Telecommunications: GSA Action Needs to Realize Benefits of	 
Metropolitan Area Acquisition Program (04-APR-02, GAO-02-325).	 
                                                                 
The Metropolitan Area Acquisition (MAA) program provides local	 
telecommunications services to federal agencies in certain U.S.  
cities. The General Services Administration (GSA) began the	 
program in 1997 to achieve immediate, substantial, and sustained 
price reductions for local telecommunications for agencies; to	 
expand their choices of high-quality services; and to encourage  
cross-agency sharing of resources. Service providers that are	 
awarded contracts under the program are allowed to compete for	 
GSA's FTS2001 long distance service contracts, so that federal	 
agencies may potentially acquire end-to-end local and long	 
distance telecommunications services from one source. Only 5 of  
the 19 metropolitan areas that were scheduled to switch from	 
existing services to MAA services by or before March 1, 2002,	 
have done so.  Although the program was intended to take	 
advantage of emerging competition in the local telecommunications
market, it has been beset by implementation challenges, including
access and use of building riser cabling, the transfer of local  
numbers between service providers, and a contractor's financial  
problems. On top of the cost of the contract services, GSA	 
charges customer agencies fees that range from about nine to 97  
percent or from $1.20 to $8.49 per line per month. Because GSA	 
does not disclose its management fees unless asked, customer	 
agencies do not necessarily have complete information to help	 
them determine whether using GSA's full range of services is	 
their most cost-effective approach. As of March 2002, GSA has	 
allowed its MAA and FTS2001 contractors to offer services in both
the local and long distance markets, a process termed		 
"crossover."							 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-02-325 					        
    ACCNO:   A02950						        
  TITLE:     Telecommunications: GSA Action Needs to Realize Benefits 
of Metropolitan Area Acquisition Program			 
     DATE:   04/04/2002 
  SUBJECT:   Competitive procurement				 
	     Contract administration				 
	     Cost control					 
	     Federal procurement				 
	     Fees						 
	     Government contracts				 
	     Prices and pricing 				 
	     Telecommunication					 
	     Telecommunication industry 			 
	     Federal Telecommunications System 2001		 
	     FTS 2001						 
	     GSA Metropolitan Area Acquisition			 
	     Program						 
                                                                 


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GAO-02-325
     
A

Report to the Chairman, Subcommittee on Technology and Procurement Policy,
Committee on Government Reform, House of Representatives

April 2002 TELECOMMUNICATIONS GSA Action Needed to Realize Benefits of
Metropolitan Area Acquisition Program

GAO- 02- 325

a

GAO United States General Accounting Office

Why GAO Did This Study

The Metropolitan Area Acquisition (MAA) program, managed by the General
Services Administration (GSA), provides local telecommunications services to
government agencies in selected metropolitan areas. Under this nonmandatory
program, local telecommunications services are to be transitioned from
existing service providers to MAA contractors within 9 months after
contractors are given notice to proceed. GAO was asked to determine, among
other things, the status of MAA contract implementation and identify reasons
for any delays.

April 2002 TELECOMMUNICATIONS GSA Action Needed to Realize Benefits of
Metropolitan Area Acquisition Program

This is a test for developing highlights for a GAO report. The full report,
including GAO?s objectives, scope, methodology, and analysis is available at
www. gao. gov/ cgi- bin/ getrpt? GAO- 02- 325. For additional information
about the report, contact Linda Koontz (202- 512- 6240). To provide comments
on this test highlights, contact Keith Fultz (202- 512- 3200) or E- mail
HighlightsTest@ gao. gov.

Highlights of GAO- 02- 325, a report to the Chairman, Subcommittee on
Technology and Procurement Policy, Committee on Government Reform, House of
Representatives.

What GAO Recommends

To improve MAA program administration, GSA should develop current, realistic
time frames for completing ongoing MAA contract implementations, and it
should develop and apply appropriate performance measures to monitor and
manage the progress of those implementation efforts.

In written comments on a draft of this report, the administrator of General
Services agreed with our recommendations and indicated that GSA was acting
to implement them.

United States General Accounting Office

What GAO Found

Although MAA contract implementation is progressing, in most metropolitan
areas GSA remains behind schedule for completion. Of 19 areas that were to
have completed the transition from existing services to MAA services by or
before March 1, 2002, 5 have done so. In the remaining areas, implementation
progress has been slow. For example, the first three pilot cities- New York,
Chicago, and San Francisco- were to have completed implementation by April
2000. As of March 1, 2002, New York had converted 37 percent of users to MAA
contracts, Chicago had converted 73 percent, and San Francisco had converted
68 percent. (The table below shows implementation status for the 19 areas,
as of March 1, 2002.) Prompt implementation of MAA contracts is central to
the major goal of the program: to achieve immediate and sustained price
reductions by taking advantage of emerging competition in the newly
deregulated telecommunications market. This goal has been met, in that MAA
contracts do offer lower rates; however, savings cannot be fully realized
until the transition to the new contracts is complete.

This transition has been delayed by a range of challenges facing GSA and the
MAA contractors. Some stem from changes in the local telecommunications
market as a result of deregulation and are beyond GSA?s control (such as
disputes concerning ownership and access to cables within buildings). Others
include insufficient preparedness on the part of contractors and customers.
However, the timely resolution of problems causing delays is hindered in
part because GSA has not revised its 9month goal for transition (even though
this time has elapsed in most cases), nor has it devised performance
measures for gauging progress. Without realistic time goals and adequate
performance measures, GSA is hampered in effectively managing
implementation.

Status of MAA Implementation as of March 1, 2002 MAA city

Months since notice to

proceed Percentage

complete MAA city Months since

notice to proceed

Percentage complete

Albuquerque 17 12% Denver 18 93% Atlanta 20 11% Indianapolis 20 93%
Baltimore 20 22% Los Angeles 20 25% Boise 12 a 100% Miami 20 4% Boston 18 8%
Minneapolis 12 a 100% Buffalo NA 100% New Orleans 16 81% Chicago 32 73% New
York 32 37% Cincinnati NA 100% San Francisco 32 68% Cleveland 20 78% St.
Louis 10 a 100% Dallas 18 22% Note: NA indicates that Implementation was
complete within 9 months of notice to proceed. a Months from notice to
proceed until 100 percent complete.

G A O Accountability Integrity Reliability

Highlights

Page i GAO- 02- 325 Telecommunications Letter 1

Results in Brief 2 Background 4 MAA Implementation Is Progressing but Is
Behind Schedule 7 Management Fees Vary Widely and Are Not Transparent to

Customers 14 GSA Has Taken Action to Enable Crossover 18 Conclusions 20
Recommendations 20 Agency Comments 21

Appendix I Objectives, Scope, and Methodology 22

Appendix II Comments from the General Services Administration 25

Tables

Table 1. MAA Contracts Awarded as of January 9, 2002 5 Table 2: GSA Local
Telecommunications Management Fees for FY

2002 (Sorted by Total Fee Percentage) 15 Table 3: Current MAA Customer and
Potential Customer Sites

Visited 23

Figures

Figure 1: Implementation Status as of March 1, 2002 9 Figure 2: Progress of
MAA Crossover by Metropolitan Area as of

March 1, 2002 19

Abbreviations

FTS Federal Technology Service GSA General Services Administration MAA
Metropolitan Area Acquisition Contents

Page 1 GAO- 02- 325 Telecommunications

April 4, 2002 The Honorable Tom Davis Chairman Subcommittee on Technology
and Procurement Policy Committee on Government Reform House of
Representatives

Dear Mr. Chairman: As you know, the Metropolitan Area Acquisition (MAA)
program provides local telecommunications services to federal agencies in
selected metropolitan areas. The MAA program manager, the General Services
Administration (GSA), initiated the program in 1997 to achieve immediate,
substantial, and sustained price reductions for local telecommunications for
agencies, to expand their choices of high- quality services, and to
encourage cross- agency sharing of resources. Further, service providers
that are awarded contracts under the MAA program are allowed to compete for
GSA?s FTS2001 long distance service contracts, so that federal agencies may
potentially acquire end- to- end local and long distance telecommunications
services from one source.

On June 13, 2001, we presented testimony on our preliminary work on the
status of the MAA program, 1 reporting on three topics: the status of MAA
contract implementations, the fees that GSA charges customer agencies for
managing and administering MAA contracts, and the steps taken by GSA to
enable MAA (local) and FTS2001 (long distance) contractors to cross over
between these programs and competitively offer both types of services.
Following our testimony, we agreed to pursue three objectives in our
continuing evaluation of the program:

 to determine the status of MAA contract implementation and identify the
reasons for delays encountered,  to document the fees that GSA charges
customer agencies for managing

and administering the MAA contracts and determine the extent to which those
fees are transparent to customer agencies, and

1 U. S. General Accounting Office, Telecommunications: Metropolitan Area
Acquisition Program Implementation and Management, GAO- 01- 798T
(Washington, D. C.: June 13, 2001).

United States General Accounting Office Washington, DC 20548

Page 2 GAO- 02- 325 Telecommunications

 to identify the steps that GSA is taking to enable the MAA and FTS2001
contractors to cross over between these sets of contracts and offer both
local and long distance services.

This report is based on our June 2001 testimony and on further work we have
performed since then. Appendix I contains a detailed discussion of our
objectives, scope, and methodology. We conducted our work from April 2001
through March 2002 in accordance with generally accepted government auditing
standards.

Although MAA contract implementation continues to progress, in most
metropolitan areas GSA remains behind schedule for completion. Of 19
metropolitan areas that were to have completed the transition from existing
services to MAA services by or before March 1, 2002, 5 have done so. In the
remaining metropolitan areas, implementation progress has been slow. For
example, the first three MAA pilot cities- New York, Chicago, and San
Francisco- were to have completed implementation by April 2000. As of March
2002, New York had converted 37 percent of users to MAA contracts, Chicago
had converted 73 percent, and San Francisco had converted 68 percent.

Implementation of the MAA contracts has been delayed by several significant
challenges that have faced GSA and MAA contractors. Although the program was
initiated by GSA to take advantage of emerging competition in the local
telecommunications market, some of the sizable implementation challenges-
access and use of building riser cabling, 2 the transfer of local numbers
between service providers, and the financial difficulties of an MAA
contractor- have their roots in this newly competitive environment. Delays
have also arisen from challenges unrelated to the new market environment,
including the charges associated with service initiation and equipment
replacements, as well as a lack of contractor and customer preparedness. By
delaying contract implementation, these challenges in turn postpone the
realization of savings that could accrue from the MAA contracts, which can
offer significantly lower costs to agencies.

2 A riser cable carries telecommunications services from the network
demarcation point to distribution facilities within a building. The network
demarcation point, which is typically in the basement of a building, is the
point of interconnection between the local exchange carrier?s facilities and
the wiring and equipment at the end user?s facilities. Results in Brief

Page 3 GAO- 02- 325 Telecommunications

GSA has taken some positive measures to improve contract administration and
implementation. For example, actions taken to improve GSA?s personnel and
processes in Chicago and to overcome contractor performance problems in Los
Angeles and San Francisco have improved implementation progress in those
cities. Nevertheless, the timely resolution of problems causing delays is
hindered in part because GSA has not established current completion
schedules and performance measures for its MAA contracts. Specifically,
although its 9- month goal for implementing existing contracts has passed in
most cases, GSA has not revised its targets for completing these
implementations, nor has it established performance measures for monitoring
their completion. Without revised time frames and appropriate performance
measures, GSA managers have no baseline against which to monitor and more
effectively manage the progress of specific MAA implementation efforts.

To support its MAA contract management services, GSA charges customer
agencies fees that currently range in total from about 9 to 97 percent or
from $1.20 to $8.49 per line per month (depending on the specific
metropolitan area); these percentages are in addition to the cost of the
contract services. Agencies can avoid one type of fee, the ?full- service
fee? for ordering and billing services, if they choose to perform these
functions themselves. However, because GSA does not disclose its management
fees unless specifically requested by customer agencies, these customers do
not necessarily have complete information to help them determine whether
using GSA?s full range of services is their most cost- effective approach to
these contracts.

GSA has taken action in the past 17 months to allow MAA and FTS2001
contractors to offer services in both the local and long distance markets, a
process termed ?crossover.? In December 2000, GSA opened the contracts in
the first three MAA cities to crossover from eligible MAA and FTS2001
contractors. In August 2001, GSA opened its FTS2001 contracts to crossover
by MAA contractors, as envisioned in the 1997 strategy. As of March 1, 2002,
GSA had opened all of its eligible MAA cities to crossover.

To address the shortcomings we identified and to improve program
administration, we are making recommendations to GSA to establish current,
realistic contract implementation time frames and to make management fees
and the services they cover transparent to customer agencies.

Page 4 GAO- 02- 325 Telecommunications

In written comments on a draft of this report, the administrator of General
Services agreed with our recommendations and said that GSA was acting to
implement them.

GSA began planning the MAA program just a few months after passage of the
Telecommunications Act of 1996, which was intended to increase competition
and reduce regulations in the telecommunications industry. The MAA program
sought to take advantage of emerging competition in the local services
market; the program focused on the largest cities in the country, whose
population density would be likely to draw competitors into their markets.
GSA recognized that this emerging competition would create an opportunity
for the government to gain an immediate price reduction in local
telecommunications services. Further, it envisioned the MAA contracts as a
complement to existing contracts in metropolitan areas, as well as a
solution for local service contracts that were expiring.

The MAA program is a set of contracts offering local voice and selected data
telecommunications services. Each contract is a fixed- price, indefinite-
delivery, indefinite- quantity contract with a base term of 4 years (48
months) from date of award, with four successive 1- year options. The
contracts state that all initial service locations identified in these
contracts are to be transitioned to the MAA contracts within 9 months after
GSA gives ?notice to proceed,? which is an authorization for the contractor
to begin implementation.

As indicated in table 1, the initial stage of the MAA program (phase I)
consisted of pilot acquisitions in the New York, Chicago, and San Francisco
metropolitan areas in May 1999. Encouraged by substantially lower prices in
these three pilot cities, GSA expanded the MAA program to other metropolitan
areas throughout the country and awarded contracts in 17 additional cities
(phase II) between February 2000 and February 2001. In its latest series of
MAA acquisitions (phase III), GSA recently awarded contracts in three cities
(San Antonio in August 2001, Detroit in November 2001, and Norfolk in
January 2002), and contracts are planned to be awarded soon in two
additional cities (Salt Lake City and Seattle). GSA estimates that the
federal government could save about $1.1 billion over Background

Page 5 GAO- 02- 325 Telecommunications

the 8- year life of the 37 phase I and phase II MAA contracts awarded to
date. 3

Table 1. MAA Contracts Awarded as of January 9, 2002 Metro area Award date
Estimated savings

(millions of dollars) Contractor( s) Phase I (pilot)

New York 20 May 1999 $150.0 AT& T Chicago 20 May 1999 75.0 AT& T San
Francisco 20 May 1999 32.0 AT& T

Phase II

Buffalo 24 Feb. 2000 6.4 AT& T Verizon Cincinnati 23 Mar. 2000 36.6 Winstar
Cleveland 24 Mar. 2000 20.0 Ameritech (SBC)

AT& T Los Angeles 24 Mar. 2000 47.0 Pacific Bell (SBC)

Winstar Baltimore 28 Mar. 2000 44.0 Winstar Atlanta 26 Apr. 2000 174.0 Bell
South

Winstar Miami 26 Apr. 2000 44.0 Bell South

Winstar Indianapolis 27 Apr. 2000 51.0 AT& T

SBC Global Winstar St. Louis 27 Apr. 2000 36.0 Southwestern Bell (SBC)

Winstar Minneapolis 31 May 2000 13.0 Qwest

Winstar Dallas 30 June 2000 128.0 AT& T

Southwestern Bell (SBC) Winstar Denver 12 July 2000 68.0 AT& T

Qwest Winstar Boston 31 July 2000 78.0 AT& T

Southwestern Bell (SBC) Verizon Winstar Albuquerque 31 Aug. 2000 19.0 Qwest
Boise 31 Aug. 2000 6.5 Qwest

3 GSA based these savings estimates on the difference between current
service prices in effect for each of the first 20 MAA cities and the total
amount of the lowest offeror?s prices for a given city. For the phase III
cities, GSA did not estimate total savings.

Page 6 GAO- 02- 325 Telecommunications

Metro area Award date Estimated savings (millions of dollars) Contractor( s)

New Orleans 16 Oct. 2000 11.0 Bell South Philadelphia 27 Feb. 2001 66.0 AT&
T

Winstar

Phase III

San Antonio 13 Aug. 2001 a Southwestern Bell Winstar Detroit 19 Nov. 2001 a
Southwestern Bell

Winstar Norfolk 9 Jan. 2002 a Verizon

a According to GSA, it no longer reports estimated savings for MAA awarded
cities because of difficulties forecasting for nonmandatory contracts.
Source: GSA Federal Technology Service.

Federal agencies are not required to use the MAA contracts. Depending on
their specific requirements, federal agencies may use the telecommunications
services provided through a GSA regional telecommunications services program
4 (using either the MAA contracts or one of GSA?s other local services
contracts or agreements), or they may acquire and manage their own local
telecommunications services and the associated equipment.

GSA?s Federal Technology Service (FTS) has responsibility for the MAA
program. FTS headquarters is responsible for planning and program
management, while GSA?s field offices implement and administer the MAA
contracts. As a self- sustaining organization, GSA assesses customer
agencies two types of management fees to finance its activities: a contract
management fee and a full- service fee. The contract management fee is
intended to recoup the cost of general program, acquisition, and contract
management activities and is applied as a percentage of service cost. In
addition to the contract management fee, the full- service fee is an
optional fee charged to those agencies that use GSA staff to support MAA
service ordering, implementation planning and coordination, and billing. It
also is applied as a percentage of the cost of contract service.

4 FTS offers a variety of programs through which agencies can acquire local
telecommunications service. For example, the Aggregated System Procurement
Program consolidated local requirements into an overall system procurement
based on the Bell Operating Company boundaries. The Individual System
Procurement Program serves locations that the aggregated program does not.
In addition, regional FTS offices have also obtained Rate Stabilization
Agreements that allow agencies to acquire local tariffed telecommunications
services at short- term discounts.

Page 7 GAO- 02- 325 Telecommunications

Although the MAA program focuses on local services, it also has implications
for increased competition in both the local services and the long distance
markets. Part of the overall FTS program strategy, developed in 1997 in
consultation with industry and the Congress, was to eventually permit
contractors to offer both local and long distance services through three
types of crossover: between the local MAA contracts; from local MAA
contracts to the long distance FTS2001 contracts; and from the FTS2001
contracts to the local MAA contracts. This crossover was envisioned to yield
two important benefits: first, ensuring the government the opportunity to
receive the best contract price and service for local and long distance
services, and second, maximizing competition for those services in both
markets. Crossover was not intended to go into effect immediately: both the
MAA and the FTS2001 contracts had to be in effect for 1 year, known as the
forbearance period, before they could be modified to permit crossover.
Furthermore, GSA delayed allowing MAA contractors to offer FTS2001 services
until it could be sure that the minimum revenue guarantees to the current
FTS2001 contractors would be met. 5

Although MAA contract implementations continue to progress, in most
metropolitan areas GSA remains behind schedule for completing these efforts.
Specifically, of 19 metropolitan areas that were to have completed the
transition from existing services to MAA services by or before March 1,
2002, 5 have done so. GSA had planned to complete the transition of 100
percent of its customer base in all 20 phase I and phase II MAA cities by
the end of March 2002. GSA is unlikely to meet this March deadline, however,
because as of March 1, 2002, the MAA program was providing service to about
52 percent of potential MAA users, so that about 77,000 potential customers
are not yet transitioned. 6

5 Each FTS2001 contractor is guaranteed minimum revenues of $750 million
over the life of the FTS2001 contract. The implications of these revenue
guarantees on GSA?s decision to allow other service providers to compete in
the FTS2001 market were addressed in a previous report: U. S. General
Accounting Office, Telecommunications: GSA?s Estimates of FTS2001 Revenues
Are Reasonable, GAO/ AIMD- 00- 123 (Washington, D. C.: April 2000).

6 The figure for currently serviced users is based on the number of users
converted to MAA contracts as of March 1, 2002 (84, 409), compared to the
total number of potential MAA users identified by GSA (161, 582), as
recorded by GSA?s MAA management reporting system. MAA Implementation

Is Progressing but Is Behind Schedule

Page 8 GAO- 02- 325 Telecommunications

Reasons for delays vary. Although GSA initiated its MAA program to take
advantage of emerging competition in the local telecommunications market,
some sizable implementation challenges arose directly from this new
environment. Challenges unrelated to the market environment have also
noticeably delayed contract implementation: for example, the customer
charges associated with service initiation and equipment replacements, as
well as a lack of contractor and customer preparedness. Although it has
taken some steps to move the implementation efforts forward, GSA has not
established current, realistic time frames for completing ongoing MAA
implementations, nor has it established performance measures for monitoring
implementation. These gaps inhibit its ability to expeditiously resolve
transition impediments. As a result, federal agencies in many locations are
not realizing the potential cost savings offered by the MAA program.

Although the MAA contracts require the transition of initial service
locations to be completed within 9 months after contractors are given notice
to proceed, this transition has not been as fast as anticipated. The
transition goal was achieved in two metropolitan areas (Buffalo and
Cincinnati); three other metropolitan areas (Minneapolis, St. Louis, and
Boise) have also completed MAA contract implementation, although not within
the 9- month goal. Figure 1 gives the dates that GSA notified the respective
contractors to proceed with contract implementation and the implementation
status for each awarded city. As shown in figure 1, although the goal for
completing MAA contract implementations for the three phase I cities was
April 2000, only 68 percent of users in San Francisco, 73 percent of users
in Chicago, and 37 percent of users in New York had been converted to MAA
contracts by March 1, 2002. Contract Implementation

Has Been Delayed

Page 9 GAO- 02- 325 Telecommunications

Figure 1: Implementation Status as of March 1, 2002

Note: Complete implementation is indicated by dark progress bars and dark
boxes around city names.

Source: GSA Federal Technology Service.

Those cities showing greatest progress with implementation have typically
benefited from simpler transition requirements. For example, Denver,
Cincinnati, and St. Louis were primarily transitioning private branch

Page 10 GAO- 02- 325 Telecommunications

exchange trunks, 7 which are relatively few in number, as compared to
transitioning individual business lines, which typically involve higher
volumes and additional effort. Buffalo, Minneapolis, New Orleans, and Boise
placed most of their MAA service orders with the incumbent service
providers.

The challenges facing GSA and the MAA contractors have hampered timely
completion of the MAA contracts and thus the realization of maximum MAA
contract savings. Some of these challenges arose as a result of the newly
deregulated local telecommunications market: disputes over MAA contractors?
access to and use of building riser cabling, problems in coordinating the
transfer of local telephone numbers between service providers, and the
financial difficulties of an MAA contractor. For example:

 Although the MAA contractor in New York was authorized to proceed with
implementation in July 1999, more than 2 years later that transition effort
is only 13 percent complete. Over half the estimated 21,000 lines to be
transitioned were affected by a dispute over access to and use of building
riser cables. That is, following the AT& T divestiture in 1984, 8 Verizon
was permitted to retain ownership rights to substantially all the building
riser cabling in the New York metropolitan area. This riser cabling carries
telecommunications services from the local exchange carrier?s facilities
(typically located in the basement of a building) up to the end user?s
facilities, located on each floor throughout a building. In order for AT& T
or another competitive local exchange carrier to provide service to tenants
in an affected building, such a carrier must either construct its own cable
riser in the building or compensate Verizon for access to and use of the
existing riser cable. Clarification of riser cable access and compensation
issues was the subject of a New York State Public Service Commission
hearing. In June 2001, this commission issued an order allowing competitive
local exchange carriers such as AT& T to have direct access to riser cable
owned by other carriers. Following that decision, GSA and

7 A private branch exchange (PBX) is a piece of equipment that acts as an
organization?s own internal telephone switch, handling internal calls and
all the connections to and from the public telephone network.

8 As a result of an antitrust suit by the U. S. government, in January 1984
AT& T divested itself of the Bell operating companies that provided local
exchange service, yielding an AT& T corporation providing long distance
services and seven independent regional telephone companies providing local
services. Numerous Causes

Contribute to Delays in Implementation

Page 11 GAO- 02- 325 Telecommunications

AT& T reached agreement on a contract modification in November 2001
recognizing this added cost; GSA expects this agreement to resolve this
long- standing impediment.

 The riser cable access issue is also a transition impediment in Atlanta
and Miami, affecting about 85 percent of buildings housing prospective MAA
customers in those cities, and about half the total lines to be served.
Although this issue first arose in Miami in December 2000, efforts are still
pending to resolve the cost issue between GSA and the affected MAA
contractor in both cities.

 Our review of program management data in Atlanta, Chicago, and Miami found
problems associated with coordinating the transfer of telephone numbers from
one local carrier to another. These problems have delayed the MAA
contractors? implementations for periods ranging from 3 to 7 weeks.

 In Atlanta and Miami, another implementation impediment has been the
financial condition of an MAA contractor. 9 This contractor?s bankruptcy
filing prompted several customer agencies to postpone their participation in
the MAA program and caused one building manager in Miami to deny the
contractor building access required to provide service to agencies in that
location.

In addition to challenges associated with the recently deregulated local
telecommunications market, other difficulties are slowing implementation of
MAA contracts: these include the customer charges associated with initiating
services and replacing equipment, as well as a lack of contractor and
customer preparedness. Because costs can be incurred just to implement the
MAA contracts (for example, service initiation charges and the cost of
changing or upgrading customer telecommunications equipment), the ability of
agencies to accommodate these added costs within their budgets can influence
the timing of MAA implementation and in some cases deter agencies from
participating. In Boston, for example, these costs have delayed
implementation of about half the prospective MAA service lines in that city.
Further, according to GSA records, contractors have not been prepared in
some cases for implementing services or have had problems with their
equipment. These issues have delayed implementations for times ranging from
12 days to 7 months in

9 In April 2001, Winstar Communications, Inc., voluntarily filed for
protection under Chapter 11 of the U. S. Bankruptcy Code with the U. S.
Bankruptcy Court for the District of Delaware. In December 2001, the IDT
Corporation acquired substantially all the operating assets of Winstar
Communications pursuant to a sale order by the U. S. Bankruptcy Court.
Winstar MAA services continue to be provided to GSA and its customers at
this time.

Page 12 GAO- 02- 325 Telecommunications

Atlanta, Chicago, Indianapolis, New York, and San Francisco. These records
also show that customer preparedness and delays in making MAA decisions have
also been factors slowing implementations in Chicago, New York, and San
Francisco.

Although some factors hindering implementation progress are beyond GSA?s
ability to control, its ability to expeditiously resolve impediments and
minimize delays has been constrained by two gaps in its program management.
First, GSA has not established current time frames for implementing specific
MAA contracts. For example, although only 2 out of 19 metropolitan areas
that began implementation 9 months ago or more actually met GSA?s initial 9-
month implementation goal, GSA has not established new time frames that
would enable it to manage the timely completion of the remaining efforts.
Second, GSA has not established performance measures that would enable its
managers to better monitor and measure the completion of specific contract
implementation efforts. Without revised time frames for completing these
specific contract implementations and without appropriate performance
measures, GSA managers have no clear, current, or coherent measurement
baseline against which to monitor and more effectively manage the progress
of the various MAA implementation efforts.

Without such an established baseline, managers may not take prompt action to
resolve impediments before they cause lengthy delays. For example:

 Although the MAA contractor in Albuquerque was authorized to proceed with
implementation in October 2000, over a year later only 2 percent of
prospective MAA users have been converted. One factor hindering
implementation was higher contract pricing for one required service,
affecting more than 60 percent of prospective MAA users in Albuquerque. GSA
executed a contract modification in August 2001 to improve pricing for this
service and enable its implementation to go forward. Prompt understanding of
the severity of this impediment could have hastened its resolution.

 A further disagreement between GSA and the Albuquerque MAA contractor,
concerning the network demarcation point, 10 first arose in October 2000,
stalling progress on an additional 36 percent of the

10 A network demarcation point is the point of interconnection between the
local exchange carrier?s facilities and the wiring and equipment at the end
user?s facilities.

Page 13 GAO- 02- 325 Telecommunications

prospective MAA lines in that area. Although agreement on a solution was
ostensibly reached by GSA regional staff and the contractors involved in
April 2001, it was not until October 2001 that GSA FTS headquarters finally
issued a decision that defined network demarcation points and brought the
matter to a close. Had the extent of this obstacle been more quickly
understood, the problem might have been resolved more rapidly.

The slow completion of contract modifications is not unique to Albuquerque;
MAA implementations in Chicago and in Indianapolis have also been held up,
pending completion of necessary modifications.

In an effort to improve contract administration and implementation, GSA has
revised its aggregate program- level goals. Specifically, GSA has changed
its goal of completing the transition of 100 percent of prospective
customers in all phase I and phase II MAA cities by March 2002; its new goal
is to transition 50 percent of prospective customers by April 2002. GSA
believes that this goal is sufficient to manage MAA implementation. GSA is
also developing aggregate program- level performance measures and is
refining the processes that will be used for tracking and reporting.

Although these are positive steps, they are not a substitute for specific
contract implementation time frames and performance measures. Aggregate
goals and performance measures are not adequate to manage MAA
implementation, because they do not allow managers to readily determine (1)
when a specific implementation effort is taking more time than expected, (2)
how to measure the loss of potential savings in such cases in order to
prioritize and expedite corrective actions, or (3) how many resources and
how much time they should devote to overcoming impediments.

Despite this shortcoming, GSA has taken positive measures to improve
contract administration and implementation. In Chicago, for example, GSA?s
implementation efforts had initially been hampered in part by its own
turnover in staff, an inadequate approach to managing service order
implementations, and poor communications with its MAA contractor. By January
2001, GSA began taking steps to solve its staffing problems and bring order
and focus to its regular communications with its contractor, and in June
2001, it implemented a new ordering process for MAA services. Our analysis
of GSA management data indicates that after these steps were completed, the
pace of MAA implementation improved in Chicago (although some implementation
problems remain). In San Francisco and Los Angeles, GSA?s managers also took
steps to overcome

Page 14 GAO- 02- 325 Telecommunications

performance problems with the contractors by exercising existing contractual
remedies to prompt performance improvement.

GSA?s positive steps notwithstanding, the implementation delays that persist
lead to increased cost: the loss of the potential savings afforded by the
MAA contracts. GSA had estimated that the MAA program could save about $1.1
billion, basing its estimate on the difference between service prices in
effect for each of the 20 phase I and phase II MAA cities at the outset of
the program and the total amount of the lowest MAA offeror?s prices for a
given city. However, this estimate did not take into account the time
required to implement these contracts. Because savings are not realized
until the service is actually implemented, delays in implementing the
contracts in turn delay the realization of substantial cost savings and
limit what can be realized over the 8- year term of the contracts. For
example, we analyzed average monthly line rates for all 20 MAA cities within
Phase I and Phase II before and after MAA contract awards, and determined
that federal agencies in these cities may be forgoing as much as $1.1
million dollars per month in cost savings for those users not yet
transitioned to MAA contracts (approximately 75,000 users 11 ).

The two types of management fees that GSA charges vary widely among the
metropolitan areas served. When expressed as a percentage of the
contractor?s base rate, GSA?s full- service fee ranges from a low of 5.5
percent in St. Louis to a high of almost 51 percent in San Francisco.

Table 2 identifies the fees that GSA has set for its MAA contracts. For
purposes of comparison, we have also computed a total fee that combines the
contract management and full- service fees.

11 These 75, 000 potential users are those in the first 20 MAA awarded
cities; the figure of 77,000 potential users, given earlier, represents
users in all MAA cities. Management Fees

Vary Widely and Are Not Transparent to Customers

Page 15 GAO- 02- 325 Telecommunications

Table 2: GSA Local Telecommunications Management Fees for FY 2002 (Sorted by
Total Fee Percentage) Fees (%) Fees (in dollars)

Metro area Contract management Full service Total fee a Contractors? line

rate b GSA?s total fee c Total line rate d

New York 47.27% 50.13% 97.40% $3.85 $3.75 $7.60

San Francisco 24.81% 50.95% 75.76% $4.18 $3.17 $7.35

Philadelphia 33.00% 30.70% 63.70% $9.33 $5.94 $15.27

San Antonio 15.04% 40.26% 55.30% $6.78 $3.75 $10.53

Boston 38.12% 15.68% 53.80% $10.97 $5.90 $16.87

Baltimore 31.96% 17.11% 49.07% $4.85 $2.38 $7.23

Denver 8.25% 40.74% 48.99% $17.33 $8.49 $25.82

Albuquerque 14.98% 32.23% 47.21% $15.95 $7.53 $23.48

Dallas 17.00% 25.60% 42.60% $10.47 $4.46 $14.93

Buffalo 32.93% 8. 25% 41.18% $13.09 $5.39 $18.48

Miami 28.00% 11.52% 39.52% $10.50 $4.15 $14.65

Detroit 30.00% 9. 00% 39.00% $12.49 $4.87 $17.36

Chicago 11.99% 24.85% 36.84% $3.42 $1.26 $4.68

Atlanta 25.98% 8. 80% 34.78% $9.20 $3.20 $12.40

Boise 5. 17% 28.90% 34.07% $15.05 $5.13 $20.18

New Orleans 14.03% 19.06% 33.09% $12.33 $4.08 $16.41

Los Angeles 13.92% 13.92% 27.84% $7.55 $2.10 $9.65

Indianapolis 1.77% 19.40% 21.17% $9.59 $2.03 $11.62

St. Louis 9.46% 5.49% 14.95% $13.85 $2.07 $15.92

Minneapolis 1.97% 11.26% 13.23% $16.78 $2.22 $19.00

Cincinnati 4. 27% 8.87% 13.14% $9.13 $1.20 $10.33

Cleveland 0. 89% 7.78% 8.67% $21.33 $1.85 $23.18

Note: Table 2 does not include Norfolk, which GSA recently awarded. a Total
fee equals contract management fee plus full- service fee.

b GSA computes a monthly weighted average analog line rate for all
contractors within a single MAA city. c GSA?s total fee equals contractors?
line rate times total fee.

d Total line rate equals contractors? line rate plus GSA?s total fee. Source
for contract management, full- service fee percentages, and weighted average
line rate: GSA Federal Technology Service.

Like other federal agencies that provide centralized services, GSA charges
these fees to recover the costs of managing the program. For example, the
contract management fee is meant to cover GSA?s cost to issue the contracts
and to resolve contract interpretation issues, disputes, and discrepancies
and to issue contract modifications. This fee is also intended to recoup the
cost of MAA program management and oversight. The optional full- service fee
is meant to cover costs associated with such

Page 16 GAO- 02- 325 Telecommunications

functions as initiating and executing service orders and monitoring service
implementation, monitoring contractor performance, coordinating government-
furnished property availability, coordinating site access for contractor
personnel, reviewing contractor invoices, and serving as customer point of
contact for technical issues.

In this type of service model, making the amounts and purposes of fees
transparent to users is appropriate and useful. First, disclosing fee
amounts provides user agencies with key input for deciding whether to
acquire services from the service provider or from alternative sources.
Second, such disclosure helps enable customers to hold the service provider
accountable for providing a level of performance commensurate with the fees
charged.

Because use of the MAA contracts is not mandatory, agencies can choose to
procure local services on their own, if they believe they could do so more
economically than going through GSA. In addition, to avoid paying the full-
service fee, a customer agency can opt to use the MAA contracts? direct
ordering and direct billing option. In so doing, the agency assumes
responsibility for its service ordering, implementation planning and
coordination, and billing management.

Rather than disclosing to agencies the fees that GSA charges, the MAA
contracts require contractors to embed the contract management fee in their
service pricing. GSA took this approach to focus agencies? attention on
making decisions based on the total cost of obtaining telecommunications
services, rather than on the management fee percentage. Its position was
that even with the management fees included, the total cost of local
telecommunications services under the MAA contracts is dramatically lower
than what is available under its other local service contracts.

As shown in table 2, comparing the fees according to percentages provides
only a partial picture- it is important to consider also the dollar amounts.
For example, the fee that GSA charges to manage and administer MAA contracts
in New York is 97 percent in addition to the contractor?s monthly line rate.
Although this fee appears high when viewed on a percentage basis, it equals
$3.75 per line. In contrast, MAA customers in Denver are charged a total
management fee of 49 percent (about half New York?s total fee percentage);
this translates, however, into $8.49 per line- more than double the dollar
amount that GSA charges in New York.

Page 17 GAO- 02- 325 Telecommunications

Of the 12 MAA customer agencies we met with in Atlanta, Chicago, Dallas,
Denver, and New York, none were aware of the actual amounts of the GSA
management fees that they were being charged. However, they were all pleased
with the bottom- line cost savings that they were receiving by obtaining
local telecommunications services through the MAA program.

The total cost of service is an important factor in making decisions on how
to buy local services, but specific information on fees would be a further
aid to agency decisionmaking. Without such information, an agency in San
Francisco, for example, would not be aware that it could lower its local MAA
monthly service costs by almost 29 percent or $2.13 per line if it assumed
additional service ordering, billing, and administration responsibilities.
12 Lacking full information on these fees, agencies cannot readily compare
the cost of GSA services with the costs they would incur if they performed
these services themselves. As a result, agencies cannot determine whether it
is more economical for them (1) to procure their own local services, (2) to
procure services through GSA but perform ordering and billing activities
themselves, or (3) to procure services through GSA and pay GSA for support.
If customers were aware of both the fees and rates for their city, they
would be able to make more informed decisions.

At the subcommittee?s June 2001 hearing on MAA contract implementation, we
noted that GSA was not disclosing to agencies the fees it charged for MAA-
related services. At that hearing, the GSA FTS commissioner disclosed the
total percentage of fees GSA was charging. The commissioner further
testified that GSA would reveal fees to customer agencies. Since that time,
GSA has revised its policy on disclosure of fees, and regional
telecommunications directors have been instructed to disclose fees to those
customer agencies that request such information. GSA has also drafted a
listing of the services that agencies can expect in return for these fees.

This action does not ensure adequate disclosure and transparency of fees for
three reasons. First, GSA intends to inform agencies of the fees being
charged only if an agency inquires. Second, GSA has not informed its
customers of this change in policy. As a result, agencies may be unaware

12 An agency?s total local MAA service cost could include the cost of
contractor service, GSA?s contract management fee, and GSA?s full- service
fee. In San Francisco for example, GSA?s full- service fee (51 percent as
high as the cost of contractor service) would represent 29 percent of an
agency?s total monthly MAA service cost.

Page 18 GAO- 02- 325 Telecommunications

that they can now learn what fees they are being charged by GSA. Third, the
listing of services GSA developed to describe what customers receive in
return for their fees does not clearly indicate what fees support the cost
of which services. For example, GSA?s lists of services bought by its
fullservice fee and those bought by its contract management fee overlap
considerably. That is, almost 88 percent of the services it identifies as
being supported by its contract management fee are also identified with its
full- service fee, making it difficult to determine which fee is supporting
which service.

GSA has recently initiated action to reexamine and simplify its management
fee structure. On November 27, 2001, GSA?s Local Rate Setting Redesign Team,
composed of GSA FTS financial, program, and regional telecommunications
personnel, held its first meeting. This group is expected to report to the
FTS assistant commissioner for Local Services in the spring of 2002 on ways
to simplify its fee structure in recouping its costs and to achieve greater
consistency in its fees between regions. At this time, this effort is
focused predominantly on how GSA calculates its fees, rather than on
services rendered in return. However, without disclosure of the management
fees it is charging and a clear delineation of what services are supported
by those fees, the actions taken by GSA will not be adequate to provide the
transparency needed to provide agency decisionmakers with full information.

GSA has taken action in the past 17 months to allow MAA and FTS2001
contractors to offer services in both the local and long distance markets.
In December 2000, GSA allowed FTS2001 and other MAA contractors to submit
proposals to offer local services in the three pilot MAA cities (New York,
Chicago, and San Francisco). In August 2001, GSA published guidance on the
submission and evaluation of proposals to initiate crossover between these
local and long distance contracts, allowing local service providers to offer
long distance services and long distance service providers to offer local
services in MAA markets. Further, as of March 1, 2002, GSA had opened all 20
eligible metropolitan areas to crossover, had received contractor proposals
for 4 of those MAA cities, and had completed a contract modification to
allow crossover in 1 city. GSA Has Taken

Action to Enable Crossover

Page 19 GAO- 02- 325 Telecommunications

Figure 2 summarizes the current status of MAA crossover activity.

Figure 2: Progress of MAA Crossover by Metropolitan Area as of March 1, 2002

Note: According to the MAA contracts, once the forbearance period is over,
GSA can award crossover contract modifications when it is in the
government?s best interests.

Source: GSA Federal Technology Service.

Page 20 GAO- 02- 325 Telecommunications

GSA continues to make progress in implementing the MAA program.
Nevertheless, in many locations GSA has not met its schedules for
transitioning agencies? telecommunications services to MAA vendors, because
of impediments including challenges posed by recent deregulation of
telecommunications services, as well as a lack of MAA contractor and
customer preparedness. As a result of these delays, federal agencies may be
forgoing substantial cost savings- as much as $1.1 million- for each month
of delay in transitioning the remaining approximately 77,000 prospective MAA
customers.

Achieving these cost savings for local telecommunications services- the
primary goal of the MAA program- is hindered because GSA managers are
missing opportunities to improve program administration. Specifically, GSA
has not yet established current and realistic implementation time frames and
associated performance measures to guide and manage the timely completion of
specific, ongoing contract implementations. As a result, GSA lacks a basic
yardstick for more consistent, reliable, and effective measurement and
management actions to address impediments before they cause lengthy delays.
In addition, GSA has not yet made its fees and services transparent to its
customer agencies and disclosed what it charges agencies for the services it
offers.

To improve MAA program administration, we recommend that the administrator
of General Services direct the commissioner of the Federal Technology
Service to

 develop current, realistic timeline objectives and schedules for
expeditiously completing those MAA contract implementations that are
currently in progress and

 use these objectives to develop and apply reliable performance measures to
gauge MAA progress and manage implementations.

To assist federal agencies in making well- informed telecommunications
choices and to improve management of GSA?s own support services, we
recommend that the administrator direct the commissioner of the Federal
Technology Service to

 routinely disclose to MAA customers the fees that GSA charges them for
managing the MAA contracts and for the ordering and billing services it
provides and

 clarify for MAA customers the services that each of the fees supports.
Conclusions

Recommendations

Page 21 GAO- 02- 325 Telecommunications

In written comments on a draft of this report, the administrator of General
Services agreed with our recommendations and indicated that GSA was acting
to implement them. In response particularly to a recommendation in the draft
report regarding opening MAA contracts to crossover on a consistent basis,
GSA agreed to open all eligible MAA cities to crossover by March 1, 2002.
After confirming that GSA had taken that action, we updated this report to
reflect the current status. GSA also provided a number of technical comments
that we have incorporated into this report as appropriate. GSA?s written
comments are presented in appendix II.

As agreed with your office, unless you publicly announce the contents of
this report earlier, we will not distribute it until 30 days from its issue
date. At that time, we will send copies of this report to the ranking
minority member, Subcommittee on Technology and Procurement Policy, and
interested congressional committees. We will also send copies to the
director of the Office of Management and Budget and the administrator of the
General Services Administration. Copies will be made available to others
upon request. This report will also be available on our home page at http://
www. gao. gov.

If you have any questions regarding this report, please contact me or Kevin
Conway at (202) 512- 6240 or by E- mail at koontzl@ gao. gov or conwayk@
gao. gov, respectively. Individuals making key contributions to this report
included Scott Binder, Barbara Collier, Michael Koury, Frank Maguire, Mary
Marshall, and Debra Rucker.

Sincerely yours, Linda D. Koontz Director, Information Management Issues
Agency Comments

Appendix I: Objectives, Scope, and Methodology

Page 22 GAO- 02- 325 Telecommunications

The objectives of our review were to identify (1) the status of Metropolitan
Area Acquisition (MAA) contract implementation and reasons for any delays,
(2) the fees charged customer agencies by the General Services
Administration (GSA) for the management and administration of those
contracts and the extent to which those fees are transparent to customer
agencies, and (3) the steps being taken by GSA to enable MAA and FTS2001
contractors to cross over between these sets of contracts and offer both
local and long distance services.

To evaluate the status of MAA contract implementation efforts, we reviewed
MAA contracting, including solicitations, contracts, and associated
modifications. We reviewed an internal GSA management report on MAA
implementation challenges prepared by GSA?s Office of Inspector General and
interviewed the staff who prepared this report. In addition, we reviewed
reports generated by GSA?s automated MAA status tracking system and verified
the information in the reports against other documentation gathered, such as
tracking reports used by regional GSA staff.

To better gauge specific MAA implementation efforts, we visited five GSA FTS
regional staff offices. We selected these regional offices because they were
responsible for implementing contracts in 14 of the 22 cities that had MAA
contracts in place at the time of our review. These contracts reflected a
range of MAA implementation experiences, as they encompassed a mix of
multiple and single award cities, and included contract awards to
competitive local exchange carriers and to incumbent local exchange
carriers. The staff offices we visited were

 GSA?s Northeast and Caribbean Region in New York, responsible for two MAA
contracts;

 the Southeast Region in Atlanta, responsible for two MAA contracts;

 the Great Lakes Region in Chicago, responsible for five MAA contracts;

 the Greater Southwest Region in Dallas, responsible for four MAA
contracts; and

 the Rocky Mountain Region in Denver, responsible for one MAA contract.
During these visits, we met with responsible GSA management staff and
analyzed information pertaining to each region?s MAA marketing and
transition plans, service ordering and billing processes, and implementation
and administration roles and responsibilities. We also analyzed
documentation pertaining to the challenges each faced in implementing its
MAA contracts. In addition to the offices visited, we reviewed marketing,
transition planning, and contract administration Appendix I: Objectives,
Scope, and

Methodology

Appendix I: Objectives, Scope, and Methodology

Page 23 GAO- 02- 325 Telecommunications

documentation from each of the four other GSA regional offices with MAA
contracts.

To gain customers? perspectives on MAA contract implementation status, we
interviewed 15 agency managers in 5 cities who were responsible for their
agency?s local telecommunications services, as shown in table 3. We also met
with officials from the Executive Office for U. S. Attorneys and the
Executive Office for U. S. Trustees, located in Washington, D. C. Officials
in each of these two offices had nationwide responsibility for local
telecommunications services and were able to offer insight into their
agencies? participation in the MAA program for multiple cities.

In determining which agencies to contact, we chose from a range of larger
and smaller agencies and also selected from both current MAA customers and
potential MAA customers. In our meetings with managers from these agencies,
we obtained documentation and discussed their GSA contract marketing
experience, their transition progress and challenges, their MAA cost
savings, and their knowledge of GSA management fees, where possible and as
appropriate.

Table 3: Current MAA Customer and Potential Customer Sites Visited City
Agency

Atlanta Department of Labor, Regional Administrative Services Office Natural
Resources Conservation Service U. S. Fish and Wildlife Service a Denver
National Institute of Standards and Technology, Boulder, Colo. a

National Renewable Energy Laboratory, Golden, Colo. a U. S. Courts for the
Tenth Circuit, Office of the Circuit Executive Dallas Health and Human
Services, Program Support Center, Administrative

Operations Service Social Security Administration, Southwest Regional Office
Chicago Environmental Protection Agency

Health and Human Services, Program Support Center, Administrative Operations
Service Internal Revenue Service New York Internal Revenue Service, Office
of the Regional Inspector North East

Region Corps of Engineers, New York District a Health and Human Services,
Program Support Center, Administrative Operations Service a Housing and
Urban Development, New York Administrative Service Center a Potential MAA
customer; has not converted yet.

Appendix I: Objectives, Scope, and Methodology

Page 24 GAO- 02- 325 Telecommunications

To gain additional information and documentation pertaining to contractor
experiences with MAA implementation, we met with AT& T MAA program managers
in Washington, D. C., and in New York; Verizon MAA program managers in
Washington, D. C.; and Winstar MAA program managers in Herndon, Virginia.

To determine the management fees charged to customer agencies by GSA and how
those fees were derived, we reviewed GSA?s method for calculating its
management fees and supporting documentation. We also reviewed statutory and
regulatory guidelines 13 governing the establishment of such program fees.
In addition, we reviewed GSA?s MAA management roles and responsibilities and
interviewed FTS program managers as well as the FTS Network Services
Financial Services Center manager responsible for developing the GSA
management fees. We also interviewed customer agencies to determine what
information GSA was disclosing to them regarding the fees that GSA charged
and services rendered.

Finally, to evaluate the actions being taken by GSA to enable MAA and
FTS2001 contractors to cross over within and between these programs, we
obtained and reviewed GSA?s contract language on the forbearance concepts
and process and reviewed both its current guidance on the crossover process
and a report on crossover status. We reviewed GSA?s June 2001 and August
2001 presentations to the Industry Advisory Group, as well as GSA?s response
to questions raised at those presentations. We also reviewed documentation
pertaining to GSA?s December 2000 decision to lift forbearance in the MAA
pilot cities and its first crossover award.

We conducted our review from April 2001 through March 2002, in accordance
with generally accepted government auditing standards.

13 P. L. 99- 500, October 18, 1986, 100 Stat. 1783- 340, and OMB Circular
No. A- 25, Revised (July 8, 1993).

Appendix II: Comments from the General Services Administration

Page 25 GAO- 02- 325 Telecommunications

Appendix II: Comments from the General Services Administration

Appendix II: Comments from the General Services Administration

Page 26 GAO- 02- 325 Telecommunications (310325)

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