[Audit Report on Department of  Education Extended Day Program, Government of Guam]
[From the U.S. Government Printing Office, www.gpo.gov]

Report No. 99-i-455

Title: Audit Report on Department of  Education Extended Day Program, Government
       of Guam



Date:  May 11, 1999




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U.S. Department of the Interior
Office of Inspector General



AUDIT REPORT
DEPARTMENT OF EDUCATION
EXTENDED DAY PROGRAM,
GOVERNMENT OF GUAM


REPORT NO. 99-I-455

MAY 1999




MEMORANDUM

             TO:  The Secretary

           FROM:  Robert J. Williams
                  Acting Inspector General

SUBJECT SUMMARY:  Final Audit Report - "Department of 
                  Education Extended Day Program, 
                  Government of Guam" (No. 99-i-455)

Attached for your information is a copy of the subject final
audit report.   The objective of our audit was to determine
whether the Government of Guam's Department of Education complied
with Federal and local laws, grant agreements, and procedures
applicable to the Department of Education Extended Day Program.

We found that the Department did not ensure that elementary
school personnel administering the Program collected and
deposited all Program income and expended Program income only for
Program purposes; competitively procured goods and services; and
adequately accounted for and controlled Program property.   We
also found that the Department did not ensure that grant funds
were adequately accounted for and Federal reimbursement claims
were adequately documented.  These deficiencies occurred because
the Department (1) did not delegate responsibility to a
senior-level official to ensure that the Program complied with
applicable rules and regulations, had a high rate of school
personnel turnover, (2) did not have clear Program income
guidelines, and (3) did not provide adequate training or
supervision for accounting personnel.  As a result, during fiscal
years 1996, 1997, and 1998 (through June 30, 1998), Program
income of at least $31,670 may not have been deposited into
Program bank accounts and another $1,000 may have been collected
improperly, expenditures totaling $84,342 were not adequately
supported, additional expenditures totaling $137,552 were not
necessary or were made for purchases that did not benefit the
Program, there was no assurance that full value was received for
Program purchases totaling $64,107, nonexpendable property of
$3,050 could not be located or accounted  for, Federal grant
funds of $325,837 were lost, and expenditures of at least
$2,017,126 in Federal reimbursement claims were not supported.

We made 12 recommendations to correct these deficiencies.
However, because a response to the draft report was not received
from the Acting Director of Education, who was appointed to that
position on March 25, 1999, the recommendations are unresolved.

If you have any questions concerning this matter, please contact
me at (202) 208-5745.


Attachment
Write-up for the Semiannual Report

Insular Areas

Guam

We concluded that the Department did not comply with all
applicable laws, regulations, and other requirements applicable
to the Extended Day Program and that it needed to make
improvements in the management of the Program.  Specifically, the
Department did not ensure that elementary school personnel
administering the Program collected and deposited all Program
income and expended Program income only for Program purposes,
competitively procured goods and services, and adequately
accounted for and controlled Program property.  In addition, the
Department did not ensure that grant funds used to finance the
Program were adequately accounted for and that all claims for
Federal reimbursement for grant-related expenses were adequately
documented.

These conditions occurred because the Department had not
delegated responsibility and authority to a specific Departmental
office and/or senior-level official for ensuring that school
principals and staff were accountable for administering the
Program in compliance with applicable rules and regulations.  In
addition, the turnover of school personnel resulted in a lack of
continuity in the Program administration, and guidelines on the
use of Program fee income were unclear.  Further,  accounting
personnel were not adequately trained or supervised.

As a result, during fiscal years 1996, 1997, and 1998 (through
June 30), Program income of at least $31,670 may not have been
deposited into Program bank accounts and another $1,000 may not
have been improperly collected; expenditures totaling $84,342
from Program income were not adequately supported; and Program
expenditures totaling $137,552 were unnecessary or were for
equipment or personnel costs that did not directly benefit the
Program's students.  In addition, the Department could not ensure
that full value was received for Program purchases totaling
$64,107.  Further, six of the eight schools reviewed did not have
current inventories of property acquired with Program funds, and
two of the eight schools could not locate or account for
nonexpendable property totaling $3,050. The Department lost about
$325,837 in Federal grant funding from the fiscal year 1996 U.S.
Department of Education Consolidated Grant for Insular Areas and
could not support expenditures of at least $2,017,126 claimed for
reimbursement from the same grant for fiscal years 1996, 1997,
and 1998 (through June 30).

We made 12 recommendations to correct these deficiencies.
However, because a response to the draft report was not received
from the Acting Director of Education who was appointed on March
25, 1999, the recommendations remain unresolved.





                                             N-IN-GUA-004-97(D)-R


Honorable Carl T.C. Gutierrez
Governor of Guam
Office of the Governor
Hagatna, Guam 96932

Subject:  Audit Report on Department of 
          Education  Extended Day Program,
          Government of Guam (No. 99-i-455)

Dear Governor Gutierrez:

This report presents the results of our review of the Department
of Education Extended Day (DEED) Program, Government of Guam.
The objective of our audit was to determine whether the
Department of Education complied with Federal and local laws,
grant agreements, and procedures applicable to the Program.

We concluded that the Department did  not comply with all
applicable laws, regulations, and other requirements applicable
to the Extended Day Program and that it needed to make
improvements in the management of the Program.  Specifically, the
Department did not ensure that elementary school personnel
administering the Program collected and deposited all Program
income and expended Program income only for Program purposes,
competitively procured goods and services, and adequately
accounted for and controlled nonexpendable property.  In
addition, the Department did not ensure that grant funds used to
finance the Program were adequately accounted for and that claims
for Federal reimbursement for grant-related expenses were
adequately documented.

These conditions occurred because the Department had not
delegated responsibility and authority to a specific Departmental
office and/or senior-level official for ensuring that school
principals and staff were accountable for administering the
Program in compliance with applicable rules and regulations.  In
addition, the turnover of school personnel resulted in a lack of
continuity in Program administration, and guidelines on the use
of Program fee income were unclear.  Further, accounting
personnel were not adequately trained or supervised.

As a result, during fiscal years 1996, 1997, and 1998 (through
June 30), Program income of at least $31,670 may not have been
deposited into Program bank accounts and another $1,000 may have
been improperly collected; expenditures totaling $84,342 from
Program income were not adequately supported; and Program
expenditures totaling $137,552 were unnecessary or were made for
equipment or personnel costs that did not directly benefit the
Program's students.  In addition, the Department could not ensure
that full value was received for Program purchases totaling
$64,107.  Further, six of the eight schools reviewed did not have
current inventories of property acquired with Program funds, and
two of the eight schools could not locate or account for
nonexpendable property totaling $3,050.  The Department lost
about $325,837 in Federal grant funding from the fiscal year 1996
U.S. Department of Education Consolidated Grant for Insular Areas
and could not support expenditures of at least $2,017,126 claimed
for reimbursement from the same grant for fiscal years 1996,
1997, and 1998 (through June 30).  We made 12 recommendations to
correct the deficiencies identified.

We received a March 30, 1999, response to the draft report from
the then-Chairperson of the Board of Education, which generally
concurred with the report's 12 recommendations but disagreed with
our classification of fees collected from Program participants as
"program income."  However, on March 25, 1999, Guam Public Law
25-03 was enacted to return control of the Department of
Education to the Governor of Guam and eliminate the Board of
Education.  A new Acting Director of Education was subsequently
appointed by the Governor.  Because of these changes to the
Department's organization, we requested that the Acting Director
submit an updated response to the draft report by April 9, 1999.
However, a response was not provided.  Therefore, since this
final report is being issued without the benefit of the Acting
Director's response, all of the 12 recommendations are considered
unresolved (see Appendix 2).

The Inspector General Act, Public Law 95-452, Section 5(a)(3), as
amended, requires semiannual reporting to the U.S. Congress on
all audit reports issued, the monetary impact of audit findings
(Appendix 1), actions taken to implement audit recommendations,
and identification of each significant recommendation on which
corrective action has not been taken.

In view of the above, please provide a response, as required by
Public Law 97-357, to this report by June 11, 1999.  The response
should be addressed to our Pacific Office, 415 Chalan San
Antonio, Baltej Pavilion, Suite 306, Tamuning, Guam 96911.  The
response should provide the information requested in Appendix 2.

We appreciate the assistance provided by the Department of
Education in the conduct of our audit.

Sincerely,

Robert J. Williams
Acting Inspector General
cc: Director, Department of  Education


CONTENTS

                                                    Page

INTRODUCTION.......................................  1  

BACKGROUND.........................................  1  
OBJECTIVE AND SCOPE................................. 3  
PRIOR AUDIT COVERAGE................................ 3  

FINDINGS AND RECOMMENDATIONS........................ 5  

A.  PROGRAM INCOME.................................. 5  
B.  PROCUREMENT AND PROPERTY MANAGEMENT.............12  
C.  FEDERAL GRANT FUNDS.............................17  

APPENDICES

1.  CLASSIFICATION OF MONETARY AMOUNTS..............20  
2.  STATUS OF AUDIT REPORT RECOMMENDATIONS..........21  

INTRODUCTION

BACKGROUND

The original (1950) version of the Organic Act of Guam (Title 48,
Section 1421g(b), of the U.S. Code Annotated) stated, "The
Governor [of Guam] shall provide an adequate public educational
system of Guam, and to that end shall establish, maintain, and
operate public schools according to the laws of Guam."  On
November 19, 1993, Guam Public Law 22-42 was enacted to repeal
and enact a new version of Title 17, Section 3101, of the Guam
Code Annotated, which established the Department of Education
within the Government of Guam.  Section 3102 of the new version
of Title 17 states, "The Department [of Education] shall be
administered through the Territorial Board of Education . . .
which shall be the governing and policy-making body of the
Department."  Further, Section 3102(a) states that the
Territorial Board will hire a Director and a Deputy Director of
Education.  

Prior to April 28, 1997, Education's primary funding was provided
by appropriations from the General Fund.  However, on April 28,
1997, Guam Public Law 24-17 created the School Operations Fund
and changed the Department's primary source of funding from
General Fund appropriations to the Gross Receipts Tax.  Under
this law, 88 percent of the total monthly collections of gross
receipts taxes are to be transferred to the Department of
Education and deposited into the School Operations Fund.
Further, effective May 21, 1997, Guam Public Law 24-34 amended
Title 11 of the Guam Code Annotated by adding Section 26208,
which designated the Director of Education as the official
responsible for receiving, accounting for, and disbursing all
monies in the School Operations Fund.

On February 27, 1998, Guam Public Law 24-142 was enacted to
divide the Board of Education into four elected District Boards
of Education, each with a District Superintendent.  In addition,
the Department of Education, with the Director appointed by the
Governor, was restructured to provide guidance to and coordinate
the activities of the districts and to "serve as the state
educational agency for purposes of Federal statutes, policies,
grants, programs and regulations."  This law also provided for
the existing school board to serve on an interim basis for a
1-year transition period and for election, in November 1998, of
the members of the four new District Boards of Education.

Subsequent to the completion of our audit, on March 25, 1999,
Public Law 25-03 was enacted by the Government of Guam.  Chapter
4, Section 18, of the Public Law states, "The governing of the
Department of Education shall temporarily revert to the Governor
of Guam until further legislative action.  The Board currently in
place shall cease to exist.  The Governor shall not appoint a
Board, but shall assume all functions, powers, duties and
responsibilities of the Board . . . ."  As a result of the public
law, on March 25, 1999, the Board of Education was eliminated,
the Department's Director and Deputy Director were placed on
administrative leave (their contracts were terminated on April 1,
1999), and an Acting Director was appointed.

The Government of Guam single audit report for the fiscal year
ended September 30, 1997, reported that the Department of
Education had total revenues of $183.4 million ($166.9 million
from local sources and $16.5 million from Federal sources) and
total expenditures of $174.8 million (local and Federal
expenditures were not reported separately).  During the same
fiscal year, the Department had 3,792 employees and administered
36 schools that had a total enrollment of 32,923 students.  For
fiscal years 1996 and 1997, the Department emphasized site-based
management for the schools, including the Extended Day Program.

Extended Day Program.  The Department of Education Extended Day
Program offers working parents of children enrolled in
kindergarten through the fifth grade the option of after-school
educational care for their children.  The Program was designed by
the Department and, along with other Department programs, was
funded by Federal grant funds provided by the U.S. Department of
Education Consolidated Grant for Insular Areas (Innovative
Education Program Strategies - Title VI).   The Department's
Federal Programs Office did not formally budget or allocate funds
for the Extended Day  Program and other programs funded by the
Consolidated Grant.  According to Departmental records, the
Department, during the audit period (October 1, 1995, through
June 30, 1998), spent Federal grant funds totaling about $2
million for the Extended Day Program from the total authorized
amount of $24.8 million in the Consolidated Grant during the same
period.  The $2 million was used to employ 614 part-time teachers
and Program coordinators to teach about 12,325 children.

Other Program expenses were paid from Program income raised from
parents, who were required to pay "per child" fees of $75 for
each quarter or $300 for the entire school year.  Program income
was to be expended only for participating students' needs.
Program fees and other Program income (such as late pick-up fees)
were collected, expended, and accounted for at each participating
school under guidelines issued by the Federal Programs Office
within the Department.  Although each school maintained its own
records of Program income collections and expenditures, summary
accounting data were not available.  However, we estimated that
about $900,000 should have been collected from registration fees
at the 15 participating schools during the audit period.

On August 7, 1979, the Board of Education issued its Board policy
"Management of Non-Appropriated and Student Activities Funds,"
which provides financial management guidelines for all funds
received by the Department without legislative appropriation,
such as Extended Day Program income.  Further, on September 13,
1990, the Department issued the "Non-Appropriated Student
Activity Fund Handbook," which established additional guidelines
for handling nonappropriated funds and identified the duties and
responsibilities of individuals handling these funds.  Further,
on August 12, 1991, the Department issued the "Non-Appropriated
Funds Procedural Handbook," which provided guidelines that were
not as detailed as those included in the September 1990 handbook
for handling the collection and disbursement of nonappropriated
funds.  Finally, on October 1, 1995, the Federal Programs Office
issued (and on August 20, 1998, revised) "Program Guidelines" for
the Extended Day Program to provide policy and operational
guidance to Program personnel.

OBJECTIVE AND SCOPE

The objective of our audit was to determine whether the
Department of Education complied with Federal and local laws,
grant agreements, and procedures applicable to the Extended Day
Program.  The scope of the audit included a review of the
documents and control procedures at the Department of Education
that were related to the collection and disbursement of grant
funds and income for the Extended Day Program during fiscal years
1996, 1997, and 1998 (through June 30).  However, our audit was
limited because the Department did not have adequate accounting
records to identify the total amount of grant funds used for
Program expenditures and did not prepare adequate summary
accounting records and reports to determine total Program income
and disbursements.  In addition to the central offices of the
Department of Education, we visited the Department of
Administration, the Bureau of Budget and Management Research, and
eight public elementary schools to interview officials and review
records pertaining to the Extended Day Program.  We also
interviewed an official from the U.S. Department of Education
regarding Federal grant funds for the Program.

Our review was made, as applicable, in accordance with the
"Government Auditing Standards," issued by the Comptroller
General of the United States.  Accordingly, we included such
tests of records and other auditing procedures that were
considered necessary under the circumstances.

As part of the audit, we evaluated the system of internal
controls related to the financial and operational management of
the Department of Education Extended Day Program to the extent
that we considered necessary to accomplish the audit objective.
Based on our review, we determined that, in general, the
Department adequately managed the processing of Extended Day
Program employee payroll charged to the Federal grant.  However,
we identified internal control weaknesses in the areas of
collecting and disbursing Program income, managing Program
property, and collecting and accounting for Federal grant funds.
These weaknesses are discussed in the Findings and
Recommendations section of this report.  Our recommendations, if
implemented, should improve the internal controls in these areas.

PRIOR AUDIT COVERAGE

During the past 5 years, neither the U.S. General Accounting
Office nor the Office of Inspector General has issued any audit
reports on the Department of Education Extended Day Program.
However, on October 19, 1998, an independent public accounting
firm issued a single audit report on the Government of Guam,
which included the Department of Education's financial statements
and the results of audit tests of the Department's grant
operations for fiscal year 1997.  With regard to the Extended Day
Program, the single audit stated that (1) the Department of
Education did not properly account for the unobligated balances
in the U.S. Department of Education Consolidated Grant for fiscal
years 1992, 1993, 1994, and 1995 and (2) the Government of Guam
had not performed physical inventories of any equipment purchased
with grant funds.

In addition, the Government of Guam's Office of Internal Audit
issued audit reports on its reviews of nonappropriated funds,
including the Extended Day Programs, at four public elementary
schools as follows: 

-  The report "Audit of the M.U. Lujan Elementary School
Non-Appropriated Student Activity Fund for the Period of July 1,
1995 through June 30, 1997" (No. IA-98-03), dated May 1998,
stated that school officials (1) did not identify the sources of
deposits of $46,206, (2) did not maintain required accounting
records, (3) did not adequately document the disposition of
Extended Day Program collections of $1,265, (4) did not
adequately support disbursements of $14,141, (5) did not prepare
monthly and annual financial reports, and (6) made disbursements
totaling $4,710 from Extended Day Program funds that did not
relate to the Program. 

-  The report "Audit of the Price Elementary School
Non-Appropriated Student Activity Fund for the Period of July 1,
1995 through February 28, 1997" (No. IA-97-05), dated August
1997, questioned Extended Day Program expenditures of $15,521,
stating that these expenditures did  not meet Program guidelines
or were unsupported and that receipts were not provided for fees
and other payments received by school personnel.

-  The report "Harmon Loop Elementary School Student Activities
Fund for School Years 1993-1995" (No. IA-97-03), dated June 1997,
stated that (1) cash receipt books (the only school records of
cash collections) could not be located for 7 months in school
year 1994 and 4 months in school year 1995, (2) cash collections
totaling $1,408 were not deposited into bank accounts, (3) the
Extended Day Program account was overspent by $1,567, and (4)
monthly and annual financial reports were not prepared. 

-  The report "Audit of the Wettengel Elementary School
Non-Appropriated Student Activity Fund" (No. IA-96-08), dated
July 1996, for the period of July 1, 1995, through March 30,
1996, stated that although the School did not adequately
segregate responsibilities and adequately account for checks that
had insufficient funds, the School generally administered the
fund in compliance with applicable Department of Education
requirements.

FINDINGS AND RECOMMENDATIONS

A.  PROGRAM INCOME

The Department of Education did not adequately control income
generated by the Extended Day Program.  Specifically, elementary
schools administering the Program did not properly collect and
deposit all Program income and expended Program income  for
purposes that did not always relate directly to the Program.  In
addition, income and related expenditures resulting from the
Program were not included in the Department's annual financial
statements.  The requirements for the accounting and use of
Program income are contained in the Code of Federal Regulations
(34 CFR 80) and internal procedural manuals of the Board and the
Department of Education.  The deficiencies occurred because the
Department had not delegated responsibility and authority to a
specific Departmental office and/or seniorlevel official for
ensuring that school principals and staff were accountable for
administering the Program in compliance with applicable rules and
regulations.  In addition, the turnover of key school personnel
resulted in a lack of continuity in Program administration, and
Program guidelines on the use of fee collections (Program income)
were unclear.  Further, Department personnel said that they did
not consider the revenues collected from Program fees to be
"Program income" but to be "nonappropriated funds," which were
excluded from the annual financial statements.  As a result,
Program income of at least $11,285 had not been deposited into
Program bank accounts, $20,385 could not be accounted for, and
another $1,000 was collected inappropriately.  Also, expenditures
from Program income totaling $84,342[1] were not adequately
supported, and additional expenditures from Program income
totaling $137,552 were unnecessary or were not made for the
direct benefit of participating students.  Further, the
Department's financial statements understated the amount of
Program income and expenditures.

General Requirements

The Code of Federal Regulations (34 CFR 80.25 (b)) states,
"Program income means gross income received by the grantee or
subgrantee directly generated by a grant supported activity . . .
."  The Code (34 CFR 80.20(b)) also states:

The financial management systems of other grantees and
subgrantees must meet the following standards: . . .

(2) Accounting records.  Grantees and subgrantees must maintain
records which adequately identify the source and application of
funds provided for financially-assisted activities.  These
records must contain information pertaining to . . . obligations,
unobligated balances, assets, liabilities, outlays or
expenditures, and income.

(3) Internal control.  Effective control and accountability must
be maintained for all grant and subgrant cash, real and personal
property, and other assets.  Grantees and subgrantees must
adequately safeguard all such property and must assure that it is
used solely for authorized purposes.

In addition, the Code (34 CFR 80.40 (a)) states, "Grantees are
responsible for managing the day-to-day operations of grant and
subgrant supported activities.  Grantees must monitor grant and
subgrant supported activities to assure compliance with
applicable Federal requirements. . . ."

Local policies and procedures related to the Extended Day Program
include Board of Education Policy 715, "Management of
Non-Appropriated and Student Activities Funds."  The policy
states, "The school treasurer shall prepare a monthly financial
statement for each fund.  It shall show the previous balance,
income and expenses for the month and the current balance."  In
addition, the Appendix to the Department's "Non-Appropriated
Funds Procedural Handbook" states, "The school treasurer shall be
responsible, in accordance with these policies and other rules
and regulations, for receiving and disbursing non-appropriated
funds, arranging for their adequate safekeeping and maintaining
adequate records thereon."  Further, the Department's Director
said that elementary school principals have the responsibility
for Extended Day Program funds at their schools.  This statement
was confirmed by the principals' job descriptions, which stated
in part that principals "control non-appropriated funds and
supervise the expenditure of such funds."

Controls Over Program Income

Board of Education Policy 715 states, "Whenever money is
collected a receipt shall be issued by the school activities
treasurer.  A copy shall be retained for the file."  Further, the
"Department of Education Extended Day (DEED) Program Guidelines"
states, "A fee of $75.00 per child per quarter will be charged."
It also states, "Monies collected in DEED are considered
nonappropriated funds . . . .  The Nonappropriated Student
Activity Fund Handbook produced by the Business Office spells out
some requirements.  However, schools should develop their own
internal control system of accounting for funds generated from
fees."  The Handbook also states, "Written receipts must be
issued for every payment made, at the time payment is made.
Payments must be recorded in official receipt books . . . ."

Based on these requirements, we reviewed the collection process
for the Extended Day Program at 8 of the 15 elementary schools
offering the Program.  During the period of October 1, 1995,
through June 30, 1998, the eight schools collected Program fees
of at least $559,977.   We found that (1) four schools did not
adequately control the use of receipts and/or reconcile
accounting reports, accounting records, and bank statements to
ensure that all Program income was collected and deposited into
appropriate bank accounts; (2) one school collected (and did not
subsequently refund) $1,000 representing an unauthorized $10
preregistration fee from parents of at least 100 prospective
students; and (3) one school did not transfer all Extended Day
Program funds to a new bank account that was established
specifically for Program income.  Further, only four of the eight
schools submitted monthly financial reports to the Department's
Business Office, and Business Office personnel did not include
the financial data in the Department's financial reports or
statements.

We also noted that the accuracy and the completeness of Program
records were adversely affected when Program administrators were
transferred or changed positions.    During the period audited,
the eight schools had a total of 19 different principals, 15
different Program coordinators, and 11 different school
treasurers.  Because of the absence of consistent management
oversight resulting from the turnover in key administrative
positions, Tamuning Elementary School improperly collected $1,000
from parents of prospective students, and four schools may not
have deposited Program fee collections of at least $31,670 into
Program bank accounts, as shown in Table 1.

Table 1.  Program Income Not Accounted For or Not Deposited Into
          Program Accounts

School                   Description                       Amount

M.U. Lujan*   Collections not accounted for                20,385
Tamuning      Collections exceeded deposits to bank account 9,355
Wettengel     Collections exceeded deposits to bank account   854
Yigo          Collections exceeded deposits to bank account   250
Yigo          Funds not transferred to new bank account       826

Total                                                     $31,670
__________

*Because M.U. Lujan School's accounting records were incomplete
for Program income and expenditures during the period of October
1, 1995, through April 13, 1998, we could not determine whether
these funds were deposited and used for Program purposes.

School personnel assigned to collect, account for, and deposit
Program collections at the eight schools told us that the
Department had not provided (1) training and guidance on how to
control the collection of Program income; (2) instructions on how
to reconcile accounting records, bank statements, and Program
financial reports; and (3) monitoring reviews for improving each
school's Program financial management.  The Administrator of
Federal Programs stated that she was generally aware of the
deficiencies in fee collections but that she did not have the
authority to require compliance with Program regulations and
guidelines.  She said that the Department's Business Office
should have revised the existing collection procedures but that
she did not consider Program fees to be Program income.

The Department's Acting Comptroller said that the Director of
Education had not specifically identified an office or
senior-level official responsible for providing oversight of the
nonappropriated funds process, including the Extended Day
Program, at the individual schools.  Further, the Acting
Comptroller stated that Extended Day Program fees, in his
opinion, met the Federal definition of "Program income" and
should have been included as grant-related revenues and
expenditures in the financial statements.  In addition, the
Administrator of the Department's Office of Financial Affairs
stated that although she had been verbally tasked by the Director
of Education to assist in administering the nonappropriated funds
at the schools by both auditing and providing training to school
personnel, she had no authority to require school administrators
to comply with applicable regulations.  Since school principals
are responsible for programs at their schools, we believe that
the Director should delegate the responsibility and authority in
writing to a specific Departmental office or official to ensure
that principals and school staff comply with all applicable
Federal and local regulations relating to the Extended Day
Program.

Expenditures From Program Income

The Code of Federal Regulations (34 CFR 80.25(g)(2)) states, "The
program income shall be used for the purposes and under the
conditions of the grant agreement."  The Code (34 CFR 80.20(b))
also states:

(4) Budget control.  Actual expenditures or outlays must be
compared with budgeted amounts for each grant or subgrant. . . . 

(6) Source documentation.  Accounting records must be supported
by such source documentation as cancelled checks, paid bills,
payrolls, time and attendance records, contract and subgrant
award documents, etc."  

Board of Education Policy 715 states:

No disbursement shall be made by the school principal and school
treasurer unless a voucher request for payment is first received
signed by the activity sponsor and the activity treasurer.  Said
voucher shall include the fund name, the item(s) for which
payment is authorized, the amount of payment and the person or
firm payable.  No activity sponsor is necessary for disbursements
from funds generated from approved fees.

The "Department of Education Extended Day (DEED) Program
Guidelines" states, "Funds collected in DEED must be expended for
student needs.  A subsidiary ledger should be kept that reflects
amounts collected and expended of DEED funds."

Unsupported Expenditures.  The accounting records maintained at
five of the eight schools reviewed did not include documentation
to adequately support whether all expenditures made from Extended
Day Program income were for Program purposes.  Program
administrators at the five schools stated that the responsible
school personnel did not know that the records were required
because prior Program coordinators or school treasurers had not
prepared or had misplaced such records.  The Program
administrators also said that when new personnel assumed the
duties related to the Extended Day Program, they were not trained
and therefore did not know that these records were required.  As
a result of the lack of adequate supporting documentation, we
were unable to confirm that expenditures totaling $84,342 (see
footnote 1) were incurred for Program purposes.

For example, Program administrators at Tamuning Elementary School
did not maintain separate files for Program expenditures or
accounting journals or similar summary records of revenues and
expenditures.  Therefore, we summarized all transactions for the
audit period based on the available source documents.  Although
invoices and similar documents were sometimes attached to the
canceled checks in the checkbook binder, we determined that of
441 transactions reviewed, 268 transactions (61 percent),
totaling $62,914, were supported only by the canceled checks and
occasional notations on the check stubs.

Unnecessary Expenditures.  Based on our review of 1,184
expenditures at eight schools, we identified 450 transactions at
seven schools for the acquisition of goods and personal services
that, in our opinion, (1) did not benefit the children who
participated in the Program, (2) unnecessarily subsidized regular
school operations, or (3) were of only partial or incidental
benefit to the children who participated in the Program.  In
addition, personnel at one school inappropriately loaned Program
funds to another nonappropriated fund.  As a result, at least
seven schools spent Program income totaling $137,552 for goods
and services that did not directly benefit the Extended Day
Program, as shown in Table 2.

Table 2.  Unnecessary Expenditures From Program Income

School         FY1996     FY1997   FY1998    Total  

Agana Heights  $3,400    $9,958   $10,431    $23,789
Harmon Loop*    9,165     6,092         0     15,257
Merizo            280       374         0        654
M.U. Lujan     10,487     8,902     5,110     24,499
Tamuning       18,717    10,031    15,358     44,106
Wettengel**    16,265     7,453     2,395     26,113
Yigo              618     1,377     1,139      3,134

Total         $58,932   $44,187   $34,433   $137,552
__________

*Name changed to Juan M. Guerrero School in 1998.
**The $666 unpaid balance of the $7,305 loan to a nonappropriated
fund is included in the fiscal year 1998 total.

For example, during fiscal years 1996 to 1998 (through June 30),
Tamuning Elementary School used Program income of $21,486 to pay
for the following general school expenses: landscaping - $8,035,
janitorial services - $9,588, and specialized ring binders for
all students at the school - $3,863.  In July 1996, Harmon Loop
Elementary School used Program income of $799 to purchase a
stair-stepper exercise machine, which, according to the Program
Coordinator, was never used in the Extended Day Program, and in
August 1996, the school used Program income of $6,981 to purchase
12 two-way radios and 6 battery chargers for use by School
personnel throughout the school day.  Further, in January 1996,
Wettengel Elementary School personnel used Program income of
$7,305 to make a loan to another nonappropriated fund to pay for
T-shirts used by faculty members and students.  As of June 30,
1998, $666 of the loan had not been repaid to the Program.
School personnel said that the $7,305 loan was necessary to allow
the school to pay an outstanding bill for the T-shirts.

Although the circumstances and explanations related to each
situation were different, the school principals and
administrators told us that Program income was used for the
questioned goods and services because (1) the Program guidelines
were unclear, (2) the Program income was needed to counterbalance
the Extended Day Program's costs of school services that were not
reimbursed, or (3) the principals believed that all funding
collected by their respective schools should be used for the
general benefit of the school.  However, these reasons for the
use of Program funds were not in accordance with Federal and
local Program guidance.  In addition, personnel at the
Department's Federal Programs Office said that the Program is
structured to avoid having to draw heavily on regular school
personnel and facilities and that, if there are unreimbursed
costs of personnel or facilities, funds from the Consolidated
Grant can be budgeted for the Program to meet those needs.  We
also found that none of the eight schools reviewed had publicly
released annual Program budgets and year-end reports for the
benefit of the parents of participating students.  Federal
regulations and Extended Day Program guidelines require Program
income to be expended only for the benefit of children
participating in the Program.  Therefore, we believe that
publicly available annual budgets and year-end reports for the
Program would help to identify shortfalls and provide a mechanism
for ensuring that collected funds are used for Program purposes.

Recommendations

We recommend that the Governor of Guam ensure that the Director
of the Department of Education:

1. Formally delegates responsibility to a senior-level official
and/or office of the Department for ensuring that individual
schools comply with applicable Federal and local regulations and
guidelines for administering the Extended Day Program. 

2. Provides applicable training and day-to-day assistance to
school personnel designated responsible for accounting for
Extended Day Program income and expenditures.

3. Develops and implements written procedures to require all
schools which offer the Extended Day Program to prepare annual
budgets for the collection and use of Program income at the
beginning of each school year, prepare year-end reports that show
the amount of income collected and how it was used, and release
budgets and year-end reports publicly for the benefit of Program
parents.

4. Develops and implements written guidelines that conform with
Federal requirements on the appropriate use of Extended Day
Program income.

5. Requires that each school submit to the Department's Business
Office separate monthly financial reports for Extended Day
Program income and expenditures and that the Business Office
include this financial information in the Department's official
accounting records for the Consolidated Grant for Insular Areas. 

6. Advises the U.S. Department of Education of the questioned
costs and either resolves the questioned costs or arranges for
repayment.

Department of Education Response and Office of Inspector General
Reply

Because the Acting Director of Education did not respond to the
draft report, the recommendations are unresolved 
(see Appendix 2).

**FOOTNOTES**

[1]:Unsupported expenditures from Program income totaled
$108,130, but $23,788 was not included in the $108,130 because it
was included in the $137,552 classified as unnecessary
expenditures from Program income.

B.PROCUREMENT AND PROPERTY MANAGEMENT

School personnel administering the Extended Day Program did not
procure goods and services competitively or adequately account
for and control nonexpendable property.  The requirements for
procurement and property management are contained in the Code of
Federal Regulations (34 CFR 80) and in internal procedural
manuals of the Board and the Department of Education.  The
deficiencies occurred because (1) the Department had not
delegated responsibility and authority to a specific Departmental
office or official for enforcement of existing procurement and
property management laws and regulations and (2) no Departmental
office or official had assumed responsibility for providing
individual schools with the necessary guidance and compliance
monitoring.  As a result, the Department could not ensure that
full value was received for Program purchases totaling
$64,107.[2]  In addition, six of the eight schools we reviewed
did not have current or complete inventories of property acquired
with Program funds, and two of the eight schools could not locate
or account for nonexpendable property valued at $3,050.
Subsequent to the audit period, on September 3, 1998, the
Department's Federal Programs Office issued guidelines and
procedures for property management to the schools that
participated in the Extended Day Program.

Procurement

The Code of Federal Regulations (34 CFR 80.36(a)) states, "When
procuring property and services under a grant, a State [which
includes Guam] will follow the same policies and procedures it
uses for procurements from its non-Federal funds."  The Code (34
CFR 80.36(c)(1)) further states, "All procurement transactions
will be conducted in a manner providing full and open
competition."  In addition, Section 3.8 of the Department of
Education's Procurement Regulations states, "Unless otherwise
authorized by law, all Department contracts shall be by
competitive sealed bidding."  Section 3.11.3.1 states, "Insofar
as it is practical for small purchases of supplies or services
between five hundred dollars ($500) and fifteen thousand dollars
($15,000), no less than three (3) businesses shall be solicited
to submit written quotations or oral quotations that are recorded
and placed in the procurement file.  Award shall be made to the
business offering the lowest acceptable quotation."  Section
3.11.3.2 of the Procurement Regulations states, "The names of the
businesses submitting quotations and the date and amount of each
quotation shall be recorded and maintained as a public record."

Despite the Federal and Departmental regulations, none of the 45
purchases made with Program income, costing between $500 and
$15,000 (all of which we reviewed), included documentation that
Program administrators at the eight schools had obtained
competitive bids or the required price quotations, as summarized
in Table 3.

Table 3.  Noncompetitive Procurement Transactions

                FY 1996       FY 1997      FY 1998          Total
School         No.Amount    No.Amount    No. Amount    No. Amount

Agana Heights   5  $8,362    0     $0     1   $1,850    6 $10,212
Harmon Loop*      610,153      3 2,347    1    2,299   10  14,799
Merizo                 0     0      0     0       0     0      00
M.U. Lujan             0     0      0     0       0     0      00
Ordot-Chalan Pago      0     0  1  1,110  0       0     1   1,110
Tamuning        8  17,225    5  9,620     6  16,260     19 43,105
Wettengel       4  20,941    0      0     0       0     4  20,941
Yigo            2   2,579    1   2,189    2   1,367     5   6,135

Total          25 $59,260    10$15,266    10 $21,776    45$96,302
__________

*Name changed to Juan M. Guerrero School in 1998.

Examples of the types of goods and services procured
noncompetitively are as follows: 

- On July 1, 1996, Wettengel Elementary School purchased six air
conditioners at a cost of $19,300.[3] 

- On August 26, 1996, Tamuning Elementary School purchased
vertical window blinds at a cost of $5,436.

- During the period of October 7, 1997, to May 31, 1998, Tamuning
Elementary School made five payments to the same vendor for
janitorial services totaling $9,043.

In each case, there was no documentation to show that competitive
bids or the required number of price quotations had been
obtained, although multiple vendors were available to bid on the
needed goods or services.  Therefore, the Department had little
assurance that it received full value for the $64,107 (see
footnote 3) in Program income spent on goods and services.

Extended Day Program personnel at the eight schools stated that
they believed the expenditure of Program income was exempt from
compliance with Department of Education procurement regulations
because the "Extended Day Program Guidelines" did not include
procurement procedures for the use of Program income.  The
Administrator of the Department's Federal Programs Office stated
that although her office verbally notified schools of the need to
follow procurement regulations, the Federal Programs Office had
no authority in this area and that it was the responsibility of
the Department's Business Office to ensure that the Department's
operational units complied with applicable regulations.  However,
the Department's Acting Comptroller stated that (1) the Business
Office had never reviewed the procurement process used by schools
for the expenditure of nonappropriated funds, (2) the Office's
procurement section was not staffed to perform such reviews, and
(3) the Office had not been assigned this responsibility.

Property Management

The Code of Federal Regulations (34 CFR 80.32(b)) requires that
property acquired with grant funds be used and managed in
accordance with state laws and procedures.  The Department's
Administrator of Supply Management stated that the March 1981
systems manual entitled "Property Management Systems and
Procedures" had been adopted by the Department for property
management procedures.   The Manual states, "Accountability and
responsibility will be charged to the officials having
administrative jurisdiction over the physical assets and they
shall be Accountable Officers for such properties.  Safeguarding
and maintenance of these assets shall be the primary
responsibility of these officers."  The Manual also specifies
that property records will be maintained for property costing
$250 or more.  Finally, the "Extended Day Program Guidelines"
states, "All equipment procured for DEED must be entered into the
site school's inventory.  Property management requirements
regarding equipment control and record keeping must be observed.
All equipment should be marked `DEED' and the fiscal year in
which it was acquired so it can be readily identified during
audits."

Despite these requirements, we found, for the eight schools we
reviewed, that one school did not have sufficient records for us
to determine whether it had Extended Day Program property, four
schools did not have current and complete property listings, two
schools could not locate all recorded property items, and the
remaining school did not have Extended Day Program property.

To verify the accuracy of the property listings that were
available, we performed limited physical inventories at each of
the six schools that purchased nonexpendable property with
Program income.  Of the 77 procurements, totaling $71,247, for
nonexpendable property that were made during the audit period, we
were unable to locate the related property items for 4
procurement transactions, totaling $3,050.  Specifically, at
Harmon Loop Elementary School, we could not locate a water heater
that cost $400, a set of stereo speakers that cost $361, and a
stair stepper exercise machine that cost $799.  At Wettengel
Elementary School, 10 electronic keyboards that cost a total of
$1,490 were reported stolen, although School personnel stated
that a police report had not been filed.  We also found that a
School employee had purchased a video camera to replace one
costing $1,599, which School officials could not locate.  The
results of our review of Extended Day Program property are
summarized in Table 4.


Table 4.  Results of Property Management Review

No. of Cost of 
School  Inventory List    Items    Items      Result of Review

Agana Heights   Aug. 19986       $10,211   Incomplete records;
   items located and secured.
Harmon Loop*    Jan. 1998 37      18,473   Three items, valued 
   at $1,560, missing.
Merizo          None--   --              No property purchased.
M.U. Lujan      None--   -- No records to determine if property
   purchased.
Ordot-Chalan Pago  Jun. 1993  1    1,110   Incomplete records;
   items located and secured.
Tamuning        Jul. 1997    12    15,035  Incomplete records;
   items not secured.
Wettengel       Feb. 1998    17    23,012  Ten items, valued at
   $1,490, missing.**
Yigo            Jun. 1997     4      3,406  Incomplete records;
   items located and secured.

Total                         77   $71,247 
__________

*Name changed to Juan M. Guerrero school in 1998.
**Does not include a video camera valued at $1,599 that was lost
but later replaced by a school employee.

School personnel administering the Extended Day Program at the
two schools that did not have inventory listings stated that they
did not know that such listings were required.  Personnel at
three of the four schools that had outdated or incomplete
inventory listings stated that they had not completed updating
the inventories because the Program coordinators had changed and
the new coordinators did not understand what to inventory.
Further, the two schools with missing property allowed school
personnel other than Extended Day Program staff to use Program
property without adequate safeguards.  Specifically, these two
schools did not have an identified property custodian, a secure
property area, property tagged as Program/government property, or
property check-out/check-in procedures.  Finally, the inventory
listing at Agana Heights Elementary School was incomplete because
it did not include the cost of the property items.  Although
Program coordinators at the schools we reviewed said that they
knew they were accountable for Program property, we found that
three schools did not store the Program property in secure
locations before and after Program use. 

Recommendations

We recommend that the Governor of Guam ensure that the Director
of the Department of Education:

1. Formally delegates responsibility and authority to a
Departmental senior-level official and/or office for ensuring
that individual schools comply with applicable Federal and local
procurement and property management regulations.

2. Advises the U.S. Department of Education of the questioned
costs and either resolves the questioned costs or arranges for
repayment.



Department of Education Response and Office of Inspector General
Reply

Because the Acting Director of Education did not respond to the
draft report, the recommendations are unresolved 
(see Appendix 2).

**FOOTNOTES**

[2]:Questioned procurement transactions totaled $96,302, of which
$32,195 was not included in the $96,302 because it was included
in the $137,552 classified as unnecessary expenditures from
Program income in Finding A.

[3]:According to school records, $13,000 was paid from Extended
Day Program income, and $6,300 was paid from Parent Teacher
Organization funds.

C.  FEDERAL GRANT FUNDS

The Department of Education did not have adequate accounting
control over Federal grant funds used to finance the Extended Day
Program.   Specifically, accounting reports showing the status of
grant funds were not available timely or were inaccurate.  The
requirements for accounting controls over grant funds are
contained in the Code of Federal Regulations (34 CFR 80) and in
internal procedures manuals of the Board and the Department of
Education.  However, these deficiencies occurred because the
Department did not adequately train or supervise its accounting
personnel.   As a result, the Department lost about $325,837 in
Federal grant funding from the fiscal year 1996 U.S. Department
of Education Consolidated Grant for Insular Areas and could not
support expenditures of at least $2,017,126 claimed for
reimbursement from the same grant for fiscal years 1996, 1997,
and 1998 (through June 30).

Accounting for Grant Funds

The Code of Federal Regulations (CFR 34 80.20(a)) states, "A
State [which includes Guam] must expend and account for grant
funds in accordance with State laws and procedures for expending
and accounting for its own funds.  Fiscal control and accounting
procedures of the State, as well as its subgrantees and cost-type
contractors, must be sufficient to: . . . (2) Permit the tracing
of funds to the level of expenditures adequate to establish that
such funds have not been used in violation of the restrictions
and prohibitions of applicable statutes."

Although the Department accounted for grant expenditures by
individual program, it accounted for grant fund authorizations
and availability only at the grant level.  Therefore, we had to
review the revenue accounting procedures for the entire U.S.
Department of Education Consolidated Grant for Insular Areas to
ensure that we reviewed the funding applicable to the Extended
Day Program.  We found that although the Department's Business
Office was aware as early as July 5, 1997, that the Department
had unobligated grant funds for the 2-year grant period covering
fiscal years 1996 and 1997 that were available for Program
purposes, the Federal Programs Office (which was responsible for
administering the funds) did not know that the funds were
available until October 1998, more than 1 year after the
availability of the grant funds had expired on September 30,
1997.  The Federal Programs Office did not know about the
availability of the funds because the accounting reports prepared
by the Business Office to make claims for reimbursement of grant
funds were not made available to the Federal Programs Office to
identify unobligated and unclaimed grant funds.  In addition, the
accounting reports prepared by the Federal Programs Office
incorrectly showed that the grant had been fully used because the
accounting procedures used by the Federal Programs Office to
record grant availability and use over the 2-year grant period
maintained separate accounts for each year of the grant period.
Because expenditures during the early part of fiscal year 1997
were recorded against the internal account for fiscal year 1996,
the fiscal year 1996 account was erroneously shown as having been
overexpended, and this overexpended balance was carried forward
to the fiscal year 1997 account when funds for the new year were
drawn down.  Additionally, reports of the Business Office and the
Federal Programs Office were not reconciled.  Although both
offices began using the same accounting reports in October 1997,
the accounting procedures that caused the erroneous balances were
not revised; therefore, there was no assurance that future grant
funds would not expire before they were used.  The Department's
Comptroller stated that this type of deficiency occurred because
the Department did not adequately train or supervise its
accounting personnel.  As a result of these accounting problems,
the Department lost grant funding of $325,837 for fiscal year
1996.

Claims for Federal Reimbursement

The Department of Education's Financial Management System
Policies and Procedures Manual states, "To ensure [the Department
of Education] is in accordance with the [U.S. Office of
Management and Budget] Common Rule, Section 42, Retention and
access requirements for records, all financial and programmatic
records, supporting documents, statistical records, and other
records of grantees or subgrantees must be maintained for a
period of no less than three (3) years after finalization of the
year end audit."  Under the claim process established with the
Department of Administration, the Department of Education
prepared and sent Request for Reimbursement on Federal Grants
Expenditures forms to the Department of Administration, which
requested the drawdowns of grant funds from the appropriate
Federal agency.  Departmental accounting personnel stated that
they prepared the requests at the end of each month (based on
that month's recorded  expenditures) for the Department of
Administration to obtain reimbursement from the appropriate
Federal grantors.

We attempted to verify that the amount of Extended Day Program
expenditures (primarily payroll charges) were accurately included
in claims for Federal grant reimbursement, but the Department's
records were incomplete.  We could not review any grant
reimbursement claims for fiscal year 1996 because Departmental
personnel could not locate the claim documents.  Although we
reviewed 8 of 48 grant reimbursement forms for fiscal years 1997
and 1998, we could not verify that the Program claims were
correct because of the lack of supporting documentation.  The
Department's records identified reimbursement claims by each
Federal grant but not by the individual programs funded by each
grant.  Therefore, we could not distinguish between claims
related to the Extended Day Program and claims for other grant
programs.  The accounting technician stated that she routinely
discarded (within 3 weeks after preparation) the listings of the
specific expenditures included on the reimbursement forms because
of insufficient filing space to retain the documents and because
she did not believe that it was important to retain these
listings.  These actions  were contrary to the 3-year minimum
requirement in the Department's Financial Management System
Policies and Procedures Manual and applicable Federal grant
management regulations.  Because of the lack of supporting
documentation, we questioned $2,017,126, which consisted of
$727,743 of Program expenditures claimed for Federal
reimbursement for fiscal year 1996, $679,007 for fiscal year
1997, and $610,376 for fiscal year 1998 (through June 30, 1998).

Recommendations

We recommend that the Governor of Guam ensure that the Director
of the Department of Education:

1. Provides the Federal Programs Office with periodic reports of
the status of Federal grant reimbursement claims.

2. Requires  all supporting documents for grant reimbursement
claims to be retained for the 3-year time period provided in the
Department's Financial Management System Policies and Procedures
Manual and applicable Federal grant management regulations.

3. Provides adequate training on applicable grant policies and
regulations to Departmental accounting personnel responsible for
processing transactions and documents related to Federal grants
and ascertains that these personnel are adequately supervised in
performing these duties.

4. Advises the U.S. Department of Education of the questioned
costs and either resolves the questioned costs or arranges for
repayment.

Department of Education Response and Office of Inspector General
Reply

Because the Acting Director of Education did not respond to the
draft report, the recommendations are unresolved 
(see Appendix 2).


APPENDIX 1

CLASSIFICATION OF MONETARY AMOUNTS


Unrealized Unsupported Cost     
Finding Area                  Revenues      Costs      Exceptions

A. Program Income Controls Over Program Income $31,670*   $1,000*
Expenditures fr Program Income: Unsupported Expenditures $84,342*
Unnecessary Expenditures                                 137,552*

B. Procurement and Property Management Procurement ***    64,107*
Property Management****                                    2,251*

C. Federal Grants
Accounting for Grant Funds 325,837**
Claims for Federal Reimbursement                      2,017,126**

Total                    $357,507       $2,165,575       $140,803


*Amounts represent Program income generated by a Federally funded
program.
**Amounts represent Federal grant funds.
***Although questioned procurement transactions totaled $96,302,
only $64,107 is shown because $32,195 was already included in the
$137,552 classified as unnecessary expenditures related to
Finding A.
****Although missing equipment had a total value of $3,050, only
$2,251 is shown because $799 was already included in the $137,552
classified as unnecessary expenditures related to Finding A.

APPENDIX 2

STATUS OF AUDIT REPORT RECOMMENDATIONS

-----------------------------------------------------------
Finding/Recommendation
Action

Reference  Status  Required  
A.1-A.6, B.1-B.2,and C.1-C.4.

Unresolved. Provide a response to the recommendations indicating
concurrence or nonconcurrence.  If concurrence is indicated,
provide an action plan that includes the target dates and
titles of the officials responsible for implementation.  If
nonconcurrence is indicated, provide reasons for the
nonconcurrence.
-----------------------------------------------------------



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TO THE OFFICE OF INSPECTOR GENERAL BY:

Sending written documents to:



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U.S. Department of the Interior
Office of Inspector General
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Calling:

Our 24 hour
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Outside the Continental United States


Caribbean Region

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Calling:
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North Pacific Region

U.S. Department of the Interior
Office of Inspector General
North Pacific Region
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Suite 807, PDN Building
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Calling:
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