U.S. International Broadcasting: Management of Middle East	 
Broadcasting Services Could Be Improved (04-AUG-06, GAO-06-762). 
                                                                 
The Broadcasting Board of Governors' (BBG) broadcasting services,
Radio Sawa, and the Alhurra satellite television		 
networks--collectively known as the Middle East Broadcasting	 
Networks, Inc. (MBN)--currently aim to reach Arabic speakers in  
19 countries and areas throughout the Middle East. Annual	 
spending for current activities amounts to about $78 million. GAO
reviewed MBN's (1) strategic planning to address competition in  
the Middle Eastern media market, (2) implementation of internal  
control, (3) procedures MBN has developed to ensure compliance	 
with its journalistic standards, and (4) performance indicators  
and whether targets have been met.				 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-06-762 					        
    ACCNO:   A58042						        
  TITLE:     U.S. International Broadcasting: Management of Middle    
East Broadcasting Services Could Be Improved			 
     DATE:   08/04/2006 
  SUBJECT:   Broadcasting standards				 
	     Competition					 
	     Internal controls					 
	     International broadcasting 			 
	     International relations				 
	     Mass media 					 
	     Public diplomacy					 
	     Radio						 
	     Radio broadcasting 				 
	     Television 					 
	     Performance measures				 
	     Employee training					 
	     Alhurra Television 				 
	     Middle East					 
	     Radio Sawa 					 

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GAO-06-762

     

     * Report to the Chairman, Subcommittee on National Security, Emerging
       Threats and International Relations, Committee on Government Reform,
       House of Representatives
          * August 2006
     * U.S. INTERNATIONAL BROADCASTING
          * Management of Middle East Broadcasting Services Could Be Improved
     * Contents
          * Results in Brief
          * Background
               * Development of MBN
               * MBN Funding
               * MBN's Mission and Scope of Operations
               * Radio Sawa's Operations
               * Alhurra's Operations
          * Lack of Long-term, Comprehensive Planning Could Limit MBN's
            Ability to Respond to Market Challenges
               * Radio Sawa and Alhurra Face Significant Competitive
                 Challenges
               * MBN Has Taken Some Steps to Address Its Competitive
                 Challenges
               * MBN Has Conducted Planning Exercises but Lacks a Long-term
                 Strategic Plan
          * MBN Has Made Progress in Developing Internal Control, but
            Additional Steps Could Improve Its Control Structure
               * MBN Faced Initial Challenges in Developing Its Internal
                 Control Structure
               * MBN Has Made Progress in Developing Its System of Internal
                 Control, but Some Control Elements Could Be Improved
                    * MBN's Internal Control Board Has Not Met to Establish
                      Protocols to Develop and Monitor Its Internal Control
                      Structure
                    * MBN Has Not Completed an Internal Control Plan
                    * MBN Has Not Established a Comprehensive Process to
                      Analyze Risk
                    * MBN Has Not Developed a Comprehensive Training Program
                      on Internal Controls
          * MBN Has Developed Editorial Procedures to Support Its
            Journalistic Standards, but Could Improve Monitoring and Some
            Quality Control Measures
               * MBN Has Developed Journalistic Standards and Implemented a
                 Wide Variety of Pre- and Postbroadcast Editorial Procedures
               * MBN Could More Fully Develop Some Quality Control Measures
                 and Lacks Regular Editorial Training
               * MBN Lacks Comprehensive, Regular Program Reviews to
                 Determine Compliance with Mission and Journalistic Standards
                    * Annual Program Reviews Have Not Been Conducted for
                      MBN's Services
                    * Radio Sawa's Program Review Was Limited by Its Emphasis
                      on Audience Input
                    * Radio Sawa's Program Quality Score Is Inconsistent with
                      Other BBG Entities
                    * MBN Staff Had Limited Awareness of the Radio Sawa
                      Program Review and Follow-up
          * BBG Has Developed Several Performance Indicators, Although
            Weaknesses in Audience Surveys Call into Question Whether MBN
            Audience Size and Credibility Targets Have Been Met
               * MBN Performance Indicators and Targets Have Been
                 Established, but Some Are Not Fully Developed
               * BBG Should Increase Steps to Ensure Reliability and
                 Transparency of Its Performance Estimates
                    * Measurement and Research Methods Should Allow for
                      Confidence in Reliability of Performance Information
                    * BBG Has Not Taken Sufficient Steps to Ensure
                      Reliability and Transparency of Its Performance
                      Estimates for MBN
          * Conclusions
          * Recommendations for Executive Action
          * Agency Comments and Our Evaluation
     * Scope and Methodology
          * Review of MBN Internal Controls
          * Review of MBN's Editorial Procedures
          * Review of MBN Audience Survey Methods and Performance Indicator
            Estimates
     * Radio Sawa and Alhurra Programming
     * Radio Sawa Program Review
     * CIBAR Standards
     * Comments from the Broadcasting Board of Governors
          * GAO Comments
     * GAO Contact and Staff Acknowledgments

Report to the Chairman, Subcommittee on National Security, Emerging
Threats and International Relations, Committee on Government Reform, House
of Representatives

August 2006

U.S. INTERNATIONAL BROADCASTING

Management of Middle East Broadcasting Services Could Be Improved

Contents

Tables

Figures

August 4, 2006Letter

The Honorable Christopher Shays Chairman Subcommittee on International
Security, Emerging Threats     and International Relations Committee on
Government Reform House of Representatives

Dear Mr. Chairman:

The President's 2006 National Security Strategy stipulates that public
diplomacy, which includes U.S. international broadcasting, is an important
instrument for engaging and informing foreign audiences, creating and
maintaining a dialogue with Muslim leaders, and confronting misinformation
about the United States. Under the direction of the Broadcasting Board of
Governors (BBG), an independent agency, the mission of all U.S.
international broadcasting services is to promote freedom and democracy
and enhance understanding through objective journalism. The BBG's priority
broadcasting services, Radio Sawa and the Alhurra satellite television
networks1-both operated since 2005 by the nonprofit grantee Middle East
Broadcasting Networks, Inc. (MBN)-currently aim to reach Arabic speakers
in 19 countries and areas throughout the Middle East. Spending for MBN's
broadcasting services has increased in recent years and currently amounts
to about $78 million annually. In fiscal year 2005, MBN received
additional funding to support a new Alhurra satellite television
initiative to reach Arabic speakers in Europe. MBN has recently requested
funding to enhance its radio and television programming content.

This report assesses (1) the extent to which MBN has used strategic
planning to address its competitive challenges in the Middle Eastern media
market, (2) the progress MBN has made in developing financial and
administrative controls to ensure that the organization operates
efficiently and complies with its grant agreement, (3) the procedures MBN
has developed to ensure compliance with its journalistic standards, and
(4) the extent to which BBG has developed performance indicators for MBN's
efforts and met its primary performance targets.

To accomplish our objectives, we reviewed documentation and spoke with
officials from the BBG and its broadcasting entities, including the
grantees (MBN, Radio Free Europe/Radio Liberty (RFE/RL), Radio Free Asia
(RFA)), the Voice of America (VOA), and the International Broadcasting
Bureau. We also spoke with several outside experts, including
representatives from the Department of State, National Public Radio, the
InterMedia research organization, Zogby International, and foreign
international broadcasters such as the British Broadcasting Corporation
(BBC) and Deutsche Welle. In addition, we visited MBN's offices in Amman,
Jordan, and Dubai, United Arab Emirates (UAE). We held telephone
interviews with MBN's current affairs contractor in Beirut, Lebanon, and
corresponded with the head of the MBN office in Baghdad, Iraq. We
conducted our evaluation from August 2005 through May 2006 in accordance
with generally accepted government auditing standards. (Appendix I
provides a more detailed description of our scope and methodology.)

Results in Brief

MBN faces a number of challenges in carrying out its mission of
broadcasting in the Middle Eastern media market and has taken some steps
to address them. Although MBN has participated in BBG's long-term planning
exercises, it has not yet established a formal long-term strategic plan. A
formal documented strategic plan could help MBN meet challenges in its
competitive marketplace. MBN's challenges include the fact that its
Alhurra television station is currently competing in a market with over
140 other stations and also faces operational and programmatic competitive
disparities, such as having fewer overseas bureaus than its primary
competitors. In addition, its Radio Sawa service lacks FM radio coverage
in certain markets. MBN has begun a number of efforts and proposed
initiatives to address some of its challenges, such as proposals for
Alhurra to increase its hours of news coverage and current affairs
programming and for Radio Sawa to increase the amount of local content it
broadcasts to better compete with local stations. However, MBN lacks a
shared vision of operations for Radio Sawa and Alhurra as well as detailed
implementation strategies and related resource requirements for its
proposed goals. According to GAO guidance,2 organizations should make
decisions in the context of a strategic plan. The absence of a long-term
plan and comprehensive strategic approach for MBN's operations limits
opportunities for strategically addressing impediments to the
organization's achieving its goals and objectives and identifying
opportunities for more efficient operations.

MBN has developed several financial and administrative controls to manage
and safeguard its financial resources. For example, in the past year, MBN
has hired additional financial staff, acquired a new financial information
system, developed administrative and financial policies and procedures,
provided some training to staff, and received an unqualified opinion on
its fiscal year 2005 financial statements. However, additional steps could
be taken to strengthen MBN's system of internal control,3 including (1)
establishing an internal control board to formally develop controls and
coordinate audits, (2) preparing an internal control plan, (3) conducting
a risk assessment to address potential risks to its operation, and (4)
developing a comprehensive training program for its staff. These steps
could help MBN more effectively manage its operations and improve its
internal control structure.

MBN has procedures in place to help ensure its programming meets its
journalistic standards and is consistently accurate, objective, balanced,
and comprehensive. However, MBN has not fully implemented some editorial
procedures, or a comprehensive, standardized program review process of its
broadcast operations. To comply with its standards, MBN has put in place a
variety of pre- and postbroadcast procedures, such as editorial meetings
and postbroadcast discussions that enable producers and editors to review
and provide input to Radio Sawa and Alhurra broadcasts on a daily basis.
However, MBN could more fully develop some quality control measures, such
as using listener and viewer feedback to improve program quality. In
addition, although the BBG calls for its broadcasting services to undergo
a standardized annual program review, MBN's Radio Sawa has had only one
program review, and Alhurra has not had a program review to date.
Furthermore, unlike reviews of other broadcasting services and contrary to
BBG guidance, the Radio Sawa program review was less comprehensive in that
it relied upon several audience panels but did not include input from
in-house analysts or external expert listeners. The lack of annual,
comprehensive program reviews hampers BBG's ability to assure its
audience, Congress, and the BBG that its services are complying with its
journalistic standards and mission.

The BBG has developed performance indicators and targets4 related to
audience size and program credibility for MBN's Radio Sawa and Alhurra
broadcasting services. However, it is not clear whether the Radio Sawa and
Alhurra performance targets have actually been met because of weaknesses
in MBN's methodology and documentation. To develop estimates for audience
size and credibility, the BBG uses results from audience research
conducted overseas. Documentation we reviewed indicated that the BBG
extensively uses nonprobability audience survey results that cannot be
reliably projected to represent a broader population in the region. While
it is not always possible to expect the BBG to use probability samples in
countries where there are security risks, the BBG did not take certain
steps that could have explained and increased the reliability of its
estimates, such as fully documenting its research methods, measuring the
level of uncertainty surrounding its estimates, disclosing significant
limitations, limiting the scope of its projections to areas actually
covered by its surveys, and developing and consistently implementing
policies and procedures for verifying data.

We are making several recommendations to the chairman of the BBG. First,
we recommend that the BBG take steps to improve the efficiency of MBN and
its ability to address challenges by ensuring that MBN develops a
comprehensive long-term strategic plan. In addition, to improve controls
and performance monitoring, we recommend that the BBG require MBN to
implement additional elements of internal control, establish a regular
mechanism for undertaking annual program reviews, implement performance
indicators consistent with other BBG entities, and improve the
transparency and documentation used for audience research to allow for
assessments of confidence in data used for performance indicators.

We received written comments on a draft of this report from the BBG. In
general, the BBG concurred with our recommendations and said that MBN has
made significant progress in the 2 years of its operation in establishing
a sound journalistic organization with financial and administrative
controls. However, the BBG raised a number of concerns about the report's
criticisms of the audience research conducted by the BBG and its
contractors.

Background

Middle East Broadcasting Networks, Inc. (MBN), which includes the services
Radio Sawa and Alhurra, is an independent nonprofit grantee overseen by
the Broadcasting Board of Governors (BBG). The BBG is an independent,
federal agency responsible for overseeing all U.S. government-sponsored,
nonmilitary, international broadcasting programs. The BBG also manages the
operations of the International Broadcasting Bureau, the Voice of America
(VOA), and the Office of Cuba Broadcasting, which are all federal
entities. It also provides funding and oversight to three independent
grantees, MBN, Radio Free Europe/Radio Liberty (RFE/RL), and Radio Free
Asia (RFA) (see figure 1).

Figure 1: Organization of the BBG

Development of MBN

In March 2002, due to concerns about the effectiveness of its outreach to
Arabic speakers in the Middle East, the BBG replaced VOA's Arabic radio
service with Radio Sawa, a 24-hour, 7-day a week, Arabic language radio
station. In April 2003, Congress, at the request of the administration,
provided $26 million in the fiscal year 2003 Emergency Wartime
Supplemental Appropriations Act5 to establish a nonprofit corporation, the
Middle East Television Network (MTN), as a grantee of the BBG to launch
and operate Alhurra TV. Ten months later, on February 14, 2004, Alhurra,
MTN's Arabic-language satellite television station, was launched and
initially started broadcasting 14 hours a day, expanding to 24 hours a day
2 months later. In November 2003, the fiscal year 2004 Emergency
Supplemental Act for Defense and for Reconstruction of Iraq and
Afghanistan6 included $40 million to establish a second 24-hour channel,
Alhurra-Iraq. On April 27, 2004, Alhurra-Iraq was launched. In 2005, MTN
was renamed the Middle East Broadcasting Networks, Inc. (MBN), and Radio
Sawa transferred to MBN. See figure 2 for a timeline of these events and
figure 3 for details on the current organization of MBN.

Figure 2: Timeline Showing Creation and Key Dates of MBN

Figure 3: Organization of MBN

MBN Funding

Congress appropriated more than $274 million to fund Radio Sawa, Alhurra,
and Alhurra-Iraq from fiscal year 2002 through fiscal year 2006.7 Each
year MBN's funding level has increased to support additional 24-hour
television streams and Radio Sawa's 24-hour radio programming. MBN's grant
in fiscal year 2006 is $78.7 million to support Alhurra, Alhurra-Iraq, and
Radio Sawa, as well as the launch of Alhurra-Europe. See figure 4 for a
breakdown of funds by fiscal year.

Figure 4: Appropriations to Radio Sawa, Alhurra, Alhurra-Iraq, and Alhurra
Europe, Fiscal Years 2002-2006

MBN's Mission and Scope of Operations

The Alhurra networks and Radio Sawa are BBG's priority broadcasting
services designed to support the BBG's antiterror broadcasting initiatives
in the Middle East and counter media campaigns used by terrorists by
providing accurate reporting and analysis of the news and by explaining
U.S. policies. Although MBN and its Alhurra broadcasting services postdate
the BBG's current 2002-2007 strategic plan, Radio Sawa, in particular, was
singled out as an opportunity in the plan to target Arabic-speaking youth
and provide them with news that is objective, comprehensive, fresh, and
relevant and to provide a forum for reasoned discussion of "hot button"
issues and U.S. policies. MBN's current mission statement is to broadcast
factual, timely, and relevant news and information about the Middle East,
the United States, and the world to people of all ages in order to advance
the long-term U.S. interests of promoting freedom and democracy and
enhancing understanding in the Middle East. Radio Sawa and Alhurra aim to
be among the sources that audiences turn to in the Middle East for news
and information, to increase the standards of other broadcasters in the
region, and to offer distinctive and provocative programming unavailable
on other stations.

MBN's target audience includes 19 Arabic-speaking countries and
territories8 in North Africa, the Near East, and the Gulf region, which
are home to approximately 250 million people. In addition to its
headquarters in Springfield, Virginia, MBN has several overseas offices,
including a production center in Dubai that broadcasts Radio Sawa's live
newscasts during 8 hours each day and produces some opinion features for
Radio Sawa and current affairs programming for Alhurra (see figure 5).9

Figure 5: Map of MBN Target Countries and Locations of Overseas Offices

Radio Sawa's Operations

Radio Sawa's broadcasts are designed to reach a target audience of 15- to
29-year olds in the Middle East with Western and Arab popular music, news
broadcasts, and specialized programming. Radio Sawa broadcasts 24 hours of
programming every day through a combination of FM, medium wave (AM),
digital audio satellite, and Internet transmission resources. See figure 6
for a map of Radio Sawa's regional reach.

Figure 6: Radio Sawa's FM and AM Broadcast Range

Radio Sawa has developed seven distinct programming streams, including (1)
Iraq, (2) Jordan and the West Bank, (3) the Gulf, (4) Egypt and the
Levant, (5) Morocco, (6) Sudan and Yemen, and (7) Lebanon. All of the
streams generally feature the same major newscasts, current affairs, and
policy features; however, the Iraq program differs slightly, and the
streams all offer differentiated music programs.10 Radio Sawa's streams
broadcast between 31 and 35 hours of news each week. (See appendix II for
more on Radio Sawa's programming.)

Alhurra's Operations

The Alhurra satellite television station is designed to reach a broad
audience in the Middle East by providing news, current affairs, and
entertainment programming 24 hours a day, 7 days a week. Alhurra-Iraq is
designed to provide Iraqi citizens with daily newscasts and talk shows
that specifically address issues in Iraq. Both Alhurra networks broadcast
between 36 and 43 hours of news and news updates a week.11 Alhurra
broadcasts on the Arabsat and Nilesat satellites, which currently allow it
to cover the entire Middle East. Alhurra-Iraq also broadcasts through
these satellites and a combination of terrestrial transmitters made
available in Iraq.12 Alhurra also expects to start broadcasting to Europe
on August 1, 2006.13 (See appendix II for more information on Alhurra and
Alhurra-Iraq programming.)

Lack of Long-term, Comprehensive Planning Could Limit MBN's Ability to
Respond to Market Challenges

MBN faces a variety of challenges to broadcasting in the Middle East,
including operating in a competitive satellite television broadcast
market, operational and programming competitive disparities, and lack of
coverage for Radio Sawa in certain FM markets. MBN has conducted some
planning efforts and, by using market research and internal assessments of
its competitors, has undertaken or proposed some initiatives to address
many of these challenges, such as increasing its hours of news coverage
and current affairs programming for Alhurra and increasing the amount of
local content Radio Sawa broadcasts. However, MBN has not developed a
long-term strategic plan that fully addresses its operational and
competitive challenges.

Radio Sawa and Alhurra Face Significant Competitive Challenges

MBN faces several significant competitive challenges. These include the
competitive Middle East satellite television market; operational and
programming competitive disparities, such as Alhurra's lack of news
bureaus compared with its competitors; and lack of coverage in certain FM
radio markets.

MBN operates in the competitive Middle Eastern satellite television market
that has over 140 channels. Pan-Arab satellite television stations-in
particular, the news stations Al Jazeera and Al Arabiya--are currently the
primary competitors to Alhurra. According to the BBG's research firm
Intermedia, Al Jazeera is currently the top international broadcaster as a
source of news and information for audiences in many countries throughout
the Middle East. Moreover, Alhurra will face new competition from the
BBC's entry to the Middle Eastern satellite television market in 2007. BBC
officials have indicated that the new station's overall approach in the
region will be multimedia in focus, taking advantage of the BBC's more
than 60 years experience of broadcasting on the radio to the region as
well as its award-winning Arabic-language news Web site. For Radio Sawa,
the primary competitive challenge comes from existing local radio stations
in its broadcast range and the BBC World Service in Arabic, as well as
from the generally increasing competitiveness of the Middle East radio
market.

Alhurra also faces operational and programmatic competitive disparities,14
since both Al Jazeera and Al Arabiya are estimated to receive significant,
although unknown, levels of funding from their respective supporting
Qatari and Saudi financiers--allowing them to develop large networks of
correspondents and bureaus throughout the Middle East and other parts of
the globe. Al Jazeera, in particular, has bureaus in over 30 locations
across 6 continents, which enable it to respond to breaking news events on
a timely basis. Alhurra and Radio Sawa, by comparison, only have overseas
bureaus in Baghdad, Dubai, and Amman. In addition, the BBC has a large
network of correspondents and bureaus around the globe and, unlike
Alhurra, has a vast in-house library of desirable BBC-produced content,
including documentaries and current affairs programming, which can be
readily translated into Arabic. The BBC also has favorable licensing and
co-production arrangements with many companies.

One of Radio Sawa's other primary challenges is its lack of broadcast
coverage in certain countries in the Middle East region. For example,
Radio Sawa does not have any broadcasting coverage in Tunisia, Libya, and
Algeria. Moreover, it has faced difficulties expanding its transmission to
include FM coverage in some countries, such as Egypt, Saudi Arabia, Syria,
Yemen, and Oman. MBN is attempting to negotiate transmission agreements
with several of these countries, but still faces significant challenges to
finalizing agreements.

MBN Has Taken Some Steps to Address Its Competitive Challenges

Since its inception, MBN has conducted some planning exercises to address
its competitive challenges. These have included developing a "2006 Goals
and Strategies" overview document to guide operations for the current
fiscal year, establishing a 2006 annual performance plan as part of the
Office of Management and Budget's Program Assessment Rating Tool process,
and participating in the development of the BBG's new long-term strategic
plan covering fiscal years 2008-2012. In addition, MBN conducts ongoing
assessments of its competitors and uses various types of market research
to  gain information about its audience and media usage patterns in the
Middle East. It has used this information to make adjustments to its
programming within its current budget, and also to develop proposals for
obtaining additional funding for new efforts. BBG and MBN officials have
explained that they use audience surveys, audience monitoring panels,
focus groups, in-depth interviews, and Arab television and music station
monitoring to inform MBN's current efforts and planning, whenever
possible.

For example:

o As a result of market research performed in August 2004, MBN officials
identified television viewing patterns and made changes to Alhurra program
schedules, such as by offering programming appealing to women (e.g.,
current affairs and health and fitness programming) during the daytime.

o Through a review of the current competition in the market, MBN officials
decided that it was important to increase the number of debate programs
they broadcast on Alhurra. As a result, MBN created a series of "town hall
meetings" that allowed journalists and experts to discuss issues of
regional interest with interaction from a live audience.

o As a result of audience monitoring panels, MBN officials made changes to
Radio Sawa's program schedule by adding new features on subjects such as
social and cultural issues. MBN officials also learned of the importance
of efforts to localize those features, and made changes to tailor programs
to the interests of audiences of the various Radio Sawa streams.

MBN has also developed program enhancement proposals for Alhurra and Radio
Sawa as part of the BBG's language review and budget request processes.
Several proposals were included in the President's fiscal year 2007 budget
request. For example, the budget request includes a proposal to increase
Alhurra's newsroom hours to increase on-the-spot and breaking news
coverage.15 In addition, in fiscal year 2005, the administration requested
additional funds for providing satellite Alhurra broadcasts to Europe.
According to planning documents, many of the Alhurra proposals were
designed to reinforce one another with the goal of improving Alhurra's
credibility, as well as building audience size and increasing viewing time
of those who already tune in.16 MBN also developed one proposal for
enhancing Radio Sawa's operations that calls for increasing the amount of
localized news content offered on five regional streams,17 which officials
say would allow the station to more effectively compete with local
stations in its broadcast range. MBN's president said that, given the
increasing level of competitiveness in radio broadcasting in the Middle
East and expressed audience interest in news about their home country,
creating more localized content on Radio Sawa streams is important.

MBN Has Conducted Planning Exercises but Lacks a Long-term Strategic Plan

Strategic planning is a good management practice for all organizations.
Although MBN has conducted some planning exercises, it lacks a long-term
strategic plan and a strategic approach that outlines (1) a shared vision
of operations for Alhurra and Radio Sawa, (2) detailed implementation
strategies to achieve measurable outcomes for its goals, and (3) the
competitive challenges it faces and how it plans to address its key
challenges to broadcasting in the Middle East.

Strategic planning, including the development of a strategic plan, is a
good management practice for all organizations. Additionally, risk
assessment is an integral part of strategic planning. According to GAO
guidance,18 organizations should make management decisions in the context
of a strategic plan, with clearly articulated goals and objectives that
identify resource issues and internal and external threats, or challenges,
that could impede the organization from efficiently and effectively
accomplishing its objectives. Additionally, Office of Management and
Budget (OMB) guidance suggests that strategic plans contain, among other
things, a statement of the organization's long-term goals and objectives;
define approaches or strategies to achieve goals and objectives; and
identify the various resources needed and the key factors, risks, or
challenges that could significantly affect the achievement of the
strategic goals.

MBN has yet to create its own long-term strategic plan. MBN's president
stated that funding uncertainties and other more pressing organizational
needs--such as the development of financial and administrative policies
and procedures--have delayed the development of MBN's strategic plan and
related planning policies. In addition, he commented that MBN did not
emphasize planning in its early stages because it was focusing on making
its networks broadcast-ready. BBG officials said another reason for the
delays in planning is that the BBG and MBN are still learning about the
market, especially for Alhurra, and are taking a close look at the results
of audience surveys, focus groups, and in-depth interviews to determine
the best direction for these initiatives. MBN has stated that, to date, it
has primarily used the BBG strategic plan for organizational guidance.
Nevertheless, BBG officials said the BBG also has the expectation that all
broadcasting entities will develop their own strategic plans, particularly
to guide funding decisions.

In the absence of a strategic plan of its own, MBN lacks a comprehensive,
strategic approach that fully outlines (1) a shared vision of operations
for Alhurra and Radio Sawa, (2) detailed implementation strategies to
achieve measurable outcomes related to its goals, and (3) the competitive
challenges it faces and how it plans to address them.

First, MBN does not have a comprehensive strategic vision for the
integration of Radio Sawa and Alhurra operations in the organization. For
example, although MBN's most recent annual performance plan contains a
goal to "integrate news operations for more effective television and radio
news-gathering," none of MBN's current plans outline specific, shared
objectives for Radio Sawa and Alhurra. MBN officials told us that several
steps toward integration of Alhurra and Sawa have occurred to date, such
as sharing financial and administrative support staff. However, Radio Sawa
and overseas bureau staff we talked with said that cooperation between
Alhurra and Radio Sawa is limited, the identities of the stations are
separate, and the two stations work largely independently of one another.
Radio Sawa staff noted several areas for further increasing cooperation,
including more sharing of interviews, sound bites, field correspondents,
Web site stories, and copy editors. One staff member in the Baghdad bureau
said that Radio Sawa and Alhurra operations in Iraq are completely
independent, including separate offices, and only the financial activities
of both offices are supervised by the same person. In addition to gaining
more efficiency in operations, a vision for further integration of Radio
Sawa and Alhurra may help MBN more effectively identify opportunities to
address its challenges from increasing competition in the Middle East.

Second, MBN has not yet developed detailed implementation and resource
strategies needed for successful implementation of its goals. For example,
with regard to MBN's initiative to localize content on Radio Sawa, we were
not able to identify a plan directing what types of local news and
features will be considered on the various streams, to what degree
existing program schedules might be affected, and how required resources
might be divided among the various streams. Additionally, although MBN's
most recent annual performance plan states a goal of "expanding overseas
production of news coverage for radio and television," neither that
document nor any other plan MBN identified provides details or direction
for the overseas production of news for Alhurra in existing overseas
offices. MBN officials have stated that uncertainties in the future
commitment of resources to Alhurra have affected MBN's ability to, for
example, plan for and use existing overseas offices for Alhurra news.
Further, BBG officials have said MBN is still learning about the Middle
Eastern media market. However, given MBN's internal enhancement requests
to the BBG to increase the number of news bureaus in the region, among
others, it should clarify, for example, what implementation steps are
necessary to maximize the use of existing overseas offices.19

Third, MBN has not yet comprehensively outlined its challenges or
developed a strategic approach for how it plans to address its key
challenges to broadcasting in the Middle East. While MBN is planning to
expand its broadcast operations into Europe, it has not clearly identified
how its broadcasts will meet competitive challenges in the Middle East. As
an example, MBN has not indicated how it will address the implications of
the upcoming BBC Arabic-language television initiative. The BBC could gain
a significant audience that potentially would interfere with Alhurra's
market share, credibility, and use as a source of alternative
information.20

MBN Has Made Progress in Developing Internal Control, but Additional Steps
Could Improve Its Control Structure

MBN was initially limited in developing its internal control structure
because it was focused on quickly starting up its broadcasting operations.
In response to an external review of its financial operations by Grant
Thornton LLP in May 2004, MBN strengthened several of its controls, after
which it received an unqualified opinion on its Fiscal Year 2005 Single
Audit.21 However, MBN has not fully implemented several of the Grant
Thornton review's key recommendations related to its control
environment,22 including (1) establishing an internal control board to
formally develop its controls and coordinate audits, (2) preparing an
internal control plan, (3) conducting a risk assessment to address
potential risks to its operation, and (4) developing a training program
for its staff.

MBN Faced Initial Challenges in Developing Its Internal Control Structure

Internal control refers to the policies and procedures that help ensure
the proper management and application of an organization's assets. Clear,
strong controls can provide some assurance that management problems are
unlikely to occur or will be addressed if they do occur. MBN's internal
control is governed by several OMB circulars cited in its grant
agreement.23 The Comptroller General's Standards for Internal Control in
the Federal Government24  also provides guidance that is available to MBN.

MBN faced some initial challenges in establishing its internal control
structure. According to MBN documents and officials, MBN management
initially focused on establishing broadcasting operations rather than the
development of internal control policies and procedures, because the
organization had only several months to plan the launch of its 24-hour a
day Alhurra television network. As a result, MBN's internal control lagged
behind. The MBN chief financial officer (CFO) told us that problems
encountered by MBN in hiring and retaining staff added to the delay in
developing internal controls.

Due to concern over the slow development of MBN's internal control
structure, the BBG commissioned a review by Grant Thornton LLP accountants
and management consultants, which was completed in spring 2004, to assess
MBN's internal control and make recommendations for improvement. The
report by Grant Thornton LLP cited numerous findings, such as inadequate
financial policies and procedures, understaffing, and inadequate training,
that impeded MBN's ability to successfully mitigate risks.25 The report,
however, also noted that MBN's controls were improving.

MBN Has Made Progress in Developing Its System of Internal Control, but
Some Control Elements Could Be Improved

Grant Thornton's May 2004 report on MBN's system of internal control made
recommendations that covered staffing, MBN's financial system, training,
administrative policies and procedures, developing a decision support
structure, improving logs and records, and MBN's control environment. MBN
accepted the review's recommendations and agreed to implement them,
according to MBN officials, and the BBG concurred with these
recommendations. Our analysis shows that MBN subsequently responded to
many of the recommendations, including hiring additional financial
department staff, developing financial and administrative policies and
procedures, and completing an annual single audit (see table 1). For
example, although MBN provided us with copies of its Fiscal Year 2003 and
Fiscal Year 2004 Single Audits well past the deadlines for completing
those audits,26 MBN's Fiscal Year 2005 Single Audit was completed on time,
provided an unqualified opinion, and showed marked improvement over
previous years.27

Table 1: Actions taken by MBN to Address Grant Thornton's Internal Control
Recommendations

                                        

          Recommendation                   Status of implementation           
Hire additional staff for the Completed: New vice president for finance    
financial department          and administration hired in August 2004.     
                                 According to MBN, the organization now has   
                                 16 financial staff, compared to the 6 who    
                                 were working there when the assessment was   
                                 conducted                                    
Acquire suitable financial    Completed: MBN acquired a new enterprise     
information system            resource planning system (Deltek-Costpoint)  
                                 in October 2004 that has enhanced its        
                                 ability to manage its finance department.    
Enhance and expand MBN's      Completed: Developed policies and procedures 
financial and administrative  that lay out roles and responsibilities.     
policies and procedures       
Improve procurement and       Completed: MBN's CFO told us that MBN        
travel logs and records       improved its procurement logs and records.   
                                 In addition, MBN has hired a travel analyst  
                                 who keeps a monthly log of travel orders and 
                                 vouchers.                                    
Develop a system for          Completed: The finance department provides   
providing timely and focused  MBN high-level management with a detailed    
financial information to      financial package on a monthly basis..       
senior management             
Undertake and complete an     Completed: Completed  in late May 2006.      
annual audit as required by   MBN's Fiscal Year 2003 and Fiscal Year 2004  
OMB Circular No. A-133        Single Audits under Circular No. A-133 were  
                                 not released within established deadlines.   
                                 MBN's Fiscal Year 2005 Single Audit was      
                                 completed on time.                           
Establish an internal control Partially Addressed: MBN's internal control  
board                         board is not yet operational.                
Prepare an internal control   Not Completed: Not done as of May 2006.      
plan                          
Conduct an MBN-wide internal  Partially Addressed: Preliminary risk        
control risk assessment       assessment did not identify objectives,      
                                 identify risks, analyze the possible effects 
                                 of the risks, or propose a strategy to       
                                 mitigate them. This document merely contains 
                                 a list of completed actions addressing the   
                                 issues raised in the Grant Thornton LLP      
                                 report.                                      
Provide training on MBN's     Partially Addressed: MBN has provided some   
internal control processes    training on internal control, but has not    
                                 yet developed a regular training schedule    
Manage training by            and training is not managed by an internal   
establishing an internal      control board.                               
control board                 

Source: GAO analysis of information provided by Grant Thornton LLP and
MBN.

Some control elements could be improved in order to better implement best
management practices based on OMB circulars and GAO internal control
standards. For example, although MBN is establishing an internal control
board, the board has not met to establish protocols and outline its
responsibilities. The organization also has not developed an internal
control plan. Furthermore, MBN has not established a comprehensive process
to analyze risks the organization faces from internal and external
sources. Finally, MBN has provided some training on internal control but
has not yet developed a regular structured training program for its
staff.28

MBN's Internal Control Board Has Not Met to Establish Protocols to Develop
and Monitor Its Internal Control Structure

The Grant Thornton review recommended that MBN establish an internal
control board of key managers and officers to determine the internal
control risks facing MBN, work towards decreasing these risks, and oversee
MBN's efforts to employ strong controls. Moreover, according to GAO
guidance,29 organizations should have an audit committee or senior
management council-similar to an internal control board-that reviews the
internal audit work and coordinates closely with external auditors.

According to the MBN president, MBN is establishing an internal control
board consisting of three members, including, as recommended, the MBN
president, general counsel, and CFO. However, the board has not yet
formally met to establish protocols and outline responsibilities. In
addition, according to MBN's general counsel, MBN has not appointed a
member from the BBG, as was recommended, to serve on the board. MBN's
executive committee, which examines issues affecting MBN and reports back
to the BBG, has provided some support on management and administrative
issues, such as approving the construction and expansion of MBN's new
facility and providing guidance on hiring high-level staff.30 However, the
committee has not fulfilled the role of an internal control board as
previously described. Instead, MBN's CFO has largely taken on the sole
responsibility of establishing and overseeing MBN's controls, reviewing
audits, and coordinating with external auditors. The MBN president told us
that they have not convened an internal control board because the
organization is too new and, therefore, is focused on developing policies
and procedures rather than mechanisms to review them. MBN is planning to
develop an internal audit function, implemented by an external firm, to
provide assurance to MBN management that the organization is operating
appropriately.

MBN Has Not Completed an Internal Control Plan

According to the Grant Thornton review, MBN should develop an internal
control plan to ensure that effective controls are established and
monitored regularly. Such a plan should identify the roles and
responsibilities of all individuals whose work affects internal control,
lay out specific control areas, cover risk assessment and mitigation
planning, and include monitoring and remediation procedures. MBN officials
told us in January 2006 that they were in the process of developing such a
plan and have developed internal control guidelines, but as of the end of
May 2006, they had not provided us with a finalized plan.

MBN Has Not Established a Comprehensive Process to Analyze Risk

The Grant Thornton review called on MBN to conduct a broad risk
assessment, led by its internal control board, to evaluate and mitigate
potential obstacles to efficiently and effectively achieving its
operational objectives. According to Grant Thornton LLP, failure to
conduct an MBN-wide risk assessment could result in the loss of resources
and could decrease confidence of the grantor and of Congress, which could
ultimately compromise MBN's achievement of its mission. According to GAO
guidance, risks should be identified during both short- and long-term
forecasting and as part of strategic planning. Moreover, after conducting
a risk assessment, organizations need to develop internal control
activities to manage or mitigate the risks that have been identified. For
example, Radio Free Asia identified avian influenza and signal jamming
from China as two threats to their operations. As part of their risk
assessment, they considered how to address and overcome these issues, such
as by broadcasting from alternate locations.

In February 2005, MBN prepared an initial risk assessment that identified
a list of actions taken to address the issues raised in the Grant Thornton
LLP report. However, the document did not identify the organization's
objectives or the risks it faces, nor did it analyze the possible effects
of the risks or propose a strategy to mitigate them, as recommended by GAO
guidance. MBN officials told us that they assess risk on an ongoing,
biweekly basis. However, in taking a short-term approach to analyzing
risk, MBN lacks a comprehensive basis from which to establish a strong
internal control structure. Some risks identified by MBN include threats
to the security of its staff and bureaus in the field, particularly in
Iraq, and the risk of a terrorist attack on its facilities in the United
States. There are some risks that MBN has not identified or addressed. For
example, PriceWaterhouseCoopers, MBN's external auditor, noted that MBN
has not adequately addressed its risks related to information security.
Doing so would reduce the risk of security incidents and unauthorized
system activity, according to the auditor. PriceWaterhouseCoopers also
found that MBN's lack of a business continuity plan or an adequate
disaster recovery plan could result in slower recovery in the case of such
an event, as well as significant loss of revenue, inability to meet
customer needs and third party obligations, and potential noncompliance
with legal requirements. The internal audit function planned by MBN may at
some point take on the function of assessing risk, but this body is not
yet operational.

MBN Has Not Developed a Comprehensive Training Program on Internal
Controls

MBN has provided some training on internal controls but has not yet
developed a regular structured training program for its staff of about
240, as recommended by the Grant Thornton LLP review and by GAO leading
practices.31 MBN's CFO and controller attended a seminar on grants
management in October 2004 and subsequently shared the information with
the 16 in-house financial staff. MBN also provided internal control
compliance training to its managers in December 2004, and the organization
regularly provides training to staff at its business manager meetings.
However, other U.S. broadcasting entities, such as Radio Free Europe/Radio
Liberty (RFE/RL) and Radio Free Asia (RFA), have more organized, ongoing
training programs on internal control. The MBN CFO concurred that there is
a great need for internal training. According to him, the underdeveloped
training situation is due to a lack of resources, including a lack of
funds specifically designated for training and limited time to plan or
implement training. This lack of structured, recurrent internal control
training can cause problems if staff are unfamiliar with an organization's
business processes and controls, and can lead to the inefficient or
improper use of resources.

MBN Has Developed Editorial Procedures to Support Its Journalistic
Standards, but Could Improve Monitoring and Some Quality Control Measures

MBN has established journalistic standards, as well as procedures to help
ensure that the organization's broadcasts comply with these standards.
However, it has not fully developed some quality control measures, such as
the use of listener and viewer feedback. Additionally, the BBG has not
held regular comprehensive program reviews for MBN, thereby making it
difficult for MBN to assure its audience, Congress, the administration,
and the BBG that its controls are working and that it is broadcasting
quality programming.

MBN Has Developed Journalistic Standards and Implemented a Wide Variety of
Pre- and Postbroadcast Editorial Procedures

The International Broadcasting Act of 199432 calls for U.S. international
broadcasting to be conducted in accordance with the highest professional
standards of broadcast journalism, including the production of news that
is consistently reliable, authoritative, accurate, and objective. The act
also calls for U.S. international broadcasting to present a balanced and
comprehensive projection of U.S. thoughts and institutions, as well as
clear and effective presentation of U.S. government policies and
responsible discussion of those policies. MBN's mission statement, which
partly draws upon the principles and standards contained in the U.S.
International Broadcasting Act of 1994, calls for MBN to broadcast
factual, timely, and relevant news and information that promotes freedom
and democracy.

MBN has developed journalistic standards, including a code of ethics, as
part of its effort to ensure that its news broadcasts are consistently
accurate, authoritative, objective, balanced, and comprehensive. MBN's
general counsel said that the code was also established to ensure that MBN
fully complies with its mission and the U.S. International Broadcasting
Act of 1994. MBN's journalistic standards were drafted by MBN management
using input from professional journalistic organizations and another
grantee. According to BBG officials, MBN's standards appear to be as good
as those of other U.S. international broadcasters. In our analysis, we
found that the standards cover areas similar to the codes of other
broadcasters--such as RFE/RL, RFA, Voice of America (VOA), and National
Public Radio--focusing on accuracy, impartiality, establishing context,
clearly distinguishing analysis from reporting, using a tone of moderation
and respect, avoiding advocacy, and promoting ethical conduct. The
standards also include guidelines for conducting interviews, as well as
editing and production requirements. For example, according to MBN
officials, MBN strives to present opposing views accurately and achieve a
balance among the guests on its current affairs shows. According to MBN
officials, when broadcasting about the war in Iraq, they try to ensure
that the program incorporates both pro-war and antiwar views.

To help ensure that staff comply with MBN's journalistic standards, Radio
Sawa and Alhurra have established a number of pre- and postbroadcast
procedures, which are roughly similar to those of other U.S. international
broadcasting entities. Examples of MBN editorial procedures include daily
editorial meetings, the use of two or more sources to support a news item,
checks by editors and producers to determine whether news stories are
properly written and accurate, a headquarters-level review of all
materials produced in MBN's overseas offices before broadcast,33 and
postbroadcast discussions. In addition, we observed that MBN employs an
experienced journalist from the Arab world to review all of Alhurra's and
Alhurra-Iraq's weekday newscasts for technical and stylistic errors, a
control not implemented by other U.S. broadcasting entities. The
journalist watches the newscasts just before they are aired, then provides
MBN management with an evaluation of the newscast's quality. MBN provided
us with records of these evaluations, which assess whether the newscasts
are presentable, balanced, and free of technical errors. In some cases,
technical mistakes can be caught before the piece is aired. However, while
MBN management follows up on critiques of individual journalists, they do
not systematically review and assess the journalist's evaluations.

MBN officials told us that the organization places a high value on
journalistic controls, particularly due to the volatility of certain areas
in the Middle East and the impact news reports can have. In addition,
MBN's controls can serve as an assurance to its audiences and others that
they are broadcasting quality programming. Since Radio Sawa and Alhurra
were established, MBN has not had to retract a single story or apologize
for any error, according to MBN officials.

MBN Could More Fully Develop Some Quality Control Measures and Lacks
Regular Editorial Training

There are several areas in which MBN could more fully develop some quality
control measures for its programming. These areas include using listener
and viewer feedback to improve program quality, making better use of
weekly compilations, and ensuring its style guide is distributed to all
staff. Unlike other U.S. international broadcasters, MBN typically only
partially utilizes the following measures:

o Although MBN collects feedback from its listeners and viewers, it does
not rely extensively on this feedback as a program quality control.

o Although MBN produces weekly compilations that are distributed to
interested parties summarizing what was broadcast on Radio Sawa and
Alhurra that week, it does not use these compilations to do any formal,
long-term analysis of errors and programming.

o MBN has developed a style guide to provide critical guidance on the use
of sensitive terms and to help staff avoid grammatical mistakes. However,
Radio Sawa staff did not receive the guide until early 2006, and MBN has
not distributed it to all of its overseas offices, inhibiting its use by
some staff.

In addition, MBN has not provided regular training to its journalists and
producers. MBN told us that it does not provide regular training to help
its editorial staff maintain and increase their professional competence.
MBN's level of training for its editorial staff is also not on a par with
the training offered by other grantees. For example, RFE/RL and RFA both
have extensive training programs for their employees at their headquarters
and in their bureaus in different countries, according to RFE/RL and RFA
officials. While MBN provides some initial technical training to its
journalists, an informal mentoring program, and sporadic training
overseas, according to MBN officials, the organization does not have an
ongoing training program to educate journalists throughout the
organization about editorial and ethical issues they might encounter on
the job. According to the MBN CFO, the organization does not have a
well-established training program because the network is relatively new
and lacks training resources. MBN officials have also noted that their
most important controls are the editors themselves, and that MBN tries to
hire experienced staff. However, regardless of experience, staff can and
do make mistakes, and MBN's lack of regular training increases the risk
that correspondents and editors will make mistakes.

MBN Lacks Comprehensive, Regular Program Reviews to Determine Compliance
with Mission and Journalistic Standards

The BBG's main mechanism to determine whether its broadcasting services
comply with its mission and journalistic standards is a regular program
review, which is designed to improve programming and ensure quality
control. However, only one review has been conducted for Radio Sawa, and
none have been conducted for Alhurra. The Radio Sawa review was more
limited in scope than program reviews conducted by other entities. In
addition, Radio Sawa's program quality score is inconsistent with other
BBG entities, and without a program review to develop a program quality
score for Alhurra, the BBG will not be able to measure the contribution of
these efforts to the goals of the organization, or be able to ensure that
the quality of Alhurra's broadcasts conforms to applicable standards.
Finally, many MBN staff were not extensively involved in the Radio Sawa
review.

Annual Program Reviews Have Not Been Conducted for MBN's Services

According to written guidance from the International Broadcasting Bureau,
which coordinates and supports all VOA program reviews, program review is
an annual process by which an institution judges itself and solicits the
judgment of others to make improvements and fulfill its mission with
regard to U.S. national interests. The process enables the broadcasting
entity to better connect its mission to the market where it is
broadcasting and assess whether its editorial procedures are functioning
effectively, while also allowing the BBG to fulfill its requirements from
OMB that it conduct regular program evaluations to capture a program's
impact over time. In addition, the Senate Committee on Foreign Relations
Report on the Fiscal Year 2003 Foreign Relations Authorization Act called
for significant resources to be dedicated to postbroadcast analysis of
Radio Sawa programming to ensure that broadcasts are consistent with U.S.
interests and values and with the standards in the U.S. International
Broadcasting Act. Program review typically includes a study of the target
area's media environment, analyses by internal and external reviewers,
background quantitative research, reports on marketing and transmission,
and target area profiles compiled by the broadcaster itself. Reviewers
rate programs

based on criteria34 for content--such as accuracy, timeliness,
objectivity, relevance, and quality of analysis and interviews--and for
presentation, such as pace and liveliness, presentation style, sound
quality, and host interaction. These inputs are then discussed at a
meeting that includes the program review coordinators and the management
and staff of the entity being reviewed. Following the main program review
meeting, key participants develop an action plan, and 3 months later the
group meets again to determine to what extent the action plan has been
carried out.

Although the BBG calls for program reviews to be conducted annually, MBN
has not complied with this guidance. Neither the BBG nor MBN has a regular
mechanism in place to systematically review MBN programs. In December
2004, the BBG convened a program review meeting for Radio Sawa, which had
begun operating in March 2002. However, there has been no Radio Sawa
review since then, while Alhurra, which has been operating for more than 2
years, has had no program review at all. The BBG is planning to initiate a
program review of Alhurra by the end of this year, but has not set a firm
date.

Radio Sawa's Program Review Was Limited by Its Emphasis on Audience Input

BBG officials have stated that program quality should be sampled and
assessed by both internal and external evaluators.35 This is designed to
produce a balanced and robust review.36 In 2000, in response to our report
that found a lack of consistency in how program quality scores were
developed, the BBG stated that it intended to harmonize and standardize

program reviews across broadcasting entities.37 BBG guidance now calls for
all U.S. international broadcasting entities to be evaluated using the
same standards, definitions, and scoring methods.

However, when conducting the Radio Sawa program review, the BBG relied
only on audience monitoring panels to assess program quality and did not
utilize internal analysts or external control listeners, as is common
practice among other U.S. international broadcasters. Using only audience
monitoring panels gives the audience more weight in the review results
and, in turn, more potential to influence the strategic direction of the
organization. In addition, since the audience tends to be unfamiliar with
a broadcasting service's journalistic standards and editorial procedures,
having input only from monitoring panels makes it more difficult for a
service to provide reasonable assurance that its editorial procedures are
working and that it is broadcasting quality programming. Also, external
control listeners are specifically tasked with examining the programming
in light of the service's mission, something audience monitoring panels
are not asked to do. As a result, Radio Sawa's program review strongly
emphasized the audience's perspective and therefore provided a less
thorough evaluation of Radio Sawa's mission and standards. (For more
information on Radio Sawa's program review, see appendix III.)

Radio Sawa's Program Quality Score Is Inconsistent with Other BBG Entities

Furthermore, MBN's program score for Radio Sawa is not comparable with
other BBG broadcaster scores for program quality--the percentage of a
station's language services judged on both content and presentation
criteria as being of good-or-better quality. The BBG says that to measure
Radio Sawa's program quality, it has developed standardized criteria
applicable to different media and methods of delivery, while minimizing
subjective judgments on content and presentation. Although the criteria
used to measure Radio Sawa's program quality are similar to those used by
other broadcasting entities, the BBG did not use as many inputs when
calculating the program quality scores for Radio Sawa, leading to a less
robust result (see table 2).

Table 2: Inputs to Program Quality Scores for BBG Broadcasting Entities

Broadcaster      Program review input  Percentage of total program quality 
                                                                        score 
MBN (Radio Sawa) Monitoring panels                                     100 
RFE/RL           Internal analysis                                      45 
                    Monitoring panels                                      35 
                    External experts                                       20 
RFA              Internal analysis                                      45 
                    Monitoring panels                                      35 
                    External experts                                       20 
VOA              Internal analysis                                      45 
                    Monitoring panels                                      35 
                    External experts                                       20 

Sources: BBG, International Broadcasting Bureau, RFE/RL, RFA.

Without a consistent process for broadcaster program reviews, the BBG is
limited in its ability to assess and compare broadcaster performance. In
addition, without a program review to develop a program quality score for
Alhurra, the BBG will not be able to measure the contribution of these
efforts to the goals of the organization, or be able to ensure that the
quality of Alhurra's broadcasts conforms to applicable standards.
Currently, the BBG is considering how it will conduct the future program
reviews for Radio Sawa, but officials could not yet provide specifics
about the approach BBG will use.

MBN Staff Had Limited Awareness of the Radio Sawa Program Review and
Follow-up

MBN staff in the United States and overseas do not appear to have much
knowledge of the Radio Sawa review or its follow-up. Program review can be
a learning experience for staff, who are usually encouraged to sit in on
their language service's program review meeting, and the process can also
bring people together who normally do not interact, which can help
generate ideas and improvements. However, according to MBN management,
most Radio Sawa staff did not attend the Radio Sawa program review. In
addition, there was also not much awareness about the program review in
MBN's overseas offices.

While Radio Sawa staff lacked awareness about their review, some staff who
had worked at VOA in the past spoke positively of the program review
process in general. Other broadcasters routinely involve staff in their
program reviews. For example, RFA requires all staff from the service that
is being reviewed to be present at the program review meeting. According
to an RFA official, program review is one of the few times that all of the
key players for a service are in one place, and it therefore presents a
good opportunity for communication. In addition, a BBC official noted that
program review can be a good way to expose staff to an organization's
values. Increasing staff involvement in program review could therefore
increase chances for communication throughout all levels of the
organization, as well as provide a forum for discussing potential
programming improvements.

BBG Has Developed Several Performance Indicators, Although Weaknesses in
Audience Surveys Call into Question Whether MBN Audience Size and
Credibility Targets Have Been Met

The BBG has established several standard performance indicators and
targets for MBN programs, including measures of audience size and
credibility; however, it has not implemented some performance indicators
fully, including a program quality measure. Additionally, we were unable
to determine the accuracy of MBN's audience size and program credibility
estimates due to weaknesses in MBN's methodology and documentation.
Therefore, it is not clear whether the Radio Sawa and Alhurra performance
targets have been met.

MBN Performance Indicators and Targets Have Been Established, but Some Are
Not Fully Developed

The Government Performance and Results Act of 1993 (GPRA) requires that
all government agencies establish performance indicators, or measures,
that provide a meaningful reading of how well the organization is
progressing towards its goals. The BBG has developed a standard set of
performance indicators for its broadcasting entities, which it says are a
best effort to measure its level of effectiveness now and where its
performance is targeted to be in the future. The BBG established common
indicators for its entities to allow it to better assess overall progress
for the organization. Although the BBG has made progress in establishing
these standard performance indicators, as well as targets for MBN's
programs, it

has not formally established or implemented all of them for Radio Sawa and
Alhurra.38

According to BBG, the three most important standard indicators for its
entities, referred to as primary performance indicators, are (1) audience
size, or the overall weekly audience of a station; (2) credibility, which
represents the percentage of viewers in a target area that consider the
station's news programs somewhat or very reliable; and (3) program
quality, or the percentage of a station's programs judged on standard
criteria as being of good-or-better quality. These three indicators are
tied to the current BBG mission and strategic plan for U.S. international
broadcasting.39 In addition to its standard primary performance
indicators, the BBG has a number of "secondary" measures that provide
management with additional information for gauging cost- effectiveness,
marketing and promotion activities, and transmission efforts, including
the number of transmitters and affiliates, cost per listener, signal
strength (radio only), and awareness.

The BBG has established and implemented two primary indicators-audience
size and credibility--for both Radio Sawa and Alhurra.40 The BBG has also
established performance targets for Radio Sawa and Alhurra for these two
indicators. For example, MBN's reported fiscal year 2005 audience size
performance target for Radio Sawa was 18 million listeners and for Alhurra
was 12.8 million viewers.41 However, the BBG has not yet established
Alhurra's program quality indicator, or consistently implemented this
measure for Radio Sawa. Without a measure of program quality for Alhurra
and Radio Sawa, the BBG will not be able to consistently assess MBN's
performance against that of other grantees, or fully assess MBN's
contribution to the overall goals of the BBG organization. The BBG has
established all of its standard secondary performance indicators for MBN's
services except for audience awareness.42 See table 3 for a list of the
performance indicators implemented for Alhurra and Radio Sawa.

Table 3: BBG's Standard Performance Indicators and MBN's Status

                                        

 Indicator      BBG         Definition       Source of     Current     Current   
    type    performance                    data used to    Alhurra      Sawa     
             indicator                       calculate   performance performance 
                name                          measure     indicator   indicator  
 Primary    Audience     Total number of   This figure   Yes         Yes         
            size (also   all adults        is calculated             
 indicators called       listening or      by the office             
            overall      viewing a         of research               
            weekly       service's         and is an                 
            audience)    programming at    estimate                  
                         least once a week derived from              
                         in target areas   audience                  
                                           surveys and               
                                           estimates of              
                                           national                  
                                           population.               
            Credibility  Percentage of     This figure   Yes         Yes         
                         total estimated   is calculated             
                         weekly            by the office             
                         viewers/listeners of research               
                         in target areas   and is an                 
                         that determined   estimate                  
                         the reliability   derived from              
                         of news and       the results               
                         information of    of audience               
                         the station to be surveys and               
                         somewhat or very  estimates of              
                         reliable          overall                   
                                           weekly                    
                                           audience.                 
            Program      Percentage of a   This figure   No          Yes         
            quality      station's         is calculated             
                         language services by the office             
                         whose programming of strategic              
                         is assessed as    planning and              
                         being of          performance               
                         good-or-better    management.               
                         quality           For Radio                 
                                           Sawa, this                
                                           figure is                 
                                           determined by             
                                           scoring from              
                                           a monitoring              
                                           panel of                  
                                           regular                   
                                           listeners                 
                                           using                     
                                           predefined                
                                           criteria for              
                                           content and               
                                           presentation.             
 Secondary  Awareness    Percentage of     This figure   No          No          
 indicators              adults in the     is calculated             
                         target area that  by the office             
                         have prompted and of research               
                         unprompted        and is an                 
                         awareness of the  estimate                  
                         station           derived from              
                                           the results               
                                           of audience               
                                           surveys and               
                                           estimates of              
                                           overall                   
                                           weekly                    
                                           audience.                 
            Affiliations Total number of   This figure   Yes         Yes         
            and          affiliates that   is calculated             
            transmitters regularly         by the office             
                         rebroadcast       of marketing              
                         identified        and program               
                         programs on       placement                 
                         competitive media using                     
                         and number of     affiliates                
                         owned and         data and the              
                         operated local    office of                 
                         transmitters      engineering               
                                           using                     
                                           transmitter               
                                           data                      
            Signal       Quality of radio  This figure   N/A         Yes         
            strength     signal monitored  is calculated             
                         and rated on a    by the office             
                         scale of nil to   of                        
                         excellent         engineering               
                                           using data                
                                           sampled                   
                                           periodically              
                                           from overseas             
                                           monitoring                
                                           stations.                 
            Cost per     Budget divided by This figure   Yes         Yes         
            listener     weekly audience   is calculated             
                                           by BBG's                  
                                           office of                 
                                           strategic                 
                                           planning and              
                                           performance               
                                           management                
                                           using budget              
                                           data and                  
                                           audience size             
                                           figures.                  

Source: GAO and BBG.

BBG Should Increase Steps to Ensure Reliability and Transparency of Its
Performance Estimates

We and others have noted that agencies' performance indicators and data
should provide a reliable means to assess progress. However, we were
unable to determine the accuracy of MBN's reported audience size and
program credibility estimates due to weaknesses in MBN's methodology and
documentation. Therefore, it is not clear whether the Radio Sawa and
Alhurra performance targets have been met. While BBG has taken several
important steps to ensure the validity and reliability of its performance
measurement approach, it has primarily used a methodology that cannot be
reliably projected to the broader population. Although it is difficult to
conduct probability sampling in many locations in the Middle East, the BBG
has not taken steps to explain and increase the reliability of MBN's
performance information, such as by maintaining more detailed
documentation to support its estimates, reporting significant data
limitations, limiting the scope of its projections to areas actually
covered by its surveys, and developing BBG policies and procedures for
verifying performance data.

Measurement and Research Methods Should Allow for Confidence in
Reliability of Performance Information

We have previously reported that performance indicators should provide a
reliable way to assess progress.43 In particular, agencies should
implement quality control procedures to mitigate errors that can occur at
various points in the collection, maintenance, processing, and reporting
of performance data and can impact its reliability. In addition, agencies
should select sampling methods that ensure representative samples, where
possible. For example, probability surveys are designed to ensure each
person in the population has a measurable chance of being selected for the
survey, enabling the results to be reliably projected to the larger
population with known levels of precision. Additionally, agency
performance reporting should provide sources, disclose limitations, and
discuss the implications of them. Explaining the limitations of
performance information--as well as actions taken to compensate for
low-quality data-can provide context for understanding and assessing
agencies' performance and the costs and challenges that agencies face in
gathering, processing, and analyzing needed data.44

The U.S. International Broadcasting Act of 1994 requires the BBG's use of
audience research to guide its decisions about its language services. For
the past 5 years, the BBG has contracted with Intermedia to serve as the
primary research contractor for the BBG and its broadcasting entities,
including MBN. Intermedia works with subcontractors, partners, or both to
gather audience research survey data from citizens in various locations
overseas. This survey information is used by the BBG to develop estimates
for MBN and other entities' audience size and credibility performance
indictors. For example, for fiscal year 2005, the BBG estimated that Radio
Sawa and Alhurra had each achieved an audience size of about 21.6 million
people. Table 4 shows the breakdown of individual survey data reported by
the BBG.

Table 4: BBG's Reported Audience Size and Credibility Estimates for Radio
Sawa and Alhurra, Fiscal Year 2005

Country          Year      Sawa  Alhurra estimated        Sawa     Alhurra 
surveyed     surveyed estimated      audience size credibility credibility 
                          audience                           rate        rate 
                              size                                
Algeria          2004       N/A          2,466,888         N/A         N/A 
Bahrain          2005   127,008            132,814          78          86 
Djibouti         2003   151,620                N/A         N/A         N/A 
Egypt            2005 4,791,552          2,019,968          82          92 
Iraq             2005 8,336,320          6,860,435          63          73 
Jordan           2005   965,216            729,120          75          68 
Kuwait           2005   299,739            249,612          82          72 
Lebanon          2005    68,400            738,720          68          79 
Morocco          2005 4,072,455          2,679,367          64          70 
Qatar            2004   324,786                N/A          79         N/A 
Saudi Arabia     2005   734,928          2,204,784          72          73 
Syria            2004 1,468,800          2,661,120          76          60 
Tunisia          2005       N/A            676,800         N/A          75 
UAE              2005   265,842            138,510         79a          82 
Regionwide                 21.6       21.6 million          69          73 
                          milliond                                
fiscal year                                                    
2005                                                           
estimateb,c                                                    

Source: BBG.

aThe BBG originally reported this figure as 55 percent, but later
determined that the correct figure was 79 percent.

bTo develop the regional estimate for audience size, listening/viewing
rates are gathered from the national surveys and are, in most cases,
multiplied by each country's respective national population estimate to
obtain a total audience size estimate for each country. For some
countries--such as Bahrain, Kuwait, Qatar, UAE and Saudi Arabia--the
results are projected to nationals and Arab expatriate populations only.
These estimates are developed for all countries surveyed and then added to
develop a regional audience figure, which is the service's overall weekly
audience estimate.

cTo develop the regional estimate for credibility, percentage credibility
scores are gathered from national surveys and multiplied by that country's
audience size estimate to obtain a total number of listeners or viewers
for a given country that view the station's news and information as very
or somewhat reliable. These estimates are developed for all countries
surveyed and then used to create a weighted average of credibility.

dThe BBG reported in its fiscal year 2007 budget request that its audience
size for Alhurra was 21.5 million.

BBG Has Not Taken Sufficient Steps to Ensure Reliability and Transparency
of Its Performance Estimates for MBN

Although the BBG has taken several important steps to enhance the validity
and reliability of its audience survey designs, several factors call into
question the accuracy of the data used for BBG's audience size and
credibility performance indicators for Radio Sawa and Alhurra. First, we
observed that, in 12 out of 14 cases, the BBG used nonprobability surveys,
which cannot be reliably projected to the broader population, to develop
its regional estimates for audience size and credibility. While it is
difficult to conduct probability surveys in hostile environments, such as
those in Iraq and Saudi Arabia, the BBG did not take certain steps that
could have increased the accuracy of its estimates and explained their
limitations, thereby increasing confidence in the data. Therefore, we are
unable to determine whether MBN actually met its performance targets for
fiscal year 2005.

BBG has taken several important steps to enhance the validity and
reliability of its audience survey designs. For example, the BBG's
questionnaires are reviewed by multiple parties, and its contractors
extensively pretest the questionnaires in the field, conduct pilot
studies, and use throwaway surveys45 for training new subcontractors. In
addition, the BBG's contractors exercise quality control when collecting
data and receiving it from the field, including by conducting preliminary
electronic testing of the data, among other things.

However, in 12 of 14 cases, we found the country-level estimates used for
generating Radio Sawa and Alhurra's fiscal year 2005 performance
indicators of audience size and credibility were not based on probability
survey46 results. Many of  the surveys conducted used judgment sampling, a
form of nonprobability sampling, instead.47 BBG officials told us that its
use of nonprobability surveys for certain countries is due to either the
cultural, political, or security situation in those countries, which
limits the selection of individuals or the geographical areas that can be
surveyed.48 In addition, the International Broadcasting Bureau director of
research stated that in many developing countries, existing map and
population data is not adequate to support pure probability-based
sampling. The Conference of International Broadcasters' Audience Research
Services, called CIBAR, whose standards are specified as a source of
guidance for BBG research contractors, requires that audience measurement
use samples based on the principles of random probability and that other
sampling methods should only be used in cases where, for reasons of
practicality or cost, proper random samples cannot be used. (See appendix
IV for more on the CIBAR standards.)

We recognize that many agencies face challenges in collecting credible
performance data and that, due to security risks and political
considerations in many Middle Eastern countries, it is not always possible
to expect BBG to use random samples. However, the BBG did not take certain
steps that could have explained and increased the reliability of its
estimates, such as fully documenting its research methods, measuring the
level of uncertainty surrounding its estimates, disclosing significant
limitations, limiting the scope of its projections to areas actually
covered by its surveys, and developing and implementing procedures for
verifying data.

First, the BBG and its research contractors were unable to provide us with
certain documentation commonly required by international broadcasting
research standards. CIBAR requires that, in all measurement research, the
sampling methods used and other technical aspects of the survey be both
fully and accurately described in the project documentation and open to
independent scrutiny. We asked the BBG and its contractors to provide us
with detailed documentation-including clear information on sampling plans
and related assumptions, response rates, and adjustments applied to the
data to reflect the effects of the survey design-for all 14 of its Middle
Eastern country surveys used to develop its fiscal year 2005 performance
indicator estimates. For two cases, the BBG was unable to provide us with
any survey documentation,49 and for all but one case, the BBG and its
contractors were unable to provide us all the detailed information we

requested.50 BBG officials acknowledged the lack of complete documentation
in contractor technical reports, and said it was due in part to their
failure to follow up with the contractors to obtain the details, aswell as
to the contractors' general practice of not generating such detailed
documentation.

Second, the BBG has not sufficiently measured the level of uncertainty
surrounding MBN's performance estimates. CIBAR requires that in all
measurement research, technical aspects of the survey, including margins
of error and confidence levels where appropriate, be both fully and
accurately described in the project documentation. The BBG has not been
able to measure sampling errors51 for its surveys, in part because it has
not required contractors to document the information that is needed to
calculate the sampling errors accurately. Moreover, officials said that it
is not customary for their contractors to maintain this information.
Therefore, the BBG only has a rough idea of what the margins of error52
might be for its surveys, further limiting confidence in the reliability
of its current performance information. One research official told us that
he believed that the overall margins of error for Radio Sawa and Alhurra's
audience size and credibility estimates are large, but said that currently
the agency cannot accurately calculate them.53

Third, the BBG lacks transparency in reporting data sources and
significant limitations affecting MBN's audience size and credibility
performance information. In reporting performance data, agencies should
provide data sources, disclose limitations, and discuss the implications
of them. CIBAR standards also recommend that proper care be exercised when
reporting estimates, to ensure that the type of audience covered by the
estimate is clearly stated and that, at all stages in the calculation and
extrapolation process, sources, assumptions, and methods be fully
documented and available for independent scrutiny. However, the BBG has
not sufficiently explained the specific methods used for generating
estimates for its performance indicators, such as the number and names of
the countries surveyed, methods of sampling used, sources of the
population data, and basic procedures used to create the estimates.
Moreover, the BBG has reported only two limitations for MBN performance
indicators to date: (1) that credibility ratings are highly dependent on
volatile political factors; and (2) that, depending on political, social,
and media conditions, measurement of audience size may either be easily
attained or impossible. However, the BBG has not explained many
significant limitations, and their resulting implications, on the data
reliability of the performance information for MBN. The largest
identifiable limitations not reported are that many of the BBG surveys are
not based on probability sampling, cover only part of the country, have
very low response rates, or have high substitution rates; therefore, those
results cannot be reliably projected to be representative of the larger
population.54 In the case of the survey in Morocco, we calculated that the
survey only covered 35 percent of the general population and had a 48
percent substitution rate, but the results were projected to represent a
broader population. In addition, we calculated low response rates for a
number of MBN's surveys; in the case of the survey of Egypt, the response
rate was about 19 percent. BBG research staff explained that their
stakeholders to date, including the BBG, have not required such a level of
detail in reporting, and specifically have not required margins of error.
However, a discussion on data limitations in performance reporting can
help decision makers determine their level of confidence in the agency's
ability to report on its performance goals and indicators and identify
actions needed to improve its ability to measure performance.

Fourth, we found the BBG has not taken sufficient steps to avoid
projections to areas outside the population surveyed. For example, the
elimination of projections to the rural population of Morocco, when only
urban areas were surveyed, or to those governorates of Jordan not
contained in the survey, would have resulted in estimates of audience size
and credibility with fewer limitations for those countries. In addition,
BBG project documentation does not clearly describe what steps have been
taken to restrict the scope of MBN's surveys to provinces or areas that
have sufficient map or population data. Probability sampling projected to
those areas only would result in more reliable estimates of audience size
and credibility.

Fifth, we found the lack of verification procedures inhibits assessments
of BBG's data quality. Data reliability is increased by the use of
verification and validation procedures, such as checking performance data
for significant errors by formal evaluation or audit. However, BBG has not
fully implemented such procedures or formally documented policies and
procedures governing its research. BBG officials said they have
implemented some forms of verification, such as a research director
review, at various stages of performance data analysis. However, it is not
clear that the BBG always thoroughly verifies performance indicator
estimates and calculations used for reporting. For example, we identified
some errors in internal calculation spreadsheets for performance
estimates, in official external reporting, and in an informal presentation
on MBN performance. BBG officials have acknowledged that they need to
develop policies and procedures and implement more rigorous verification
of performance data. They said that, as a result of our review, they have
taken some steps to expand their verification procedures and will document
those and other research procedures in the BBG's research contract and
manual of operations.

Conclusions

MBN was established to broadcast accurate and relevant news and
information to the Middle East in order to advance freedom, democracy, and
long-term U.S. interests in the region. MBN's programs are challenged by
existing television competitors, such as Al Jazeera and Al Arabiya, and
planned initiatives such as the BBC's planned Arabic-language television
network; by numerous local radio stations across the region; and by
limited opportunities for increasing coverage of radio transmission. It
has attempted to address these challenges through some planning efforts,
such as by developing proposals to increase its news time for Alhurra and
expand its number of news bureaus in the Middle East. However, MBN has not
developed a strategic plan or taken a detailed strategic approach to
addressing certain issues, including identifying opportunities for
additional gains that could be made from further integrating Radio Sawa
and Alhurra or fully utilizing MBN's overseas offices. Developing a
strategic plan that establishes specific objectives, provides an overall
shared vision or framework for decision-making, and comprehensively
addresses competitive challenges could enable MBN to identify efficiencies
or opportunities to address its competitors more effectively and increase
congressional confidence in its operations.

Although MBN has developed a number of financial and administrative
controls, it could take additional steps to ensure its system of internal
control is fully implemented. MBN's planned internal control board needs
to establish protocols to oversee and monitor its internal control
structure and to ensure timely completion of MBN's financial audits.
Additionally, MBN should develop an internal control plan, conduct a
comprehensive risk assessment, and develop an organized training program
for its staff.

Further, MBN has developed journalistic standards for its broadcast
operations and has put in place a number of editorial procedures. However,
the network has not conducted annual program reviews called for in BBG
guidance. These reviews are a key mechanism for improving programming and
ensuring quality control.

Finally, the BBG has established performance indicators and targets for
MBN services related to measures of audience size and program credibility.
For example, in fiscal year 2005, the BBG reported that Radio Sawa and
Alhurra had each achieved radio and television audiences of about 21.6
million. However, limitations in the survey methods and documentation used
for developing these estimates raise questions about the accuracy of MBN's
performance estimates. In addition, the BBG has not put in place policies
and procedures for verifying the accuracy of its performance information.
These weaknesses in methodology and documentation inhibit an accurate
assessment of whether the Radio Sawa and Alhurra performance targets have
been met. The accuracy of the MBN estimates could be improved by more
rigorous reliance on probability sampling, wherever possible, and
avoidance of projections to areas not contained within the survey. At the
same time, insistence on proper fieldwork documentation from contractors,
full disclosure of survey methods and limitations, and greater
transparency in the development of aggregate audience estimates would
further enhance confidence in MBN performance estimates.

Recommendations for Executive Action

To improve efforts to monitor performance and the efficiency and
effectiveness of the broadcasting activities of the Middle East
Broadcasting Networks, Inc., we recommend that the chairman of the BBG do
the following:

o Require that MBN develop a long-term strategic plan, which incorporates
a shared vision for Alhurra and Radio Sawa operations and details specific
measurable objectives and implementation strategies for the successful
implementation of the goals in the plan.

o Require that MBN implement the remaining recommendations from the Grant
Thornton LLP report and require that its internal control board meet on a
regular basis to coordinate MBN's single audits and oversee MBN's ongoing
efforts to use sound internal control procedures.

o Develop a process for analyzing risk as part of strategic planning that
identifies approaches to mitigate the potential obstacles to efficiently
and effectively achieving MBN's operational objectives.

o Require MBN to develop a comprehensive training program covering both
internal controls and editorial procedures to meet the continuing needs of
all employees.

o Initiate a schedule of annual program reviews for Radio Sawa and Alhurra
to regularly ensure that the quality of Alhurra's broadcasts conforms to
applicable standards.

o Implement program quality performance indicators for MBN's broadcast
services, consistent with other BBG entities, to assess and compare their
performance and measure the contribution of these efforts to the goals of
the overall organization.

o Require research contractors to improve the methods used in audience
research to allow for probability sampling and document the sample
selection so that survey sampling errors can be calculated, where
possible.

o Identify and report significant methodological limitations and the
implications of them for performance indicators, including, where
applicable, sampling errors, margins of error, or confidence intervals.

o Develop, document, and report policies and procedures for verification
and analysis of performance indicator estimates.

Agency Comments and Our Evaluation

The Broadcasting Board of Governors (BBG) provided written comments on a
draft of this report. The BBG's comments, along with our response to
specific points, are reprinted in appendix V. The BBG also provided
technical comments, which we incorporated where appropriate.

In general, the BBG concurred with all of our recommendations and said it
looked forward to implementing them. The BBG said that MBN has made
significant progress in the 2 years of its operations in establishing a
sound journalistic organization with financial and administrative
controls. However, the BBG raised a number of concerns about the report's
criticisms of the audience research conducted by the BBG and its
contractors. Specifically, the BBG said that we did not fully understand
the difficulty in surveying audiences in Middle Eastern countries and that
the research practices used by the BBG and its contractors follow industry
standards for commercial and media research.

Our report examines the reliability of the BBG's fiscal year 2005
performance information in order to determine whether or not MBN's
performance targets have been met. We acknowledge, in our report, that BBG
has taken positive steps to enhance the validity and reliability of its
audience survey designs. We also acknowledge that there are challenges to
conducting audience research in the Middle East, and that there are
tradeoffs between cost and data reliability when conducting research. In
conducting our data reliability assessment, as referenced in the draft, we
largely used the international audience research guidelines published by
the Conference of International Broadcasters' Audience Research Services
(CIBAR), which are specified as a source of guidance for BBG research
contractors. For example, CIBAR standards recommend that the proper care
be exercised when reporting estimates to ensure that the type of audience
covered by the estimate is clearly stated, and that, at all stages in the
calculation and extrapolation process, sources, assumptions, and methods
are fully documented and available for independent scrutiny. We were
unable to determine the accuracy of MBN's fiscal year 2005 audience size
and program credibility estimates due to weaknesses in MBN's methodology
and documentation. As noted in the report, in several instances the BBG
and its contractors departed from CIBAR research standards. In particular,
the BBG did not take certain steps that could have explained and increased
the reliability of its estimates, such as by fully documenting its
research methods, measuring the level of uncertainty surrounding its
estimates, disclosing significant limitations, limiting the scope of its
projections to areas actually covered by its surveys, and developing and
consistently implementing policies and procedures for verifying data. For
these reasons, it is not clear whether the Radio Sawa and Alhurra
performance targets have been met.

As agreed with your office, unless you publicly announce the contents of
this report earlier, we plan no further distribution of it until 30 days
from the date of this letter. We will then send copies to others who are
interested and make copies available to others who request them.

If you or your staff have any questions about this report, please contact
me on (202) 512-4128. Contact points for our Offices of Congressional
Relations and Public Affairs may be found on the last page of this report.
Key contributors are listed in appendix VI.

Sincerely yours,

Jess T. Ford Director, International Affairs and Trade

Appendix I:  Scope and Methodology 

To accomplish our objectives, we reviewed documentation and spoke with
officials from the Department of State; the Broadcasting Board of
Governors (BBG) and its grantees; including the Middle East Broadcasting
Networks; Inc. (MBN); Radio Free Europe/Radio Liberty (RFE/RL); Radio Free
Asia (RFA); the Voice of America (VOA); and the International Broadcasting
Bureau. We also spoke with several outside experts, including
representatives from National Public Radio, the InterMedia research
organization, Zogby International, and foreign international broadcasters
such as the British Broadcasting Corporation (BBC) and Deutsche Welle.

In addition to our audit work in the Washington, D.C., area, we visited
MBN's offices in Amman, Jordan, and Dubai, United Arab Emirates. We held
telephone interviews with MBN's current affairs contractor in Beirut,
Lebanon, and sent questions to the MBN office in Baghdad, Iraq.

Because our work was focused on reviewing the BBG's MBN
initiatives--Alhurra and Radio Sawa-we did not include RFE/RL
Arabic-language media activities in Iraq in the scope of our work.

Review of MBN Internal Controls

To address our objective of assessing MBN's internal controls, we used
criteria contained in MBN's grant agreement, OMB Circulars No. A-110 and
A-133, GAO published standards on internal controls, and a report on MBN's
internal controls completed by Grant Thornton LLP accountants and
management consultants. We also met with other broadcasters, including
RFE/RL, RFA, and National Public Radio, to obtain an understanding of
their internal controls and to make comparisons with MBN. We held
discussions with MBN officials and reviewed documentation provided by them
to determine whether the organization was complying with appropriate
criteria. We spoke with PriceWaterhouseCoopers officials responsible for
the 2003, 2004, and 2005 single audits to obtain their perspectives on the
status of problems cited in the Grant Thornton LLP report and to learn
about any new issues arising from their audit work. We did not test MBN's
controls, since doing so would have been beyond the scope of our review.

Review of MBN's Editorial Procedures

To address our objective of assessing the procedures MBN has developed to
ensure it complies with its journalistic standards, we spoke with other
broadcasters, including RFE/RL, RFA, VOA, and National Public Radio, to
compare their editorial standards and procedures with those of MBN. We
also met with the BBG general counsel, as well as MBN producers, editors,
and journalists. To better understand the program review process, we
attended several VOA program reviews. We also held detailed discussions
and obtained documentation on program review from the BBG officials who
conducted Radio Sawa's review, the International Broadcasting Bureau
office of performance review, and the research directors of RFA and
RFE/RL. We did not test MBN's editorial procedures.

Review of MBN Audience Survey Methods and Performance Indicator Estimates

To address our objective of determining the extent to which the BBG met or
exceeded its fiscal year 2005 performance MBN targets, we reviewed the
reliability of BBG audience research that was used to generate the
estimates of credibility and audience size contained in the BBG's Fiscal
Year 2007 Budget Request, which was the BBG's most up-to-date source of
officially-reported GPRA performance information for MBN for fiscal year
2005. We did not review the inputs used to generate performance
information for fiscal years other than 2005, nor did we review the
reliability of the data used to develop other MBN performance indictors
reported in the 2007 Budget Request.

To conduct our assessment of the reliability of BBG estimates of
credibility and audience size for fiscal year 2005, we reviewed available
documentation provided as of May 2005 against applicable standards and
common professional research practices, including Conference of
International Broadcasters' Audience Research Services (CIBAR) guidelines
and the professional standards of the American Association for Public
Opinion Research. We reviewed relevant surveys, including technical
reports and printouts of the survey results, as well as spreadsheets used
to calculate the performance indicator estimates. We also conducted a
series of interviews and corresponded extensively with the BBG's
coordinator for performance planning and research, the head of the
International Broadcasting Bureau office of research, and officials from
Intermedia to discuss the survey methods and how performance indicator
estimates were generated. In addition, we requested information from the
BBG's research subcontractors, including AC Nielsen and D3 Systems, to
obtain details on the survey sampling plans and related assumptions,
response rates, and adjustments applied to the data to reflect the effects
of the survey design. As a result of our review, we determined that MBN's
reported audience size and credibility estimates are not statistically
reliable and are rather rough estimates of performance.

Appendix II:  Radio Sawa and Alhurra Programming 

Radio Sawa currently has seven programming streams,1 with the Iraq
programming stream airing more news and features than the other streams.
We reviewed one week of programming and found that the Iraq stream aired
about 50 hours of news and features a week, while five other streams aired
about 40 hours a week (see table 5).

Table 5: Radio Sawa's Weekly News and Features Programming

Programs            Jordan    Iraq   Persian    Morocco    Egypt    Sudan  
                                        Gulf                           
Total news          31 hrs 2  34 hrs 31 hrs 2   31 hrs 2   31 hrs 2 31 hrs 
programming time    min       48 min min        min        min      2 min  
Total features      8 hrs     14 hrs 8 hrs 22.5 7 hrs 57.5 8 hrs    7 hrs  
programminga time   22.5 min  47 min min        min        29.5 min 57.5   
                                                                       min    
Total time for news 39 hrs 25 49 hrs 39 hrs 25  39 hrs     39 hrs   39 hrs 
and features        min       36 min min                   32 min   

Source: GAO analysis of sample MBN programming schedule.

Note: The sample programming schedule was provided for the week of October
19, 2005. The exact breakdown of programming may differ from week to week.

aFeatures programming includes the following Radio Sawa shows: Ask the
World Now, Sawa Chat, Call Us Answers, Call Us Questions, Health News,
What's New, Free Zone, Challenges, To the Point, A Poet's Story, Window on
the Iraqi Constitution, Law and the Citizen, and Heart of the Matter.

Alhurra's programming focuses on news and information, including hourly
news updates, daily hour-long newscasts, and current affairs talk shows
(see table 6). In addition, Alhurra broadcasts current affairs shows on
subjects including health and fitness, entertainment, sports, and science
and technology. Alhurra also airs documentaries on a diverse range of
topics designed to appeal to a broad audience. In a sample week, Alhurra's
acquired programming, which mainly includes documentaries, accounted for
the largest number of hours aired, about 35 percent of the total weekly
programming hours--or approximately 60 hours in a week. News and news
updates amounted to 22 percent of weekly programming hours.

Table 6: Alhurra's Weekly Programming Schedule

Programming News    Talk  Current News    Economic Acquired     Change in    
time                shows affairs updates news     programminga programmingb 
                                             updates               
Per week    26      29    32 hrs, 10 hrs, 36 min   58 hrs, 20   9 hours      
               hours   hrs,  50 min  21 min           min          
                       40                                          
                       min                                         
Total       166     
               hours   
               and 47  
               minutes 

Source: GAO analysis of sample MBN programming schedule for the week of
February 19-25, 2006.

Note: The breakdown of shows may differ from week to week.

aAcquired programming includes documentaries, historical programs,
profiles, and travel and adventure programs.

bChange in programming is a deviation from the normal schedule, including
broadcasts of National Basketball Association games.

In contrast, Alhurra-Iraq's talk shows accounted for the largest number of
hours aired--- about 46 hours, or 27 percent of total programming time
(see table 7).

Table 7: Alhurra-Iraq's Weekly Programming Schedule

Programming News  Talk  Current News    Economic   Acquired    Change in   
time              shows affairs updates news       programming programming 
                                           updates                
Per week    34    45    31 hrs, 8 hrs,  36 min     42 hrs      5 hours     
               hours hrs,  20 min  24 min                         
                     40                                           
                     min                                          
Total       167   
               hours 

Source: GAO analysis of sample MBN programming schedule for the week of
February 19-25, 2006.

Note: The breakdown of shows may differ from week to week.

Appendix III:  Radio Sawa Program Review

The BBG initiated the Radio Sawa review because MBN did not have the
in-house capacity to do so, according to a BBG official. Moreover, both
the BBG and MBN wanted to ensure that the review was conducted by an
entity other than MBN to make it more independent.

To plan and conduct this review, BBG officials reported that they held
preliminary discussions with the International Broadcasting Bureau's
office of performance review, hired an outside expert to serve as a
consultant to the project, and contracted with the InterMedia research
organization to convene panels of regular listeners in Iraq, Morocco,
Egypt, and Jordan. According to representatives of InterMedia, they
recruited a large number of panelists because the BBG wanted more input
than usual. Panelists listened to and evaluated 6 days worth of
programming, responded to a questionnaire that evaluated all of Radio
Sawa's broadcast criteria, answered open-ended questions, provided
detailed feedback, and made recommendations about the programming.
Overall, the results of Radio Sawa's monitoring panels were generally
positive, with an overall program quality score of 2.9 out of 4, which is
considered "good" by the BBG.1 To follow up on the program review, MBN is
attempting to implement action points drafted by the BBG after the review,
such as reducing abrupt transitions between music and news and localizing
Radio Sawa's streams.

The BBG told us it placed great emphasis on the audience's response,
noting that if there had been any problems, they would have heard about
them from the listeners. The BBG's research contractor concurred that it
is important to obtain the audience's perspective, since the audience can
judge programming in the context of the alternatives available to them in
the local media market. According to a BBG official, it was decided that
information obtained from the audience monitoring panel would capture the
issues that would normally be covered by the internal analysts in the
content and production analyses.

However, even a detailed, well-thought-out questionnaire does not replace
the different perspectives internal and external control reviewers bring
to the review, according to a grantee official. According to an
International Broadcasting Bureau official, even though the three
components of a program review-audience panels and internal and external
reviewers-use nearly the same criteria, they provide different insights
into the program's quality, direction, and context. According to several
media experts,2 while audience panelists can evaluate news and information
from their own perspective, they are less qualified to evaluate a
service's mission or judge the extent to which a show complies with
journalistic standards. In particular, the absence of an internal review
meant that Radio Sawa's programming was not evaluated by people familiar
with BBG and MBN standards and controls. Moreover, the external control
listener's evaluation is intended to give the service a sense of what the
panel's responses would be like if the environment were freer and more
open, information that a monitoring panel cannot provide.

The BBG told us that it did not believe an internal evaluation was
necessary because the English translations of each of the panel reports
enabled them to examine and assess MBN's programming. The BBG also told us
that it did not use external control listeners in the review for several
reasons: (1) Radio Sawa's focus on youth and popular music would make it
difficult for a typical older control listener to evaluate Sawa's
programs; (2) the BBG lacked resources to use control listeners for the
multiple countries in Radio Sawa's review; (3) it would have been hard to
find impartial listeners; and (4) the four in-country panels ensured
enough diversity of opinion so that there was less need for a control
reviewer. However, according to an International Broadcasting Bureau
official, the VOA is able to successfully evaluate youth shows using its
regular internal reviewers. Moreover, it may be possible to use younger
control listeners, or to use the older ones selectively. For example,
RFE/RL uses a control listener to evaluate the news of Radio Farda. In
addition, the challenge of finding impartial control listeners is not
unique to the Middle East, but is potentially present to some degree for
every language service.

Appendix IV:  CIBAR Standards

The Conference of International Broadcasters' Audience Research Services
(CIBAR) guidelines were developed by an international group of
broadcasters - including the BBG's International Broadcasting Bureau -- to
encourage, among other things, the appropriate use of audience and market
data for decision-making within international broadcasting organizations,
the establishment and maintenance of standards in international audience
research, and the efficient and responsible use and application within
member organizations of all forms of audience feedback. By providing a
context for international audience research and a clear statement of the
minimum standards required, the guidelines attempt to address the
challenges faced by international broadcasters, including the tension
between the needs of proper audience measurement and survey practice and
the conditions and expertise in many of the countries where the research
is carried out.

The third edition of the guidelines, published in 2001, covers the nature
of international audience research measures; survey design, sampling, and
fieldwork; and data management and reporting.1 Specific guidelines
relevant to this report include the following:

4.1: Samples and method:

o The basis for audience measurement should be samples based on the
principles of random probability.

o The principles of random selection should be applied at all stages of
the sampling process, from initial sampling point to selection of
individuals.

o Quota samples should be used only in cases where, for reasons of
practicality, cost, or both, proper random samples cannot be used. When
quota samples are used, this should be clearly labeled in the reporting
and documentation of the data.

o It should be a requirement of all measurement research that the sampling
methods used and other technical aspects of the survey, including margins
of error and confidence levels where appropriate, be both fully and
accurately described in the project documentation, and open to independent
scrutiny.

4.2: Survey coverage:

o Where certain groups are disproportionately sampled and weighting
techniques are applied at the analysis stage to correct for this, project
documentation should give full details of the weights applied.

5.2: Data reporting:

o The research agency should provide the following information to a
contracting broadcaster:

o Background information - client for whom the study was conducted;
purpose of the study; names of subcontractors and consultants performing
any substantial part of the work.

o Intended and achieved sample -- universe covered; statistics used (e.g.
census data; size, nature and geographical distribution of the sample;
sampling method and weighting methods used; response rates and possible
bias due to non-response).

o Data collection - method of collection; field staff; briefing and field
quality control; method of recruiting respondents; and fieldwork dates.

o Presentation of results - relevant factual findings obtained; bases of
percentages (weighted and unweighted); margins of error; and questionnaire
and other documents used.

o Proper care be exercised when reporting such estimates, to ensure that
the type of audience covered by the estimate is clearly stated.

o At all stages in the calculation and extrapolation process, it is vital
that sources, assumptions, and methods be fully documented and available
for independent scrutiny.

o All reporting of worldwide and regional audiences should be accompanied
by a technical appendix giving details of the sources, assumptions, and
measures used.

Appendix V:  Comments from the Broadcasting Board of Governors

The following are GAO's comments on the Broadcasting Board of Governor's
(BBG) letter dated July 20, 2006.

GAO Comments

1.GAO acknowledges in the report that MBN has participated in long-range
planning in coordination with the BBG's update of its 2008-2012 strategic
plan, and that MBN has developed a 2006 annual performance plan as part of
the OMB Program Assessment Rating Tool process. However, contrary to the
BBG's comments, the fiscal year 2006 performance plan document for MBN
that we obtained did not contain all of the elements of a stand-alone
strategic plan. In addition, we were told by the former executive director
of the BBG, who is currently the president of MBN, that the Radio Sawa
strategic plan drafted in 2002 by the BBG-which the BBG stated in its
comments contributed to its considerable long-term planning for MBN--was
never adopted by the BBG. We were also told by MBN's former president that
he had never received a copy of the draft Radio Sawa strategic plan.

2.The BBG stated that MBN's Single Audit evaluates the effectiveness of
its internal control program. However, while MBN's Single Audits address
the fair presentation of the organization's financial statements, its
compliance with certain laws and regulations, and the organization's
internal control as it relates to financial reporting, MBN's 2005 Single
Audit as prepared by PriceWaterhouseCoopers does not-contrary to what the
BBG stated in its comments--offer an opinion on the overall effectiveness
of MBN's internal control. Thus, the unqualified opinion that MBN received
on its fiscal year 2005 Single Audit does not provide a broad assessment
or opinion of MBN's internal control system. For the purposes of our
report, it was therefore necessary to consider other assessments of MBN's
financial and administrative controls, including the Grant Thornton
report.

3.MBN's grant agreement states that MBN should make every reasonable
effort to achieve the purpose of the grant in accordance with OMB
Circulars A-110, A-122, and A-133. Our report did not attempt to make an
assessment of MBN's compliance with its grant agreement, but rather
focused on the progress MBN has made in developing its system of internal
control and the ways in which MBN can continue to strengthen this system.
To that end, we drew upon the work of Grant Thornton LLP, which assessed
the status of MBN's controls against relevant OMB Circulars and GAO
guidance on internal control.

4.While the Grant Thornton recommendations are not obligatory, they are
based on best management practices from OMB and GAO. According to
officials, both the BBG and MBN accepted the results of the report, which
provides detailed insight into MBN's financial operations, when it was
completed in May 2004. Adopting the report's remaining recommendations
would help MBN in its efforts to build a fully mature internal financial
management operation.

5.The BBG stated that it believes its standards yield data of sufficient
reliability to allow it to estimate MBN's audiences and credibility.
However, the BBG offers no evidence for this. BBG's estimates for MBN are
based on judgment and not statistics, and its current methods do not and
cannot estimate the error in its estimates. As noted in the report, in
several instances the BBG and its contractors departed from CIBAR research
standards. For example, we analyzed 12 of the 14 country surveys conducted
by BBG contractors for 2005. In the BBG's fiscal year 2007 budget request,
the BBG reported the results of each country survey and an overall
estimate for audience size of 21.5 for Alhurra and 21.6 million for Radio
Sawa. However, our analysis of the 12 surveys identified a number of
methodological weaknesses, including BBG's failure to fully document
research methods, measure the level of uncertainty surrounding its
estimates, disclose significant limitations, limit the scope of its
projections to areas actually covered by its surveys, and develop and
consistently implement policies and procedures for verifying data. These
limitations were not reported in BBG's audience survey estimates and
prevent us from concluding that the estimates are accurate and reliable.

6.We acknowledge in the report that there are challenges to conducting
audience research in the Middle East, and that there are tradeoffs between
cost and data reliability when conducting research.

7.As we noted in the report, it is difficult to conduct probability
sampling in many locations in the Middle East. But, it is not impossible.
Organizations, including the United States Census Bureau, have
collaborated on probability surveys in the Middle East, including in Saudi
Arabia and Jordan. The major problem of the BBG estimates is their lack of
transparency, and the lack of an explanation for the methodology behind
BBG's estimates.

8.In conducting our data reliability assessment, as referenced in the
report, we largely used the international audience research guidelines
published by CIBAR. The BBG participated in drafting these standards,
which are specified as a source of guidance for BBG research contractors.
CIBAR standards recommend that proper care be exercised when reporting
estimates to ensure that the type of audience covered by the estimate is
clearly stated, and that, at all stages in the calculation and
extrapolation process, sources, assumptions, and methods are fully
documented and available for independent scrutiny. As noted in the report,
in several instances the BBG and its contractors departed from CIBAR
research standards, leading to weaknesses in MBN's methodology and
documentation. As a result, we were unable to determine the accuracy of
MBN's fiscal year 2005 audience size and program credibility estimates.

9.The BBG stated that it believes the level of methodological detail it
has provided in public documents is comparable with that typically used by
other research organizations for studies in the Islamic world; therefore,
it believes it is consistent with industry practice. However, the Reports
Consolidation Act of 20001 requires federal agencies, such as the BBG, to
assess the completeness and reliability of the performance data in their
performance reports and to discuss any material inadequacies in the
completeness and reliability of their performance data, as well as actions
to address the inadequacies. In performance reporting such as the BBG
fiscal year 2007 budget request, the BBG reported the results of its
research for MBN as 21.5 million viewers for Alhurra and 21.6 million for
Radio Sawa. However, the BBG did not sufficiently explain the specific
methods used for generating estimates for its performance indicators, such
as the number and names of the countries surveyed (including the sizes of
its samples), methods of sampling used, sources of the population data,
and basic procedures used to create the estimates. Moreover, the BBG
reported only two limitations for MBN performance indicators to date: (1)
that credibility ratings are highly dependent on volatile political
factors; and (2) that, depending on political, social, and media
conditions, measurement of audience size may either be easily attained or
impossible. Significant limitations not reported are that many of the BBG
surveys are not based on probability sampling, cover only part of the
country, have very low response rates, or have high substitution rates.
Therefore, the BBG does not provide a full level of confidence in the
credibility of its performance data for MBN. In contrast, the Department
of Transportation, has a separate compendiums available online that
provides source and accuracy statements, which provide detail on the
methods used to collect performance data, sources of variation and bias in
the data, and methods used to verify and validate the data.

10.The BBG cannot calculate the sampling error for the BBG estimates of
audience size and credibility because the probability of selection is not
known. Although increased sample size will generally decrease sampling
error, it is impossible to accurately estimate the sampling error of the
BBG surveys because they are nonprobability surveys. As the BBG has
stated, its use of a simple random sampling formula when calculating
sampling errors for its surveys underestimates the sampling error. This
formula is not appropriate for the sample designs used by MBN.

11.Although our recommendation asks the BBG to require research
contractors to improve the methods used in audience research to allow for
probability sampling and document the sample selection so that survey
sampling errors can be calculated, where possible, it is the
responsibility of the BBG to explain and justify the need to conduct
nonprobability samples.

Appendix VI:  GAO Contact and Staff Acknowledgments

GAO Contact

Jess Ford, (202) 512-4268

Staff Acknowledgments

Diana Glod, Melissa Pickworth, Eve Weisberg, Dorian Herring, and Joe
Carney made key contributions to this report. Chanetta Reed, Jay Smale,
Karen O'Conor, and Jackie Nowicki provided technical assistance.

(320376)

www.gao.gov/cgi-bin/getrpt?GAO-06-762.

To view the full product, including the scope

and methodology, click on the link above.

For more information, contact Jess T. Ford at (202) 512-4128 or
[email protected].

Highlights of GAO-06-762, a report to the Chairman, Subcommittee on
National Security, Emerging Threats and International Relations, Committee
on Government Reform, House of Representatives

August 2006

U.S. INTERNATIONAL BROADCASTING

Management of Middle East Broadcasting Services Could Be Improved

The Broadcasting Board of Governors' (BBG) broadcasting services, Radio
Sawa, and the Alhurra satellite television networks-collectively known as
the Middle East Broadcasting Networks, Inc. (MBN)-currently aim to reach
Arabic speakers in 19 countries and areas throughout the Middle East.
Annual spending for current activities amounts to about $78 million.

GAO reviewed MBN's (1) strategic planning to address competition in the
Middle Eastern media market, (2) implementation of internal control, (3)
procedures MBN has developed to ensure compliance with its journalistic
standards, and (4) performance indicators and whether targets have been
met.

What GAO Recommends

GAO is making several recommendations to the chairman of the BBG to
improve the efficiency and operations of MBN. These include fully
implementing strategic planning, internal control, and regular program
reviews, as well as addressing weaknesses in the conduct and reporting of
its audience research.

The BBG generally concurred with our recommendations, although it
disagreed with some of our analysis.

MBN faces a number of competitive challenges in carrying out its mission
of broadcasting in the Middle Eastern media market and has taken some
steps to address them. However, MBN lacks a comprehensive, long-term
strategic plan. As MBN emerges from its start-up mode and faces future
challenges, a long-term strategic plan will be important.

While MBN has developed financial and administrative controls to manage
and safeguard its financial resources, it could take additional steps to
strengthen its system of internal control. For example, the MBN has not
(1) convened a meeting of its internal control board to formally develop
its controls and coordinate audits, (2) completed an internal control
plan, (3) completed a risk assessment to address potential risks to its
operation, or (4) developed a comprehensive training program for its
staff.

MBN has procedures in place to help ensure its programming meets its
journalistic standards. However, MBN lacks regular editorial training and
has not fully implemented a comprehensive, regular program review process
to determine whether its programming complies with those standards or with
MBN's mission. While the BBG calls for its broadcasters to undergo an
annual program review, Radio Sawa has only held one such review, and
Alhurra has not completed one to date.

The BBG has developed several performance indicators and targets for MBN's
Radio Sawa and Alhurra services, including measures of audience size and
program credibility. However, it is not clear whether the Radio Sawa and
Alhurra performance targets have been met because of weaknesses in MBN's
survey methodology and documentation. The BBG did not take certain steps
that could have explained and increased the reliability of its estimates,
such as by fully documenting its research and estimation methods,
measuring the level of uncertainty surrounding its estimates, disclosing
significant limitations, and consistently implementing policies and
procedures for verifying data.

Alhurra's Broadcast Center in Springfield, Virginia
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