In accordance with the United States International Broadcasting Act of 1994, as amended, BBG manages and oversees all U.S. civilian international broadcasting, including the federal entities VOA and OCB and the grantees MBN, RFA, and RFE/RL. Collectively, these entities include 69 language services that produce content in 59 languages for radio, television, the Internet, mobile devices, and social media in more The International Broadcasting Bureau provides all than 100 countries.support services to BBG, oversight over grantee operations, and transmission and distribution services to BBG entities. BBG is managed by a nine-member part-time bipartisan Board of Governors. As an element of U.S. public diplomacy, BBG is to be responsive to U.S. foreign policy and national security priorities while maintaining editorial independence. All BBG entities are required to provide news and information that is consistently reliable, authoritative, accurate, objective, and comprehensive. VOA provides global, U.S., and local news, as well as information on U.S. policies, to people living in closed societies. OCB provides news and information to the people of Cuba. The role of the grantee broadcasters--MBN, RFA, and RFE/RL--is to operate as surrogates for the local media in countries where a free and open press does not exist. Following specific foreign policy challenges over the last decade, Congress created the five broadcasting entities that compose BBG. In some instances, BBG entities were created or directed to broadcast in languages and countries where VOA was already present. BBG officials noted, for example: The International Broadcasting Act authorized RFA in 1994 to broadcast in seven Asian countries where VOA already broadcast. In 2009, a House of Representatives Committee on Appropriations report and a Senate Committee on Appropriations report directed BBG to provide an increase in daily broadcast hours for VOA's language service in the Afghanistan-Pakistan region (Deewa Radio) while also calling for the establishment of an RFE/RL radio program (Radio Mashaal) in the region. Figure 1 shows the creation of BBG entities since 1942. Figure 2 describes each BBG entity's mission and shows the amount of appropriated funds each entity received in fiscal year 2012. BBG annually conducts a language service review, as required by law, intended to help the agency make decisions regarding allocating resources to language services. In conducting the language service review, BBG considers foreign policy priorities, the domestic media environment in countries that receive BBG broadcasts, audience research, and the impact of BBG programming. BBG uses the review to determine which language services should be enhanced or added and which services to recommend for closure or reduced funding. From 2001 through 2012, BBG eliminated 20 language services, including VOA's Czech, Polish, and Slovak services and RFE/RL's Czech and Slovak services. In its fiscal year 2009 through 2013 annual budget requests, BBG has proposed to eliminate additional language services, including two services that overlap with another service. In response to BBG's proposals, Congressional appropriations committees, which have jurisdiction over BBG funding, in some years have directed the continuation of the language services. Nearly two-thirds of the BBG language services--that is, offices that produce content for particular languages and regions--overlap with another BBG service by providing programs to the same countries in the same languages. BBG's 2012-2016 strategic plan identifies the need to reduce overlap among its language services. However, BBG's annual language service reviews have not systematically considered the cost and impact of overlap. We identified 23 instances of overlap, involving 43 of BBG's 69 language services (62 percent), where two services provide programming to the same countries in the same languages. For example, in 8 instances involving 16 services, a VOA service and an RFA service overlapped. Figure 3 shows the extent of overlap among BBG language services as of June 2012. (See app. II for a detailed list of BBG language services.) Of the 43 language services that overlap in terms of language and country, 91 percent (39 services) also overlap in terms of platform (i.e., radio or television).broadcast on the same platforms, while in others, such as Ukraine, RFE/RL broadcasts only by radio and VOA broadcasts only on television. In almost all countries, the overlapping entities BBG officials noted some benefits of its overlapping language services, such as the availability of news from various sources in countries of strategic interest to the United States. In addition, BBG officials noted that in authorizing more than one entity to undertake international broadcasting, the statutory structure appears to envision that some overlap in activities may be necessary to achieve U.S. government objectives. However, these officials acknowledged that overlap among its language services reduces the funding available for other BBG broadcasts, including those that may have greater impact. BBG officials emphasized that overlapping language services are sometimes distinguished by their broadcast hours or purpose and content. Broadcast hours. BBG officials told us that overlapping language services generally coordinate with one another to broadcast at different hours of the day to ensure that audiences are able to access programs from both services. For example, VOA officials from the Farsi language service told us that VOA and RFE/RL collaborate to avoid overlap and do not broadcast on the radio simultaneously. BBG officials also said that overlapping services coordinate regarding their broadcast hours even if using different platforms. Purpose and content. BBG officials said that VOA and the grantee broadcasters have different purposes and that flexibility in their governing laws allows some overlapping content. The officials noted that according to those laws, VOA must represent the United States, presenting and explaining the country's policies in addition to providing accurate news. In contrast, the grantee broadcasters, in their surrogate role, generally act as regional or local news providers, with less emphasis on international news and limited discussion of U.S. policies or interests. However, BBG officials noted that the entities' mandates and missions allows for some flexibility related to programming content. For example, the International Broadcasting Act states that in order to be effective, VOA must win the attention and respect of listeners. According to BBG officials, to attract a larger audience and to provide fuller news coverage, some VOA language services produce not only news about the United States and the views of the U.S. government but also local news, which a BBG grantee might also broadcast in the same language and country. BBG officials stated that the roles of VOA and grantee broadcasters when both VOA and a grantee broadcast in a particular country and language are not clearly established. For example, it is not clear whether, in such cases, VOA should provide strictly U.S. and international news and the grantee should provide strictly local and regional news or whether the types of content they provide can, or should, overlap. BBG officials told us that this can lead to overlapping content. For example, officials from Deewa Radio (VOA) stated that they sometimes cover the same news stories, with similar content, as Radio Mashaal (RFE/RL) in the same region. Although BBG has identified the need to reduce overlap among its broadcast entities' language services, BBG has not systematically considered the cost or impact of such overlap as part of its annual language service review process. The International Broadcasting Act, as amended, directs BBG to consider issues related to overlap, such as duplication, among some language services. For example, the law requires that grant agreements to RFE/RL shall include a provision stating that duplication of language services and technical operations between RFE/RL and VOA should be reduced to the extent appropriate, as determined by BBG's Board of Governors. In addition, the law gives the board authority to identify areas in which broadcasting activities could be made more efficient and economical. In its strategic plan for 2012-2016, BBG addresses language service overlap and recognizes the need to streamline and improve coordination and efficiency. The plan states that BBG found that its language services overlapped significantly and that the agency could not easily manage its resources for highest impact and efficiency. In the plan, BBG states in general terms that it will end language services in countries that have more developed, independent media and that are no longer strategic priorities; however, the plan does not describe specific steps for achieving this goal. The plan also states that where there are two broadcast entities operating in a given country, they will cooperate--with shared bureaus, freelance reporters, and distribution networks--and will provide complementary, not duplicative, content. According to BBG officials, some entities already cooperate with each other to share resources and maximize efficiency. For example, VOA and RFE/RL staff share office space in Afghanistan and collaborate on their Persian service to share news agendas and reduce duplication of effort. BBG officials also said that the agency's proposed management reforms included in the strategic plan may enhance their ability to increase coordination, reduce overlap, and create a more integrated and efficient organization. Although BBG's strategic plan includes a general proposal to reduce language service overlap, BBG's annual language service review--the agency's primary method of prioritizing broadcast languages and planning resource allocations--does not systematically consider the cost and impact of language service overlap. BBG's language service review is intended to help the agency make decisions regarding allocating resources to language services by considering factors such as foreign policy priorities and the domestic media environment in countries that receive BBG broadcasts. The resulting Annual Language Service Review Briefing Book provides detailed data for all language services, including information regarding the media and political environments in which the services operate. example, when more than one BBG entity broadcasts in a language--it does not discuss the cost or impact associated with this overlap. BBG officials stated that the methodology for the language service review does not include an assessment of the cost and impact of overlapping language services because officials are already well aware of overlap among their language services and because the law has not required BBG to include assessments of overlap as part of its annual language service review. For example, BBG considers the Media Sustainability Index, which measures a number of contributing factors of a well-functioning media system and considers both traditional media types and new media platforms. Among its other measures, the index includes a measure of plurality of news sources. associated with maintaining the 43 overlapping language services is about $149 million, or nearly 20 percent of BBG's total appropriations for fiscal year 2011. This amount represents the sum of the total cost for all overlapping language services, including employee salaries, benefits, and general operating expenses, as reported in BBG's Annual Language Service Review Briefing Book from fiscal year 2011. This amount exceeds the potential savings from eliminating or reducing overlap. The amount of money that could be saved by reducing or eliminating overlapping language services would depend on a variety of factors, including which services were reduced or eliminated, which transmission assets or broadcast hours were reduced or transferred, and whether staff and other resources from an eliminated service were transferred to the remaining services. More than half of BBG's broadcast languages are used by other international broadcasters, although these broadcasters' objectives differ from those of BBG. Specifically, we found that U.S. commercial broadcasters transmit in 7 of the 59 BBG languages and target different audiences, and other democratic nations' government-supported broadcasters transmit in over half of BBG languages, but each represents the unique perspectives and interests of its respective country. BBG's annual language service review has not systematically considered the activities of these broadcasters, and as a result BBG risks missing opportunities to strengthen its allocation of resources. BBG and the other international broadcasters we reviewed broadcast in many of the same languages, although their objectives differ. The U.S. commercial international broadcasters that we identified, including CNN International and Fox News, broadcast in 7 of the 59 languages that BBG uses. Officials from both BBG and commercial broadcasters said that they target different audiences and consider their approaches to providing content to be distinct. Commercial broadcasters are often not present in smaller markets where vernacular languages are spoken, because these markets offer little potential for generating profit.broadcasters may target audiences such as business people and other professionals. For example, officials from one network told us they target U.S. citizens outside the United States, including travelers and expatriates. In contrast, BBG targets foreign audiences. Moreover, commercial broadcasters generally provide broad international or regional programming as opposed to the more localized content that BBG entities often provide. Collectively, major government-supported international broadcasters from other democratic nations--Audiovisuel Exterieur de la France (AEF), the British Broadcasting Corporation World Service (BBC), Deutsche Welle (DW), and Radio Netherlands Worldwide (RNW)--transmit programs in 35 of the 59 languages that BBG uses (see fig. 4). These broadcasters transmit programs in 10 languages that BBG does not use. (For the full list of languages used by the democratic nations' broadcasters, see app. III.) Representatives of other democratic nations' government-supported international broadcasters generally told us that they coordinate with each other and BBG on issues such as broadcast transmission and audience research. However, most of these broadcasters do not consider the presence of, or coordinate with, other international broadcasters when determining whether to transmit in a given language or country, because their objectives differ in several ways. Democratic nations' international broadcasters focus on respective national interests. According to the broadcasters' representatives, no nation's international broadcaster can accurately represent the interests, perspectives, values, and culture of another nation. AEF, DW, BBC, and RNW's missions are to represent, respectively, the French, German, British, and Dutch perspectives on international news and events in an independent and unbiased manner. Although democratic nations' broadcasters represent many of the same perspectives on values such as democracy and freedom of speech, the representatives stated that their countries' particular perspectives cannot be accurately represented by another country's international broadcaster. Democratic nations' international broadcasters have different substantive and geographic targets. The focus and target audiences of democratic nations' broadcasters' programming differ significantly, according to the broadcasters' representatives. For example, while DW aims to provide thorough information to opinion makers and to emphasize human rights issues, BBC aims to serve as the premiere independent and unbiased global news provider. RNW recently adopted a narrower focus, targeting individuals between the ages of 15 and 30 and focusing on free speech. Representatives of democratic nations' broadcasters also indicated that foreign policy priorities may weigh in favor of a broadcaster's presence in a given language even when other broadcasters are present. For example, partly because of the current strategic importance of the Middle East, BBG, BBC, DW, AEF, and RNW all broadcast in Arabic. Additionally, broadcasters told us they believed that the presence of multiple democratic nations' broadcasters in the same broadcast language can be positive and provide multiple perspectives in countries in which the press is not free. Representatives of these major democratic nations' broadcasters further suggest that the surrogate role served by BBG grantees--MBN, RFA, and RFE/RL--is a distinct U.S. contribution to the context of government- supported international broadcasting. According to the representatives, other democratic nations' broadcasters present their countries' perspectives, but their primary functions generally do not include acting as indigenous media or providing local news and information in countries in which press freedom is limited or nonexistent. Other democratic nations' broadcasters have faced declining budgets in recent years and have consequently reduced their broadcasting and implemented other organizational changes. For example, RNW's budget decreased by 70 percent from 2012 to 2013 (from approximately $60 million to $18 million), and BBC World Service's budget decreased by 11 percent from 2009 to 2012 (from approximately $402 million to $356 million). To cope with declining resources, broadcasters have taken steps such as restructuring their organizations and changing their program formats and distribution. For example, the broadcasters have significantly reduced their broadcasts in shortwave radio, which are more expensive to maintain than are other broadcast platforms. In addition, BBC eliminated five language services and moved other services from radio transmission to Internet only. In early 2013, RNW will reduce its number of broadcast languages from ten to five and will end direct distribution on platforms other than the Internet. The International Broadcasting Act contains 18 standards and principles for U.S. international broadcasting, including that U.S. international broadcasting shall not duplicate the activities of private U.S. broadcasters or of other democratic nations' government-supported broadcasting entities. BBG officials stated that the agency is in compliance with this principle. The law does not specify, however, that BBG should assess duplication in its annual language service reviews. Moreover, BBG officials noted that the law provides BBG broad latitude on how to interpret duplication and that the term should be considered in the context of BBG's overall authorities and responsibilities. BBG officials stated that to maximize the impact of its resources, BBG should be aware of, and complement, the efforts of commercial U.S. broadcasters and of other democratic nations' broadcasters. BBG's annual language service review generally considers the broadcast alternatives available to targeted audiences by identifying the most significant broadcasters in each market BBG serves. The resulting briefing book lists the top 10 sources of news in each market. However, the language service review process does not systematically identify the languages used, and the countries served, by other major democratic nations' international broadcasters and U.S. commercial broadcasters. Further, it does not assess the extent to which these broadcasters provide similar or complementary alternatives to BBG broadcasts. BBG officials noted that the law has not required that the annual language service review consider other international broadcasters. BBG officials also stated that individual BBG entities are well informed about the broadcast activities of relevant commercial international broadcasters and other democratic nations' broadcasters. However, without regularly reviewing and documenting the activities of other international broadcasters, BBG risks missing opportunities to better allocate its resources. U.S. public diplomacy efforts rely on U.S. international broadcasting to communicate directly with audiences in countries with limited journalism alternatives. Over the past 70 years, Congress authorized five separate entities to broadcast news and information throughout the world to address new foreign policy priorities, and these entities overlap substantially with one another in the countries and languages they serve. BBG's strategic plan for 2012-2016 broadly recognizes the need to reduce overlap and reallocate limited resources to broadcasts that will have the greatest impact. However, by not systematically considering the cost and impact of overlap in its annual language service reviews--BBG's primary method of prioritizing broadcast languages and planning resource allocations--the agency risks missing opportunities to reduce overlap as appropriate, strengthen impact, and improve coordination among its entities. Further, without systematically considering the activities of other international broadcasters in its annual language service review, BBG also may be missing opportunities to better allocate its resources in order to maximize the impact of U.S. international broadcasting. To strengthen BBG's efforts to streamline and maximize the impact of U.S. international broadcasting, we recommend that BBG's Board of Governors take the following two actions: Ensure that BBG's annual language service review includes systematic consideration of the cost and impact of internal overlap among BBG entities' language services. Ensure that BBG's annual language service review includes systematic consideration of the activities of U.S. commercial broadcasters and other democratic nations' broadcasters, such as the languages used and the countries served. We sent a draft of this report to BBG, State, and USAID for comment. BBG provided written comments, which are reprinted in appendix IV, as well as technical comments, which we incorporated as appropriate. State and USAID had no comments. We also sent excerpts of the draft to the U.S. commercial broadcasters and other major democratic nations' government-supported international broadcasters that we reviewed, and we incorporated their comments as appropriate. In its written comments, BBG agreed with our recommendations and said that it had begun the planning necessary to include a more in-depth and systematic review of overlapping language services in its annual language service review and that it would assess the countries served and languages broadcast by other commercial and government- sponsored broadcasters. BBG noted that it broadly agreed with our presentation of the challenges involved in addressing overlap and offered several comments on the issues we discussed in the draft report. First, BBG noted that its spending in fiscal year 2011 to maintain language services broadcasting in the same countries and languages--$149 million--represented the baseline budget for the 43 overlapping language services we identified but not the amount that could be saved if overlapping services were eliminated. For example, BBG stated that some overlap may be necessary and beneficial, and that, in some cases, the overlap resulted from statutory mandates. In addition, BBG noted that its strategic plan for 2012-2016 recognized the existence of overlapping language services and that it had introduced proposals to reduce unnecessary overlap. BBG further noted that enhancing the programming and operations of two language services in distinct organizations is a complex and sensitive undertaking. In each case, and as BBG acknowledged, our draft report generally reflected this information. Including a more in-depth and systematic assessment of overlapping language services in its annual language service review will provide BBG with an opportunity to balance these considerations, improve its operational efficiency, and maximize the impact of U.S. international broadcasting. We are sending copies of this report to interested congressional committees and to BBG, State, and USAID. In addition, the report is available at no charge on the GAO website at http://www.gao.gov. Should you or your staff have questions concerning this report, please contact me at (202) 512-3665 or dinapolit@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. Other key contributors to this report are listed in appendix V. This report examines the extent to which (1) Broadcasting Board of Governors (BBG) language services overlap with one another, and (2) BBG broadcasts in the same languages as other international broadcasters. To examine BBG language service overlap, we reviewed laws, reports, and other documents related to U.S. international broadcasting, including BBG's strategic plan for 2012-2016 and its 2011 Annual Language Service Review Briefing Book. In particular, we reviewed the United States International Broadcasting Act of 1994, as amended, and other laws relevant to the five BBG entities--federal entities the Voice of America (VOA) and Office of Cuba Broadcasting (OCB), and nonprofit grantees Middle East Broadcasting Networks, Inc. (MBN), Radio Free Asia (RFA), and Radio Free Europe/Radio Liberty (RFE/RL). We obtained and reviewed BBG's interpretation of the International Broadcasting Act provisions related to overlap and duplication. We also reviewed information from BBG on the broadcast coverage of each entity, by country, language, and platform. To assess language service overlap among BBG entities, we identified instances in which the language services of two BBG entities broadcast in the same language and country, and we calculated the percentage of language services that overlap with another BBG language service. In our calculations, each instance of overlap involved two overlapping services. Some language services produce content in multiple languages; for those, we considered the language service to overlap if any of its languages overlapped with other BBG services. In addition, we counted BBG's services in English, English to Africa, and Special English/Learning English as one language service. To obtain views about the causes and impact of overlap, we interviewed officials from BBG, the Department of State, and the U.S. Agency for International Development, as well as experts from U.S. and international organizations. We visited and conducted interviews at the headquarters of VOA (Washington, D.C.), MBN (Springfield, Va.), RFA (Washington, D.C.), and RFE/RL (Prague, Czech Republic), and we interviewed OCB officials by telephone. We also reviewed BBG's methodology for its annual language service review and described the extent to which it included consideration of the cost and impact of overlap. We did not analyze the content of broadcast programs, overlap in BBG administrative or technical operations, or management and administrative streamlining proposals. To examine the extent to which BBG broadcasts in the same languages as other international broadcasters, we interviewed representatives of U.S. commercial broadcasters and democratic nations' government- supported international broadcasters. Through interviews with the National Association of Broadcasters, the Association for International Broadcasting, and other experts, we identified several U.S. commercial broadcasters that provide general news programming to audiences outside the United States. We conducted interviews with representatives of two of these broadcasters: Fox News and CNN International. We interviewed major democratic nations' international broadcasters-- Audiovisuel Exterieur de la France (AEF), the British Broadcasting Corporation World Service (BBC), Deutsche Welle (DW), and Radio Netherlands Worldwide (RNW)--as well as several other public international broadcasters, including Voice of Russia. We interviewed some international public broadcasters at a global media forum in Bonn, Germany, and others by telephone. For both U.S. commercial broadcasters and democratic nations' international broadcasters, we reviewed information on their objectives and the languages in which they broadcast, and we compared these to BBG objectives and broadcast languages. We assessed BBG's processes for compiling information on the broadcast languages used and countries served by BBG entities' language services, and we determined that these data were adequate and sufficiently reliable for the purposes of our review. We conducted this performance audit from February 2012 to January 2013 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives. Voice of America (VOA) Africa Division Central Africa (Kinyarwanda, Kirundi) Horn Of Africa (Amharic, Tigrigna, Afaan Oromoo) Office of Cuba Broadcasting (OCB) Radio Free Europe/Radio Liberty (RFE/RL) Balkans (Bosnian, Macedonian, Serbian, Albanian, Montenegrin, Croatian)* Radio Farda (Persian)* Radio Free Afghanistan (Dari and Pashto)* Radio Mashaal (Pashto)* Radio Free Iraq (Arabic)* North Caucasus Unit (Avar, Chechen and Circassian) Tatar-Bashkir (Tatar, Crimean Tatar, Bashkir) Radio Free Asia (RFA) Middle East Broadcasting Networks (MBN) Swahili (Kiswahili) In addition to the contacts named above, Jason Bair (Assistant Director), Marissa Jones, Mary Moutsos, Ashley Alley, Qahira El'Amin, Julia Jebo Grant, and Reid Lowe made key contributions to this report. Additional assistance was provided by Mike Courts, Etana Finkler, Dave Hancock, Julia Ann Roberts, Mike Rohrback, Mike Silver, and Mike ten Kate.

Summary:
U.S. international broadcasting is intended to communicate directly with audiences in countries with limited journalism alternatives and to inform, engage, and connect people around the world. BBG oversees two U.S. government entities--Voice of America and the Office of Cuba Broadcasting-- and three nonprofit grantees that act as surrogates for local media--Middle East Broadcasting Networks, Inc.; Radio Free Asia; and Radio Free Europe/Radio Liberty. In 2003, GAO found overlap among BBG's language services. In its strategic plan for 2012- 2016, BBG recognizes the need to reduce language service overlap. GAO was asked to review issues related to international broadcasting. This report examines the extent to which (1) BBG language services overlap with one another and (2) BBG broadcasts in the same languages as other international broadcasters. GAO reviewed laws, reports, and other documents related to U.S. international broadcasting; analyzed information on the BBG entities; and interviewed representatives of the five BBG entities and international broadcasters. Nearly two-thirds of the Broadcasting Board of Governors (BBG) language services--offices that produce content for particular languages and regions-- overlap with another BBG service by providing programs to the same countries in the same languages. GAO identified 23 instances of overlap involving 43 of BBG's 69 services. For example, in 8 instances involving 16 services, a Voice of America service and a Radio Free Asia service overlapped. Almost all overlapping services also broadcast on the same platform (i.e., radio or television). BBG officials noted that some overlap may be helpful in providing news from various sources in countries of strategic interest to the United States; however, they acknowledged that overlap reduces the funding available for broadcasts that may have greater impact. BBG budget information indicates that BBG spent approximately $149 million in fiscal year 2011 to maintain language services broadcasting in the same countries and languages--nearly 20 percent of its total appropriations. However, BBG has not estimated the potential savings and efficiencies from reducing unnecessary overlap. Further, BBG's annual language service review--its primary means of prioritizing broadcast languages and planning resource allocations--does not systematically consider the cost and impact of overlap. As a result, BBG may be missing opportunities to reduce overlap as appropriate, strengthen impact, and improve BBG entity coordination. More than half of BBG's broadcast languages are used by other international broadcasters--U.S. commercial international broadcasters and other major democratic nations' government-supported international broadcasters--although these broadcasters' objectives differ from BBG's. The U.S. commercial broadcasters that GAO identified transmit in seven of the BBG languages and target different audiences, with for-profit aims. Other democratic nations' broadcasters, including Germany's Deutsche Welle and the United Kingdom's BBC, transmit in 35 of the 59 BBG languages, although each broadcaster represents the unique perspectives and interests of its respective country. BBG's annual language service review generally considers the broadcast alternatives available to targeted audiences by identifying the most significant broadcasters in each market BBG serves. However, the review process does not systematically identify the languages used and the countries served by other international broadcasters, and it does not assess the extent to which these broadcasters provide similar or complementary alternatives to BBG broadcasts. As a result, BBG risks missing additional opportunities to better allocate its resources. GAO recommends that BBG systematically consider in its annual language service reviews (1) the cost and impact of overlap among BBG entities' language services and (2) the activities of other international broadcasters. BBG agreed with GAO's recommendations and reported taking initial steps to implement them.