Military Housing: Better Reporting Needed on the Status of the Privatization Program and the Costs of Its Consultants
Published: 2003-10-09T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: In 2000, Congress required the Department of Defense (DOD) to report quarterly on the services' expenditures for consultants in support of the military family housing privatization programs. GAO was asked to review the costs of the consultants DOD used to support privatizing housing for servicemembers and their families. This report discusses (1) the number of family housing units the services have privatized, particularly newly constructed or renovated units, and project to be privatized by fiscal year 2005; (2) the portion of privatization support costs used for consultants; (3) the services' consistency in the definition for privatization support and consultant costs; and (4) factors that limit an evaluation of how consultant fees for the military housing initiative compare among the services.
section_title: What GAO Found
paragraphs: Although DOD reported to Congress that the services plan to privatize most of their family housing by fiscal year 2005, DOD's reports do not provide decision makers with the number of privatized units that have been renovated or newly constructed. As of March 2003, the services had contracts privatizing about 28,000 family housing units and planned to privatize 140,000 units by fiscal year 2005. As a result of this privatization, about 7,600 units had been constructed or renovated. It can take developers several years to renovate existing housing or construct new units after they are privatized. As the program progresses, it will become increasingly important to have complete data on which to determine how quickly the privatization program is creating adequate family housing. Costs for consultants are less than half of the services' privatization support costs. The services anticipate many privatization support and consultant costs to peak in fiscal year 2004 when the need for consultants diminishes once most privatization contracts are signed. Remaining support costs will then focus increasingly on managing the portfolio of the privatized housing. The services are not consistent in their definitions for privatization support and consultant costs. The differences in the services' definitions for privatization support costs result in inconsistent budgeting for these costs. Also, the differences in the services' definitions for consultant costs result in inconsistent reporting of consultant costs in the department's quarterly housing privatization report to Congress. Further, the Office of the Secretary of Defense does not report its own program consultant costs in the quarterly report. Several factors, such as differences in labor categories, hours, and skills mix that each consulting firm can use to accomplish work, limited our evaluation of how consultant fees for the military housing initiative compare among the services. Even though these factors hinder a comparative evaluation of consultant fees, service officials told us they believe that they have contracted with firms that provide the best value to the government based on their needs and that the consultants' fees are fair and reasonable.

section_title: Letter
paragraphs: The Department of Defense (DOD) has estimated that about 60 percent, or  over 180,000 units, of its family housing inventory in the United States is  inadequate, lacking modern amenities, and in need of renovation or  replacement in 1998. DOD has determined that fixing this problem using  only traditional military construction would cost as much as $16 billion  and take over 20 years. Recognizing this problem, Congress provided DOD  with new authorities to improve military housing more economically and  at a faster rate than could be achieved through traditional military  construction funding. Known as the Military Housing Privatization  Initiative, the basic premise behind this program is for DOD to use private  sector investment capital and housing construction expertise to finance,  own, operate, and maintain military housing. Under this program, the  department can provide direct loans, loan guarantees, or co-investments of  land or cash to encourage the private sector to use private investment  funds to build or renovate housing for use by military servicemembers and  their families. Under the privatization effort, for example, developers  assume responsibility for existing military housing units included in the  contracts and may demolish or renovate existing units and construct new  units. For DOD, this program has represented a new way of doing business  and has proven to be inherently complex to implement because of the  extensive real estate, financial, and legal expertise required. As a result,  DOD has relied on consultants to provide this expertise and help advance  the program.
Over time, Congress has expressed concern about the lack of progress  with the military’s housing privatization program and required the Office  of the Secretary of Defense (OSD) to report quarterly to Congress on the  status of the services’ housing privatization projects. In 2000, Congress  added another requirement that DOD report quarterly information on the  services’ expenditures for consultants due to its concern about the cost of  implementing the program. In turn, DOD has included this information in  its Military Housing Privatization Initiative Housing Privatization  Report to the Congress.  The military services consider consultant costs as  a type of privatization support costs—a category that includes other  support costs for the program, such as civilian salaries, training, and  travel.
In March 2003, you requested that we review the costs of consultants used  by DOD to support privatizing military housing. In July 2003, we provided  your offices with briefing materials on our preliminary findings. This  report summarizes our findings. Specifically, it discusses (1) the number of  family housing units the services have privatized, particularly those units  newly constructed or renovated, and projected to be privatized by fiscal  year 2005; (2) the portion of privatization support costs that are used for  consultants; (3) the services’ consistency in the definition for privatization  support and consultant costs; and (4) factors that limit an evaluation of  how consultant fees for the military housing program compare among the  services. In conducting our work, we interviewed Army, Navy, Marine  Corps, and Air Force headquarters’ officials to obtain information related  to the status of the privatization program, the use and costs of consultants,  and the variances in privatization support and consultant costs. We also  interviewed and discussed these data and the results of our work with  officials of OSD’s Housing and Competitive Sourcing Office and the Office  of the Under Secretary of Defense (Comptroller).
subsections: section_title: Background
paragraphs: The 1996 Military Housing Privatization Initiative allows private-sector  financing, ownership, operation, and maintenance of military family and  unmarried junior servicemember (barrack) housing. Under the program,  the department can provide direct loans, loan guarantees, and other  arrangements to encourage private developers to renovate existing  housing or construct and operate housing either on or off military  installations. Servicemembers, in turn, may use their housing allowance to  pay rent and utilities to live in the privatized housing. Because the program  represents a new way of doing business for both the military and the  private sector, DOD has relied on consultants for a variety of advisory and  assistance services. In completing privatization agreements, many  financial, budgetary and other issues need to be resolved to the  satisfaction of the government, developers, and private lenders before a  deal can be closed. Further, each privatization agreement is different and  involves unique issues. According to DOD officials, consultants provide  the necessary expertise and assistance to help resolve these issues.
Initially, DOD established the Housing Revitalization Support Office in  OSD to facilitate implementation of the military housing privatization  program. This office established the financial and legal framework for the  new initiative and provided assistance to the services as they began to  consider housing privatization. Initial progress in implementing the  program was slow and, in 1998, DOD shifted primary responsibility for  implementing the program to the individual services. With this change, the  Housing Revitalization Support Office was eliminated, and housing  privatization oversight responsibility was assigned to a newly created  office in OSD—now known as the Housing and Competitive Sourcing  Office. This office establishes DOD policy for the program and monitors  the services’ implementation of the program.
Concerned about the lack of progress with the military’s housing  privatization program, Congress in 1998 required OSD to begin reporting  quarterly on the status of all privatization projects for which funds had  been appropriated. In addition, in 2000, Congress required that DOD  report information quarterly on expenditures for consultants used by the  services to implement the program. DOD now includes this information in  its Military Housing Privatization Initiative Housing Privatization  Report to the Congress.  The report lists each privatization project,  identifies the number of units to be privatized, shows the project  milestones, and includes the cumulative amount spent on consultants by  project and service.
Military construction appropriations fund the military housing  privatization program, including privatization support and consultant  expenditures. Privatization support includes costs for consultants, federal  civilian salaries, and training and travel activities. Some of the services  also include costs for environmental assessments; land boundary surveys;  and supervision, inspection, and overhead construction activities.  Consultant costs generally include costs for advisory and assistance  activities, such as individual project development, solicitation  development and preparation, pre-award evaluations of project proposals,  and financial and real estate analysis.
section_title: DOD Plans to Privatize Most Family Housing by 2005, but Its Reported Data Do Not Fully Show Progress in Eliminating Inadequate Housing
paragraphs: Although DOD reported to Congress that the services plan to privatize  most of their family housing units by the end of fiscal year 2005, these  reports do not include the number of privatized units that have been  renovated or newly constructed. Such data would show the program’s  progress in creating adequate family housing and the status of  improvements to the living conditions of the servicemembers and their  families. These renovation and construction numbers should accelerate  over time.
As of March 2003, the military services had signed contracts privatizing  about 28,000 family housing units and plan to privatize a total of about  140,000 units by the end of fiscal year 2005. The services plan to privatize  72 percent of their total family housing inventory, representing about  183,000 units, as shown in figure 1, by fiscal year 2007 instead of by 2010 as  originally scheduled.
As a result of these privatization contracts, as of March 2003 the services  had constructed 4,396 new housing units and renovated 3,184 existing  units—total of 7,580 units (see table 1).
We recognize it can take developers several years to renovate existing  housing units or construct new ones after the military housing is  privatized. However, data regarding this process, although maintained at  the installation level, are not collectively tracked and reported to Congress  by OSD. Thus, decision makers do not have complete data to fully assess  the housing privatization program’s progress. Furthermore, as the  privatization program progresses, it will become increasingly important to  have complete data on the status of actual renovation and new  construction of privatized housing units on which to determine how  quickly the program is creating adequate family housing and improving the  living conditions of the servicemembers and their families.
section_title: Consultant Costs Represent Less than Half of Total Privatization Support Costs
paragraphs: According to the services’ budget data, costs for consultants are less than  half of the services’ total privatization support costs, actual and projected.  For example, for fiscal year 2002 consultant costs were about $24 million,  or about 42 percent, of the services’ total support costs of about $57  million for their housing privatization efforts. Furthermore, the services  incur other privatization support costs besides the costs for consultants,  such as federal salaries, training, and travel. In addition, some services  include the cost of environmental assessments and land boundary surveys  in their privatization support costs.
As the services sign the contracts to privatize most of their family housing  units, service officials said their privatization support costs would decline  as the need for consultants diminishes. While these costs are expected to  decline, other assistance costs for portfolio management services for the  privatization program are expected to become a key component of the  remaining support costs as more projects are completed. As figure 2  shows, the services project sharp declines in privatization support and  consultant costs after fiscal year 2004.
section_title: Military Services Use Inconsistent Definitions of Privatization Support and Consultant Costs
paragraphs: The military services are not consistent in their definitions for  privatization support and consultant costs. The differences in the services’  definitions for privatization support costs result in inconsistent budgeting  for these costs. Also, the differences in the services’ definitions for  consultant costs result in inconsistent reporting of consultant costs in the  department’s quarterly housing privatization report to Congress.  Furthermore, OSD does not report its own program consultant costs in the  quarterly report.
subsections: section_title: Differences in the Services’ Definitions for Privatization Support Costs Result in Inconsistent Budgeting
paragraphs: Since OSD had not defined privatization support costs when it gave the  services operational responsibility for the program in 1998, the services  individually defined them, resulting in inconsistencies in the types of costs  included in the services’ budgeting for privatization support. The Navy, for  example, does not include the costs of environmental assessments and  land boundary surveys as privatization support costs while the Army and  the Air Force do. Similarly, the Army and the Navy do not include the  costs for supervision, inspection, and overhead construction activities as  privatization support costs while the Air Force does. Without a common  definition, these differences in accounting lead to an increased variance in  the services’ reported costs and add difficulty for DOD and Congress to  accurately determine total privatization support costs across the services.
According to officials in the Office of the Under Secretary of Defense  (Comptroller), DOD does not have written budget guidance defining what  types of privatization support costs should be included in the services’  budget estimates. Thus, the services account for housing privatization  support costs differently. For example, according to Navy officials, the  Navy’s privatization support budget account does not include costs for  activities that the other services do, such as environmental assessments  and land boundary surveys. As such, the Navy’s privatization support  expenses may not be as low as they appear in its budget. Navy has  combined the management of the family housing program with its real  estate, acquisition, and construction contracting expertise in the Naval  Facilities Engineering Command—the command responsible for military  construction. Thus, the costs for environmental assessments, land  boundary surveys, and supervision, inspection, and overhead construction  activities are part of how the command conducts its mission and are not  captured in the Navy’s privatization support budget. According to Navy  officials, these activities are conducted and funded within the command  and a budget request distinction is not made as to whether the costs for  these activities are for a privatization housing project or a traditional  military construction project. For example, Navy’s estimated $5 million  costs for environmental assessments for its privatization housing efforts  through 2008 will not be reflected in its privatization support account  although this cost is in the other services’ privatization support accounts.  Similarly, the Army’s expenses for construction supervision, inspection,  and overhead activities are part of the developers’ costs; and the Army  does not reflect these costs in its privatization support budget, whereas  the Air Force does.
DOD officials said that the budget inconsistencies have created a problem  for the services. According to DOD officials, Congress has reduced the  Army and the Air Force privatization support budgets due to the  perception that their budgets are unreasonably high when compared with  the Navy’s.
section_title: Differences in the Services’ Definitions for Consultant Costs Result in Inconsistent Reporting to Congress
paragraphs: Because OSD had not defined the types of costs to be included in  determining consultant costs, the services define them differently,  resulting in inconsistent reporting of consulting expenditures in the  department’s quarterly housing privatization report to Congress.  Specifically, the services are beginning to contract for assistance in  managing the portfolio of housing privatization projects to better ensure  long-term program success. The Air Force views portfolio management as  a contractor cost and, as such, is not including this expense in its  consultant cost data to OSD for the quarterly housing privatization report.  In contrast, the Army, the Navy, and the Marine Corps view portfolio  management as a consultant cost; and this expense is included in the  report to Congress. As a result, OSD is providing inconsistent service data  regarding consultant costs in the department’s quarterly housing  privatization report to Congress. Furthermore, as costs for portfolio  management are expected to become a key component of remaining  support costs as the services privatize more housing, the inconsistent cost  reporting will become more pronounced in the future.
Also, important in explaining inconsistencies and variances in consultant  costs among the services is the organizational placement of the  privatization program and the number of projects per service. For  instance, the Navy’s consulting costs are less than the other services  because it has combined the management of its program with its real  estate, acquisition, and construction contracting expertise in the Naval  Facilities Engineering Command. According to Navy and OSD officials,  that decreases the Navy’s need for consultants. Then again, according to  Air Force officials, the Air Force’s consulting costs are higher than the  other services, when its contractor’s portfolio management costs are  included, because it has more privatization projects needing consultant  assistance and advice. Currently, the Air Force plans on 53 family housing  privatization projects whereas the Army and the Navy are planning on  27 and 37 projects, respectively.
The services reported in the quarterly housing privatization report to  Congress that they had spent about $73 million, in total, on consultants  associated with its housing privatization efforts as of March 31, 2003  (see table 2). The extent of their expenditures varied, with the Army  expending $34 million, more than twice the amount expended by the Navy  and the Marine Corps.
section_title: OSD Does Not Report Its Own Consultant Costs in the Quarterly Housing Privatization Report
paragraphs: OSD does not, and is not required to, include its own costs for consultants  associated with its implementation of the military housing privatization  program in the quarterly report to Congress. Officials within OSD’s  Housing and Competitive Sourcing Office stated that OSD has not reported  about $10 million in consultant costs since the beginning of the program in  1996. These consultant costs were not in direct support of a particular  installation and most occurred when OSD had centralized control over the  program. With the transfer of operational responsibility for the program to  the individual services in 1998, OSD’s consultant costs have decreased  significantly, currently averaging about $1 million a year. These consultant  costs are mostly to assist OSD design program evaluation criteria and to  help with budget scoring requirements.
section_title: Several Factors Limit Evaluation and Comparison of Consultant Fees
paragraphs: Although housing privatization fees paid to individual consultants vary  among the services, several factors limit an evaluation and comparison of  these fees. Such factors include the differences in labor categories, hours,  and skills mix that each consulting firm can use to describe the work they  need to do to accomplish the work specified by the services, such as the  following:
Labor categories. Despite some commonalities (e.g., program manager  and financial analyst), the services for the most part list different labor  categories and staff positions in their consultant contracts. The Air Force,  for example, identified 22 labor categories for each of its five consultants,  while the Navy and Army listed 5 and 7 labor categories, respectively.
Labor and hour mixes. Each consulting firm generally emphasizes a  different mix of staff and anticipated number of labor hours, depending on  the needed work. As such, contracting with a consultant with lower hourly  fees will not necessarily result in the lowest total cost because the  different consultant firms use a mix of staff with varying hourly pay rates  and charge different hours to complete the work. Air Force data, for  example, showed that one firm, which charges higher average hourly fees,  planned to dedicate fewer labor hours to a proposed task than another  firm, which charges a lower average hourly fee. The particular mix of staff  and labor hours proposed by both firms led to only a 3 percent cost  variance for a proposed project of about $780,000. In addition, Air Force  data showed that two firms proposed that its senior managers dedicate  considerably fewer hours to the project although charging higher hourly  fees, while another firm proposed that its senior managers dedicate  considerably more hours to the project but charge significantly lower  hourly fees. Thus, a comparison of consultant fees in isolation could  create a misleading assessment.
Scope of work. Different scopes of work within the various housing  privatization projects may generate different labor mixes or entirely new  labor categories for a particular consultant, making comparison difficult.  For example, the Air Force uses two different sets of labor categories for  the same firm—one for the portfolio management work and another,  which is slightly different, for the privatization support work.
Capacities. Consulting firms have different capacities—some are small  businesses while others are global enterprises—and each firm has  different capabilities and expertise. According to Air Force data, for  example, the firms charging the lowest average hourly fee at the  managerial level have only six Air Force family housing privatization  projects between them. However, Air Force officials told us they believe  these firms are small businesses operating at capacity and cannot take on  another project, despite having lower fees than some of the other  consulting firms.
Even though these factors limit a comparative evaluation of consultant  fees, service officials told us they believe that their particular consultant  fees are fair and reasonable because they (1) awarded their consultant  contracts competitively; (2) examined consulting rates published by the  General Services Administration, particularly those in its Management,  Organizational, and Business Improvement Services Schedule, to assist in  determining if the rates were reasonable; and (3) selected consultants  through “best value” determinations. In striving to obtain best value,  service officials said that the services select firms offering the most  advantageous deal to the government and that cost is only one of several  evaluation considerations. Past performance and the capability to perform  the proposed work, among other considerations, are evaluated alongside  fee considerations in assessing contract awards. As a result, service  officials said that they have contracted with firms that provide the best  value to the government based on their needs.
section_title: Conclusions
paragraphs: The military housing privatization program was established for a faster  creation of quality housing for military servicemembers and their families.  As such, the Secretary of Defense has directed the military services to  increase their use of privatization and eliminate their inadequate housing  inventory, moving the completion date for the privatization up from 2010  to 2007. However, until the number of renovated or newly constructed  housing units under privatization are routinely tracked and reported to  Congress, it will be difficult to adequately assess the impact of the  privatization program. Further, as the program progresses and additional  privatized units are expected to be under contract, more complete and  informative data on the number of privatized housing units that have been  renovated or newly constructed will become increasingly important to  decision makers. Such data are needed to determine how quickly the  privatization program is creating adequate family housing and improving  the living conditions of servicemembers and their families.
Until OSD provides a common definition of the types of cost to be  included in determining privatization support costs, including consultant  costs, the military services will continue to budget inconsistently for  privatization support costs and OSD will continue to use inconsistent data  from the services to report consultant costs in its quarterly housing  privatization report to Congress. Similarly, without an OSD determination  of whether portfolio management costs are costs that should be included  as consultant costs, the services will continue to provide OSD with  inconsistent data on consultant costs for its quarterly report to Congress.  Furthermore, until OSD includes its own program consultant costs in the  department’s quarterly housing privatization report, Congress will not  have complete knowledge of the total housing privatization consultant  costs. Without consistent and complete information, Congress and DOD  cannot make the most informed decisions regarding the appropriateness  of support and consultant costs requested and expended in support of the  military housing privatization program.
section_title: Recommendations for Executive Action
paragraphs: To illustrate the number of inadequate housing units eliminated and of  new or renovated units brought on line through the military housing  privatization program, we recommend that the Secretary of Defense direct  the Under Secretary of Defense for Acquisition, Technology and Logistics  to track the supporting data and report the number of privatized units  renovated and newly constructed to the Congress on a periodic basis.
To provide for more consistent and complete data on military housing  privatization support costs, we recommend that the Secretary of Defense  direct the Under Secretary of Defense (Comptroller), in consultation with  the Housing and Competitive Sourcing Office, to define privatization  support costs for the military services. Specifically, this definition should  address the differences in how the services consider the costs of  environmental assessments; land boundary surveys; and supervision,  inspection, and overhead construction activities associated with the  housing privatization program.
To provide for more consistent and complete data on privatization  consultant costs, we recommend that the Secretary of Defense direct the  Under Secretary of Defense for Acquisition, Technology, and Logistics, in  consultation with the Under Secretary of Defense (Comptroller), to  (1) define consultant costs, including a determination of the inclusion of  portfolio management costs, for the military services; and (2) include  OSD’s own program consultant costs associated with its efforts to  privatize military housing in the department’s quarterly housing  privatization report to Congress.
section_title: Agency Comments and Our Evaluation
paragraphs: In written comments on a draft of this report, the Director for Housing and  Competitive Sourcing within the Office of the Under Secretary of Defense  for Acquisition, Technology and Logistics agreed with our  recommendations, stating the department is or will be taking steps to  implement them. In reference to our recommendation to track supporting  data and report on the number of privatized units renovated and newly  constructed, DOD concurred with the recommendation, stating it is  essential that project progress be monitored. However, DOD stated that its  semi-annual Program Evaluation Plan report is a more appropriate  vehicle to track this data than the quarterly reporting specified in our draft  report and has initiated steps to do so. We believe the collection and  periodic reporting of this data to the Congress, regardless of the reporting  format, will benefit decision makers to better assess the housing  privatization program’s progress in creating adequate family housing and  improving the living conditions of the servicemembers and their families.  Accordingly, we modified our recommendation to recognize the potential  for greater flexibility in reporting. DOD’s comments are included in  appendix I of this report.
section_title: Scope and Methodology
paragraphs: We performed our work at the headquarters offices responsible for  implementing the privatization program for the Army, the Navy, the Marine  Corps, and the Air Force. At each location, we interviewed officials  cognizant of the program and reviewed applicable policies, procedures,  and documents. We also interviewed officials at the Air Force Center for  Environmental Excellence in San Antonio, Texas, which has responsibility  for executing Air Force contracts for consultant assistance with the  military housing privatization program. We also discussed our analyses  with officials of OSD’s Housing and Competitive Sourcing Office and the  Office of the Under Secretary of Defense (Comptroller). For the military  housing privatization program, our analyses mostly covered 1996—the  beginning of the military housing privatization program—through 2008  when the services expect to have privatized all of their planned housing.
To determine the number of projects and family housing units the services  have privatized and project to privatize since program inception to fiscal  year 2008, we interviewed service officials and obtained relevant data. We  obtained data for the number of projects and units already privatized from  OSD’s Military Housing Privatization Initiative Housing Privatization  Report to Congress. However, because project execution schedules for  future projects change regularly and the services told us several future  project dates are tentative, we requested the latest estimates of projects  and units to be privatized from the services. Army and Air Force officials  provided us with their privatization schedules while Navy officials told us  to use their fiscal year 2004 budget request data. In addition, the services  provided data on the number of units newly constructed or renovated as  of March 31, 2003, but stated that estimated data was not readily available  for fiscal years 2004 through 2008.
To identify the portion of privatization support costs used for consultants,  we obtained and analyzed budget data from the services for actual and  projected amounts covering fiscal years 1996 through 2008. The services  identified those activities that they considered to be a privatization  support cost and consultant cost. We did not validate these recorded  budget amounts.
To analyze the services’ consistency in defining privatization support and  consultant costs, we compared budget data provided by the services and  noted differences in what they considered privatization support and  consultant costs. We met with service officials to discuss those differences  and possible reasons for these differences. To report data on the services’  cumulative expenditures as of March 31, 2003, for military housing  privatization consultants, we used the department’s latest quarterly  housing privatization report dated April 2003. We interviewed OSD and  service officials about the reporting requirements for the quarterly housing  privatization report and corresponding budget guidance on privatization  support and consultant costs. In addition, we met with officials from the  Office of the Under Secretary of Defense (Comptroller) to obtain their  views on our privatization support and consultant cost analyses.
To assess how consultant fees for the military housing privatization  program compare among the services, we reviewed and analyzed the  services’ consultant contracts and individual task orders, noting the hourly  fees charged by each consultant. We obtained data from the appropriate  General Services Administration federal supply schedule for Management,  Organizational, and Business Improvement Services Schedule and made  fee comparisons. We also interviewed service officials to discuss their  assessment process for evaluating consultant fees and selecting  consultants. Finally, we interviewed officials from the Air Force’s Brooks  City Base, San Antonio, Texas, and from the Army’s Fort Sam Houston,  San Antonio, Texas, to discuss DOD’s use of consultants in similar  privatization activities.
In performing this review, we did not validate DOD’s reported housing  requirements or privatization information. We conducted our work from  April 2003 through July 2003 in accordance with generally accepted  government auditing standards.
We are sending copies of this report to the Secretaries of Defense, the  Army, the Navy, and the Air Force; the Commandant of the Marine Corps;  and the Director, Office of Management and Budget. We will also make  copies available to others upon request. In addition, the report is available  at no charge on GAO’s Web site at www.gao.gov.
Please contact me on (202) 512-8412, or my Assistant Director, Mark Little,  at (202) 512-4673 if you or your staff have any questions regarding this  report. Major contributors to this report were Laura Talbott, Shawn  Arbogast, Jason Aquino, Jane Hunt, and R.K. Wild.