IPP project proposals are prepared and submitted to DOE by officials from the participating national laboratories. Each national laboratory provides technical and financial oversight for a set of projects. An Inter-Laboratory Board (ILAB) serves as the primary coordinating body for the national laboratories involved in the program. Partnerships are formed by the national laboratories between U.S. companies—known as industry partners—and institutes in Russia and other countries. IPP project proposals are reviewed by DOE’s national laboratories, the IPP program office, and other agencies before they are approved for funding. Because the national laboratory prepares the proposal, the laboratory project manager is responsible for including, among other things, a list of intended participants and for designating the WMD experience for each participant. The proposed participants are assigned to one of the following categories: Category I—direct experience in WMD research, development, design, production, or testing; Category II—indirect WMD experience in the underlying technologies of potential use in WMD; or Category III—no WMD-relevant experience. After the project passes an initial review within the national laboratory, it is analyzed by the ILAB and its technical committees, which then forward the proposal to DOE for review. DOE, in turn, consults with State and other agencies on policy, nonproliferation, and coordination considerations. DOE’s IPP program office is responsible for making final decisions on all projects. DOE requires that at least 65 percent of each IPP project’s funding be used as payments to individuals actually working on the project or to the participating institutes in payment for project-related supplies, equipment, and overhead. Because the IPP program is not administered through a government-to-government agreement, DOE distributes IPP funding through three tax-exempt entities to avoid paying foreign taxes. These organizations transfer funds directly to the personal bank accounts of IPP project participants. To receive payment, project participants must submit paperwork to these organizations indicating, among other things, whether they possess WMD experience. DOE has not accurately portrayed the IPP program’s progress in the number of WMD scientists receiving DOE support and the number of long- term, private sector jobs created. Many of the scientists in Russia and other countries that DOE has paid through its IPP program did not claim to have WMD experience. Furthermore, DOE’s process for substantiating the weapons backgrounds of IPP project participants has several weaknesses. In addition, DOE has overstated the rate at which weapons scientists have been employed in long-term, private sector jobs because it does not independently verify the data it receives on the number of jobs created, relies on estimates of job creation, and includes in its count a large number of part-time jobs that were created. Finally, DOE has not revised the IPP program’s performance metrics, which are based on a 1991 assessment of the threat posed by former Soviet weapons scientists. A major goal of the IPP program is to engage former Soviet weapons scientists, engineers, and technicians, and DOE claims to have supplemented the incomes of over 16,770 of these individuals since the program’s inception. However, this number is misleading because this figure includes both personnel with WMD experience and those without any WMD experience, according to DOE officials. We reviewed the payment records of 97 IPP projects, for which information was available and complete, and found that 54 percent, or 3,472, of the 6,453 participants in these projects did not claim to possess any WMD experience in the declarations they made concerning their backgrounds. We also found that DOE is not complying with a requirement of its own guidance for the IPP program—that is, each IPP project must have a minimum of 60 percent of the project’s participants possessing WMD-relevant experience prior to 1991 (i.e., Soviet-era WMD experience). We found that 60 percent, or 58, of the 97 projects for which we had complete payment information did not meet this requirement. Finally, many IPP project participants that DOE supports are too young to have contributed to the Soviet Union’s WMD programs. Officials at 10 of the 22 Russian and Ukrainian institutes we interviewed said that IPP program funds have allowed their institutes to recruit, hire, and retain younger scientists. We found that 15 percent, or 972, of the 6,453 participants in the payment records of the 97 projects we reviewed were born in 1970 or later and, therefore, were unlikely to have contributed to Soviet-era WMD efforts. While DOE guidance for the IPP program does not prohibit participation of younger scientists in IPP projects, DOE has not clearly stated the proliferation risk posed by younger scientists and the extent to which they should be a focus of the IPP program. In 1999, we recommended that, to the extent possible, DOE should obtain more accurate data on the number and background of scientists participating in IPP program projects. DOE told us that it has made improvements in this area, including developing a classification system for WMD experts, hiring a full-time employee responsible for reviewing the WMD experience and backgrounds of IPP project participants, and conducting annual project reviews. However, DOE relies heavily on the statements of WMD experience that IPP project participants declare when they submit paperwork to receive payment for work on IPP projects. We found that DOE lacks an adequate and well-documented process for evaluating, verifying, and monitoring the number and WMD experience level of individuals participating in IPP projects. According to DOE officials, IPP projects are scrutinized carefully and subjected to at least 8, and in some cases 10, stages of review to assess the WMD experience of the project participants. However, we found limitations in DOE’s process. Specifically: DOE has limited information to verify the WMD experience of personnel proposed for IPP projects because government officials in Russia and other countries are reluctant to provide information about their countries’ scientists. For example, three national laboratory officials stated that it is illegal under Russian law to ask project participants about their backgrounds, and that instead they make judgments regarding the WMD experience of the project participants on the basis of their personal knowledge and anecdotal information. Some IPP project proposals may advance from the national laboratories to DOE with insufficient vetting or understanding of all personnel who are to be engaged on the project. Senior representatives at five national laboratories told us that they and their project managers do not have sufficient time or the means to verify the credentials of the proposed project participants. DOE does not have a well-documented process for verifying the WMD experience of IPP project participants, and, as a result, it is unclear whether DOE has a reliable sense of the proliferation risk these individuals pose. DOE’s review of the WMD credentials of proposed project participants relies heavily on the determinations of the IPP program office. We examined the proposal review files that the program maintains, and we were unable to find adequate documentation to substantiate the depth or effectiveness of the program office’s review of the WMD experience of proposed IPP project participants. Because it can be a matter of months or longer between development of an IPP project proposal and project implementation, the list of personnel who are actually paid on a project can differ substantially from the proposed list of scientists. For several IPP projects we reviewed, we did not find documentation in DOE’s project files indicating that the department was notified of the change of staff or had assessed the WMD backgrounds of the new project participants. For example, one IPP project—to discover new bioactive compounds in Russia and explore their commercial application—originally proposed 27 personnel and was funded at $1 million. However, 152 personnel were eventually paid under this project, and we did not find an updated list of the project personnel or any indication of a subsequent review by DOE in the IPP project files. The limited information DOE obtains about IPP project participants and the limitations in DOE’s review of the backgrounds of these individuals leave the IPP program vulnerable to potential misallocation of funds. We found several instances that call into question DOE’s ability to adequately evaluate IPP project participants’ backgrounds before the projects are approved and funded. For example, a National Renewable Energy Laboratory official told us he was confident that a Russian institute involved in a $250,000 IPP project to monitor microorganisms under environmental stress was supporting Soviet-era biological weapons scientists. However, during our visit to the institute in July 2007, the Russian project leader told us that neither he nor his institute was ever involved in biological weapons research. As a result of this meeting, DOE canceled this project on July 31, 2007. DOE’s cancellation letter stated that the information provided during our visit led to this action. Although a senior DOE official described commercialization as the “flagship” of the IPP program, we found that the program’s commercialization achievements have been overstated and are misleading. In its most recent annual report for the IPP program, DOE indicated that 50 projects had evolved to support 32 commercially successful activities. DOE reported that these 32 commercial successes had helped create or support 2,790 new private sector jobs for former weapon scientists in Russia and other countries. In reviewing these projects, we identified several factors that raise concerns over the validity of the IPP program’s reported commercial success and the numbers of scientists employed in private sector jobs. For example: The annual survey instrument that the U.S. Industry Coalition distributes to collect information on job creation and other commercial successes of IPP projects relies on “good-faith” responses from U.S. industry partners and foreign institutes, which are not audited by DOE or the U.S. Industry Coalition. In 9 of the 32 cases, we found that DOE based its job creation claims on estimates or other assumptions.