer from the  general fund of the Treasury. At the end of fiscal year 2010, the Trust  Fund had total assets and liabilities of $3.74 billion, with nearly 55 percent  of that total in special accounts.
section_title: EPA’s Use of Special Accounts for Superfund Cleanup
paragraphs: Section 122(b)(3) of CERCLA allows EPA to retain and use funds  received pursuant to an agreement with a PRP for purposes of carrying  out an agreement. EPA retains those funds in subaccounts of the Trust  Fund called “special accounts.” As part of the settlement, those funds  placed in a special account may be used for that specific site or may be  transferred by EPA to the general portion of the Trust Fund. EPA’s goal in  establishing special accounts is to preserve the use of annual  congressionally appropriated funds for cleanup at sites without a viable  PRP. EPA regions are encouraged to create and use special accounts as  an incentive to secure PRP cleanups and to fund EPA’s cleanup when it  has lead responsibility. EPA officials said that they believe that PRPs are  more willing to settle when assured that their settlement money will  generally be used at the site where they hold liability, rather than at  another site.
According to EPA guidance, regions should strive to use model  (standardized) settlement language to establish special accounts. The  model language is intended to allow EPA flexibility in deciding for what  specific response actions special account funds can be used and  therefore when to use these funds. It allows EPA to use the funds for a  response action at the site associated with the account, and EPA  guidance states that special account funds are site-specific and are  generally not available for EPA to use at other sites. The model language  also retains EPA’s authority to transfer funds from a special account to  the general portion of the Trust Fund for future appropriation by  Congress. EPA guidance notes that the language of the actual agreement  governs EPA use of a particular special account’s funds.
Generally, funds may be deposited in a special account regardless of  whether the settling party is performing the work. According to EPA, the  agency typically receives funds as a result of agreements entered when  the PRPs are unable or unwilling to perform the response action, as is the  case in a bankruptcy or an “ability to pay” settlement for parties facing  financial difficulties. EPA may also determine that the hazardous  substance contributed by a particular PRP was minimal in amount and  toxicity compared with other substances at a site and therefore allow that  party a de minimis settlement. In addition, PRPs who are conducting  some response actions may make payments to EPA to address past or  future response actions. EPA’s costs of overseeing the PRPs’  implementation of the work are usually included in future response costs.  These payments may be made for the estimated amount of oversight or  on a periodic basis. However, under its guidance, EPA is only to establish  a special account for a site where future cleanup work remains at a site.  According to EPA officials, they prefer to establish one centralized special  account per site because this generally allows them to more easily  manage funds for a site, but certain situations may require more than one  account for a site. For example, multiple special accounts for one site  may be established for amounts that EPA will provide or disburse to  PRPs who agree to perform the response work (serving as a settlement  incentive for the PRPs to perform the work), or for each separate  operable unit or different response action at a site.
Once settlement proceeds are deposited in a special account, EPA  regional staff enter plans for the use of those funds into CERCLIS.  According to EPA guidance, regional staff, such as the sites’ regional  remedial project managers, are to evaluate the planned uses of special  account funds on an ongoing basis, as warranted by site activity, to  ensure that these resources are used efficiently and effectively and make  corresponding changes to their planned use as appropriate. The regional  staff are to consider both the short- and long-term plans for the site; thus  they often plan several fiscal years in advance. According to the  guidance, estimates of EPA’s future response costs at a site should be  based on the best information available at a given point in time and the  best professional judgment of regional staff. Various EPA groups,  including regional counsel, regional program management, regional  finance, and headquarters staff are all involved in this planning process.
In general, according to EPA guidance, special account funds should be  used prior to annual congressional appropriations. This guidance  establishes priorities for the use of special account funds, referred to as  the General Hierarchy of Special Account Use. According to this  hierarchy, funds in special accounts should be used to facilitate settlement with PRPs for response actions; used to fund EPA’s costs for response actions;  reclassified to reimburse previous EPA site expenditures made from  annual congressional appropriations; reclassification is available when  an EPA region reasonably estimates that the special account contains  more funds than are needed to address all known and potential future  work at the site.used by EPA at another Superfund site for the same category of  expenditure as the costs being reimbursed; and  Funds made available from reclassification may be  transferred to the general portion of the Trust Fund, when  reclassification has already been considered and is not appropriate,  and the special account balance exceeds the estimated known and  potential future cleanup costs at that site.  In contrast to reclassified  funds, transferred funds require a future congressional appropriation  to make the funds available for use by EPA.
Typically, EPA closes special accounts when (1) all site work has been  completed; (2) no funds are left in the account, and no future deposits are  anticipated; or (3) EPA does not anticipate incurring any additional costs  at those sites. To close an account, the remaining funds in the special  account, if any, are then transferred to the general portion of the Trust  Fund to increase the balance available for future appropriation for  cleanups.
section_title: EPA IG’s Recommendations for Better Management of Special Accounts
paragraphs: Generally funds that are not used for future response work at a site are reclassified or  transferred to the general portion of the Trust Fund, rather than returned to PRPs, unless  it is specifically written into the settlement that they should be returned to PRPs. or the regions was responsible for managing, overseeing, and  coordinating special accounts work. In addition, the IG found that EPA  headquarters did not have a structured approach for following up on  regional plans to use special account funds to ensure that they were  being managed correctly and that EPA lacked detailed guidance and  policy on the proper use, management, and monitoring of special  accounts funds. As a result, among other things, the IG recommended  that EPA designate a central management official for special accounts  with responsibility for developing an action plan to ensure that  management accountability and related issues regarding special  accounts were addressed. The IG stated that this action plan should  include, among other things, (1) a process for ensuring completed  CERCLIS reports with accurate special accounts data to manage the  program and improve performance; (2) an annual planning process— including a determination that regional special account funds will be used  consistent with the General Hierarchy—to aid in monitoring special  accounts; (3) development of headquarters and regional controls that  include follow-up to make sure planned or requested uses (e.g.,  reclassifications and transfers to the Trust Fund of special account funds)  were conducted; and (4) establishment of guidance and policy that  addresses the proper application and amount of special account funds  that should be reserved for future use. In addition, the IG recommended  that EPA regularly analyze the “oldest accounts” for opportunities to  better use special account funds.
section_title: About Half of the $3.7 Billion that EPA Has Collected in Special Accounts Is Available for Future Superfund Cleanup
paragraphs: From fiscal year 1990 through October 2010, EPA collected from PRPs  over $3.7 billion that it placed in 1,023 special accounts. Nearly half of  these funds—$1.8 billion—are still available to be obligated for future  Superfund cleanup; and the remaining funds—$1.9 billion—have already  been obligated, but not all of these obligated funds have been  disbursed.regions reclassified about $131 million from 96 special accounts to pay  for previous EPA site expenditures, transferred about $14 million from 39  accounts to the general portion of the Trust Fund, and closed 76  accounts.
subsections: section_title: Status of Unobligated Funds in EPA Special Accounts
paragraphs: As of October 2010, of the $3.7 billion that it placed in 1,023 special  accounts, EPA held nearly $1.8 billion in unobligated funds in 947 open  accounts—accounts that have funds available for use in future cleanup  responses at specific sites—at 769 Superfund sites; 503 of these sites  are currently on the NPL. The number of special accounts increased  significantly from 2001 through 2010: 854 of the 1,023 accounts, or 83  percent, were established during this period. Table 1 shows these  accounts by region, with the number of open accounts, sites, NPL  designation, and unobligated funds.
The majority of available special account funds are concentrated in a  small number of special accounts. As of October 2010, 33 open accounts,  or 3 percent, had a total of $1 billion available, or 61 percent of the total  amount available in special accounts. Table 2 below shows the number of  open accounts that have an available balance of less than $500,000, from  $500,000 to $10 million, and greater than $10 million.
As of October 2010, EPA had plans to obligate 99.8 percent of the $1.8  billion available in special accounts, according to our analysis of EPA  CERCLIS data. EPA tracks plans for unobligated special account funds in  CERCLIS by three categories: (1) planned obligations; (2) additional  reserved uses (estimated costs) not captured as planned obligations; and  (3) amounts for work parties (e.g., generally PRPs who have agreed to  conduct response work under a settlement agreement) that are included  in settlements but have not yet been distributed to them. Specifically:
Planned obligations are costs anticipated by EPA to be incurred in  association with specific site response actions. Planned obligations  are grouped into five categories: removal and removal support,  pipeline operations, remedial action, enforcement, and federal  facilities.
Additional reserved uses are regional staff’s estimated costs for  possible or long-term future actions. This category includes 14  different types of potential uses, such as 5-year reviews.  Reclassifications and transfers to the Trust Fund are also included in  this category, but EPA prefers to break out this information separately  for the purpose of evaluating the data in management reviews.
Amounts for work parties refers to funds promised in settlements to  parties performing the cleanup work at the site; these are amounts  that were used as a settlement incentive in negotiations with potential  work parties.
Figure 3 shows, as of October 2010, how EPA planned to use  unobligated funds in special accounts.
Planned obligations were made for 64.9 percent—$1.16 billion—of the  $1.8 billion in unobligated funds at the beginning of fiscal year 2011,  according to our analysis of EPA data. Funds designated for remedial  action and pipeline operations made up the largest portions of the $1.16  billion. Approximately $671 million, or 58 percent of these funds, were  planned for remedial action, and $418 million, or 36 percent of these  funds, were planned for pipeline operations.
According to EPA headquarters officials, in some instances, funds for  anticipated long-duration Superfund cleanup actions may be planned as  much as 40 or 50 years in advance, when there are enough funds in an  account to plan that far in advance. Regional data indicate that, of the  available special account resources that have planned obligations, more  than half are planned to be obligated from fiscal years 2011 through 2013  and, according to EPA officials, 95 percent will be obligated by fiscal year  2022. However, EPA regional officials told us that the special account  planned obligations are estimates rather than commitments. According to  headquarters and regional officials, planned funds may not be used for  their original planned use or may not be used in the originally designated  fiscal year for a number of reasons, such as unforeseen issues that arise  with Superfund cleanups, especially during the remedial investigation and  remedial actions; EPA regional staff responding to national and regional  emergencies; or site schedule changes. EPA regional staff must either  delete or move forward plans to use special account funds into a  subsequent fiscal year when special account obligations for a prior fiscal  year are not obligated as previously planned. Table 3 shows CERCLIS  information on the number of special accounts and associated obligations  planned by type of EPA cleanup activity, enforcement, and federal  facilities for fiscal years 2011 through 2070.
Additional reserved uses made up 32.6 percent—or $585 million—the  second largest portion of the national planned uses for all special account  funds in fiscal year 2011. According to EPA officials, they have not yet  entered these estimates as specific planned obligations in CERCLIS  because the planning of these funds is more challenging to predict or in  some cases, there are limitations for how obligations can be entered into  CERCLIS. For example, only one 5-year review can be entered as a  planned obligation in CERCLIS as a site financial transaction. The  “outyear five year review” field may be used to enter estimates for  subsequent 5-year reviews. Other funds under this category represent  such items as potential EPA work takeover from a PRP where the PRP  does not have adequate or liquid financial assurance and anticipated  costs prior to determination of the final remedy for cleanup. This category  also includes special account funds that are planned for reclassification or  transfer to the Trust Fund, which we discuss in greater detail later.
Amounts for work parties were approximately $42.2 million—or about 2.4  percent of the $1.8 billion in unobligated special account funds—as  promised in settlements, as of the beginning of fiscal year 2011,  according to EPA regions’ planning documents. These funds will be  disbursed to work parties as they submit claims for reimbursement to  EPA, in accordance with milestones established in the settlement  documents.
The unassigned remaining balance was approximately 0.2 percent of  special account funds, or approximately $3 million, as of October 2010.  According to the national special accounts coordinator, EPA headquarters  generally permits a small amount of the total balance of unobligated  special account funds to remain unplanned. However, according to an  EPA official, headquarters staff question regions when the unassigned  remaining balance of a special account is generally more than 10 percent  of its available balance, more than 10 percent of the total available funds  for the region, or more than $100,000 per account.
section_title: Status of Obligated Special Account Funds
paragraphs: As of October 2010, of the total accumulated receipts of $3.7 billion in  1,023 special accounts, about $1.9 billion had been obligated for site  specific response work, according to our analysis of EPA data. Of this  total, EPA had disbursed approximately $1.6 billion for Superfund cleanup  expenses; the remaining $247 million in obligations had not yet been  disbursed (i.e., unliquidated obligations).
Furthermore, EPA regions have not disbursed any funds from 240 of the  947 open special accounts with a total of $228 million available in these  accounts. Twenty-five of these 240 accounts include unliquidated  obligations. According to officials from regions that had large numbers of  special accounts with no disbursements, there are numerous reasons for  not having disbursed any funds from these accounts for site cleanup. For  example, one regional official stated that funds are often deposited in  special accounts early in the Superfund site cleanup process, sometimes  years before cleanup at the site actually begins. Also, regions often retain  funds in special accounts for contingency purposes if cleanup plans  change (e.g., potential EPA work takeover at a later date). Another  regional official stated that numerous special accounts in the region had  recently received sizeable deposits from a large bankruptcy settlement,  and the funds have been planned for but not obligated as of the time of  our review.
section_title: Status of Reclassification, Transfer of Funds, and Closure of Special Accounts
paragraphs: Historically, EPA has conducted few reclassifications or transfers of funds  to the general portion of the Trust Fund. Recently, however, EPA regions  have begun to reclassify more funds from open special accounts. While  all EPA regions reclassified about $131 million from 96 special accounts  during the 20-year period from fiscal years 1990 through 2010, about  $111 million, or about 85 percent, of this amount was reclassified during  the last 3 years of this period. In addition, since fiscal year 1990, EPA has  transferred about $14 million from 39 special accounts to the Trust Fund.
According to EPA guidance, for reclassification and transfer, regions  should provide planning estimates for the current fiscal year, as well as  the two subsequent fiscal years. According to EPA data, for fiscal years  2011 through 2013, about 4.1 percent—$74 million—of the total $1.8  billion in unobligated special account funds were designated for  reclassification or transfer to the Trust Fund. Of the $74 million, EPA  regions plan to reclassify about $61 million, or about 82 percent, from  special accounts and to transfer the remaining $13 million. EPA’s plans to  reclassify or transfer funds may change as a result of changing site  conditions throughout the Superfund cleanup process. For example, in  fiscal year 2010, EPA planned to reclassify $43 million and transfer about  $4 million; however, at the end of the fiscal year, EPA actually had  reclassified only $26 million and transferred about $3 million. Tables 4  and 5 show, by region, the number and value of special accounts planned  for reclassification and transfer for fiscal years 2011 to 2013, as of  October 2010.
EPA guidance states that reclassifications and transfers to the Trust Fund  should not take place until it can be reasonably estimated that the special  account contains more funds than are needed for remaining response  actions at the site. Therefore, according to EPA officials, it is generally  easier for the regions to determine if special account funds can be  reclassified or transferred once response actions at a site are  substantially complete. EPA officials said that they consider “Construction  Complete,” “NPL Delete,” and “Post Construction” to be the three phases  in the Superfund cleanup process when a site most likely can be  considered substantially complete and, therefore, the funds in a special  account may be considered for reclassification or transferred to the Trust  Fund. As of October 2010, the cleanup activities at 297 of the 769  Superfund sites with open accounts were considered substantially  complete, according to our analysis of EPA data, and therefore more  likely to have funds eligible to be reclassified or transferred than sites in  the earlier stages of the cleanup process. Table 6 presents the number of  Superfund sites with special accounts in each phase or milestone of the  cleanup process, from the remedial investigation/feasibility study to  deletion from the NPL, as of October 2010.
EPA requires special accounts to be closed when (1) all site work has  been completed, (2) no funds are left in the account and no future  deposits are anticipated, or (3) EPA does not anticipate incurring any  additional costs at those sites. As of October 2010, EPA had closed 76  special accounts since the beginning of the program; these accounts  were open an average of 7 years. According to our analysis of EPA data,  EPA closed 9 special accounts from fiscal years 2000 through 2005 and  67 accounts from fiscal years 2006 through 2010, including 33 in fiscal  year 2010. According to EPA officials, the steady increase in closures has  occurred because the regions are improving their management of special  accounts and closing accounts where no funds remain or funds are no  longer needed for future work.
section_title: EPA Has Implemented Processes and Policies in Recent Years to Better Monitor and Manage Superfund Special Accounts
paragraphs: In response to the IG’s findings and recommendations,officials’ own recognition that the agency needed to provide better  oversight of the special accounts process, EPA has implemented the  following processes and policies in the last few years to better monitor  and manage special accounts: (1) processes to better plan the use of  special account funds, (2) increased oversight of special accounts by  designating a national special accounts coordinator, and a Special  Accounts Senior Management Committee, and (3) strategies and  guidance on how to plan for using and monitoring special accounts.
subsections: section_title: EPA Has Implemented Processes to Better Plan for Use of Funds in Special Accounts
paragraphs: To facilitate regional management and headquarters planning and review  of special accounts, in 2008, EPA established a process to better track  planned uses for special account funds. That is, it established a section in  CERCLIS—referred to as the Special Account Management Screen (or  planning screen)—that enables EPA regions to see and enter special  account planning data into specific data fields and create reports so that  both EPA headquarters and regional officials can monitor the special  account balances against planned obligations for ongoing and future site- specific response activities. According to EPA officials, reports based on  data entered into fields on this screen have allowed both EPA  headquarters and regional staff to review the data to assure that, among  other things, the agency maximizes opportunities to use, reclassify, or  transfer these resources to the general portion of the Trust Fund over  time.
In the first few years of using this new planning screen, regional staff  noticed that some funds did not easily fit into the specified categories in  the screen, and they had to place the funds under other catchall fields,  according to EPA headquarters officials. As a result, in December 2010,  EPA added four new fields under the reserved use section and combined  two categories into one. These changes are intended to allow EPA  headquarters staff to better track the regions’ funding plans and to comply  with guidance issued in September 2010 clarifying how special account  funds are to be planned and used. For example, EPA headquarters  created a new field for funds reserved for a potential EPA takeover of the  work if one or more PRPs who are performing the site cleanup work  become insolvent; in such cases, EPA might have to fund necessary work  with special account funds. According to officials we spoke with in one  EPA region, these changes have helped reduce the number of questions  and concerns from headquarters during its reviews of regions’ plans to  allocate funds.
section_title: EPA Has Increased Oversight for Special Accounts
paragraphs: Before the IG’s 2009 report, EPA had recognized that it needed to better  oversee the regions’ management of special accounts, according to an  EPA headquarters official. In 2008, an EPA staff person in the Office of  Superfund Remediation and Technology Innovation—with assistance  from staff from other offices such as the Office of Site Remediation  Enforcement and Office of the Chief Financial Officer—was permanently  assigned to coordinate the management of special accounts with the  regions. This headquarters staff person—the national special accounts  coordinator—conducts annual and midyear reviews and holds  discussions with regional staff to evaluate regions’ plans to allocate  special account funds, among other things. Specifically, every August, in  preparation for the annual review of these funds, the coordinator analyzes  planning data on all open special accounts using monitoring reports  developed from CERCLIS data to ensure that regions are entering quality  data into CERCLIS, complying with special account guidance, and  effectively managing special accounts.
The coordinator told us that she focuses on particular details of a special  account in the annual review that may indicate a potential for special  account management problems. In particular, the coordinator examines  accounts that (1) disbursed no funds, and (2) have a large amount of  funds remaining although construction is complete or the site has been  deleted from the NPL, and (3) those accounts that are 10 years old or  more. In addition, the coordinator stated that she looks closely at certain  types of special accounts on a regular basis, such as the following:
Accounts with balances over $10 million. The coordinator examines  these accounts—which make up 61 percent of available special  account balances—to see the types of actions that have occurred. For  example, the coordinator told us that she checks whether planned  funding for prior fiscal years was actually obligated and disbursed as  planned. Specifically, she looks for any indications that a region  might be continually shifting the same planned obligated funds from  one fiscal year to the next and, if so, investigates the reasons for this  shift.
Accounts that had planned reclassifications, transfers to the Trust  Fund, or planned closures. The EPA coordinator told us that she  regularly examines whether these actions have occurred. For  example, according to EPA data, in fiscal year 2010, regions planned  to reclassify $43.1 million from 75 accounts at the beginning of the  year; however, the coordinator found that regions had actually  reclassified $26.2 million from 41 accounts by the end of that fiscal  year. For those 34 accounts where reclassification was not  completed, 20 accounts had their planned reclassifications moved to  future fiscal years, 10 accounts were identified as needing funds for  further work at the site, and 4 had their planned reclassified funds  transferred instead to the Trust Fund.
In addition, according to the coordinator, beginning in fiscal year 2011,  EPA focused on reviewing those special accounts with available balances  less than $10,000 to help ensure that funds are used as quickly as  possible so that the accounts can be closed. According to the coordinator,  this review allows the regions to focus their workload efforts on managing  the larger special accounts rather than the many accounts with relatively  few funds.
According to the coordinator, during this annual review, she may pose  questions regarding the regions’ planning estimates and suggest certain  actions to ensure better management of specific special accounts. For  example, the coordinator might suggest that the regions (1) use the funds  in a special account as an incentive for future settlements with PRPs, (2)  reclassify or transfer to the Trust Fund unneeded funds and close the  account when a site cleanup is completed or near completion, (3) correct  and update the account (such as entering funds in the proper planning  category), (4) use special account funds before using appropriated funds,  or (5) move previously planned obligated funds that have not yet been  obligated in a previous fiscal year to a future fiscal year. For example,  during the special account fiscal year 2011 annual review conducted in  2010, the coordinator asked questions regarding the regions’ planning  estimates on 285 special accounts. Based on our analysis of these  planning data, we identified 65 questions or suggestions related to  whether there was potential to reclassify or transfer to the Trust Fund  some or all account funds or close an existing account. The remaining  questions or suggestions identified a variety of subjects, including  whether the planned funding was put in the wrong category on the special  accounts planning screen in CERCLIS, and whether special account  funds could be used as an incentive for the PRP to do the work.
During the annual review, regional staff agree to make changes or  adequately explain the reasons why the coordinator’s suggestion should  not be taken at that time. According to EPA regional officials we spoke  with, all of the coordinator’s questions during the fiscal year 2011 annual  review were addressed before the next midyear planning sessions  conducted in the spring of 2011. However, according to a regional official  and the coordinator, a question from a previous planning session may be  asked again in subsequent planning sessions if it was not entirely or  sufficiently addressed. In some cases, the coordinator stated she wanted  to obtain more detailed information from the region to ensure that funds  were planned for use in the most effective and efficient way possible. In  other cases, while funds were planned in accordance with guidance, the  regional officials and the coordinator had a difference of opinion on the  best planned use of funds.
To examine this process in more detail, we sampled 20 accounts from  EPA headquarters’ 2010 annual planning review of 285 accounts about  which the coordinator had questions. For all of these accounts, the  regions addressed all the coordinator’s questions or took the  recommended action requested or suggested by the coordinator. For  example, the coordinator questioned $989,000 in special account funds  that were placed in the “Other” field without a detailed explanation on  when the determination for use of these funds would be made. As a result  of discussions with EPA headquarters and a change to the planning  screen, these funds were moved to a new field created in December  2010—”Protectiveness Contingencies.” According to EPA documentation,  this field should be used when current site information indicates there is  reasonable potential that a remedy will not be protective in the future. For  the account in question, EPA regional officials determined that available  special account funds for the site would still be needed to protect nearby  residences from the effects of a hazardous chemical contamination— Trichloroethylene (TCE). The remedy chosen for this TCE  contamination in the groundwater—an underground drainage system— had not resulted in lower contamination levels, and EPA had found vapor  intrusion in the crawl spaces of houses located at the site. EPA  determined that it would need the special account funds to assess  whether new migration systems need to be installed to prevent inhalation  of TCE from the crawl spaces.
According to the coordinator, once the planning discussions take place,  the regions are expected to make any corrections to planned special  account funds in CERCLIS. The coordinator then reviews the data again  and uses this information to establish a baseline for fiscal year planning.  In addition, the coordinator provides an annual work planning review  report to EPA management in December. In March of the following year,  the coordinator conducts midyear reviews to follow up on regional issues  and to monitor planned actions previously identified.
EPA headquarters holds bimonthly national conference calls with regional  officials to discuss any special accounts issues that have arisen and to  discuss possible changes to the special accounts process to make it  more efficient. Several regional officials we spoke with stated that,  between the conference calls, and other events, such as the annual  Superfund Special Accounts National Meeting and Cost Recovery  Training Conference, staff are provided with the information they need  to effectively manage special accounts.
In 2009, in response to the IG’s recommendation that a central  management official in headquarters for special accounts be established  to ensure management accountability, EPA established a Special  Accounts Senior Management Committee. Unlike the coordinator, who  has daily responsibility for special accounts, the committee has broader  responsibilities. It meets semiannually to provide overall management  oversight and monitor the status of special accounts. The IG had  recommended that a single office in headquarters be responsible for the  management of special accounts, but EPA officials told us that the  agency did not think this was a workable arrangement because the  management of special accounts requires the involvement of, and  coordination among, several EPA offices, including the regional offices.  The committee consists of directors from EPA headquarters offices  involved in the special accounts process, including the Office of  Superfund Remediation and Technology Innovation, the Office of Site  Remediation Enforcement, and the Office of the Chief Financial Officer,  as well as directors of relevant Superfund divisions from the regions.  Regional representation is rotated among regions every 2 years. A  committee charter lists the responsibilities of each office in managing  special accounts.
According to several EPA regional officials we spoke with who have  responsibilities for special accounts, the level of coordination and  transparency in managing special accounts between headquarters and  the regions has improved over the last few years. For example, one  regional official stated that the high level of coordination is evident from  headquarters’ review of regional planning data and related meetings to  discuss potential issues with specific special accounts. Another regional  official stated that headquarters has been very responsive, sharing  information and obtaining policy viewpoints from the region, and  implementing ways to streamline and improve the process.
section_title: EPA Has Issued Strategies and Guidance on Managing Special Accounts
paragraphs: EPA has issued new strategy and guidance documents to help manage  special accounts in response to the IG’s recommendations and EPA  headquarters’ own recognition that the agency needed to provide a more  nationally consistent approach to managing and monitoring special  accounts. Specifically, EPA established the Superfund Special Accounts  Management Strategy in 2009. This strategy sets forth the agency’s plan  to improve the use, management, and monitoring of special accounts to  help support Superfund site cleanups. According to EPA documentation,  this strategy serves as a road map for EPA regional and headquarters  personnel who are responsible for overseeing and managing special  accounts. The Special Accounts Senior Management Committee is  responsible for implementing this strategy. The strategy focuses on four  main areas: (1) coordination and transparency, such as intraagency  coordination between the EPA offices that are responsible for managing  special accounts; (2) special account use and planning efforts, such as  effective regional planning and use of the CERCLIS special account  planning screen; (3) monitoring special accounts, such as annual regional  work planning and midyear reviews; and (4) regional support, guidance,  and training.
EPA has also issued guidance on the (1) planning, use, and monitoring of  special account funds and (2) reclassifying special account funds,  transferring funds to the Trust Fund, and closing special accounts.
Planning, use, and monitoring of special account funds. EPA’s special  account guidance, issued in 2010, updated and expanded previous EPA  guidance that was originally published in 2001 and 2002. This newer  guidance provides specific information on the proper use and planning of  special account funds throughout the cleanup process. For example, EPA  generally expects that planning for the use of special account funds  occurs within 3 months after establishing a special account, and planning  should be updated on a regular basis during the year. According to EPA  regional officials we spoke with, they try to plan for the use of special  account funds as soon as possible. However, according to some regional  officials, various circumstances can affect whether planning can occur  within 3 months. For example, they noted, large special accounts usually  are associated with large, complex cleanup sites and therefore it is likely  to take longer to plan how funds will be used. At the same time, officials  said, these accounts are often a priority because of the hazards involved.  The workload required to plan and manage accounts with large balances  may result in less time available to plan for accounts with smaller  balances.
EPA also issued a detailed Monitoring Plan for Special Account Planning  Data in 2009, which EPA updated in November 2010. This plan describes  the process that EPA headquarters and the regions should follow to  monitor special account planning data, including the scheduled times  when middle of fiscal year and end of fiscal year final planning data  should be reviewed and discussed with the regions, made final, and  reported to the Special Accounts Senior Management Committee.
Reclassifying special account funds, transferring funds to the Trust Fund,  and closing special accounts. EPA headquarters issued detailed  guidance on the reclassification of special account funds in 2009,  including when EPA regions should consider doing a reclassification and  a step-by-step description of the reclassification process the regions  should follow. At the same time, it also issued a model memorandum for  transferring funds from a special account to the Trust Fund and closing  out a special account. In this guidance and memorandum, EPA states  that regions must notify headquarters when they plan to reclassify funds,  transfer funds to the Trust Fund, or close out an account. The regions  must submit a draft memorandum to headquarters staff in the Office of  Site Remediation Enforcement and the Office of Superfund Remediation  and Technology Innovation to discuss any potential issues with the action  prior to proceeding with the action. However, regional officials we spoke  with stated that the process for reclassifying funds has been complex and  that the requirements for conducting a reclassification were resource  intensive and time consuming. For example, regions had to submit a  memorandum with detailed information on the special account—no matter  how small the amount of funds to be reclassified. As a result, in April  2011, EPA headquarters issued revised model notifications to streamline  the process and accelerate the review process for reclassifications of  funds, transfer of funds to the Trust Fund, and closing of a special  account. According to EPA officials, the most significant change  eliminates the requirement for a formal memorandum for those  transactions that involve $200,000 or less. For those transactions, EPA  regions now only need to send an e-mail to headquarters staff informing  them of the intended action and provide the appropriate assurances in  accordance with guidance (e.g., if an account is to be closed, the region  does not anticipate any future deposits). For transactions involving  $200,000 or more, regions still need to send formal notification  memoranda to headquarters. However, these actions can now be  included in the same memorandum, rather than separate memorandums  if (1) a transfer of funds to the Trust Fund or closeout occurs at the same  time or immediately following a reclassification or (2) a closeout occurs at  the same time or immediately following a transfer of funds to the Trust  Fund  Several regional officials we spoke with stated that, overall the increased  guidance has been helpful, and that EPA headquarters has done a  thorough job of establishing any needed special accounts policy and  guidance documents, addressing all major aspects and issues relating to  the management of special accounts. In addition, officials from EPA  regions 3, 5, and 9 stated that their regions have added management  tools specific to their regions to enhance those available from  headquarters, including a special accounts regional database, intranet  site page, and guidance specific to their regions, respectively. An EPA  headquarters official stated that an increased emphasis has been made  in the last few years in headquarters to better manage the regions’  special account process, particularly the “back end” of the process  involving special account reclassifications, transfers to the Trust Fund,  and account closures. However, EPA headquarters officials told us that  the agency has recognized it may need to be more involved in the “front  end” of the special accounts process, when regions are deciding whether  to establish a special account. EPA headquarters is evaluating whether it  is efficient for the regions to open special accounts for small amounts, or  for those sites that may be further along in the cleanup process, because  regions need to spend time and staff resources monitoring these new  accounts. An EPA official stated that EPA’s Superfund Special Accounts  Senior Management Committee has approved a review of the policy for  establishing special accounts. The committee plans to begin this study in  fiscal year 2012 and, if needed, develop further guidance on the opening  of special accounts.
Furthermore, according to several of these regional officials, the changes  to notifications and revised model memorandum have made the  reclassification and transfer processes easier by minimizing the number  of staff who need to prepare and approve reclassifications and transfers  while saving time by eliminating extensive preparation and headquarters  review of notifications. The revised processes allow special account funds  to be reclassified and transferred faster. In addition, in June 2011, EPA  issued two fact sheets to regional special accounts staff that provide  supplemental information on special account reclassifications, as well as  specific steps required to close out a special account.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to EPA for review and comment. EPA  provided technical comments that we incorporated into the report, as  appropriate.
As agreed with your office, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies to the appropriate  congressional committees, Administrator of EPA, and other interested  parties. The report also will be available at no charge on the GAO website  at http://www.gao.gov.
If you or your staff members have any questions about this report, please  contact me at (202) 512-7114 or yocomc@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 major contributions to this  report are listed in appendix II.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: This appendix provides information on the scope of the work and the  methodology used to (1) describe the status of special accounts— including balances, locations, and recent and planned uses—of  Superfund special accounts and (2) examine the extent to which the  Environmental Protection Agency’s (EPA) headquarters and regions are  implementing processes and policies to improve the monitoring and  management of Superfund special accounts.
To describe the status of the 1,023 special accounts, we obtained and  analyzed data from EPA’s Comprehensive Environmental Response,  Compensation, and Liability Information System (CERCLlS) database.  Specifically, for information on special accounts balances; locations; and  recent and planned uses, including funds that had been obligated and  disbursed, as well as funds reclassified, transferred to the Superfund  Trust Fund, or closed, we analyzed spreadsheets obtained from officials  with EPA’s Office of Superfund Remediation and Technology Innovation.  For those funds that were planned to be obligated and reserved for future  use, as well as reclassified and transferred, we analyzed spreadsheets of  planned funds derived from EPA’s CERCLIS special accounts planning  screen, as of October 2010. We also obtained data and interviewed  officials at EPA’s headquarters and the Office of the Chief Financial  Officer regarding the makeup and current status of funds in the Trust  Fund.
To assess the reliability of the data from EPA’s CERCLIS database used  in this report, we analyzed related documentation, examined the data to  identify if there were any obvious errors or inconsistencies, and  interviewed knowledgeable agency officials about the data to see if there  were any known problems with the data and to learn more about their  procedures for maintaining the data. We determined the data to be  sufficiently reliable for the purposes of this report.
To examine the extent to which EPA’s headquarters and regions are  implementing policies and procedures to improve the monitoring and  management of Superfund special accounts, we analyzed documents  and interviewed officials from EPA headquarters offices, including the  Office of Superfund Remediation and Technology Innovation, the Office  of Site Remediation Enforcement, and the Office of the Chief Financial  Officer. Specifically, we obtained and reviewed strategies and guidance  issued by EPA headquarters to the regions on the special accounts  process, as well as available EPA regional documentation on the use of  management tools unique to EPA’s regions. We also analyzed  documents and interviewed officials from EPA’s Office of Inspector  General (IG) regarding their 2006 and 2009 reports on EPA’s  management of special accounts. We also conducted interviews with  officials in each of EPA’s 10 regional offices and collected supporting  documentation to determine how the regions managed and monitored  their special accounts and coordinated with EPA headquarters and, if  needed, conducted follow-up interviews to obtain additional data as a  result of our analysis. During these interviews, we also obtained  information on how EPA regions addressed EPA headquarters questions  or recommendations for actions on their special accounts that arose  during EPA’s fiscal year 2011 annual review of the regions’ planning data.  Specifically, we discussed and obtained data on 20 special accounts (2  special accounts from each region) taken from a sample of 285 accounts  about which EPA had questions or recommendations for actions. These  accounts were chosen from a random nonprobability sample and  therefore cannot be generalized to all special accounts.
We conducted this performance audit from October 2010 to January 2012  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
section_title: Appendix II: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the individual named above, Vincent P. Price, Assistant  Director; Greg Carroll; Laina Poon; and Amy Ward-Meier made key  contributions to this report. Elizabeth Beardsley, Cindy Gilbert, Julia  Kennon, Ruben Montes de Oca, and Carol Herrnstadt Shulman also  made important contributions.