Question:
Why GAO Did This Study

HIPAA and its implementing regulations, as amended by the Health Information Technology for Economic and Clinical Health Act, require health care providers to give patients, upon request, access to their medical records, which contain protected health information (i.e., diagnoses, billing information, medications, and test results). This right of access allows patients to obtain their records or have them forwarded to a person or entity of their choice—such as another provider—in a timely manner while being charged a reasonable, cost-based fee. Third parties, such as a lawyer or someone processing disability claims, may also request copies of a patient's medical records with permission from the patient.
The 21st Century Cures Act included a provision for GAO to study patient access to medical records. Among other things, this report describes (1) what is known about the fees for accessing patients' medical records and (2) challenges identified by patients and providers when patients request access to their medical records. GAO reviewed selected HIPAA requirements and implementing regulations and guidance, and relevant laws in four states selected in part because they established a range of fees associated with obtaining copies of medical records. GAO also interviewed four provider associations, seven vendors that work for providers, six patient advocates, state officials, and Department of Health and Human Services' (HHS) officials. The information GAO obtained and its analysis of laws in the selected states are not generalizable. HHS provided technical comments on this report.

What GAO Found

Available information suggests that the fees charged for accessing medical records can vary depending on the type of request and the state in which the request is made. Under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and its implementing regulations, providers are authorized to charge a reasonable, cost-based fee when patients request copies of their medical records or request that their records be forwarded to another provider or entity. In the case of third-party requests, when a patient gives permission for another entity—for example, an attorney—to request copies of the patient's medical records, the fees are not subject to the reasonable cost-based standard and are generally governed by state law. According to stakeholders GAO interviewed, the fees for third-party requests are generally higher than the fees charged to patients and can vary significantly across states.
The four states GAO reviewed have state laws that vary in terms of the fees allowed for patient and third-party requests for medical records. For example, three of the states have per-page fee amounts for patient and third-party records requests. The amounts charged are based on the number of pages requested and vary across the three states.
One of the three states has established a different per-page fee amount for third-party requests. The other two do not authorize a different fee for patient and third-party requests.
One of the three states also specifies a maximum allowable fee if the provider uses an electronic health records system. The other two do not differentiate costs for electronic or paper records.
In the fourth state, state law entitles individuals to one free copy of their medical record. The statute allows a charge of up to $1 per page for additional copies.
Patient advocates, provider associations, and other stakeholders GAO interviewed identified challenges that patients and providers face when patients request access to their medical records.
Patients' challenges include incurring what they believe to be high fees when requesting medical records—for example, when facing severe medical issues that have generated a high number of medical records. Additionally, not all patients are aware that they have a right to challenge providers who deny them access to their medical records.
Providers' challenges include the costs of responding to patient requests for records due to the allocation of staff time and other resources. In addition, according to provider associations and others GAO interviewed, fulfilling requests for medical records has become more complex and challenging for providers, in part because providers may store this information in multiple electronic record systems or in a mix of paper and electronic records.


Question:
Why GAO Did This Study

FEMA, an agency of the Department of Homeland Security (DHS), has obligated more than $36 billion in PA grants to state, local, and tribal governments to help communities recover and rebuild after major disasters since 2009. Further, costs are rising with disasters, such as Hurricanes Harvey, Irma, and Maria in 2017. FEMA recently redesigned how the PA program delivers assistance to state and local grantees to improve operations and address past challenges identified by GAO and others. FEMA tested the new delivery model in selected disasters and announced implementation in September 2017.
GAO was asked to assess the redesigned PA program. This report examines, among other things, the extent to which FEMA's new delivery model addresses (1) past workforce management challenges and assesses future workforce needs; and (2) past information sharing challenges and key IT management controls. GAO reviewed FEMA policy, strategy, and implementation documents; interviewed FEMA and state officials, PA program applicants, and other stakeholders; and observed implementation of the new model at one test location following Hurricane Matthew in 2016.

What GAO Found

The Federal Emergency Management Agency (FEMA) redesigned the Public Assistance (PA) grant program delivery model to address past challenges in workforce management, but has not fully assessed future workforce staffing needs. GAO and others have previously identified challenges related to shortages in experienced and trained FEMA PA staff and high turnover among these staff. These challenges often led to applicants receiving inconsistent guidance and to PA project delays. As part of its new model, FEMA is creating consolidated resource centers to standardize and centralize PA staff responsible for managing grant applications, and new specialized positions, such as hazard mitigation liaisons, program delivery managers, and site inspectors, to ensure more consistent guidance to applicants. However, FEMA has not assessed the workforce needed to fully implement the new model, such as the number of staff needed to fill certain new positions, or to achieve staffing goals for supporting hazard mitigation on PA projects. Fully assessing workforce needs will help to ensure that FEMA has the people and the skills needed to fully implement the new PA model and help to avoid the long-standing workforce challenges the program encountered in the past.
FEMA designed a new PA information and case management system—called the FEMA Applicant Case Tracker (FAC-Trax)—to address past information sharing challenges, such as difficulties in sharing grant documentation among FEMA, state, and local officials and tracking the status of PA projects, but additional actions could better ensure effective implementation. Both FEMA and state officials involved in testing of the new model stated that the new information system allows them to better manage and track PA applications and documentation, which could lead to greater transparency and efficiencies in the program. Further, GAO found that this new system fully addresses two of four key information technology (IT) management controls—project planning and risk management—that are necessary to ensure systems work effectively and meet user needs. However, GAO found that FEMA has not fully addressed the other two controls—requirements development and systems testing and integration. By better analyzing progress on high-level user requirements, for example, FEMA will have greater assurance that FAC-Trax will meet user needs and achieve the goals of the new delivery model.

What GAO Recommends

GAO is making five recommendations, including that FEMA assess the workforce needed for the new delivery model and improve key IT management controls for its new information sharing and case management system, FAC-Trax. DHS concurred with all recommendations.


Question:
Why GAO Did This Study

The nation's gas pipeline network moves about 74 billion cubic feet of combustible gas to homes and businesses daily. To alert the public of a gas leak before an explosion occurs, PHMSA has different requirements for odorizing gas. All gas transported by distribution pipelines throughout communities must be odorized. Gas transported across many miles by transmission pipelines is required to be odorized only in certain populated areas. There are no requirements to odorize gas in gathering pipelines. Congress included a provision in statute for GAO to review odor requirements for all pipelines.
This report presents the views of federal and state pipeline safety officials and industry and safety stakeholders on: (1) the advantages and disadvantages of odorizing combustible gases in pipelines; and (2) whether and how federal requirements for odorizing pipelines should be modified. GAO reviewed relevant regulations and reports; surveyed officials in 48 states and the District of Columbia; and interviewed PHMSA and NTSB officials. GAO also interviewed 34 stakeholders, including 14 experts identified by the National Academies, and 20 other industry and safety stakeholders.

What GAO Found

Pipeline and Hazardous Materials Safety Administration (PHMSA) and National Transportation Safety Board (NTSB) officials, state officials, and stakeholders GAO contacted cited safety as the main advantage to odorizing combustible gases in pipelines, primarily for distribution pipelines in densely populated areas (see figure). Specifically, adding a chemical with a distinctive odor to gas allows the public to generally detect leaks before an explosion can occur. The most frequently cited disadvantage was that commonly used sulfur-based odorants must be removed—primarily from gas in transmission pipelines—before the gas can be used in certain processes, such as producing fertilizer.
While federal odorization requirements follow a risk-based approach by focusing on pipelines in populated areas, the officials and stakeholders GAO contacted disagreed on the need to modify these requirements for some pipelines. Specifically, because distribution pipelines run through populated areas, everyone GAO contacted generally agreed that these pipelines should be odorized for safety, as currently required. For gathering pipelines, the majority of officials and stakeholders did not see a need to modify regulations because these pipelines would be technically challenging to odorize and are primarily located in rural areas. However, about two-thirds of state officials and about half of stakeholders said that additional transmission pipelines should be odorized for public safety.
Conversely, officials from PHMSA and NTSB and about half of the stakeholders contacted noted that, because transmission pipelines operate at high pressure and generally rupture rather than leak, it is unlikely that odorant could mitigate risk. Instead, other required safety practices—such as internal pipeline inspections—can provide more preventative, risk-based safety management, according to PHMSA officials. In this regard, PHMSA officials said that they plan to strengthen risk-based safety requirements for transmission and gathering pipelines as part of on-going rulemakings. PHMSA anticipates issuing these rules in 2019.


Question:
Why GAO Did This Study

IRS estimates that fraudsters attempted at least $14.5 billion in IDT tax refund fraud in tax year 2015. Since 2015, GAO's High-Risk List has included IRS's efforts to address IDT refund fraud. Starting with its March 2015 Security Summit, IRS has partnered with state tax administrators and tax preparation companies, among others, on initiatives aimed at better preventing and detecting IDT refund fraud.
GAO was asked to examine IRS's efforts to collaborate with these partners. This report, among other things, (1) describes actions taken to implement the ISAC and RRT, (2) evaluates the extent to which the ISAC pilot aligns with leading practices for pilot design, and (3) identifies actions, if any, that IRS could take to improve the ISAC pilot.
GAO reviewed planning and other documents on the initiatives. It interviewed IRS and state officials and industry and trade organization representatives, among others involved in the ISAC and RRT. GAO also conducted four non-generalizable focus groups with state and industry partners.

What GAO Found

The Internal Revenue Service (IRS) launched an Identity Theft Tax Refund Fraud Information Sharing and Analysis Center (ISAC) pilot for the 2017 filing season. It aims to allow IRS, states, and tax preparation industry partners to quickly share information on identity theft (IDT) refund fraud. The ISAC pilot includes two components: an online platform run by IRS to communicate data on suspected fraud, and an ISAC Partnership, a collaborative organization comprised of IRS, states, and industry, which is intended to be the governance structure. As of November 2017, the ISAC had 48 members: 31 states (including full members and those receiving alerts only), 14 tax preparation companies, and 3 financial institutions. In addition, IRS is using a Rapid Response Team (RRT) in partnership with states and industry members to coordinate responses to IDT refund fraud incidents that pose a significant threat within 24 to 72 hours of being discovered. IRS deployed the RRT for six incidents in 2016 and once in 2017.
GAO found that the ISAC pilot aligns with key aspects of all five leading practices for effective pilot design GAO previously identified, but none fully. For example, IRS has worked to incorporate stakeholder input, but its message about the ISAC's benefits has not fully reached states. Further, IRS does not have criteria for assessing whether the pilot's objectives have been met. Without this assessment and better alignment with leading practices, IRS, its partners, and Congress will have difficulty determining the effectiveness of the pilot and whether to implement it more broadly.
IRS has taken actions to improve the ISAC pilot, but the ISAC Partnership does not have an outreach plan. While the ISAC Senior Executive Board limited industry participation to partners who participated in its Security Summit, the ISAC has obtained support from trade organizations. However, officials from almost all states represented in our focus groups noted that they either had not used, or were unfamiliar with, the ISAC-specific resources. While the ISAC Board has taken steps to engage stakeholders, the ISAC Partnership does not have an outreach plan to increase membership and improve states' and industry partners' understanding of the ISAC's benefits. Without such a plan, less effective collaboration is likely among stakeholders and opportunities to prevent IDT refund fraud may be missed.

What GAO Recommends

GAO recommends IRS ensure (1) the ISAC better aligns with leading practices for effective pilot design, and (2) the ISAC Partnership develops an outreach plan to expand membership and improve understanding of the ISAC's benefits. IRS and the ISAC Board state and industry co-chairs agreed with the recommendations.


Question:
Why GAO Did This Study

Congress recognizes the harmful effects of permitting delays on infrastructure projects and has passed legislation to streamline project reviews and hold agencies accountable. For example, in 2015 Congress passed the Fixing America's Surface Transportation Act, which included provisions streamlining the permitting process. Federal agencies, including the Department of the Interior and FERC, play a critical role by reviewing energy infrastructure projects to ensure they comply with federal statutes and regulations.
This testimony discusses factors GAO found that can affect energy infrastructure permitting timeliness and efficiency. To do this work, GAO drew on reports issued from July 2012 to December 2017. GAO reviewed relevant federal laws, regulations, and policies; reviewed and analyzed federal data; and interviewed tribal, federal, state and industry officials, among others.

What GAO Found

GAO's prior work has found that the timeliness and efficiency of permit reviews may be affected by a range of factors. For the purposes of this testimony, GAO categorized these factors into five categories.
Coordination and Communication. GAO found that better coordination between agencies and applicants is a factor that could result in more efficient permitting. Coordination practices that agencies can use to streamline the permitting process include the following:
Designating a Lead Coordinating Agency . GAO found having a lead agency to coordinate the efforts of federal, state, and local stakeholders is beneficial to permitting processes. For example, in a February 2013 report on natural gas pipeline permitting, industry representatives and public interest groups told GAO that the interstate process was more efficient than the intrastate process because in the interstate process the Federal Energy Regulatory Commission (FERC) was lead agency for the environmental review.
Establishing Coordinating Agreements among Agencies . In the February 2013 report, GAO reported that FERC and nine other agencies signed an interagency agreement for early coordination of required environmental and historic preservation reviews to encourage the timely development of pipeline projects.
Human Capital. Agency and industry representatives cited human capital factors as affecting the length of permitting reviews. Such factors include having a sufficient number of experts to review applications. GAO reported in November 2016 on long-standing workforce challenges at the Department of the Interior's Bureau of Indian Affairs (BIA), such as inadequate staff resources and staff at some offices without the skills to effectively conduct such reviews. GAO recommended that Interior incorporate effective workforce planning standards by assessing critical skills and competencies needed to fulfill its responsibilities related to energy development. Interior agreed with this recommendation, and BIA stated that its goal is to develop such standards by the end of fiscal year 2018.
Collecting and Analyzing Accurate Milestone Information. GAO's work has shown that a factor that hinders efficiency and timeliness is that agencies often do not track when permitting milestones are achieved, such as the date a project application is submitted or receives final agency approval. Having quality information on permitting milestones can help agencies better analyze process deficiencies and implement improvements.
Incomplete Applications. Agency officials and agency documents cited incomplete applications as affecting the duration of reviews. For example, in a 2014 budget document, BLM reported that—due to personnel turnover in the oil and gas industry—operators were submitting inconsistent and incomplete applications for drilling permits, delaying permit approvals.
Significant Policy Changes. Policy changes unrelated to permitting can affect permitting time frames. For example, after the 2010 Deepwater Horizon incident and oil spill, Interior issued new safety requirements for offshore drilling. GAO found that review times for offshore oil and gas drilling permits increased after these safety requirements were implemented.

What GAO Recommends

GAO has made numerous recommendations about ways to improve energy infrastructure permitting processes. Federal agencies have implemented a number of GAO's recommendations and taken steps to implement more efficient permitting, but several of GAO's recommendations remain open, presenting opportunities to continue to improve permitting processes.


Question:
Why GAO Did This Study

For decades, Energy, its predecessor agencies, and contractors employed thousands of employees in hazardous work in nuclear weapons production, exposing many employees to toxic substances. The Energy Employees Occupational Illness Compensation Program, administered by DOL, provides compensation for illnesses linked to exposures. Since 2004, DOL has provided about $4.4 billion to eligible employees and their survivors.
GAO was asked to review aspects of the claims process for contracted employees. GAO examined (1) the number and outcome of compensation claims for illnesses resulting from exposure to toxins that DOL has reopened since 2012, and (2) the Advisory Board's advice to DOL on the scientific soundness of its database on toxins and illnesses, and DOL's responses. GAO analyzed DOL claims data for 2012—when a new data system was introduced— through 2017 and assessed their reliability. GAO reviewed relevant federal laws and DOL procedures, and Advisory Board documents and interviewed DOL officials, Advisory Board members, experts, and a claimant advocate.

What GAO Found

The Department of Labor (DOL), from 2012 through 2017, reopened more than 7,000 compensation claims by contracted workers with illnesses resulting from exposure to toxins at Department of Energy (Energy) worksites. Of these reopened claims, 69 percent were approved for compensation (see figure). Claims can be reopened for various reasons, including new information on toxic substances and associated illnesses or new evidence provided by a claimant. According to DOL's Office of the Ombudsman officials, some claims may have been denied as a result of claimants not understanding the evidence required to support their claim. Moreover, the Ombudsman's two most recent reports in 2015 and 2016 found DOL's letters to claimants requesting additional evidence or informing them of the final decision did not clearly explain the specific evidence needed or why previously submitted evidence was deemed insufficient. GAO's previous work also found deficiencies in the quality of a sample of DOL's written communication with claimants. DOL has provided training to claims examiners on how to write clearly in correspondence and plans to assess the training. The assessment is an opportunity for DOL to better understand why some claimants remain confused about needed evidence and could help DOL target its training resources more effectively.
The Advisory Board on Toxic Substances and Worker Health (Advisory Board) recommended in 2016 and 2018 that DOL incorporate additional sources of information on toxic substances and associated illnesses into the database it uses to help determine eligibility for claims compensation. While DOL noted that certain additional data sources might be useful, it has not added all of the recommended data sources. The Advisory Board was created to provide technical advice to DOL on its database, among other things.

What GAO Recommends

GAO recommends that DOL ensure any assessment of its staff training efforts considers claimants' challenges with understanding DOL's communications on evidence for claims. DOL neither agreed nor disagreed with the recommendation except to note that it plans to focus its training on such topics as quality of written communications and assess its training efforts.


Question:
Why GAO Did This Study

Developing independently capable ANDSF is a key component of U.S. and coalition efforts to create sustainable security and stability in Afghanistan under the North Atlantic Treaty Organization (NATO)-led Resolute Support mission. The United States is the largest contributor of funding and personnel to Resolute Support, providing and maintaining ANDSF equipment, along with training, advising, and assistance to help the ANDSF effectively use and sustain the equipment in the future.
House Report 114-537 included a provision for GAO to review the ANDSF's capability and capacity to operate and sustain U.S.-purchased weapon systems and equipment. This report addresses (1) what has been reported about ANDSF capabilities and capability gaps and (2) the extent to which DOD has information about the ANDSF's ability to operate and maintain U.S.-purchased equipment. To conduct this work, GAO analyzed DOD and NATO reports and documents, examined three critical equipment types, and interviewed DOD officials in the United States and Afghanistan.
This is a public version of a sensitive report issued in September 2018. Information that DOD deemed sensitive has been omitted.

What GAO Found

Since the Resolute Support mission began in 2015, the Afghan National Defense and Security Forces (ANDSF) have improved some fundamental capabilities, such as high-level operational planning, but continue to rely on U.S. and coalition support to fill several key capability gaps, according to Department of Defense (DOD) reporting. DOD has initiatives to address some ANDSF capability gaps, such as a country-wide vehicle maintenance and training effort, but DOD reports it does not expect the ANDSF to develop and sustain independent capabilities in some areas, such as logistics, for several years.
While DOD has firsthand information on the abilities of the Afghan Air Force and Special Security Forces to operate and maintain U.S.-purchased equipment, it has little reliable information on the equipment proficiency of conventional ANDSF units. U.S. and coalition advisors are embedded at the tactical level for the Air Force and Special Security Forces, enabling DOD to directly assess those forces' abilities. However, the advisors have little direct contact with conventional ANDSF units on the front lines. As a result, DOD relies on those units' self-assessments of tactical abilities, which, according to DOD officials, can be unreliable.
GAO's analysis of three critical equipment types illustrated the varying degrees of DOD's information (see figure above). For example, DOD provided detailed information about the Air Force's ability to operate and maintain MD-530 helicopters and the Special Security Forces' ability to operate and maintain Mobile Strike Force Vehicles; however, DOD had limited information about how conventional forces operate and maintain radios and Mobile Strike Force Vehicles. DOD's lack of reliable information on conventional forces' equipment operations and maintenance abilities adds to the uncertainty and risk in assessing the progress of DOD efforts in Afghanistan.

What GAO Recommends

GAO recommends that DOD develop options for collecting reliable information on conventional ANDSF units' ability to operate and maintain U.S.-purchased equipment. DOD concurred with this recommendation.


Question:
Why GAO Did This Study

To secure the southwest border between ports of entry, Border Patrol uses approximately 5,200 miles of roads, most of which are owned by other entities, both private and public. CBP estimates spending $12.5 million in fiscal year 2016 to maintain and repair roads Border Patrol uses for its operations, including roads CBP does not own.
GAO was asked to review Border Patrol's use and maintenance of roads for its border security operations. This report examines the extent to which (1) CBP has processes and authorities to access and maintain roads for its security operations and (2) CBP's operations are affected by its use of public roads it cannot maintain, and options CBP could consider to address any needed maintenance. GAO selected three southwest border sectors to visit based on the sectors' total mileage of non-owned roads and number of apprehensions of illegal border crossers. GAO interviewed officials from Border Patrol, and from selected federal, state, local, tribal, and private and community organizations. The information collected from these entities is not generalizable, but provides valuable insights.

What GAO Found

U.S. Border Patrol, within the Department of Homeland Security's (DHS) U.S. Customs and Border Protection (CBP), generally has access to public roads and has certain processes and authorities to use other federal, state, local, tribal, and private owned roads for its operations. CBP may enter into arrangements or agreements to address maintenance of certain federal, state, local, and private roads, but CBP has not consistently documented these arrangements, or shared them with all relevant Border Patrol sector officials. This could hinder maintenance efforts and, therefore, Border Patrol's access to the roads. Six of the nine southwest Border Patrol sectors reported that they do not document all road maintenance arrangements and agreements. Developing a policy and guidance for documenting maintenance arrangements and agreements, as needed, could help all sectors more consistently work with landowners to address road maintenance. CBP has two categories for the roads it maintains: (1) roads that CBP owns and has a right to maintain (owned operational roads) and (2) roads that CBP does not own, but may maintain through a license or permit (non-owned operational roads). Border Patrol has established a process for prioritizing maintenance of owned operational roads, but it has not clearly documented the process and criteria for non-owned operational roads, or shared this information with sector officials. Moreover, no sector official GAO spoke with reported being aware of the process and criteria. By clearly documenting and communicating the process and criteria it uses to prioritize non-owned operational roads, Border Patrol could enable sectors to more adequately plan for and better anticipate funding to meet road maintenance needs.
Border Patrol sector officials reported negative effects from using public roads in poor condition that they cannot maintain, such as limited road access and poor relations with local governments and border communities that attribute the poor road conditions to Border Patrol's regular use. However, the full extent of these effects is unknown due to lack of data on Border Patrol's use of non-owned roads. While CBP officials discussed options for addressing maintenance of non-federal public roads, including a specific appropriation or a grant program, it has not assessed the feasibility of these or other options. Assessing the feasibility of options, including a review of data needed to show Border Patrol's reliance on non-owned roads, including public roads, could lead to a possible solution for enhancing Border Patrol's operations and its community relationships.

What GAO Recommends

GAO recommends that CBP develop policy and guidance for documenting arrangements with landowners, as needed, and share the arrangements with its sectors; document and communicate the process and criteria for prioritizing funding of non-owned operational roads; and assess the feasibility of options, including data needs, for addressing the maintenance of non-federal public roads. DHS concurred with the recommendations.


Question:
Why GAO Did This Study

The Caribbean region, which shares geographic proximity and common interests with the United States, faces high rates of crime and violence. In 2010, the United States and Caribbean countries formally launched CBSI, which aims to increase citizen safety. GAO was asked to examine U.S. assistance through CBSI. This report (1) discusses U.S. funding for CBSI activities, (2) examines the extent to which there is a planning and reporting process for CBSI, and (3) examines the extent to which State and USAID have established objectives and performance indicators to measure progress of their CBSI activities. GAO analyzed State and USAID data; assessed government strategies and performance reports; selected a non-generalizable sample of 25 CBSI activities and analyzed State and USAID documentation related to those activities; interviewed relevant officials; and conducted fieldwork in Barbados, Dominican Republic, and Jamaica, which are the countries generally receiving the most CBSI funding.

What GAO Found

U.S. agencies have allocated more than $560 million for the Caribbean Basin Security Initiative (CBSI) from fiscal years 2010 through 2018 for activities related to the three pillars of CBSI—reduce illicit trafficking (such as in narcotics and firearms), improve public safety and security, and promote social justice. For example, State Department's (State) Bureau of International Narcotics and Law Enforcement Affairs (INL) has ongoing activities such as advisory programs and equipment procurements, while the U.S. Agency for International Development (USAID) has activities aimed at increasing economic opportunities for at-risk youth and improving the skills of prosecutors.
The U.S. government has undertaken some planning and reporting of CBSI activities, but State has not created an initiative-wide planning and reporting mechanism. Agencies individually set strategic goals and priorities with CBSI countries and plan and report on their CBSI activities on a country-specific basis. However, State has not created an initiative-wide planning and reporting mechanism that facilitates interagency coordination or establishes consistent performance indicators across agencies, countries, and activities—key elements for effectively aligning foreign assistance strategies. Without such a planning and reporting mechanism, overall progress of the initiative cannot be assessed.
State and USAID have established objectives and performance indicators for selected CBSI activities, and INL is taking steps to improve identified weaknesses in its program monitoring. State and USAID had established objectives and performance indicators for the 25 activities in our sample. However, INL cannot ensure the reliability of its program monitoring data because collection and maintenance of this data is conducted differently in each country and there is no centralized data storage system. INL recently contracted to improve and standardize its program monitoring data for Western Hemisphere activities, but according to INL officials, data challenges remain—in particular, how to collect standardized data from each of the embassies and how to build a data management system that is compatible with State requirements. Without reliable data, INL may continue to struggle with program monitoring of CBSI activities.

What GAO Recommends

GAO recommends that State (1) create an initiative-wide planning and reporting mechanism for CBSI that includes the ability to monitor, evaluate, and report the results of collaborative efforts, and (2) ensure that INL develops and implements a data management system for centrally collecting reliable CBSI data. State agreed with the recommendations, noting that it plans to develop an updated Results Framework for initiative-wide planning and reporting and to improve centralized data collection through an enhanced data management system.


Question:
Why GAO Did This Study

The U.S. workforce force has become increasingly diverse and is projected to become even more diverse in the coming decades. As a result, many private sector organizations have recognized the importance of recruiting and retaining minorities and women for key positions to improve their business or organizational performance and help them better meet the needs of a diverse customer base. The financial services industry is a major source of employment in the United States and affects the economic well-being of its customers. However, questions remain about diversity in the financial services industry, which provides services that help families build wealth and are essential to economic growth.
GAO was asked to analyze diversity trends in the financial services industry, particularly in management positions. This report examines (1) trends in management-level diversity in the financial services industry from 2007 through 2015, (2) trends in diversity among potential talent pools, and (3) challenges financial services firms identified in trying to increase workforce diversity and practices firms used to address them.
GAO analyzed data from the Equal Employment Opportunity Commission (EEOC) and the Department of Education. The most recent available data were from 2015. GAO also reviewed studies on workforce diversity and interviewed representatives from financial services firms and organizations that advocate for the financial services industry, women, or minorities. EEOC provided technical comments on a draft of this report that GAO incorporated as appropriate.

What GAO Found

Overall representation of minorities in first-, mid-, and senior-level management positions in the financial services industry increased from about 17 percent to 21 percent from 2007 through 2015. However, as shown in the figure below representation varied by race/ethnicity group and management level. Specifically, representation of African-Americans at various management levels decreased while representation of other minorities increased during this period. Overall representation of women was generally unchanged during this period. Representation of women among first- and mid-level managers remained around 48 percent and senior-level managers remained about 29 percent from 2007 through 2015.
Potential employees for the financial services industry, including those that could become managers, come from external and internal pools. For example, the external pool includes those with undergraduate or graduate degrees, such as a Master of Business Administration. In 2015, about 33 percent of the external pool included minorities and around 60 percent were women. The internal talent pool for potential managers in financial services includes those already in professional positions. In 2015, nearly 28 percent of professional positions in financial services were held by minorities and just over 51 percent were held by women.
Research, financial services firm representatives, and financial industry stakeholders described challenges to recruiting and retaining members of racial/ethnic minority groups and women and practices that could help address these challenges, including recruiting from a wider variety of schools. Firm representatives said that it is important for firms to assess firm-level data on diversity and inclusiveness. However, firm representatives and other stakeholders differed in their views on whether firm-level diversity data should be made public. For example, one stakeholder stated that sharing diversity data publicly would create incentives for improvement. However, a firm representative said that for firms that are not diverse, making employee diversity data public could make improvement of workforce diversity more difficult for them.


Question:
Why GAO Did This Study

Congress has authorized federal agencies to collect hundreds of billions of dollars annually in fees, fines, and penalties. These collections can fund a variety of programs, including programs related to national security, and the protection of natural resources. Data on collections are important for congressional oversight and to provide transparency in agencies' use of federal resources.
GAO was asked to review the availability of government-wide data on fees, fines, and penalties. This report examines (1) the extent to which data on collections of fees, fines, and penalties are publically available and useful for the purpose of congressional oversight; and (2) the benefits and challenges to government-wide reporting of fees, fines, and penalties. GAO assessed government-wide fee, fine, and penalty data against criteria for availability and usefulness based on multiple sources, including prior GAO work and input from staff of selected congressional committees. GAO interviewed OMB staff, Treasury officials, and representatives of organizations with expertise in federal budget issues and reviewed prior GAO work to identify benefits and challenges of reporting these data.

What GAO Found

There are no comprehensive, government-wide data at the level of detail that identifies specific fees, fines, or penalties. The Office of Management and Budget (OMB) and the Department of the Treasury (Treasury) report data that include these collections at the budget account level, which generally covers a set of agency activities or programs. OMB and Treasury also report some summary data for budgeting and financial management purposes. In the Budget of the U.S. Government , for example, OMB data showed government-wide fees totaled just over $335 billion in fiscal year 2017. These reports, however, are not designed to inventory or analyze fee, fine, or penalty collections and have significant limitations for that purpose.
Although OMB collects more disaggregated data on fees, fines, and penalties, it does not make the data publicly available. OMB uses the disaggregated data in its OMB MAX database—such as the agency and account—to compile reported totals, such as the government-wide fees total in the Budget of the U.S. Government . Until OMB makes more disaggregated data publicly available, Congress has limited information on collections by agency to inform oversight and decision-making.
OMB's government-wide total of fees includes collections that are not fees and excludes some fee collections. The total includes all collections for accounts in which fees make up at least half of the account's collections and excludes all others. OMB does not direct agencies to regularly review and update the accounts included in the total. Therefore, if accounts' makeups change such that fee collections drop below, or rise above, the 50 percent threshold, accounts may have incorrect fee designations and the total may be inaccurate.
Further, OMB does not disclose the limitation that the total may exclude some fees and include other collections that are not fees. As a result, some users of the data are likely unaware of the potential for the total fees to be overestimated or underestimated.
Further, no source of government-wide data consistently reports data elements on fees, fines, and penalties that could help inform congressional oversight. Generally, congressional staff told us that additional data, such as amounts of specific penalties, would increase transparency and facilitate oversight. These data could help Congress identify trends in collections and significant changes that could be an indication of an agency's performance. While reporting government-wide fee, fine, and penalty data provides benefits, there are trade-offs in terms of the time and federal resources it would take to develop and implement a process for agencies to report these data. The level of federal investment would vary depending on factors, such as the number of data elements included and the level of detail reported. Developing a comprehensive and accessible data source would provide greater benefits, but would likely be resource intensive. Alternatively, incorporating a small number of data elements that Congress identifies as most useful for oversight into ongoing government-wide reporting efforts could incrementally improve transparency and information for oversight and decision-making, with fewer resources.

What GAO Recommends

GAO is making four recommendations to enhance OMB reporting on fees, fines, and penalties, including making disaggregated data publically available, updating instructions to federal agencies to review accounts designated as containing fees, and disclosing limitations in data reported. OMB did not provide comments.


Question:
Why GAO Did This Study

FSA administers billions of dollars in student financial aid, including loans and grants, to eligible college students. The processing of student aid is complex, and FSA relies on non-school partners to carry out various activities supporting the student aid process, such as loan repayment and collection.
GAO was asked to review how FSA ensures the protection of PII by its non-school partners. The objectives of this review were to (1) describe the roles of non-school partners and the types of PII shared with them and (2) assess the extent to which FSA policies and procedures for overseeing the non-school partners' protection of student aid data adhere to federal requirements, guidance, and best practices.
To address these objectives, GAO collected and reviewed FSA documentation, reports, policies, and procedures and compared FSA policies and procedures to four key practices included in federal guidance for overseeing the protection of PII by non-federal entities. GAO also interviewed FSA officials with responsibility for the oversight of non-school partners.

What GAO Found

The Department of Education's Office of Federal Student Aid (FSA) partners with various entities (“non-school partners”) that are involved primarily in supporting the repayment and collection of student loans.
Federal loan servicers are responsible for collecting payments on loans and providing customer service to borrowers on behalf of the Department of Education through its Direct Loan program.
Private collection agencies collect on loans that are in default and work with borrowers to help them get out of default.
Guaranty agencies insure lenders against loss due to borrower default and carry out a variety of loan administration activities.
Federal Family Education Loan lenders are non-federal lenders, such as banks, credit unions, or other lending institutions, that made loans to students in the past and continue to service these loans.
FSA shares a variety of personally identifiable information (PII) on borrowers with its non-school partners. This includes names, addresses, phone numbers, email addresses, Social Security numbers, and financial information.
Key practices for overseeing the protection of PII shared with non-federal entities include requiring (1) risk-based security and privacy controls, (2) independent assessments to ensure controls are effectively implemented, (3) corrective actions to address identified weaknesses in controls, and (4) ongoing monitoring of control status. FSA established oversight policies and procedures for loan servicers and private collection agencies that generally address these key practices. However, FSA exercises minimal oversight of lenders' protection of student data (see table).
FSA officials maintain that the lenders are subject to other legal and regulatory requirements for protecting customer data. However, FSA does not have a process for ensuring lenders are complying with these requirements, and thus lacks assurance that appropriate risk-based safeguards are being effectively implemented, tested, and monitored.

What GAO Recommends

GAO is making six recommendations to FSA to ensure that its oversight of non-school partners addresses the four key practices for ensuring the protection of PII. FSA concurred with three of the recommendations, partially concurred with two, and did not concur with one. It also described actions planned or under way to implement four of the recommendations. GAO maintains that all of its recommendations are warranted.


Question:
Why GAO Did This Study

Lead paint in housing is the most common source of lead exposure for U.S. children. HUD awards grants to state and local governments to reduce lead paint hazards in housing and oversees compliance with lead paint regulations in its rental assistance programs. The 2017 Consolidated Appropriations Act, Joint Explanatory Statement, includes a provision that GAO review HUD’s efforts to address lead paint hazards. This report examines HUD’s efforts to (1) incorporate statutory requirements and other relevant federal standards in its lead grant programs, (2) monitor and enforce compliance with lead paint regulations in its rental assistance programs, (3) adopt federal health guidelines and environmental standards for its lead grant and rental assistance programs, and (4) measure and report on the performance of its lead efforts. GAO reviewed HUD documents and data related to its grant programs, compliance efforts, performance measures, and reporting. GAO also interviewed HUD staff and some grantees.

What GAO Found

The Department of Housing and Urban Development’s (HUD) lead grant and rental assistance programs have taken steps to address lead paint hazards, but opportunities exist for improvement. For example, in 2016, HUD began using new tools to monitor how public housing agencies comply with lead paint regulations. However, HUD could further improve efforts in the following areas:
Lead grant programs. While its recent grant award processes incorporate statutory requirements on applicant eligibility and selection criteria, HUD has not fully documented or evaluated these processes. For example, HUD’s guidance is not sufficiently detailed to ensure consistent and appropriate grant award decisions. Better documentation and evaluation of HUD’s grant program processes could help ensure that lead grants reach areas at risk of lead paint hazards. Further, HUD has not developed specific time frames for using available local-level data to better identify areas of the country at risk for lead paint hazards, which could help HUD target its limited resources.
Oversight. HUD does not have a plan to mitigate and address risks related to noncompliance with lead paint regulations by public housing agencies. We identified several limitations with HUD’s monitoring efforts, including reliance on public housing agencies’ self-certifying compliance with lead paint regulations and challenges identifying children with elevated blood lead levels. Additionally, HUD lacks detailed procedures for addressing noncompliance consistently and in a timely manner. Developing a plan and detailed procedures to address noncompliance with lead paint regulations could strengthen HUD’s oversight of public housing agencies.
Inspections. The lead inspection standard for the Housing Choice Voucher program is less strict than that of the public housing program. By requesting and obtaining statutory authority to amend the standard for the voucher program, HUD would be positioned to take steps to better protect children in voucher units from lead exposure as indicated by analysis of benefits and costs.
Performance assessment and reporting. HUD lacks comprehensive goals and performance measures for its lead reduction efforts. In addition, it has not complied with annual statutory reporting requirements, last reporting as required on its lead efforts in 1997. Without better performance assessment and reporting, HUD cannot fully assess the effectiveness of its lead efforts.

What GAO Recommends

GAO makes nine recommendations to HUD including to improve lead grant program and compliance monitoring processes, request authority to amend its lead inspection standard in the voucher program, and take additional steps to report on progress. HUD generally agreed with eight of the recommendations. HUD disagreed that it should request authority to use a specific, stricter inspection standard. GAO revised this recommendation to allow HUD greater flexibility to amend its current inspection standard as indicated by analysis of the benefits and costs.


Question:
Why GAO Did This Study

VA's disability compensation program pays cash benefits to veterans with disabilities connected to their military service. In recent years, the number of appeals of VA's benefit decisions has been rising. For decisions made on appeal in fiscal year 2017, veterans waited an average of 3 years for resolution by either VBA or the Board, and 7 years for resolution by the Board. The Veterans Appeals Improvement and Modernization Act of 2017 makes changes to VA's current (legacy) appeals process, giving veterans new options to have their claims further reviewed by VBA or appeal directly to the Board. The Act requires VA to submit to Congress and GAO a plan for implementing a new appeals process, and includes a provision for GAO to assess VA's plan.
This testimony focuses on the extent to which VA's plan: (1) addresses the required elements in the Act, and (2) reflects sound planning practices identified in prior GAO work. GAO's work entailed reviewing and assessing VA's appeals plan and related documents against sound planning practices, and soliciting VA's views on GAO's assessments.

What GAO Found

The Department of Veterans Affairs' (VA) plan for implementing a new disability appeals process while attending to appeals in the current process addresses most, but not all, elements required by the Veterans Appeals Improvement and Modernization Act of 2017 (Act). VA's appeals plan addresses 17 of 22 required elements, partially addresses 4, and does not address 1. For example, not addressed is the required element to include the resources needed by the Veterans Benefits Administration (VBA) and the Board of Veterans' Appeals (Board) to implement the new appeals process and address legacy appeals under the current process. VA needs this information to certify, as specified under the Act, that it has sufficient resources to implement appeals reform and make timely appeals decisions under the new and legacy processes.
VA's appeals plan reflects certain sound planning practices, but it could benefit from including important details in several key planning areas:
Performance measurement : VA's plan reflects steps taken to track performance, but could articulate a more complete and balanced set of goals and measures for monitoring and assessing performance on a range of dimensions of success. Specifically, the plan reports that VA is developing a process to track timeliness of the new and legacy processes. However, contrary to sound planning practices, the plan does not include timeliness goals for all five appeals options available to veterans, does not include goals or measures for additional aspects of performance (such as accuracy or cost), and does not explain how VA will monitor or assess the new process compared to the legacy process. Unless VA clearly articulates a complete and balanced set of goals and measures, it could inadvertently incentivize staff to focus on certain aspects of appeals performance over others or fail to improve overall service to veterans.
Project management : VA's plan includes a master schedule for implementing the new appeals plan; however, this schedule falls short of sound practices because it does not include key planned activities—such as its pilot test of two of the five appeals options. In addition, the schedule does not reflect other sound practices for guiding implementation and establishing accountability—such as articulating interim goals and needed resources for, and interdependencies among, activities. Unless VA augments its master schedule to include all key activities and reflect sound practices, VA may be unable to provide reasonable assurance that it has the essential program management information needed for this complex and important effort.
Risk assessment : VA has taken steps to assess and mitigate some risks related to appeals reform by, for example, pilot testing two of the five appeals options through its Rapid Appeals Modernization Program (RAMP). However, as designed, RAMP does not include key features of a well-developed and documented pilot test. For example, VA has not articulated how it will assess RAMP before proceeding with full implementation. In addition, RAMP is not pilot testing three options and, as a result, VA will not have data on the extent to which veterans will appeal directly to the Board when given the option. Unless VA identifies and mitigates key risks associated with implementing a new process, VA is taking a chance that untested aspects will not perform as desired.

What GAO Recommends

In its forthcoming report, GAO is considering recommending that VA: fully address all legally required elements in its appeals plan, articulate how it will monitor and assess the new appeals process as compared to the legacy process, augment its master schedule for implementation, and more fully address risk.