Government Efficiency and Effectiveness: Implementing GAO Recommendations Can Achieve Financial Benefits and Strengthen Government Performance
Published: 2015-12-10T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: GAO’s mission is to support Congress in meeting its constitutional responsibilities and to help improve the performance and ensure the accountability of the federal government for the benefit of the American people. GAO provides nonpartisan, objective, and reliable information to Congress, executive branch agencies, and the public. To help Congress and the government, GAO recommends solutions across the broad spectrum of federal responsibilities to foster efficiency and effectiveness in federal programs and address high risks, management issues, and other challenges.
GAO’s work supports a broad range of interests throughout Congress. In fiscal year 2015, GAO received requests for work from 97 percent of the standing committees of Congress and 66 percent of their subcommittees.
Since fiscal year 2003, GAO’s work has resulted in over ½ trillion dollars in financial benefits and about 17,000 program and operational benefits that helped to improve public services and promote sound management throughout government. Executive branch cooperation and congressional oversight have been, and will continue to be, critical in helping realize the benefits of GAO’s recommendations.
This statement discusses (1) the status of GAO’s recommendations, including key outcomes and open issues and (2) mechanisms for focusing attention on implementing GAO’s open recommendations. It is based on GAO’s prior work spanning the federal government, including high-risk areas and ways to address fragmentation, overlap, and duplication.
section_title: What GAO Found
paragraphs: GAO's work routinely generates recommendations for improving the efficiency and effectiveness of government programs, resulting in measurable improvements. Since fiscal year 2010, GAO's work has resulted in over $330 billion in financial benefits and over 8,000 program and operational benefits. In fiscal year 2015 alone, GAO's work yielded $74.7 billion in financial accomplishments—a return of about $134 for every dollar invested in GAO. Other wide-ranging benefits include helping to avoid sequestration and identifying legislative solutions to federal performance and management issues. GAO has made an average of 1,800 recommendations a year with an average of about 80 percent implemented between fiscal years 2010 and 2015.
As of November 12, 2015, about 4,800 of GAO's recommendations to executive branch agencies and the Office of Management and Budget remain open across the federal government. If implemented, they could result in significant benefits, such as increased savings, better services to the public, and improved federal programs. A couple of examples to illustrate this potential follow:
Department of Defense (DOD) Weapon Systems Acquisition: On GAO's High Risk List since 1990, GAO's work has identified several opportunities for DOD to maximize its use of taxpayer dollars by improving its acquisition process. For example, given DOD's plans to increase F-35 funding by billions of dollars over the next 5 years, GAO recommended that DOD conduct a comprehensive affordability analysis of the program's procurement plan. DOD maintains that it accomplishes this through its annual budget process; however, without a more thorough and complete analysis, DOD may not fully understand the affordability implications of increasing funding at the planned rates.
Medicare Program Payment Policy: On GAO's High Risk List since 1990 due in part to its complexity and susceptibility to mismanagement, GAO has made many recommendations to improve Medicare, including improving the accuracy of the adjustment made for differences in diagnostic coding practices between Medicare Advantage (MA) and Medicare Fee-For-Service. For example, the Centers for Medicare & Medicaid (CMS) could better account for additional beneficiary characteristics, such as residential location, and use more current and refined data in determining MA payments. GAO made this recommendation because of shortcomings in CMS's adjustment, which resulted in excess payments to MA plans totaling an estimated $3.2 billion to $5.1 billion over a 3-year period from 2010 through 2012.
GAO continuously engages with executive branch agencies to ensure recommendations are implemented. For example, GAO regularly follows up with agencies on its recommendations and posts their status online. This year GAO sent letters to the heads of key executive branch agencies identifying unimplemented recommendations that warrant priority attention. GAO's high risk and fragmentation, overlap, and duplication work also highlights critical open recommendations for executive branch agencies and Congress. In addition, GAO works with Congress to further progress on recommendations, including incorporating GAO work into legislation.

section_title: Letter
paragraphs: Thank you for the opportunity to discuss how implementation of GAO’s  recommendations improves the federal government’s performance and  the efficiency and effectiveness of its operations. GAO’s work has  resulted in billions of dollars in savings and significantly improved  government programs and operations. Addressing unimplemented  recommendations can lead to additional savings, better services to the  public, and improved program performance and accountability.
GAO’s mission is to support Congress in meeting its constitutional  responsibilities and to help improve the performance and ensure the  accountability of the federal government for the benefit of the American  people. GAO provides nonpartisan, objective, and reliable information to  Congress, executive branch agencies, and the public and supports a  broad range of interests throughout Congress. In fiscal year 2015, GAO  received requests for work from 97 percent of the standing committees of  Congress and 66 percent of their subcommittees. Through our work  across the breadth and scope of the federal government’s responsibilities,  we recommend solutions that offer significant opportunities to foster  government efficiency, effectiveness, and responsiveness to high priority  risks, management issues, and other challenges facing Congress and the  nation. Executive branch cooperation and congressional oversight has  been and will continue to be critical in realizing the full benefits of GAO’s  recommendations.
My testimony today describes (1) the status of GAO’s recommendations,  including key outcomes and open recommendations and (2) mechanisms  for focusing attention on implementing GAO’s open recommendations.  This statement is based on our previous work in areas spanning the  federal government such as defense, health care, and information  technology; our high-risk program; fragmentation, overlap, and  duplication; and our performance and accountability report. This  statement is based upon work GAO conducted in accordance with  generally accepted government auditing standards and GAO’s quality  assurance framework. We believe that the evidence obtained provides a  reasonable basis for this statement.
subsections: section_title: GAO’s Work Has Contributed to Significant Financial and Other Benefits, but Further Opportunities Exist to Save Money and Improve Government
paragraphs: Our work routinely leads to recommendations for improving efficiency and  effectiveness across the federal government’s programs, resulting in  measurable savings and improvements. Since fiscal year 2003, our work  has resulted in over ½ trillion dollars in financial benefits and about  17,000 program and operational benefits that helped to improve public  services and promote sound management throughout government.
About 65 percent of our products contain recommendations, and since  2010, we have issued an average of almost 1,800 recommendations  each year. Management of the audited agencies has discretion on  whether to implement our recommendations, and executive branch  agencies have implemented an average of about 80 percent of our  recommendations, as reported in our performance and accountability  reports for fiscal years 2010 through 2015 (see table 1).
Since fiscal year 2010, our work has resulted in over $330 billion in  financial benefits and over 8,000 program and operational benefits that  helped to change laws, improve public services, and promote sound  management throughout government.  The following examples illustrate  the wide-ranging benefits from our work in several categories, including  (1) identifying cost savings and revenue opportunities to help to avoid  sequestration; (2) identifying legislative solutions; (3) achieving financial,  program, and operational benefits; (4) helping Congress oversee key  programs; (5) addressing high-risk areas; and (6) reducing fragmentation,  overlap, and duplication in government programs.
subsections: section_title: Helping to Avoid Sequestration
paragraphs: Our work helped Congress achieve some of the billions in savings and  revenue enhancements that could avoid sequestration in fiscal years  2014 through 2017. For example, key decisions adopted by Congress in  the Bipartisan Budget Act of 2013 were linked to our work and helped  Congress achieve about $23 billion in savings and revenue  enhancements to avoid sequestration in fiscal years 2014 and 2015, such  as  improving the cost-effectiveness of filling the Strategic Petroleum  Reserve, estimated by the Congressional Budget Office (CBO) to  save $3.2 billion from 2014 to 2023;  increasing aviation security fees to cover 43 percent of aviation  security costs in 2014, estimated by CBO to save $12.6 billion from  2014 through 2023; expanding the risk-based element of the Pension Benefit Guaranty  Corporation’s premium rate structure, estimated by CBO to increase  revenues and offset direct spending by $7.9 billion from 2014 through  2023  limiting the amount of compensation contractors working on a federal  contract can charge to the government to $487,000 annually, a  decrease from the previous cap of $952,308;  and  improving the collection of unemployment insurance overpayment by  $159 million and reducing improper payments to inmates for disaster  relief and other assistance resulting in savings of $80 million from  2014 through 2023, according to CBO.
The Bipartisan Budget Act of 2015 also included key provisions that  linked to our work and which could help Congress achieve about $30  billion in savings and revenue enhancements (as estimated by CBO and  the Joint Committee on Taxation (JCT)) needed to avoid sequestration in  fiscal years 2016 and 2017, including  streamlining and simplifying audit procedures for certain partnerships,  resulting in increased revenue estimated to be $9.3 billion from 2016  through 2025; and authorizing a 58 million barrel sale from the Strategic Petroleum  Reserve, estimated at $5.1 billion from 2018 to 2025; making additional spectrum, which companies use to provide services  such as mobile broadband, available for auction, estimated to  generate $4.4 billion from 2016 through 2025; allowing for potential savings through reforming Social Security  disability insurance by expanding fraud units, increasing criminal and  civil penalties for fraud, and allowing the receipt of electronic payroll  data to improve program administration, which is estimated to save  $140 million from 2019 through 2025.
section_title: Identifying Legislative Solutions
paragraphs: The Congress has used our work to identify legislative solutions to  increase government transparency, achieve cost savings, address  emerging problems, and find efficiencies in federal agencies and  programs. Our work has contributed to a number of key authorizations,  appropriations, and reauthorizations, including the following examples:
The Digital Accountability and Transparency Act of 2014 requires the  federal government to set government-wide data standards for  financial data intended to result in consistent, reliable, and searchable  government-wide spending data available to the Congress, agency  managers, and the public.
The Consolidated and Further Continuing Appropriations Act, 2015,  and its accompanying explanatory statement, rescinded or reduced  Administration proposals for weapon systems (for an estimated total  of over $500 million from programs such as for the Amphibious  Combat Vehicle, Joint Tactical Radio System, and the Kiowa Warrior  helicopter program); directed the Department of Veterans Affairs (VA)  to report to Congress on why its strategy to serve the burial needs of  rural veterans does not include all the elements required by law and  why it has not used census tract data to calculate veteran populations  served; and addressed the severe financial difficulties of  multiemployer pension plans and the Pension Benefit Guaranty  Corporation’s Multiemployer Insurance Program.
Provisions of law commonly referred to as Federal Information  Technology Acquisition Reform Act (FITARA) addressed cost and  performance issues in federal information technology (IT) acquisitions  by expanding the authorities of chief information officers and directing  agencies to improve the transparency of high-risk IT investments,  reduce duplication, and achieve cost savings opportunities.
The Veterans Access, Choice, and Accountability Act of 2014  changed the procedures by which the VA will pay for health care for  veterans outside of the VA system and addressed concerns about  coordination between VA and the Indian Health Service on veteran’s  health care.
The Protecting and Securing Chemical Facilities from Terrorist  Attacks Act of 2014 responded to emerging security issues with  regard to chemical facility security, which should improve risk  assessment procedures.
section_title: Achieving Financial, Program, and Operational Benefits
paragraphs: In fiscal year 2015, our work yielded $74.7 billion in financial  accomplishments—a return of about $134 for every dollar invested in us.  These financial benefits result from executive branch agency or  congressional actions to change agency business operations or activities;  restructure federal programs; or modify entitlements, taxes, or user fees.  Table 2 includes examples of new financial benefits for fiscal year 2015.
Many other benefits resulting from our work cannot be measured in dollar  terms, but improve programs and operations across the government.  During fiscal year 2015, we recorded 1,286 of these benefits; a few  examples follow:  Improved TSA Rail Security Incident Data. In 2012, we reported  that weaknesses hampered the Transportation Security  Administration’s (TSA) ability to extract information from its rail  security incident data system, causing TSA to miss chances to identify  important trends or patterns. In response to our recommendations,  TSA established a process and provided guidance to ensure the  completeness of incident data and minimize errors. TSA also  developed the Surface Compliance Trend Analysis Network, which in  part provides stakeholders with analyses of rail security trends and  potential threats. These actions will help TSA develop  recommended security measures for rail agencies, as appropriate.
Protected Elderly Americans. Our reports on elder abuse identified  challenges that state Adult Protective Services (APS) had in  addressing growing caseloads. These challenges stemmed from,  among other things, difficulty collecting and using data to track  outcomes and assess APS program effectiveness, leaving states with  limited information for resolving cases of abuse. In response to our  recommendations, the Department of Health and Human Services  (HHS) established the National Adult Protective Services Resource  Center to provide technical assistance to APS to enhance the quality  and effectiveness of state programs. The department also is working  with states to develop a nationwide APS data system. This data  system will, for the first time ever, provide consistent national data on  the extent and nature of the exploitation and abuse of vulnerable older  adults, allowing states and the federal government to better  understand and respond to the problem.
Secured the Skies with Stronger Aviation Cybersecurity. In 2015,  we reported that the Federal Aviation Administration lacked a  comprehensive model for identifying cybersecurity threats to the  NextGen air traffic control system. Our work drew congressional,  media, and public attention to these potential threats, and spurred the  agency to develop a cybersecurity model.
Reduced Technology Threats to Financial Markets. We reported  that the Securities and Exchange Commission faced challenges in  protecting financial securities markets from information technology  outages and cyberattacks. In response to our work, in 2014, the  commission required market participants better manage their  information technology risks. As a result, markets should be more  resilient to problems arising from both internal failures and external  threats.
section_title: Helping Congress Oversee and Strengthen Key Programs
paragraphs: We continue to build key bodies of work that help Congress (1) address  current and emerging challenges to the well-being and financial security  of the American people, (2) respond to changing security threats and  global interdependence, and (3) transform the federal government to  address national challenges. Work completed in fiscal year 2015 in these  areas included these examples:
Protection of children. We reported on children’s health insurance,  unregulated custody transfers of adopted children, oversight  challenges for the Bureau of Indian Education, and care for  unaccompanied alien children in U.S. custody.
Veterans. We reported on the availability of qualified nursing staff at  the VA medical centers, inconsistencies in processing veterans’  disability benefits, improvements needed to support eligibility  decisions for veterans’ disability benefits, and the need to improve  monitoring of veterans’ antidepressant use and the accuracy of  veterans’ suicide data.
Health care. We reported on the need to address improper payments  in the Medicare and Medicaid programs, expand efforts to reduce  antipsychotic drug use among older adults receiving care in homes  and community-based settings, improve Indian health care services,  and improve oversight of tax provisions for individuals under the  Patient Protection and Affordable Care Act (PPACA).
Science and Technology. We reported on the need to enhance the  nation’s biosurveillance capabilities, address safety lapses at high- containment laboratories, address potential gaps in environmental  satellite coverage, and minimize long-term federal exposure to  climate-related risks. Our technology assessments included reducing  freshwater use in hydraulic fracturing and thermoelectric power plant  cooling.
section_title: Addressing High-Risk Areas
paragraphs: We maintain a list for Congress of high-risk areas, which focuses on  government operations that are at high-risk of fraud, waste, abuse, and  mismanagement, or that need broad-based transformation to address  economy, efficiency, or effectiveness challenges of government  operations. Selected examples of programs on the High-Risk List  include:
Strengthening the foundation for efficiency and effectiveness.
Restructuring the U.S. Postal Service to achieve sustainable financial  viability and funding the nation’s surface transportation system.
Transforming the Department of Defense (DOD) program  management. DOD financial management and DOD supply chain  management.
Ensuring public safety and security. Strengthening the Department  of Homeland Security management functions, ensuring the security of  federal information systems and cyber critical infrastructure and  protecting the privacy of personally identifiable information.
Managing federal contracting more effectively. DOE’s contract  management for the National Nuclear Security Administration and  Office of Environmental Management, and NASA acquisition  management.
Assessing the efficiency and effectiveness of tax law  administration. Enforcement of tax laws and confronting identity theft  tax fraud.
Modernizing and safeguarding insurance and benefit programs.
Improving and modernizing federal disability programs and the  national flood insurance program.
In 2015, we issued our biennial update of our High-Risk List. This report  offers solutions to 32 identified high-risk problems, including two new  high-risk areas:
Managing Risks and Improving VA Health Care. Since 2000, we  have reported about VA facilities’ failure to provide timely health care.  In some cases, these delays or VA’s failure to provide care at all have  reportedly harmed veterans. Although VA has taken actions to  address some of our recommendations, more than 100 have not been  fully addressed, including recommendations related to the following  areas: (1) ambiguous policies and inconsistent processes, (2)  inadequate oversight and accountability, (3) information technology  challenges, (4) inadequate training for VA staff, and (5) unclear  resource needs and allocation priorities. The Veterans Access,  Choice, and Accountability Act of 2014 included provisions to help  VA address systemic weaknesses.  Improving the Management of IT Acquisitions and Operations.  The administration has undertaken numerous initiatives to better  manage IT investments. Nonetheless, federal IT investments too  frequently fail to be completed or incur cost overruns and schedule  slippages while contributing little to mission-related outcomes, which  led us to designating this as a new high-risk area in 2015. We found  that the federal government spent billions of dollars on failed and  poorly performing IT investments, which often suffered from  ineffective management, such as project planning, requirements  definition, and program oversight and governance. Over the past 6  years, we have made more than 800 recommendations in this area;  about 32 percent have been fully implemented as of October 2015. It  will be critical for executive branch agencies to implement our  remaining recommendations—particularly in the areas of (1)  incremental development, (2) reviews of troubled projects, (3)  transparency, (4) operations and maintenance, (5) data center  consolidation, and (6) portfolio management—as well as the  provisions commonly known as FITARA, which also aims to improve  the transparency and management of federal IT acquisitions and  operations.
We identified five criteria that form a road map for efforts to improve and  ultimately address high-risk issues. Addressing some of the criteria leads  to progress, while satisfying all of the criteria is central to removal from  the list. Figure 1 shows the five criteria and examples of actions taken by  agencies to address the criteria.
In 2015, we introduced a rating system for showing progress in high-risk  areas to help more easily visualize continuing progress and remaining  actions in high-risk areas (see figure 2). Each point of the star represents  one of the five criteria for removal from the High-Risk List and each ring  represents one of three designations: not met, partially met, or met. An  unshaded point at the innermost ring means that the criterion has not  been met, a partially shaded point at the middle ring means that the  criterion has been partially met, and a fully shaded point at the outermost  ring means that the criterion has been met.
These progress ratings are an important part of our efforts to provide  greater transparency and specificity to agency leaders as they seek to  address high-risk areas. Beginning in the spring of 2014 and leading up to  our 2015 high-risk update, we met with agency leaders to discuss  preliminary progress ratings and actions taken as well as actions needed  to address the high-risk issues. Several agency leaders told us that the  additional clarity provided by the progress rating helped them better target  their improvement efforts.
Our high-risk report noted that solid, steady progress has been made in  the vast majority of the high-risk areas. This progress has been possible  through the concerted actions and efforts of Congress and the leadership  and staff in executive branch agencies and the Office of Management and  Budget (OMB). As shown in appendix I, 18 high-risk areas have met or  partially met all five criteria for removal from the list; 11 of these areas  also fully met at least one criterion. Further, for two of these areas— Protecting Public Health through Enhanced Oversight of Medical  Products and DOD Contract Management—enough progress has been  made to remove subcategories of the high-risk areas.
Solving these high-risk problems has the potential to save billions of  dollars, improve service to the public, and strengthen the performance  and accountability of the U.S. government. For example, in 2015, our  high-risk work resulted in $17 billion in financial benefits and 435 other  benefits. We have documented more than $40 billion in financial benefits  and 866 other improvements related to high-risk areas. The following are  examples of benefits from this work.
Managing federal real property. In 2014, we reported that a lack of  criteria could have caused the General Services Administration (GSA)  to miss opportunities for its “swap-construct” program, through which  the government can provide unneeded property to developers in  exchange for improving federal buildings on other properties. We also  found that GSA provided too few details about construction needs to  get meaningful input from interested parties. In response to our  recommendations, GSA issued new guidance addressing these  concerns, which will help the government address long-standing  challenges with disposing of surplus real property and modernizing  outdated buildings.
Strengthening Department of Homeland Security management  functions. The Department of Homeland Security (DHS) has  established various initiatives collectively intended to improve its unity  of effort by, improving the department’s planning, programming,  budgeting, and execution processes through strengthened  departmental structures and increased capability, among other things.  In addition, DHS has increased component-level acquisition capability  by, among other things, initiating monthly Component Acquisition  Executive staff forums to provide guidance and share best practices.  DHS has also strengthened its enterprise architecture program (or  blueprint) to guide and constrain information technology acquisitions,  and it obtained a clean opinion on its financial statements for three  consecutive years, fiscal years 2013 through 2015.
section_title: Reducing Fragmentation, Overlap, and Duplication in Government Programs
paragraphs: Our annual reports on opportunities to reduce fragmentation, overlap, and  duplication and achieve other financial benefits also have contributed to  significant financial benefits and improved efficiency and effectiveness  across the federal government. As of November 2015, 36 percent of the  over 500 actions from our five annual reports have been addressed (see  table 3). Executive branch and congressional efforts to address these  recommendations have resulted in over $20 billion in financial benefits  with about $80 billion to accrue in future years from the continued  implementation of these recommendations. Further, fully addressing all  the remaining actions we identified in our annual reports could lead to  tens of billions in additional savings.
section_title: Other Open Recommendations with Significant Potential Benefits
paragraphs: While much progress has been made on many of our recommendations,  other critical recommendations to improve efficiency and effectiveness  across the federal government remain unimplemented. As of November  12, 2015, about 4,800 of our recommendations to the executive branch  agencies and OMB remain open across the federal government. The  following examples illustrate opportunities for realizing significant  financial, program, and operational benefits if our open recommendations  are implemented.
DOD’s portfolio of major defense acquisition programs, which has been  on our High-Risk List since 1990, consists of 78 programs with an  estimated cost of $1.4 trillion. While DOD continues to show progress in  following a knowledge-based approach to reduce risk, it has significant  room for improvement. While programs that have recently passed through  major decision points have demonstrated best practices—such as  constraining development times and achieving design stability—key  practices like demonstrating technology maturity or controlling  manufacturing processes are still not being fully implemented. This is of  particular concern for programs that have recently entered system  development before satisfying best practices, leaving them at risk for  future cost and schedule growth. However, we were pleased to find that  more programs are implementing selected acquisition reforms focused on  affordability, cost savings, and competition than in the past. Given the  austere budgetary environment, the department should continue and  even increase the use of these practices, as well as more fully implement  others to avoid past problems.
We have open recommendations related to four acquisition programs that  would benefit from the department’s attention given the size of DOD’s  investments in them and their cost, schedule, and performance  challenges, including:
F-35 Joint Strike Fighter Program: In April 2015, we reported that  the F-35 Joint Strike Fighter program continues to encounter  significant technical problems, including engine and bulkhead failures,  which require design changes at the same time aircraft production is  well underway. DOD plans to steeply increase F-35 funding over the  next 5 years and projects that it will need between $14 billion and $15  billion annually for nearly a decade. This poses significant affordability  challenges as other major programs—including the KC-46A Tanker,  the DDG 51 Destroyer, and the Ohio-class submarine replacement— will vie for significant funding commitments at that time. Accordingly,  we recommended that DOD conduct a comprehensive affordability  analysis of the F-35 program’s procurement plan that reflects various  assumptions about future technical progress and funding availability.  DOD agreed with our recommendation, although it maintains it  accomplishes this through its annual budget process. However,  without a more thorough analysis of possible future scenarios, DOD  may not be able to accurately account for the future technical and  funding uncertainty it faces, and thus may not fully understand the  affordability implications of increasing F-35 procurement funding at  the planned rates.
Littoral Combat Ships (LCS): DOD also continues to contract for  multiple LCS even though the ships have not demonstrated key  capabilities. Specifically, the ships have not completed key testing,  such as rough water, shock, and total ship survivability. The LCS’s  ability to conduct missions with two of the three mission packages is  also largely undemonstrated. Moreover, the Navy has significantly  altered its acquisition strategy and is modifying the design of future  ships. As a result, we recommended that key tests be successfully  completed before contracting for additional ships. DOD partially  concurred with our recommendation; however, unless the program is  re-evaluated, the Navy remains at risk of procuring ships that do not  meet mission requirements.
CVN 78 Ford-class aircraft carrier: The Navy faces technical,  design, and construction challenges in completing the CVN 78 Ford- class aircraft carrier, which have already led to cost increases,  schedule delays, and reduced capabilities. In particular, the maturity  and testing of key technologies have fallen years behind. The ship is  likely to need more time to complete testing. Cost estimates for the  next carrier, CVN 79, have not fully reflected the actual experiences of  CVN 78. As a result, we recommended that DOD explore capability  tradeoffs, allot sufficient time for testing, and ensure that follow-on  ships have realistic cost estimates. DOD generally concurred with  our recommendations, but stated that the capability analysis would  occur after operational testing, which we think may be too late to  make effective tradeoff decisions, and the Navy continues to overlap  test activities which will constrain its opportunities to implement  corrective action.
Missile Defense Agency (MDA): MDA faces acquisition  management challenges that hamper the agency’s ability to make  wise investment choices and develop and deliver cutting edge,  integrated technologies within budget and time constraints. For over a  decade, MDA has provided Congress with very limited insight into  cost and schedule growth for individual elements. While baseline  reporting is improved, in many instances, there is no way to track cost  and schedule growth over time using those baselines. In April 2013,  we recommended that MDA stabilize acquisition baselines to enable  meaningful comparisons over time and make its cost estimates more  comprehensive by including operation and support costs. While  DOD concurred with our recommendations, since the issuance of our  report, we continue to see content and costs shift within or between  programs, making it difficult to make meaningful comparisons over  time. We will continue to monitor MDA’s progress on stabilizing its  baselines over the course of future audits.
In 2014, Medicare financed health services for about 54 million elderly  and disabled beneficiaries at a cost of $603 billion. Due to its size,  complexity, and susceptibility to mismanagement and improper  payments, we designated it as a high-risk program in 1990 and have  identified several key recommendations to help address these issues.
For example, in January 2012, we recommended that the Centers’ for  Medicare & Medicaid Services (CMS) take steps to improve the accuracy  of the adjustment made for differences in diagnostic coding practices  between Medicare Advantage (MA) and Medicare Fee-For-Service. For  example, CMS could better account for additional beneficiary  characteristics, such as sex and residential location, and use more  current and refined data in determining MA payments. We made our  recommendation because we found that shortcomings in CMS’s  adjustment resulted in excess payments to MA plans totaling an  estimated $3.2 billion to $5.1 billion over a 3-year period from 2010  through 2012. CMS said it would take our findings into consideration,  but as of April 2015 the agency has not established definitive plans or  timeframes for improving the accuracy of its adjustment. Until CMS  updates its practices, excess payments due to differences in coding  practices are likely to increase.
Transparency and Integrity of Medicaid Program  Medicaid covered an estimated 65 million low-income people in fiscal  year 2014, and enrollment is growing under PPACA. Medicaid outlays for  fiscal year 2014 were $508 billion, of which $304 billion was financed by  the federal government and the remainder by states. Medicaid accounted  for 14 percent ($17.5 billion) of the almost $125 billion improper payment  estimate in fiscal year 2014 with the estimate increasing to $29.1 billion  for fiscal year 2015 (government-wide estimate not yet available). We  designated Medicaid as a high-risk area in 2003.
Over the past several years, we made numerous recommendations that if  effectively implemented, could improve program management, help  reduce improper payments in these programs, and help improve the  government’s fiscal position. These recommendations include the  following:
Medicaid Demonstrations: We continue to be concerned that the  approval process for demonstration waivers lacks transparency and  raises cost concerns. For example, we estimated potential savings of  about $33 billion in five states if HHS had approved spending limits  consistent with what documentation supported. We have a  longstanding recommendation that HHS take certain steps to improve  its budget neutrality process and policy so the basis for spending  limits would be clear and consistent and ensure that these  demonstrations, which now represent almost one-third of Medicaid  expenditures, do not further increase federal Medicaid liabilities.  HHS does not agree with our recommendation and suggested that  steps it has taken, such as updating some guidance, have increased  transparency. We agree that these steps may provide some guidance,  but the overall efforts fall short of clarifying HHS’s budget neutrality  policy.
Medicaid Improper Payments: We reported concerns in 2014 that  neither CMS nor the states are well-positioned to identify improper  payments made to managed care organizations or to ensure that  these organizations are taking appropriate steps to identify and  prevent improper payments to providers. Given the growth in  managed care and its increasing share of Medicaid expenditures, the  lack of a comprehensive program integrity strategy for managed care  leaves a growing portion of Medicaid funds at risk. We recommended  that CMS increase its oversight of Medicaid managed care program  integrity. Specifically, we recommended that CMS provide audit  support and guidance to states, and hold them accountable for closer  scrutiny of managed care payments. CMS has proposed major new  guidance related to Medicaid managed care and this guidance  includes provisions that would be relevant to this recommendation.
Supplemental Security Income (SSI)
The Social Security Administration’s (SSA) SSI program provides cash  benefits to eligible low-income individuals with disabilities, including  children. In December 2014, SSA paid more than $860 million to about  1.3 million disabled children, the majority of whom received benefits due  to a mental impairment.
SSA is required to periodically conduct reviews to determine if children  are still eligible for payments, but in June 2012 we found that more than  24,000 continuing disability reviews (CDRs) for children with mental  impairments were overdue by 6 or more years, including over 6,000  CDRs for children who were expected to medically improve within 6 to 18  months of their initial determination. We also identified several cases  which exceeded their scheduled review date by 13 years or more. When  CDRs are not conducted as scheduled, the potential for improper  payments increases as some recipients receive benefits for which they  are no longer eligible. SSA attributes delays in performing CDRs to  resource limitations and other factors; SSA also generally gives lower  priority to conducting CDRs for children receiving SSI. In 2012, we  recommended that SSA eliminate the existing CDR backlog for children  with impairments who are likely to improve and regularly conduct reviews  for this group.
In each year since our audit, SSA has increased its number of reviews  and officials said that with sustained, predictable funding, SSA will  continue to work toward eliminating this backlog. In April 2015, we  estimated that if this recommendation were implemented, SSA could  potentially save $3.1 billion over 5 years, based on our analysis of fiscal  year 2011 data. When reviews are not conducted as scheduled, the  government is at risk of billions of dollars in overpayments.
Since 2009, we have designated the reform of the U.S. financial  regulatory system as high-risk. In 2010, the Dodd-Frank Wall Street  Reform and Consumer Protection Act created the Financial Stability  Oversight Council (FSOC) to identify and address threats to the stability  of the U.S. financial system and Office of Financial Research (OFR) to  support FSOC and Congress by providing financial research and data.
In 2012, we reported that FSOC and OFR face challenges in achieving  their missions to identify risks and respond to emerging threats to  financial stability, and that some efforts may be duplicative because  multiple FSOC members, such as the Federal Reserve, also have  ongoing efforts to monitor threats to financial stability. We  recommended FSOC and OFR clarify responsibility for implementing  requirements to monitor threats to financial stability across FSOC and  OFR, including FSOC members and member agencies. In response,  Treasury questioned the need for FSOC and OFR to clarify these  responsibilities and as of October 2015, FSOC staff said formal  distinctions are not needed because FSOC and OFR work well together.  However, we maintain that more specific actions are still needed, as our  past work has shown that without clearly delineating and coordinating  roles and responsibilities, there can be duplication of efforts, confusion,  and regulatory gaps.
The security of federal cyber security has been on our High-Risk List  since 1997. Nineteen of 24 agencies covered by the Chief Financial  Officers Act (CFO Act agencies) declared cybersecurity as a significant  deficiency or material weakness for fiscal year 2014. In addition, most of  the 24 agencies continue to have weaknesses in key controls such as  those for limiting, preventing, and detecting inappropriate access to  computer resources and managing the configurations of software and  hardware.
Since 2010, we have made approximately 2,000 recommendations in this  area. Executive branch agencies have taken steps to address them, but  about 840 recommendations remain outstanding. For example, we  recommended that OMB (1) address agency cyber incident response  practices in its oversight of agency information security programs, and (2)  collaborate with stakeholders to enhance reporting guidance for the  inspector general community. OMB did not comment on the first  recommendation and generally concurred with the second one, stating  that it was working with stakeholders to improve the reporting process.  Implementing these and other outstanding recommendations will enable  federal agencies to better respond to cyberattacks and data breaches and  will provide for more consistent and useful reporting to Congress.
Safety of the Food Supply  On our High-Risk List since 2007, the fragmented federal food safety  system has caused inconsistent oversight, ineffective coordination, and  inefficient use of resources. While agencies and Congress have taken  some steps to improve federal food safety oversight, several key  recommendations remain unimplemented. For example, in September  2014, we found that the U.S. Department of Agriculture (USDA), which is  responsible for ensuring the safety of poultry products, had not developed  performance measures for all poultry products, such as ground chicken,  to determine whether poultry processing plants are meeting the agency’s  goals for protecting human health. Ensuring the safety of poultry  products is particularly important because poultry products contaminated  with pathogens cause more deaths than any other commodity;  specifically, Salmonella and Campylobacter cause more than 2 million  human illnesses per year. We recommended that performance measures  be developed to help reduce illnesses caused by Salmonella and  Campylobacter contamination for certain types of chicken and turkey.  USDA agreed with our recommendations and noted it is taking steps  toward implementing them; however, measures and targets have yet to  be established. In the absence of such measures and targets,  performance information is not being publicly reported, limiting  transparency, oversight, and accountability.
In the 2013 duplication and cost savings annual report, we reported that  federal agencies could achieve significant cost savings annually by  expanding and improving their use of strategic sourcing—a contracting  process that moves away from numerous individual procurement actions  to a broader aggregated approach. For example, DOD, DHS, VA, and the  Department of Energy accounted for 80 percent of the $537 billion in  federal procurement spending in fiscal year 2011, but reported managing  about 5 percent, or $25.8 billion, through strategic sourcing efforts. In  contrast, leading commercial firms leverage buying power by strategically  managing 90 percent of their spending—achieving annual savings of 10  percent or more. While strategic sourcing may not be suitable for all  procurement spending, we reported that a reduction of 1 percent from  procurement spending at the largest agencies at that time would equate  to over $4 billion in savings annually—an opportunity also noted in the  House Budget Resolution for fiscal year 2016.
OMB has made progress on improving strategic sourcing efforts across  the federal government by issuing guidance on calculating savings for  government-wide strategic sourcing contracts.  In December 2014 it  issued a memorandum on category management that, among other  things, identifies federal spending categories suitable for strategic  sourcing. These categories cover some of the government’s largest  spending categories, including information technology and professional  services, which, according to OMB, accounted for $277 billion in fiscal  year 2013 procurements. While these are important first steps, until OMB  sets government-wide goals and establishes metrics, the government  may miss opportunities for billions in cost savings through strategic  sourcing.
In December 2014, we recommended that DHS develop a plan to better  control and reduce the Federal Emergency Management Agency’s  (FEMA) administrative costs for major disasters. FEMA has begun efforts  to develop an integrated plan to control and reduce administrative costs  for major disaster declarations. However, until FEMA meets its targets  for controlling administrative costs, these costs could continue to increase  federal expenditures by millions of dollars. We also recommended that  FEMA develop a methodology to better assess a jurisdiction capability to  respond to and recover from a disaster without federal assistance.  FEMA has submitted a report to Congress outlining various options that it  could take to implement our recommendation. However, without an  accurate assessment of jurisdiction capabilities to respond to and recover  from a disaster, FEMA runs the risk of recommending to the President  that federal disaster assistance be awarded without considering a  jurisdiction’s response and recovery capabilities or its fiscal capacity.
In recent years, we identified a number of recommendations for improving  a variety of the DHS border security programs and operations. For  example, we recommended that DHS enhance the U.S. Immigration and  Customs Enforcement’s (ICE) oversight of the Student and Exchange  Visitor Program. DHS has begun to take steps to address our  recommendations, such as working to re-certify schools eligible to admit  foreign students. To fully address the recommendations, DHS needs to  complete its recertification process and take any necessary compliance  actions to help ensure that schools approved to admit foreign students  are consistently following program requirements and to better position  ICE to identify and mitigate fraud and other risks in the program. We also  recommended that U.S. Customs and Border Protection (CBP) improve  the acquisition management of the Arizona Border Surveillance  Technology Plan to better ensure the reliability of its planning documents,  such as schedules and cost estimates; inform future decision-making  about technology deployments; and assess the effectiveness of deployed  technologies. CBP is working toward addressing these recommendations.
Mission-critical skills gaps in such occupations as cybersecurity and  acquisition pose a high-risk to the nation: whether within specific federal  agencies or across the federal workforce, they impede federal agencies  ability to cost-effectively serve the public and achieve results. Addressing  complex challenges, such as disaster response, national and homeland  security, and rapidly evolving technology and privacy security issues,  requires a high-quality federal workforce able to work seamlessly with  other agencies, levels of government, and across sectors. On our High- Risk List since 2011, we have reported on human capital strategies which  will help agencies meet their mission in an era of constrained resources.  We made several recommendations that collectively will strengthen  agencies’ leadership commitment and capacity to address skills gaps.  OPM agreed with these recommendations, which included the following:
Strengthening OPM’s coordination and leadership of government- wide human capital issues, in part by developing a government-wide  human capital strategic plan that would establish priorities, time  frames, responsibilities, and metrics to better align the efforts of  members of the federal human capital community;
Exploring the feasibility of expanded use of enterprise or “whole of  government” solutions to address shared human capital issues—such  as workforce planning tools and lessons learned that would help build  the capacity of agencies to address skills gaps; and
Reviewing the extent to which new capabilities are needed to promote  agile talent management—including developing or sharing tools and  resources to help identify skills gaps and mechanisms for increasing  staff mobility within and across agencies.
In response, OPM is considering a multi-phase human capital strategy  designed to, among other things, institutionalize processes for identifying  and addressing government-wide and agency skills gaps and emphasize  the use of workforce data and analytic tools.
Our work has also identified a number of opportunities for the government  to reduce costs and increase revenue collections through congressional  action, including the following examples:
Social Security Offsets. In our 2011 annual duplication and cost  savings report, we reported that the SSA needs data from state and  local governments on retirees who receive pensions from employment  not covered under Social Security to better enforce offsets and ensure  benefit fairness. In particular, SSA needs this information to fairly and  accurately apply the Government Pension Offset, which generally  applies to spouse and survivor benefits, and the Windfall Elimination  Provision, which applies to retired worker benefits. The Social  Security’s Government Pension Offset and Windfall Elimination  Provision attempt to take noncovered employment into account when  calculating Social Security benefits. While information on receipt of  pensions from noncovered employment is available for federal  pension benefits from the federal Office of Personnel Management, it  is not available to SSA for many state and local pension benefits.
We suggested that Congress give the IRS the authority to collect the  information that SSA needs on government pension income to  administer the Government Pension Offset (GPO) and Windfall  Elimination Provision (WEP) accurately and fairly. The President’s  Fiscal Year 2016 Budget submission re-proposed legislation that  would require state and local governments to provide information on  their noncovered pension payments to SSA so that the agency can  apply the GPO and WEP. The proposal includes funds for  administrative expenses, with a portion available to states to develop  a mechanism to provide this information. Providing information on the  receipt of state and local noncovered pension benefits to SSA could  help the agency more accurately and fairly administer the  Government Pension Offset and Windfall Elimination Provision and  could result in an estimated $2.4 billion in savings over 10 years,  according to CBO, if enforced both retrospectively and prospectively.  If Social Security only enforced the offsets prospectively, the overall  savings still would be less.
Paid Preparer Regulation. Establishing requirements for paid tax  return preparers could improve the accuracy of the tax returns they  prepare. Oregon began regulating preparers in the 1970s and  requires testing among other requirements. In August 2008, we found  that the odds that a return filed by an Oregon paid preparer was  accurate were 72 percent higher than the odds for a comparable  return filed by a paid preparer in the rest of the country. In August  2014, IRS reported that 68 percent of all tax returns claiming the EITC  in tax years 2006 and 2007 were prepared by paid tax preparers— most of whom were not subject to any IRS regulation—and that from  43 to 50 percent of the returns overclaimed the credit. Similarly, in  our undercover visits in 2014 to randomly selected tax preparers, a  sample that cannot be generalized, we found errors in EITC claims  and non-Form W-2 income reporting (for example, cash tips) resulting  in significant overstatement of refunds. Establishing requirements  for paid tax return preparers could improve the accuracy of the tax  returns they prepare. In 2014, we suggested Congress consider  granting IRS the authority to regulate paid tax preparers, if it agrees  that significant paid preparer errors exist. Multiple bills have been  introduced which, if enacted, would regulate paid preparers.
Math error authority. IRS has the authority to correct calculation  errors and check for other obvious noncompliance such as claims  above income and credit limits. Treasury has proposed expanding  IRS’s “math error” authority to “correctible error” authority to permit it  to correct errors in cases where information provided by the taxpayer  does not match information in government databases, among other  things. Expanding such authority—which we have suggested  Congress consider with appropriate safeguards—could help IRS  correct additional errors and avoid burdensome audits and taxpayer  penalties. In March 2015, JCT estimated that more flexible  correctible error authority could raise $133 million through 2025.
section_title: GAO Uses Various Mechanisms to Encourage Implementation of Its Recommendations
paragraphs: We focus attention on following up on our recommendations to help  ensure that they are implemented effectively and in a timely manner.  Notably, we engage with executive branch agencies on an on-going basis  about opportunities to improve program performance during the course of  our audit work. By communicating with executive branch agency officials  throughout the audit process, deficiencies identified in our work can be  immediately addressed, without waiting for a report to be issued. For  example, when conducting our recent review of the IRS Whistleblower  program, we identified some errors in awards payments IRS sent to  whistleblowers. IRS took immediate action and reviewed all of its 17  closed high-dollar cases and found additional problems, which it resolved  by providing affected whistleblowers with corrected award payments.
Figure 3 highlights the mechanisms we use to emphasize our  recommendations.
Agency Review and Comment. We provide executive branch agency  officials with an opportunity to review and comment on a draft of our  report, including the recommendations, before it is issued. Through this  process, agency officials may indicate steps that they are taking or  planning to take to address the recommendations, and we reflect these  steps in the report as appropriate. If the officials do not agree with our  recommendations, they can provide the rationale for any disagreement  with our report findings. After receiving the agency’s comments, we  consider their substance, revise the draft product as appropriate, and  present the agency’s comments in the final report.
Agency Reporting to Congress. When we issue a report containing  recommendations to the head of an agency, that official is required by  statue to submit a written statement of the actions taken by the agency on  our recommendations to the Senate Committee on Homeland Security  and Governmental Affairs and the House Committee on Oversight and  Government Reform not later than 60 days after the date of the report  and also to the Senate and House Appropriations Committees. This  process has been in place for over 40 years. I believe it is time to  examine how well it is addressing Congress’s needs, especially in the  current budget environment. We will report the results of this examination  to the committee.
Outreach to Agencies. At least once a year we reach out to agencies to  determine the extent to which they have implemented our  recommendations and if benefits can be attributed to our work.  Throughout this process, our leadership works with executive branch  agency officials to bring attention to our recommendations. Our analysts  also update the status of recommendations when conducting related work  on a particular topic.
Report on Recommendation Status. Updates are posted to a public  database at www.gao.gov, which Congress can use to prepare for  oversight hearings and budget deliberations. In addition, we update the  status of recommendations when preparing testimony for Congress and  as part of ongoing related work. Continued attention to recommendations  is important because failure to implement our prior recommendations is  often a major factor that leads to issues escalating to the point where they  become high-risk.
In addition to these processes, our high-risk and fragmentation, overlap,  and duplication work and efforts on priority recommendations highlight  critical unimplemented recommendations that we believe warrant  attention by agencies and Congress. We maintain attention on these  issues through our biennial reports to Congress on high-risk issues and  our annual reports on duplication and cost savings.
Monitoring areas of high-risk and fragmentation, overlap, and  duplication. As part of our high-risk initiative, we have met with OMB’s  Deputy Director for Management and with top agency officials to discuss  progress in addressing individual high-risk areas. Such efforts are critical  to tracking progress, pinpointing improvement opportunities, and  resolving high-risk issues.
To further progress on outstanding duplication and cost savings  recommendations, we regularly engage with OMB and recently identified  a list of key issues where OMB attention could be instrumental in  furthering progress on recommendations that involve multiple agencies or  government-wide improvements. We also monitor the progress executive  branch agencies and Congress have made in addressing the over 500  actions identified in our 2011 through 2015 annual reports. To maintain  attention on these issues, in 2013, we launched GAO’s Action Tracker, a  publicly accessible online search tool that allows executive branch  agencies, Congress, and the public to track the progress the government  is making in addressing the issues we have identified.
To stimulate further progress in addressing high-risk issues, Senators  Ernst, Heitkamp, and Casey sponsored the Program Management  Improvement Accountability Act (S. 1550) which, if enacted, would  establish processes for improving program and project management  across the federal government. The act, among other things, designates  Program Management Improvement Officers at agencies and establishes  an interagency council to make recommendations to OMB based on  GAO’s high-risk work. In addition, the act would have GAO review the  effectiveness of these program and project management improvements  outlined in the bill. In November 2015, the bill passed the Senate, and a  related bill H.R. 2144 Program Management Improvement and  Accountability Act of 2015 has been referred to the House Committee on  Oversight and Government Reform.
Identifying priority recommendations. In 2015, we undertook an effort  to call attention to unimplemented recommendations that we believe  warrant priority attention by the Secretary or agency heads at key  departments and agencies. We sent letters to the heads of key  departments and agencies identifying these high priority  recommendations and urging the agency head to continue to provide  attention to these issues. Fully implementing these priority  recommendations should yield significant improvements in agency  operations, program management, or costs.
Initial agency response to our letters has been positive, and in some  instances, agencies have begun to take action on the priority  recommendations including the following examples:
Following our letter to the Secretary of HHS, we met with CMS  officials in October 2015 to discuss the agency’s efforts to address our  recommendations. Officials noted that they are now tracking open  recommendations using a dashboard that includes quarterly targets  for closing recommendations. To facilitate CMS’s efforts to close our  recommendations, we agreed to hold regular meetings to discuss the  status of our recommendations and what remains to be done to close  them.  In response to our letter to GSA, the Administrator committed to  continuing to work with us to address the priority recommendations in  advance of our next high-risk update in February 2017. We meet  quarterly with GSA senior executives to discuss progress on  implementing recommendations that would help GSA take steps to  remove federal real property management from our High-Risk List and  address other key management concerns.
Working with Congress to address recommendations. Congress  plays a key role in providing oversight and maintaining focus on our  recommendations to ensure they are implemented and produce desired  results. In addition to reporting on the status of recommendations to  Congress, we engage with Congress on strategies for further addressing  our recommendations. These strategies include incorporating our  recommendations into legislation. For example, our improper payments  work informed the Improper Payments Elimination and Recovery  Improvement Act of 2012 (IPERIA), the latest in a series of laws  Congress passed to address improper payments.
We also recommend agencies assess the need for legislation and report  their findings to Congress. For example, we recommended that IRS fully  assess the costs and benefits of accelerating Form W-2 deadlines to  provide information needed for Congress to deliberate the merits of  making such a significant change, which we previously reported could  help improve problems associated with identity theft tax fraud and Earned  Income Tax Credit improper payments. In September 2015, IRS  provided us a report on the potential costs and benefits of accelerating  the Form W-2 deadlines, which concluded that the federal government  could potentially protect billions of dollars in net revenue by using W-2  information to detect identity theft refund fraud before issuing refunds. We  requested additional information on certain costs and benefits not detailed  in the report. The Senate Committee on Finance held a hearing on  improper payments and the tax gap in October 2015, which further  brought attention to this issue.
Additionally, Congress can use its budget, appropriations, and oversight  processes to incentivize executive branch agencies to act on our  recommendations and monitor their progress. For example, Congress  can hold hearings, withhold funds, or take other actions to provide  incentives for the agencies to act. This strategy can be useful when  agencies disagree or have a limited response to our recommendations.  For example, Congress took such steps after we reported in 2012 that  DOD’s approach to acquiring combat uniforms was fragmented,  potentially resulting in increased risk on the battlefield and lost  opportunities to save millions of dollars. A provision in the National  Defense Authorization Act for Fiscal Year 2014 established as policy that  the Secretary of Defense shall eliminate the development and fielding of  service-specific combat and camouflage utility uniforms in order to adopt  and field common uniforms for specific environments to be used by all  members of the armed forces. Because of this legislation, the Army  chose not to introduce a new family of camouflage uniforms into its  inventory, avoiding about $4.2 billion in costs over 5 years. Congressional  use of our work sends an unmistakable message to agencies that  Congress considers these issues a priority.
In conclusion, as the fiscal pressures facing the government continue, so  too does the need for executive branch agencies and Congress to  improve the efficiency and effectiveness of government programs and  activities. Our recommendations provide a significant opportunity to  improve the government’s fiscal position, better serve the public, and  make government programs more efficient and effective. We will continue  to work with Congress to monitor and draw attention to these important  issues.
Chairman Lankford, Ranking Member Heitkamp, and Members of the  Subcommittee, this completes my prepared statement. I would be  pleased to answer questions that you may have at this time.
For further information on this testimony please contact Heather Krause,  Acting Director, Strategic Issues, who may be reached at (202) 512-6806  or krauseh@gao.gov. Contact points for our Offices of Congressional  Relations and Public Affairs offices may be found on the last page of this  statement.
section_title: Appendix I: GAO’s 2015 High Risk Areas Rated Against Five Criteria for Removal
paragraphs: Appendix I: GAO’s 2015 High Risk Areas Rated  Against Five Criteria for Removal This is a work of the U.S. government and is not subject to copyright protection in the  United States. The published product may be reproduced and distributed in its entirety  without further permission from GAO. However, because this work may contain  copyrighted images or other material, permission from the copyright holder may be  necessary if you wish to reproduce this material separately.