Critical Infrastructure Protection: DHS Has Fully Implemented Its Chemical Security Expedited Approval Program, and Participation to Date Has Been Limited
Released: 2017-06-29T00:00:00

Letter

Background

DHS’s National Protection and Programs Directorate leads the country’s effort to protect and enhance the resilience of the nation’s physical and cyber infrastructure. The directorate includes the Office of Infrastructure Protection, which leads the coordinated national effort to reduce risk to U.S. critical infrastructure posed by acts of terrorism. Within the Office of Infrastructure Protection, ISCD leads the nation’s effort to secure high-risk chemical facilities and prevent the use of certain chemicals in a terrorist act on the homeland; ISCD also is responsible for implementing and managing the CFATS program, including its EAP.

The CFATS program is intended to ensure the security of the nation’s chemical infrastructure by identifying, assessing the risk posed by, and requiring the implementation of measures to protect high-risk chemical facilities. Section 550 of the DHS Appropriations Act, 2007, required DHS to issue regulations establishing Risk-Based Performance Standards for chemical facilities that, as determined by DHS, present high levels of risk; the act also required vulnerability assessments and development and implementation of site security plans for such facilities. DHS published the CFATS interim final rule in April 2007 and appendix A to the rule, published in November 2007, lists 322 chemicals of interest and the screening threshold quantities for each. According to DHS, subject to certain statutory exclusions, all facilities that manufacture chemicals of interest, as well as facilities that store or use such chemicals as part of their daily operations, may be subject to CFATS. However, only chemical facilities determined to possess a requisite quantity of chemicals of interest (i.e., the screening threshold quantity) and subsequently determined to present high levels of security risk are subject to the more substantive requirements of the CFATS regulation.

The CFATS regulation outlines a specific process for how ISCD is to administer the CFATS program. A chemical facility that possesses any of the 322 chemicals of interest in the quantities that meet or exceed a threshold quantity is required to use ISCD’s Chemical Security Assessment Tool, a web-based application through which owners and operators of chemical facilities provide information about the facility to ISCD. If ISCD determines that a facility is high risk, the facility must complete and submit to ISCD a standard security plan, expedited security plan, or Alternative Security Program. Tier 1 and tier 2 facilities must use the standard security plan or Alternative Security Program, while tier 3 and tier 4 facilities also have the option to use the expedited security plan. For a facility that submits a standard security plan or Alternative Security Program, ISCD reviews it for compliance with CFATS. If compliant, ISCD issues a letter of authorization and conducts an authorization inspection. If the facility passes the authorization inspection, ISCD issues a letter of approval and the facility implements the approved security plan or program. Subsequently, ISCD conducts compliance inspections to confirm that the facility has implemented its approved security plan or program.

For tier 3 or tier 4 facilities that choose to submit the expedited security plan, ISCD reviews the expedited plan to determine if it is sufficient and, if so, issues a letter of acceptance. If the expedited plan is determined to be facially deficient, the facility is no longer eligible to participate in the EAP and must submit a standard security plan or Alternative Security Program. For expedited facilities that receive a letter of acceptance, ISCD does not conduct an authorization inspection because the CFATS Act of 2014 does not provide for this inspection at expedited facilities. However, ISCD intends to subsequently conduct compliance inspections to confirm that the expedited facility has implemented its approved security plan.

Regarding the EAP, the CFATS Act of 2014 states that, among other things, DHS is to issue guidance for EAP facilities not later than 180 days after enactment of the act that identifies specific security measures sufficient to meet Risk-Based Performance Standards; approve a facility’s expedited security plan if it is not facially deficient based upon a review of the expedited plan; verify a facility’s compliance with its expedited security plan through a compliance inspection; require the facility to implement additional security measures or suspend the facility’s certification if, during or after a compliance inspection, security measures are insufficient to meet Risk-Based Performance Standards based on misrepresentation, omission, or an inadequate description of the site; and conduct a full evaluation of the EAP and submit a report on the EAP not later than 18 months after the date of enactment of the act to Congress.

DHS Has Fully Implemented the EAP and Reported to Congress on Its Assessment of the Program

DHS Has Issued Guidance for the EAP and Fully Implemented the Program

On May 12, 2015, DHS issued EAP guidance for eligible facilities to use to prepare their expedited plans. DHS fully implemented the EAP about a month later when facilities could submit expedited security plans and certification forms to ISCD. Consistent with the act, DHS developed the guidance within 180 days after the date the act was enacted and identified specific security measures that are sufficient to meet Risk- Based Performance Standards applicable to facilities under DHS’s standard security plan process. The guidance is intended to help facilities prepare and submit their expedited security plans and certifications to ISCD, and includes an example that identifies specific (i.e., prescriptive) security measures that facilities are to have in place. Appendix I provides an example of the EAP’s prescriptive security measures and shows the measures that an EAP facility is to have in place to respond to a threat or actual theft or release of a chemical of interest.

ISCD officials told us that, in developing prescriptive security measures for the EAP, they considered various sources, including: lessons learned from approving prior standard security plans and Alternative Security Programs for tier 3 and tier 4 facilities and conducting inspections at these facilities;

Risk-Based Performance Standards used to develop a standard security plan or Alternative Security Program; and relevant academic literature, and security directives, guidelines, standards, and regulations issued by other federal agencies, such as the U.S. Army and the Department of Labor.

ISCD officials told us that they developed the EAP security measures with clear, specific guidance, so that facility officials would have the information needed to successfully obtain approval of their expedited security plan upon submission. The CFATS Act of 2014 allows facilities to submit only one expedited plan to DHS. Specifically, if ISCD determines that an expedited plan is facially deficient due to an error, the act does not allow facility officials to correct the error and resubmit the plan. In addition, ISCD officials said that prescriptive, clear, and easily understood EAP security measures are needed because the act requires DHS to approve an expedited plan that has all applicable prescribed security measures and does not provide for an authorization inspection under the EAP. Therefore, ISCD’s goal in developing required security measures for an expedited security plan was to ensure that a facility had adequate security in place until inspectors could conduct a compliance inspection at the facility approximately 1 year after approving the plan.

ISCD officials also stated that, before and after implementing the EAP, they reached out to industry representatives to ensure that eligible facilities were aware of the EAP and its availability as an option to the standard security plan and Alternative Security Program. Specifically, ISCD held meetings with officials representing the Chemical Sector Coordinating Council, the Food and Agriculture Sector Coordinating Council, and the Oil and Natural Gas Subsector Coordinating Council before issuing the EAP guidance and also contacted them after doing so.

ISCD also made presentations about the EAP at the Chemical Sector Security Summit in July 2015, and to other groups, including three labor unions prior to implementing the EAP. In addition, ISCD chemical security inspectors and other staff routinely discuss the EAP when conducting CFATS-related outreach.

Officials we interviewed at the three coordinating councils confirmed that DHS had contacted them about the EAP. Also, officials from 8 of the 11 industry organizations we interviewed said they have been generally pleased with DHS’s efforts to communicate with them about the CFATS program in recent years. However, officials from a Sector Coordinating Council stated that ISCD did not accept the council’s offers to assist in developing the EAP guidance and were concerned that ISCD may not accept future offers to work on CFATS issues. A senior ISCD official stated that ISCD did not accept the council’s offers to assist in developing the EAP guidance because the CFATS Act of 2014 required DHS to develop the guidance within 6 months of enactment, which did not allow time to involve all interested stakeholders in developing it. The ISCD official stated that ISCD continues to value stakeholder input, appreciates the desire of Sector Coordinating Council members and other stakeholders to provide input on CFATS materials, and plans to seek input from Sector Coordinating Councils and other stakeholders, as appropriate, on future relevant issues.

ISCD officials also told us that they developed draft, standard operating procedures to evaluate expedited security plans and conduct compliance inspections, and that officials used the draft procedures to evaluate expedited plans since the EAP’s implementation. ISCD staff who review expedited security plans have received training on how to do this and vetting an expedited plan is relatively simple and straightforward because it does not require extensive analysis, according to ISCD officials. Specifically, ISCD staff review an expedited security plan to determine if facility officials have checked all required boxes for applicable security measures, adequately explained any planned security measures or material deviations, and signed the required certification. If ISCD staff concludes that all of these things have been done, they recommend that the ISCD Director approve the expedited security plan. ISCD staff prepares a summary of the review, including the recommendation, and provides it to the Director. These standard operating procedures were approved on May 25, 2017.

DHS’s Report on the EAP Discussed All Statutory Elements

DHS’s report to Congress on the EAP, issued on August 2, 2016, discussed all elements listed in the CFATS Act of 2014, but did not quantify costs associated with the EAP because most of DHS’s initial costs were for salary and benefits and DHS did not require its employees to track the hours they worked on the EAP. DHS also did not quantify associated costs to the regulated community, but stated that it expects that these costs were very low. In addition, DHS’s report did not include a recommended frequency of compliance inspections at facilities that use the program because, currently, there is no mandated frequency for any facility regardless of the type of security plan submitted. DHS noted that it would prioritize conducting an initial compliance inspection at an expedited facility over inspection of a similar facility that received approval of a traditional (i.e., standard) security plan or Alternative Security Program, in part, because that would be the first inspection conducted at the expedited facility. In addition, the report stated that, among other things, it was difficult to assess the effect of the EAP on DHS operations and the operations of facilities because only a single facility had participated in the EAP at the time the report was issued. Our analysis of the DHS report and follow-up discussions with ISCD officials is discussed below.

Assess the number of eligible facilities that used the EAP versus the standard process to develop and submit a site security plan. DHS reported that, as of June 2, 2016, it assigned a final tier of 3 or 4 to 2,244 facilities (806 tier 3 facilities and 1,438 tier 4 facilities). Of these facilities, only one facility (a tier 4 facility) submitted an expedited security plan, while 2,194 facilities had submitted a security plan or Alternative Security Program using the standard process, and 49 facilities had yet to submit a security plan or Alternative Security Program.

Assess the EAP’s impact on the backlog for site security plan approvals and authorization inspections. DHS reported that, with only a single facility electing to submit an expedited security plan, the EAP had no noticeable impact on DHS’s projected completion date for all authorization inspections and site security plan approvals. ISCD officials told us that if enough facilities use the EAP in the future, DHS would evaluate the EAP’s effect on its CFATS operations.

Assess the ability of EAP facilities to submit sufficient site security plans. DHS reported that the only facility to submit an expedited security plan was able to submit a sufficient plan.

Assess any impact of the EAP on the security of chemical facilities. DHS reported that it is difficult to assess the impact of the EAP on the security of chemical facilities because only one facility submitted an expedited security plan. DHS noted that the public availability of the EAP guidance would likely have a positive impact on chemical facility security because the guidance can serve as reference material for any facility looking to develop a security plan, regardless of whether that facility is regulated under CFATS. ISCD officials told us that if enough facilities use the EAP in the future, DHS would evaluate the EAP’s effect on the security of chemical facilities.

Identify any costs and efficiencies associated with the EAP. DHS reported that it expended significant internal resources to comply with the statutory requirement to develop an EAP, but DHS did not quantify the cost associated with the EAP. According to DHS, the resources expended included costs to develop EAP processes and procedures, and develop the associated guidance and outreach materials. ISCD officials told us that most of DHS’s initial costs were for salary and benefits for federal employees working on the EAP, including policy, compliance, and legal staff who developed the EAP guidance, and information technology staff who updated the Chemical Security Assessment Tool. However, ISCD officials also told us that they were unable to quantify these costs because headquarters employees are only required to track overall hours worked each day versus time spent on individual tasks. ISCD officials stated that they have expended, and expect to continue to expend, minor funding amounts to keep the EAP operational. DHS also reported that it was unable to discern how much time and resources members of the regulated community or other stakeholders expended on activities, such as reviewing EAP proposals or considering whether to use the EAP. However, DHS stated that it expects that EAP costs to the regulated community were very low.

Recommend the frequency of compliance inspections that may be required for EAP facilities. DHS discussed factors that can influence the frequency of compliance inspections, but did not quantify a recommended frequency for facilities in the EAP because, currently, there is no mandated frequency for any facility regardless of the type of security plan submitted. According to DHS, a variety of factors can influence the frequency of compliance inspections regardless of the type of site security plan the facility submits, including the facility’s risk-based tier and previous compliance history, the corporate owner’s compliance history, and the number and type of planned measures in the facility’s approved security plan. The report also stated that DHS would consider if a facility elected to submit an expedited security plan when determining the timing of the facility’s initial compliance inspection and frequency of subsequent inspections. Although DHS did not quantify a recommended frequency of compliance inspections, it noted that the election to use an expedited security plan would have the most impact on scheduling the initial compliance inspection because that would be the first inspection DHS would conduct at the facility. In addition, DHS would prioritize conducting an initial compliance inspection at an expedited facility over inspection of a similar facility that received approval of a traditional (i.e., standard) security plan or Alternative Security Program.

Low EAP Participation May Be Due to Various Factors

Two Chemical Facilities Have Used the EAP since Its Inception

According to DHS, as of April 2017, 2 of the 2,496 eligible facilities had used the EAP since ISCD implemented it; however, one of the two facilities was no longer in the EAP because ISCD no longer considers the facility to be high risk. ISCD had approved both facilities’ expedited security plans—one before DHS issued the aforementioned report to Congress and one after the report. ISCD officials stated that they have not assessed why only two facilities have used the EAP and do not intend to do so because they did not have a preconceived number of facilities that they expected to use it. They also said that the EAP is one of three options—the expedited security plan, the standard security plan, and the Alternative Security Program—that tier 3 and tier 4 facilities can use. ISCD does not encourage facilities to use the EAP or discourage facilities from using it because facility officials are in the best position to decide which approach is the best option for their facility.

Officials representing the two EAP chemical facilities told us that their companies involve small operations that store a single chemical of interest on site and do not have staff with extensive experience or expertise in chemical security. Officials from both facilities said they used the EAP instead of a standard site security plan or Alternative Security Program because the EAP would reduce the time and cost to prepare and submit their security plans. Officials from both facilities also stated that the EAP’s prescriptive nature helped them to quickly determine the security measures required to be in their site security plans. For example, the contractor who prepared the site security plan for one of the two EAP facilities said that the facility probably saved $2,500 to $3,500 in consulting fees by using the EAP instead of a standard security plan. According to ISCD, the first compliance inspection at the one remaining EAP facility is scheduled to start later in calendar year 2017.

ISCD and Stakeholders Identified Several Factors That May Explain Why the EAP Has Not Been More Widely Used

ISCD and industry stakeholders we interviewed identified several factors that may explain why the EAP has not been more widely used, as discussed below.

Timing of the EAP’s Implementation. ISCD officials stated that the timing of the EAP’s implementation may be the primary reason that only two facilities have used it. The officials explained that, by the time ISCD had implemented the EAP, the majority of eligible facilities had already submitted standard site security plans or Alternative Security Programs to ISCD, so it was not worthwhile for the facilities to start over again to use the EAP. For example, ISCD officials told us that they had already approved standard security plans and Alternative Security Programs from about 61 percent (1,463 of approximately 2,400) of facilities that had been assigned to tier 3 or tier 4 prior to the EAP’s implementation. Also, officials from 5 of the 11 industry organizations we interviewed stated that the timing of the EAP’s implementation resulted in limited interest in using the EAP.

Prescriptive Nature of the EAP. As previously discussed, the CFATS Act of 2014 required DHS to develop specific security measures for the EAP that are sufficient to meet Risk-Based Performance Standards. ISCD officials and officials from 6 of the 11 industry organizations we interviewed stated that the prescriptive security measures required in the expedited security plan likely deterred some facilities from using the EAP. According to ISCD officials, some industry officials think that certain EAP- required security measures are too strict for tier 3 and tier 4 facilities. Officials we interviewed from 5 of the 11 industry organizations said that some, if not most, EAP-required security measures are more robust or strict than they should be for tier 3 and tier 4 facilities; however, officials from a Sector Coordinating Council and a member organization said that the EAP’s required security measures are fair or appropriate for tier 3 and tier 4 facilities. ISCD officials agreed that some EAP required security measures are strict because the CFATS Act of 2014 requires that DHS develop specific security measures and approve expedited security plans that are determined to not be facially deficient based only on a review of the plan. For example, an industry official told us that a security measure pertaining to screening and inspection of vehicles is too strict. Specifically, the EAP guidance states that a facility must screen and inspect all vehicles for firearms, explosives, or certain materials prior to allowing vehicles access to the facility’s perimeter by visually inspecting the vehicle, using a trained explosive detection dog team, under/over vehicle inspection systems, or cargo inspection systems. ISCD officials told us that this security measure is required because ISCD would not be able to evaluate the capability of a facility’s random or percentage-based screening and inspection program by doing a review of the facility’s expedited security plan; therefore, ISCD requires that EAP facilities apply this requirement to all vehicles prior to accessing a facility’s perimeter.

However, ISCD officials and officials from 4 of 11 industry organizations also stated that the EAP’s prescriptive measures actually could encourage some facilities to use the EAP. For example, officials from an industry organization stated that smaller facilities often lack staff with the expertise needed to prepare a standard site security plan or Alternative Security Program and may prefer the EAP because it clearly states what a facility is required to do to meet security measures. This was consistent with the views of the officials representing the two facilities that submitted EAPs, as discussed earlier.

Lack of an Authorization Inspection under the EAP. As previously discussed, ISCD conducts an authorization inspection at facilities using the standard process, but does not conduct this inspection at facilities using the EAP. ISCD officials stated that the lack of an authorization inspection under the EAP may discourage some facilities from using it because some facility officials have told ISCD that this inspection provides useful information about their facility’s security. However, ISCD officials also said that some facilities may prefer the lack of an authorization inspection under the EAP because this expedites the approval process for a site security plan compared to the process for a standard security plan or Alternative Security Program.

Certification Form Required for the EAP. An ISCD official and an industry official we interviewed told us that the certification form that a facility official must sign under penalty of perjury and submit to ISCD with the expedited security plan, may deter some facilities from using the EAP. For example, the DHS official stated that the form contains strict requirements and could result in the signing official being legally liable and subject to penalties in certain circumstances. However, officials for the two facilities that submitted expedited security plans and certification forms to ISCD told us that they were not concerned about signing the form.

The Effect of Recent Changes to the CFATS Program on Future Use of the EAP Is Uncertain

Two other factors that could influence facilities’ participation in the EAP are the introduction of revised processes for (1) facilities to provide information to ISCD and (2) ISCD to determine the risk tier for each facility. ISCD officials stated that, in fall 2016, they implemented a revised Chemical Security Assessment Tool for facilities to provide information to ISCD in response to industry concerns, such as asking facilities to answer duplicate questions. In the same time frame, ISCD implemented a revised risk-tiering methodology in response to our prior reports and stakeholder concerns about not addressing all elements of risk (threat, vulnerability, and consequence). ISCD officials said they revised the risk-tiering methodology to enhance its ability to consider the elements of risk associated with a terrorist attack.

The revised Chemical Security Assessment Tool, called the Chemical Security Assessment Tool 2.0, includes a revised Top-Screen and a streamlined version of the standard site security plan. ISCD officials said that a primary reason they revised the assessment tool was to eliminate duplication and confusion associated with the original standard security plan. The streamlined security plan, in ISCD officials’ view, flows more logically, is more user-friendly, requires facility officials to write less narrative, does not have ambiguous questions, and pre-populates data from one part to another, so users do not have to re-type the same information multiple times. According to ISCD officials, industry feedback about Chemical Security Assessment Tool 2.0 has been very positive. Officials in 9 of the 11 industry organizations we interviewed told us that they have positive views about the revised assessment tool and that it is better than the original assessment tool. For example, officials from 5 of the 11 industry organizations stated that ISCD had improved the assessment tool by streamlining or eliminating duplicative questions. If the updated tool proves easier to use, it could affect future interest in using the expedited program.

Regarding the revised tiering methodology, ISCD initiated a phased approach to re-tier about 27,000 facilities. ISCD officials said these facilities must re-submit Top-Screens using Chemical Security Assessment Tool 2.0 and the revised tiering methodology will be used to determine if each facility is high risk and, if so, assign the appropriate risk tier to the facility. According to a senior ISCD official, the re-tiering efforts are resulting in shifts in the risk assessments for some facilities due to the revised tiering methodology and because many facilities have not submitted new information in 7 or 8 years; however, dramatic shifts in the risk tiers of a large number of facilities are not expected. Nevertheless, ISCD is uncertain about the effect that Chemical Security Assessment Tool 2.0 and the revised tiering methodology will have on the future use of the EAP because ISCD cannot predict the extent to which facilities may be re-assigned from tier 1 or tier 2 to tier 3 or tier 4, or vice versa; assigned to tier 3 or tier 4 and submit an expedited security plan instead of a streamlined standard plan or Alternative Security Program, or vice versa; new to CFATS and assigned to tier 3 or tier 4; or no longer considered to be high risk.

Given that only one facility is currently covered by the EAP, and about 27,000 facilities are to ultimately re-submit Top-Screens using Chemical Security Assessment Tool 2.0 and be tiered using the revised tiering methodology, it is too early to tell what impact, if any, the revised CFATS process will have on the future use of the EAP.

Agency Comments

We provided a draft of this report to DHS for review and comment. DHS did not provide formal comments, but did provide a technical comment, which we incorporated, as appropriate.

We are sending copies of this report to interested congressional committees and the Secretary of Homeland Security. In addition, the report is available at no charge on the GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact me at (404) 679-1875 or CurrieC@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. Key contributors to this report are listed in appendix II.

Appendix I: Example of a Section in an Expedited Approval Program Site Security Plan

The following security measures are from Section D of the site security plan example for the Expedited Approval Program. For facilities that prepare an expedited security plan and submit it to the Department of Homeland Security (DHS), facility officials are to put a checkmark next to each applicable security measure that the facility has in place. For each applicable security measure that the facility does not have in place, facility officials are to explain the security measure planned to be implemented in the next 12 months. If the facility has a material deviation from a security measure, facility officials are to explain compensatory measures that provide comparable security.

Section D: Response Measures (Risk-Based Performance Standards 9, 11, 13, and 14)

D.1 Response Planning

D.1.1 ___ The facility has a defined emergency and security response organization in order to respond to site emergencies and security incidents.

D.1.2 ___ The facility has a crisis management plan which includes emergency response procedures, security response plans, and post- incident security plans (post-terrorist attack, security incident, natural disaster, etc.).

For Release facilities only: D.1.2.1 ___ The facility has additional portions to their crisis management plan, which include emergency shutdown plans, evacuation plans, re-entry/recovery plans, and community notification plans to account for response to Release chemicals of interest. ___ The facility is not regulated for Release chemicals of interest.

D.1.3 ___ The facility has designated individual(s) responsible for executing each portion of the crisis management plan and individual(s) have been trained to execute all duties.

D.1.4 ___ The facility has the appropriate resources (staff, emergency/response equipment, building space, communications equipment, process controls/safeguards, etc.) to execute all response plans. Emergency equipment includes at least one of the following:

A radio system that is redundant and interoperable with law enforcement and emergency response agencies.

At least one backup communications system, such as cell phones/desk phones.

An emergency notification system (e.g., a siren or other facility-wide alarm system).

Automated control systems or other process safeguards for all process units to rapidly place critical asset(s) in a safe and stable condition and procedures for their use in an emergency.

Emergency safe-shutdown procedures for all process units.

D.1.5 ___ All facility personnel have been trained on all response plans and response plans are exercised on a regular basis and at a minimum of biennially.

D.1.6 ___ The facility has an active outreach program with local first responders (Police Department and Fire Department) which includes providing response documentation to agencies, providing facility layout information to agencies, inviting agencies to facility orientation tours, notifying agencies of the facility’s chemicals of interest (regulated chemicals of interest and other chemical holdings identified on Appendix A) and security concern, and maintaining regular communication with agencies.

D.2 Elevated and Specific Threats (Risk-Based Performance Standards 13 and 14):

D.2.1 ___ The facility has a documented process for increasing security measures commensurate to the designated threat level during periods of elevated threats tied to the National Terrorism Advisory System and when notified by DHS of a specific threat.

D.2.2 ___ The facility will begin to execute security measures for elevated and specific threats within 8 hours of notification.

D.2.3 ___ The facility will execute the following measures as a result of an elevated or specific threat:

Coordinate with Federal, state, and local law enforcement agencies.

Increase detection efforts through either dedicated monitoring of security systems (Intrusion Detection System (IDS) or Closed Circuit Television (CCTV)), increased patrols of the perimeter and/or asset area(s), or stationing of personnel at access points and/or asset area(s).

For Theft/Diversion and Sabotage facilities only, increase frequency of outbound screening and inspections.

For Sabotage facilities only, increase monitoring of outbound shipments.

For Release facilities only, increase frequency of inbound screening and inspections.

Response Planned Measures

Material Deviation

Appendix II: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

In addition to the contact named above, John Mortin, Assistant Director, and Joseph E. Dewechter, Analyst-in-Charge, managed this audit engagement. Chuck Bausell, Michele Fejfar, Tracey King, Michael Lenington, and Claire Peachey made significant contributions to this report.