USDA Graduate School: Revenue Reporting Needs to Be Improved
(15-OCT-01, GAO-02-5).
The U.S. Department of Agriculture, a nonappropriated fund
instrumentality (NAFI), provides extensive training opportunities
to government employees and others through its Graduate School.
As a NAFI, the Graduate School operates solely on revenue derived
from providing training services. During fiscal year 1999, the
agencies or agency components GAO reviewed had 20 interagency
agreements, totaling about $5.7 million, with the Graduate School
and 531 contracts, totaling about $29 million, with private
companies for training and other related services. The Graduate
School incorrectly identified the portion of revenue that was
earned through interagency agreements in its fiscal year 1999
financial statements. This misclassification resulted primarily
from the Graduate School's reporting policies.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-02-5
ACCNO: A02320
TITLE: USDA Graduate School: Revenue Reporting Needs to Be
Improved
DATE: 10/15/2001
SUBJECT: Education or training
Interagency relations
Schools
Financial statements
Nonappropriated fund instrumentalities
Federal Supply Schedule
******************************************************************
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GAO-02-5
Report to the Subcommittee on Department Operations, Oversight, Nutrition,
and Forestry, Committee on Agriculture, House of Representatives
United States General Accounting Office
GAO
October 2001 USDA GRADUATE SCHOOL
Revenue Reporting Needs to Be Improved
GAO- 02- 5
Page 1 GAO- 02- 5 USDA Graduate School
October 15, 2001 The Honorable Robert Goodlatte Chairman Subcommittee on
Department Operations,
Oversight, Nutrition, and Forestry Committee on Agriculture United States
House of Representatives
Dear Mr. Chairman: The U. S. Department of Agriculture (USDA) provides
extensive training opportunities to government employees and others through
its Graduate School. In fact, the USDA Graduate School has a unique role as
a training source for federal employees. As a nonappropriated fund
instrumentality (NAFI), the USDA Graduate School is not funded through
congressional appropriations; its revenue is solely derived from providing
training services to federal employees and others.
Based on your interest in the USDA Graduate School, you asked several
questions about its role in providing training services. In response to your
questions and after discussions with your office, we agreed to conduct an
evaluation that focused on the following objectives:
* characterizing the purpose and operating structure of the Graduate School,
as a NAFI, determining the extent of training services that selected
federal agencies
obtained from the Graduate School and private companies during fiscal year
1999 and learning how these agencies decide on vendors, and assessing the
reasonableness of interagency agreement revenue reported
by the Graduate School in fiscal year 1999. The U. S. Department of
Agriculture Graduate School is a unique source of training for federal and
other professional staff. It is a nonappropriated fund instrumentality whose
purpose is to provide training to the federal sector as well as to other
organizations and individuals. Although established in 1921 to support the
Department of Agriculture?s research scientists, its purpose and curriculum
have expanded over the years to include many professional disciplines. Its
operations are managed by a governing board that sets policies for the
school. As a NAFI, the Graduate School receives no appropriated funds but
operates solely on revenue derived from providing training services. It is
not a federal agency, and
United States General Accounting Office Washington, DC 20548
Results in Brief
Page 2 GAO- 02- 5 USDA Graduate School
certain federal laws generally applicable to federal agencies, such as the
Freedom of Information Act, do not apply to its operations. However,
Congress specifically authorized federal agencies to enter into interagency
agreements with the Graduate School to obtain training services.
We examined a nonstatistical sample of agencies for which the Graduate
School indicated it had provided training services in fiscal year 1999 and
assessed the scope of training and how the training services were provided.
1 During fiscal year 1999, the agencies or agency components we reviewed had
20 interagency agreements, totaling approximately $5.7 million, with the
Graduate School and 531 contracts, totaling about $29 million, with private
companies for training and other related services. Agency officials
characterized their use of the Graduate School to meet their training
requirements for any given year as limited, ranging from 0 to 11 percent of
an agency?s total annual training budget. All of the surveyed agencies had
specific policies, practices, and procedures that governed the acquisition
of external training for their employees and required the consideration of
other vendors to fulfill a training requirement. When a federal agency
selects the Graduate School as the vendor to provide training, the agency
has several options through which to procure the training, including
contracts or interagency agreements. The agencies indicated that interagency
agreements generally are more convenient because they take less time to
process than contracts.
The Graduate School incorrectly identified the portion of revenue that was
earned through interagency agreements in its fiscal year 1999 financial
statements. Specifically, while the Graduate School reported about $7.1
million in interagency agreement revenue for fiscal year 1999, 2 on the
basis of our stratified random sample, we estimated interagency agreement
revenue to be about $14.9 million. 3 The difference of $7.8 million
represents a misclassification of certain interagency
1 The sample consisted of six agencies with which, we were told by the
school, it had interagency agreements in fiscal year 1999: the Census
Bureau, Customs Service, Federal Deposit Insurance Corporation, Internal
Revenue Service, National Aeronautics and Space Administration, Rural
Development Corporation. The seventh agency in our sample, the Department of
Labor, was identified as not having an agreement during that time. We used
the Department of Labor for comparison purposes.
2 Graduate School, USDA Financial Statements for the Year Ended September
30, 1999.
3 We are 95 percent confident that the interagency agreement revenue is
between $13. 9 million and $15. 9 million based on our review of a
stratified random sample of billings made in fiscal year 1999.
Page 3 GAO- 02- 5 USDA Graduate School
agreement revenue as contract training revenue on the financial statements.
This misclassification resulted primarily from the Graduate School?s
reporting policies. Under those policies, the school classified the fixed-
price portion of interagency agreement revenue as contract training revenue.
Graduate School officials told us that they accumulate revenue as fixed-
price versus cost- reimbursable so that the school can monitor the use of
cost- reimbursable contracts. 4 We also noted two other matters regarding
the processing of revenue transactions and the retention of revenue records.
Specifically, we identified about $600,000 in additional misclassified
transactions and missing supporting documentation for six transactions in
the sample we reviewed. We are making recommendations to the Executive
Director of the Graduate School to improve its reporting of interagency
agreement revenue in its financial statements.
The Graduate School commented on a draft of this report and agreed with our
findings. (See appendix I.)
Nonappropriated fund instrumentalities (NAFI) are federal government
entities whose funding does not come from congressional appropriations but
rather from their own activities, such as the sales of goods and services.
Their receipts and expenditures are not reflected in the federal budget.
NAFIs were established to provide services and items for the morale,
welfare, and recreational needs of government employees. Some NAFIs, for
example the exchange system run by the Department of Defense, are created by
statute. Others are created and regulated by government agencies. Some
NAFIs, for example the Department of Agriculture?s Graduate School, after
being established by an agency, may subsequently receive congressional
approval.
No single federal statute establishes the overall authority to create NAFIs
or defines how they are to operate. The Department of Defense military
exchange system- which includes general retail stores, specialty stores, and
consumer services at military installations- is the largest NAFI program.
Some other agencies that use NAFIs are the Department of Veterans Affairs,
the Coast Guard, and the State Department.
4 Cost- reimbursable contracts provide for payment of allowable incurred
costs, to the extent prescribed in the contract. Absent the contracting
officer?s approval, the contractor exceeds the established cost ceiling at
its own risk. Fixed- price contracts provide for a firm price that is
generally not subject to any adjustment on the basis of the contractor?s
costs in performing the contract. Background
Page 4 GAO- 02- 5 USDA Graduate School
Procurement laws and regulations applicable to federal government agencies
generally do not apply to NAFIs. For example, the Federal Acquisition
Regulation, the governmentwide regulation prescribing procedures for federal
procurements and acquisitions with appropriated funds, does not include NAFI
procurements with nonappropriated funds.
Even though NAFIs generally are not covered under federal procurement
regulations, the government agency that establishes a NAFI generally has
financial oversight or control of its operations. For example, the
Department of Defense established financial oversight procedures for its
NAFI activities. The Secretary of Defense is required by statute to
prescribe regulations governing (1) the purposes for which nonappropriated
funds of a NAFI may be expended and (2) the financial management of such
funds to prevent waste, loss, or unauthorized use (10 U. S. C. sect.2783).
The Graduate School was established by the Secretary of Agriculture on
September 2, 1921, to provide continuing education for research scientists
within the department. Over the years the Graduate School has expanded as a
center for professional training of government employees at the federal,
state, and local levels. A major expansion in its training curriculum
occurred on May 16, 1995, when the Office of Personnel Management
transferred eight of its training centers to the Graduate School.
The Graduate School currently provides more than 1,500 courses annually and
is open to all adults regardless of their place of employment or educational
background. Training is offered in a variety of subject areas including
computer science, leadership development, and government auditing. Courses
are available during the daytime, evening, and on weekends. In addition, the
Graduate School offers a distance learning program in which courses can be
taken by correspondence and online. The Graduate School also provides
training services such as conference and meeting management.
Page 5 GAO- 02- 5 USDA Graduate School
The Graduate School?s stated purpose is, through education, training, and
related services, to improve the performance of government and to provide
opportunities for individual life- long learning. Certificates of
accomplishment to encourage participants to complete planned programs in
their fields of study are awarded by the Graduate School. Some courses
receive college credit recommendations from the American Council on
Education?s College Credit Recommendation Service. The credit
recommendations guide colleges and universities when they consider awarding
credit to participants whom have successfully completed courses at the
Graduate School.
The Graduate School is under the general direction of the Secretary of
Agriculture. Regulations issued by the Secretary require the Graduate School
to be governed by a General Administration Board that sets the school?s
policies, employs its director, and oversees its operations. These
regulations also require that the board and most of the board?s leadership
positions be filled by employees of the department. The Graduate School
employs more than 1,200 part- time faculty who are drawn from government,
academia, and the private sector. Graduate School employees are not part of
the civil service system.
The Graduate School receives no appropriated funds but operates on revenue
derived from providing training services. The school?s revenue comes
primarily from three sources: (1) training services provided through
interagency agreements with federal agencies, (2) training services provided
on a contractual basis, and (3) individual tuition, otherwise known as ?open
enrollment.? The school uses three categories to define and report its
revenue each year: (1) interagency agreement revenue, (2) contractual
revenue, and (3) open enrollment revenue. An annual financial audit
conducted by a private sector accounting firm is reviewed by the school?s
board.
In 1984, the Comptroller General ruled that the Graduate School, because it
was not a federal agency, could not enter into interagency agreements with
federal agencies under the Economy Act (31 U. S. C. sect.1535). 5 After this
ruling, the Graduate School?s revenue decreased about one- third, according
to officials. In 1990, Congress authorized federal agencies to enter into
interagency agreements with the Graduate School for training and other
related services (7 U. S. C. sect.5922). That authority permits federal
5 64 Comp. Gen. 110 (1984). Purpose and
Operating Structure of the Graduate School
Page 6 GAO- 02- 5 USDA Graduate School
agencies to enter into such agreements without regard to competition
requirements mandated in the Federal Property and Administrative Services
Act of 1949 (40 U. S. C. 471, et seq.) or other procurement laws. The
statute also gives the Comptroller General authority to conduct audits of
the Graduate School?s financial records relating to interagency agreements
entered into under this provision.
In 1996, Congress passed legislation that made it clear that as of April 4,
1996, the Graduate School would continue to operate as a NAFI (7 U. S. C.
sect.2279b). Any fees collected by the Graduate School are not considered
federal funds and are not required to be deposited in the United States
Treasury. That statute also provides that the Graduate School is exempt from
various other federal provisions generally applicable to federal agencies,
including the Freedom of Information Act, the Privacy Act, and the Federal
Tort Claims Act. Consequently, the Graduate School does not have to respond
to Freedom of Information Act requests, nor does it have any legal
obligation to release any of its training materials, such as specific
curriculum outlines, to the general public. The law authorizes the Graduate
School?s use of the Department of Agriculture facilities and resources on a
cost- reimbursable basis. According to financial reports for fiscal year
1999, the Graduate School reimbursed the department approximately $1.5
million for use of office space and other facilities.
To get information regarding the extent to which agencies use the Graduate
School, we reviewed seven executive branch agencies. Collectively, the seven
federal agencies we surveyed used private companies more frequently in
fiscal year 1999 than the Graduate School. 6 As table 1 indicates, these
agencies had far more contracts with the private sector than interagency
agreements with the Graduate School (531 vs. 20, respectively) for training.
In examining the funding received by the Graduate School, we found a similar
result: the agencies surveyed spent more on contracts with private
companies- about $29 million- than on interagency agreements with the
Graduate School- about $5.7 million. The selected agencies accounted for
approximately one- third of the total interagency agreement revenue earned
by the Graduate School in fiscal year 1999. We also surveyed these agencies
regarding their total level of
6 In addition to using the Graduate School and private companies for
external training, agencies also use colleges, universities, and other
training sources, including other federal agencies. The USDA Graduate
School Is Not the Principal Choice of Agencies for Training Services
Page 7 GAO- 02- 5 USDA Graduate School
Table 1: Fiscal Year 1999 Interagency Agreements With the Graduate School
and Contracts With Primarily Private Companies
Agency Interagency Agreements With the Graduate School Contracts With
Private
Companies Number Amount Number Amount
Census Bureau 1 $62,400 2 $192,870 Customs 0 0 55 8, 088,087 DOL 0 0 61 - a
IRS 12 3, 870,613 15 b 7,622,804 FDIC 5 1, 476,948 52 10,917,932 NASA
(Headquarters and Goddard)
2 304,486 346 2,539,009 Rural Development (Headquarters and St. Louis
Region)
0 0 0 0
Total 20 $5,714,447 531 $29,360,702
Note: Our sample was drawn from a list of entities that the Graduate School
told us had interagency agreements with it in fiscal year 1999, with the
exception of the Department of Labor, which had no interagency agreements
with the school during this time period. Those entities included the Census
Bureau, Customs Service, Federal Deposit Insurance Corporation, Internal
Revenue Service, National Aeronautics and Space Administration (Headquarters
and Goddard Space Flight Center), and Rural Development (Headquarters and
St. Louis Region). During our evaluation, we determined that two of these
entities, the Customs Service and Rural Development in fact did not have
interagency agreements with the school in fiscal year 1999. Nonetheless, we
retained those entities along with the Department of Labor in our work
because they were able to provide other relevant information. a The dollar
amount for these contracts was not available.
b Sixty- eight task orders were written under 15 umbrella contracts. Source:
Internal Revenue Service, Department of Labor, National Aeronautics and
Space Administration, Rural Development, Census Bureau, Customs Service, and
Federal Deposit Insurance Corporation
training supported by the Graduate School (rather than training only
acquired through interagency agreements). Officials at the agencies reported
that the Graduate School?s share of their overall training budgets was
minimal, ranging from 0 percent to 11 percent of their total annual training
budgets.
Agency officials we surveyed told us they followed specific internally
established policies, practices, and procedures for making decisions on
vendors and procurement methods. While only two of the seven agencies had
documented these policies, officials from all seven told us their policies
were consistently applied and required that at least two other vendors be
considered for any procurement. For example, the U. S. Customs Service has
written policies governing the acquisition of training
Page 8 GAO- 02- 5 USDA Graduate School
that are published in a directive and a Memorandum from the Assistant
Commissioner. All Customs external training purchases require the advance
approval of the appropriate management officials with delegated authority to
approve training. NASA officials said they follow the external training
guidelines in the Federal Acquisition Regulation. However, NASA officials at
its Goddard Space Flight Center told us that when potential vendors were
considered for each training requirement, a ?Request for Training Quote
Information? form is required for each potential vendor. This form is used
to collect information regarding each potential vendor and to assess its
ability to provide the training services required.
All of the agency officials said they consider a number of factors before
deciding which vendor and contracting approach to use. The most commonly
cited factors were cost and the ability of the vendor to provide the
requested training. Additional factors agencies consider include customer
needs, timeliness, past experience with the vendor, and quality of the
product. Some agencies, such as the Internal Revenue Service and the Census
Bureau, indicated that they conduct ?market analysis? studies to identify
all potential vendors. In addition, some agencies identified potential
vendors using the General Services Administration?s Federal Supply Schedule
and the Government Wide Awarded Contracts.
If the USDA Graduate School is selected as the vendor to provide training to
an agency, that training can be acquired through a variety of procurement
methods including interagency agreements and contracts. In general, agencies
indicated that an interagency agreement can be easier to use because it is
faster to put into place. Several of the agencies we surveyed also had
formal written guidance addressing the use of interagency agreements that
also applies to those established with the Graduate School. For example,
Census Bureau guidance specifically mentions that interagency agreements are
entered into under the authority of the Economy Act, 7 including agreements
with the Graduate School. Even though the Customs Service had no interagency
agreements with the Graduate School in fiscal year 1999, its 1998
Interagency Agreement Guide makes direct reference to the Economy Act and
its provisions and is applicable to agreements established with the Graduate
School.
7 31 U. S. C. sect.1535
Page 9 GAO- 02- 5 USDA Graduate School
The interagency agreement line item in the Graduate School?s fiscal year
1999 financial statements did not include all of the revenue received from
interagency agreements. The Graduate School?s fiscal year 1999 financial
statements reported interagency agreement revenue of about $7.1 million.
Graduate School officials acknowledged that its reported revenue by type was
imprecise. We independently estimated interagency agreement revenue as $14.9
million using a stratified random sample of revenue billings made in fiscal
year 1999. 8 The $7.8 million difference between the reported interagency
agreement revenue and our estimate occurred because the Graduate School
included certain revenue under contract training that should have been
reported as interagency agreement revenue. According to Graduate School
officials, only revenue earned under costreimbursable arrangements is
reported as interagency agreement revenue. All fixed- price revenue is
recorded as contract training, even though a significant amount of this
revenue was provided through interagency agreements. Had management labeled
these two line items as costreimbursable and fixed- price, rather than
contract training and interagency agreements, the financial statements would
have correctly disclosed the sources of revenue. However, mislabeling these
line items caused the fiscal year 1999 financial statements to be misleading
with regard to the procurement method used to generate revenue.
Graduate School officials said they chose their method of accumulating
revenue as fixed- price because it provides the information needed to
support certain management decisions. For example, the school has a goal of
avoiding heavy reliance on cost- reimbursable interagency agreement revenue.
Further, the Graduate School Board of Directors monitors the composition of
the fixed- price revenue versus cost- reimbursable revenue.
In the course of our work, we noted two other matters regarding transaction
processing and records retention. First, based on our sample results, we
estimated that the Graduate School misclassified $563,416 9 in fiscal year
1999 revenue that was generated under contracts as interagency agreement
revenue. These misclassification errors resulted from inaccurate manual
coding of revenue transactions. Second, the Graduate School could not locate
five billing invoices and documentation supporting
8 We are 95 percent confident that the actual total is between $13. 9
million and $15.9 million. 9 We are 95 percent confident that the
misclassified amount is between $446, 872 and $679,961. Graduate School?s
Financial Statements Incorrectly Identified Interagency Agreement Revenue
Page 10 GAO- 02- 5 USDA Graduate School
one cash receipt in our sample. We considered the six items as complete
errors and classified them as interagency agreements. 10
The USDA Graduate School is a nonappropriated fund instrumentality whose
purpose is to improve the performance of government through training of its
employees. The operating structure of the Graduate School includes oversight
by the Secretary of Agriculture and a governing board. Employees of the
Graduate School are not part of the civil service. In examining the extent
of training received by selected federal agencies in fiscal year 1999, the
majority of this training was provided by sources other than the Graduate
School.
The Graduate School?s revenue line items need to be consistent with the
revenue sources for the school?s financial statements to be meaningful. The
interagency agreement line item in the school?s fiscal year 1999 financial
statements was not clearly and accurately reported because it did not
reflect approximately half of the interagency agreement revenue that was
classified as contract revenue. As a result, a reader could not determine
the actual amount of total revenue derived from interagency agreements.
We recommend that the Executive Director of the USDA Graduate School revise
the Graduate School?s current financial reporting policy to ensure that the
revenue line items are properly presented in the school?s financial
statements.
We requested comments on a draft of this report from the Executive Director
of the USDA Graduate School. In its written comments, the Graduate School
agreed with the report?s content, conclusions, and recommendation. The
Graduate School comments are reprinted in appendix I.
10 We are 90 percent confident that at least $147,743 represents the portion
of contract revenue that did not have documentation. Conclusions
Recommendation Agency Comments
Page 11 GAO- 02- 5 USDA Graduate School
Our work was done at the USDA Graduate School headquarters and at selected
federal agencies: the Department of Labor, the Internal Revenue Service, the
Department of Agriculture?s Rural Development, the Federal Deposit Insurance
Corporation, the U. S. Customs Service, the Census Bureau, and the National
Aeronautics and Space Administration.
To provide information on the purpose and operating framework of the
Graduate School we interviewed Graduate School officials and reviewed
documentation including legislation, policies, and strategic plans governing
the Graduate School. We determined the extent of training services that
selected federal agencies obtained from the Graduate School and private
contractors and- by interviewing agency officials and reviewing appropriate
documents, including agency procurement regulations and listings of
agreements and contracts- we learned how such decisions were made. Six
agencies covered by our work were nonstatistically selected based on their
having interagency agreements and contracts with the Graduate School during
fiscal year 1999. 11 The seventh agency in our sample, the Department of
Labor had no interagency agreements with the Graduate School during this
period. Our work was performed using fiscal year 1999 data because this was
the last year for which a complete data set was available when we initiated
our evaluation. The seven nonstatistical selected agencies accounted for
approximately one- third of the total interagency agreement revenue earned
by the Graduate School in fiscal year 1999. To assess the reasonableness of
interagency agreement revenue reported in the Graduate School?s fiscal year
1999 financial statements, we met with Graduate School officials and
external auditors for the school; read their audited financial statements
for fiscal years 1999 and 1998; and read the school policies and procedures
governing the classification of revenue and contracting. Further, we
11 Our sample was drawn from a list of entities that the Graduate School
told us had interagency agreements with it in fiscal year 1999. Those
entities included the Census Bureau, Customs Service, Federal Deposit
Insurance Corporation, Internal Revenue Service, National Aeronautics and
Space Administration (Headquarters and Goddard Space Flight Center), and
Rural Development (Headquarters and St. Louis Region). During our
evaluation, we determined that two of these entities, the Customs Service
and Rural Development, in fact did not have interagency agreements with the
school in fiscal year 1999. Nonetheless, we retained those entities in our
work because they were able to provide other relevant information. Scope and
Methodology
Page 12 GAO- 02- 5 USDA Graduate School
independently estimated interagency agreement revenue by selecting a
stratified random probability sample of 145 transactions from 2,439
interagency agreement revenue billings made during fiscal year 1999. We
stratified the population into four strata on the basis of the total of
revenue billings for fiscal year 1999. In addition, we independently
estimated contract revenue by selecting a stratified random probability
sample of 185 transactions from 3,523 contract revenue billings made during
fiscal year 1999. We stratified the population into five strata on the basis
of the total amount of revenue billings for fiscal year 1999. Each sample
element was subsequently weighted in the analysis to account statistically
for all members of the respective populations, including those that were not
selected.
Transactions selected in the sample were tested for accuracy and to
determine whether or not they were classified correctly. The confidence
level used for estimating the value of misclassified amounts was 95 percent
and the expected tolerable amount in error (test materiality) was $545,950.
We also tested the reliability of the $6.1 million in fixed- price
interagency agreement revenue identified by Graduate School officials that
was reported as contract training revenue. We did not audit the Graduate
School?s financial statements or review the other auditor?s workpapers.
Furthermore, we are not expressing an opinion on the Graduate School?s
financial statements or on whether their auditors followed professional
standards.
We conducted our review in the Washington, D. C., metropolitan area from
November 2000 to June 2001 in accordance with generally accepted government
auditing standards. We requested comments on a draft of this report from the
Executive Director of the Graduate School.
We are sending copies of this report to the Chairman of the House Committee
on Agriculture; the Director of the USDA Graduate School; the Secretaries of
the Departments of Agriculture, Labor, Treasury, and Commerce; the Directors
of the Federal Deposit Insurance Corporation and U. S. Census Bureau; the
Administrator of the National Aeronautics and Space Administration; the
Commissioners of the Internal Revenue
Page 13 GAO- 02- 5 USDA Graduate School
Service and U. S. Customs Service; and the Deputy Undersecretary of the
Rural Development and other interested parties. We will also make copies
available to others on request. Major contributors to this report are listed
in appendix II. If you have any questions please call me at (202) 512- 9490.
Sincerely yours, George H. Stalcup Director Strategic Issues
Appendix I: Comments From the Department of Agriculture Page 14 GAO- 02- 5
USDA Graduate School
Appendix I: Comments From the Department of Agriculture
Appendix II: GAO Contacts and Staff Acknowledgments Page 15 GAO- 02- 5 USDA
Graduate School
George H. Stalcup, (202) 512- 9490. Key contributors to this report were
Charlesetta Bailey, Jeffrey Bass, Sharon Byrd, Brandon Haller, Jeffrey
Isaacs, Casandra Joseph, Boris Kachura, Carla Lewis, Delois Richardson,
Sylvia Shanks, Alana Stanfield, Michael Volpe, McCoy Williams, and Gregory
Wilmoth. Appendix II: GAO Contacts and Staff
Acknowledgments GAO Contact Acknowledgments
490054 450004
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