Financial Management: Improvements Needed in Air Force Vendor Payment
Systems and Controls (Letter Report, 09/28/1998, GAO/AIMD-98-274).

As illustrated by two cases in which officials with contracting
responsibilities tried to steal or embezzle more than $1 million, lax
internal controls over the Air Force's vendor payment system--primarily
the lack of segregation of duties among individuals--have left Air Force
funds vulnerable to fraudulent and improper payments. As of June 1998,
more than 1,800 employees of the Air Force and the Defense Finance and
Accounting Service had a level of access to the vendor payment system
that allowed them to enter contract information, including the contract
number, delivery orders, modifications, and obligations, as well as
invoice and receiving report information and remittance addresses. No
single person should be able to control all key aspects of a transaction
without appropriate compensating controls. This level of access allowed
these employees to submit all the information needed to create
fraudulent and improper payments. At the same time, the automated vendor
payment system was plagued by computer security weaknesses, including
inadequate password controls. Missing records, another indicator of weak
internal controls, prevented GAO from reconstructing the complete
history of the two Air Force contracts associated with fraud at Bolling
Air Force Base. GAO also was unable to determine whether the Air Force
received the goods and services paid for under these contracts because,
in addition to missing records, several improper procedures were
followed for receipt and control of equipment and services paid for
under the contracts. GAO summarized this report, along with
GAO/OSI-98-15, in testimony before Congress; see: Financial Management:
Improvements Needed in Air Force Vendor Payment Systems and Controls, by
Jeffrey C. Steinhoff, Director of Planning and Reporting in the
Accounting and Information Management Division, before the Subcommittee
on Administrative Oversight and the Courts, Senate Committee on the
Judiciary. GAO/T-AIMD-98-308, Sept. 28 (17 pages).

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  AIMD-98-274
     TITLE:  Financial Management: Improvements Needed in Air Force
	     Vendor Payment Systems and Controls
      DATE:  09/28/1998
   SUBJECT:  Financial management systems
	     Department of Defense contractors
	     Fraud
	     Internal controls
	     Financial records
	     Contractor payments
	     Air Force procurement
	     White collar crime
	     Computer security
	     Erroneous payments

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GAO/AIMD-98-274

Cover
================================================================ COVER

Report to the Chairman, Subcommittee on Administrative Oversight and
the Courts, Committee on the Judiciary, U.S.  Senate

September 1998

FINANCIAL MANAGEMENT -
IMPROVEMENTS NEEDED IN AIR FORCE
VENDOR PAYMENT SYSTEMS AND
CONTROLS

GAO/AIMD-98-274

Air Force Vendor Payment Systems

(918919)

Abbreviations
=============================================================== ABBREV

  AFB - air force base
  COR - contracting officer representative
  COTR - contracting officer's technical representative
  DFAS - Defense Finance and Accounting Service
  DISA - Defense Information Systems Agency
  DMC - Defense Megacenter
  DOD - Department of Defense
  FAR - Federal Acquisition Regulation
  FMFIA - Federal Managers' Financial Integrity Act
  OMB - Office of Management and Budget
  SAM - Single Agency Manager

Letter
=============================================================== LETTER

B-280635

September 28, 1998

The Honorable Charles E.  Grassley
Chairman, Subcommittee on Administrative Oversight
 and the Courts
Committee on the Judiciary
United States Senate

Dear Mr.  Chairman:

This report responds to your request that we review two specific
cases of fraud involving vendor payments made on behalf of the Air
Force.  The first case involved fraudulent activity between October
1992 and February 1993 related to two Bolling Air Force Base (AFB)
office automation contracts resulting in an embezzlement of over
$500,000.\1 The second case covered fraudulent activities between
October 1994 and June 1997 at Castle AFB, California, and the Defense
Finance and Accounting Service (DFAS) Dayton resulting in a $435,000
embezzlement and attempted theft of over $500,000.  The Dayton case
also involved the altering of invoices to improve reported payment
performance, thereby depriving government contractors of interest
payments.

As agreed with your office, our objectives were (1) to identify
internal control weaknesses that contributed to the two fraud cases,
(2) to provide our observations on whether the same or similar
internal control weaknesses continue to leave Air Force funds
vulnerable to fraud or improper payments, and (3) to the extent
possible, reconstruct the history of the two contracts associated
with the Bolling AFB fraud to determine whether the government
received the goods and services paid for under the contracts.  We
performed our work from October 1997 through August 1998 in
accordance with generally accepted government auditing standards.  We
requested written comments on a draft of this report from the
Secretary of Defense or his designee.  We had not received comments
by the time we finalized our report.  Details on our scope and
methodology are in appendix I.

--------------------
\1 GAO's Office of Special Investigations issued a separate report on
contractor activities associated with the Bolling AFB contract fraud
entitled DOD Procurement Fraud:  Fraud by an Air Force Contracting
Official (GAO/OSI-98-15, September 23, 1998).

   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

The two cases of fraud resulted from a weak internal control
environment.  The lack of segregation of duties and other control
weaknesses, such as weak controls over remittance addresses, created
an environment where employees were given broad authority and the
capability, without compensating controls, to perform functions that
should have been performed by separate individuals under proper
supervision.  Similar internal control weaknesses continue to leave
Air Force funds vulnerable to fraudulent and improper vendor
payments.

For example, as of mid-June 1998, over 1,800 DFAS and Air Force
employees had a level of access to the vendor payment system that
allowed them to enter contract information, including the contract
number, delivery orders, modifications, and obligations, as well as
invoice and receiving report information and remittance addresses.
No one individual should control all key aspects of a transaction or
event without appropriate compensating controls.  This level of
access allows these employees to submit all the information necessary
to create fraudulent and improper payments.  In addition, the
automated vendor payment system is vulnerable to penetration by
unauthorized users due to weaknesses in computer security, including
inadequate password controls.

Further, DFAS lacked procedures to ensure that the date that invoices
were received for payment and the date that goods and services were
received were properly documented.  These are critical dates for
ensuring proper vendor payments and compliance with the Prompt
Payment Act,\2 which requires that payments made after the due date
include interest.

Missing records, another indicator of a weak internal control
environment, prevented us from reconstructing the complete history of
the two Air Force contracts associated with the Bolling AFB fraud.
We also were unable to determine whether the Air Force received the
goods and services paid for under these contracts because, in
addition to missing records, a number of improper procedures were
followed for receipt and control of equipment and services paid for
under the contracts.  For example, the Air Force employee who was
convicted of submitting false claims to the United States directed
the contractor to falsify invoices and receiving reports by changing
the type and quantity of items received under a delivery order.

--------------------
\2 Except where otherwise specified within contracts, the act
generally provides that agencies pay within 30 days after the
designated office receives the vendor invoice or the government
accepts the items ordered as satisfactory, whichever is later.

   BACKGROUND
------------------------------------------------------------ Letter :2

Effective internal controls are essential to achieving the proper
conduct of government business with full accountability for the
resources made available.  Internal controls serve as the first line
of defense for preventing and detecting fraud and help ensure that an
agency meets its missions, goals, and objectives; complies with laws
and regulations; and is able to provide reliable financial and other
information concerning its programs, operations, and activities.

The Accounting and Auditing Act of 1950 requires agency heads to
establish and maintain effective internal controls.  Since then,
other laws have required renewed focus on internal controls.  For
example, the Federal Managers' Financial Integrity Act (FMFIA) of
1982 was enacted by the Congress because of repeated reports of
fraud, waste, and abuse caused by weak internal controls and control
breakdowns.  FMFIA requires agency heads to periodically evaluate
their systems of internal control using the guidance issued by the
Office of Management and Budget (OMB) and to report annually to the
President and the Congress on whether their systems conform to
internal control standards issued by GAO.  Pursuant to FMFIA, OMB
Circular A-123, Management Accountability and Control, provides the
requirements for assessing controls and GAO's Standards for Internal
Control in the Federal Government\3 provide the measure of quality
against which controls in operation are assessed.  Most recently, the
Federal Financial Management Improvement Act of 1996, in focusing on
financial management systems, identified internal control as an
integral part of those systems.

Over the years, we and Defense auditors have issued a number of
reports that have pointed to serious internal control weaknesses in
the Department of Defense's (DOD) payment processes and systems.  In
part, because of the seriousness of these problems and other related
problems, we identified DOD's contract payment process as error prone
and costly and designated DOD contract management as a high-risk
area.\4 In this regard, we have reported that serious internal
control weaknesses have resulted in numerous erroneous and, in some
cases, fraudulent payments.\5 For example, $3 million in fraudulent
payments were made to a former Navy supply officer on over 100 false
invoices.\6

Also, we have identified computer security as a governmentwide
high-risk area.  With respect to DOD, in May 1996, we reported\7 that
unknown and unauthorized individuals are increasingly attacking
highly sensitive unclassified information on DOD's computer systems,
which we found were particularly susceptible to attack through
Internet connections.

During fiscal year 1997, the DFAS Denver Center and its accounting
and disbursing offices processed a reported $17.2 billion in vendor
payments for the Air Force.  The DFAS Denver Center, which was
activated in January 1991, is responsible for accounting, disbursing,
collecting, and financial reporting for Air Force vendor contracts.
As a result of DFAS consolidations between 1991 and 1998, Defense
Accounting Offices were closed.  Under the DFAS Denver Center,
financial services for vendor contracts are now performed by the
Directorate of Finance and Accounting Operations, in Denver,
Colorado, and five DFAS operating locations at Dayton, Ohio;
Limestone, Maine; Omaha, Nebraska; San Antonio, Texas; and San
Bernardino, California.

The vendor payment process includes the processing and approval of
payments for operational support such as utilities, medical services,
and administrative supplies and services.  Payments must be supported
by (1) a signed contractual document, such as a purchase order, (2)
an obligation, (3) an invoice, and (4) a receiving report.  If the
process is operating as intended, vendor payment team members at the
various operating locations are to review these documents for
accuracy and completeness and enter information into the vendor
payment system--the Integrated Accounts Payable System--to create a
payment voucher, which is subsequently approved by a certifying
officer.  Certifying officers are to compare payment vouchers to
invoices and receiving reports to ensure the accuracy of the payment
information prior to disbursement.  For the first and last payments
on a contract, certifying officers are to verify contract information
as well.  Following certification, the payment information is loaded
into the disbursing system--the Integrated Paying and Collecting
system.

Before funds are disbursed, an independent check of available
obligations (prevalidation) is to be made by electronically comparing
vendor payment system transactions to obligations recorded in the
General Accounting and Finance System (general ledger).  Once
available obligations are confirmed, the disbursing system uses the
payment transactions generated by the vendor payment system to make
the disbursements and report the payment data to the Department of
the Treasury.  In addition, the vendor payment system generates
payment transactions to update the accounting system.  Finally, the
Merged Accountability and Fund Reporting reconciliations between the
accounting, vendor payment, and disbursing systems are performed on a
daily basis to help ensure that detail transactions, such as contract
expenditures, are in agreement.

--------------------
\3 GAO's Policy and Procedures Manual for Guidance of Federal
Agencies, Title 2, Appendix II, Standards for Internal Control in the
Federal Government, 1983.

\4 High-Risk Series:  An Overview (GAO/HR-95-1, February 1995),
High-Risk Series:  Defense Contract Management (GAO/HR-95-3, February
1995), and High-Risk Series:  Defense Contract Management
(GAO/HR-97-4, February 1997).

\5 DOD Procurement:  Millions in Overpayments Returned by DOD
Contractors (GAO/NSIAD-94-106, March 14, 1994) and Funds Returned by
DOD Contractors (GAO/NSIAD-98-46R, October 28, 1997).

\6 Financial Management:  Status of Defense Efforts to Correct
Disbursement Problems (GAO/AIMD-95-7, October 5, 1994).

\7 Information Security:  Computer Attacks at Department of Defense
Pose Increasing Risks (GAO/AIMD-96-84, May 22, 1996).

   INTERNAL CONTROL AND SYSTEM
   WEAKNESSES CONTRIBUTED TO FRAUD
------------------------------------------------------------ Letter :3

To reduce the risk of error, waste, or wrongful acts and to reduce
the risk of them going undetected, GAO internal control standards
require segregation of key duties and responsibilities in
authorizing, processing, recording, and reviewing transactions and
maintaining custody over assets.  No one individual should control
all key aspects of a transaction or event without appropriate
compensating controls.  Also, the individuals performing these duties
are to receive qualified and continuous supervision to ensure that
the agency's internal control objectives are met.  To ensure that
financial reports provide timely, accurate information on the results
of operations, internal control standards require that transactions
and other significant events are to be promptly recorded and properly
classified.  In addition, periodic evaluations are required to assess
risks, identify deficiencies, and effect corrective action.

For the two fraud cases, the primary internal control weakness was
the lack of segregation of duties.  In each case, the individuals
committing the fraud had authority or capability to perform functions
that should have been segregated.  For example, in the Bolling AFB
case, the contracting officer's technical representative (COTR) had
authority to authorize, approve, verify, and process contract and
payment documentation and receive and accept goods and services.  In
the Dayton case, the Staff Sergeant, who at different times held
positions in accounting and payment processing, was responsible for
recording contract data, including obligations; invoice and receiving
report information; and remittance addresses.  After the Staff
Sergeant's access to the Dayton vendor payment system was removed, he
was able to perform these functions by obtaining and using the
computer password of another employee who had a level of access to
the vendor payment system comparable to the level of access the Staff
Sergeant previously held.

      INTERNAL CONTROL WEAKNESSES
      RELATED TO THE BOLLING AFB
      FRAUD
---------------------------------------------------------- Letter :3.1

An Air Force civilian employee, who was the COTR on the two Bolling
AFB contracts, had broad authority to request contract amendments,
order goods and services, receive and accept the goods and services,
and approve payment for the items received.  In addition, this person
was not adequately supervised.  The COTR's supervisor told
investigators and us that she allowed the COTR to perform these
duties independently without close supervision.  The COTR was able to
embezzle over $500,000 by creating fictitious invoices and receiving
reports.

In September 1992, the COTR requested that contractor employees
submit five false invoices totaling $342,832, for billings of goods
and services that had not been ordered or received.  According to
contractor employees, the COTR told them that he was requesting
advance billings to prevent the expiration of unused funding.  While
DOD has some authority to make advance payments,\8 advance billings
are not authorized for this purpose.  Contractor employees submitted
the five false invoices, as well as false receiving reports for each
invoice, as instructed by the COTR.

The COTR also gave the contractor a memo dated October 14, 1992,
instructing the contractor to order $500,000 of legislative
consulting services from a subcontractor, Applied Quantitative
Systems, and include a 25 percent markup ($125,000) for overhead to
be retained as the contractor's fee when submitting the invoice to
the Air Force.  The COTR's memo listed the five false invoices
discussed above as partial documentation of these services.  However,
Applied Quantitative Systems was a fictitious company created by the
COTR that had not provided any services under this contract, and the
remittance address on the invoice was for a post office box opened by
the COTR to receive the $500,000 payment.  Had the contractor
followed through on the COTR's instructions, it would have eventually
billed the government $625,000,\9 sent $500,000 to the COTR's
fictitious company address, and kept $125,000 as overhead.  However,
according to contractor internal review files, management determined
that legislative services were outside the scope of the contract and,
as a result, did not submit this invoice to the government.

In November 1992, contractor management became aware of the five
false invoices that had been submitted at the COTR's request and
retrieved from the bank four checks received from the Air Force
totaling $322,032 for payment of three\10 of the invoices.  The
contractor voided the checks and returned them to the Air Force.
Reportedly at the request of the contractor, the COTR had the Air
Force withdraw the remaining two invoices totaling $20,800.

Then, in December 1992, the COTR, without the contractor's
involvement, prepared 11 false invoices resulting in $504,941 in
fraudulent payments.  As with the Applied Quantitative Systems
invoice, the COTR used his own post office box as the remittance
address on the 11 false invoices.  The COTR retrieved the payment
from the post office box and deposited the funds in two newly
established accounts at a bank where he maintained a personal
account.

The COTR was able to accomplish this scheme without detection by Air
Force officials because he took advantage of his broad authority and
the lack of adequate supervision.  In addition, at the time of this
incident, the address on the invoice was used as the remittance
address, which is a control weakness.  Therefore, directing the
payments to himself was a simple matter of listing his post office
box as the contractor address on the false invoices.

Authorities were only alerted to the COTR's embezzlement when he
attempted to withdraw a large portion of the funds, and suspicious
bank officials put a hold on the accounts and notified the U.S.
Secret Service.  After coming under suspicion, the COTR prepared a
letter stating that overbilling errors had been made and returned the
funds to the government.  Following an investigation by the Air Force
Office of Special Investigation, the COTR pleaded guilty and was
sentenced to 3 years probation and ordered to pay $495.  Further
details on the COTR's schemes can be found in GAO/OSI-98-15.

Since the 1992-1993 Bolling AFB fraud, contractors are generally
required to send invoices to DFAS Denver's Directorate of Finance and
Accounting Operations for payment.  As a result, COTRs generally do
not review or approve invoices.  In addition, the Single Agency
Manager (SAM) was put in place in March 1995.  The mission of SAM, in
general, is to provide, manage, operate, and maintain designated
information technology services for all applicable components and
customers.  As a part of that mission, SAM operates and maintains
information technology systems.  In order to procure information
technology systems and services, SAM utilizes contracting offices at
the Pentagon and at Bolling AFB.  SAM is in the process of
implementing a position for contracting officer representatives (COR)
who are to be responsible for the direct supervision of COTRs'
performance of contract-related duties, such as the writing of
technical specifications, inspection of contractors' technical
performance, and submission of receiving reports.  A SAM official
told us that this change, which is targeted for full implementation
by the spring of 1999, is intended to address the lack of close
supervision that contributed to the Bolling AFB fraud.

--------------------
\8 10 U.S.C.  2307.

\9 This amount relates to $342,832 on the five invoices the
contractor had already submitted plus an additional $282,168.

\10 One of the three invoices was paid by two checks.

      INTERNAL CONTROL WEAKNESSES
      RELATED TO CASTLE AFB AND
      DFAS DAYTON FRAUD
---------------------------------------------------------- Letter :3.2

An Air Force Staff Sergeant was convicted of fraudulent activities at
two locations.  The first known location where fraudulent payments
were made was Castle AFB, California, between October 1994 and May
1995.  The Staff Sergeant, who was Chief of Material in the
Accounting Branch, had broad access to the automated vendor payment
system, which allowed him to enter contract information, including
contract numbers, delivery orders, modifications, and obligations as
well as invoice and receiving report information and remittance
addresses.  The Staff Sergeant used this broad access to process
invoices and receiving report documentation that resulted in eight
fraudulent payments totaling $50,770 that were identified.  The
invoices prepared by the Staff Sergeant designated the name of a
relative as the payee and his own mailing address as the remittance
address, although any address, including a post office box, could
have been used.  Castle AFB closed in September 1995, and the Staff
Sergeant was transferred to DFAS Dayton.

At DFAS Dayton, the Staff Sergeant was assigned as the Vendor Pay
Data Entry Branch Chief in the Vendor Pay Division.  As Vendor Pay
Chief, the Staff Sergeant was allowed a level of access to the vendor
payment system similar to the access he previously held at Castle
AFB.  Between November 1995 and January 1997, the Staff Sergeant
prepared false invoices and receiving reports that resulted in nine
fraudulent payments totaling $385,916.  By designating the remittance
address on the false invoices, the Staff Sergeant directed fraudulent
payments to an accomplice.

In February 1997, the Staff Sergeant was reassigned to DFAS Dayton's
Accounting Branch and his access to the vendor payment system was
removed.  However, while assigned to the Accounting Branch, the Staff
Sergeant created two false invoices totaling $501,851 and submitted
them for payment in June 1997, using the computer password of another
DFAS employee who had a level of access comparable to that previously
held by the Staff Sergeant.  The Staff Sergeant's fraudulent
activities were detected when, for an invoice totaling $210,000, an
employee performing the Merged Accountability and Fund Reporting
reconciliation identified a discrepancy between the contract number
associated with the invoice in the vendor payment system and the
contract number associated with the invoice in the accounting system.
These two numbers should always agree.  For this invoice, the Staff
Sergeant failed to ensure that the contract cited was the same in
both systems.  Further research determined that the contract was not
valid and the payment was fraudulent.  A second fraudulent invoice
for $291,851, the $50,770 in fraudulent payments at Castle AFB, and
the $385,916 in fraudulent payments at DFAS Dayton were detected
during the subsequent investigation of the DFAS Dayton fraud.

The Staff Sergeant was convicted of embezzling over $435,000 and
attempted theft of over $500,000.  He was also convicted of altering
invoices and falsifying information in the vendor payment system--in
violation of 18 U.S.C.  1001\11 --to avoid interest on late payments
and improve reported performance for on-time payments.  In July 1998,
the Staff Sergeant was sentenced to 12 years imprisonment.

--------------------
\11 Under 18 U.S.C.  1001, knowingly and willfully falsifying or
concealing a material fact in relation to any matter within the
jurisdiction of an executive agency or department of the United
States government is a criminal offense, punishable by fine, 5 years
in prison, or both.

   VENDOR PAYMENT SYSTEM HAS
   SERIOUS CONTROL WEAKNESSES
------------------------------------------------------------ Letter :4

At DFAS Dayton and DFAS Denver Directorate of Finance and Accounting
Operations, we observed internal control weaknesses in the vendor
payment process that were similar or the same as those that
contributed to the incidents of fraud discussed in this report.  In
addition, we identified weaknesses in computer security that would
permit improper access to the vendor payment system.

      INADEQUATE ACCESS CONTROLS
      LEAVE PAYMENT SYSTEM
      VULNERABLE TO UNAUTHORIZED
      USE
---------------------------------------------------------- Letter :4.1

The lack of segregation of duties with respect to the level of access
to the vendor payment system held by the Staff Sergeant that allowed
him to embezzle funds remains widespread.  We identified three
critical access control weaknesses in the vendor payment system:  (1)
access levels do not provide adequate functional segregation of
duties, (2) the number of staff with such access is excessive and
widespread throughout DFAS and the Air Force, and (3) computer
security over the operating system and the vendor payment application
for DFAS Denver is weak.

With regard to the first issue, an August 1996 Air Force Audit
Report\12 disclosed that DFAS personnel did not properly control
access to the vendor payment system and recommended that DFAS review
and reduce vendor payment system access levels where appropriate.
Our review of vendor payment system access levels as of mid-June 1998
showed that across DFAS and Air Force installations, individual users
could enter contract data, including obligations, and invoice and
receiving report information, and change remittance addresses for
vendor payments.  Currently, there are four access levels to the
vendor payment system:  inquiry, clerk, subsupervisor, and
supervisor.  Inquiry is read only access.  Clerk access allows the
user to enter data other than remittance addresses.  Subsupervisor
access allows the user to input or change contract data; information
on obligations, invoices, and receiving reports; and remittance
addresses.  Supervisor access allows the user to perform all
subsupervisor functions as well as assign or remove access.  The
Staff Sergeant who committed the DFAS Dayton fraud had supervisor
access.

Proper and effective internal controls would preclude allowing any
individual user to have the ability to record an obligation, create
and change invoices and receiving reports, and enter remittance
addresses.  Once these activities are segregated organizationally by
assigning them to different individuals, the authority to enter
contract data and payment information must be functionally segregated
within the vendor payment system application to maintain the
integrity of the organizational segregation.  Without segregation of
these duties and controls over access to the system, appropriate
compensating controls need to be in place, such as reviews of
remittance address change activity and periodic verification of
payment addresses with the vendors.

Our review of the vendor payment process at DFAS Dayton and DFAS
Denver's Directorate of Finance and Accounting Operations confirmed
that employees with supervisor and subsupervisor access to the vendor
payment system could make fraudulent payments without detection by
entering contract information and obligations, invoice and receiving
report data, and changing or creating a remittance address.  If the
data on a false invoice and receiving report match the information on
the voucher, certifying officers are not likely to detect a
fraudulent payment through their certification process, a key
prevention control.

Second, problems with the lack of segregated access within the
payment system application are compounded by the excessive and
widespread access to the system throughout DFAS and the Air Force.
Our review of vendor payment system access levels as of mid-June 1998
showed that 1,867 users across DFAS and Air Force installations had
supervisor or subsupervisor access.  Further, 94 of these users had
not accessed the system since 1997, indicating that they may no
longer be assigned to vendor payment operations.  In addition, 171
users had not accessed the system at all, possibly indicating that
access is not required as a regular part of their duties.  DFAS
officials told us they were unaware that such a large number of
employees had broad access to the vendor payment system.

DFAS Denver Center has scheduled operational reviews of all DFAS
operating locations for completion by January 1999.  These reviews
are intended to assess whether DFAS operations comply with DFAS
policies and procedures as well as laws and regulations.  However, we
found that the review program did not address the implementation and
effectiveness of internal controls, including the segregation of
duties and systems access issues identified in this report.  After we
briefed the DFAS Denver Center Director about our concerns, he told
us that the operational review program would be revised to place a
greater focus on internal controls, including the review of vendor
payment system access levels.  DFAS officials told us that for Air
Force employees outside the operating locations who had supervisor or
subsupervisor access, but only need status reports, they have
initiated action to reduce the level of access to inquiry only.  They
also told us that they would consider modifying the supervisor and
subsupervisor access levels across DFAS locations to provide for
greater segregation of duties within the vendor payment application
for employees responsible for processing payments.

Finally, with respect to access controls, there are significant
weaknesses in the mainframe operating system security and the vendor
payment system application that would allow unauthorized users to
make fraudulent or improper payments.  A recently completed review by
the Defense Information Systems Agency (DISA), performed at our
request, determined that the Defense Megacenter (DMC) in San Antonio,
on which DFAS Denver's Directorate of Finance and Accounting
Operations vendor payment system runs, did not appropriately restrict
access to powerful system utilities.  These utilities enable a user
to access and manipulate any data within the mainframe computer and
vendor payment system.  The DMC had granted this privileged access to
an excessive number of users and was not able to provide adequate
documentation of management approval and review for most of these 161
users.  In addition, the DMC had granted 673 users higher levels of
access authority than necessary to perform their duties.  These
high-level security profiles enable a user to bypass the regular
control features, which the mainframe computer and vendor payment
system are capable of providing to preclude unintentional or
unauthorized manipulation of vendor payment files.

The DISA review also determined that routine system monitoring and
oversight was not performed to identify and follow-up on user
noncompliance with security standards.  This allowed serious security
weaknesses to exist, which are commonly exploited by hackers.  For
example, the review team was able to access user IDs and passwords
residing in unsecured files on the system and gain access to other
systems.  Also, default passwords, which are commonly known, were not
disabled.  Further, passwords and user IDs were not managed according
to DISA policies.  In general, all user IDs and passwords were
allowed to remain inactive for 90 days, contrary to DISA policy
requiring that user IDs and passwords be disabled after 35 days of
inactivity.  There were also 36 users whose passwords expired after
180 days, and 12 users, including a security administrator, whose
passwords were set to never expire, which exceeds the 90-day DISA
policy.  These situations increase the risk that user IDs will be
compromised to gain unauthorized access to DOD systems.

In addition, our tests of the local network and communication links
to the DFAS Denver Directorate of Finance and Accounting Operations
and the DFAS Dayton vendor payment systems showed that these systems
are vulnerable to penetration by unauthorized internal DFAS and Air
Force users.  For example, because vendor payment system passwords
and user IDs are transmitted across the local network and
communication links in clear text, readily available software would
permit any user to read vendor payment system passwords and user IDs.
Thus, a clerk could obtain the passwords and user IDs of employees
with higher access and use this information to enter the vendor
payment system and perform all payment processing functions.

DOD does not encrypt passwords and user IDs for unclassified
financial data.  However, other technological controls could be used
to improve user authentication procedures, such as a smart card.\13
Alternatively, other internal controls could be implemented, such as
supervisory review and validation of user activity.  As with the
selection of any internal control, consideration of these
alternatives would entail an assessment of the cost and benefits of
each.

--------------------
\12 Air Force Audit Agency Project 96054010:  General and Application
Controls Within the Integrated Accounts Payable System (August 1,
1996).

\13 Smart cards are access cards containing encoded information and
sometimes a microprocessor and a user interface.  The encoded
information and/or the information generated by the processor are
used to gain access to a computer system or facility.

      INADEQUATE CONTROLS OVER
      REMITTANCE ADDRESSES
---------------------------------------------------------- Letter :4.2

The control over remittance addresses remains a weakness.  DFAS
changed its policy in April 1997 to require that the contractor
address listed in the contract be used as the remittance address, but
it still permits the use of the invoice address if the invoice states
that payment must be made to a specified address.  This continues to
afford a mechanism to misdirect payments for fraudulent purposes.  In
addition, widespread access to the vendor payment system that allows
users to enter changes to the remittance address, as discussed
earlier, remains a weakness.

The Defense Logistics Agency has an initiative under way intended to
validate remittance addresses.  Under the Central Contractor
Registry,\14 contractors awarded a contract on or after June 1, 1998,
are required to be registered in order to do business with the
government.  While DFAS Denver Center officials did not have a target
date for full implementation of the Registry, they expect that 80
percent of the eligible contracts will be included in the Registry by
mid-1999.

The Registry, which is accessed through the Internet using a password
or manually updated using a standard form, is intended to ensure that
the contractor providing payment data, including the remittance
address, is the only one authorized to change these data.  However,
this process, while an improvement, still has vulnerabilities related
to control over remittance address changes.  First, as previously
discussed, DOD's computer systems are particularly susceptible to
attack through connections on the Internet.  In addition, once the
addresses are downloaded from the Registry to the vendor payment
system, they will be vulnerable to fraudulent or improper changes due
to the access control weaknesses previously discussed.  Therefore,
Registry controls over the remittance addresses will only be
effective to the extent that access to remittance addresses currently
held by DFAS and Air Force employees is eliminated or compensating
controls are implemented.

--------------------
\14 The Registry will not cover grants, awards, utilities, legal
claims, or claims for household goods.

   DFAS DAYTON CONTROL ENVIRONMENT
   PERMITTED CIRCUMVENTION OF
   PROMPT PAYMENT ACT PROVISIONS
------------------------------------------------------------ Letter :5

Internal controls are put in place not only to help ensure
accountability over resources, but also to help an agency achieve
full compliance with laws and regulations, such as the Prompt Payment
Act of 1982, as amended.  This act provides governmentwide guidelines
for establishing due dates on commercial invoices and provides for
interest payments on invoices paid late.  Except where otherwise
specified within contracts, the act provides, generally, that
agencies pay within 30 days after the designated office receives the
vendor invoice or the government accepts the items ordered as
satisfactory, whichever is later.  According to Office of Management
and Budget Circular A-125, Prompt Payment, which provides
implementation guidance under the act, if the government does not
reject items received within 7 days, acceptance will be deemed to
occur on the 7th day after receipt.  Payments made after the required
payment date must include interest.  One performance measure used by
DFAS to assess operating location performance is the amount of
interest paid.

The falsification of payment documentation to improve reported
performance for on-time payments was a violation of 18 U.S.C.  1001.
In addition, it undermined DFAS Dayton's internal controls over
payments and impaired its ability to detect or prevent fraud.
According to DFAS internal review and Air Force investigative
reports, the Staff Sergeant convicted of embezzlement had also
instructed his branch employees to falsify invoice dates in an effort
to improve reported payment performance, thereby depriving government
contractors of interest on late payments.  This was done by (1)
altering dates on invoices received from contractors, (2) replacing
contractor invoices with invoices created using an invoice template
that resided on DFAS Dayton personal computers used by vendor payment
employees, and (3) throwing away numerous other invoices.

According to DFAS internal review and Air Force investigative
reports, during 1996, DFAS Dayton also used faxed invoices to alter
invoice receipt dates to avoid late payment interest required by the
Prompt Payment Act.  According to documents presented at the Staff
Sergeant's trial, this was done by using a photocopy of the fax and
manually changing the dates and then photocopying the fax again.
DFAS Dayton staff then faxed the photocopied document to their own
office to create a new date.  Not only did this practice undermine
late payment controls, but an environment in which altered documents
are commonplace made it more difficult to detect other fraudulent
activity, such as the false invoices generated for personal financial
gain.

In addition, we found that in June 1996, DFAS Dayton implemented an
Air Force-wide initiative to improve payment timeliness which
generally permitted (1) payment of invoices under $2,500 without
receiving reports and (2) acceptance of remittance addresses recorded
on invoices without further verification.  As of October 1997, the
payment of invoices without receiving reports was to be terminated
based on legal concerns about compliance with prompt payment and
advance payment statutes.

Our review of selected fiscal year 1997 DFAS Dayton and DFAS Denver
Directorate of Finance and Accounting Operations vendor payment
transactions identified a number of problems, including inadequate
documentation, which affect not only Prompt Payment Act compliance
but the ability to determine whether payments were proper or whether
the government received the goods and services paid for under Air
Force contracts.  Further, without adequate supporting documentation
for disbursements, DFAS cannot ensure that fraud has not occurred.

For DFAS Dayton, we tested 27 vendor payment disbursement
transactions made during fiscal year 1997 as part of our audit of the
governmentwide consolidated financial statements.\15 Our tests
disclosed that 9 of 27 disbursement transactions were not supported
by proper payment documentation, which includes a signed contract,
approved voucher, invoice, and receiving report.  Of the remaining 18
disbursement transactions, receiving report documentation for 12
transactions did not properly document the date that goods and
services were received.  Instead, the receiving report documentation
showed the date that the document was signed.

At your request, we reviewed 77 vouchers for Bolling AFB contracts
paid by DFAS Denver's Directorate of Finance and Accounting
Operations in 1997 and 1998 that were obtained by your staff during
their review of the DFAS Denver Directorate's vendor payment
operations in March 1998.  All 77 of the payment vouchers had
deficiencies, ranging from incomplete information to identify the
individual receiving the goods and services to a missing receiving
report.  For example, 13 of the 77 DFAS Denver Directorate's payment
vouchers were replacement invoices that were marked "duplicate
original" or "reprint," possibly indicating that the original
invoices had been lost or misdirected before being entered in the
vendor payment system.  In addition, 31 of the 77 vouchers contained
receiving report documentation that omitted the date that goods and
services were received.  On March 25, 1998, in response to concerns
regarding these 31 vouchers, the DFAS Denver Directorate revised its
receiving report requirements to help ensure proper documentation of
this date.  However, at the end of our review in mid-August 1998, we
were told that this problem had not yet been corrected at DFAS Dayton
or the other vendor payment operating locations.

Our review also showed that 2 of the 77 vouchers had discrepancies
similar to those identified as part of the DFAS Dayton investigation.
Specifically, one voucher had been voided and resubmitted later
without the appropriate interest calculation.  The other voucher
included an invoice that appeared to have been created by a DFAS
Denver Directorate employee because, according to the contract, the
contractor lacked invoicing capability.  The practice of creating
invoices for contractors provides an opportunity for DFAS and Air
Force employees to create false invoices.  In the absence of
computerized invoicing, contractors can submit billing letters that
identify quantities, items billed, and costs.  Thus, there appears to
be no valid reason for DFAS or Air Force employees to create
invoices.

In addition, we reviewed five examples of altered invoices identified
by DFAS Dayton staff who had raised concerns about the payment
process.  We obtained copies of the invoices from the Air Force Audit
Agency in June 1998.  In one case, the invoice was duplicated and
then altered so that interest due the vendor for a late payment was
charged to the Defense Stock Fund rather than the appropriate
Operation and Maintenance appropriation interest account.  DFAS
performance measures for late payments do not include interest paid
from the Stock Fund.  The other four invoices were created to alter
the invoice dates by using an invoice template that is a standard
file on Air Force and DFAS personal computers.  These invoices were
substituted for the original invoices submitted by the vendors to
avoid interest payments.

We also found that neither DFAS Dayton nor DFAS Denver's Directorate
of Finance and Accounting Operations tracks invoices, whether mailed
or faxed, from the time they are received until they are entered into
the vendor payment system.  One means of tracking both mailed and
faxed invoices would be for the mail room employees to enter invoice
information into the vendor payment system at the time the invoices
are received.  This control would help ensure that the payment team
personnel who are measured on timely performance are not also
responsible for establishing the invoice receipt date for one of the
key documents that determines when a payment is late.

--------------------
\15 Financial Audit:  1997 Consolidated Financial Statements of the
United States Government (GAO/AIMD-98-127, March 31, 1998).

   DOCUMENTATION IS NOT AVAILABLE
   TO RECONSTRUCT HISTORY OF
   CONTRACTS
------------------------------------------------------------ Letter :6

Due to missing and altered records, we were unable to reconstruct the
history of the two contracts associated with the Bolling AFB
embezzlement to determine whether the Air Force received the goods
and services it paid for under the contracts.

      INSUFFICIENT DOCUMENTATION
      TO RECONSTRUCT CONTRACTS
---------------------------------------------------------- Letter :6.1

On July 30, 1986, a $49.6 million contract was awarded to provide
office automation hardware, software, maintenance, training, and
contractor support services for Air Staff offices at the Pentagon and
several other locations.  Responsibility for managing the contract
was assigned to a contracting office at Bolling AFB.  The contract
ran from July 30, 1986, through December 31, 1991.  Under this
contract, almost 500 delivery orders were used to acquire goods and
services.

Under the Federal Acquisition Regulation (FAR), all records,
documents, and other files pertaining to contracts such as this must
be maintained for 6 years and 3 months after final payment.
According to a Bolling AFB contracting official, the last payment on
this contract was made in December 1992.  Therefore, records
pertaining to this contract should be maintained until at least March
1999.  Nevertheless, despite an extensive search of both DFAS and Air
Force records, we were unable to locate documentation showing the
total amount paid under the contract.  Further, neither the Air Force
nor DFAS Denver officials were able to locate all the files
pertaining to these contracts.  As agreed with your office, due to
the magnitude of missing records, we did not make further attempts to
reconstruct the payment history for the 1986 contract.

A Bolling AFB contracting official told us that a team has been
formed to close out the contract.  Under the FAR, the team would need
to confirm that a final invoice has been approved or a final payment
has been made for goods and services received and accepted before
closing the contract.  The contractor's report on its 1993 internal
review of the contract\16 indicated that its records identified
approximately $38 million of goods and services that were delivered
over a 5-1/2 year period under the 1986 contract.  We were unable to
locate the contractor records needed to verify this amount.  Given
the extent of missing records, DFAS and Air Force efforts to confirm
that payment was made for goods and services received will be
difficult, if not impossible.

On March 13, 1992, a follow-on contract was awarded, effective
January 3, 1992, to the company responsible for the first contract.
As with the 1986 contract, responsibility for managing this contract
was assigned to Bolling AFB and the same COTR.  The 1992 contract
provided for hardware and software maintenance, technical support,
parts, training, and a computer maintenance database.  This contract
also used delivery orders to acquire goods and services.  During the
life of the contract, contracting staff awarded 41 delivery orders
and 81 modifications to these delivery orders.

Based on available Air Force records, the total amount obligated
under the 1992 contract appears to be about $8.2 million.  We were
able to locate payment vouchers totaling $6.7 million.  However, we
also found invoices in the contract files totaling over $279,000 for
which payment vouchers could not be located.  Further, the DFAS
Denver Directorate was unable to locate check registers.  Thus, we
were unable to determine whether these invoices had been paid.  As
was the case for the 1986 contract, due to poor recordkeeping,
neither Bolling AFB nor the contractor were able to accurately
determine the status of payments and deliveries under the 1992
contract.  The last delivery order for the contract was dated October
1, 1995.  However, the contract extended through September 1996.  On
March 31, 1998, the contractor submitted a final bill totaling
$194,000, which listed 16 invoices for which full or partial amounts
may still be owed by the Air Force.  DFAS officials told us that they
did not plan to pay the final bill until they finish reviewing and
validating the items included in the invoice because they believe
that payment has already been made for some of these items.

--------------------
\16 During 1993, the contractor performed an internal review of
activities associated with the two Bolling AFB contracts after being
contacted by the Secret Service relative to the COTR's improper
activities.

      UNABLE TO DETERMINE WHETHER
      GOODS AND SERVICES WERE
      RECEIVED DUE TO INADEQUATE
      CONTRACT MANAGEMENT
---------------------------------------------------------- Letter :6.2

We were also unable to determine whether the Air Force received the
goods and services paid for under the two contracts because, in
addition to missing records, a number of improper and questionable
procedures were followed for receipt and control of equipment and
services paid for under the contracts.

As discussed earlier, from June 1988 until February 1993, the COTR
had broad authority to order, receive, and accept goods and services.
In ordering equipment, the COTR designated the delivery location and
later signed for the receipt and acceptance of the equipment.  Also,
the COTR directed equipment to be delivered to or from an Air Force
storage facility.  Beginning in 1990, the contractor requested a
change in procedures whereby the Air Force would sign for equipment
purchased under the 1986 contract but let the contractor store the
equipment at the contractor's warehouse until the Air Force was ready
to take delivery.  However, because neither the Air Force nor the
contractor maintained accurate, complete property records on this
equipment, we could not determine whether the Air Force received this
equipment.

Because of its desirability and portability, computer equipment is
highly susceptible to theft.  Under DOD's Financial Management
Regulation, pilferable items, such as personal computers, are
required to be recorded in the property records.  We attempted to
determine whether the government received 29 computer equipment items
identified as being maintained under the contract at Air Force
locations in the Washington, D.C., area.  We located 10 items and
obtained documentation on the disposal of 3 items.  Of the 16
remaining items, all of which were computer servers, only 4 were
recorded in the property records.  However, we were unable to locate
the 4 servers.  In addition, we could not locate or identify
documentation for the 12 remaining servers.  Property officials told
us that computer equipment delivered and paid for under the contract
was not always recorded in property records.

In several instances, the COTR directed the contractor to bill for
equipment as maintenance in order to avoid contract limitations on
the amount of equipment that could be procured.  The contractor's
1993 internal review report stated that equipment was misdescribed as
maintenance on 116 of 142 invoices reviewed.

Although the 1992 contract required the contractor to develop a
database to track equipment maintenance, neither Air Force nor
contractor files contained complete maintenance records for equipment
purchased under the contract.  According to a contractor official,
the contractor's 1993 internal review team inadvertently destroyed
the equipment maintenance database that the contractor was required
to develop and maintain under the contract.  Further, while the 1992
contract required the contractor to provide certificates for
completed training, Bolling AFB contract records did not contain
training certificates.

   CONCLUSIONS
------------------------------------------------------------ Letter :7

Internal control weaknesses that contributed to past fraud in the Air
Force's vendor payment process continue.  DFAS and the Air Force have
not developed adequate segregation of duties to ensure that one
individual cannot establish a contract obligation, enter invoice and
receiving report information, and change a remittance address.
Moreover, the Air Force's vendor payment system is vulnerable to
unauthorized users due to weaknesses in operating computer system and
local network security.  Until DFAS and the Air Force address control
weaknesses in systems and processes and maintain accountability over
goods and services received, the Air Force vendor payment process
will continue to be vulnerable to fraudulent and improper payments.

   RECOMMENDATIONS
------------------------------------------------------------ Letter :8

To address the continuing vulnerabilities in the vendor payment
process, we recommend that the DFAS Director

  -- strengthen payment processing controls by establishing separate
     organizational responsibility for entering (1) obligations and
     contract information, (2) invoice and receiving report
     information, and (3) changes in remittance addresses;

  -- revise vendor payment system access levels to correspond with
     the segregation of organizational responsibility delineated
     above; and

  -- reduce the number of employees with vendor payment system access
     by (1) identifying the minimum number of employees needing
     on-line access to specific functions, (2) determining whether
     the access levels given to each user are appropriate for the
     user's assigned duties, and (3) removing access from employees
     who are no longer assigned to these functions.

To strengthen computer security for the vendor payment system, we
recommend that the DISA Director (1) correct the system security
control weaknesses in the operating system (mainframe) on which DFAS
Denver's vendor payment system application runs and (2) assess the
costs and benefits of implementing technological and/or
administrative controls over user IDs and passwords.

To ensure that internal controls are properly designed and operating
as intended, we recommend that the DFAS Director revise the
operational review program to include assessments of the internal
controls over the vendor payment process.

To help ensure that vendor payments are proper and that they comply
with Prompt Payment Act time frames, we recommend that the DFAS
Director ensure that (1) the date that invoices are received and the
date that goods and services are received are properly documented and
(2) invoices are tracked from receipt through disbursement of funds.
In addition, we recommend that the DFAS Director no longer permit the
creation of contractor invoices by DFAS employees and require those
contractors that lack invoicing capability to submit billing letters.

---------------------------------------------------------- Letter :8.1

We are sending copies of this report to the Ranking Minority Member
of the Subcommittee on Administrative Oversight and the Courts,
Senate Committee on the Judiciary; the Chairmen and Ranking Minority
Members of the Senate Committee on Armed Services, the House
Committee on National Security, the Senate Committee on Governmental
Affairs, the House Committee on Government Reform and Oversight, and
the House and Senate Committees on Appropriations; and the Director
of the Office of Management and Budget.  We are also sending copies
to the Secretary of Defense; the Secretary of the Air Force; the
Director, Defense Finance and Accounting Service; the Director,
Defense Information Systems Agency; and the Director, Defense
Logistics Agency.

Please contact me at (202) 512-9095 if you or your staff have any
questions.  Major contributors to this report are listed in appendix
II.

Sincerely yours,

Lisa G.  Jacobson
Director, Defense Audits

OBJECTIVES, SCOPE, AND METHODOLOGY
=========================================================== Appendix I

In accordance with your request, our objectives were to (1) identify
internal control weaknesses that contributed to Bolling AFB, Castle
AFB, and the DFAS Dayton fraud, (2) provide our observations on
whether the same or similar internal control weaknesses at the
locations covered by our review continue to leave the Air Force
vulnerable to fraud, and (3) to the extent possible, reconstruct the
history of the two contracts associated with the Bolling AFB fraud to
determine whether the government received the goods and services paid
for under the contracts.

To identify internal control weaknesses that contributed to the
Bolling AFB and the Castle AFB and DFAS Dayton fraud, we reviewed
investigative reports by DFAS internal reviewers and the Air Force's
Office of Special Investigations on how these incidents of fraud were
accomplished.  We also discussed the control weaknesses related to
the fraud cases with DFAS Denver and Dayton managers.  We compared
the activities involved in the fraud with GAO internal control
standards and federal agency requirements for assessing controls
contained in OMB Circular A-123, Management Accountability and
Control.  Our work was limited to a review of the fraud incidents and
related documentation for which the two individuals were convicted
and does not address any ongoing investigations involving any
additional participants.

Our observations on the current internal control environment are
based on the following.

  -- A review of the current vendor payment processes at the DFAS
     Denver Directorate of Finance and Accounting Operations and DFAS
     Dayton.

  -- A test of 27 fiscal year 1997 DFAS Dayton vendor payment
     transactions included in a statistical sample of payment
     transactions tested as part of our governmentwide consolidated
     financial statement audit effort.

  -- A review of 77 vendor payment vouchers processed by DFAS Denver
     in 1997 and 1998 that were provided to us by Subcommittee staff.
     We were asked to analyze this sample which was obtained by the
     Subcommittee staff as part of its review of DFAS Denver vendor
     payments.

  -- A review of five examples of altered invoices identified by DFAS
     Dayton staff, which we obtained from the Air Force Audit Agency.

  -- A test of computer system access controls for the vendor payment
     system--Integrated Accounts Payable System and the Central
     Contractor Registry.

  -- Discussions with DFAS, Air Force, and Single Agency Manager
     officials.

To identify significant operating computer system control weaknesses,
we reviewed the Defense Information Systems Agency's (DISA) Security
Readiness Review methodology and compared it with GAO's Financial
Information System and Control Audit Methodology.  We also considered
the results of Security Readiness Reviews performed by DISA at the
Defense Megacenters in San Antonio, Texas, and Warner-Robins AFB,
Georgia, which are the data processing centers for DFAS Denver and
Dayton, respectively.

In attempting to summarize the history of the 1986 and 1992 Bolling
AFB contracts, we

  -- reviewed Bolling AFB contract files to determine the purpose,
     scope, and cost of the 1986 Air Staff Office Automation System
     contract and the 1992 Air Staff CAISS Air Force Follow-on
     contract and

  -- reviewed the 1986 and 1992 contract activity using records
     obtained from Bolling AFB, the Air Force finance office at the
     Pentagon, and DFAS Denver's Directorate of Finance and
     Accounting Operations.

In our efforts to determine whether the Air Force received the goods
and services paid for under the 1986 and 1992 contracts, we reviewed
contract records, payment documents, and systems data at Bolling AFB,
the Air Force finance office at the Pentagon, and the Single Agency
Manager office at the Pentagon.

We performed our work from October 1997 through August 1998 in
accordance with generally accepted government auditing standards.  We
conducted our review at the 11th Wing Contracting Squadron at Bolling
AFB, Washington, DC; the Single Agency Manager office at the Pentagon
in Arlington, Virginia; DFAS Dayton in Ohio; the DFAS Denver Center
and DFAS Denver Directorate of Finance and Accounting Operations; and
the Defense Megacenters at San Antonio, Texas, and Warner-Robbins
AFB, Georgia.

We requested comments on a draft of this report from the Secretary of
Defense or his designee.  We had not received comments by the time we
finalized our report.

MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix II

ACCOUNTING AND INFORMATION
MANAGEMENT DIVISION, WASHINGTON,
D.C.

Gayle L.  Fischer, Assistant Director
Crawford L.  Thompson, Assistant Director, EDP Audits
James Ariail, Jr., Senior Auditor
Jeffrey Isaacs, Senior Auditor
Francine DelVecchio, Communications Analyst

ATLANTA OFFICE

Sharon S.  Kittrell, Senior EDP Auditor

DAYTON OFFICE

Keith McDaniel, Senior Auditor
Bill Bricking, Senior Evaluator
Roger Corrado, Senior Evaluator

NORFOLK OFFICE

Robert Wagner, Project Manager
Susan Mason, Evaluator

OFFICE OF THE GENERAL COUNSEL

Thomas Armstrong, Assistant General Counsel
Andrea Levine, Senior Attorney

*** End of document. ***