8(a) Subcontracting Limitations: Continued Noncompliance with Monitoring Requirements Signals Need for Regulatory Change
Released: 2014-09-16T00:00:00

Letter

Background

Subcontractors can perform work under 8(a) contracts, but certain limitations apply regarding the percentage of personnel costs that these firms may incur under service, supply, and construction contracts. For example, for service contracts, the 8(a) prime contractor must incur at least 50 percent of the personnel costs with its own employees. In other words, the total personnel costs associated with the employees of the 8(a) prime contractor must be equal to or greater than the total personnel costs associated with the employees of all subcontractors performing work under the service contract. Table 1 identifies how much work the firm awarded the 8(a) contract must perform according to the requirements in the subcontracting limitation clause currently in the FAR and applicable to the contracts reviewed for this report.

Procuring agency contracting officers are responsible for monitoring whether 8(a) contractors are in compliance with subcontracting limitations. For all of the agencies in our review, SBA has delegated responsibility for contract administration to the procuring agencies through partnership agreements. Partnership agreements between the agencies and SBA outline the responsibilities of both parties in the 8(a) contracting process. These agreements delegate SBA’s contract administration responsibilities, such as overseeing the contractor’s performance, to the procuring agencies after SBA has accepted the procurement into the 8(a) program. The partnership agreements explicitly address subcontracting limitations in a few ways by requiring the agencies to at the time of the contract award, conduct and document an assessment of the 8(a) firm’s ability to comply with the subcontracting limitations; include monitoring and oversight provisions in all 8(a) contracts to ensure that the contractors comply with the subcontracting limitations; and ensure that 8(a) contractors comply with the subcontracting limitations.

SBA, DOD, DHS, and HHS officials responsible for administering the 8(a) program stated that contracting officers are responsible for implementing these requirements. Our past work and the work of others, however, have found that contracting officers generally do not do so. In our April 2006 report, we reviewed 16 contracts awarded to 8(a) firms owned by Alaska Native Corporations and found almost no evidence that agencies were monitoring compliance with subcontracting limitations. Contracting officers we spoke with were generally confused about whose responsibility it was to monitor compliance or were unclear about how to monitor the subcontracting limitation requirements under IDIQ contracts. We recommended that SBA take steps to clearly assign accountability for monitoring compliance. SBA did not state if it agreed or disagreed with our recommendations but, in response, the agency provided training to procurement officials and revised the 8(a) partnership agreements to more clearly delineate responsibility to the procuring agency for the monitoring. SBA also provided training to procuring agencies on the contents of the partnership agreements.

Nevertheless, about 6 years later, we reported that of 71 8(a) contracts confirmed to have subcontracting, we found no evidence of regular and systematic monitoring of the subcontracting limitations. Contracting officers were still unclear who was responsible for the monitoring and uncertain about how to conduct the monitoring. In this January 2012 report, we noted that the FAR requires contracting officers to include the subcontracting limitations clause in 8(a) contracts but does not state who is accountable for monitoring compliance with the required percentages. In addition, many contracting officials told us that they did not know how to monitor the percentage of work that is subcontracted, in part, because they did not have visibility into subcontractor costs. Lastly, we found no evidence that the contracting officers were enforcing requirements that 8(a) contractors semi-annually demonstrate compliance with subcontracting limitations under IDIQ contracts, in part, because these requirements were not referenced in the FAR. We recommended that OFPP, in consultation with SBA, take a number of actions, such as amending the FAR to direct contracting officers to document in the contract file the steps they had taken to ensure compliance and to clarify the percentage of work required by an 8(a) participant under IDIQ contracts. OFPP agreed with our recommendations and some actions have been taken to address them. For example, SBA amended its regulations regarding subcontracting limitations under IDIQ contracts, issuing a final rule on October 2, 2013. Prior to this change, the 8(a) participant was to demonstrate semi-annually that it had performed the required amount of work for the combined total of all task or delivery orders at the end of each 6-month period under an IDIQ contract. The amended regulations require the 8(a) firm to demonstrate compliance with the subcontracting limitations after each performance period—e.g., for the base period and any option period thereafter. OFPP and SBA stated that they would address the other recommendations as they developed regulations to comply with the most recent amendments to the Small Business Act.

SBA has also found that contracting officers are generally not monitoring compliance with the subcontracting limitations. To address FAR requirements, SBA conducts surveillance reviews each fiscal year at various contracting offices to monitor their compliance with small business policies, statutory requirements, and applicable regulations. As part of these reviews, SBA examines a sample of small business contracts to determine whether the contract files contain evidence that the contracting officer monitored compliance with the subcontracting limitations. According to SBA officials, these reviews generally find that the contracting officers are not taking steps to ensure such compliance. For example, through these reviews, SBA has found that contracting officers were either not including the FAR subcontracting limitations clause in contracts or were not monitoring compliance. SBA has made recommendations to these contracting offices to provide training or issue guidance on the requirement so contracting officers better understand their responsibilities to monitor subcontracting limitations.

Responsibilities for Ensuring Compliance with Subcontracting Limitations Still Not Fully Met or Understood

Contracting Officers Are Generally Not Ensuring Compliance with Subcontracting Limitations

With two exceptions, the contracting officers we met with generally do not monitor the amount of subcontracted work to ensure 8(a) contractors comply with subcontracting limitations, which is consistent with our past findings. Table 2 shows that contracting officers rarely performed all subcontracting limitations-related responsibilities in their agency’s 8(a) partnership agreements with SBA.

As noted in the table, only four contracting officers documented and assessed if the offeror could comply with the subcontracting limitations prior to contract award. These assessments varied from questioning the offeror on how it would comply with the subcontracting limitations to using award evaluation criteria that required the offeror to identify the steps it would take to ensure it was in compliance. As required by the FAR, all of the contracts included the subcontracting limitations clause, which requires the contractor to perform a certain percentage of the work.

None of the contracts, however, included a monitoring and oversight provision to require the contractor to demonstrate the percentage of work it performed.

Subcontracting limitations were monitored for an HHS and a Navy contract we reviewed. In addition to assessing if these contractors would be able to comply, these two contracting officers required the contractor to regularly provide information on the extent to which work was subcontracted. The contracting officers told us that it was their standard practice to monitor subcontracting for this purpose. We did not find evidence that these limitations were monitored in the other eight contracts. In reviewing these eight contracts, we also did not find sufficient evidence in the contract files to independently determine the extent of work subcontractors completed. The other contracting officers we spoke with stated that they do not monitor the extent of subcontracted work to ensure contractors comply with subcontracting limitations.

Contracting officers cited many reasons for not ensuring 8(a) contractors complied with subcontracting limitations. We often found that contracting officers, even one of the two who monitored subcontracting limitations, were not fully aware of what they were required to do under the partnership agreements or were unclear on how to ensure compliance (see table 3).

Generally, contracting officers understood that they had some responsibility to monitor compliance with subcontracting limitations, but told us that this responsibility was also shared with CORs, in part, because contracting officers are not always onsite to oversee contractor performance as CORs generally are. CORs associated with the 10 contracts we reviewed, however, stated that contracting officers have not delegated this responsibility to them and they do not take steps to monitor the amount of subcontracted work.

In addition, some contracting officers stated that the contractor was responsible for ensuring compliance with subcontracting limitations, in part, because the contract included the limitation on subcontracting FAR clause. For example, one HHS contracting officer stated that the 8(a) contractors he works with understand the amount of work they must perform, should be monitoring the amount of subcontracted work, and should inform the government if subcontractors perform more work than allowed. This contracting officer, however, was not aware if the contractor had performed the required amount of work on the contract we reviewed, and contractor representatives for this contract told us that they were not in compliance with the subcontracting limitations at the time we spoke with them.

In several interviews during this review and in prior work, contracting officers told us that they primarily rely on the FAR and their agencies’ policies and guidance to understand what their responsibilities are and how to implement them. While agencies’ policies and guidance may supplement parts of the FAR, the purpose of the FAR is to provide uniform policies and procedures for federal acquisitions, and most agencies must follow these regulations. The FAR requires contracting officers to include the subcontracting limitations clause in any solicitation and contract awarded under the 8(a) program, but it does not address the contracting officers’ responsibilities as outlined in the 8(a) partnership agreements. Three contracting officers told us they were fully aware of the contents of the 8(a) partnership agreements, but had not fully implemented those responsibilities, and only one had taken steps to ensure the contractor was in compliance with subcontracting limitations. Four contracting officers were aware of the partnership agreement generally but were not aware that it required them to include, among other things, a monitoring and oversight provision in the contract. Another contracting officer was completely unaware of the partnership agreement. DHS, DOD, and HHS procurement and small business contracting officials we met with stated that their agencies have not developed any specific policies or guidance for contracting officers to reinforce or re-state these responsibilities. When contracting officers are not aware of or do not implement their responsibilities to monitor 8(a) subcontracting limitations, there is an increased risk that contractors are not in compliance.

Further, six contracting officers also expressed confusion about their ability to monitor subcontracted work performed under 8(a) contracts, stating that they did not have access to the costs of the subcontracted work. These contracting officers generally stated it was their understanding that only large businesses could be compelled to report on subcontracted work. Large businesses awarded contracts that are expected to exceed a certain amount are required to develop a plan detailing the extent to which they will subcontract work to small businesses, which is evaluated by contracting officers prior to awarding a contract. These businesses are then required to report on the amount of work subcontracted to those small businesses on a federal government website. While the FAR exempts small businesses from the requirement to submit a subcontracting plan, it does not prohibit contracting officers from requiring that small businesses report on subcontracting for the purposes of demonstrating compliance with the subcontracting limitations.

Six contracting officers also generally thought that the government does not have access to the costs of subcontracted work under firm, fixed priced contracts but would under cost-reimbursement contracts. Contracting officers are not prohibited from requesting information on the amount of subcontracted work under firm, fixed priced contracts. In fact, we found that contracting officers were able to request and collect information on the amount of subcontracted work, regardless of the contract type. The two contracting officers that monitored subcontracting did so by requiring contractors to submit information on the amount of subcontracted work for both a cost-reimbursement contract and a fixed- priced contract. For example, prior to approving new work on a cost- reimbursement contract for conference logistics and planning services, an HHS contracting officer required the 8(a) contractor to propose how it would comply with subcontracting limitations. As work was performed, this contracting officer calculated how much work was completed by subcontractors using subcontractor invoices provided by the contractor. In the other instance, a fixed-priced contract for facility support services, a Navy contracting officer included evaluation criterion in the solicitation to ensure that any offeror would be able to perform the required amount of work. Even though this was a fixed-price contract, the contracting officer required the contractor to semi-annually report on the amount of subcontracted work from the start of the period of performance. These two contracting officers stated that 8(a) contractors they work with generally have no problem providing data or information required to demonstrate compliance with subcontracting limitations, regardless of the contract type.

8(a) Contractors Are Willing and Able to Provide Subcontracting Data If Required

All of the 10 8(a) contractors we met with said they are willing and able to provide information to demonstrate compliance with subcontracting limitations, but generally would only do so if required. They stated that contracting officers rarely ask for or require this information. All contractor representatives stated that they maintain information on the costs of their subcontracted work, but most do not track if they are in compliance with subcontracting limitations. They said, however, that they likely could demonstrate compliance if required. In some cases, construction contractors noted that they might need to obtain more information on the personnel costs associated with subcontracted work, in part, because some subcontractors invoice for total costs rather than providing details on all of their costs. Three contractor representatives explained that they monitor compliance as a regular practice by manually calculating the percentage of subcontracted work using subcontractors’ invoices or generating automated reports through the firm’s financial accounting system.

Contractor representatives stated that providing information to demonstrate compliance with subcontracting limitations would not burden them if such a requirement was put in place prior to or at the time of contract award. They said that the earlier such information is required or requested, the easier it is to determine and demonstrate compliance. Some contractor representatives added that they would be hesitant to provide details on costs they considered to be proprietary information under fixed priced contracts, but would provide information on the percentage of subcontracted work.

Observed Situations That Underscore the Need to Monitor Subcontracting

In the course of our review, we observed situations presenting an increased risk that subcontracting limitations may be exceeded. While all 8(a) contracts must comply with subcontracting limitations, these situations highlight the importance of monitoring the extent of subcontracting. Our observations included situations when the 8(a) prime contractor proposed subcontractors that were the agency’s prior incumbent contractor or that had more experience in meeting the agency’s current requirement than the prime contractor. Figure 1 shows that 5 of the 10 contracts in our sample exhibited one or more of these situations.

While we could not independently verify the amount of work subcontracted, of the five contracts we found to be at increased risk of not complying with the subcontracting limitations, contractor representatives from two of these firms stated that they were not in compliance at the time of our review. In both of these instances, the contracting officer did not monitor the amount of subcontracted work. In one of these cases, the contractor initially proposed that none of the work for general construction services on a U.S. Air Force base would be subcontracted. The Air Force program office, however, delayed the start of the project multiple times which required the firm to redirect its employees to perform work on other construction projects. This shift resulted in the firm hiring subcontractors to perform the contracted work. In reviewing the contract file, we found evidence to suggest that subcontractor employees performed significant roles on the project, which the contractor representatives confirmed. Some of these roles, however, should have been performed by the 8(a) prime contractor, according to the contracting officials. For example, a subcontractor employee emailed program officials to request facility access for employees from other subcontractor firms. In another instance, the same subcontractor employee signed a material request form where the prime contractor would generally sign, identifying his title as the “PM” or project manager. Contractor representatives stated that while this subcontractor prepared these documents, an employee of the prime contractor served as the project manager. They noted, however, that the 8(a) firm did not collect specific data on the cost of its subcontracted labor to determine what percentage of work subcontractors performed.

In a DHS contract, for file scanning and destruction services, the prime contractor representative estimated that the firm was meeting the subcontracting limitations but could not confirm this. This representative, whose firm’s expertise was information technology services, told us that the firm did not have any experience providing the services required under the contract. Therefore, the firm had teamed with a subcontractor— recently graduated from the 8(a) program—who had been the incumbent contractor for the file scanning and destruction requirement. In its proposal, the 8(a) firm stated that its subcontractor would perform 49 percent of the work, nearly the maximum allowed under the subcontracting limitation requirements. DHS paid the prime contractor a fixed price for each scanned page and for each box of documents destroyed. The prime contractor had a similar pricing arrangement with its subcontractor and did not obtain the personnel costs associated with the subcontracted work, which are needed to demonstrate compliance with the subcontracting limitations. Instead, the firm maintained documentation on how many documents were scanned and boxes destroyed. Representatives from the firm stated that had the contracting officer included a monitoring provision in the contract or requested such information, the firm would have collected the information needed to determine the amount of work completed by its subcontractor.

For a Navy contract, the contracting officer found that for the first year, the 8(a) contractor was not in compliance with the subcontracting limitations. The contract was for facility support services, which included janitorial services and vehicle or equipment support. A representative from the 8(a) prime contractor told us that while the firm was experienced with providing janitorial services, it did not have any experience providing vehicle and equipment support. The 8(a) firm teamed with a subcontractor who had been the incumbent contractor for the same requirement but had graduated from the 8(a) program and needed a partner to continue performing the work. The firm’s proposal identified that the incumbent contractor would be a significant subcontractor but that the 8(a) firm would be able to perform at least 50 percent of the work. Contractor representatives explained, however, that the initial task orders awarded under the IDIQ contract were for vehicle and equipment support, which were generally completed by the subcontractor. During this time, the Navy contracting officer required the contractor to submit a report every 6 months on the amount of subcontracted work. The 8(a) firm eventually complied with the subcontracting limitations after it was awarded a high-dollar task order for janitorial and other services. The firm’s representative said that reporting on the amount of subcontracted work every 6 months was an easy requirement to meet and helped the firm understand the steps it needed to take to be in compliance.

Initial Step Taken but Statutory Changes to Subcontracting Limitations Could Take Years to Implement and Would Reportedly Have Mixed Effects

While SBA has taken an initial step to implement the statutory changes to subcontracting limitations by announcing that it is drafting a proposed rule, it could take years to reflect these changes in regulation. Many actions are needed to revise small business regulations, which in this case will lead to revisions in the FAR. Contracting officers and contractors reported that these pending changes could have mixed effects on monitoring compliance.

Changes to How Subcontracted Work Is Determined

The NDAA for Fiscal Year 2013 amended the Small Business Act to change what costs are considered to be subcontracted work under 8(a) contracts, in part, to make it easier for contractors to determine if they are in compliance. Because these changes are not yet implemented in the FAR, agency procurement officials told us that contracting officers are to enforce the current subcontracting limitations, that is, those that were in effect before this amendment. Table 4 compares the subcontracting limitations in the FAR, as implemented today, to those in the amended Small Business Act.

The NDAA amendments to the Small Business Act were enacted on January 2, 2013, and it could take years to incorporate these changes into the FAR. For example, we recently reported on a small business regulation change that took 3 years to complete, a time frame that agency officials told us is typical. In January 2014, SBA announced that it was drafting a proposed rule to implement these changes into federal regulations through the public rulemaking process, which is generally an initial step in the federal rulemaking process needed to amend the small business regulations as well as the FAR. According to SBA officials, the proposed rule will include the prescribed changes in the Small Business Act for service and supply contracts and revised subcontracting limitations for construction contracts. SBA officials stated that the agency had drafted the proposed rule in June 2014 and that it is currently in the review process. The officials stated that SBA will submit the final rule to the FAR Council, chaired by the Administrator of OFPP, which will then solicit comments from other interested parties and take steps to incorporate any changes into the FAR.

Some contracting officers and nearly all contractor representatives told us that they would need additional guidance on how to implement these changes but offered some varied perspectives on potential effects. Contracting officers said these changes could simplify the information needed to determine the amount of subcontracted work allowed under 8(a) service contracts, which was the intent of these amendments. Instead of needing information on both the 8(a) firm’s and its subcontractors’ total personnel costs, only the amount paid to subcontractors would be needed to determine the amount of subcontracted work. Contractor representatives stated that these changes could have mixed effects on their ability to perform the required amount of work. Several acknowledged that not counting work performed by other 8(a) firms as subcontracted work could make it easier to comply with the limitations and would encourage subcontracting to these firms. Yet almost all of the contractor representatives we met with noted that if the new subcontracting limitations do not exclude certain costs, such as costs for materials and travel, then it could make it more difficult to comply.

Establishment of Monetary Penalties for Violating Subcontracting Limitations

The NDAA for Fiscal Year 2013 also amended the Small Business Act to impose a monetary penalty on contractors that violate the subcontracting limitations. The minimum penalty is $500,000, and a contractor would be required to pay up to the difference between the amount of subcontracted work allowed and the actual amount expended on subcontracted work— whichever is greater. For example, if only $5 million of work was allowed to be subcontracted out but the actual amount of subcontracted work was valued at $6 million, the penalty could be up to $1 million. Prior to this change, no such monetary penalty existed. SBA officials stated that the June 2014 draft proposed rule addresses this penalty.

According to a January 2014 semi-annual announcement of current and projected rules, SBA plans to incorporate the penalty into federal regulations and to provide protection to small businesses that, despite good faith efforts, exceed the subcontracting limitations. SBA officials noted that the penalty could currently be enforced by the Attorney General, but were not aware of any such actions. Most of the contractor representatives told us that the monetary penalty for violating the subcontracting limitations would bankrupt or put an 8(a) firm out of business if enforced, which they noted creates a significant incentive for prime contractors to complete the required amount of work. Contractor representatives were particularly concerned because while they intend to complete the required amount of work, they may not always be able to for reasons outside of their control. For example, half of the representatives pointed to situations when the work performed under a contract differed from the work they expected to perform based on the government’s solicitation. In such situations, they had to use subcontractors to perform work they were not able to complete.

Modifications to Existing Subcontracting Reporting System

These key individuals consist of the contracting officer, Director of the Office of Small and Disadvantaged Business Utilization, and SBA Administrator. See 15 U.S.C. § 645(g)(2). contractors exceed the subcontracting limitations or notifies key individuals when those situations occur. Contractors currently report subcontracting data for federal contract awards into two systems: (1) the electronic Subcontracting Reporting System (eSRS) and (2) the Federal Funding Accountability and Transparency Act Subcontracting Reporting System (FSRS). The Small Business Act did not specify which system to modify. In February 2014, SBA notified the General Services Administration that FSRS would need to be modified to address the act’s requirement. SBA officials told us the agency would draft a separate proposed rule to implement the requirement in its regulations, which would also be implemented in the FAR, but noted that this process would take years to complete. General Services Administration officials told us that they had not determined which system, eSRS or FSRS, would be modified, but that any system changes would not occur until after the public rulemaking process is complete and any necessary changes are made to the FAR.

Both eSRS and FSRS would require changes to fully address the requirement to modify an existing federal subcontracting reporting system. ESRS, for example, is used to monitor large businesses’ progress in meeting small business subcontracting goals. Small businesses, however, are not required to report subcontracting information into eSRS. FSRS, on the other hand, provides the public with transparency into the extent of subcontracting performed under federal awards. Both large and small businesses report certain subcontract award information into the system, including the subcontractor’s name and total dollar value of sub-award. FSRS, however, does not capture all subcontract awards or the level of detail needed to identify instances when subcontracting limitations are exceeded. For example, the system includes subcontracting data only on prime contract and subcontract awards that are at least $25,000; and includes only the total value of the subcontract awards and does not break out the costs for labor and materials needed to identify violations under the current and revised subcontracting limitations.

Conclusions

When contracting officers do not take steps to ensure 8(a) contractors can and do comply with subcontracting limitations, there is an increased risk that an improper amount of the work may be completed by subcontractors rather than the 8(a) firm awarded the contract. We previously reported on this issue in 2006, and to date, little has improved. Our prior recommendations that OFPP and SBA clarify how contracting officers are to monitor and document compliance with subcontracting limitations still need to be fully addressed. In general, contracting officers are unaware of their responsibilities in the 8(a) partnership agreements and are not taking appropriate steps to ensure that 8(a) contractors are in compliance. These findings are even more troubling when there are situations with an increased risk that a contractor may not be able to complete the required amount of work, such as when the prior contractor becomes a major subcontractor for the same requirement. As we found, however, monitoring can be done—as demonstrated by the two contracting officers who were diligent in carrying out most of their responsibilities in this regard. Additionally, when asked, 8(a) contractors have provided the necessary information. Further, once again we have found that although some guidance was in the partnership agreements and small business regulations, contracting officers turn to the FAR for guidance and, as of this date, their responsibilities for monitoring subcontracting limitations are not clearly set forth in procurement regulation. Until the FAR reflects these responsibilities, the 2013 statutory changes are likely to have muted effects. As the process of developing the new rules unfolds, OFPP has an opportunity to incorporate contracting officers’ responsibilities into the FAR, including outlining steps that can be taken to monitor subcontracting throughout the period of contract performance.

Recommendations for Executive Action

We recommend that the Administrator of OFPP take appropriate steps to amend the FAR to include the following three requirements:

At the time of the contract award, contracting officers shall conduct and document an assessment of the 8(a) firm’s ability to comply with the subcontracting limitations;

Contracting officers shall include monitoring and oversight provisions in all 8(a) contracts to ensure that the contractors comply with the subcontracting limitations; and

Prime 8(a) contractors shall periodically report to the contracting officer on the percentage of subcontracted work being performed.

Agency Comments and Our Evaluation

We provided a draft of this report to OFPP, SBA, DOD, DHS, and HHS for review and comment. We also provided selected portions of the report, dealing with the subcontracting system issues, to GSA. We received an email response from OFPP and technical comments from GSA. DOD, DHS, HHS, and SBA did not have any comments on the draft report.

In its email response, a senior OFPP official stated that OFPP generally agreed with our recommendations to strengthen the monitoring and oversight of the required performance percentages for 8(a) contractors, as well as for all small businesses that receive set-aside awards. OFPP intends to ask the FAR Council to take steps to revise the FAR to address this issue to encompass the recommendations from this report, along with recommendations from our January 2012 report, and the changes to the subcontracting limitations enacted in the NDAA for Fiscal Year 2013. The official noted that OFPP will begin the process of revising the FAR when SBA finalizes its implementing regulations addressing limitations on subcontracting, adding that SBA’s associated proposed rule is currently under review.

In providing technical comments, a senior GSA official stated that GSA would determine what electronic subcontracting reporting system changes are necessary once SBA issues implementing guidance for subcontracting limitations, and after any applicable FAR changes are made. The official added that GSA would ensure SBA’s approval before implementation of the changes and would engage with federal agencies so they are aware of any pending changes and can take any necessary actions to prepare.

We are also sending copies of this report to other interested committees; the Director of the Office of Management and Budget; the Secretaries of Defense, Homeland Security, and Health and Human Services; and the Administrators of the Small Business Administration and General Services Administration. The report also is available at no charge on the GAO website at http://www.gao.gov.

If you or your staff have questions regarding this report, please contact me at (202) 512-4841 or MackinM@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 key contributions to this report are listed in appendix I.

Appendix I: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

In addition to the contact named above Tatiana Winger, Assistant Director; Justin Jaynes, Analyst in Charge; Jenny Chanley; Dani Greene; Julia Kennon; Sylvia Schatz; Jared Sippel; and Ozzy Trevino made key contributions to this report.