Overseas Allowances: State Should Assess the Cost-Effectiveness of Its Hardship Pay Policies
Published: 2017-09-13T00:00:00

Fast Facts:
The Department of State provides two types of additional compensation for employees working in challenging overseas areas: hardship pay and danger pay. When employees temporarily leave those posts, State adjusts the pay.
While danger pay is automatically adjusted, State's procedures for adjusting hardship pay are resource intensive—involving 10,000 manual adjustments each year—and contributed to $2.9 million in payment errors between 2015 and 2016.
We recommended that State assess its hardship pay policies and increase its efforts to identify, recover, and prevent payment errors.

Highlights:
section_title: Why GAO Did This Study
paragraphs: State provides hardship and danger pay, among other allowances, as incentives for State personnel to work at challenging overseas locations. Hardship pay compensates employees for service at overseas posts where conditions differ substantially from those in the United States. Danger pay compensates employees for service at posts where civil insurrection, civil war, terrorism, or wartime conditions threaten the health or well-being of an employee.
This report examines hardship and danger pay, specifically, (1) State’s spending at overseas posts in fiscal years 2011-2016, (2) the extent to which State has followed its process for determining rates, (3) the procedures State uses to implement its policies for starting and stopping hardship and danger pay, and (4) the extent to which State has identified improper payments. GAO analyzed State data and documents; interviewed State officials in Washington, D.C.; and conducted fieldwork at four posts that receive hardship or danger pay: Islamabad, Pakistan; Mexico City, Mexico; New Delhi, India; and Tunis, Tunisia.
section_title: What GAO Found
paragraphs: The Department of State (State) spent about $732 million for hardship pay and $266 million for danger pay at overseas posts in fiscal years 2011 through 2016.
State has mostly followed its process for determining hardship and danger pay rates at overseas posts. To determine hardship rates, State calculates scores for overseas posts based on information from post surveys and data on factors such as air pollution and crime. GAO reviewed scores for 192 posts and found that State mostly followed its process. However, in 12 of 15 cases where State added points for extreme conditions not captured in its written standards—Director Points—it did not clearly document how posts met these criteria. Without adequate documentation, the department cannot ensure that it is awarding these points consistently. For danger pay, State followed a process that bases rates on threat levels for political violence and terrorism and whether family members are allowed at post.
State’s procedures for stopping and starting hardship pay when employees temporarily leave posts—based on several factors—are resource intensive, but State has not assessed their cost-effectiveness. State uses diplomatic cables to adjust hardship pay, but these procedures are resource intensive—requiring 10,000 pay actions each year—and contribute to improper payments, which are costly to recover. State’s procedures for adjusting danger pay through time and attendance, based on whether or not employees are present at posts, are mostly automated. State has not assessed the cost-effectiveness of its hardship pay policies and procedures in accordance with its Foreign Affairs Manual .
State identified $2.9 million in improper payments related mostly to hardship pay in fiscal years 2015-2016. State conducts required improper payments audits but has not analyzed available data that could help further identify and recover overpayments related to hardship pay. Guidance from the Office of Management and Budget notes that such data analysis could be part of an internal control program to prevent, detect, and recover overpayments.
section_title: What GAO Recommends
paragraphs: GAO recommends that State clearly document the use of Director Points for extreme conditions at posts; assess the cost-effectiveness of its policies and procedures for stopping and starting hardship pay for overseas employees; and analyze available data to identify, recover, and prevent improper payments related to hardship pay. State concurred with these recommendations.

section_title: Letter
paragraphs: The Department of State (State) provides a range of allowances to  compensate its employees for costs and hardships related to foreign  assignments at overseas posts, many of which are critical to U.S. foreign  policy objectives. State personnel working abroad may be eligible for  such allowances in locations where they encounter harsh or dangerous  living conditions. They also may be reimbursed for costs related to  working overseas, including the cost of living in locations more expensive  than Washington, D.C.; dependent education costs; and the costs of  relocating to a new post or maintaining family members away from a post.  Two allowances, in particular—hardship and danger pay—serve as key  incentives for State personnel to work at challenging overseas locations.  Hardship pay can provide additional compensation, up to 35 percent  above basic compensation, for service at places where conditions of  environment differ substantially from those in the continental United  States. For example, such locations might include overseas posts with  unhealthy levels of pollution, high crime, or limited access to medical  care. Danger pay can provide additional compensation, up to 35 percent  above basic compensation, for service at places where civil insurrection,  civil war, terrorism, or wartime conditions threaten physical harm or  imminent danger to the health or well-being of an employee. In 2015,  State announced changes to its process for determining which overseas  posts are eligible to receive hardship and danger pay and the rates for  these allowances. In the same year, State also expanded its efforts to  identify and recover overpayments related to hardship and danger pay.
You asked us to review issues related to State’s administration of  hardship and danger pay for its employees. This report examines (1)  State’s spending at overseas posts for hardship and danger pay in fiscal  years 2011-2016, (2) the extent to which State has followed its process  for determining hardship and danger pay rates at overseas posts, (3) the  procedures State uses to implement its policies for stopping and starting  hardship and danger pay when employees temporarily leave their  assigned overseas posts, and (4) the extent to which State has identified  improper payments related to hardship and danger pay.
To examine State’s spending at overseas posts for hardship and danger  pay in fiscal years 2011-2016, we analyzed payroll data from State’s  Bureau of the Comptroller and Global Financial Services (CGFS) after  determining it sufficiently reliable for the purposes of our reporting  objective. All spending data in this report are presented in nominal  dollars. We also interviewed CGFS officials. To determine the extent to  which State has followed its process for determining hardship and danger  pay rates at overseas posts, we compared State’s implementation of its  process for determining hardship and danger pay rates with its guidance.  For hardship pay, we analyzed scoring for 192 overseas posts to  determine whether the hardship rates for these posts accurately reflected  the numeric scores they received based on State’s analysis of conditions  at posts. For danger pay, we reviewed memos and other documents  approving changes to danger pay rates and analyzed these to determine  whether they followed State’s methodology. We also interviewed officials  from the Office of Allowances (ALS), CGFS, and the Bureaus of  Diplomatic Security (DS) and Human Resources (HR). To examine the  procedures State uses to implement its policies for stopping and starting  hardship and danger pay when employees temporarily leave their  assigned posts, we analyzed State policies and procedures and  interviewed ALS, CGFS, and HR officials. To determine the extent to  which State has identified improper payments related to hardship and  danger pay, we analyzed CGFS data on the amount of improper  payments identified and recovered for hardship and danger pay in 2015  and 2016. We also analyzed CGFS cable data from overseas posts in  2015 and 2016—cables that included information needed by CGFS to  make adjustments to hardship pay. To address multiple objectives, we  conducted a videoconference with officials at the U.S. embassy in Port- au-Prince, Haiti, and conducted fieldwork at U.S. embassies in  Islamabad, Pakistan; Mexico City, Mexico; New Delhi, India; and Tunis,  Tunisia. We selected these posts for fieldwork based on several factors,  including their hardship and danger pay rates, whether they were affected  by changes State made in 2015 to its process for determining hardship  and danger pay eligibility and rates, and to provide geographic dispersion.  See appendix I for additional information about our objectives, scope, and  methodology.
We conducted this performance audit from April 2016 through September  2017 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
subsections: section_title: State Provides Hardship and Danger Pay at Many of Its Overseas Posts
paragraphs: State provides hardship and danger pay to employees who serve at many  of its overseas posts as an incentive to work in harsh or dangerous  locations, many of which are critical to advancing U.S. foreign policy  objectives. As of February 5, 2017, State offered hardship pay at 188 of  its 273 overseas posts (about 69 percent), with hardship rates ranging  from 5 percent to 35 percent above basic compensation in 5-percent  increments (see fig. 1). For example, State employees serving at posts  such as Dhaka, Bangladesh; Kabul, Afghanistan; and Abuja, Nigeria,  were eligible for the maximum hardship rate of 35 percent above basic  compensation. State employees serving at posts such as Windhoek,  Namibia; Reykjavik, Iceland; and Vilnius, Lithuania, were eligible for the  minimum 5-percent hardship rate. State did not offer hardship pay at 85  of its 273 overseas posts (about 31 percent). According to State data,  about three-quarters of the department’s Foreign Service overseas work  force, as of September 30, 2016, was based at a post designated for  hardship pay.
As of February 5, 2017, State had provided danger pay at 25 of its 273  overseas posts (about 9 percent), with danger pay rates ranging from 15  percent to 35 percent above basic compensation, in 10-percent  increments (see fig. 2). State employees serving at posts such as  Baghdad, Iraq; Juba, South Sudan; and Islamabad, Pakistan, received  the maximum danger pay rate of 35 percent above basic compensation.  State employees serving at posts in Cairo, Egypt; Port-au-Prince, Haiti;  and Tunis, Tunisia, received the minimum danger pay rate of 15 percent  above basic compensation. State did not offer danger pay at 248 of its  273 overseas posts (about 91 percent). According to State data, about 15  percent of the department’s Foreign Service overseas work force, as of  September 30, 2016, was based at a post designated for danger pay.
At some posts, State employees are eligible to receive both hardship and  danger pay up to a maximum combined rate of 70 percent above basic  compensation. As of February 5, 2017, 21 overseas posts were eligible  for both allowances, and 6 posts were receiving the maximum 70 percent  combined rate for hardship and danger pay.
section_title: State Assessments in 2011 and 2015 Validated the Importance of Hardship and Danger Pay to Staffing Posts
paragraphs: State completed assessments in 2011 and 2015 that identified hardship  and danger pay as important factors in employees’ bidding decisions and  staffing for overseas posts. A 2011 evaluation found hardship and  danger pay to be the most important individual incentives in staffing  hardship posts. Specifically, the 2011 evaluation stated that an increase  in either incentive would have a positive impact on bidding and staffing,  whereas a decrease would have a negative impact. A survey component  of the evaluation concluded that hardship and danger pay were among  the top three most important individual incentives, among 52 different  incentives, for employees at most career stages and types of family  status to take into consideration when bidding on hardship posts. Another  component of the evaluation, which analyzed the relationship between  spending on financial incentives and success in staffing hardship posts,  determined that, among 10 financial incentives, hardship and danger pay  had the strongest influence on filling positions, including hard-to-fill  positions. In 2015, State reconfirmed these findings as part of a study to  determine which incentives were viewed as most influential in the  recruitment of Foreign Service officers to Priority Staffing Posts. As part  of this study, State employees identified hardship and danger pay as  among the top 4 out of 16 incentives that would influence them to bid on  Priority Staffing Posts. During our fieldwork, we held roundtable  discussions with staff across various offices from five overseas posts, and  most employees confirmed that hardship and danger pay remained  important incentives for making bidding decisions.
section_title: Various State Entities Help Administer Hardship and Danger Pay
paragraphs: Several State entities play roles in the administration of hardship and  danger pay.
ALS develops and coordinates policies, regulations, standards, and  procedures to administer hardship and danger pay, among other  allowances, under the Department of State Standardized Regulations  (DSSR). In particular, ALS is responsible for implementing processes  to determine which overseas posts will be eligible to receive hardship  and danger pay and the rates for these allowances. For example, ALS  analyzes information on conditions at overseas posts to determine  appropriate hardship pay rates. The Director of ALS also chairs the  Danger Pay Review Board, which makes recommendations to the  Assistant Secretary for Administration concerning overseas posts  proposed for danger pay.
CGFS processes hardship and danger pay for State employees  through State’s payroll system and oversees the identification and  recovery of overpayments for these and other allowances when they  occur.
State offices at overseas posts serve various functions related to  hardship and danger pay. They provide information to ALS through  periodic hardship questionnaires that inform hardship pay  determinations and may provide information to the Danger Pay  Review Board through their regional bureaus requesting changes to  danger pay outside of the annual review cycle. These offices also  administer systems and procedures at posts to facilitate the  processing of hardship and danger pay and to ensure compliance with  State’s rules on employee eligibility for these allowances. For  example, overseas posts manage the time and attendance process,  which State uses to record danger pay hours for permanently  assigned employees. Overseas posts are also responsible for  notifying CGFS when employees temporarily depart and return to  posts so that CGFS can stop and start hardship pay in accordance  with State’s policy.
The Bureau of Diplomatic Security’s Office of Intelligence and  Threat Analysis generates annual Security Environment Threat List  (SETL) ratings for overseas posts—such as for political violence,  terrorism, and crime—which play a role in determining danger pay  eligibility and hardship pay rates.
State’s Undersecretary for Management determines whether  eligible family members are allowed at overseas posts (i.e.,  “accompanied status”), which is the primary factor in determining the  rates above basic compensation that employees are paid at posts that  State deems eligible for danger pay. When determining “accompanied  status,” State considers factors that could impact a post’s operations;  movement; and the health, safety, and security of a post’s facilities  and its personnel.
section_title: State Spent About $1 Billion for Hardship and Danger Pay in Fiscal Years 2011- 2016
subsections: section_title: State Spent About $732 Million for Hardship Pay and $266 Million for Danger Pay during Fiscal Years 2011-2016
paragraphs: State spent about $1 billion for hardship and danger pay in fiscal years  2011 through 2016, including $732 million for State employees serving in  locations designated for hardship pay and $266 million for employees  serving in locations designated for danger pay. As shown in figure 3,  spending on danger pay declined from about $49 million to $33 million  over this period, whereas spending on hardship pay increased from about  $122 million to $128 million. Combined spending for the two allowances  declined by about $10 million in fiscal years 2011 through 2016, primarily  because of reduced spending on these allowances in Iraq and  Afghanistan. Specifically, spending on hardship and danger pay in Iraq  and Afghanistan declined by almost $28 million in fiscal years 2011  through 2016, whereas spending on these allowances at all other posts  increased by about $17 million over this period.
section_title: State’s Worldwide Spending on Hardship and Danger Pay in Fiscal Years 2011-2016 Varied by Country
paragraphs: State’s global spending for hardship and danger pay in fiscal years 2011  through 2016 varied, depending on the allowance rates and staffing levels  at posts in a given country. For example, in fiscal year 2016, State spent  about the same amount on hardship pay in Dhaka, Bangladesh  ($1,348,242), a post eligible for hardship pay at 35 percent above basic  compensation, as it did in Bangkok, Thailand ($1,328,286), a post eligible  for hardship pay at 10 percent above basic compensation, because State  has almost three times as many personnel assigned to Thailand (132  Foreign Service officers) as it has to Bangladesh (47 Foreign Service  officers). Figure 4 shows State’s worldwide spending for hardship pay in  fiscal years 2011 through 2016.
As illustrated in figure 5, countries with danger pay spending in fiscal  years 2011 through 2016 are largely concentrated in the Middle East and  Africa. Several countries with danger pay spending during this period— including Mexico, Colombia, and Saudi Arabia—were no longer eligible  for danger pay, as of February 5, 2017.
An interactive graphic accompanying this report illustrates hardship and  danger pay spending by country and fiscal year and provides information  on hardship and danger pay rates and numbers of Foreign Service  officers by overseas post for fiscal year 2016.
section_title: Afghanistan and Iraq Were the Top Two Countries for State Spending on Hardship and Danger Pay in Fiscal Years 2011-2016
paragraphs: Afghanistan and Iraq were the top two countries for State’s spending on  both hardship and danger pay in fiscal years 2011 through 2016 and  accounted for a substantial portion of State’s spending on these two  allowances. As shown in figure 6, State spent about $138 million on  hardship pay in Afghanistan and Iraq in fiscal years 2011 through 2016— about 19 percent of its total spending on hardship pay. State spent about  $125 million on danger pay in these two countries over the same period,  almost half of its worldwide danger pay spending. Posts in Afghanistan  and Iraq are among the largest in the world, and all have hardship and  danger pay rates of 30 or 35 percent.
section_title: State Mostly Followed Its Process for Determining Hardship Pay Rates and Followed Its Process for Determining Danger Pay Rates
paragraphs: In most cases, State followed its process for determining hardship pay  rates by analyzing survey responses and other data on living conditions  at overseas posts. However, in a few cases, State awarded “Director  Points”—additional points awarded at the discretion of the Director of  State’s Office of Allowances (ALS)—to increase hardship pay without  clearly explaining in its documentation how posts met relevant criteria.  For danger pay, State followed its process of determining rates based on  political violence and terrorism threat ratings and whether family members  are allowed at overseas posts.
subsections: section_title: State Mostly Followed Its Process for Determining Hardship Pay Rates at Overseas Posts but in a Few Cases Awarded Director Points without Adequately Explaining How Posts Met Relevant Criteria
subsections: section_title: State Mostly Followed Its Process for Determining Hardship Pay Rates at Overseas Posts
paragraphs: ALS determines hardship pay rates through a process of analyzing  factors affecting living conditions at overseas posts such as physical and  social isolation, crime, air pollution, and medical care. ALS collects  information on these factors based on periodic surveys of overseas posts  and data from State offices and other sources. ALS employees evaluate  this information against written standards and assign points for each  factor. For example, a post with unhealthy levels of air pollution would  receive more points for this factor than a post with good air quality. ALS  sums the points assigned to individual factors to calculate a total numeric  score for each post, and specified ranges of scores correspond to  hardship pay rates ranging from 0 to 35 percent above basic  compensation. For example, under State’s system, posts with scores  under 50 do not receive hardship pay, whereas posts with scores of 150  or higher are eligible for the maximum hardship pay rate of 35 percent  above basic compensation. Table 1 shows the factors that contribute to a  post’s hardship score and the percent of the total score accounted for by  each category of factors.
Specifically, ALS develops the hardship scores as follows:
ALS bases about half of a post’s score on its analysis of the post’s  responses to a survey. Among other things, the survey includes  questions about the physical isolation of the post, level of community  resources, environmental conditions and sanitation, and the incidence  of certain diseases. Multiple offices at post contribute to the survey  responses, and posts may include supporting documentation such as  photos or orientation materials provided to newly arriving employees.
ALS determines the other half of a post’s score based on its analysis  of data collected from State offices. For example, ALS obtains  information on levels of crime at overseas posts from DS, medical  services capabilities from the Office of Medical Services, and  education facilities from the Office of Overseas Schools.
The Director of ALS reviews a post’s score as determined by ALS and  can add additional Director Points if she deems that there are extreme  conditions at the post not adequately captured in State’s written  standards.
ALS normally scores and updates hardship rates for each post every 4  years. According to ALS officials, overseas posts remain free to submit  new surveys outside of the normal 4-year cycle if warranted by significant  changes to the living conditions at a post. For example, ALS officials said  that Embassy Caracas submitted an out-of-cycle hardship survey in  October 2015 because of rapidly deteriorating conditions in Venezuela.  Based on this new information, ALS calculated a new score for Embassy  Caracas and approved a 5-percentage point increase in its hardship rate,  from 20 percent to 25 percent.
section_title: State Awarded Director Points in a Few Cases without Adequately Documenting How Posts Met Relevant Criteria
paragraphs: State mostly followed its process for determining hardship pay rates for  overseas posts but in a few cases awarded Director Points without  adequately explaining in its documentation how the conditions at posts  met relevant criteria. We reviewed ALS scoring for 192 overseas posts as  of October 2016 and determined that the hardship rates for these posts  accurately reflected the scores they received based on State’s analysis of  the conditions at these posts. For 15 of these posts, State awarded  additional Director Points ranging from 2 to 12 points, which in each case  enabled the posts to reach the scoring threshold for the next-highest  hardship rate. That is, State approved hardship rates for these posts that  were 5 percent higher than the rate they would have received in the  absence of Director Points. State policies note that Director Points may  be awarded for extreme conditions not adequately captured in State’s  written standards. For each of the 15 posts, State documented its  decision to award Director Points in a memo approved by the Director of  ALS. We reviewed the 15 memos and found the following:
Three of the 15 memos clearly documented how the posts met  State’s criteria for awarding Director Points. Specifically, these  memos noted that the three posts submitted hardship surveys shortly  before State’s revised standards and scoring system took effect in  2015, and State awarded these three posts Director Points to  compensate for extreme living conditions that would have received  additional credit under the updated methodology.
Twelve of the 15 memos did not clearly document how the posts  met State’s criteria for awarding Director Points. All 12 memos  cited conditions that are already factored into State’s hardship  standards and scoring system, such as high crime, social isolation, or  a difficult climate. Additionally, some of these memos cited conditions  that did not meet State’s criteria for awarding Director Points. For  example, some cited concerns at posts over losing danger pay as part  of the justification, and one cited, among other things, a desire to keep  the post at its previous hardship pay rate—in part to preserve its  eligibility for additional “rest and recuperation” leave, which was  contingent upon its being designated as a hardship post.
The current ALS Director was unsure why Director Points were approved  in the cases we identified as lacking clear explanations for how conditions  at the specified posts met State’s criteria. These cases predated her  tenure as Director of ALS and, as of June 6, 2017, she had not approved  Director Points for any posts since she assumed her position in the  summer of 2016. She noted that Director Points may have been used  more liberally in 2015 to ease the transition for posts concerned about  losing danger pay, but she underscored that the updates State made to  its hardship standards and scoring system in 2015 should lessen the  need to use Director Points because the new standards better reflect the  type and severity of conditions at overseas posts. Accordingly, the ALS  Director noted that State plans to limit the use of Director Points going  forward so as not to “tip the scales” for specific posts, although there still  may be extenuating circumstances that justify their use. Moreover, she  added that in the instances when Director Points are justified, ALS would  need to clearly show how the conditions justifying Director Points are not  already captured in State’s hardship standards.
State’s Foreign Affairs Manual (FAM) states that employees, within their  area of responsibility, must create and preserve documents that properly  and adequately document the organization, functions, policies, decisions,  procedures, and essential transactions of the department. Furthermore,  the FAM provision on adequacy of documentation states that records  should be complete to the extent necessary to facilitate the making of  decisions and policies and the taking of action by the incumbents and  their successors in office. Although State has used memos to document  its decisions to award Director Points, in some cases these memos do not  clearly explain how the conditions at posts met State’s criteria. Without  clearer documentation, State does not have information that is clear  enough to facilitate the making of decisions and policies by incumbent  and successors of the office of the ALS Director. Furthermore, State  cannot provide assurances that it is applying Director Points fairly across  posts and tenures of ALS Directors, which could lead to inconsistent  hardship pay determinations.
section_title: State Followed Its Process for Determining Danger Pay Rates at Overseas Posts
paragraphs: We found that State followed the new process it implemented in 2015 for  determining danger pay rates at overseas posts. To determine danger  pay rates at overseas posts, State uses a two-part process that bases  danger pay eligibility on threat ratings for political violence and terrorism  at posts and danger pay rates on whether eligible family members are  allowed at posts (see fig. 7).
Following its policies, State determines eligibility for danger pay based on  SETL ratings for (1) political violence and (2) terrorism at posts, which  are generated by the DS Office of Intelligence and Threat Analysis.  Overseas posts with a critical threat rating in either of these categories  are eligible for danger pay. DS generates SETL ratings annually,  reflecting threat levels for all overseas posts permanently staffed by direct  hire personnel who operate under the Chief of Mission. SETL ratings  reflect the views of the leadership team at each post as well as the  analysts at DS who assess threats to overseas posts worldwide. Political  violence ratings incorporate the threat to U.S. officials from civil unrest,  government collapse, demonstrations, coups d’état, and inter- or  intrastate conflicts, to include, but not limited to, armed insurgents and  drug trafficking organizations. Terrorism ratings consider the threat of  violence from foreign terrorist organizations and other international  terrorist groups that possess the capability and intent to recruit, plan,  finance, and execute local attacks against official U.S. interests. For posts  that meet eligibility criteria, State determines danger pay rates based on  the “accompanied status” at overseas posts—that is, whether eligible  family members are allowed to reside at posts. The three tiers of danger  pay (15, 25, and 35 percent above basic compensation) correspond to  different types of accompanied status. Fully accompanied posts receive  the lowest danger pay rate of 15 percent above basic compensation.  Partially accompanied posts receive a 25-percent danger pay rate.  Unaccompanied posts and posts that allow only adult working-eligible  family members are entitled to the highest danger pay rate of 35 percent.
The Danger Pay Review Board evaluates danger pay rates as part of an  annual review cycle and on an ad hoc basis for event-driven reasons. The  board meets each fall to reevaluate danger pay following DS’s release of  new SETL ratings and recommends posts to add or delete from the  danger pay list. Regional bureaus may also request danger pay for posts  outside of the annual cycle for event-driven reasons—for example, if  political unrest leads to the evacuation of family members from a post.  These requests must specify the conditions at the location that meet the  qualifying factors in the danger pay statute and regulations. Additionally,  regional bureaus may request danger pay for locations other than  established overseas posts where employees from State or other eligible  agencies operate. Because these locations do not have SETL ratings, the  Danger Pay Review Board evaluates these requests and makes its  recommendations based on the specific conditions at these locations.  The board generally makes recommendations regarding requests for  danger pay at these other locations in conjunction with its annual review.
State implemented its current process for determining danger pay rates in  April 2015—the result of its first review of its processes for determining  danger pay rates at overseas posts since the 1980s. Prior to these  changes, ALS scored posts and determined danger pay rates based on  responses to a danger pay survey completed periodically by posts, similar  to the process now used to determine hardship pay. State’s review  identified some inconsistencies between the conditions at posts receiving  danger pay and the qualifying factors cited in the authorizing statute and  regulations. For example, some posts were receiving danger pay  primarily because of high crime rates even though danger pay regulations  stipulate that the qualifying conditions for danger pay do not include acts  characterized chiefly as economic crime. State’s review also determined  that the survey-based scoring process was largely duplicative with the  SETL process led by DS and, moreover, that DS possessed greater  expertise than ALS for assessing the threats at overseas posts and  ensuring consistency in threat ratings across posts. According to State  officials, the new process for determining danger pay rates ensures  greater transparency, consistency, and fairness.
In 2015, State completed its first annual review of danger pay under the  new process by assessing whether overseas posts had qualifying SETL  ratings and then determining rates based on the accompanied status of  these posts. As a result, 34 overseas posts and other locations lost  danger pay, 7 received danger pay that previously had not been eligible  for it, and 15 experienced increases in their danger pay rates.
In conjunction with its implementation of the new process for determining  danger pay rates, State adjusted hardship pay rates for affected posts by  adding or subtracting credit for political violence and terrorism—factors  that help determine rates for both allowances. Credit for these factors  must be removed from hardship pay when a post receives danger pay to  avoid duplication of benefits for the same condition. Removing this credit  from the hardship scoring usually results in a decrease in the hardship  pay rate. Conversely, credit for these factors is added back into hardship  pay when a post loses danger pay, commonly resulting in an increase in  the hardship pay rate. As a result of these adjustments, most of the posts  that lost danger pay (27 of the 34) experienced an increase in hardship  pay that offset some or all of their loss in danger pay. For example, six  posts in Mexico lost danger pay under the new process because they  lacked qualifying SETL ratings. However, all six received increases in  hardship pay, which partially or fully offset the loss of danger pay.  Correspondingly, six of the seven posts that became newly eligible for  danger pay experienced partially offsetting reductions in hardship pay. In  November 2016, State conducted its second annual danger pay review  cycle under the new process. Four posts subsequently lost danger pay  because they no longer had qualifying SETL ratings, and three posts or  other locations either received danger pay or were awarded a higher rate  of danger pay.
Consistent with its prescribed process for determining rates, as of June 6,  2017, State had also approved three requests for danger pay outside of  the annual review cycle because of changes in conditions at posts.  Specifically, in January 2016, State approved 35-percent danger pay for  Bujumbura, Burundi, because of increasing political violence that led to a  partial evacuation of the post. Danger pay for Bujumbura was later  renewed in November 2016 as part of the regular review cycle based on  a qualifying SETL rating. Additionally, in March 2016, State approved  danger pay for several posts in Turkey because of increasing terrorist  attacks and a growing threat of political violence. Lastly, in June 2016,  State approved danger pay for Bamako, Mali, because of increasing  terrorist threats. State also has adjusted danger pay for one post because its accompanied status changed outside of the annual review cycle. In  May 2016, State reduced the danger pay rate for Tunis, Tunisia, from 25  percent to 15 percent when the post’s accompanied status changed from  partially accompanied to fully accompanied.
section_title: State’s Procedures to Implement Its Policies for Stopping and Starting Hardship Pay Are Resource Intensive, but State Has Not Assessed Their Cost- Effectiveness; State’s Procedures for Danger Pay Are Mostly Automated
paragraphs: State’s policies for stopping and starting hardship pay when employees  temporarily leave their assigned overseas posts depend on a variety of  factors such as the travel destination, purpose of travel, and assigned  post. To implement these policies, overseas posts must send diplomatic  cables instructing CGFS to manually adjust hardship pay for employees.  State officials said that these procedures are resource intensive, requiring  more than 10,000 manual adjustments to employee pay in both 2015 and  2016. Moreover, CGFS officials said that State’s policies and procedures  contribute to improper payments related to hardship pay, which are costly  to recover. However, State has not assessed the cost-effectiveness of its  policies and procedures for stopping and starting hardship pay in  accordance with its Foreign Affairs Manual, which requires that all  managers establish and review cost-effective policies and procedures to  ensure that U.S. government activities are managed effectively,  efficiently, and economically. State’s policies for stopping and starting  danger pay are based on a single factor—whether or not permanently  assigned employees are present at their assigned posts—and State’s  procedures for implementing these policies are mostly automated through  its time and attendance system.
subsections: section_title: State’s Policies for Stopping and Starting Hardship Pay Depend on a Range of Factors
paragraphs: State’s policies for stopping and starting hardship pay when an employee  temporarily leaves his post are based on a range of factors, including the  employee’s travel destination, sequencing of travel, purpose of travel,  assigned post, and whether family members remain at post, among other  things. State has made multiple modifications and added exceptions to  the policies since introducing them in 1953; the current policies reflect  these revisions.
Travel destination and assigned posts affect hardship pay.
According to State’s policy, generally employees who are temporarily  absent from a hardship post in a location other than the United States  retain hardship pay for up to 42 days. However, if they take leave in  the United States, they generally lose hardship pay on the day their  travel starts, unless specific exceptions apply, such as when an  eligible family member remains at the post and the primary purpose of  the travel is for detail or medical evacuation.
Sequencing of travel destinations affects hardship pay. According  to State’s policy, employees at a hardship post who take leave in a  foreign location en route to the United States lose hardship pay when  they arrive in the United States. However, if employees travel directly  from a hardship post to the United States and take leave in a foreign  location en route back to their post, they lose hardship pay at close of  business the day they leave the post.
The purpose of travel and whether employees have eligible  family members that remain at a hardship post affects hardship  pay during travel to the United States. According to State’s policy,  employees who do not have eligible family members at their hardship  post and are in the United States for a detail or medical evacuation  would lose hardship pay for the duration of their absence. However,  if employees do have eligible family members who remain at the post,  they would continue to earn hardship pay for up to 42 consecutive  days.
Figure 8 is an illustrative flowchart that summarizes State’s policies for  stopping and starting hardship pay when an employee is away from her  permanently assigned post, based on our analysis of State documents  and interviews with State officials.
section_title: State Uses Diplomatic Cables to Manually Stop and Start Hardship Pay in Accordance with Its Policies
paragraphs: To implement State’s policies for stopping and starting hardship pay for  employees who temporarily leave their assigned overseas posts, officials  at posts must use diplomatic cables to instruct CGFS to manually adjust  hardship pay. For State employees permanently assigned to a hardship  post, CGFS must suspend and reinstate hardship pay when an employee  is temporarily absent from a post—particularly during trips to the United  States that do not meet one of the exceptions noted in State’s policies.  Overseas posts are responsible for tracking employee arrivals and  departures and sending diplomatic cables to CGFS with this information  so that CGFS can process changes to hardship pay. To adhere to State’s  policy, these cables should include information about employees’ travel  dates, the purpose of their travel, and the status of any dependents.  Overseas posts we visited had developed different policies and  procedures for tracking employee travel to the United States and  reporting this travel to CGFS. For example, at Embassy Tunis, the  Human Resources Office is responsible for sending diplomatic cables to  CGFS and requires employees to fill out a form with relevant information  needed for the cables whenever they travel to and return from the United  States. For each diplomatic cable, CGFS determines how the travel will  impact hardship pay and manually adjusts the allowance in the payroll  system for the employee. When the employee returns to the post, the  post must send a similar diplomatic cable to CGFS with instructions to  reinstate hardship pay, and CGFS again manually adjusts the employee’s  pay.
section_title: State’s Procedures to Implement Its Hardship Pay Policies Are Resource Intensive and Contribute to Improper Payments
paragraphs: According to State officials, the procedures it uses to stop and start  hardship pay when employees temporarily leave their post, in accordance  with its policies, are resource intensive and contribute to improper  payments. For example, administering hardship pay policies involves a  large volume of diplomatic cables, which CGFS officials noted are costly  for them to process. According to CGFS data, overseas posts sent  diplomatic cables requiring CGFS to make more than 10,000 manual  adjustments to temporarily stop and start employees’ hardship pay in both  2015 and 2016. CGFS officials also pointed to untimely diplomatic cables  as a primary cause of overpayments related to hardship pay, which are  costly to recover. Various officials at the posts we visited also described  the resources involved in managing, maintaining, and enforcing the  policies for hardship pay. For example, at Embassy Mexico City, several  steps are required to stop and start hardship pay. First, an employee  must fill out an electronic leave request including information about  whether he is traveling to the United States, the purpose of the U.S.  travel, and whether any eligible family members will remain at the post.  Second, timekeepers must notify the Financial Management Office of the  employee’s travel to the United States through a travel log that they  update based on the electronic leave requests. Finally, the financial  specialist sends the diplomatic cable to CGFS. In 2015 and 2016,  according to CGFS data, posts in Mexico sent cables to CGFS that  prompted almost 2,800 actions to temporarily turn on or off hardship pay  for employees. The financial specialist in the Financial Management  Office explained that she spent about an hour each morning checking the  travel log and sending diplomatic cables to CGFS.
section_title: State Has Not Assessed the Cost-Effectiveness of Its Policies and Procedures for Stopping and Starting Hardship Pay
paragraphs: State has not assessed the cost-effectiveness of its policies and  procedures for stopping and starting hardship pay, which were  established decades ago. State’s FAM requires that all managers  establish and review cost-effective policies and procedures to ensure that  U.S. government activities are managed effectively, efficiently, and  economically. According to State officials, State has not assessed the  cost-effectiveness of its policies and procedures for stopping and starting  hardship pay because State has not directed such an assessment. CGFS  officials and other State officials we interviewed during our overseas  fieldwork noted that it might be more cost-effective to apply a flat hardship  pay rate over an employee’s entire overseas assignment rather than  adjust hardship pay each time an employee temporarily leaves and  returns to her post. Officials also suggested that State could improve the  administration of hardship pay by adopting simpler policies that base  hardship pay solely on whether employees are present at their overseas  posts. Without reviewing the cost-effectiveness of its policies and  procedures, State does not know the extent to which they are effective,  efficient, and economical.
section_title: State Uses Its Time and Attendance System to Automatically Stop and Start Danger Pay
paragraphs: State uses its time and attendance system to automatically stop and start  danger pay when a permanently assigned employee temporarily leaves  his post, based on policies that depend solely on whether the employee is  present at the post. The policies to stop and start danger pay specify that  employees are eligible for danger pay when present at a danger pay post  and ineligible for danger pay when not present at a danger pay post.  These policies have mostly remained constant since danger pay was  authorized in the Foreign Service Act of 1980. Unlike with hardship pay,  the policies list no exceptions based on the assigned post, purpose of  travel, destination, whether eligible family members remain at the post, or  any other factors. To implement these policies, timekeepers at overseas  posts record danger pay hours for employees assigned to their posts and  submit these hours to CGFS through State’s time and attendance system.  CGFS then processes danger pay for these employees automatically  according to the hours recorded in the system.
section_title: State Identified $2.9 Million in Improper Payments Related to Hardship and Danger Pay but Has Not Analyzed Data That Could Identify More
paragraphs: CGFS identified a total of about $2.9 million in improper payments for  hardship and danger pay in fiscal years 2015 and 2016, including about  $2.8 million for hardship pay and nearly $67 thousand for danger pay  (see table 2). These improper payments accounted for about 30 percent  of the $9.6 million in improper payments that CGFS identified related to  compensation for U.S. employees in 2015 and 2016. CGFS identified  almost twice the amount of improper payments for hardship pay in fiscal  year 2015 as it did in 2016. According to CGFS officials, the amount of  improper payments it identified declined in 2016 because the bureau  made progress working through a backlog of diplomatic cables from  overseas posts and instituted new work processes that helped to reduce  improper payments. As of March 2017, CGFS had recovered almost $2.7  million, or about 92 percent, of the improper payments it identified in 2015  and 2016 related to hardship and danger pay. According to CGFS  officials, the bureau was continuing efforts to recover the remaining 8  percent.
CGFS officials cited late notification of employee arrivals and departures  from overseas posts as the main cause of improper payments related to  hardship and danger pay. For employees assigned to hardship posts,  State’s policy specifies that hardship pay must be suspended upon travel  to the United States, with some exceptions. To implement these rules,  overseas posts must send diplomatic cables to CGFS with instructions to  suspend and reinstate hardship pay for their employees. According to  CGFS officials, improper payments may occur when CGFS processes  hardship pay cables for dates outside of the current pay period because a  cable arrived after the end of a pay period or CGFS was unable to  process the cable during the pay period when it arrived. For danger pay,  which is recorded in conjunction with the time and attendance process at  overseas posts, CGFS officials said that they primarily identify  overpayments when they receive timesheet corrections from posts  involving danger pay after danger pay has been processed for a given  pay period.
While CGFS has identified about $2.9 million in improper payments  related to hardship and danger pay as part of its regular pay processing  activities, according to CGFS officials, it has not identified any additional  improper payments through recovery audits, which are generally required  by the Improper Payments Elimination and Recovery Act of 2010  (IPERA). IPERA requires these audits, if they are not prohibited under  any other provision of law, if it is a program and activity of the agency that  expends $1 million or more annually and if conducting such audits would  be cost-effective. The Office of Management and Budget and State refer  to these recovery audits as “payment recapture audits.” A recapture audit  is a review and analysis of accounting and financial records, supporting  documentation, and other information supporting payments that is  specifically designed to identify overpayments. CGFS identified U.S.  employee compensation, including hardship and danger pay, as one of  the State programs that meet these criteria and expanded its recapture  audit activities in fiscal year 2015 to cover this area. For example, CGFS  has reviewed instances where hardship pay was paid to employees  assigned to a domestic location. However, according to CGFS officials,  as of March 2017, it had not found any additional overpayments related  specifically to hardship and danger pay through these recapture audit  efforts. They explained that recapture audit efforts for U.S. employee  compensation are in their initial phases, and they plan to expand them in  the future.
We found that CGFS had not analyzed available data that could help to  identify hardship posts at risk of overpayments and thereby aid in  recapture audit and improper payment prevention efforts. In 2015, CGFS  began collecting data on types of diplomatic cables from overseas posts  that include requests for hardship pay to be suspended or reinstated for  employees. According to CGFS officials, CGFS initiated this data  collection effort in order to reduce improper payments by better managing  workloads and prioritizing cases in which hardship pay needed to be  suspended before CGFS processed pay. CGFS officials emphasized that  they did not originally intend for the data to be used to facilitate recapture  audits. CGFS officials agreed, however, that analyzing patterns in the  data could help identify posts more likely to be out of compliance with the  rules for hardship pay and therefore at higher risk for improper payments.  For example, the diplomatic cable data could help identify anomalies such  as posts that have fewer than expected requests for suspensions and  reinstatements of hardship pay relative to the size of their workforce or  proximity to the United States. Once CGFS has identified these  anomalous posts, the posts would be able to use other data, such as  information from travel management systems, to identify and recover any  overpayments and could develop systems to prevent future improper  payments. For example, one post we visited conducted an internal audit  of employee travel and identified 18 instances over 8 months when the  post did not send diplomatic cables to CGFS to suspend hardship pay.  The post later sent cables to CGFS with this information so that CGFS  could recover the associated overpayments. The post also developed a  standard operating procedure to improve compliance with the policies for  hardship pay and prevent similar overpayments related to hardship pay  going forward.
We independently analyzed the diplomatic cable data by post and  identified several anomalies. For example, we identified nine countries— accounting for a total of about $2 million in hardship pay spending in fiscal  years 2015 and 2016—that did not send either suspension or  reinstatement cables to CGFS to request adjustments to hardship pay  during this time period. CGFS officials confirmed that the lack of  diplomatic cables was a possible indication that these posts were not  following State’s rules for hardship pay. Additionally, we identified some  overseas posts located in the same region of the world and with similar  Foreign Service staffing levels that generated substantially different  numbers of diplomatic cable requests to suspend and reinstate hardship  pay. For example, the data indicate that—among two neighboring posts in  Southeast Asia with similar Foreign Service officer staffing levels—one  post sent a total of 235 diplomatic cable requests to suspend and  reinstate hardship pay in fiscal years 2015 and 2016, whereas the other  post sent 39. State spent a total of about $3.5 million on hardship pay in  each of these countries in fiscal years 2015 and 2016.
Data analytics involves a variety of techniques to analyze and interpret  data to facilitate decision making and may be used to identify patterns or  trends, determine whether problems are widespread and systemic in  nature, and evaluate program performance outcomes. Guidance from the  Office of Management and Budget notes that such techniques could be  part of an internal control program to prevent, detect, and recover  overpayments. Moreover, a forum we convened in September 2016 to  advance the intergovernmental dialogue on implementing data analytics  to prevent and detect improper payments highlighted the importance of  agencies inventorying existing data sources and considering how they  could be used to identify improper payments. By not analyzing the  available diplomatic cable data, CGFS may be missing an opportunity to  identify, recover, and prevent additional overpayments of hardship pay as  part of its recapture audits.
section_title: Conclusions
paragraphs: Advancing U.S. foreign policy objectives throughout the world requires  State employees to serve at overseas locations where conditions may be  harsh or dangerous. Hardship and danger pay are important incentives  for State employees to work at these challenging locations. Although  State mostly followed the new processes it established in 2015 for  determining hardship and danger pay rates and locations, in a few cases  it awarded Director Points that increased hardship pay for posts without  clearly explaining in its documentation how the conditions at these posts  met State’s criteria. Without clearer documentation, State cannot provide  assurances that it is applying Director Points consistently across posts  and tenures of ALS Directors, potentially leading to increased spending  on hardship pay not otherwise justified under State’s current process for  determining rates. Moreover, State has not assessed the cost- effectiveness of its policies and procedures for stopping and starting  hardship pay when employees temporarily leave their overseas posts.  State officials noted that these policies and procedures are resource  intensive to implement and contribute to improper payments, which are  costly to recover. Without reviewing the cost-effectiveness of these  policies and procedures, State does not know whether they are effective,  efficient, and economical. Finally, by not analyzing available data  compiled by CGFS, State may be missing an opportunity to identify,  recover, and prevent improper payments related to hardship pay with the  potential to produce cost savings for the U.S. government. Our  independent analysis of State data identified overseas posts accounting  for millions of dollars in hardship spending in fiscal years 2015 and 2016  that may be at high risk for improper payments.
section_title: Recommendations for Executive Action
paragraphs: We are making the following three recommendations to State:
The Director of ALS should clearly document how the conditions at  relevant posts meet the criteria for Director Points to ensure that  hardship pay rates for overseas posts are consistently determined  across posts and tenures of ALS Directors. (Recommendation 1)
The Undersecretary of Management should assess the cost- effectiveness of State’s policies and procedures for stopping and  starting hardship pay for employees who temporarily leave their  assigned overseas posts. (Recommendation 2)
The Department’s Comptroller should analyze available diplomatic  cable data from overseas posts to identify posts at risk of improper  payments for hardship pay, identify any improper payments, and take  steps to recover and prevent them. (Recommendation 3)
section_title: Agency Comments
paragraphs: We provided a draft of this report to State for comment. In its comments,  reproduced in appendix II, State concurred with all three  recommendations. State also provided a technical comment, which we  incorporated.
We are sending copies of this report to the appropriate congressional  committees and the Secretary of State. In addition, the report will be  available at no charge on the GAO website at http://www.gao.gov.
If you or your staff members have any questions about this report, please  contact me at (202) 512-8980 or courtsm@gao.gov. Contact points for  our Offices of Congressional Relations and Public Affairs may be found  on the last page of this report. GAO staff who made contributions to this  report are listed in appendix III.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: The objectives of this review were to examine (1) the Department of  State’s (State) spending at overseas posts for hardship and danger pay in  fiscal years 2011-2016, (2) the extent to which State has followed its  process for determining hardship and danger pay rates at overseas posts,  (3) the procedures State uses to implement its policies for stopping and  starting hardship and danger pay when employees temporarily leave their  assigned overseas posts, and (4) the extent to which State has identified  improper payments related to hardship and danger pay.
To examine State’s spending at overseas posts for hardship and danger  pay, we analyzed data in fiscal years 2011 to 2016 from State’s  Consolidated American Payroll Processing System, which is administered  by the Bureau of the Comptroller and Global Financial Services (CGFS).  Because hardship and danger pay are processed through payroll, CGFS  provided us with spending data for the 26 pay periods that best  approximated each fiscal year from 2011 to 2016, and we used these  data to summarize spending by fiscal year. All spending data in this report  are presented in nominal dollars. We also used the gross domestic  product price index to analyze trends in hardship and danger pay,  expressed in terms of constant (inflation-adjusted) dollars. To assess the  reliability of the data that State provided, we performed testing to identify  missing data, outliers, and errors; and interviewed CGFS officials. We  determined that the data we used were sufficiently reliable for the  purposes of summarizing spending for hardship and danger pay by fiscal  year and country.
To determine the extent to which State has followed its process for  determining hardship and danger pay rates at overseas posts, we  analyzed data from State’s Office of Allowances (ALS) on its hardship  scoring for overseas posts and hardship and danger pay rates by post.  We reviewed State’s policies and standards for hardship and danger pay  in the Department of State Standardized Regulations (DSSR), standard  operating procedures, and hardship pay survey and scoring system. We  also reviewed other documents that inform hardship and danger pay  rates, including Security Environment Threat List ratings and reports on  the operating status of overseas posts. We compared State’s  implementation of its process for determining hardship and danger pay  rates with its guidance. For hardship pay, we analyzed ALS scoring for  192 overseas posts as of October 2016 to determine whether the  hardship rates for these posts accurately reflected the scores they  received based on the ALS analysis of conditions at these posts. For the  15 posts for which ALS awarded Director Points, we reviewed the memos  approving Director Points to determine whether State adequately  documented how these posts met State’s criteria. For danger pay, we  reviewed memos and other documents approving changes to danger pay  rates and analyzed these to determine whether they followed State’s  methodology. We interviewed officials from various State offices,  including ALS, CGFS, and the Bureaus of Diplomatic Security (DS) and  Human Resources (HR). We also interviewed officials from the American  Foreign Service Association to obtain their views on hardship and danger  pay. To understand how State applies its processes for determining  hardship and danger pay in specific locations, we conducted a  videoconference with officials at the U.S. embassy in Port-au-Prince,  Haiti, and completed fieldwork at U.S. embassies in Islamabad, Pakistan;  Mexico City, Mexico; New Delhi, India; and Tunis, Tunisia. We selected  these posts for site visits based on various criteria, including their  hardship and danger pay rates, Foreign Service staffing levels, whether  they gained or lost hardship or danger pay because of the changes State  made to its process in 2015, and whether they had experienced issues  with improper payments related to these allowances. We also selected  posts for site visits to provide broad geographic representation and to  include an overseas post designated by State as a Priority Staffing Post.
To examine the procedures State uses to implement its policies for  stopping and starting hardship and danger pay when employees  temporarily leave their assigned overseas posts, we reviewed State  policies and procedures for implementing hardship and danger pay,  including the Foreign Affairs Manual, standard operating procedures  developed by CGFS, and guidance from the posts we visited. We also  reviewed the frequently asked questions related to hardship and danger  pay published by ALS and analyzed versions of the DSSR from 1953 to  the present to identify changes to the rules for stopping and starting  hardship and danger pay for employees assigned to overseas posts.  Finally, we interviewed officials from ALS, CGFS, HR, and at selected  overseas posts.
Lastly, to determine the extent to which State has identified improper  payments related to hardship and danger pay, we reviewed State’s  Annual Financial Reports for 2015 and 2016, the first 2 years that State  reported information on improper payments related to compensation for  U.S. employees. We analyzed CGFS data on the amount of improper  payments identified and recovered for hardship and danger pay in 2015  and 2016. We also reviewed data from CGFS on the types of diplomatic  cables it received from overseas posts in 2015 and 2016—cables that  included information needed by CGFS to make adjustments to hardship  pay. We compared these diplomatic cable data to hardship spending to  identify countries at risk for overpayments of hardship pay. We also  reviewed legal and Office of Management and Budget requirements  related to improper payments, as well as federal internal control  standards. We interviewed CGFS officials to understand State’s process  and methodology for identifying, recovering, and preventing improper  payments related to hardship and danger pay as both part of its normal  business process and its recapture audits. On our site visits, we  examined posts’ controls to prevent and reduce overpayments and  interviewed State employees to understand their experiences with State’s  overpayment recovery efforts.
We conducted this performance audit from April 2016 through September  2017 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
section_title: Appendix II: Comments from the Department of State
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Hynek Kalkus (Assistant  Director), Drew Lindsey (Analyst-in-Charge), Alana Miller, Timothy Carr,  Debbie Chung, Gita Devaney, Neil Doherty, Jeff Isaacs, Grace Lui, Jill  Lacey, and Eli Stiefel made key contributions to this report.