Homeland Security: Responses to Posthearing Questions Related to 
the Department of Homeland Security's Integrated Financial	 
Management Systems Challenges (10-AUG-07, GAO-07-1157R).	 
                                                                 
On June 28, 2007, GAO testified before the Senate Subcommittee on
Federal Financial Management, Government Information, Federal	 
Services, and International Security, Committee on Homeland	 
Security and Governmental Affairs, at a hearing entitled,	 
"Financial Management Systems Modernization at the Department of 
Homeland Security: Are Missed Opportunities Costing Us Money?" At
the hearing, we discussed the Department of Homeland Security's  
(DHS) failed efforts to implement the Electronically Managing	 
Enterprise Resources for Government Effectiveness and Efficiency 
(eMerge2) program that was expected to integrate financial	 
management systems across the entire department. Our testimony	 
and related report focused on (1) DHS's financial management	 
systems modernization efforts, (2) key financial management	 
system transformation challenges, and (3) the four building	 
blocks that form the foundation for successful financial	 
management system implementation efforts. This letter responds to
Congress's July 10, 2007, request for responses to follow-up	 
questions relating to our June 28, 2007, testimony. The responses
are based on work associated with previously issued GAO products.
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-07-1157R					        
    ACCNO:   A74255						        
  TITLE:     Homeland Security: Responses to Posthearing Questions    
Related to the Department of Homeland Security's Integrated	 
Financial Management Systems Challenges 			 
     DATE:   08/10/2007 
  SUBJECT:   Accountability					 
	     Accounting procedures				 
	     Federal agency reorganization			 
	     Financial management				 
	     Financial management systems			 
	     Financial statement audits 			 
	     Homeland security					 
	     Internal controls					 
	     Program evaluation 				 
	     Program management 				 
	     Strategic planning 				 
	     Technology modernization programs			 
	     Program implementation				 

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GAO-07-1157R

   

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August 10, 2007

The Honorable Tom Carper
Chairman
Subcommittee on Federal Financial Management, Government Information,
Federal Services, and International Security
Committee on Homeland Security and Governmental Affairs
United States Senate

Subject: Homeland Security: Responses to Posthearing Questions Related to
the Department of Homeland Security's Integrated Financial Management
Systems Challenges

Dear Mr. Chairman:

On June 28, 2007, we testified^1 before your subcommittee at a hearing
entitled, "Financial Management Systems Modernization at the Department of
Homeland Security: Are Missed Opportunities Costing Us Money?" At the
hearing, we discussed the Department of Homeland Security's (DHS) failed
efforts to implement the Electronically Managing Enterprise Resources for
Government Effectiveness and Efficiency (eMerge^2) program that was
expected to integrate financial management systems across the entire
department. Our testimony and related report^2 focused on (1) DHS's
financial management systems modernization efforts, (2) key financial
management system transformation challenges, and (3) the four building
blocks that form the foundation for successful financial management system
implementation efforts.

This letter responds to your July 10, 2007, request for responses to
follow-up questions relating to our June 28, 2007, testimony. The
responses are based on work associated with previously issued GAO
products. Your questions, along with our responses, follow.

           1. The Electronically Managing Enterprise Resources for Government
           Effectiveness and Efficiency (Emerge^2) program began in January
           2004 to integrate financial management systems across the
           Department. GAO will testify that the Department could not
           determine or support the cost of $52 million spent on the Emerge^2
           project. Prudently, Mr. Norquist declared the project "dead"
           before spending an estimated $229 million on a system that would
           not provide the desired functionality or performance.

           GAO has reported there are many long-standing problems that plague
           financial management system improvement efforts.

                        o Is the Department not getting the message?

                        o What needs to be done to get that message across?

                        o How should the Department incorporate lessons
                        learned to avoid unnecessary spending on projects
                        doomed to fail?

^1GAO, Homeland Security: Transforming Departmentwide Financial Management
Systems Remains a Challenge, GAO-07-1041T (Washington, D.C.: June 28,
2007).

^2GAO, Homeland Security: Departmentwide Integrated Financial Management
Systems Remain a Challenge, GAO-07-536 (Washington, D.C.: June 21, 2007).

The consolidation of an entity as large and diverse as DHS poses
significant management challenges, including integrating a myriad of
redundant financial management systems and addressing existing and newly
identified weaknesses in the inherited components. Our report^3 noted that
DHS had an inventory of over 500 financial management systems and had
inherited 18 material internal control weaknesses^4 from agencies that
were transferred to DHS. In order for DHS to avoid unnecessary spending on
failed projects like eMerge^2, it must adopt solutions that reduce the
risks associated with these efforts to acceptable levels. We have
identified four key concepts that will be critical to DHS's ability to
successfully complete the implementation of an integrated financial
management system. The four concepts are (1) developing a concept of
operations document, (2) defining standard business practices, (3)
developing an implementation or migration strategy, and (4) defining and
effectively implementing disciplined processes necessary to properly
manage the specific projects. Effective human capital management, such as
strategic workforce planning and change management, is also identified as
critical to successfully implementing a new financial management system.
Our report provides specific recommendations aimed at helping DHS
incorporate lessons learned and best practices.

In comments on the draft report, and at the hearing held on June 28, 2007,
DHS officials indicated their willingness to adopt these recommendations
and discussed the initiatives under way to do so. However, DHS's financial
management system integration effort is in the early stages, and continued
focus and commitment, among other things, will be necessary for it to be
successful.

           2. The Department is required by law to prepare expenditure plans
           for information technology (IT) projects (such as United States
           Visitor and Immigration Status Indicator and Immigration and
           Customs Enforcement).

                        o What level of oversight is needed and by whom?

                        o In light of continued project failures, should
                        expenditure plans be prepared, reviewed, and approved
                        for the Transformation and Systems Consolidation
                        (TASC) project in light of the Emerge^2 project
                        failure?

                        o Are expenditure plans an effective method for
                        helping the Department meet cost, schedule, and
                        performance objectives of its information technology
                        projects?

^3GAO-07-536.

^4The definition of a material weakness is a significant deficiency, or
combination of significant deficiencies, that results in more than a
remote likelihood that a material misstatement of the financial statements
will not be prevented or detected.

Expenditure plan reviews have proven to be an effective method of
providing accountability for projects. For example, we recently reviewed^5
DHS's Science and Technology (S&T) Directorate's Expenditure Plan, noting
that the projected expenditures were not broken out and justified as
required by law. The S&T Directorate was established by the Homeland
Security Act of 2002 to, among other things, coordinate the federal
government's civilian efforts to identify and develop countermeasures to
emerging terrorist threats to our nation. Our review found that the S&T
Directorate's fiscal year 2007 expenditure plan, including related
documentation and other information provided by S&T program officials, did
not fully satisfy the conditions set forth in the Department of Homeland
Security Appropriations Act of 2007.^6 Specifically, management and
administrative costs were not broken down by program, project, and
activity (PP&A) as required by the Act. The Congress could use a similar
expenditure plan approach to help provide oversight for DHS's
Transformation and Systems Consolidation (TASC) project, particularly in
light of the failed eMerge^2 project.

While expenditure plans can provide valuable and useful information,
additional types of information are needed to fully assess the
effectiveness of the processes being used to manage a project. For
example, in addition to all project costs being correctly shown on an
expenditure plan, the agency and others need assurance that (1) the risks
associated with the project have been reduced to acceptable levels and (2)
the future planned costs are realistic. These matters are best determined
by effectively implementing the disciplined processes necessary to manage
a given project.

Further, given the importance of IT to DHS's mission performance and
outcomes, it is vital for the department to adopt and employ an effective
institutional approach to IT investment management. We have previously
recommended^7 that DHS devote the appropriate attention to the development
and implementation of effective investment management processes. This
includes fully defining and documenting project- and portfolio-level
policies and procedures that oversee (i.e., control) IT projects and
systems, including specifying the procedural rules for the investment
boards' operations and decision-making during project oversight. Without
this, DHS lacks the institutional capability needed to help ensure that it
is investing in IT projects that best support its strategic mission needs
and that ongoing projects will meet cost, schedule, and performance
expectations.

^5GAO, Department of Homeland Security: Science and Technology
Directorate's Expenditure Plan, GAO-07-868 (Washington, D.C.: June 22,
2007).

^6Pub. L. No. 109-295, 120 Stat. 1355, 1375 (2006).

^7GAO, Information Technology: DHS Needs to Fully Define and Implement
Policies and Procedures for Effectively Managing Investments, GAO-07-424
(Washington, D.C.: Apr. 27, 2007).

           3. Most financial management modernization projects take a long
           time to complete, and many of the top leaders have a limited
           tenure, or a stove-piped view.

                        o In your view, is there a shared, department-wide
                        view on how to move forward with financial management
                        modernization?

                        o Who within the Department has a sustainable,
                        long-term view of financial management modernization?

                        o Does this require top leadership buy-in?

Regardless of the strategy DHS takes, sustained leadership will be key to
a successful migration strategy for moving DHS toward a consolidated
financial management system. In our Executive Guide: Creating Value
Through World-class Financial Management,^8 we found that leading
organizations made financial management improvement an entitywide priority
by, among other things, providing clear, strong executive leadership. We
also reported that making financial management a priority throughout the
federal government involves changing the organizational culture of federal
agencies. Although the views about how an organization can change its
culture can vary considerably, leadership (executive support) is often
viewed as the most important factor in successfully making cultural
changes. Top management, such as the Secretary, must be committed in both
words and actions to changing the culture, and this commitment must be
sustained and demonstrated to staff. Sustained and committed leadership
will be a key factor in the successful migration of DHS's financial
management systems.

The federal government has faced a long-standing challenge of sustaining
the momentum of transformation because of the limited tenure of key
administration officials, and managing the transformation of an
organization of the size and complexity of DHS requires comprehensive
planning and integration of key management functions across the
department. We have previously supported the establishment of a Chief
Management Officer (CMO) position at DHS.^9 The CMO would serve as the
strategic, enterprisewide integrator of efforts to transform agency
business operations, including financial management.

Moreover, a concept of operations document with a clear definition and
scope of the financial management activities to be included is another key
element that can provide a shared, departmentwide view. A concept of
operations defines how an organization's day-to-day operations are or will
be carried out to meet mission needs. The concept of operations includes
high-level descriptions of information systems, their interrelationships,
and information flows. It also describes the operations that must be
performed, who must perform them, and where and how the operations will be
carried out. Our review^10 of the concept of operations prepared as part
of the eMerge^2 project found that it lacked several key attributes called
for by best practices. For example, the eMerge^2 concept of operations did
not take into consideration the over 500 financial management and related
legacy systems in operation at DHS. Because of the large number of
systems, DHS needs to define in its concept of operation (1) which legacy
systems will be migrated to the new environment and (2) how this
transition is envisioned to occur in order to achieve an integrated
environment. Not only is this needed from an investment management point
of view, it is a key element in addressing human capital challenges
relating to change management strategies. DHS has recognized the
importance of a well-defined concept of operations and is drafting one
that it expects to address component-specific legacy systems and how they
will interact or be replaced.

^8GAO, Executive Guide: Creating Value Through World-class Financial
Management, GAO/AIMD-00-134 (Washington, D.C.: April 2000).

^9GAO, Federal Financial Management: Critical Accountability and Fiscal
Stewardship Challenges Facing Our Nation, GAO-07-542T (Washington, D.C.:
Mar. 1, 2007).

           4. During the Emerge^2 program, the Department had identified over
           7,000 system and business requirements. Department officials
           believe many of these requirements are reusable for future
           information technology projects. However, GAO raised concerns
           about whether any of the 7,000 requirements are salvageable. You
           have raised concerns about the ability of the Department to use
           some of the 7,000 requirements developed during its Emerge^2
           program for another project.

                        o What are your concerns and could you outline
                        possible remedies?

                        o If the Department purchases a commercially
                        available system, would this eliminate the need to
                        develop requirements?

Although DHS officials told us that they expect the requirements developed
for eMerge^2 to be salvageable and provide a foundation for its future
efforts, our review found that key requirements developed for eMerge^2 did
not have attributes associated with good requirements developed using best
practices. The attributes of good requirements include being correct,
unambiguous, complete, consistent, ranked for order of importance,
verifiable, modifiable, and traceable. Some of the missing attributes of
the eMerge^2 requirements were clarity, traceability, and completeness.
Most importantly, the eMerge^2 requirements were not based on (1) a good
concept of operations, (2) reengineered business processes, and (3) an
appropriate internal control structure. For example, we were unable to
identify critical requirements relating to inventory in the eMerge^2
documentation, even though DHS's fiscal year 2006 financial statements
identified approximately $677 million in inventory and supplies. To help
reduce the risks associated with consolidating its financial management
systems, we recommended^11 that DHS implement a disciplined requirements
management process. DHS concurred with this recommendation, and we are
encouraged that DHS recognized that attention is needed and is developing
plans to address these financial management systems issues.

Such detailed requirements are still necessary even with the acquisition
of a commercial off-the-shelf (COTS) system to make sure the
implementation decisions that are required to make the COTS package
operational result in a system that addresses the needs of the users.
Major commercial software packages, such as those being acquired by the
Defense Logistics Agency, National Aeronautics and Space Administration,
the Departments of the Army, Navy, and Health and Human Services, and
others to improve their financial management operations, are similar to
the ones DHS is contemplating and are extremely complex. Therefore, it is
critical that DHS understands what its users want the system to do, in
order to configure the system to ensure that its expectations are met.
Fundamental to this effort is an understanding of the requirements that
are needed to achieve the desired functionality.

^10GAO-07-536.

^11GAO-07-536.

           5. The main takeaway in GAO's testimony is that the Department
           needs to follow systematic methods or "disciplined processes." We
           continue to hear about failed federal agency projects due in large
           part to failures by agency managers to follow "disciplined
           processes."

                        o Why are the Department managers not following these
                        processes?

                        o What actions are being taken to address this?

                        o What is your recommendation about how to correct
                        this problem?

History has shown a direct relationship between the effectiveness of the
processes used to manage a project and how well that project meets its
cost, schedule, and performance objectives--projects with strong processes
have a far greater probability of meeting their objectives than projects
that have weak processes. These disciplined processes are based on the
best practices identified by the Software Engineering Institute (SEI),^12
the Institute of Electrical and Electronics Engineers, Inc. (IEEE),^13 the
Project Management Institute, and other experts, which have been proven to
reduce the risk in implementing systems. A disciplined software
implementation management process can maximize the likelihood of achieving
the intended results (performance) within established resources (costs) on
schedule. Moreover, it is critical to have the right people in the right
place at the right time to efficiently apply disciplined processes.

As we do more work in this area, we continue to find that the quality of
these processes is a leading indicator of future successes and failures.
These observations are consistent with those of experts reviewing private
sector system development efforts. We previously recommended^14 that the
Office of Management and Budget (OMB) develop specific guidance for
agencies on disciplined processes for financial systems implementation and
provide a standard set of practices to guide the migrations from legacy
systems to new systems and application service providers. OMB agreed with
our recommendation and in September 2006 issued high-level guidance to
federal agencies. The guidance identified various disciplined processes,
such as project management, requirements management, and data conversion,
to reduce the risks associated with financial management systems
implementations. While OMB's guidance is a notable first step, more
detailed guidance is needed to help ensure a consistent understanding of
the needed processes.

^12SEI is a federally funded research and development center operated by
Carnegie Mellon University and sponsored by the U.S. Department of
Defense. The SEI objective is to provide leadership in software
engineering and in the transition of new software engineering technology
into practice.

^13IEEE is a nonprofit, technical professional association that develops
standards for a broad range of global industries, including the
information technology and information assurance industries, and is a
leading source for defining best practices.

^14GAO, Financial Management Systems: Additional Efforts Needed to Address
Key Causes of Modernization Failures,  GAO-06-184 (Washington, D.C.: Mar.
15, 2006).

A key for DHS to avoid the long-standing implementation problems
identified at other agencies is to successfully implement the
recommendations in our report.^15 These recommendations are consistent
with OMB's high-level guidance. Toward this end, DHS has recognized the
importance of disciplined processes, and acknowledged that the success of
its efforts is predicated on having a disciplined set of processes from
requirements development to acceptance. In comments on our draft
report,^16 DHS also indicated that it planned to add staff with program
management and systems capabilities experience to manage its risks.

           6. We have been told that the long-term vision of the Department
           is to consolidate its financial management systems down to 2 from
           about 500. Mr. Norquist and Mr. Charbo testified that by 2011 97%
           of the Department will be on consolidated financial management
           systems. According to their testimony, they will move to Phase 2
           and move the entire department to one financial management system.
           It is not clear what they mean by Phase 2.

                        o What are your views on this two-phased approach
                        that Mr. Norquist and Mr. Charbo have outlined?

The scope of our review did not include an analysis of DHS's two-phased
approach to consolidating financial management systems because DHS first
announced this approach at the June 28, 2007, hearing. As noted in DHS's
comments to our draft report,^17 it expects to use several financial
management systems for an extended period. For example, DHS noted that the
systems used by the Secret Service and the Federal Law Enforcement
Training Center were not going to be migrated to one of the two
consolidated financial management systems until at least 2011.
Accordingly, it is unclear whether one or more of these systems will also
need to undergo major upgrades before they are transitioned to one of the
two planned financial management systems. Significant cost, time, and
effort are associated with maintaining and upgrading financial management
systems over an extended period of time. Therefore, it is important to
recognize that such an approach may result in excessive costs.

           7. OMB has recently taken over the responsibilities of the former
           Joint Financial Management Improvement Program (JFMIP) to perform
           tests on financial management systems or packages used by agencies
           to ensure that the packages met a set of "core requirements." Once
           the financial management packages pass the tests, OMB certifies
           them as "JFMIP compliant" and ready for use by the agencies.
           However, GAO has reported that agencies that have implemented
           these "certified" packages still had significant problems.

                        o Has the OMB process for certifying financial
                        management systems or packages improved agencies
                        ability to successfully implement these systems?

                        o In your view, have these "certified" systems helped
                        the Department?

^15GAO-07-536.

^16GAO-07-536.

^17GAO-07-536.

The certification process has been helpful but it is just one part of the
equation. First, the certification process covers a subset of the
financial management requirements needed to meet the requirements called
for in the Federal Financial Management Improvement Act (FFMIA) of
1996.^18 Agencies must be mindful of this distinction. Second, agencies
must fully understand that these packages are extremely complex and the
user does not simply open a box, install the software, and turn it on.
Agencies must make many decisions when installing these complex systems,
and these decisions will affect the ultimate success of a project. An
agency has little assurance that even though the package is certified, its
implementation of a new system will also be compliant with FFMIA. This is
due to (1) configuration decisions made during system implementation and
(2) manual and non-COTS processes that are needed for successful
implementation. While the certification tests are useful, federal agencies
need to perform a great deal of their own testing to ensure that the
system as ultimately implemented meets their needs and complies with FFMIA
requirements. For example, although the COTS products adopted by DHS were
tested and certified by JFMIP,^19 DHS still needs to test whether the
products were implemented in a manner that ensured the packages continued
to comply with the federal financial management systems requirements.

Further, the certification testing by necessity focuses on the technology
portion of the equation. As noted in our report, each of the two financial
management systems selected by DHS has significant material weaknesses,
some of which were caused by factors outside the COTS package technology,
such as people and process problems. Accordingly, DHS will also need to
focus on these areas and correct these weaknesses before it can have
reasonable assurance that its consolidation efforts will result in
compliant systems.

^18Pub. L. No. 104-208, div. A., S101(f), title VIII, 110 Stat. 3009,
3009-389 (Sept. 30, 1996). FFMIA requires the heads of the 24 major
departments and agencies ("Chief Financial Officer (CFO) Act agencies") to
maintain systems that comply substantially with three requirements: (1)
federal financial management systems requirements, (2) federal accounting
standards, and (3) the U.S. Standard General Ledger (SGL) at the
transaction level.

^19The former Joint Financial Management Improvement Program (JFMIP) was
formed under the Budget and Accounting Procedures Act of 1950, Pub. L. No.
81-784, S 111 (f), 64 Stat. 832, 835 (Sept. 12, 1950) (codified at 31
U.S.C. S 3511), as a joint and cooperative undertaking of GAO, the U.S.
Department of the Treasury, OMB, and Office of Personnel Management (OPM),
working in cooperation to improve financial management practices in the
federal government. In an effort to eliminate duplicative roles and
streamline financial management improvement efforts, some of the former
responsibilities of the JFMIP were placed under the Financial Systems
Integration Office. (See OMB, Realignment of Responsibilities for Federal
Financial Management Policy and Oversight, Memorandum (Washington, D.C.:
Dec. 2, 2004)). As a result of the realignment, JFMIP ceased to exist as a
separate organization, although the principals will continue to meet at
their discretion.

           8. GAO and the Department auditors have reported since its
           inception that internal control and financial management
           weaknesses have prevented the Department from implementing
           successful financial management systems that improve Department
           business operations and provide accurate and reliable day-to-day
           financial and performance information. For fiscal years 2006 and
           2005, the Department auditors were unable to provide an opinion on
           the Department consolidated financial statements. GAO points out
           in its report that achieving a "clean" opinion is not the end
           game. The Department needs to resolve its outstanding internal
           control issues.

                        o How will obtaining a clean opinion on the
                        Department's financial statements impact its
                        financial management modernization?

While there continues to be much focus on agency and governmentwide audit
opinions, getting a clean audit opinion, though important in itself, is
not the end goal. The end goal is the establishment of a fully functioning
Chief Financial Officer (CFO) operation that includes (1) modern financial
management systems that provide reliable, timely, and useful information
to support day-to-day decision-making and oversight and for the systematic
measurement of performance; (2) a cadre of highly qualified senior-level
and supporting financial management staff; and (3) sound internal controls
that safeguard assets and ensure proper accountability. Ultimately, DHS
must be able to provide reliable, useful, and timely financial management
information so that DHS leadership and the Congress are well-positioned to
make fully informed decisions to secure America's homeland. Because of the
10 material weaknesses reported^20 by DHS financial statement auditors,
DHS management, the Congress, and others do not have reliable financial
data for managing the agency. It is imperative that DHS reengineer its
processes across the agency as part of addressing these material
weaknesses.

In early March 2007, DHS officials issued a high-level plan to address
these material weaknesses, referred to as the Internal Control Over
Financial Reporting Playbook. However, the Playbook is not a comprehensive
effort to address DHS's financial management systems needs because it is
limited to financial statement preparation based on two tracks. The first
track focuses on corrective action strategies for material weaknesses, and
the second track focuses on building support for the Secretary's internal
control over financial reporting assurance statement. Much more detail is
needed to provide a financial management strategy or plan for integrating
and modernizing DHS's financial management systems. In addition, it is
important to fix the problems that are embedded in the existing financial
management systems before other DHS components are migrated to the any of
these systems.

                          - - - - - - - - - - - - - -

We are sending a copy of this report to the Secretary of Homeland
Security, and other interested parties. This report is also available on
GAO's home page at [3]http://www.gao.gov . Should you have any questions
on matters discussed in this report or need additional information, please
contact McCoy Williams at (202) 512-9095 or at [4][email protected] or
Keith A. Rhodes at (202) 512-6412 or at [5][email protected] . Contact
points for our Offices of Congressional Relations and Public Affairs may
be found on the last page of this report. Major contributors to this
report include Chris Martin, Senior-Level Technologist; Kay Daly,
Assistant Director; Chanetta Reed; Francine DelVecchio; and Felicia
Brooks.

^20Department of Homeland Security, Performance and Accountability Report
Fiscal Year 2006 (Washington, D.C.: November 2006).

Sincerely yours,

McCoy Williams
Director
Financial Management and Assurance

Keith A. Rhodes
Chief Technologist
Applied Research and Methods
Center for Technology and Engineering

(195121)

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