Kennedy Center: Stronger Oversight of Fire Safety Issues,
Construction Projects, and Financial Management Needed
(06-APR-05, GAO-05-516T).
Since fiscal year 1995, the John F. Kennedy Center for the
Performing Arts (Kennedy Center) has received nearly $203 million
in federal funds to complete capital projects and intends to
request an additional $43 million in appropriations through
fiscal year 2008. The Kennedy Center's Comprehensive Building
Plan identifies these capital projects as necessary to renovate
the Center and to meet or exceed relevant life safety and
disabled access regulations. GAO was asked to examine (1) the
progress the Center has made in completing key capital projects
within estimated costs and the information it has communicated
about this progress to key stakeholders; and (2) the status of
the Center's plans to address fire life safety and disabled
access requirements.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-05-516T
ACCNO: A20957
TITLE: Kennedy Center: Stronger Oversight of Fire Safety Issues,
Construction Projects, and Financial Management Needed
DATE: 04/06/2005
SUBJECT: Kennedy Center
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GAO-05-516T
United States Government Accountability Office
GAO Testimony
Before the Chairman, Subcommittee on Interior, Environment, and Related
Agencies, Committee on Appropriations, House of Representatives
For Release on Delivery
Expected at 10:00 a.m. EDT KENNEDY CENTER
Wednesday, April 6, 2005
Stronger Oversight of Fire Safety Issues, Construction Projects, and Financial
Management Needed
Statement of Mark L. Goldstein, Director Physical Infrastructure Issues
GAO-05-516T
Highlights of GAO-05-516T, a testimony before the Subcommittee on
Interior, Environment, and Related Agencies, Committee on Appropriations,
House of Representatives.
Since fiscal year 1995, the John F. Kennedy Center for the Performing Arts
(Kennedy Center) has received nearly $203 million in federal funds to
complete capital projects and intends to request an additional $43 million
in appropriations through fiscal year 2008. The Kennedy Center's
Comprehensive Building Plan identifies these capital projects as necessary
to renovate the Center and to meet or exceed relevant life safety and
disabled access regulations. GAO was asked to examine (1) the progress the
Center has made in completing key capital projects within estimated costs
and the information it has communicated about this progress to key
stakeholders; and (2) the status of the Center's plans to address fire
life safety and disabled access requirements.
GAO makes recommendations to the Chairman of the Kennedy Center Board of
Trustees including increasing oversight and better complying with fire
safety code. The Kennedy Center agrees that more oversight would be
useful, but it is unsure what the best mechanism would be for providing
such oversight. Furthermore, the Kennedy Center believes that it is in
compliance with fire code, but agrees to seek third party review of its
approach in addressing certain fire code deficiencies.
www.gao.gov/cgi-bin/getrpt?GAO-05-516T.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Mark L. Goldstein at (202)
512-2834 or [email protected].
April 2005
KENNEDY CENTER
Stronger Oversight of Fire Safety Issues, Construction Projects, and Financial
Management Needed
The Kennedy Center has achieved its goal of renovating the Opera House,
Concert Hall, and plaza-level public spaces, and installed a building wide
fire alarm system, but each of these projects exceeded its budget
estimates, sometimes by substantial amounts. Project cost growth resulted
from modifications made during the renovation process, due, in part, to
the Kennedy Center's lack of knowledge of the building's site conditions.
Unexpected site conditions and related challenges make renovation
projects, like those undertaken by the Kennedy Center, difficult to
complete. Modifications led to overtime charges paid to meet tight
construction schedules. Also, the Center may have paid higher costs than
necessary by negotiating the value of contract modifications after work
was completed. The Kennedy Center lacks comprehensive policies and
procedures related to capital improvements that could impact its ability
to safeguard federal funds. Furthermore, our review of communication
documents showed that Kennedy Center management did not always provide
timely or accurate information on project cost growth and delays to its
Board of Trustees or Congress.
Cost Over Initial Budgets for Selected Kennedy Center Projects
Projects
Concert Hall renovation
Opera House renovation
50%Fire alarm system increase
Public space
modifications
0 1020304050
Percentage cost increase
Source: GAO analysis of Kennedy Center data.
The Kennedy Center has worked to address fire life safety deficiencies,
and improvements are ongoing, but after requesting and obtaining funds
from Congress the Kennedy Center decided against its plan to meet fire
safety code requirements by installing sprinklers and smoke evacuation
systems in the Grand Foyer, the Hall of States, and the Hall of Nations.
Furthermore, the Kennedy Center did not have its decisions independently
reviewed nor did it clearly inform its Board or Congress that it was not
spending the funds as planned. Two additional areas of concern are (1)
doors in critical areas do not provide adequate protection from fire, and
(2) the Millennium Stages have exit deficiencies and lack sprinkler and
smoke evacuation systems required by code. The Kennedy Center has complied
with disabled access
requirements in renovated areas of the Center.
Mr. Chairman, Ranking Minority Member, and Members of the Subcommittee:
Thank you for the opportunity to testify before you today on our work
related to the management and oversight of capital projects at the John F.
Kennedy Center for the Performing Arts (Kennedy Center). Since fiscal year
1995, the Kennedy Center has received almost $203 million1 in federal
funds for capital repairs and alterations included in its comprehensive
building plans (CBP). Kennedy Center officials said that additional
appropriations totaling $43 million through fiscal year 2008 are needed to
complete the planned projects. For more than a decade, we have identified
shortcomings in, and made recommendations to improve, the Kennedy Center's
construction, planning, and management processes. In the 1990s, we
reported that the Kennedy Center did not have sufficient staff capability
to effectively manage its planned capital improvements.2 In 2003, we
reported that the Kennedy Center needed to strengthen the management and
oversight of large construction projects, such as the garage expansion and
renovation project.3 In 2004, we reported that the Kennedy Center had
implemented most of the projects in its CBP but would likely not complete
its plan by 2008, given the number and size of the renovation projects
that remained to be done, anticipated future appropriations, and the
likelihood that project budgets may increase as designs are completed.4
Today my testimony will discuss (1) the progress the Kennedy Center has
made in completing key capital projects-such as the renovation of the
Opera House, Concert Hall, and its plaza-level public spaces, and
installation of a building wide fire alarm system-within estimated costs
and how it has communicated the information about this progress to its
1This includes a $35.3 million beginning balance, the value of transfers
from the National Park Service and Smithsonian Institution, and
approximately $167.6 million in federal appropriations.
2GAO, Kennedy Center: Information on the Capital Improvement Program,
GAO/GGD-93-46 (Washington, D.C.: February 1993) and GAO, Kennedy Center:
Information on Facility Management Capability, GAO/GGD-98-56 (Washington,
D.C.: March 25, 1998).
3GAO, Kennedy Center: Improvements Needed to Strengthen the Management and
Oversight of the Construction Process, GAO-03-823 (Washington, D.C.: Sept.
5, 2003).
4GAO, Kennedy Center: More Information on Project Status and Budgets
Needed to Understand the Impact of Future Funding Decisions, GAO-04-933
(Washington, D.C.: Sept. 15, 2004).
Board of Trustees and Congress, and (2) the Kennedy Center's status with
regard to fire life safety and disabled access requirements. My statement
is based on our report that we will issue later this month. Our report
will include additional information on best practices for project
management that could help the Kennedy Center improve its capital projects
planning and management process. In summary, we found the following:
o Although the Kennedy Center has achieved its goal of renovating the
Opera House, Concert Hall, and its plaza-level public spaces, and
installed a building wide fire alarm system, each of these projects
exceeded its budget estimates by amounts ranging from 13 to 50 percent,
and it does not appear that Kennedy Center officials always timely or
accurately communicated the cost growth and delays to its Board of
Trustees or Congress. Cost growth in these projects resulted from
unanticipated modifications made during the renovation process and
condensed schedules. Such modifications were necessary, in part, because
the Kennedy Center lacked knowledge of the building's site conditions. The
project modifications, in turn, led to overtime charges paid to meet tight
construction schedules. For example, the Kennedy Center paid $560,000 in
overtime charges during the Opera House renovation to complete the work on
schedule. The Kennedy Center also may have paid higher costs to
contractors than necessary by routinely negotiating the value of project
modifications after contractors had already completed the work. In
addition, the absence of comprehensive policies and procedures across the
project management, contracting, and finance departments has impeded
effective project management and diminished the oversight of federal
funds. Finally, our review of the communications documentation showed that
the Kennedy Center management did not always timely or accurately
communicate cost overruns and schedule changes to its Board of Trustees or
Congress. For example, the Concert Hall renovation resulted in cost growth
of $6.2 million, or 41 percent, over the original budget; however, Kennedy
Center officials repeatedly testified before Congress, several years after
renovations were complete, that the project was completed within budget
estimates.
o The Kennedy Center does not appear to meet some fire safety code
requirements but has complied with, and exceeded in some instances,
disabled access requirements in renovated areas of the Center. After
requesting and obtaining funds from Congress to address fire code
deficiencies, such as the need for fire suppression systems, the Kennedy
Center decided against its plan to meet fire safety code requirements by
installing sprinklers and smoke evacuation systems in the Grand Foyer, the
Hall of States, and the Hall of Nations. The Kennedy Center reversed its
decision to install these systems without having its decision
independently reviewed or clearly informing its Board or Congress that it
was not spending the funds as planned.5 To identify and mitigate fire
protection issues concerning exit paths through the Grand Foyer, the Hall
of States, and the Hall of Nations, the Kennedy Center commissioned and
used the results of a fire-modeling study. The Kennedy Center has not
implemented some of the study's recommendations, nor did it seek peer
review of the study even though the fire code provides for third party
validation and support for a study's assumptions and conditions.
Thirdparty validation is particularly important in this instance because
the Kennedy Center's fire safety decisions are not subject to external
review. In addition, we identified two deficiencies, based on fire code,
that are of immediate concern. First, the doors in critical areas such as
the fire pump room and the Fire Command Center do not provide adequate
separation from fire as outlined in the fire safety code. Second,
fire-safety related problems exist with the Millennium Stages. The stages
located at the ends of the Grand Foyer could pose exit problems in the
event of fire (see fig. 8).6 Furthermore, the Millennium Stages do not
have sprinkler and smoke control systems as required by fire code.
Officials from the Kennedy Center said that they believe that all fire
safety code requirements are being met but agreed to add fire protective
doors and document their key decisions. Regarding disabled access
projects, we concluded that the Kennedy Center meets or exceeds the
requirements outlined in the Americans with Disabilities Act7 (ADA) based
on our independent expert's
review. For example, disabled patrons can now access all tiers of the
Concert Hall and Opera House and ushers receive special training for
assisting disabled patrons.
The Kennedy Center has begun to take steps to improve its management of
capital projects, such as the hiring of new staff, updating its CBP, and
drafting a policies and procedures manual. However, we were unable to
5In accordance with fire code, the Kennedy Center conducted an egress and
fire modeling study to determine if occupants could safely exit the
building in the event of a fire. The modeling study predicted that patrons
would be able to escape the Center safely in the event of a fire before
conditions became untenable provided that the Kennedy Center took steps to
minimize evacuation delays and limit storage of combustible materials. The
study also recommended that the Kennedy Center install sprinklers in the
Millennium Stages for added protection.
6Fire code defines means of egress as a continuous and unobstructed way of
travel from any point in a building to a public way consisting of three
separate and distinct parts: (1) the exit access, (2) the exit, and (3)
the exit discharge.
742 U.S.C. S: 12101 et. seq.
gauge the impact of some of these changes as they are relatively recent in
nature or still in development.
GAO makes recommendations to the Chairman of the Kennedy Center Board of
Trustees including increasing oversight and better complying with fire
safety code. The Kennedy Center agrees that more oversight would be
useful, but it is unsure what the best mechanism would be for providing
such oversight. Furthermore, the Kennedy Center believes that it is in
compliance with fire code, but agrees to seek third party review of its
approach in addressing certain fire code deficiencies.
We conducted our review from August 2004 through March 2005 in accordance
with generally accepted government auditing standards.
Background The Kennedy Center opened in 1971 and is located on 17 acres
along the Potomac River in Washington, D.C. The Center houses four major
theaters and several smaller theaters, five public halls or galleries,
educational facilities, rehearsal spaces, offices, and meeting rooms in
about 1.1 million square feet of space. The plaza level, which is the
primary focus for patrons and tourists, includes three main theaters, the
Grand Foyer, the Hall of States, and the Hall of Nations. Access to other
areas, such as the roof terrace level, is provided through the Grand
Foyer, the Hall of States, and the Hall of Nations. Figure 1 provides a
diagram of the Kennedy Center's plaza level.
Figure 1: Kennedy Center's Plaza-Level Public Spaces and Theaters
In 1994, legislation was enacted that gave the Kennedy Center's Board of
Trustees sole responsibility for carrying out capital improvements at the
Kennedy Center.8 One purpose of the legislation was to provide autonomy
8The Kennedy Center's Board of Trustees currently consists of 23
government positions, including congressional members, as well as 36
general trustees appointed by the President of the United States. Each
general trustee serves a term of 6 years.
for the overall management of the Kennedy Center, including better control
over its capital projects, and to renovate the Center. The legislation
further required the Board of Trustees to develop and annually update a
CBP.9
In response to the 1994 legislation, the Center published its first CBP in
1995 describing the goals of the renovation, including addressing
deficiencies in fire life safety and disabled access codes, through
actions such as installing sprinklers throughout the Center, replacing
inefficient building systems, and improving visitor services. The law the
Kennedy Center follows with regard to facility construction or alteration
requires that the Center be in compliance with nationally recognized model
building codes and other applicable nationally recognized fire safety
codes to the maximum extent feasible.10 As in the case of other federal
agencies, the Kennedy Center is the authority having jurisdiction for
making a final determination on whether the Center is complying with fire
safety code.11 The Kennedy Center's policy on building codes states that,
where feasible, the Center will comply with the International Building
Code (2003),12 International Fire Code (2003),13 and selected provisions
of NFPA 101 (2003).14 In 1995, the Kennedy Center anticipated undertaking
critical fire life safety projects by the end of fiscal year 1999.
However, to minimize disruption to performances, the Kennedy Center
changed its approach to making capital improvements. Rather than
undertaking broad-scale projects that could disrupt the entire Center, the
Kennedy Center chose to implement renovations incrementally while keeping
the rest of the Center open and operating. For example, rather than
installing a new sprinkler system for fire suppression throughout the
entire Center, which would have closed multiple theaters simultaneously,
the Center is installing sprinklers in each theater as it is renovated.
Thus, only one theater is closed at a time. According to Center officials,
this approach minimizes the disruptions to ongoing operations in other
areas of the Kennedy Center
920 U.S.C. S: 76j(a)(1)(F).
1040 U.S.C. S: 3312.
11For purposes of certain laws, the Kennedy Center is treated as a federal
agency.
12International Code Council, International Building Code 2003.
13International Code Council, International Fire Code 2003.
14National Fire Protection Association, Life Safety Code 101 (Quincy,
Massachusetts: 2003).
that could result in lost revenue. When the Opera House was renovated, for
example, it was closed for almost a year but performances continued in all
of the other theaters.
The Kennedy Center is a bureau of the Smithsonian Institution. The John F.
Kennedy Center Act Amendments of 1994 (Kennedy Center Act) designates the
Kennedy Center as a "federal entity" for purposes of the Inspector General
Act of 1978, as amended, (IG Act).15 The Kennedy Center Act states that
only federally appropriated funds are subject to the requirements of a
federal entity under the IG Act. The Kennedy Center Act authorizes the
Smithsonian Institution's Office of the Inspector General (Smithsonian
OIG) to audit and investigate activities of the Kennedy Center involving
federally appropriated funds, on a reimbursable basis, if requested by the
Kennedy Center Board of Trustees. To date, the Kennedy Center has not
requested the Smithsonian OIG to conduct an audit or investigation of its
activities.
The Kennedy Center conducts capital projects primarily through three
offices-Project Management, Contracts, and Finance. Figure 2 illustrates
the organization of these three offices within the Kennedy Center. The
Kennedy Center receives federal appropriations annually for capital repair
and restoration to implement its CBP and for the operations, maintenance,
and security of the facility. In fiscal year 2005, the Kennedy Center
received approximately $16.1 million in federal funds for capital
improvement projects, and $16.9 million for operations, maintenance, and
security of the facility.16 The Kennedy Center receives appropriated funds
to support its CBP as a lump sum and not on an individual project by
project basis. In addition, the Kennedy Center's appropriated funds for
capital projects remain available until expended. Federal appropriations
represent less than half of the Kennedy Center's total revenue. The
Kennedy Center generates the majority of its revenues from performances
1520 U.S.C. S: 76l (d).
16The Kennedy Center's appropriation for fiscal year 2005 is contained in
the Consolidated Appropriations Act of 2005, P.L. 108-447, 118 Stat. 2809
(2004). P.L. 108-447 appropriated to the Kennedy Center $16,334,000 for
capital improvements and $17,152,000 for operations and maintenance. There
are two rescissions in the 2005 appropriations act that reduced the final
amount provided to the Kennedy Center for capital improvements and
operations and maintenance. The first is an across-the-board rescission of
0.594 percent for Interior and Other Related Agencies, which applied to
the Kennedy Center. The second is an additional across-the-board
rescission of 0.8 percent for most agencies, which also applied to the
Kennedy Center.
at the Center, contributions, and investments. Federal funds, not the
Kennedy Center's private funds, are used for capital improvements in the
CBP. Federal appropriations are not used for performance-related expenses.
The Kennedy Center's total operating expenses in fiscal year 2003 were
about $118 million.
Figure 2: Kennedy Center Organization of Selected Positions and Offices
Key Capital Projects Completed, but Costs Exceeded Budget Estimates and Were
Not Always Reported Timely or Accurately
The Kennedy Center has completed many renovation projects (see fig. 3),
but each of the projects we reviewed exceeded its budget due to contract
modifications that added work to projects. Many changes were necessary
because the Kennedy Center did not have good knowledge of the building's
site conditions. Additionally, the absence of comprehensive policies and
procedures has impeded effective management of federal funds. Finally, the
information on cost growth and delays has not always been timely or
accurately communicated to the Kennedy Center Board of Trustees or
Congress.
Figure 3: Scope of Key Kennedy Center Capital Projects
Kennedy Center Has Completed Many Renovations, but Contract Modifications
Increased Project Costs
The Kennedy Center has completed renovations to the Opera House, Concert
Hall, and its plaza-level public spaces and installed a building wide fire
alarm system, but the actual costs of the projects we reviewed exceeded
the original budgeted costs. Specifically, costs exceeded budget estimates
by about 41 percent for the Concert Hall renovation, 21 percent for the
Opera House renovation, 50 percent for the fire alarm system renovation,
and 13 percent for the plaza-level public space renovations (see fig. 4).
These findings are consistent with our finding, reported in 2003, that the
costs of the Kennedy Center's garage expansion and site improvements
projects greatly exceeded the estimates.17
Figure 4: Budgeted and Actual Costs for Selected Kennedy Center Capital
Projects
Renovation projects like those undertaken by the Kennedy Center are
difficult to complete due to associated challenges with refurbishing as
opposed to new construction. For example, according to the Kennedy
17GAO-03-823.
Center, renovation projects are susceptible to cost increases stemming
from unexpected site conditions. This is consistent with our finding that
a primary cause of cost growth in the projects we evaluated were contract
modifications resulting from the Kennedy Center's lack of knowledge of the
building's existing conditions. The Kennedy Center lacked knowledge of
site conditions because (1) it does not have as-built drawings18 that show
how building components were originally constructed and (2) schedule and
building conditions at times limited the Center's ability to conduct
detailed investigations during project design stages. According to a
Kennedy Center official, given the nature of construction, installed work
often differs from what is indicated on the original architectural plans,
sometimes in significant ways. Without accurate drawings, designers could
not ascertain certain current building conditions, and inaccuracies were
inadvertently built into project plans and designs.
Architects and engineers additionally lacked sufficient access to the
project sites during the design phase. According to Kennedy Center
officials, because the Kennedy Center focused on maximizing its theaters'
operating time, designers were at times limited in their ability to survey
the project site and document its condition. This type of exploration
often requires the removal of some portion of the existing finishes to see
what is behind them. Because invasive surveys were not completed,
designers did not identify utilities and structural components shielded
behind walls, floors, and ceilings. In cases where the unforeseen
conditions affected construction, contract modifications were needed.
Kennedy Center officials said that they did not allow exploratory design
work in order to preserve the building's aesthetics. Kennedy Center
officials indicated that they are working to improve the design of future
projects by using noninvasive exploratory methods, such as X-ray
technology, to better ascertain site conditions.
According to the Kennedy Center, about $1 million of the Concert Hall's
contract modifications and $1.5 million of the Opera House's contract
modifications were the result of actual conditions that differed from
those shown on design drawings. In the Opera House renovation, the Kennedy
Center attributed the following unexpected site conditions to absent
asbuilt drawings and resulting in contract modifications: (1) the ceiling
crawl space was not as large as the drawings indicated, (2) steel
reinforcement
18As-built or record drawings show the work as it was actually installed,
which is often different from how it was designed to be installed or
built.
that was not shown on the drawings existed in the balconies, and (3) a
large steel-reinforced concrete beam in the orchestra floor was not
depicted on existing drawings. Figure 5 provides a description of the
concrete beam and shows how it contributed to cost growth on the Opera
House renovation project.
Figure 5: Opera House Unforeseen Site Condition
In attempting to maintain its construction schedule while minimizing the
impact on its performance schedules, the Kennedy Center incurred a
considerable amount of overtime charges. As the Kennedy Center relies on
proceeds from ticket sales, programs, and contributions, Center managers
sought to limit the disruption to major performance venues, such as the
Opera House and Concert Hall. In planning the Opera House renovation, for
example, the Kennedy Center set a firm goal of completing work by December
2003 to ensure that the work would be completed in time to host the annual
Kennedy Center Honors.19 Over $560,000 of the $4 million cost growth for
the Opera House renovation resulted from overtime pay to contractors
completing the renovations.
The Kennedy Center also may have paid contractors more than necessary
because it routinely negotiated the value of project modifications after
contractors had already completed the work. For example, contractors
performed about $2.2 million worth of work in the Concert Hall renovation
and about $2.1 million worth of work in the Opera House rehabilitation
without negotiating the value of the modifications with the Kennedy Center
beforehand. Kennedy Center officials said that this was necessary to
maintain tight schedules. The practice of establishing cost after work has
been completed is discouraged in federal contracting regulations. Our
previous work has shown that contractors have limited incentive to control
costs until firm prices are negotiated for contract changes, and the
government does not have an opportunity to consider more efficient
construction methods or management controls if work is completed before
the price is established.20
In an attempt to reduce risk to the Kennedy Center, it has entered into a
contract for theater renovation work that shifts much of the project's
risk to the contractor. Under this "construction manager at-risk"
arrangement, a construction management contractor will be hired to
participate in the design process and will then be responsible for hiring
contractors to do the construction. The construction management contractor
will be at risk from the standpoint of being responsible to the Kennedy
Center for managing the construction according to the established cost,
schedule,
19Begun in 1978, the Kennedy Center Honors is an annual ceremony that
recognizes artists with lifetime achievement awards. The ceremony also
serves as a major fundraising event.
20GAO, NASA Procurement: Challenges Remain in Implementing Improvement
Reforms, GAO/NSIAD-94-179 (Washington, D.C.: Aug. 18, 1994).
and scope. However, this method may not reduce costs because contractors
will increase their price to cover the risk shifted to them.
Lack of Clearly Designed, Comprehensive Policies and Procedures Undermined
Effective Project Management
While it was beyond the scope of this engagement to conduct a
comprehensive financial review of the Kennedy Center's procurement
process, we found some deficiencies in procurement operations for capital
improvement projects. During a review of a limited selection of the
Kennedy Center's capital expenditures, we found that the Center did not
maintain complete and accurate financial records which could impact
safeguarding of federal funds. These deficiencies can be attributed, in
part, to the Center's lack of a comprehensive set of documented policies
and procedures to guide the various activities related to the acquisition
of goods and services for its capital improvements program. As a result,
the Kennedy Center may not be able to properly account for or report
financial transactions to Congress and other interested parties.
According to the guidance for federal agencies21 contained in the Joint
Financial Management Improvement Program's (JFMIP) Framework for Federal
Financial Management Systems and Office of Management and Budget (OMB)
Circular No. A-127, Financial Management Systems, effective financial
management depends on appropriate control of financial transactions and
timely recording of financial information in a manner that satisfies
multiple users. Requirements for internal controls over financial
operations can be found in both OMB Circular No. A-123,
Management Accountability and Control, and GAO's Standards for Internal
Controls in the Federal Government.22 Federal agencies are required to
establish financial controls; ensure reliable and timely information is
obtained and maintained; and produce accurate, consistent, and complete
financial data to enable cost-effective mission achievement and risk
mitigation. The Kennedy Center's policy is to rely on contractor invoices
to establish the dates the services were performed and make specific
reference to the invoices in its receipt certifications. Because the
Center does not record the date or period that services were performed at
the time of occurrence, it is unable to establish and maintain reliable up
to date accounting records. This lack of real-time data hampers the
Center's
21The Kennedy Center is an independent establishment of the executive
branch of government as defined in OMB Circular A-127 and, as such, is
subject to OMB guidance regarding financial management and internal
controls.
22GAO/AIMD-00-21.3.1, Nov. 1999.
ability to prepare reliable quarterly financial reports regarding the
status of funds and budget execution and to manage project costs. When
status reports are required, construction costs could be recognized before
invoices are received by recording an estimate of costs incurred based on
a percentage of completion of the projects that are in progress, or some
other systematic process that approximates actual up to date costs.
OMB guidance and GAO standards for internal controls state that agencies
need to properly document their transactions. The documentation should be
clear and complete and show sufficient information to adequately account
for the disbursement. During our review of a selection of 224 Kennedy
Center capital expenditures-dating from September 2000 to September
2004-we found that 63 of the contractor invoices (28 percent) paid by the
Center did not contain enough detailed information to support their
accuracy and validity. Furthermore, without current and accurate
information to substantiate payments, the Kennedy Center may be hampered
in its ability to detect erroneous or improper payments. For example, we
found a duplicate payment that may have been prevented if the Center had
better information available.
Of the invoices that lacked sufficient detail, nearly all were related to
services the Center received from the U.S. Army Corps of Engineers. The
Center's transactions with the U.S. Army Corps of Engineers are governed
by the Economy Act (31 U.S.C. 1535 and 1536), which authorizes an agency
acquiring goods or services from another agency to reimburse the
performing agency only for its actual costs of providing the goods or
services. The Kennedy Center did not have sufficient procedures in place
to ensure that it was being charged for costs consistent with its Economy
Act agreement. We found, for example, that invoices from the U.S. Army
Corps of Engineers generally identified separate total amounts for the
agreed-upon services (as billed by the Corps' contractors) and overhead
and labor costs incurred by the Corps, but that the invoices did not
provide any details regarding the basis for the claimed costs, such as
overhead rates. We were unable to determine, from either the Corps
invoices submitted to the Kennedy Center for reimbursement or the
information accompanying them, whether the costs being claimed for work
performed were for actual costs consistent with the Economy Act agreement.
This lack of detail on invoices subjects the Kennedy Center to risk of
paying the Corps amounts inconsistent with the Corps' actual costs, as
agreed to.
In response to a GAO recommendation,23 the Project Management Office
initiated the development of a policy and procedure manual that is
currently in draft form. The manual begins the process of outlining roles
and responsibilities for the project management staff and defining
standard operating procedures for managing projects. However, the Kennedy
Center has not completed this manual, nor has it formalized its
contractual and financial management policies and procedures. This makes
it difficult for people in the different Kennedy Center departments to
understand their role and requirements in the oversight of federal funds.
In working to improve its management capabilities, the Kennedy Center
hired a Contracts Chief in March 2003, and is seeking an additional
contracting officer. Also, in March 2004 the Kennedy Center hired a
Director of Capital Projects to lead the Project Management Office.
The Kennedy Center Did Not Always Timely or Accurately Communicate Cost
Growth and Schedule Delays to Its Board or Congress
The Kennedy Center uses several communication methods, both internal and
external to the organization, to convey information about its capital
projects, and we found that the Center sometimes provided untimely or
inaccurate information on projects. Figure 6 illustrates the main
mechanisms the Kennedy Center uses to communicate information about
project schedules, costs, and status to Congress, its Board of Trustees,
and the public. The legislation that authorized the Kennedy Center Board
of Trustees to carry out capital improvement projects required the Board
to develop and annually update a CBP. However, the Kennedy Center has not
consistently updated the CBP on an annual basis. The Kennedy Center
provides budget justifications and receives federal funding annually for
capital improvement projects based on its CBP, and testifies before
various congressional committees when requested. According to the Kennedy
Center, the Center's Board of Trustees oversees the President of the
Kennedy Center on the overall management and direction of the Center.
Within the Board of Trustees, the Operations Committee is responsible for
ensuring the appropriate use of federal funds for capital projects and
efficient management of the operations and maintenance of the Center. In
doing that, it reviews plans for capital expenditures identified in the
CBP and receives status reports on projects as they are planned and
implemented.
23GAO-03-823.
Figure 6: Kennedy Center Communication Methods
aMembers of Congress serve on the Kennedy Center Board of Trustees and the
Operations Subcommittee.
Our analysis of officially documented communication using these mechanisms
showed certain inconsistencies in the information the Kennedy Center
presented. For example, in its fiscal year 2001 budget request, which
according to a Kennedy Center official was prepared in 1999, the Kennedy
Center management reported that it planned to obligate $23.3 million for
capital repairs. Operations Committee meetings held over the course of
fiscal year 2001 reported revised obligation amounts ranging between $41.6
and $44.4 million. The amount actually obligated was $36.4 million. While
planned obligations can change over time, the reasons for these
differences are not clear because the Kennedy Center did not include
sufficient project-level budget information in its budget justifications
to Congress. Rather, as we reported in September 2004, projects are
grouped into broad budget categories, which do not include budget
information for specific projects.24 As a result, it is difficult to
understand or have stakeholders hold the Kennedy Center accountable for
true project costs and schedules, compare the data presented through the
various communications mechanisms, or determine if funds were used as
intended.
24GAO-04-933. Page 19 GAO-05-516T
The following examples illustrate untimely and inaccurate communication on
the projects we reviewed:
o Concert Hall. Kennedy Center officials testified to Congress in 1999,
2000, and 2001, that the Concert Hall rehabilitation-completed in 1997-was
"on time and on budget." However, this is inconsistent with a September
1997 Operations Committee Meeting status report that states the project
experienced extraordinary interior design changes, all of which were
unbudgeted and contributed to a cost increase of almost $1.2 million.
Also, our analysis of Kennedy Center project documents shows that the
project cost $6.2 million more than its initial budget of $15.1 million.
o Fire suppression sprinklers. The Fiscal Year 2005 Budget Justification
and the 2004 CBP continue to emphasize that the Kennedy Center intends to
install sprinkler systems throughout the entire facility. However, we
determined as part of our review, and verified through interviews with
Kennedy Center officials, that the Center does not intend to install
sprinklers in the large parts of the Kennedy Center, specifically, the
Grand Foyer, the Hall of States, and the Hall of Nations.
o Fire Alarm system. References to improving the building fire alarm
system are included in Kennedy Center Budget Justifications for fiscal
years 1995 through 2005. Language in these budget justifications refers to
project phases, but start and completion dates change from year to year
without explanation. For example, the completion date for the project was
reported as being scheduled in fiscal year 2002 in the Kennedy Center's
Fiscal Year 2003 Budget Justification, but the Center's 2005 Budget
Justification listed the project as being scheduled for completion in
fiscal year 2004.25 Reasons for the project's delay were not evident in
the records that we reviewed.
Poor Record Retention Makes It Impossible to Determine How Much the
Building Plan Has Changed Since 1995
According to a Kennedy Center official, the Center does not have a formal
records retention policy, and the Kennedy Center did not retain complete
project budget information previous to the 2002 CBP. CBP updates also do
not provide historical data, such as budget information for past projects
or how changes to those budgets affected the overall plan. Because the
Kennedy Center lacks records, GAO could not determine how any cost and
schedule changes affected the overall implementation of the 1995 CBP or if
federal funds were used as originally anticipated. However, our
25Fire alarm system installation was substantially completed in February
2004.
finding that several of the major projects from that time went over their
budget estimates suggests that funds must have been reallocated.
Information on reallocations, reconciliation of estimates to actual
spending, and other project-level accounting of federal funds is not
routinely reported to the Board or Congress. In addition, project records
for the Concert Hall renovation were incomplete and the as-built drawings
for the Kennedy Center were missing.
Kennedy Center Does Not Appear to Meet Some Fire Safety Code Requirements but
Exceeds Access Requirements
Based on an independent expert's assessment, we determined that the
Kennedy Center does not appear to meet some fire safety code requirements.
After requesting and obtaining funds from Congress to meet fire code
deficiencies, such as a lack of fire suppression sprinklers, as well as
other needs, the Kennedy Center decided against its plan to meet fire
safety code requirements and chose not to install sprinklers and smoke
evacuation systems in the Grand Foyer, the Hall of States, and the Hall of
Nations. The Kennedy Center reversed its decision to install these systems
without having its decisions independently reviewed or clearly informing
its Board or Congress that it was not spending the funds as planned.
According to our independent expert, the Kennedy Center has met or
exceeded disabled access requirements as part of its renovation.
The Kennedy Center Does Not Appear to Comply with Fire Safety Code
While the Kennedy Center has worked to address fire life safety
deficiencies, and improvements are ongoing, based on an assessment
performed by an independent expert hired by GAO, we found that the Kennedy
Center does not appear to meet some fire life safety requirements.26 Over
the past decade, several internal Kennedy Center reports have also
identified other fire life safety deficiencies-such as exit paths that
might not protect occupants from fire-in the Grand Foyer, the Hall of
States, and the Hall of Nations (see fig. 7).
26UNICCO Government Services, Inc., Life Safety, Fire Alarm System and ADA
Assessment of the John F. Kennedy Center For The Performing Arts
(Centreville, VA: 2005).
Figure 7: Exit Routes from the Kennedy Center's Major Theaters
NFPA 101 allows two approaches for dealing with fire safety issues: an
entity can adhere directly to the fire safety code (also called a
prescriptive approach), such as installing sprinklers or smoke evacuation
systems, or it can provide an alternative that allows people to exit the
building safely in case of fire (also called a performance-based
approach). The Kennedy Center chose the second approach and commissioned
an egress and fire
modeling study in 2003 to address the exit issue, specifically as it
pertained to the discharge of occupants from the facility. 27 Due to the
results of this study, the Kennedy Center did not implement its earlier
plan of installing a fire suppression system and smoke evacuation system
in the Grand Foyer, the Hall of States, and the Hall of Nations.
The modeling study indicates that, in the event of a fire, the time needed
for evacuation would be less than the time it would take for these exit
pathways to become untenable, provided certain steps are taken. These
steps include (1) installing sprinklers at the Millennium Stages and (2)
developing and implementing a program to manage the storage of scenery,
props, and other combustible materials. With input from our independent
expert, we concluded that the above steps have not been taken and thereby
invalidate the study's assumptions. Since the Kennedy Center does not meet
the conditions upon which the study was based, it appears to fall short of
providing the level of protection intended by the code. Furthermore,
Kennedy Center stakeholders, such as the Board of Trustees, have not
accepted and adopted the terms of the study as described in NFPA 101. The
Kennedy Center has not documented these determinations, but Kennedy Center
officials said that the key decisions would be documented at the end of
the fire life safety improvements at the Center.
We also identified two additional deficiencies, based on NFPA 101, that
are of immediate concern. First, there are no fire rated doors in some
areas, such as the fire pump room and the Fire Command Center. These
locations contain key emergency systems that would need protection in the
event of a fire. Second, several fire-safety related problems were evident
with the Millennium Stages. The stages are located at the ends of the
Grand Foyer, a configuration that poses an exit deficiency because it does
not provide two different, marked exit routes for occupants (see fig. 8).
Additionally, NFPA 101 indicates that the stages must have a smoke control
system that is integrated with a sprinkler system and smoke detectors over
the stage area. These systems have not been installed.
Officials from the Kennedy Center said that they believe that all fire
safety code requirements are being met but agreed to make some changes.
For example, the Kennedy Center said that it would install fire protective
doors on the fire pump room and the Fire Command Center, and that it
27Ehrenkrantz Eckstut & Kuhn Architects, PC, Egress and Fire Modeling
Study of the Grand Foyer, Hall of States, and Hall of Nations (Washington,
D.C., 2003).
would document its key decisions once its Life Safety Improvement Program
was completed.
Figure 8: Millennium Stage Located at the End of the Grand Foyer Outside of the
Eisenhower Theater
The curtains along the side of the Millennium Stage obscure emergency
exits when closed.
The Kennedy Center Chose Not To Install Sprinklers Throughout the Center,
But Did Not Consult Independent Experts or Clearly Inform Key Stakeholders
After requesting the necessary funds from Congress to meet fire code
deficiencies, the Kennedy Center decided not to install sprinklers and
smoke evacuation systems in the plaza-level public spaces as initially
planned based on the findings of the modeling study. In an October 2002
meeting with its Trustees, the Kennedy Center reported that design and
first stages of construction of the sprinkler and smoke evacuation systems
would be completed in 2003. The Kennedy Center no longer plans to install
sprinklers in the Grand Foyer, the Hall of Nations, the Hall of States, or
at the Millennium Stages. Recent Kennedy Center documents continue to
state that the funds will be spent to install sprinkler systems throughout
the Center.
Furthermore, in deciding not to install sprinklers and smoke evacuation
systems in the plaza-level public spaces, the Kennedy Center did not
consult any independent experts, such as the General Services
Administration's (GSA) Fire Protection Engineer for the National Capital
Region, or any other recognized expert about whether this was an
appropriate choice. In contrast, NFPA 101 provides for peer review of
modeling studies of this nature. In addition, our independent expert and
GSA officials also stated that it is prevailing professional practice to
seek external peer review of a modeling study of this nature. GSA
officials said that other federal entities occasionally consult with them
regarding how to approach difficult code issues, but that the Kennedy
Center has not done so about this exit deficiency.
Peer review may be particularly important for the Kennedy Center for two
reasons. First, the Center lacks sufficient on-staff expertise to
adequately interpret and evaluate this type of modeling study. The Kennedy
Center official who is principally responsible for making fire life safety
code compliance decisions said that he does not have formal training or
certification in engineering or fire protection planning and that he is
not qualified to evaluate modeling studies. Second, the Kennedy Center's
fire safety decisions are not subject to external review. In contrast, GSA
requires a registered fire protection engineer to be heavily involved in
fire safety code compliance decisions for its federal properties, and its
Office of Inspector General (OIG) has the authority to review GSA's
approach to fire safety issues and policies. A GSA Fire Protection
Engineer said that the OIG has provided useful guidance on these issues.
Specifically, a 1999 GSA OIG report concluded that the National Capital
Region Safety, Environment and Fire Protection Branch generally has taken
adequate
measures to meet the mission and goals of its fire safety program, but
made a recommendation for improving building fire safety assessments.28 As
previously mentioned, the Smithsonian OIG has authority to conduct reviews
at the Kennedy Center relating to the expenditure of federal funds, but
the Kennedy Center has not requested assistance from the Smithsonian OIG
or any other federal accountability office in gaining assurance that the
Center is taking prudent steps relating to fire safety decisions. Private
sector entities are accountable to the local fire marshal's assessment of
their compliance with fire safety code. In addition, the Kennedy Center
Act authorizes the Kennedy Center Board of Trustees to utilize or employ
the services of any agency or instrumentality of the federal government or
the District of Columbia on a reimbursable basis. The Kennedy Center has
not sought assistance, as authorized by law, from relevant federal or
District of Columbia officials on fire safety code compliance.
The Kennedy Center Has Improved Disabled Access to Fully Renovated
Theaters and Public Spaces
Our independent expert concluded that the Kennedy Center's compliance with
regulations outlined in ADA has generally met or exceeded the requirements
of the act in the theaters and public spaces that have been renovated. The
Kennedy Center has added numerous ramps, improved signage, and renovated
several bathrooms and elevators to meet ADA requirements (see fig. 9). In
an attempt to make the Center as accessible as possible to disabled
patrons, visitors, and employees, the Kennedy Center has made all levels
of the renovated Concert Hall and Opera House accessible to wheelchairs.
Additionally, the Kennedy Center has hired and trained specialized
personnel to assist patrons and visitors with disabilities. An
Accessibility Manager position is staffed and the Kennedy Center provides
special training to numerous "access" ushers, who help patrons navigate
their way to their seats. In addition, the Kennedy Center's Office of
Accessibility provides details of its special access services over the
phone, and the Kennedy Center's Web site provides access information and
maps showing entrances, restrooms, and other services for the disabled.
28General Services Administration National Capital Region Office of
Inspector General, Audit of National Capitol Region Fire Safety Program,
Report Number: A995174/P/W/R99530 (Washington, D.C.: Sept. 10, 1999).
Figure 9: Selected Access for the Disabled Improvements to the Kennedy
Center as Part of the Comprehensive Building Plan
ADA improvements at the Kennedy Center include (clockwise from top)
disabled access ramp in the Grand Foyer leading to the Opera House,
disabled access ramp in passageway, ADA-compliant signage, and wheelchair
lift.
The areas that the Kennedy Center has not yet renovated have fewer ADA
improvements. For example, the Eisenhower and Terrace Theaters have
limited wheelchair access. The Kennedy Center plans to make additional ADA
improvements Center-wide as part of its CBP, but the Terrace Theater
upgrades have been deferred until after fiscal year 2008.
External Oversight of Kennedy Center Is Limited
Conclusions
Oversight of the Kennedy Center's management of capital projects is
limited in that the Kennedy Center has not requested the Smithsonian OIG
to conduct audits and has not fully complied with the requirements of the
IG Act. The Smithsonian Inspector General said that his office would
respond to an audit request by the Kennedy Center and has conducted
similar audit work for other external organizations. While the IG Act does
not require the Kennedy Center to establish an OIG, the Center is required
to report annually to Congress and OMB on its audit and investigative
activities.29 However, Kennedy Center officials said that they were
unaware of this requirement but plan to start complying with it this year.
As previously discussed, the Kennedy Center Act authorizes the Kennedy
Center Board of Trustees to utilize or employ the services of any agency
or instrumentality of the federal government or the District of Columbia
on a reimbursable basis. To date, the Kennedy Center has not sought such
external assistance.
In summary, Mr. Chairman, the Kennedy Center has made major capital
improvements to the Center since taking over management control in 1995,
but inadequate management and oversight have at times undermined assurance
over processes and programs for fire safety, construction, and financial
management. Of immediate concern are questions about the Kennedy Center's
compliance with some fire safety codes. Taking steps to better address
fire life safety issues can only heighten confidence of the Kennedy Center
and Congress that visitors are enjoying world-class performances in a safe
facility. Questions also remain about the management of construction costs
and accounting procedures associated with recording and paying for the
renovations. Overtime charges resulting in part from aggressive schedules,
a lack of comprehensive information about the construction sites, and a
practice of negotiating the value of contract changes after the completion
of contract work, helped drive the cost of each project we reviewed over
budget.
Although the Kennedy Center has taken steps to improve project management,
key mechanisms to ensure accountability and sound financial management
practices in spending federal funds remain absent or only partially
implemented. Specifically, without more detailed, transparent, and timely
information on how funds have been budgeted and
29See Inspector General Act of 1978, as amended, 5 U.S.C. S: App. 3,
section 8G, and 2004 List of Federal Entities, 70 Fed. Reg. 4157 (Jan. 28,
2005).
spent, the Kennedy Center's Board and Congress will lack timely and
accurate information on projects and thus will lack reasonable assurance
that the Kennedy Center is deploying its resources as intended. In
addition, the Kennedy Center has never made use of any other federal
accountability office-the Smithsonian OIG or another qualified entity-to
review the management of programs employing federal funds. Establishing a
continuing relationship with an OIG and a federal fire safety expert could
help the center to minimize risks that future capital projects will
encounter planning problems, budget overruns, or fire safety code
deficiencies.
Recommendations
1. We recommend that the Chairman of the Board of Trustees for the
Kennedy Center exercise greater oversight of the Center's management
through the Board of Trustees. The Kennedy Center should work with the
Smithsonian OIG, or another independent federal government oversight
organization, to provide strategic and annual audit plans for ongoing
oversight of the Kennedy Center's use of federal funds based on an
analysis of risk, safety, and vulnerability to internal control
weaknesses. These plans should also specify the audits to be provided on a
reimbursable basis by the Smithsonian OIG or another independent federal
government oversight organization.
2. To ensure the safety of the Kennedy Center, we recommend that the
Chairman of the Board of Trustees direct the President of the Kennedy
Center to implement the following two recommendations:
a.
b.
Take steps to better comply with the fire safety code. At a minimum, these
steps should include fully implementing the conditions of the modeling
study, ensuring that doors in key areas provide adequate separation from
fire, and addressing the code deficiencies at the Millennium Stages.
Promptly seek peer review by a knowledgeable third party of the egress and
fire modeling study used as a substitute for prescriptive code solutions
and implement any recommendations. Additionally, consult with recognized
experts, such as GSA, to determine whether the Kennedy Center is fully
adhering to prevailing professional practices regarding fire life safety
issues.
3. To improve the Kennedy Center's management of capital projects, we
recommend that the Chairman of the Board of Trustees direct the
President of the Kennedy Center to implement the following five
recommendations:
a. Provide more timely and accurate information about capital projects by
detailing their budget, scope, cost, and schedule, and providing to
stakeholders an annual reconciliation of the status of all planned,
delayed, eliminated, and actual projects.
b. Take steps to control cost growth and schedule changes in future
capital projects by setting more flexible schedules and improving its
management of contract modifications.
c. Strengthen the Kennedy Center's financial management controls by
designing and implementing comprehensive contract, financial, and project
management policies and procedures in accordance with prescribed federal
guidance. These policies and procedures should ensure that
o the Project Management Office prepares inspection reports, or similar
documents, when services are performed that include a description of the
services performed and the date(s) or period of performance and use this
information to verify the validity of contractors' invoices;
o complete, up to date costs for construction and other services are
recognized and used to prepare quarterly financial reports and manage
project costs;
o reasonable efforts are made to match invoices with inspection reports
and previously paid invoices to prevent or detect duplicate payments;
o contractors' invoices meet minimum requirements and contain sufficient
detailed information to clearly support the accuracy and validity of
invoices; and
o for Economy Act transactions, payments to other federal agencies are
for actual costs consistent with the Economy Act agreement.
d. Establish and enforce a documents retention policy that allows for
accountability of the Kennedy Center's federal funds;
Agency Comments
e. Have relevant Kennedy Center offices develop as-built drawings and
better track future changes to the Center.
We provided these findings and recommendations in a draft of our upcoming
report to the Kennedy Center for its review and comment. The Kennedy
Center disagreed with several of our recommendations and agreed with
others. The Kennedy Center agrees that more oversight would be useful, but
it is unsure what the best mechanism would be for providing such
oversight. The Kennedy Center also believes that it is in compliance with
fire code, but agreed to seek a third-party review of its approach to
addressing certain fire code deficiencies. The Kennedy Center agreed that
it should improve its information about capital projects, its document
retention practices, and its knowledge of site conditions at the Center.
However, it disagreed that it needed to strengthen its financial controls
in some of the ways that we have recommended. For example, it believes
that its information is up to date and plans to fully comply with the
Economy Act. We carefully reviewed the Kennedy Center's concerns and
overall we still believe that the Center needs to better comply with fire
safety code and strengthen its management controls. The Kennedy Center
also provided technical comments that we incorporated as appropriate.
Scope and Methodology
We conducted our review from August 2004 through March 2005 in accordance
with generally accepted government auditing standards. During our work, we
reviewed files for five of the largest projects-the renovation of the
Concert Hall, Opera House, Eisenhower Theater, Plaza-Level Public Spaces,
and installation of a new Fire Alarm system-to the extent that they
existed. These projects represent the three largest theaters at the
Kennedy Center, the largest public spaces, and the most expensive fire
life safety improvement completed to date. Files that we reviewed included
the Kennedy Center's audited financial statements, federal authorization
and appropriation laws; other related laws, contractor invoices; project,
contracting, and finance files; minutes from the Board of Trustees
meetings; minutes and agendas of the Board's Operations Subcommittee
meetings; the CBP's published since 1995; annual Kennedy Center budget
justifications to Congress since 1995; and testimonies before Congress
over this same period. We also interviewed numerous Kennedy Center senior
managers and officials in the Project Management, Contracts, Finance, and
President's Offices, and officials from the Smithsonian OIG, GSA National
Capital Region, and the D.C. Fire Marshal. Furthermore, our staff of
licensed professional engineers toured the site, and we contracted with an
independent expert to assess the
Kennedy Center's compliance with applicable fire life safety code and
disabled access requirements.30 For our analysis of the Kennedy Center's
compliance with the fire life safety code, we took the Center's ongoing
and planned fire life safety upgrades into consideration when identifying
deficiencies, and we did not identify deficiencies where upgrades or
improvements were planned.
Mr. Chairman, this concludes my prepared statement. I would be pleased to
respond to any questions that you or the other Members of the Subcommittee
may have.
For further information about this testimony, please contact me at (202)
512-2834 or [email protected]. Michael Armes, Lindsay Bach, Chris Bonham,
Matt Cail, Keith Cunningham, John Davis, George Depaoli, Tim Dinapoli,
Terrell Dorn, Edda Emmanuelli-Perez, Colin Fallon, Susan Fleming, Brandon
Haller, John Krump, Julie Phillips, Theresa Patrizio, Robert Preshlock,
Susan Michal-Smith, and Carrie Wilks also made key contributions to this
statement.
GAO Contacts and Staff Acknowledgments
30UNICCO Government Services, Inc., Life Safety, Fire Alarm System and ADA
Assessment of the John F. Kennedy Center For The Performing Arts
(Centreville, VA: 2005).
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