Trade Adjustment Assistance: Changes Needed to Improve States'	 
Ability to Provide Benefits and Services to Trade-Affected	 
Workers (14-JUN-07, GAO-07-995T).				 
                                                                 
The Trade Adjustment Assistance (TAA) program, administered by	 
the Department of Labor (Labor), is the nation's primary program 
providing income support, job training, and other benefits to	 
manufacturing workers who lose their jobs as a result of	 
international trade. In fiscal year 2006, Congress appropriated  
about $900 million for TAA, including about $220 million for	 
training. GAO has conducted a number of studies on the TAA	 
program since the program was last reauthorized in 2002. This	 
testimony draws upon the results of two of those reports, issued 
in 2006 and 2007, as well as ongoing work, and addresses issues  
raised and recommendations made regarding (1) Labor's		 
administration of the TAA program, (2) the challenges states face
in providing services to trade affected workers, (3) the factors 
that affect workers' use of the wage insurance and health	 
coverage benefits, and (4) the impact of using industrywide	 
certification approaches on the number of workers potentially	 
eligible for TAA.						 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-07-995T					        
    ACCNO:   A70766						        
  TITLE:     Trade Adjustment Assistance: Changes Needed to Improve   
States' Ability to Provide Benefits and Services to		 
Trade-Affected Workers						 
     DATE:   06/14/2007 
  SUBJECT:   Allocation (Government accounting) 		 
	     Employee training					 
	     Employment assistance programs			 
	     Federal aid programs				 
	     Federal funds					 
	     Federal/state relations				 
	     Funds management					 
	     International trade				 
	     Manufacturing industry				 
	     Program evaluation 				 
	     Training utilization				 
	     Eligibility criteria				 
	     Certification (occupational)			 
	     Income insurance					 
	     Policies and procedures				 
	     Trade Adjustment Assistance Program		 

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GAO-07-995T

   

     * [1]Background

          * [2]TAA Benefits and Services
          * [3]TAA Certification Process and Eligibility Requirements
          * [4]Training Funds
          * [5]TAA Performance Reporting System

     * [6]Labor Could Improve Its TAA Program Administration

          * [7]Labor's Policies for Allocating Training Funds Present Chall
          * [8]TAA Data Do Not Provide a Complete and Credible Picture of t

     * [9]States Face Challenges in Providing Services to Workers

          * [10]Limited Flexibility in Use of Training Funds Hinders Case Ma
          * [11]Training Deadline Can be Challenging and Confusing

     * [12]Several Factors Limit Participation in the Wage Insurance an

          * [13]Deadline to Find Employment and Other Requirements Limit Par
          * [14]Cost Is a Key Factor Limiting Participation in the Health Co

     * [15]Certification Applied Industrywide May Increase Number Eligi

          * [16]Extent of Increase in Eligible Workers Depends on How Additi
          * [17]Certifying Industries Subject to Trade Remedies Could Increa
          * [18]Potential Design and Implementation Challenges Exist

     * [19]Concluding Observations
     * [20]GAO Contacts and Staff Acknowledgments
     * [21]GAO's Mission
     * [22]Obtaining Copies of GAO Reports and Testimony

          * [23]Order by Mail or Phone

     * [24]To Report Fraud, Waste, and Abuse in Federal Programs
     * [25]Congressional Relations
     * [26]Public Affairs

Testimony before the Committee on Ways and Means, House of Representatives

United States Government Accountability Office

GAO

For Release on Delivery
Expected at 10:00 a.m. EDT
Thursday, June 14, 2007

TRADE ADJUSTMENT ASSISTANCE

Changes Needed to Improve States' Ability to Provide Benefits and Services
to Trade-Affected Workers

Statement of Sigurd R. Nilsen, Director
Education, Workforce, and Income Security Issues

GAO-07-995T

Mr. Chairman and Members of the Committee:

I am pleased to be here today to discuss the challenges states have faced
in implementing some aspects of the Trade Adjustment Assistance Act (TAA)
program. We have conducted a number of studies on the TAA program since
the program was last reauthorized in 2002, and my testimony today will
focus primarily on the results of that work as well as from our ongoing
work.1 Today I'll be talking about issues we identified and our
recommendations for improving the program.

The Trade Adjustment Assistance program, established in 1962 and
administered by the Department of Labor (Labor), is the nation's primary
program providing income support, job training, and other benefits for
manufacturing workers who lose their jobs as a result of international
trade. In fiscal year 2006, Congress appropriated about $655 million for
income support payments and another $220 million for training for
trade-affected workers. In 2002, Congress made a number of key changes
designed to expand benefits and decrease the time it takes to get workers
into services. Among the changes, the act

           o established a deadline for workers to enroll in training, after
           they have been laid off or their petition has been approved, in
           order to maintain eligibility for extended income support
           payments;
           o created a wage insurance benefit for workers age 50 and older,
           subsidizing the difference between the prior and new wages of some
           trade-affected workers who find reemployment quickly; and
           o created a health coverage tax credit to help trade-affected
           workers pay for health insurance.

In order for workers to receive TAA benefits and services, Labor must
certify that workers in a particular layoff have been adversely affected
by international trade. The certification process begins when a petition
is filed with Labor on behalf of a group of laid-off workers. Labor then
surveys the firm undergoing the layoff and its customers and also reviews
data on the firm's industry to determine whether it meets the criteria for
certification. Congress is now considering approaches that would
facilitate certifying entire industries for TAA. One approach being
considered would make an industry eligible to be investigated for possible
certification when Labor certifies three petitions from that industry
within 180 days. An investigation would determine whether the entire
industry has been affected by trade and, therefore, whether workers in any
future layoff in that industry should automatically be eligible for TAA.

1 For further information on TAA, please see the following reports: GAO,
Trade Adjustment Assistance: Changes to Funding Allocation and Eligibility
Requirements Could Enhance States' Ability to Provide Benefits and
Services, [27]GAO-07-701 , [28]GAO-07-702 (Washington, D.C.: May 31,
2007); Trade Adjustment Assistance: Labor Should Take Action to Ensure
Performance Data Are Complete, Accurate, and Accessible, [29]GAO-06-496
(Washington, D.C.: Apr. 25, 2006); Trade Adjustment Assistance: Most
Workers in Five Layoffs Received Services, but Better Outreach Needed on
New Benefits, [30]GAO-06-43 (Washington, D.C.: Jan. 31, 2006); and Trade
Adjustment Assistance: Reforms Have Accelerated Training Enrollment, but
Implementation Challenges Remain, [31]GAO-04-1012 (Washington, D.C.: Sept.
22, 2004).

In preparation for reauthorizing the program, you asked us to provide
information on some of the key issues identified in our work that should
be addressed in reauthorization. In addition, you asked us to analyze the
impact of an alternative industrywide approach to certifying TAA
petitions. My testimony today will provide information and highlight our
recommendations on (1) Labor's administration of the TAA program, (2) the
challenges states face in providing services to trade-affected workers,
(3) the factors that affect workers' use of the wage insurance and health
coverage benefits, and (4) the impact of using industrywide certification
approaches on the number of workers potentially eligible for TAA.

To address the first objective, we drew upon our most recent report and a
2006 report on TAA performance data.2 Our recent report was based, in
part, on a survey of the 46 states that received an initial allocation of
TAA training funds in federal fiscal year 2006, and a supplemental survey
to collect additional financial information on fiscal year 2006 training
expenditures and obligations. Information on performance data is based
primarily on a survey of 46 states conducted between November 2005 and
January 2006 and on site visits to five states--California, Iowa, Ohio,
Texas, and Virginia. To answer the second and third objectives, we
interviewed Labor and Internal Revenue Service (IRS) officials and visited
state and local officials in four states--California, Massachusetts,
Michigan, and North Carolina. We also analyzed Labor's quarterly activity
reports and IRS's data on the health coverage benefit. To address the
fourth objective, we interviewed officials at Labor and the International
Trade Commission and analyzed Labor's data on TAA petitions from calendar
year 2003 to 2005, the Bureau of Labor Statistics' Mass Layoff Statistics
data, and the Census Bureau's data on trade and production, as well as the
International Trade Commission's data on trade remedies. We conducted our
work in accordance with generally accepted government auditing standards.

2 [32]GAO-07-701 , [33]GAO-07-702 , [34]GAO-06-496 .

In summary, our work shows that Labor could improve the way it administers
the program in two key areas--the process it uses to allocate training
funds to states and its tracking of program outcomes. Labor's process for
allocating training funds does not adequately reflect the current demand
for training services in the state, and Labor distributes additional funds
to states regardless of whether they need them. Regarding program
outcomes, we found that TAA performance data are incomplete and may be
inaccurate. For example, only half the states are including all
participants, as required by Labor. States face challenges in providing
services to workers, including the lack of flexibility to use training
funds to provide trade-affected workers with case management services,
such as counseling to help them decide whether they need training and
which training would be most appropriate. States receive no TAA program
funds for case management and must either use their limited administrative
funds or seek resources from other programs, such as those funded by the
Workforce Investment Act (WIA). States also reported that their efforts to
enroll workers in training are sometimes hampered by the training
enrollment deadline and that workers find the deadline confusing. Few TAA
participants take advantage of the wage insurance and health coverage
benefits, and several factors limit participation. For example, several
states reported that the requirement that workers must find a job within
26 weeks to receive the wage insurance benefit was the major factor
preventing more workers from taking advantage of the benefit. Regarding
the health coverage benefit, several states told us that high
out-of-pocket costs may discourage workers from using the benefit.
Finally, an industry certification approach based on three petitions
certified within any 180-day period would likely increase the number of
workers eligible for TAA-- potentially doubling those eligible--but also
presents some design and implementation challenges. For example, using an
industrywide approach raises the possibility that workers who have not
been affected by trade will be certified. We made a number of
recommendations to Labor to address the issues we identified, as well as
suggested that Congress make changes during reauthorization to improve the
program.

Background

The TAA program was designed to assist workers who have lost their jobs as
a result of international trade. The program provides two primary benefits
to these workers--training and extended income support. In addition, as a
result of the TAA Reform Act of 2002, workers also have access to wage
insurance and health coverage benefits. In order to be eligible for any of
these benefits, Labor must certify that a layoff was trade affected.

TAA Benefits and Services

Under TAA, workers enrolled in the program have access to a variety of
benefits and services, including the following:

Training. Participants may receive up to 130 weeks of training, including
104 weeks of vocational training and 26 weeks of remedial training, such
as English as a second language.

Extended income support. Participants may receive a total of 104 weeks of
extended income support beyond the 26 weeks of unemployment insurance (UI)
benefits available in most states.

Job search and relocation benefits. Payments are available to help
participants search for a job in a different geographical area and to
relocate to a different area to take a job.

Wage insurance benefit. The wage insurance benefit, known as the
Alternative Trade Adjustment Assistance (ATAA) program, was created by the
TAA Reform Act of 2002 as a demonstration project for workers age 50 or
older and those who find reemployment within 26 weeks of being laid off
that pays less than $50,000 and less than what they previously earned.
Workers who meet these criteria are eligible to receive 50 percent of the
difference between their new and old wages, up to a maximum of $10,000
over 2 years. For the fiscal year 2008 budget request, Labor estimated
wage insurance benefits at $23 million.

Health coverage benefit. The health coverage benefit, known as the Health
Coverage Tax Credit (HCTC) and also created by the TAA Reform Act, helps
workers pay for health care insurance through a tax credit.3 Workers can
choose to receive the benefit in one of two ways--as an advance option
that covers 65 percent of their monthly premiums, allowing them to lower
the amount they have to pay out of pocket for health coverage, or as an
end-of-year tax credit that is claimed on their income taxes. To be
eligible for the health coverage benefit, workers must either be (1)
receiving extended income support payments or eligible for extended income
support but still receiving UI payments, or (2) receiving the wage
insurance benefit. IRS administers the health coverage tax credit program.
There are three health plan options that are automatically eligible: COBRA
continuation plans,4 coverage through the worker's spouse, and individual
market plans purchased by the worker. In addition, the TAA Reform Act also
allows states to designate other coverage alternatives--called
state-qualified options.

3 The Trade Adjustment Assistance Reform Act of 2002 created a health
coverage tax credit for certain workers who are eligible to receive income
support benefits under the TAA program because their jobs were lost due to
foreign competition and for certain retirees whose pensions from a former
employer were terminated and are now paid by the Pension Benefit Guaranty
Corporation (PBGC).

TAA Certification Process and Eligibility Requirements

Currently, Labor certifies workers for TAA on a layoff-by-layoff basis.
Petitions may be filed by the employer experiencing the layoff, a group of
at least three affected workers, a union, or the state or local workforce
agency. Labor investigates whether a petition meets the requirements for
TAA certification and is required to either certify or deny the petition
within 40 days of receiving it.

The TAA statute lays out certain basic requirements for petitions to be
certified, including that a significant proportion of workers employed by
a company be laid off or threatened with layoff and that affected workers
must have been employed by a company that produces articles. In addition,
a petition must demonstrate that the layoff is related to international
trade in one of several ways, including the following:

           o Increased imports--imports of articles that are similar to or
           directly compete with articles produced by the firm have
           increased, the sales or production of the firm has decreased, and
           the increase in imports has contributed importantly to the decline
           in sales or production and the layoff or threatened layoff of
           workers.
           o Shift of production--the firm has shifted production of an
           article to another country, and either

                        o the country is party to a free trade agreement with
                        the United States or
                        o the country is a beneficiary under the Andean Trade
                        Preference Act, the African Growth and Opportunity
                        Act, or the Caribbean Basin Economic Recovery Act or
                        o there has been or is likely to be an increase in
                        imports of articles that are similar to or directly
                        compete with articles produced by the firm.

4 Under the Consolidated Omnibus Budget Reconciliation Act (COBRA) of
1985, certain employers with 20 or more employees are required to make
available 18 to 36 months of continued health care coverage for former
employees and their dependents who lose health coverage due to certain
circumstances, such as when a worker is laid off.

Labor investigates whether each petition meets the requirements for TAA
certification by taking steps such as surveying officials at the
petitioning firm, surveying its customers, and examining aggregate
industry data. When Labor has certified a petition, it notifies the
relevant state, which has responsibility for contacting the workers
covered by the petition, informing them of the benefits available to them,
and telling them when and where to apply for benefits.

Training Funds

Approximately $220 million is available annually for training, and states
have 3 years to spend these funds. Thus fiscal year 2006 funds must be
used by the end of fiscal year 2008. Each year Labor allocates 75 percent
of the training funds to states according to a formula that takes into
consideration several factors, including the average amount of training
funds allocated to states, reported accrued training expenditures, and the
average number of training participants over the previous 2 1/2 years. In
addition, to minimize year-to-year fluctuations in state funding, Labor
uses a hold harmless policy that ensures that each state's initial
allocation is at least 85 percent of the initial allocation received in
the previous year. In fiscal year 2006, Labor initially allocated $165
million of training funds to 46 states. To cover administrative costs,
Labor allocates to each state an additional 15 percent of its training
allocation. Labor holds the remaining 25 percent in reserve to distribute
to states throughout the year according to need as they experience
unexpected large layoffs.

TAA Performance Reporting System

Labor is responsible for monitoring the performance of the TAA program.
States are required to submit information on exiting participants through
the Trade Act Participant Report (TAPR) each quarter. The TAPR data
submitted by states are used to calculate national and state outcomes on
the TAA performance measures for each fiscal year, which include
reemployment rate, retention rate, and wage replacement rate. Unlike other
training programs, like WIA, TAA has no individual state performance
goals, and states do not receive incentives or sanctions based on their
performance levels, nor are they otherwise held accountable for their
performance. In addition to submitting TAPR data, states also submit data
to Labor on TAA services and expenditures each quarter.

Labor Could Improve Its TAA Program Administration

Labor could improve the way it administers the program in two key
areas--the process it uses to allocate training funds and its tracking of
program outcomes. Labor's process for allocating training funds presents
two significant challenges to states. First, the amount states receive at
the beginning of the fiscal year does not adequately reflect states'
spending the year before or the current demand for training services in
the state. Second, Labor distributes a significant amount of funds to most
states on the last day of the fiscal year, even to states that have spent
virtually none of their current year's allocation. In addition the
performance information that Labor makes available on the TAA program does
not provide a complete and credible picture of the program's performance.
For example, only half the states are including all participants, as
required, in the performance data they submit to Labor.

Labor's Policies for Allocating Training Funds Present Challenges to States in
Managing Their Funds

Labor's process for allocating training funds does not adequately
recognize the episodic nature of layoffs or the extent to which states
have used their previous year's allocations. Labor allocates 75 percent of
TAA training funds based upon a formula that takes into account
expenditures and participation over the previous 2 1/2 years. The
year-to-year fluctuation in layoffs within a state may result in states
receiving more or less funds than they actually need. For example, the
estimated number of trade-affected workers being laid off declined
dramatically in Kansas from fiscal years 2004 to 2005 and increased
somewhat in 2006. Overall the estimated number of trade-affected workers
in Kansas laid off in fiscal year 2006 represented about an 80 percent
decrease from 2004. On the other hand, Missouri experienced an 80 percent
increase in the number of trade-affected workers being laid off between
fiscal years 2004 and 2006 (see fig. 1). Kansas used hardly any of its
fiscal year 2006 training fund allocation, while Missouri used virtually
all of its. Despite these trends, both states received about 15 percent
less in fiscal year 2007 than they received in 2006.

Figure 1: Fluctuation in Estimated Number of Trade-Affected Workers Laid
Off from Fiscal Years 2004 to 2006 in Kansas and Missouri

While the 46 states responding to our survey reported using (spending or
obligating), on average, about 62 percent of their fiscal year 2006
training funds during the fiscal year, the percentage of funds states
expended and obligated varied widely. Thirteen of the states reported
using less than 1 percent of their fiscal year 2006 funds for training,
while 9 states reported using more than 95 percent of their fiscal year
2006 training funds(see fig. 2). The amount individual states reported
using ranged from 0 percent in several states to about 230 percent in 1
state.

Figure 2: States with High and Low Use of Fiscal Year 2006 Training Funds

A particular problem with Labor's allocation process is the hold harmless
policy, which guarantees that each state receives no less than 85 percent
of what it received in the previous year. While this policy is intended to
minimize significant fluctuations in state funding from prior years, it
awards states comparable training funds without recognition of the
previous year's expenditures or obligations. For example, the 13 states
that used less than 1 percent of the fiscal year 2006 funds received
nearly $41 million in fiscal year 2007--an amount slightly less than they
received in fiscal year 2006. Moreover, 5 of the 13 states received a
larger allocation in fiscal year 2007 than they received in 2006.

Labor distributes a significant amount of funds to most states on the last
day of the fiscal year, regardless of whether states need these additional
funds. Labor distributed end-of-year funds to 48 states, including about
$5 million to states that had spent or obligated less than 1 percent of
their initial fiscal year 2006 allocation.5 Labor distributes these funds
to each state based upon a calculation that takes into account the amount
of training funds each state received from its initial allocation plus any
additional amount it received during the year.6 According to Labor
officials, all states will receive an end-of-year allocation unless a
state specifically informs Labor it does not want any additional funds or
if it had not received any funds at all during the year. Waiting until the
last day of the fiscal year to distribute training funds to states does
not reflect good planning or management of program funds. Labor officials
agreed that the distribution of reserve training funds could be improved
so that more funds are disbursed throughout the year rather than on the
last day. Officials also acknowledged that states that have not spent or
obligated any of their initial allocation probably should not receive
additional training funds at the end of the year.

In our recent report, we recommended that the Secretary of Labor develop
procedures to better allocate training funds and ensure that any reserve
funds are given to only those states that have spent or obligated a
substantial portion of the current fiscal year allocation. In its
comments, Labor agreed with our findings and recommendations and noted
that it would examine the process for allocating training funds to states.

TAA Data Do Not Provide a Complete and Credible Picture of the Program's
Performance

TAA performance data are incomplete and may be inaccurate. States report
that they are not including all TAA participants in their performance
data, despite Labor's requirement that all participants be included after
they exit the program. We found that only 23 of the 46 states we surveyed
reported that they are including all exiting participants in their
submissions to Labor. In general, states have information on those in
training, but may not systematically track those who receive other
assistance, but not training. Furthermore, Labor does not have a process
in place to ensure that states are including all exiting TAA participants
in their reporting submissions. Despite the importance of accurately
identifying exiters, the exit dates themselves may not be accurate because
some states do not consistently obtain proper documentation to verify the
dates. Accurate exit dates are critical to TAA performance data for two
reasons. First, whether a participant exits determines if the individual
should be included in the state's report to Labor. Second, the actual exit
date determines when a participant's employment outcome will be assessed.

5 Hawaii and North Dakota did not receive end-of-the year funding because
these states received no training funds at all during the year.

6 For example, if Labor had distributed a total of $200 million in
training funds during the year and a state had received a total of $10
million (received $7 million from its initial training allocation and had
requested an additional $3 million during the year), then that state would
receive 5 percent of any reserve funds distributed at the end of the year.

Some states are not using all available data sources to determine TAA
participants' employment outcomes. Labor requires states to use UI wage
records to determine the employment outcomes of participants reported to
Labor. However, each state's wage record database includes only wage data
on workers within the state and does not have data on participants who
found employment in another state.

In our 2006 report, we made several recommendations to Labor to help
ensure that TAA participant data reported by states are consistent,
complete, and accurate, including issuing clarifying guidance. Labor has
taken some steps to share information with states and to improve data
quality. In fiscal year 2006, Labor distributed $250,000 to each state to
help them improve their TAA performance data systems, but it is too soon
to know whether their efforts will improve the quality of the data.

States Face Challenges in Providing Services to Workers

States report being challenged by the lack of flexibility to use training
funds to provide trade-affected workers with case management services,
such as counseling to help them decide whether they need training and what
type of training would be most appropriate. In addition, efforts to enroll
workers in training are sometimes hampered by the confusing TAA training
enrollment deadline that requires workers be enrolled in training within 8
weeks of certification or 16 weeks of layoff to qualify for extended
income support.

Limited Flexibility in Use of Training Funds Hinders Case Management Services

States also cited the lack of flexibility to use training funds to provide
trade-affected workers with case management services as a challenge.
Workers often need help making decisions about training--what type of
training to take or whether to enroll in training at all. Difficulty
funding case management services for trade-affected workers was a concern
among officials in the states we visited. For example, state officials in
one state said providing proper assessment, career counseling, and other
case management services was a real challenge and noted that additional
funds from other sources are limited. States do not receive TAA program
funds for case management and, by law, cannot use training funds for this
service. As a result, states must either use their limited TAA
administrative funds or use funds from other programs to pay for case
management, but there are limitations with these funding sources.

According to Labor officials, states are encouraged to co-enroll
participants in the Workforce Investment Act (WIA) program, and in Labor's
view states have sufficient WIA funds to pay for case management for TAA
participants. About three-fourths of the states reported in our survey
that they were able to utilize WIA funds to help pay for case management
services. Yet nearly half of the states also reported that coordination
with WIA was a challenge. For example, WIA funding may not always be
available for TAA workers, especially during a large layoff. Furthermore,
local officials in a state we visited said that while 85 percent of TAA
participants do co-enroll in WIA, a large layoff can strain funding and
makes it difficult for WIA to completely fund case management for
trade-affected workers.

States also reported limitations to using administrative funds to provide
case management. More than half of the states responding to our survey
reported the shortage of administrative funds as a challenge. One state
noted that its administrative funds are usually exhausted by the end of
the first quarter because of the amount of case management that is
required for the program. A local official in one state we visited said
that it uses Wagner-Peyser funds to pay for case management because not
enough TAA administrative funds are received and TAA training funds cannot
be used. As a result, only one case manager could be funded, and this one
person had to cover three counties and serve approximately 1,000 workers.
Moreover, officials in some of the states we visited cautioned that
administrative funds should not be used for case management because case
management is a program activity--any increase in the administrative limit
to pay for this service could lead to the misconception that the program
has too much overhead. These state officials noted that having the
flexibility to use TAA training funds for case management would alleviate
this concern.

In our recent report, we suggested that Congress may wish to consider
allowing a portion of TAA training funds to be used for case management
services to allow states greater flexibility in how they may use their TAA
funds to provide services to workers. Labor, however, contended that the
WIA, rather than TAA, should finance case management. We agree with Labor
that co-enrollment with WIA should be encouraged, but as our report points
out, WIA funds are not always available to provide this service,
especially during large layoffs. We believe that states would benefit from
having the option to use a portion of their training funds to defray the
costs of providing case management services to trade-affected workers.

Training Deadline Can be Challenging and Confusing

Efforts to enroll workers in training are sometimes hampered by the "8-16"
training enrollment deadline--that is, the requirement that workers be
enrolled in training within 8 weeks of certification or 16 weeks of
layoff, whichever is later, to qualify for extended income support. Nearly
three-quarters of the states responding to our survey reported that
enrolling workers in training by the 8-16 deadline was a challenge. For
example, one state noted that trying to enroll participants in training by
the 8-16 deadline is particularly challenging when dealing with large
layoffs because it is difficult to handle all the logistics, such as
notifying workers and setting up appointments, for a large number of
workers within the deadline. Moreover, officials in the four states we
visited also indicated that the deadline is very confusing to workers.
They told us that workers become confused about which point in time the 8
weeks or 16 weeks apply to and, as a result, are not sure when the clock
starts and stops. We previously reported that about three-fourths of
states responded that workers, at least occasionally, inadvertently miss
the deadline and consequently lose their eligibility for extended income
support.7 In that report, we recommended that Labor track the ability of
workers to meet the 8-16 deadline.8 As of April 2007, Labor had not yet
begun gathering information on the impact of the deadline. In our recent
report, we suggested that in order to make it easier for workers to comply
with the training enrollment deadline, Congress may wish to consider
simplifying the deadline by specifying a single time period that commences
when workers are laid off or petitions are certified, whichever is later.

Several Factors Limit Participation in the Wage Insurance and Health Coverage
Benefits

Several factors, including a short deadline for getting a job and the cost
of buying health coverage, may limit participation in two new benefits
resulting from the TAA Reform Act of 2002. In our site visits, states
reported that the requirement that workers must find a job within 26 weeks
to receive the wage insurance benefit was the major factor preventing more
workers from taking advantage of the benefit. An additional factor that
may limit participation in wage insurance by some older workers is the
requirement that for a group of workers to be certified as eligible, the
petitioning workers must have been laid off from a firm where the affected
workers lacked easily transferable skills and a significant portion of
those workers were aged 50 or over. While cost is one of the most
significant factors limiting participation in the health coverage benefit,
some states also reported that the health coverage tax credit program can
be complicated and difficult to understand for both workers and local case
managers.

7 [35]GAO-04-1012 .

8 GAO-06-43.

Deadline to Find Employment and Other Requirements Limit Participation in the
Wage Insurance Benefit

Few TAA participants take advantage of the wage insurance benefit.
According to Labor officials, in calendar year 2006, 6,316 workers
received the wage insurance benefit. The universe of workers eligible for
wage insurance cannot be estimated because data are not available on the
number of workers certified for TAA who are 50 years old or older and meet
the other eligibility requirements. However, two-thirds of the states we
surveyed reported that 5 percent or less of TAA participants received wage
insurance in fiscal year 2006.9 We previously reported in a study of five
layoffs that less than 20 percent of the workers potentially eligible for
the wage insurance benefit received it.10 In this study, we found that
workers' awareness of the wage insurance benefit varied greatly--many
workers who were 50 years old and older were simply unaware of the
benefit. While state or local officials told us they discussed the ATAA
benefit at rapid response meetings or TAA information meetings, workers
were often overwhelmed by the volume of information received after the
layoff, and didn't necessarily recall some of the specifics.

Although officials in the states we visited for our most recent study
believe the wage insurance benefit is beneficial to older workers close to
retirement, two key factors limit participation. Officials said that one
of the greatest obstacles to participation was the requirement for workers
to find a new job within 26 weeks after being laid off. For example,
according to officials in one state, 80 percent of participants who were
seeking wage insurance but were unable to obtain it because they failed to
find a job within the 26-week period. The challenges of finding a job
within this time frame may be compounded by the fact that workers may
actually have less than 26 weeks to secure a job if they are laid off
prior to becoming certified for TAA. For example, a local case worker in
one state we visited said that the 26 weeks had passed completely before a
worker was certified for the benefit.

9 This percentage is based on the total number of TAA participants because
the number of workers potentially eligible for the wage insurance benefit
is not readily available.

10 GAO-06-43.

Another factor that may limit participation by some older workers is the
requirement that, under the TAA Reform Act, for a group of workers to be
certified, they must have been laid off from a firm where the affected
workers lacked easily transferable skills and a significant portion were
aged 50 or over. Labor interprets a "significant portion" as the lesser of
5 percent of the affected workforce or 50 workers at a firm with 50 or
more workers, or at least 3 workers in a firm with fewer than 50 affected
workers. Labor investigates each petition to see if the firm meets the
requirements, and in fiscal year 2006, nearly 90 percent of TAA-certified
petitions were also certified for the wage insurance benefit. Labor
officials said that eliminating this step of the TAA certification
process--that is, allowing any TAA-certified workers who meet the
individual eligibility criteria for the wage insurance benefit to
participate--would decrease the agency's investigation workload somewhat
and may increase participation in the wage insurance benefit.

Labor officials told us they are taking steps to overcome the lack of
awareness of wage insurance and promote the benefit by informally
encouraging states to ensure case workers talk about wage insurance during
one-on-one case management sessions. Furthermore, in our most recent
report, we suggested that in order to enable more workers to take
advantage of the wage insurance benefit, Congress may wish to consider
increasing the length of time workers have to become reemployed and
eliminating the requirement that to be certified as eligible for wage
insurance, the petitioning workers must have been laid off from a firm
where the affected workers lacked easily transferable skills and a
significant portion of those workers were aged 50 or over.

Cost Is a Key Factor Limiting Participation in the Health Coverage Benefit

The high cost of the health coverage benefit to participants is the
greatest barrier to higher participation. State officials said that many
laid-off workers cannot afford to pay 35 percent of their health care
premiums while their primary income is unemployment insurance benefits.
IRS officials reported that the workers' 35 percent share is among the
primary barriers to participation in the benefit. For example, in the four
states we visited, the average monthly premium for COBRA policies covering
two or more individuals was about $800. The workers' out-of-pocket cost
for COBRA coverage in these states would be nearly one-fourth of their
monthly UI payment (see table 1).

Table 1: Comparison of Average Monthly Premiums

                                                    Workers' 35               
                     Average      Average monthly percent share Percentage of 
                  monthly UI    COBRA premium for    of monthly    monthly UI 
State             payment          two or more       premium       payment 
California         $1,176                 $777          $272            23 
Massachusetts       1,465                  895           313            21 
Michigan            1,161                  737           258            22 
North Carolina      1,074                  770           270            25 
Average             1,219                  795           278            23 

Source: Source: GAO analysis of UI data from states and average COBRA
premiums from IRS.

State-qualified plans are similarly expensive and are often more expensive
than COBRA coverage. Currently, 43 states have such plans, which, among
other requirements, must provide for preexisting conditions. For example,
in one state we visited, the premium for the state-qualified plan for a
family was about $940 per month, while the average COBRA premium was about
$740 per month. The worker's share of the state-qualified premium was
about $330---or about 30 percent of the UI benefit--compared to about $260
for COBRA coverage.

In addition, there is currently a period of up to about 3 months where
workers must cover the full cost of their health premiums before beginning
to receive the advance credit, and these costs are not reimbursable. IRS
officials reported that inability to pay the out-of-pocket costs between
layoff and application for the advance credit is one of the reasons
workers lose eligibility and may be denied the benefit.

While cost is one of the most significant factors limiting participation
in the health coverage benefit, some states also reported that the health
coverage tax credit program can be complicated and difficult to understand
for both workers and local case managers. In our survey, nearly two-thirds
of the states reported that limited IRS guidance on the benefit was still
a challenge. Furthermore, during our site visits, some state and local
officials said that they are not experts on the health coverage benefit
and do not know enough details of the benefit to get information out to
workers and to assist them with the enrollment process. In some local
areas, case managers we interviewed said that they provide minimal
information about the benefit and primarily refer workers to pamphlets or
the IRS call center for details. We previously reported on the complexity
of the health coverage benefit, noting that the process for workers to
become eligible and enroll for the benefit was fragmented and difficult to
navigate.11 In that report, we recommended to several agencies, including
Labor and IRS, that a centralized resource be made available at the time
individuals must make decisions about purchasing qualifying health
coverage and meeting other eligibility requirements. In February 2007, IRS
began distributing to all workers covered by a petition a more simplified
program kit for the health coverage benefit.

Certification Applied Industrywide May Increase Number Eligible, but
Implementation Challenges Exist

Two alternatives are being considered that would expand the current firm
by firm petition certification approach. One approach being considered
would make an industry eligible to be investigated for possible
certification when Labor certifies three petitions from that industry
within 180 days. Another approach would require certification of an
industry once a trade remedy had been applied.12 An industry certification
approach based on three petitions certified within 180 days would likely
increase the number of workers eligible for TAA, but the extent of the
increase depends upon the specific criteria that are used. Using trade
remedies for industrywide certification could also result in expanded
worker eligibility for TAA in a number of industries, but the extent is
uncertain. As we identify in our forthcoming report, either approach
presents some design and implementation challenges.13

Extent of Increase in Eligible Workers Depends on How Additional Criteria Are
Set

From 2003 to 2005, 222 industries had three petitions certified within 180
days and therefore would have triggered an investigation to determine
whether an entire industry should be certified, if such an approach had
been in place at that time. These industries represented over 40 percent
of the 515 industries with at least one TAA certification in those 3 years
and included 71 percent of the workers estimated to be certified for TAA
from 2003 to 2005.14 The 222 are a diverse set of industries, including
textiles, apparel, wooden household furniture, motor vehicle parts and
accessories, certain plastic products, and printed circuit boards.

11GAO, Health Coverage Tax Credit: Simplified and More Timely Enrollment
Process Could Increase Participation. [36]GAO-04-1029 . (Washington, D.C.:
September 30, 2004).

12 Trade remedies include, for example, a duty imposed on an imported
product because the industry had been injured by unfair trade practices.

13 For more detailed information on our analysis, see our forthcoming
report, Trade Adjustment Assistance: Industry Certification Would Likely
Make More Workers Eligible, but Design and Implementation Challenges
Exist. GAO-07-919. (Washington, D.C.: forthcoming).

14 These industries are classified according to the four-digit Standard
Industrial Classification (SIC) System codes.

The proposals for this approach would require that, once an industry meets
the three-petition criterion, Labor investigate to determine whether there
is evidence of industrywide trade effects. Not all 222 industries would
likely be certified industrywide. In its investigation, Labor would use
additional criteria and likely consider such factors as the extent to
which an industry has been affected by imports, changes in production
levels in the industry, or changes in employment levels.

The number of workers that would become eligible for TAA through an
industry certification approach depends on what additional criteria are
established. We used information from the 69 industries for which we had
comprehensive data on petitions, unemployment, trade and production to
estimate the potential increases in eligible workers programwide.15 We
found that, if there were no additional criteria beyond three petitions
certified in 180 days, the overall number of workers eligible for TAA
might have nearly doubled, from about 118,000 to about 233,000 in 2005. If
the trade threshold were set at a 10 percent increase in the import share
of the domestic market, the number of eligible workers might have
increased by approximately 49 percent from 118,000 to about 175,000. If
certification were limited to industries with a 15 percent increase in any
1 year, the number of workers eligible for TAA might have increased by
approximately 27 percent to about 150,000. Finally, if the criterion was a
20 percent increase in the import share in any 1 year, the number of
workers might have increased by about 22 percent, to 144,000. More
stringent criteria would result in a smaller increase in the number of
workers eligible for TAA.16

15 Of the 222 industries, we analyzed 69 for which we had complete data.
The data available used different classification systems that we matched
to each other, but we only included data for which we had complete and
well-defined matches. Since the 69 industries were not drawn from a random
sample, the results of this analysis are not necessarily representative of
the entire 222 industries.

16 Our analysis applied the same threshold to all industries. In practice,
the criteria would likely vary by industry in order to take into account
industry-specific patterns in trade and other economic factors.

Certifying Industries Subject to Trade Remedies Could Increase Eligible
Population, but the Extent Is Uncertain

Using trade remedies for industrywide certification could result in
expanded worker eligibility for TAA in a number of industries. The number
of workers eligible for TAA might increase under this approach in areas in
which there have been few or no TAA petitions. For example, even though
ITC found that domestic producers of certain kinds of orange juice had
been injured by imports, there appear to be no TAA petitions for workers
producing orange juice.17

However, the number of workers eligible for TAA may not increase
substantially in some areas, in part because of overlap between trade
remedies and TAA petitions. For example, over half of outstanding
antidumping and countervailing duty orders are for iron and steel
products, for which hundreds of TAA petitions have been certified. In
addition, industries with trade remedies may not necessarily have
experienced many trade-related job losses because the International Trade
Commission (ITC) does not focus on employment when determining whether an
industry has been injured, according to an ITC official. Furthermore,
trade remedies are intended to mitigate the trade-related factors that
caused the injury to the industry, so employment conditions in an industry
could improve after the trade remedy is in place.

It is difficult to estimate the extent that industry certification based
on trade remedies would increase the number of workers eligible for TAA
because trade remedies are imposed on specific products coming from
specific U.S. trade partners, and data are not available on job losses at
such a detailed level. The product classifications for a given trade
remedy can be very narrow, such as a dye known as "carbazole violet
pigment 23" or "welded ASTM A-312 stainless steel pipe."

Potential Design and Implementation Challenges Exist

Although industry certification based on three petitions certified in 180
days is likely to increase the number of workers eligible for TAA, it also
presents several potential challenges.

           o Designing additional criteria for certification. Any
           industrywide approach raises the possibility of certifying workers
           who were not adversely affected by trade. Even in industries that
           are heavily affected by trade, workers could lose their jobs for
           other reasons, such as the work being relocated domestically. In
           addition, using the same thresholds for all industries would not
           take into account industry-specific patterns in trade and other
           economic factors.

           o Determining appropriate duration of certification. Determining
           the length of time that an industry would be certified may also
           present challenges. If the length of time is too short, Labor may
           bear the administrative burden of frequently re-investigating
           industries that continue to experience trade-related layoffs after
           the initial certification expires. However, if the time period is
           too long, workers may continue to be eligible for TAA even if
           conditions change and an industry is no longer adversely affected
           by trade.

           o Defining the industries. How the industries are defined would
           significantly affect the number of workers who would become
           eligible for TAA through an industry certification approach. Our
           analysis defined industries according to industry classification
           systems used by government statistical agencies. However, some of
           these industry categories are broad and may encompass products
           that are not adversely affected by trade.

           o Notifying workers and initiating the delivery of services.
           Notifying workers of their eligibility for TAA has been a
           challenge and would continue to be under industry certification.
           Under the current certification process, workers are linked to
           services through the petition process. The specific firm is
           identified on the petition application, and state and local
           workforce agencies work through the firm to reach workers in
           layoffs of all sizes. For industry certification, however, there
           are no such procedures in place to notify all potentially eligible
           workers in certified industries. For large layoffs in a certified
           industry, agencies could make use of the existing Worker
           Adjustment and Retraining Notification (WARN) notices to connect
           with workers.18 However, in smaller layoffs in certified
           industries, or when firms do not provide advance notice, workforce
           agencies may not know that the layoff has occurred.19

           o Verifying worker eligibility. Verifying that a worker was laid
           off from a job in a certified industry to ensure that only workers
           eligible for TAA receive TAA benefits may be more of a challenge
           under industry certification than under the current system. For
           example, it may be difficult to identify the specific workers who
           made a product in the certified industry if their employer also
           makes products that are not covered under industrywide
           certification. In addition, determining who should conduct this
           verification may also present challenges. A centralized process
           conducted by Labor would likely be unwieldy, while verification by
           state or local workforce agencies could take less time, but
           ensuring consistency across states might prove challenging.

17 We cannot be certain about the degree of overlap between TAA petitions
and trade remedy products because product information is not recorded in a
standardized way in Labor's petitions data.

18 The WARN Act requires employers to give their employees or their
representatives, the state's dislocated worker unit, and local government
officials 60 days advance notice of a mass layoff or plant closure.
Generally speaking, the WARN Act applies to employers with 100 or more
full-time workers involved in layoffs or plant closures that affect 50 or
more workers.

An approach using trade remedies presents some of the same challenges as
an industry certification approach based on three petitions certified in
180 days.

Concluding Observations

Through our work on the Trade Adjustment Assistance Program since passage
of the Reform Act in 2002 we have identified a number of areas where Labor
and the Congress should take action. Taking steps to limit confusion, ease
restrictions, and provide support for case management would facilitate
workers' access to services and benefits. States' ability to assist these
workers would be enhanced by an improved process for allocating training
funds.

Mr. Chairman, this concludes my prepared statement. I will be happy to
respond to any questions you or other members of the committee may have at
this time.

19 In a 2003 report on the WARN Act, GAO found that employers provided
notice for an estimated 36 percent of mass layoffs or plant closures that
appeared subject to WARN's advance notice requirements. GAO, The Worker
Adjustment and Retraining Notification Act: Revising the Act and
Educational Materials Could Clarify Employer Responsibilities and Employee
Rights, [37]GAO-03-1003 (Washington, D.C.: Sept. 19, 2003).

GAO Contacts and Staff Acknowledgments

For information regarding this testimony, please contact Sigurd R. Nilsen,
Director, Education, Workforce, and Income Security Issues, at (202)
512-7215. Individuals who made key contributions to this testimony include
Dianne Blank, Wayne Sylvia, Yunsian Tai, Michael Hoffman, and Rhiannon
Patterson.

Related GAO Products

Trade Adjustment Assistance: Changes to Funding Allocation and Eligibility
Requirements Could Enhance States' Ability to Provide Benefits and
Services. [38]GAO-07-701 , [39]GAO-07-702 . (Washington, D.C.: May 31,
2007).

Trade Adjustment Assistance: New Program for Farmers Provides Some
Assistance, but Has Had Limited Participation and Low Program
Expenditures. [40]GAO-07-201 . (Washington, D.C.: December 18, 2006).

National Emergency Grants: Labor Has Improved Its Grant Award Timeliness
and Data Collection, but Further Steps Can Improve Process. [41]GAO-06-870
. (Washington, D.C.: September 5, 2006).

Trade Adjustment Assistance: Labor Should Take Action to Ensure
Performance Data Are Complete, Accurate, and Accessible. [42]GAO-06-496 .
(Washington, D.C.: April, 25, 2006).

Trade Adjustment Assistance: Most Workers in Five Layoffs Received
Services, but Better Outreach Needed on New Benefits. [43]GAO-06-43 .
Washington, D.C.: January 31, 2006.

Workforce Investment Act: Substantial Funds Are Used for Training, but
Little Is Known Nationally about Training Outcomes. [44]GAO-05-650 .
Washington, D.C.: June 29, 2005.

Trade Adjustment Assistance: Reforms Have Accelerated Training Enrollment,
but Implementation Challenges Remain. [45]GAO-04-1012 . Washington, D.C.:
September 22, 2004.

Workforce Investment Act: Better Guidance and Revised Funding Formula
Would Enhance Dislocated Worker Program. [46]GAO-02-274 . Washington,
D.C.: February 11, 2002.

(130785)

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Highlights of [54]GAO-07-995T , a testimony before the Committee on Ways
and Means, House of Representatives

June 14, 2007

TRADE ADJUSTMENT ASSISTANCE

Changes Needed to Improve States' Ability to Provide Benefits and Services
to Trade-Affected Workers

The Trade Adjustment Assistance (TAA) program, administered by the
Department of Labor (Labor), is the nation's primary program providing
income support, job training, and other benefits to manufacturing workers
who lose their jobs as a result of international trade. In fiscal year
2006, Congress appropriated about $900 million for TAA, including about
$220 million for training. GAO has conducted a number of studies on the
TAA program since the program was last reauthorized in 2002. This
testimony draws upon the results of two of those reports, issued in 2006
and 2007, as well as ongoing work, and addresses issues raised and
recommendations made regarding (1) Labor's administration of the TAA
program, (2) the challenges states face in providing services to trade
affected workers, (3) the factors that affect workers' use of the wage
insurance and health coverage benefits, and (4) the impact of using
industrywide certification approaches on the number of workers potentially
eligible for TAA.

Labor could improve the way it administers the program in two key
areas--the process it uses to allocate training funds and its tracking of
program outcomes. Labor's process for allocating training funds presents
two significant challenges to states. First, the amount states receive at
the beginning of the fiscal year does not adequately reflect the current
demand for training services in the state. Second, Labor distributes a
significant amount of funds to most states on the last day of the fiscal
year, even to states that have spent less than 1 percent of the current
fiscal year training allocation. Regarding program outcomes, TAA
nationwide performance data are incomplete and may be inaccurate. We
recommended that Labor develop procedures to better allocate the training
funds and improve data. Labor recently noted that it would examine its
processes.

States face challenges in providing services to workers, including the
lack of flexibility to use training funds to provide trade-affected
workers with case management services, such as counseling to help them
decide whether they need training and which training would be most
appropriate. States receive no TAA program funds for case management and
must either use their limited administrative funds or seek resources from
other programs, such as those funded by the Workforce Investment Act.
States also reported that their efforts to enroll workers in training are
sometimes hampered by the training enrollment deadline and that workers
find the deadline confusing. We have suggested that Congress consider
providing states the flexibility to use training funds for case management
and simplifying the training enrollment deadline.

Few TAA participants take advantage of the wage insurance and health
coverage benefits, and several factors limit participation. For example,
several states reported that the requirement that workers must find a job
within 26 weeks to receive the wage insurance benefit was the major factor
preventing more workers from taking advantage of the benefit. Regarding
the health coverage benefit, several states told us that high
out-of-pocket costs may discourage workers from using the benefit.
Furthermore, states also reported that the health coverage benefit can be
complicated and difficult to understand. We have suggested that the
Congress may wish to consider increasing the length of time workers have
to become eligible for wage insurance. In addition, we also recommended
that a centralized resource be developed to assist workers with their
questions about health coverage. In response, the agency has developed new
simplified materials.

Finally, an industry certification approach based on three petitions
certified within any 180-day period would likely increase the number of
workers eligible for TAA, potentially doubling those eligible. The
approach also presents some design and implementation challenges.

References

Visible links
  27. http://www.gao.gov/cgi-bin/getrpt?GAO-07-701
  28. http://www.gao.gov/cgi-bin/getrpt?GAO-07-702
  29. http://www.gao.gov/cgi-bin/getrpt?GAO-06-496
  30. http://www.gao.gov/cgi-bin/getrpt?GAO-06-43
  31. http://www.gao.gov/cgi-bin/getrpt?GAO-04-1012
  32. http://www.gao.gov/cgi-bin/getrpt?GAO-07-701
  33. http://www.gao.gov/cgi-bin/getrpt?GAO-07-702
  34. http://www.gao.gov/cgi-bin/getrpt?GAO-06-496
  35. http://www.gao.gov/cgi-bin/getrpt?GAO-04-1012
  36. http://www.gao.gov/cgi-bin/getrpt?GAO-04-1029
  37. http://www.gao.gov/cgi-bin/getrpt?GAO-03-1003
  38. http://www.gao.gov/cgi-bin/getrpt?GAO-07-701
  39. http://www.gao.gov/cgi-bin/getrpt?GAO-07-702
  40. http://www.gao.gov/cgi-bin/getrpt?GAO-07-201
  41. http://www.gao.gov/cgi-bin/getrpt?GAO-06-870
  42. http://www.gao.gov/cgi-bin/getrpt?GAO-06-496
  43. http://www.gao.gov/cgi-bin/getrpt?GAO-06-43
  44. http://www.gao.gov/cgi-bin/getrpt?GAO-05-650
  45. http://www.gao.gov/cgi-bin/getrpt?GAO-04-1012
  46. http://www.gao.gov/cgi-bin/getrpt?GAO-02-274
  47. http://www.gao.gov/
  48. http://www.gao.gov/
  49. http://www.gao.gov/fraudnet/fraudnet.htm
  50. mailto:[email protected]
  51. mailto:[email protected]
  52. mailto:[email protected]
  53. http://www.gao.gov/cgi-bin/getrpt?GAO-07-995T
  54. http://www.gao.gov/cgi-bin/getrpt?GAO-07-995T
*** End of document. ***