U.S. Coast Guard National Pollution Funds Center: Claims Payment 
Process Was Functioning Effectively, but Additional Controls Are 
Needed to Reduce the Risk of Improper Payments (03-OCT-03,	 
GAO-04-114R).							 
                                                                 
The Oil Spill Liability Trust Fund (Fund) is a $1 billion fund	 
authorized by the Oil Pollution Act of 1990 (OPA) to pay for (1) 
federal removal actions, (2) certain claims for uncompensated	 
removal costs and damages,and (3) natural resource damage and	 
restoration activities resulting from oil spills or the 	 
substantial threat of oil spills to the waters or shorelines of  
the United States. The Fund is administered by the National	 
Pollution Funds Center (NPFC) of the U.S. Coast Guard. In May	 
2002, our Office of General Counsel reported on legal issues and 
limitations of the Fund and concluded that certain administrative
costs were inappropriately being paid out of the Fund. In light  
of this conclusion, we reviewed the internal controls over	 
disbursements from the Fund. Specifically, we reviewed the Fund  
to determine whether (1) the design of internal controls over the
claims process provides reasonable assurance that improper	 
payments will not occur or will be detected in the normal course 
of business and (2) internal controls over the claims process are
operating as designed to help ensure proper payment of claims.	 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-04-114R					        
    ACCNO:   A08659						        
  TITLE:     U.S. Coast Guard National Pollution Funds Center: Claims 
Payment Process Was Functioning Effectively, but Additional	 
Controls Are Needed to Reduce the Risk of Improper Payments	 
     DATE:   10/03/2003 
  SUBJECT:   Administrative costs				 
	     Claims processing					 
	     Erroneous payments 				 
	     Internal controls					 
	     Questionable payments				 
	     Trust funds					 
	     Oil Spill Liability Trust Fund			 

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GAO-04-114R

United States General Accounting Office Washington, DC 20548

October 3, 2003

The Honorable Lane Evans Ranking Minority Member Committee on Veterans
Affairs House of Representatives

The Honorable Bob Filner Ranking Minority Member Subcommittee on Coast
Guard

and Maritime Transportation Committee on Transportation and Infrastructure
House of Representatives

The Honorable Corrine Brown House of Representatives

Subject: U.S. Coast Guard National Pollution Funds Center: Claims Payment
Process Was Functioning Effectively, but Additional Controls Are Needed to
Reduce the Risk of Improper Payments

The Oil Spill Liability Trust Fund (Fund) is a $1 billion fund authorized
by the Oil
Pollution Act of 1990 (OPA) to pay for (1) federal removal actions, (2)
certain claims
for uncompensated removal costs and damages, and (3) natural resource
damage and
restoration activities resulting from oil spills or the substantial threat
of oil spills to
the waters or shorelines of the United States. The Fund is administered by
the
National Pollution Funds Center (NPFC) of the U.S. Coast Guard. In May
2002, at
your request, our Office of General Counsel reported on legal issues and
limitations
of the Fund and concluded that certain administrative costs were
inappropriately
being paid out of the Fund. In light of this conclusion, you asked that we
review the
internal controls over disbursements from the Fund.

This report summarizes the information provided during our briefing on our
review of
claim payments made from the Fund, which was provided to your staff on
September 17, 2003. A second briefing will be provided to your staff on
the results of
our review of controls over operating expenses and other disbursements
from the
Emergency Fund.1 The enclosed briefing slides highlight the results of our
work and
the information provided. Specifically, we reviewed the Fund to determine
whether

1The Emergency Fund is used to pay for emergency removal activities and
the initiation of natural resource damage assessments.

(1) the design of internal controls over the claims process provides
reasonable assurance that improper payments will not occur or will be
detected in the normal course of business and (2) internal controls over
the claims process are operating as designed to help ensure proper payment
of claims.

Results in Brief

The U.S. Coast Guard NPFC follows a systematic and effective process for
payment of claims. However, there are some weaknesses in the design of
internal controls over the claims process that expose the Fund to improper
payments. The weaknesses in the design of controls include (1) ineffective
access restrictions to the Authorization-to-Pay2 (ATP) form, (2) lack of
segregation of duties between individuals preparing and approving ATPs for
payment, (3) lack of procedures to verify the validity of ATPs prior to
payment by the U.S. Coast Guard Finance Center, (4) lack of compliance
with certain established policies and procedures in the claims process and
the claims processing system, and (5) inadequate documentation of the
originator of actions in the claims processing system.

We found that existing internal controls related to the documentation and
approval of claims were generally operating in accordance with established
policies and procedures. Of the 88 statistically sampled paid claims for
fiscal year 2002, all but 3 had adequate documentation.3 We found no
exceptions with approvals for the 88 statistically sampled claims. We also
found that all 88 claims met NPFC's 10 requirements for validity, as
listed in appendix I of the attached slides. Through data mining, 4 we
selected a nonstatistical sample of 50 claim payments and 8 denied claims
for fiscal years 1998 through 2002 and performed limited tests to
determine if the claims payments were valid and if the denied claims were
properly processed. While we found some documentation and approval issues,
we found that the 50 claim payments were valid and that the 8 denied
claims were properly processed.

Recommendations for Executive Action

To improve the design of internal controls over the claims process, we
recommend that the Commandant of the U.S. Coast Guard direct the Director
of the National Pollution Funds Center to

o  require automatic control numbers for each ATP form;

o  	limit access to the ATP form control numbers to one individual and an
alternate in each claims division;

o  	require two signatures on each ATP form, one for the preparer and one
for the approver;

2An ATP is a form used to approve claim payments and generate the payments
to claimants.
3Based on these results, we estimate that 3.4 percent of the fiscal year
2002 paid claims lacked
adequate documentation. We are 95 percent confident that the error rate
was between 1 to 9 percent
for claims paid in fiscal year 2002.
4Data mining applies a search process to a data set, analyzing for trends,
relationships, and interesting
associations. For instance, it can be used to efficiently query
transaction data for characteristics that
may indicate potentially improper activity.

o  	establish procedures requiring the National Pollution Funds Center to
authenticate ATP forms prior to submitting them to the U.S. Coast Guard
Finance Center for payment;

o  	establish and implement controls so that any required legal reviews of
claims are completed before they are approved for payment;

o  	establish and implement controls to ensure that a release form is
received from a claimant before a claim can be approved for payment; and

o  	modify the claims processing system to consistently identify the
originator of all actions on user screens.

We also recommend that the Commandant of the U.S. Coast Guard direct the
Chief Financial Officer of the U.S. Coast Guard to require that the
Finance Center verify the validity of ATP forms prior to processing claim
payments.

Agency Comments

We obtained oral comments on a draft of our briefing slides from the U.S.
Coast Guard. U.S. Coast Guard officials agreed with our findings and
recommendations and stated that they have already begun to take corrective
actions to implement many of them and will continue to take additional
actions as soon as possible to address the remaining recommendations. They
provided us with a detailed list of actions taken or to be taken, which if
properly implemented, should address our recommendations. U.S. Coast Guard
officials also provided technical and clarifying comments that we
incorporated as appropriate.

Scope and Methodology

To determine whether the design of internal controls over the claims
process provided reasonable assurance that improper payments would not
occur or would be detected in the normal course of business, we (1)
reviewed OPA and related sections of the Code of Federal Regulations, (2)
reviewed the Comptroller General's Standards for Internal Control in the
Federal Government,5 (3) reviewed NPFC's Standard Operating Procedures
related to the claims process, and (4) performed walkthroughs of the
claims process, including the claims processing system, and compared the
results to NPFC's Standard Operating Procedures and the Comptroller
General's Standards for Internal Control in the Federal Government.

To determine if internal controls over the claims process were operating
as designed to ensure proper payments of claims, we selected a statistical
sample of 88 paid claims for fiscal year 2002, and reviewed the related
claim files and the claims processing system records to test for adequate
documentation, proper approvals, and validity. To test for validity, we
also performed limited data mining of claims paid in fiscal years 1998
through 2002 to identify unusual transactions and patterns. Based on the
data mining, we selected a nonstatistical sample of 50 claim payments and
8 denied claims, reviewed the related documentation, and performed limited
tests.

5U.S. General Accounting Office, Standards for Internal Control in the
Federal Government, GAO/AIMD-00-21.3 (Washington, D.C.: November 1999).

We requested comments on a draft of the enclosed briefing slides from the
Commandant of the U.S. Coast Guard or his designee and have included any
comments as appropriate in the letter and enclosed slides. We conducted
our work from December 2002 through July 2003, in accordance with
generally accepted government standards.

This report is available at no charge on our home page at
http://www.gao.gov. If you have any questions about this report, please
contact me at (202) 512-9508 or Rosa R. Harris, Assistant Director,
Financial Management and Assurance, at (202) 512-9492. You may also reach
us by e-mail at [email protected] or [email protected]. Additional
contributors to this assignment were H. Donald Campbell, Lisa J. Crye, and
Edward F. Tanaka.

Linda M. Calbom
Director, Financial Management and Assurance

Enclosure

                                U.S. Coast Guard
                        National Pollution Funds Center

Claims Payment Process Was Functioning Effectively, but Additional
Controls Are Needed to Reduce the Risk of Improper Payments

Briefing to the Staff of the Committees on Veterans Affairs and
Transportation and Infrastructure, House of Representatives

September 17, 2003

Table of Contents

o  Introduction and Objectives

o  Results in Brief  o Background

o  Overview of Effective Internal Control

o  Internal Control Design

o  Internal Control Operation

o  Conclusions

o  Recommendations

o  Agency Comments

o  Scope and Methodology

Introduction and Objectives

o 	The Oil Spill Liability Trust Fund (Fund) is a $1 billion fund
authorized to pay for (1) federal removal actions, (2) certain claims for
uncompensated removal costs and damages, and (3) natural resource damage
assessments and restoration activities by designated federal, state, or
Indian tribe officials, resulting from oil spills or the substantial
threat of oil spills to the waters or shorelines of the United States.

o 	In May 2002, at your request, the GAO Office of General Counsel (OGC)
reported on legal issues related to the uses and limitations of the Fund.

o 	The U.S. Coast Guard reported that the Fund was being used to pay not
only uncompensated claims, but also costs associated with processing those
claims, including salaries and other administrative expenses. OGC
concluded that the Fund is not available to pay employee salaries and
other administrative expenses.

Introduction and Objectives (cont.)

o 	In light of this conclusion, you asked that we review the controls over
disbursements from the Fund. This is the first of two briefings on our
review of disbursements from the Fund. This briefing covers the results of
our work related to the review of claim payments made from the Fund. A
second briefing on the results of our review of controls over operating
expenses and other disbursements from the Emergency Fund1 will be
presented at a later date.

o  Specifically, we reviewed the Fund to determine whether

o 	the design of internal controls over the claims process provides
reasonable assurance that improper payments will not occur or will be
detected in the normal course of business and

o 	internal controls over the claims process are operating as designed to
help ensure proper payment of claims.

1The Emergency Fund is used to pay for emergency removal activities and
the initiation of natural resource damage assessments.

Results in Brief

o 	The U.S. Coast Guard National Pollution Funds Center (NPFC) generally
follows a systematic process for payment of claims. However, we found some
weaknesses in the design of internal controls over the claims process that
increase the risk of improper payments.

o  Weaknesses in the design of the controls included

o 	ineffective access restrictions to the Authorization-to-Pay (ATP) form,

o 	lack of segregation of duties between individuals preparing ATPs and
approving ATPs for payment,

o 	lack of procedures to verify the validity of ATPs prior to payment by
the U.S. Coast Guard Finance Center,

Results in Brief (cont.)

o 	lack of compliance with certain established policies and procedures in
the claims process and the claims processing system, and

o 	inadequate documentation of the originator of actions in the claims
processing system.

Results in Brief (cont.)

o 	We also found that, generally, existing internal controls related to
documentation and approval of claims were operating in accordance with
established policies and procedures.

o 	We statistically sampled 88 paid claims for fiscal year 2002. Of these,
3 did not have adequate documentation. We found no instances of invalid
claim payments.

o 	We selected a nonstatistical sample of 50 claim payments and 8 denied
claims through data mining2 for fiscal years 1998 through 2002. While we
found some documentation and approval issues, we found no instances of
invalid claim payments. The 8 denied claims were properly processed.

2Data mining applies a search process to a data set, analyzing for trends,
relationships, and interesting associations. For instance, it can be used
to efficiently query transaction data for characteristics that may
indicate potentially improper activity.

Results in Brief (cont.)

o 	We are making several recommendations intended to improve the design of
internal controls over the claims process.

o 	U.S. Coast Guard officials agreed with our recommendations and
indicated that they have already prepared an action plan to address them.

Background

o 	The Oil Pollution Act of 1990 (OPA)3 authorized the Fund to pay claims
for certain costs resulting from oil spills or the substantial threat of
oil spills. The act also

o 	authorized the President to make available from the Fund without
further congressional appropriation up to $50 million each year to pay for
emergency removal costs and initiation of natural resource damage
assessments resulting from oil spills,

o  authorized an appropriation from the Fund of not more than

$25 million each year for operating expenses incurred by the U.S. Coast
Guard to implement the act, and

o 	provided authorization for the appropriation of funds for other uses,
such as research, development, testing, and evaluation, and acquisition,
construction, and improvements.

3Pub. L. No. 101-380, 104 Stat. 484 (1990).

Background(cont.)

o 	Administration of the Fund was delegated to the U.S. Coast Guard by
Executive Order, and in February 1991, NPFC was commissioned to perform
this function as an independent headquarters unit reporting directly to
the Coast Guard Chief of Staff.

o  NPFC administers and manages uses of the Fund by

o 	making funds available for immediate federal oil removal activities and
the initiation of natural resource damage assessments,

o  paying claims for losses or damages associated with an oil spill, and

o  recovering costs from responsible parties.

Background (cont.)

o  NPFC has two claims processing divisions:

o 	Claims - adjudicates claims for uncompensated removal costs and damages
from oil spills

o 	Natural Resource Damage Claims - adjudicates natural resource damage
(NRD) claims from federal, state, Indian tribe, or foreign trustees as
designated pursuant to OPA

Background (cont.)

Claims paid in fiscal years 1998 through 2002

                 Fiscal year Number of paid    Total dollars    
                             claims             (millions)      
                    1998          598              $ 3.7        
                    1999          507              10.4         
                    2000          601               2.4         
                    2001          311              16.8         
                    2002          300               7.0         
                   Totals        2,317            $ 40.3        

Source: NPFC's data file for fiscal years 1998 through 2002.

Background (cont.)

o NPFC's Standard Operating Procedures (SOP)

o 	provides guidance and requirements for the Claims and Natural Resource
Damage Claims Divisions for the adjudication and payment of uncompensated
removal costs and damages and NRD claims and

o  describes the responsibilities and conduct for each division.

o 	The claims processing system (CPS) is NPFC's current automated system
for tracking and controlling claims.

Overview of Effective Internal Control

As discussed in GAO's Standards for Internal Control in the Federal

4

Government,

o 	internal control-a major part of managing an organization-is a
continuous, built-in component of operations that provides reasonable, not
absolute, assurance of meeting agency objectives;

o 	internal control consists of the plans, methods, and procedures used to
meet the agency's missions, goals, and objectives; and

o 	internal control should be designed to provide reasonable assurance
regarding prevention or prompt detection of unauthorized acquisition, use,
or disposition of an agency's assets.

4Standards for Internal Control in the Federal Government,
GAO/AIMD-00-21.3.1, which was prepared to fulfill our statutory
requirement under the Federal Managers' Financial Integrity Act, provides
an overall framework for establishing and maintaining internal control and
for identifying and addressing major performance and management challenges
and areas at greatest risk of fraud, waste, abuse, and mismanagement.

Internal Control Design

The design of internal controls over the claims process did not provide
reasonable assurance that improper payments would not occur or would be
detected in the normal course of business.

Control weakness: ATPs are word-processing documents that do not have
control numbers and can be readily created by any individual who has
access to the ATP in the claims processing system.

o 	Standards for Internal Control in the Federal Government states that
access to resources and records should be limited to authorized
individuals, and accountability for their custody and use should be
assigned and maintained.

o 	The lack of control over the payment phase of the claims process
increases the risk of invalid ATPs and improper or erroneous payments.

Internal Control Design (cont.)

Control weakness: NPFC does not have controls to prevent the same
individual from preparing and approving an ATP. Because NPFC policies
require that an ATP be signed only by the approver, there is no assurance
that the preparer and approver functions are separate.

o 	Standards for Internal Control in the Federal Government states that
key duties and responsibilities need to be divided or segregated among
different people to reduce the risk of error or fraud.

o 	As a result of this weakness, the risk that fictitious ATPs may be
prepared and processed is increased.

Internal Control Design (cont.)

Control weakness: NPFC does not ensure that ATPs sent to the U.S. Coast
Guard Finance Center (FINCEN) for payment are authenticated, nor does
FINCEN verify the validity of ATPs prior to processing payments.

o 	When NPFC faxes ATPs to FINCEN for payment, FINCEN processes payments
for claimants without independently verifying whether ATPs have been
properly authorized.

o 	Standards for Internal Control in the Federal Government states that
controls should be established to ensure that all transactions are
authorized.

o 	As a result of this weakness, anyone with a basic knowledge of the
claims payment process could divert funds. The risk of duplicate or
erroneous payments is also increased.

Internal Control Design (cont.)

Control weakness: The design of NPFC's claims process and its CPS

are not in accordance with all of NPFC's policies and procedures. For
example, NPFC does not have controls in place to prevent a payment from
occurring (1) prior to required legal review and (2) without NPFC's
receipt of the claimant's acceptance.

o 	Standards for Internal Control in the Federal Government states that
only valid transactions and other events should be initiated or entered
into, in accordance with management's decisions and directives. The terms
of authorization should be in accordance with directives and within
limitations established by law, regulation, and management.

o 	The lack of controls to help ensure that the SOP is followed further
increases the risk of invalid claim payments.

Internal Control Design (cont.)

Control weakness: Information regarding who originated claim actions is
not always readily available for management review in the claims
processing system. While CPS is designed to track this information, due to
a coding issue, user screens do not always display who originated claim
actions.

o 	Standards for Internal Control in the Federal Government states that
significant events need to be clearly documented, and the documentation
should be readily available for examination.

o 	Lack of information regarding who originated claim actions could impede
management and others' ability to readily assess the validity of the
claims or the integrity of the claims process.

Internal Control Operation

Internal controls over the claims process were generally operating in
accordance with established NPFC policies that are currently in place to
help ensure proper payment of claims.

o 	We tested a statistical sample of 88 paid claims for fiscal year 2002
and reviewed the related claim files and CPS records to test for

o  adequate documentation,

o  proper approvals, and

o  validity.

Internal Control Operation (cont.)

Documentation

o 	The SOP requires that claim files include supportingdocumentation for
claim payments, including documentation of determinations, offers to
claimants, release forms, and authorizations to pay.

o 	We found that 3 of the 88 claims did not have adequate documentation in
the claim files. For example, the claim payment amounts were not fully
supported.

o 	Based on these results, we estimate that 3.4 percent of the fiscal year
2002 paid claims lacked adequate documentation.5

o 	While we found some exceptions, NPFC is generallydocumenting the claims
process in accordance with its policies and procedures.

5We are 95 percent confident that the error rate was between 1 and 9
percent for claims paid in fiscal year 2002.

Internal Control Operation (cont.)

Approvals

o 	The SOP requires proper approvals of offers to claimants; legal
reviews, in certain cases; and approvals of payments to claimants.

o 	We found no exceptions with approvals of claims for the 88
statistically sampled claims.

Validity

o 	The SOP requires that a claim meet the 10 initial review requirements
to be valid (see app. I).

o 	We found no exceptions with the validity of the 88 statistically
sampled claims.

Internal Control Operation (cont.)

Through data mining, we selected a nonstatistical sample of 50 claim
payments and 8 denied claims and performed limited tests to determine if
the claims were valid and if the denied claims were properly processed.

o 	We found that the claim payments were valid and that the denied claims
were properly processed.

o 	While we were able to satisfy ourselves with the validity of the
claims, we found some documentation and approval issues.

Conclusions

o 	The U.S. Coast Guard NPFC has a systematic and effective process for
payment of claims. However, certain weaknesses in the design of internal
controls over the claims process expose the Fund to improper payments.
While we found no instances of invalid claim payments in our testing, the
weaknesses we identified, if left uncorrected, make the Fund vulnerable to
future improper payments.

Recommendations

To improve the design of internal controls over the claims process, we
recommend that the Commandant of the U.S. Coast Guard direct the Director
of NPFC to

o  require automatic control numbers for each ATP;

o 	limit access to ATP control numbers to one individual and an alternate
in each claims division;

o 	require two signatures on each ATP, one for the preparer and one for
the approver;

o 	establish procedures requiring NPFC to authenticate ATPs prior to
submitting them to the U.S. Coast Guard Finance Center for payment;

Recommendations (cont.)

o 	establish and implement controls so that any required legal reviews of
claims are completed before they are approved for payment;

o 	establish and implement controls so that a release form is received
from a claimant before a claim can be approved for payment; and

o 	modify the claims processing system to consistently identify the
originator of all actions on user screens.

Recommendations (cont.)

We also recommend that the Commandant of the U.S. Coast Guard direct the
Chief Financial Officer of the Coast Guard to require that the Finance
Center verify the validity of ATPs prior to processing payments.

Agency Comments

o 	U.S. Coast Guard officials agreed with our recommendations and stated
that they have already begun to take corrective actions to implement many
of them and will continue to take additional actions as soon as possible
to address the remaining recommendations. They provided us with a detailed
list of actions taken or to be taken, which if properly implemented,
should address our recommendations. U.S. Coast Guard officials also
provided technical and clarifying comments, which we incorporated as
appropriate.

Scope and Methodology

To determine whether the design of internal controls over the claims
process provides reasonable assurance that improper payments would not
occur or would be detected in the normal course of business, we

o 	reviewed OPA and related sections of the Code of Federal Regulations;

o  reviewed Standards for Internal Control in the Federal Government;

o 	reviewed NPFC's Standard Operating Procedures related to the claims
process; and

o 	performed walkthroughs of the claims process, including the claims
processing system, and compared the results to NPFC's Standard Operating
Procedures and GAO's Standards for Internal Control in the Federal
Government.

Scope and Methodology (cont.)

To determine if internal controls over the claims process were operating
as designed to help ensure proper payments of claims, we

o 	selected a statistical sample6 of 88 claims paid in fiscal year 20027
and

o 	reviewed the related claims files and CPS records to test for adequate
documentation, proper approvals, and validity.

6Our sample was based on a 95 percent confidence level and an expected
error rate of 3 percent.
7We selected claims from fiscal year 2002 because we were assessing the
condition of current controls and because this
was the most recent information available at the time of review.

Scope and Methodology (cont.)

o 	To test for adequate documentation, we reviewed the claims files and
CPS records to determine if

o  the claim payments were adequately supported and

o 	the files and records were complete and included the offer letters to
the claimants, summary/recommendation forms, claimant release forms, and
the ATP forms.

Scope and Methodology (cont.)

o 	To test for proper review and approval, we reviewed the claim files and
CPS records to determine if the

o 	Claims Division Branch Chief approved the determination letter prior to
the payment of a claim,

o 	legal reviews were obtained for policy and determinations when
required,

o 	determination letters for reconsiderations were properly approved,

o 	claims manager signed the determination letter prior to payment of a
claim,

o  claimant signed the release form, and

o 	Division or Branch Chief approved the ATP prior to payment of a claim.

Scope and Methodology (cont.)

To test for validity, we

o 	reviewed documentation for the 88 statistically sampled claims and
performed tests to determine if they met the 10 SOP initial review
requirements;

o 	performed limited data mining of claims paid in fiscal years 1998
through 2002 to identify unusual transactions and patterns, specifically
looking for claims with even dollar amounts, large dollar amounts,
multiple payments of the same dollar amounts, multiple payments to the
same claimant for the same incident, incorrect coding, questionable
status, and claims that had been denied; and

o 	selected, based on our data mining, a nonstatistical sample of 50 claim
payments and 8 denied claims, reviewed the related documentation, and
performed limited tests.

Scope and Methodology (cont.)

o 	We requested comments on a draft of these briefing slides from the U.S.
Coast Guard. We received oral comments from U.S. Coast Guard officials
that were incorporated into these briefing slides as appropriate.

o 	We conducted our work from December 2002 through July 2003 in
accordance with generally accepted government auditing standards.

Appendix I

                        Ten Initial Review Requirements

The incident is after the implementation of OPA (Aug.18, 1990). The claim
is not currently the subject of litigation in any court.

The incident involved the discharge, or substantial threat of discharge,
of oil from a The claimant has not waived right of recourse

covered source. against any party relative to the incident giving rise to
the claim. The discharge was into or upon the navigable

waters of the United States, their adjoining shorelines, or the Exclusive
Economic Zone of The claimant has signed the claim in ink.

the United States.

The claimant has not already been The claimant has demonstrated an injury
that compensated for the costs or damages in the was caused by the
incident described above, or current claim.by the response to that
incident.

The claim has been presented to NPFC within The claim has been properly
presented to the the applicable statute of limitations. responsible party
prior to submission to the Fund.

(190113)

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                  Waste, and Abuse in E-mail: [email protected]

Federal Programs Automated answering system: (800) 424-5454 or (202)
512-7470

Public Affairs 	Jeff Nelligan, Managing Director, [email protected] (202)
512-4800 U.S. General Accounting Office, 441 G Street NW, Room 7149
Washington, D.C. 20548
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