Nuclear Nonproliferation: DOE Needs to Reassess Its Program to Assist Weapons Scientists in Russia and Other Countries
Published: 2008-01-23T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: During the decades before its dissolution, the Soviet Union produced a cadre of scientists and engineers whose knowledge and expertise could be invaluable to countries or terrorist groups trying to develop weapons of mass destruction (WMD). After the Soviet Union's collapse in 1991, many of these scientists suffered significant cuts in pay or lost their government-supported work. To address concerns about unemployed or underemployed Soviet-era weapons scientists, the Department of Energy (DOE) established the Initiatives for Proliferation Prevention (IPP) program in 1994 to engage former Soviet weapons scientists in nonmilitary work in the short term and create private sector jobs for these scientists in the long term. GAO was asked to assess (1) DOE's reported accomplishments for the IPP program, (2) DOE's exit strategy for the program, and (3) the extent to which the program has experienced annual carryovers of unspent funds and the reasons for any such carryovers. In December 2007, GAO issued a report--Nuclear Nonproliferation: DOE's Program to Assist Weapons Scientists in Russia and Other Countries Needs to Be Reassessed, (GAO-08-189)--that addressed these matters. To carry out its work, GAO, among other things, analyzed DOE policies, plans, and budgets and interviewed key program officials and representatives from 22 Russian and Ukrainian institutes.
section_title: What GAO Found
paragraphs: DOE has overstated accomplishments on the number of scientists receiving DOE support and the number of long-term, private sector jobs created. First, although DOE claims to have engaged over 16,770 scientists in Russia and other countries, this total includes both scientists with and without weapons-related experience. GAO's analysis of 97 IPP projects involving about 6,450 scientists showed that more than half did not claim to possess any weapons-related experience. Furthermore, officials from 10 Russian and Ukrainian weapons institutes told GAO that the IPP program helps them attract, recruit, and retain younger scientists and contributes to the continued operation of their facilities. This is contrary to the original intent of the program, which was to reduce the proliferation risk posed by Soviet-era weapons scientists. Second, although DOE asserts that the IPP program helped create 2,790 long-term, private sector jobs for former weapons scientists, the credibility of this number is uncertain because DOE relies on "good-faith" reporting from U.S. industry partners and foreign institutes and does not independently verify the number of jobs reported to have been created. DOE has not developed an exit strategy for the IPP program. Officials from the Russian government, Russian and Ukrainian institutes, and U.S. companies raised questions about the continuing need for the program. Importantly, a senior Russian Atomic Energy Agency official told GAO that the IPP program is no longer relevant because Russia's economy is strong and its scientists no longer pose a proliferation risk. DOE has not developed criteria to determine when scientists, institutes, or countries should "graduate" from the program. In contrast, the Department of State, which supports a similar program to assist Soviet-era weapons scientists, has assessed participating institutes and developed a strategy to graduate certain institutes from its program. Even so, we found that DOE is currently supporting 35 IPP projects at 17 Russian and Ukrainian institutes where State no longer funds projects because it considers them to have graduated from its program. In addition, DOE has recently expanded the program to new areas. Specifically, DOE began providing assistance to scientists in Iraq and Libya and, through the IPP program, is working to develop projects that support a DOE-led international effort to expand the use of civilian nuclear power. In every fiscal year since 1998, DOE carried over unspent funds in excess of the amount that the Congress provided for the program. Two main factors have contributed to this recurring problem--lengthy review and approval processes for paying former Soviet weapons scientists and delays in implementing some IPP projects. In its recent report, GAO recommended, among other things, that DOE conduct a fundamental reassessment of the IPP program, including the development of a prioritization plan and exit strategy. DOE generally concurred with GAO's findings, but does not believe that the IPP program needs to be reassessed.

section_title: Letter
paragraphs: I am pleased to be here today to discuss the Department of Energy’s  (DOE) Initiatives for Proliferation Prevention (IPP) program, which seeks  to engage former Soviet weapons scientists in nonmilitary work in the  short term and create private sector jobs for these scientists in the long  term. Specifically, my remarks are based on the report we issued in  December 2007—Nuclear Nonproliferation: DOE’s Program to Assist  Weapons Scientists in Russia and Other Countries Needs to Be  Reassessed. This report is our second review of the IPP program. In 1999,  we found significant problems with DOE’s management of the IPP  program and, as a result, we made several recommendations that DOE has  implemented to improve the program.
After the Soviet Union’s collapse in 1991, many scientists and engineers  with weapons of mass destruction (WMD) knowledge and expertise  suffered significant cuts in pay or lost their government-supported work.  To address concerns that these scientists would sell their expertise to  terrorists or countries of concern, DOE began its IPP program in 1994.  Through October 1, 2007, there were 929 draft, active, inactive, and  completed IPP projects involving personnel at about 200 nuclear,  chemical, and biological institutes in Russia and other countries. As of  April 2007, DOE reported it had supplemented the salaries of over 16,770  scientists, engineers, and technicians and created 2,790 long-term, private  sector jobs in Russia and other countries through the IPP program.
My testimony today will discuss (1) DOE’s reported accomplishments for  the IPP program, (2) DOE’s exit strategy for the IPP program, and (3) the  extent to which the IPP program has experienced annual carryover  balances of unspent funds and the reasons for such carryovers. In  conducting our review, we examined 207 of the 929 IPP projects. We  selected this sample of projects on the basis of a variety of factors, such as  geographic distribution, representation of all participating U.S. national  laboratories, and project costs. We interviewed key DOE and national  laboratory officials and analyzed documentation, such as program  guidance, project proposals, and financial information. We also  interviewed officials from 15 Russian and 7 Ukrainian institutes and 14  U.S. companies that participate in the program. In addition, we analyzed  program cost and budgetary information, interviewed knowledgeable  officials on the reliability of these data, and determined that they were  sufficiently reliable for the purposes of our review. We conducted this  performance audit from October 2006 through December 2007 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: IPP project proposals are prepared and submitted to DOE by officials from  the participating national laboratories. Each national laboratory provides  technical and financial oversight for a set of projects. An Inter-Laboratory  Board (ILAB) serves as the primary coordinating body for the national  laboratories involved in the program. Partnerships are formed by the  national laboratories between U.S. companies—known as industry  partners—and institutes in Russia and other countries. IPP project  proposals are reviewed by DOE’s national laboratories, the IPP program  office, and other agencies before they are approved for funding. Because  the national laboratory prepares the proposal, the laboratory project  manager is responsible for including, among other things, a list of intended  participants and for designating the WMD experience for each participant.  The proposed participants are assigned to one of the following categories:  Category I—direct experience in WMD research, development, design,  production, or testing; Category II—indirect WMD experience in the  underlying technologies of potential use in WMD; or Category III—no  WMD-relevant experience. After the project passes an initial review within  the national laboratory, it is analyzed by the ILAB and its technical  committees, which then forward the proposal to DOE for review. DOE, in  turn, consults with State and other agencies on policy, nonproliferation,  and coordination considerations. DOE’s IPP program office is responsible  for making final decisions on all projects.
DOE requires that at least 65 percent of each IPP project’s funding be used  as payments to individuals actually working on the project or to the  participating institutes in payment for project-related supplies, equipment,  and overhead. Because the IPP program is not administered through a  government-to-government agreement, DOE distributes IPP funding  through three tax-exempt entities to avoid paying foreign taxes. These  organizations transfer funds directly to the personal bank accounts of IPP  project participants. To receive payment, project participants must submit  paperwork to these organizations indicating, among other things, whether  they possess WMD experience.
section_title: DOE Has Overstated the IPP Program’s Progress and Achievements
paragraphs: DOE has not accurately portrayed the IPP program’s progress in the  number of WMD scientists receiving DOE support and the number of long- term, private sector jobs created. Many of the scientists in Russia and  other countries that DOE has paid through its IPP program did not claim  to have WMD experience. Furthermore, DOE’s process for substantiating  the weapons backgrounds of IPP project participants has several  weaknesses. In addition, DOE has overstated the rate at which weapons  scientists have been employed in long-term, private sector jobs because it  does not independently verify the data it receives on the number of jobs  created, relies on estimates of job creation, and includes in its count a  large number of part-time jobs that were created. Finally, DOE has not  revised the IPP program’s performance metrics, which are based on a 1991  assessment of the threat posed by former Soviet weapons scientists.
subsections: section_title: Many Scientists in Russia and Other Countries Who Did Not Claim Direct Experience with WMD Have Received Funds from DOE
paragraphs: A major goal of the IPP program is to engage former Soviet weapons  scientists, engineers, and technicians, and DOE claims to have  supplemented the incomes of over 16,770 of these individuals since the  program’s inception. However, this number is misleading because this  figure includes both personnel with WMD experience and those without  any WMD experience, according to DOE officials. We reviewed the  payment records of 97 IPP projects, for which information was available  and complete, and found that 54 percent, or 3,472, of the 6,453 participants  in these projects did not claim to possess any WMD experience in the  declarations they made concerning their backgrounds. We also found that  DOE is not complying with a requirement of its own guidance for the IPP  program—that is, each IPP project must have a minimum of 60 percent of  the project’s participants possessing WMD-relevant experience prior to  1991 (i.e., Soviet-era WMD experience). We found that 60 percent, or 58, of  the 97 projects for which we had complete payment information did not  meet this requirement.
Finally, many IPP project participants that DOE supports are too young to  have contributed to the Soviet Union’s WMD programs. Officials at 10 of  the 22 Russian and Ukrainian institutes we interviewed said that IPP  program funds have allowed their institutes to recruit, hire, and retain  younger scientists. We found that 15 percent, or 972, of the 6,453  participants in the payment records of the 97 projects we reviewed were  born in 1970 or later and, therefore, were unlikely to have contributed to  Soviet-era WMD efforts. While DOE guidance for the IPP program does not  prohibit participation of younger scientists in IPP projects, DOE has not  clearly stated the proliferation risk posed by younger scientists and the  extent to which they should be a focus of the IPP program.
section_title: DOE’s Process for Assessing IPP Project Participants’ WMD Credentials Has Weaknesses
paragraphs: In 1999, we recommended that, to the extent possible, DOE should obtain  more accurate data on the number and background of scientists  participating in IPP program projects. DOE told us that it has made  improvements in this area, including developing a classification system for  WMD experts, hiring a full-time employee responsible for reviewing the  WMD experience and backgrounds of IPP project participants, and  conducting annual project reviews. However, DOE relies heavily on the  statements of WMD experience that IPP project participants declare when  they submit paperwork to receive payment for work on IPP projects. We  found that DOE lacks an adequate and well-documented process for  evaluating, verifying, and monitoring the number and WMD experience  level of individuals participating in IPP projects.
According to DOE officials, IPP projects are scrutinized carefully and  subjected to at least 8, and in some cases 10, stages of review to assess the  WMD experience of the project participants. However, we found  limitations in DOE’s process. Specifically:    DOE has limited information to verify the WMD experience of personnel  proposed for IPP projects because government officials in Russia and  other countries are reluctant to provide information about their countries’  scientists. For example, three national laboratory officials stated that it is  illegal under Russian law to ask project participants about their  backgrounds, and that instead they make judgments regarding the WMD  experience of the project participants on the basis of their personal  knowledge and anecdotal information.
Some IPP project proposals may advance from the national laboratories to  DOE with insufficient vetting or understanding of all personnel who are to  be engaged on the project. Senior representatives at five national  laboratories told us that they and their project managers do not have  sufficient time or the means to verify the credentials of the proposed  project participants.
DOE does not have a well-documented process for verifying the WMD  experience of IPP project participants, and, as a result, it is unclear  whether DOE has a reliable sense of the proliferation risk these  individuals pose. DOE’s review of the WMD credentials of proposed  project participants relies heavily on the determinations of the IPP  program office. We examined the proposal review files that the program  maintains, and we were unable to find adequate documentation to  substantiate the depth or effectiveness of the program office’s review of  the WMD experience of proposed IPP project participants.
Because it can be a matter of months or longer between development of  an IPP project proposal and project implementation, the list of personnel  who are actually paid on a project can differ substantially from the  proposed list of scientists. For several IPP projects we reviewed, we did  not find documentation in DOE’s project files indicating that the  department was notified of the change of staff or had assessed the WMD  backgrounds of the new project participants. For example, one IPP  project—to discover new bioactive compounds in Russia and explore their  commercial application—originally proposed 27 personnel and was  funded at $1 million. However, 152 personnel were eventually paid under  this project, and we did not find an updated list of the project personnel or  any indication of a subsequent review by DOE in the IPP project files.
The limited information DOE obtains about IPP project participants and  the limitations in DOE’s review of the backgrounds of these individuals  leave the IPP program vulnerable to potential misallocation of funds. We  found several instances that call into question DOE’s ability to adequately  evaluate IPP project participants’ backgrounds before the projects are  approved and funded. For example, a National Renewable Energy  Laboratory official told us he was confident that a Russian institute  involved in a $250,000 IPP project to monitor microorganisms under  environmental stress was supporting Soviet-era biological weapons  scientists. However, during our visit to the institute in July 2007, the  Russian project leader told us that neither he nor his institute was ever  involved in biological weapons research. As a result of this meeting, DOE  canceled this project on July 31, 2007. DOE’s cancellation letter stated that  the information provided during our visit led to this action.
section_title: DOE Has Overstated the Number of Jobs Created By the IPP Program
paragraphs: Although a senior DOE official described commercialization as the  “flagship” of the IPP program, we found that the program’s  commercialization achievements have been overstated and are misleading.  In its most recent annual report for the IPP program, DOE indicated that  50 projects had evolved to support 32 commercially successful activities.  DOE reported that these 32 commercial successes had helped create or  support 2,790 new private sector jobs for former weapon scientists in  Russia and other countries. In reviewing these projects, we identified  several factors that raise concerns over the validity of the IPP program’s  reported commercial success and the numbers of scientists employed in  private sector jobs. For example:    The annual survey instrument that the U.S. Industry Coalition distributes  to collect information on job creation and other commercial successes of  IPP projects relies on “good-faith” responses from U.S. industry partners  and foreign institutes, which are not audited by DOE or the U.S. Industry  Coalition. In 9 of the 32 cases, we found that DOE based its job creation  claims on estimates or other assumptions. For example, an official from a  large U.S. company told us that the number of jobs it reported to have  helped create was his own rough estimate.
We could not substantiate many of the jobs reported to have been created  in our interviews with the U.S. companies and officials at the Russian and  Ukrainian institutes where these commercial activities were reportedly  developed. For example, officials from a U.S. company we interviewed  claimed that 250 jobs at two institutes in Russia had been created, on the  basis of two separate IPP projects. However, during our visit to the  Scientific Research Institute of Measuring Systems in Russia to discuss  one of these projects, we were told that the project is still under way,  manufacturing of the product has not started, and none of the scientists  have been reemployed in commercial production of the technology.
section_title: DOE Has Not Revised the IPP Program’s Performance Metrics
paragraphs: The IPP program’s long-term performance targets do not accurately reflect  the size and nature of the threat the program is intended to address  because DOE is basing the program’s performance measures on outdated  information. DOE has established two long-term performance targets for  the IPP program—to engage 17,000 weapons scientists annually by 2015 in  either IPP grants or in private sector jobs resulting from IPP projects, and  to create private sector jobs for 11,000 weapons scientists by 2019.  However, DOE bases these targets on a 16-year-old, 1991 National  Academy of Sciences (NAS) assessment that had estimated approximately  60,000 at-risk WMD experts in Russia and other countries in the former  Soviet Union. DOE officials acknowledged that the 1991 NAS study does  not provide an accurate assessment of the current threat posed by WMD  scientists in Russia and other countries. However, DOE has not formally  updated its performance metrics for the IPP program and, in its fiscal year  2008 budget justification, continued to base its long-term program targets  on the 1991 NAS estimate.
Moreover, DOE’s current IPP program metrics do not provide sufficient  information to the Congress on the program’s progress in reducing the  threat posed by former Soviet WMD scientists. The total number of  scientists supported by IPP grants or employed in private sector jobs  conveys a level of program accomplishment, but these broad measures do  not describe progress in redirecting WMD expertise within specific  countries or at institutes of highest proliferation concern. DOE has  recognized this weakness in the IPP program metrics and recently initiated  the program’s first systematic analysis to understand the proliferation risk  at individual institutes in the former Soviet Union. DOE officials briefed us  on their efforts in September 2007, but told us that the analysis is still  under way, and that it would not be completed until 2008. As a result, we  were unable to evaluate the results of DOE’s assessment.
section_title: DOE Has Not Developed an Exit Strategy for the IPP Program but Instead Has Expanded Efforts to New Areas
paragraphs: DOE has yet to develop criteria for phasing-out the IPP program in Russia  and other countries of the former Soviet Union. Russian government  officials, representatives of Russian and Ukrainian institutes, and  individuals at U.S. companies raised questions about the continuing need  for the IPP program, particularly in Russia, whose economy has improved  in recent years. Meanwhile, DOE is departing from the program’s  traditional focus on Russia and other former Soviet states to engage  scientists in new countries, such as Iraq and Libya, and to fund projects  that support GNEP.
subsections: section_title: Russian Government Officials, Russian and Ukrainian Scientists, and U.S. Industry Representatives Questioned the Continuing Need for the IPP Program
paragraphs: Officials from the Russian government, representatives of Russian and  Ukrainian institutes, and individuals at U.S. companies raised questions  about the continuing need for the IPP program. Specifically:    A senior Russian Atomic Energy Agency official told us in July 2007 that  the IPP program is no longer relevant because Russia’s economy is strong  and its scientists no longer pose a proliferation risk.
Officials from 10 of the 22 Russian and Ukrainian institutes we interviewed  told us that they do not see scientists at their institutes as a proliferation  risk. Russian and Ukrainian officials at 14 of the 22 institutes we visited  told us that salaries are regularly being paid, funding from the government  and other sources has increased, and there is little danger of scientists  migrating to countries of concern.
Representatives of 5 of the 14 U.S. companies we interviewed told us that,  due to Russia’s increased economic prosperity, the IPP program is no  longer relevant as a nonproliferation program in that country.
In economic terms, Russia has advanced significantly since the IPP  program was created in 1994. Some of the measures of Russia’s economic  strength include massive gold and currency reserves, a dramatic decrease  in the amount of foreign debt, and rapid growth in gross domestic product.  In addition, the president of Russia recently pledged to invest substantial  resources in key industry sectors, including nuclear energy,  nanotechnology, and aerospace technologies. Many Russian institutes  involved in the IPP program could benefit from these initiatives,  undercutting the need for future DOE support.
In another sign of economic improvement, many of the institutes we  visited in Russia and Ukraine appeared to be in better physical condition  and more financially stable, especially when compared with their  condition during our previous review of the IPP program. In particular, at  one institute in Russia—where during our 1998 visit we observed a  deteriorated infrastructure and facilities—we toured a newly refurbished  building that featured state-of-the-art equipment. Russian officials told us  that the overall financial condition of the institute has improved markedly  because of increased funding from the government as well as funds from  DOE. In addition, one institute we visited in Ukraine had recently  undergone a $500,000 renovation, complete with a marble foyer and a  collection of fine art.
section_title: DOE Has Not Developed Criteria to Phase Out the IPP Program
paragraphs: DOE has not developed an exit strategy for the IPP program, and it is  unclear when the department expects the program to have completed its  mission. DOE officials told us in September 2007 that they do not believe  that the program needs an exit strategy. However, they acknowledged that  the program’s long-term goal of employing 17,000 WMD scientists in  Russia and other countries does not represent an exit strategy.
DOE has not developed criteria to determine when scientists, institutes, or  countries should be “graduated” from the IPP program, and DOE officials  believe that there is a continued need to engage Russian scientists. In  contrast, State has assessed institutes and developed a strategy—using a  range of factors, such as the institute’s ability to pay salaries regularly and  to attract external funding—to graduate certain institutes from its Science  Centers program. We found that DOE is currently supporting 35 IPP  projects at 17 Russian and Ukrainian institutes that State considers to  already be graduated from its Science Center program and, therefore, no  longer in need of U.S. assistance.
section_title: DOE Has Expanded Efforts to Iraq and Libya and Is Working to Support GNEP
paragraphs: DOE recently expanded its scientist assistance efforts on two fronts: DOE  began providing assistance to scientists in Iraq and Libya, and, through the  IPP program, is working to develop IPP projects that support GNEP.  These new directions represent a significant departure from the IPP  program’s traditional focus on the former Soviet Union. According to a  senior DOE official, the expansion of the program’s scope was undertaken  as a way to maintain its relevance as a nonproliferation program.
DOE has expanded the IPP program’s efforts into these new areas without  a clear mandate from the Congress and has suspended parts of its IPP  program guidance for implementing projects in these new areas.  Specifically:    Although DOE briefed the Congress on its plans, DOE officials told us that  they began efforts in Iraq and Libya without explicit congressional  authorization to expand the program outside of the former Soviet Union.  In contrast, other U.S. nonproliferation programs, such as the Department  of Defense’s Cooperative Threat Reduction program, sought and received  explicit congressional authorization before expanding their activities  outside of the former Soviet Union.
In Libya, DOE is deviating from IPP program guidance and its standard  practice of limiting the amount of IPP program funds spent at DOE’s  national laboratories for project oversight to not more than 35 percent of  total expenditures.
Regarding efforts to support GNEP, DOE has suspended part of the IPP  program’s guidance that requires a U.S. industry partner’s participation,  which is intended to ensure IPP projects’ commercial potential.
section_title: The IPP Program’s Large Balances of Unspent Program Funds Result from Multiple DOE and Contractor Reviews and Delays in Project Implementation
paragraphs: Since fiscal year 1994, DOE has spent about $309 million to implement the  IPP program but has annually carried over large balances of unspent  program funds. Specifically, in every fiscal year from 1998 through 2007,  DOE carried over unspent funds in excess of the amount that the Congress  provided for the program in those fiscal years. For example, as of  September 2007, DOE had carried over about $30 million in unspent  funds—$2 million more than the $28 million that the Congress had  appropriated for the IPP program in fiscal year 2007. In fact, for 3 fiscal  years—2003 through 2005—the amount of unspent funds was more than  double the amount that the Congress appropriated for the program in  those fiscal years, although the total amount of unspent funds has been  declining since its peak in 2003.
Two main factors have contributed to DOE’s large and persistent  carryover of unspent funds: the lengthy and multilayered review and  approval processes DOE uses to pay IPP project participants for their  work, and long delays in implementing some IPP projects. DOE identified  three distinct payment processes that it uses to transfer funds to individual  scientists’ bank accounts in Russia and other countries. These processes  involve up to seven internal DOE offices and external organizations that  play a variety of roles, including reviewing project deliverables, approving  funds, and processing invoices. DOE officials told us that these processes  were introduced to ensure the program’s fiscal integrity and  acknowledged the enormity of the problem that the lag time between the  allocation of funds, placement of contracts, and payment for deliverables  creates for the IPP program and told us they are taking steps to streamline  their payment processes. In addition, Russian and Ukrainian scientists at 9  of the 22 institutes we interviewed told us that they experienced delays in  payments ranging from 3 months to 1 year.
Delays in implementing some IPP projects also contribute to DOE’s large  and persistent carryover of unspent funds. According to officials from U.S.  industry partners, national laboratories, and Russian and Ukrainian  institutes, some IPP projects experience long implementation delays. As a  result, project funds often remain as unspent balances until problems can  be resolved. These problems include implementation issues due to  administrative problems, the withdrawal or bankruptcy of the U.S.  industry partner, and turnover in key project participants.
In part to address concerns about unspent program funds, DOE began  implementing its Expertise Accountability Tool, a new project and  information management system designed to better manage IPP projects’  contracts and finances, in October 2006. According to DOE officials, the  system will allow instant sharing of IPP project data between DOE and  participating national laboratories. DOE officials believe that the system  will allow the IPP program office to better monitor the progress of IPP  projects at the national laboratories, including reviews of IPP project  participants’ WMD backgrounds and tracking unspent program funds.
Mr. Chairman, this concludes my prepared statement. We would be happy  to respond to any questions you or the other Members of the  Subcommittee may have.
section_title: GAO Contact and Staff Acknowledgments
paragraphs: For further information about this testimony, please contact me at (202)  512-3841 or at robinsonr@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this statement. Gene Aloise (Director), Glen Levis (Assistant Director),  R. Stockton Butler, David Fox, and William Hoehn made key contributions  to this statement.
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.