Radiation Exposure Compensation: Analysis of Justice's Program
Administration (17-SEP-01, GAO-01-1043).
From 1945 through 1962, the United States conducted a series of
aboveground atomic weapons tests as it built up its Cold War
nuclear arsenal. Many people exposed to radiation resulting from
the nuclear weapons testing program subsequently developed
serious diseases, including various types of cancer. On October
15, 1990, in order to establish a procedure to make partial
restitution to these victims for their suffering, the President
signed into law the Radiation Exposure Compensation Act (RECA).
RECA established the Radiation Exposure Compensation Trust Fund
(Trust Fund), criteria for determining claimant eligibility for
compensation, and a program, administered by the Attorney
General, to process and adjudicate claims under the act. The
Department of Justice (DOJ) established the Radiation Exposure
Compensation Program (RECP) within its Civil Division to
administer its responsibilities under the act. Through the end of
fiscal year 2000, RCEP has received 7,819 applications for
compensation. Roughly equal numbers of applications have been
approved and denied, awarding compensation to about 46 percent of
the claimants and denying compensation to about 46 percent. RECA
claims are most frequently denied because the disease contracted
by the victim is not specifically designated as eligible for
compensation under the RECA program. The costs for administering
RECP have fluctuated from the first full year of program
implementation, fiscal year 1993, through fiscal year 2000. For
example, administrative costs were $2.1 million in fiscal year
1993 and $1.3 million in fiscal year 2000. DOJ has procedures in
place to certify that funds are appropriately disbursed from the
Trust Fund. A review of the payment documentation for 30 randomly
selected RECA cases, where compensation was awarded, indicated
that all payments were made as authorized. To identify and inform
candidates of their potential eligibility for compensation under
the program and to help them apply for funds, RECP engages in
three primary outreach programs. The program has established an
Internet website, conducts onsite visits to groups and
organizations to promote the program, and operates a toll-free
telephone line for program queries.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-01-1043
ACCNO: A01775
TITLE: Radiation Exposure Compensation: Analysis of Justice's
Program Administration
DATE: 09/17/2001
SUBJECT: Compensation claims
Radiation accidents
Radiation safety
Victim compensation
Eligibility criteria
Nuclear weapons testing
Radiation Exposure Compensation Program
Radiation Exposure Compensation Trust
Fund
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GAO-01-1043
Report to Congressional Committees
United States General Accounting Office
GAO
September 2001 RADIATION EXPOSURE COMPENSATION
Analysis of Justice's Program Administration
GAO- 01- 1043
Page i GAO- 01- 1043 Radiation Exposure Compensation Letter 1
Results in Brief 2 Background 3 Scope and Methodology 10 Analysis of
Processed RECA Claims 12 Certification of the Trust Fund Payments Appears
Adequate 19 Views on RECP?s Outreach Activities Are Mixed 20 Agency Comments
and Our Evaluation 23
Appendix I Data on Refiled and Appealed Claims 26
Appendix II GAO Contacts and Staff Acknowledgments 28
Tables
Table 1: Summary of Key Legal RECA Provisions by Claimant Category 4 Table
2: Number of RECA Claims Received From Fiscal Years 1992
Through 2000 13 Table 3: Radiation Exposure Compensation Trust Fund
Activity,
Fiscal Years 1992 Through 2000 15 Table 4: Average Processing Time for
Approved and Denied
Applications for Fiscal Years 1992 Through 2000 16 Table 5: Average Number
of Days to Process Approved and Denied
Claims for Fiscal Years 1992 Through 2000 17 Table 6: Average FTE Staff
Levels and Administrative Costs for
Processing RECA Claims for Fiscal Years 1992 Through 2000 19 Table 7:
Results of Appealed RECP Decisions for Fiscal Years 1992
Through 2000 27
Figure
Figure 1: RECP?s Claims Adjudication Process 8 Contents
Page ii GAO- 01- 1043 Radiation Exposure Compensation Abbreviations
DOJ Department of Justice FTE full- time equivalent JMD Justice Management
Division NGO Nongovernmental organization OPB& E Office of Planning, Budget
and Evaluation RECA Radiation Exposure Compensation Act RECP Radiation
Exposure Compensation Program WLM working level months
Page 1 GAO- 01- 1043 Radiation Exposure Compensation
September 17, 2001 Congressional Committees From 1945 through 1962, the
United States conducted a series of aboveground atomic weapons tests as it
built up its Cold War nuclear arsenal. Many people exposed to radiation
resulting from the nuclear weapons testing program subsequently developed
serious diseases, including various types of cancer. On October 15, 1990, in
order to establish a procedure to make partial restitution to these victims
for their suffering, 1 the President signed into law the Radiation Exposure
Compensation Act (RECA). 2 RECA established the Radiation Exposure
Compensation Trust Fund (Trust Fund), criteria for determining claimant
eligibility for compensation, and a program (administered by the Attorney
General) to process and adjudicate claims under the act. The Department of
Justice (DOJ) established the Radiation Exposure Compensation Program (RECP)
within its Civil Division to administer its responsibilities under the act.
Almost 2 years later, RECP began processing claims in April 1992. RECA has
been amended several times, 3 most recently on July 10, 2000, when the
President signed into law the Radiation Exposure Compensation Act Amendments
of 2000. 4 The 2000 amendments further broaden the scope of eligibility for
benefits coverage to include new victim categories and modify the criteria
for determining eligibility for compensation.
The 2000 amendments also mandate that we periodically report to the Congress
on DOJ?s administration of the program. This report covers program
performance from 1992 to the end of fiscal year 2000 and (1) determines the
outcomes of RECP?s claim review and adjudication process; (2) quantifies the
costs to DOJ for administering the program; (3) documents DOJ?s procedures
to certify that funds are appropriately disbursed from the Trust Fund; and
(4) describes RECP?s outreach
1 The amount of money paid does not completely compensate for the victim?s
costs or suffering. 2 P. L. 101- 426, 104 Stat. 920 (Oct. 5, 1990).
3 Early amendments included November 1990 amendments (P. L. 101- 510, 104
Stat. 1835, 1837), which among other things expanded eligibility to include
onsite participants and October 1992 amendments (P. L. 102- 486, 106 Stat.
3131), which provided for the judicial review of denied claims.
4 P. L. 106- 245, 114 Stat. 501.
United States General Accounting Office Washington, DC 20548
Page 2 GAO- 01- 1043 Radiation Exposure Compensation
activities intended to inform potential claimants about and facilitate their
applying for compensation.
Through the end of fiscal year 2000, RECP has received 7,819 applications
for compensation. Roughly equal numbers of applications have been approved
and denied, awarding compensation to about 46 percent of the claimants and
denying compensation to about 46 percent. Approximately 8 percent of the
applications were still pending at the time of our analysis. RECA claims are
most frequently denied because the disease contracted by the victim is not
specifically designated as eligible for compensation under the RECA program.
Treasury paid $245.1 million in compensation to 5,150 victims or their
survivors, but later awards were not paid by the end of fiscal year 2000
because the money in the Trust Fund was depleted. Subsequently, funds were
appropriated to pay these claims. Although lack of funds may have prevented
timely payment of compensation in some cases, RECP generally processed
claims in a timely fashion. RECP case histories data showed that 89 percent
of the claims were processed within the mandated 12 months. According to
RECP officials, the remaining claims were not processed in a timely fashion
because of mitigating circumstances. For example, rather than denying a
claim in certain situations, RECP allowed a claimant extra time to find
documentation to substantiate his or her claim, which delayed adjudication
of the case.
The costs for administering RECP have fluctuated from the first full year of
program implementation, fiscal year 1993, through fiscal year 2000. For
example, administrative costs were $2.1 million in fiscal year 1993 and $1.3
million in fiscal year 2000. Full- time equivalent (FTE) staff levels have
ranged from 15.4 in fiscal year 1994 to10. 4 in fiscal year1999.
DOJ has procedures in place to certify that funds are appropriately
disbursed from the Trust Fund. Our review of the payment documentation for
30 randomly selected RECA cases, where compensation was awarded, indicated
that all payments were made as authorized.
To identify and inform candidates of their potential eligibility for
compensation under the program and to help them apply for funds, RECP
engages in three primary outreach activities. The program has established an
Internet website, 5 conducts onsite visits to groups and organizations to
promote the program, and operates a toll- free telephone line for program
5 The RECP website address is http:// www. usdoj. gov/ civil/ torts/ const/
reca/ index. htm. Results in Brief
Page 3 GAO- 01- 1043 Radiation Exposure Compensation
queries. We spoke with 11 nongovernmental organizations (NGO) that assist
potential RECA claimants. These groups had mixed comments about RECP?s
outreach efforts. Although five organizations said that RECP had made an
effort to inform them about their eligibility for the program, eight said
that RECP had made no attempt to coordinate its outreach efforts with them.
RECP officials told us that they are looking into the concerns raised by the
NGOs and are actively exploring new techniques for meeting the needs of
claimants and others interested in the program.
In its comments on a draft of this report, Justice generally concurred with
our results.
RECA establishes a procedure to make partial restitution to individuals who
contracted serious diseases, such as certain types of cancers, presumably
resulting from their exposure to radiation from aboveground nuclear tests or
as a result of their employment in uranium mines. The law established three
claimant categories- uranium mine employees (those who worked in underground
uranium mines in certain specified states), downwinders (those who were
downwind from aboveground nuclear weapons tests conducted at the Nevada test
sites), and onsite participants (those who actually participated onsite in
aboveground nuclear weapons tests). Table 1 summarizes the key provisions of
RECA by type of claim, prior to the RECA 2000 Amendments. Background
Page 4 GAO- 01- 1043 Radiation Exposure Compensation
Table 1: Summary of Key Legal RECA Provisions by Claimant Category Claimant
category a Time periods Location Amount of
compensation Examples of diseases covered Other
Uranium mine employees Any time from January 1,
1947- December 31, 1971. Colorado, New Mexico, Arizona,
Wyoming, or Utah. $100,000 Lung cancer and
certain nonmalignant respiratory diseases.
Victims must have been exposed to minimum levels of radiation. b Downwinders
A period of at least 2
years from January 21, 1951- October 31, 1958 or for the period between June
30 and July 31, 1962.
Certain Utah, Nevada, and Arizona counties downwind from the Nevada test
site.
$50,000 All of the primary cancers listed in RECA, such as leukemia and
lymphomas, multiple myeloma, and primary cancer of the thyroid.
Onsite participants Designated nuclear tests
from July 16, 1945- December 31, 1962.
Onsite testing areas include the Nevada, Pacific, Trinity, and the South
Atlantic test sites. c
$75,000 Certain types of leukemia and lymphomas, multiple myeloma, and
primary cancer of the thyroid.
Justice identifies the test sites in the RECA implementation regulations.
a Also includes victim?s survivors. b Levels of exposure to radiation are
referred to as working level months (WLMs) and are calculated by multiplying
the number of months an individual worked in a particular uranium mine and
the radon level in the mine during the period of employment. Minimum WLM
exposure for eligibility purposes varied from 200 to 500 WLMs and is on the
basis of the victim?s smoking history and age of diagnosis with a
compensable disease.
c Justice lists the dates and locations of the atmospheric tests conducted
by the federal government in regulations codified at 28 C. F. R. Part 79.
For claimant eligibility, Justice adds 6 months to the end of the designated
time span for each of the listed test periods.
Source: RECA and related regulations.
In addition to creating eligibility criteria for compensation, the law
stipulates that appropriated funds be held in the Trust Fund to pay claims.
By law, the Trust Fund is to be administered by the Secretary of the
Treasury but maintained by the Attorney General. The Attorney General is
also responsible for reviewing applications to determine whether applicants
qualify for compensation and establishing procedures for paying claims. To
discharge these two responsibilities, the Attorney General issued a final
regulation implementing RECP on April 10, 1992.
The regulation established RECP within Justice?s Civil Division and charged
it with administering claims adjudication and compensation under the act. To
file for compensation, applicants submit the appropriate claims forms along
with corroborating documentation to RECP, whose claims examiners and legal
staff review and adjudicate the claims. If the claim is approved, Justice
authorizes the Treasury Department to make payment
Page 5 GAO- 01- 1043 Radiation Exposure Compensation
from the Trust Fund. If the victim is deceased, compensation may be awarded
to the victim?s eligible survivors (e. g., the victim?s spouse or children).
Figure 1 shows RECP?s claims adjudication process, including the procedures
for refiling and administratively appealing denied claims.
If RECP denies a claim, it notifies the claimant in writing of the basis for
the denial and the claimant?s rights to refile or appeal the claim.
Claimants may refile a claim with new information to RECP up to two times.
If denied, claimants may file an administrative appeal to a Justice Appeals
Officer, who can affirm or reverse the original decision or remand the claim
back to RECP for further action. Applicants may also appeal denied claims in
the U. S. district courts. RECP officials said that through July 3, 2001,
claimants sought a judicial remedy only eight times.
More recently, the Attorney General approved revisions to the regulations,
effective April 21, 1999, to assist claimants in establishing entitlement to
an award. The revised regulations modified eligibility restrictions
regarding the claimants? use of tobacco. Prior to the revision, RECP would
apply stricter standards if the victim contracted certain qualifying
diseases and was a ?heavy smoker? or ?heavy drinker.? 6 The revised
regulations, among other things, allow claimants to submit affidavits to
establish smoking use histories and to submit pathology reports showing
specified diseases. In addition, the changes permit applicants, whose claims
were denied prior to the implementation of these regulations, to file
another three times.
The RECA Amendments of 2000, 7 signed into law by the President on July 10,
2000, expanded the criteria for compensation, opening RECP to more people
and establishing a prompt payment period. Some of the major changes include:
permitting eligible aboveground uranium mine employees, uranium mill
workers, and individuals, who transported uranium ore, to qualify for
compensation; they are entitled to a payment of $100,000;
increasing the geographic areas included for eligibility and extending the
time period considered for radiation exposure for uranium mine employees;
6 The revisions modify the definition of nonsmoker to include former smokers
who stopped smoking at least 15 years prior to the diagnosis of a
compensable disease. 7 P. L. 106- 245.
Page 6 GAO- 01- 1043 Radiation Exposure Compensation
expanding the list of specified diseases that may qualify individuals for
compensation to include other types of cancer and also noncancers (e. g.,
salivary gland, brain, and colon cancer);
decreasing the level of radiation exposure that is necessary to qualify
for compensation for uranium mine employees; 8
making certain medical documentation requirements less stringent for
potential claimants;
eliminating distinctions between smokers and nonsmokers pertaining to
diseases such as lung cancer and nonmalignant respiratory diseases; and
requiring the Attorney General to ensure that a claim is paid within 6
weeks of approval.
8 The minimum radiation exposure level for uranium mine employees was
reduced from a range from 200 to 500 WLMs to 40 WLMs.
Page 7 GAO- 01- 1043 Radiation Exposure Compensation
Page 8 GAO- 01- 1043 Radiation Exposure Compensation
Figure 1: RECP?s Claims Adjudication Process
Claim received by
RECP RECP notifies
claimant of approval and authorizes the
payment of claim by Treasury Claims examiner
analyzes the information and
recommends approval or, if the
eligibility criteria cannot be met,
denial No
No No
Ye s Ye s
B
Ye s RECP attorney
reviews the recommendation
and drafts a decision a
Claimant notified of the denial and the reason for the
denial b
A C
Is the claim application complete
and appropriately documented?
Does assistant director
approve the claim? a
Is required information
received? Receipt is
acknowledged RECP requests
additional information from
the claimant and outside organizations to
correct the deficiency
If the information Is not provided after a second request, the claims
examiner
recommends that claim be
denied
Page 9 GAO- 01- 1043 Radiation Exposure Compensation
a The RECP attorney may request additional supporting information before
making a recommendation (for approval or denial) to the Assistant Director.
B
No Ye s
Applicant refiles claim with RECP c
Returned to claimant unfiled (not placed in system) and explained to
claimant why it was
not refiled Process for Refiling Denied RECP Claims
Process for Appealing Denied RECP Claims Does claim
meet criteria of previous denial or more
current criteria? Process for refiling and appealing denied claims
A
Ye s
C
Case closed Ye s
No Sent to RECP
Ye s Cover letter with
denial decision sent to claimant
Ye s Independent
RECP appeals attorney reviews
claim and may do additional
research and consultation Does the
applicant appeal the denied
claim? Appeals attorney
drafts a decision recommending
one of three possible actions
Appeals officer reviews the recommended decision and makes a
determination to reverse or affirm the
denial or remand It back to the RECP d
Is the denial reversed? Is the denial
affirmed? Is the
case remanded to RECP for reconsideration? Or Or
Page 10 GAO- 01- 1043 Radiation Exposure Compensation
b As of July 10, 2000, based on the 2000 amendments, an applicant can file a
claim for consideration up to three times. c Applicants whose claims have
been denied are permitted to refile their claims if (1) they provide
information to correct the deficiency that was the basis for the last denial
under the original RECA legislation or (2) they believe that they are now
eligible as result of the 1999 regulatory changes and/ or the 2000
amendments. d The Appeals Officer may (1) reverse the denial (award
compensation to the claimant), (2) affirm the denial (deny compensation to
the claimant), or (3) remand the case to RECP. The decision is equivalent to
a negative determination for the other two options.
Source: Prepared by GAO based on RECP?s information.
In addition to RECA, other programs provide compensation to persons who have
presumably become ill as a result of working for the federal government in
producing or testing nuclear weapons. For example, the Radiation- Exposed
Veterans Compensation Act of 1988, in general, provides monthly compensation
to veterans who were present at certain atomic bomb exercises, served at
Hiroshima and Nagasaki during the post World War II occupation of Japan, or
were prisoners of war in Japan. 9 In addition, on October 30, 2000, the
President signed into law The Floyd D. Spence National Defense Authorization
Act for Fiscal Year 2001. 10 Title XXXVI of this act establishes the ?Energy
Employees Occupational Illness Compensation Program? to, in general,
compensate covered employees who contracted certain illnesses resulting from
exposure to certain ultrahazardous materials during employment in Department
of Energy facilities that processed or produced radioactive materials used
in the production of atomic weapons. Certain uranium employees who are
eligible for compensation under RECA may also be eligible for additional
compensation and medical benefits under title XXXVI. This would be RECP?s
administrative responsibility.
To determine the outcomes of the claims adjudication process, including the
number of approved and denied claims, the timeliness of the claims
adjudication process, the primary reasons for denials, and the amount of
money awarded, we obtained and analyzed RECA- related case information from
DOJ?s Civil Division?s case histories database. Our analysis was done on
claims filed during fiscal years 1992 through 2000. Our analysis was done
using the case histories database, as of February 26, 2001. We also analyzed
claims payment information from the Civil Division?s Office of Planning,
Budget and Evaluation (OPB& E). We discussed the basis for any
9 P. L. 100- 321, 102 Stat. 485 (May 20, 1988). 10 P. L. 106- 398, 114 Stat.
1654. Scope and
Methodology
Page 11 GAO- 01- 1043 Radiation Exposure Compensation
major fluctuations with RECP officials. While we did not independently
verify the accuracy of the RECA data extracted from the database, we did,
however, ask the Civil Division?s Office of Management Information, the
office that maintains the database, to complete a data reliability
questionnaire about the design specifications and documentation for the
database. The reliability questionnaire also posed questions about quality
controls and procedures used to ensure data reliability. Our analysis of the
questionnaire responses did not indicate any data reliability problems.
To determine the cost of administering the RECP and the FTE program staff
levels, we requested that OPB& E provide us with RECP administrative costs
by budget object class for the end of fiscal years 1992 through 2000. The
cost provided includes items such as personnel compensation and benefits,
travel and transportation of persons, and printing and reproduction costs.
To determine FTE staffing levels, the office provided us with FTE staff
levels for RECP at the end of fiscal years 1992 through 2000.
To determine the nature of expenditures from the Trust Fund, we evaluated
annual Trust Fund activity (appropriations, interest earned on investments
in government securities, and payments to awarded individuals) from fiscal
years 1992 through 2000 provided by OPB& E.
To verify that compensation awarded by RECP was paid as authorized, we
randomly selected 30 individual payments from DOJ?s Civil Division?s case
histories database of 1,592 RECA payments made from fiscal years1996 through
2000. We then obtained financial documentation for each payment from OPB& E,
including (1) RECP?s payment authorization letter to OPB& E, (2) the fiscal
payment request invoice approval sheet from OPB& E to the Justice Management
Division?s (JMD) Financial Operations Service, and (3) the payment
certification summary generated from a JMD financial database that shows
that the Department of the Treasury made payments electronically or by check
to the authorized individuals. We interviewed officials from RECP, OPB& E,
and JMD to determine how they authorize, process, and certify payments from
the Trust Fund. Finally, we interviewed officials from Treasury?s Financial
Management Service to clarify Treasury?s role in disbursing the awarded RECA
compensation.
To determine the nature of RECP?s outreach activities, we interviewed RECP
officials who described the elements of their outreach efforts and provided
us with a list of the office?s outreach- related onsite visits that could be
identified from existing records. To obtain insights on RECP?s outreach
efforts, we conducted telephone interviews with a judgmental sample of 11
NGOs that (1) had members who could be eligible for
Page 12 GAO- 01- 1043 Radiation Exposure Compensation
compensation under RECA or (2) provided assistance and information about the
program to potentially eligible candidates. We selected these organizations
from a list provided by RECP, an Internet search, and a list of those who
testified before the Congress in a RECA- related 1998 hearing. 11 In
addition, we asked officials from these organizations to suggest other
related groups for us to contact, some of which we contacted.
As agreed, we focused our review on Justice?s administration of RECA from
its inception in fiscal year 1992 through the end of fiscal year 2000. We
began our review in October 2000 and performed our audit work from January
to August 2001 in Washington, D. C., in accordance with generally accepted
government auditing standards.
When RECP reviews and adjudicates a claim, the process ends in one of two
possible outcomes- approval or denial of the claim. If approved, Justice
electronically submits a request for payment to Treasury. If denied,
applicants may refile their claims or pursue other avenues of appeal.
Through the end of fiscal year 2000, RECP received 7,819 applications for
compensation. During this period, RECP approved and denied roughly equal
numbers of applications, awarding compensation to about 46 percent of the
claimants, and denying compensation to about 46 percent. Moreover,
approximately 8 percent of the applications were still pending at the time
of our analysis. RECA claims are most frequently denied because the disease
contracted by the victim is not specifically designated as eligible for
compensation under the RECA program. Through the end of fiscal year 2000,
$245.1 million was paid from the Trust Fund to 5,150 victims or their
survivors, but some of the claims awarded by RECP were not paid because
money in the Trust Fund was depleted. Although lack of funds may have
prevented timely payment of compensation in some cases, RECP generally
processed claims in a timely fashion. Our analysis of information from the
case histories database showed that about 89 percent of claims were awarded
or denied within the mandated 12- month time frame. The agency reported that
the remaining claims were sometimes not processed within the 12- month
period due to mitigating circumstances, such as claimants requesting extra
time to find documentation to substantiate their claims.
11 Radiation Workers Justice Act of 1998: Hearings on H. R. 3539 before the
Subcommittee on Immigration and Claims of the Committee on the Judiciary,
House of Representatives, 105th Cong. (1998). Analysis of Processed
RECA Claims
Page 13 GAO- 01- 1043 Radiation Exposure Compensation
Our analysis of RECA- related claims information from the case histories
database shows that from the April 1992 inception of the claims adjudication
program through the end of fiscal year 2000, RECP had received 7,819
applications for compensation. As shown in table 2, there were 3,627 uranium
mine employee- based applications (about 46 percent of the total); 3,140
downwinder- based applications (about 40 percent of the total); and 1,052
onsite participant- based applications (the remaining 14 percent of the
total).
Table 2: Number of RECA Claims Received From Fiscal Years 1992 Through 2000
Type of claim Uranium mine
employees Downwinders Onsite participants Total
Approved 1,708 1,664 226 3,598 Denied 1,555 1,273 740 3,568 Pending 364 203
86 653
Total 3,627 3,140 1,052 7,819
Note: Approved, denied, and pending data at the time of our analysis.
Source: GAO?s analysis of RECA claims data from DOJ?s Civil Division?s case
histories database.
Of the 7,819 claims filed, RECP approved 3,598 and denied 3,568. These
amounts represent almost an even split between approvals and denials- about
46 percent for each. The remaining 8 percent of the claims were still
pending at the time of our analysis. RECP approved about 47 percent of the
uranium mine employee- based claims, about 53 percent of the downwinder-
based claims, and about 21 percent of the onsite participantbased claims.
Through the end of fiscal year 2000, applicants had filed claims amounting
to almost $600 million, and RECP had awarded (or obligated) about $269
million to individuals on the basis of these claims. 12 Of the amount
awarded, only $245.1 million was paid through the end of fiscal year 2000
because the Trust Fund was depleted (see further discussion in the next
section). RECP awarded $170 million to eligible individuals based on uranium
mine employee applications (or about 63 percent of the total), $83 million
based on downwinder applications (or about 31 percent of the total), and $16
million based on onsite participant applications (or about 6
12 In certain cases, awarded compensation may not actually be paid. For
example, an eligible individual may refuse to accept payment or the victim
may pass away before the money is disbursed and an eligible surviving
beneficiary cannot be located. Equal Numbers of Claims
Approved and Denied
Page 14 GAO- 01- 1043 Radiation Exposure Compensation
percent of the total). Appendix I contains data on refiled and appealed
applications.
RECP denies claims when the applicants fail to meet eligibility requirements
established by RECA and the Department of Justice?s implementation
regulations. Our analysis of RECA- related information from the case
histories database shows that through the end of fiscal year 2000, RECP
denied claims for compensation for 13 different reasons. The most frequent
reason for denial for all three types of RECA claims was that the disease
contracted by the victim was not specifically designated as eligible for
compensation under the RECA program (in about 46 percent of the cases). By
type of claim, the primary reasons for denial were as follows:
Uranium mine employee- based claims- The victim did not meet the minimum
exposure to radiation requirements (in about 53 percent of the cases) or did
not contract a disease that was eligible for compensation (in about 36
percent of the cases).
Downwinder- based claims- The victim did not contract an eligible disease
(in about 49 percent of the cases), was not physically present in the
designated areas during the required time period (in about 21 percent of the
cases), or was either under or over the required age when first exposed to
radiation (in about 17 percent of the cases).
Onsite participant- based claims- The victim did not contract a disease
that was eligible for compensation under RECA (64 percent of the denied
cases) or did not qualify as an onsite participant (in 17 percent of the
cases).
According to OPB& E, through the end of fiscal year 2000, Treasury paid
about $245. 1 million in awarded compensation to 5,150 individuals from the
Trust Fund. The number of individuals who received compensation exceeds the
number of claims awarded compensation. For example, in certain instances
where the victim was deceased, compensation was awarded to the victim?s
eligible children. On May 9, 2000, the amount of money awarded to claimants
exceeded the amount of funds available in the Trust Fund. By the end of
fiscal year 2000, 227 awards totaling $19.2 million had not been paid
because money in the Trust Fund was depleted.
As shown in table 3, the Congress initially appropriated $30 million to the
Trust Fund in fiscal year 1992. Additional appropriations were made in
fiscal years 1993, 1997, 1998, and 2000. Money remaining in the Trust Fund
Applicants Denied
Primarily Because Illnesses Are Not Compensated Under the Law
Lack of Funds Leaves Some Awarded Applicants Unpaid
Page 15 GAO- 01- 1043 Radiation Exposure Compensation
at the end of any given fiscal year is generally carried forward to the next
fiscal year. According to Justice officials, money on deposit in the Trust
Fund that is not needed in the short run for award payments may be invested
in interest- bearing U. S. Treasury securities. The paid interest is then
added to the account balance.
Table 3: Radiation Exposure Compensation Trust Fund Activity, Fiscal Years
1992 Through 2000 Dollars in thousands Fiscal year
Carry forward from prior years a
Appropriated funds
Interest earned from government
securities Payments Balance at end of fiscal year
1992 0 $30,000 0 $22,454 $7,546
1993 $7,546 $170,750 $2,493 $57,390 $123,399
1994 $123,399 0 $2,300 $60,651 $65,048
1995 $65,048 0 $1,365 $31,242 $35,171
1996 $35,171 0 $464 $21,133 $14,502
1997 $14,502 $30,000 $332 $15,882 $28,952
1998 $28,952 $4,381 0 $12,339 $20,994
1999 $20,994 0 $259 $12,822 $8,431
2000 $8,431 $3,200 0 $11,200 $431 b
a The amount carried forward is equal to the sum of appropriated funds and
interest earned, less payments from the Trust Fund. b The $431,000 is the
amount of money that was obligated, as of May 9, 2000, but not paid as of
the
end of fiscal year 2000. According to data provided independently by
Treasury and Justice, the ending balance for fiscal year 2000 was $431, 000.
Source: DOJ?s Civil Division?s OPB& E.
According to OPB& E, Justice requested that $21.7 million be appropriated to
the Trust Fund in fiscal year 2000; however, the Congress appropriated $3.2
million. Combined with funds carried over from fiscal year 1999, a total of
$11.6 million was on deposit in the Trust Fund at the beginning of fiscal
year 2000. 13 These funds were fully committed by May 9, 2000, and payment
of awards was deferred. RECP notified the eligible candidates by letter that
although they qualified for compensation, their award could not be paid
until additional funds became available. By the end of fiscal year 2000,
payments for 227 approved claims amounting to about $19.2 million were
delayed. 14 Subsequently, on December 21, 2000, the President signed
13 The $11.6 million is comprised of the approximately $8. 4 million carried
forward from fiscal year 1999 plus the $3. 2 million appropriated in fiscal
year 2000. 14 Payments of the obligated funds continued after May 9, 2000.
Page 16 GAO- 01- 1043 Radiation Exposure Compensation
into law an appropriation of $10.8 million for the Trust Fund, with the
stipulation that the money was only to be used to pay applicants who
qualified under RECA as it existed on June 1, 2000, prior to the RECA 2000
Amendments. As of June 2001, according to RECP, 70 of the 227 delayed
payments from fiscal year 2000 have been made- this amounted to about $5.2
million. On July 24, 2001, the President signed into law a supplemental
appropriations act, which provided the Trust Fund with ?. . . such funds as
may be necessary. . . .? to pay approved claims through the end of fiscal
year 2001.
The RECA legislation requires that applications be processed within 1 year.
As shown in table 4, about 89 percent of the applications were processed
within 12 months. 15 According to RECP officials, applicants may request
additional time to submit more documentation to support their claims. We
could not readily determine how many of the 692 applications that were not
processed within 1 year were due to such requests.
Table 4: Average Processing Time for Approved and Denied Applications for
Fiscal Years 1992 Through 2000 Applicant Type Processing time in months a
Uranium mine
employees Downwinders Onsite participants Total Percent of
total
12 months or less 2,437 2,613 730 5,780 89 13 months 122 35 20 177 3 14
months 87 24 13 124 2 15 months 50 10 7 67 1 16 months 36 9 1 46 1 17 months
31 3 4 38 1 18 to 24 months 113 18 15 146 2 More than 24 months 63 7 24 94 1
Total 2,939 2,719 814 6,472 100
a Appealed and pending cases have been excluded. Source: GAO?s analysis of
information from DOJ?s Civil Division?s case histories database.
Processing times for claims differed among the three applicant types. Our
analysis of information from the case histories database showed that for
fiscal years 1992 through 2000 the average processing time from the date
15 Processing time begins when a claim is received by RECP and ends at case
disposition. Further, appealed and pending cases have been excluded. Most
Claims Processed on
Time
Page 17 GAO- 01- 1043 Radiation Exposure Compensation
the application was filed until its disposition was 269 days for uranium
miner employee- based claims, 190 days for downwinders- based claims, and
245 days for onsite participant- based claims.
As shown in table 5, the average processing times for approved and denied
applications varied by application type from fiscal year 1992 through fiscal
year 2000.
Table 5: Average Number of Days to Process Approved and Denied Claims for
Fiscal Years 1992 Through 2000
Applicant type Uranium mine
employees Downwinders Onsite participants Average
Approved 251 185 324 224 Denied 291 198 217 243
Note: Approved and denied data were at the time of our review and only apply
to claims that were not appealed.
Source: GAO?s analysis of information from DOJ?s Civil Division?s case
histories database.
RECP attributed fluctuations in the time required to process claims to the
unique characteristics associated with each claim and the different factors
involved in the review and application of the law for the three claims
categories. RECP told us that since the inception of the program, its policy
has been to assist claimants in any way that it can. In addition, rather
than denying a claim, RECP said that it allows the claimant additional time
to provide corroborating documentation.
RECP cited other reasons for delays in processing claims, including RECP?s
need, in certain cases, to gather medical records to address the statutory
restrictions on certain compensable diseases and in other cases to gather
the documentation necessary to establish that the victim meets the radiation
exposure eligibility requirements. RECP said that in these instances, staff
would conduct additional research on behalf of the claimant or allow the
claimant more time to provide the proof necessary to establish exposure.
Justice processed and adjudicated 496 claims that were subsequently refiled.
On average, these 496 claims were initially processed and adjudicated within
317 days. For those claims that were refiled for the first time, RECP took
on average 258 days to process and adjudicate them. Furthermore, for those
21 claims refiled for a second time, RECP took on average 212 days to
process and adjudicate them. When denied RECA claims were administratively
appealed to Justice, Justice took on average
Page 18 GAO- 01- 1043 Radiation Exposure Compensation
115 days to process and adjudicate appealed claims when it affirmed the
denials and 262 days when it reversed the denials.
As shown in table 6, RECP?s FTE staff levels and administrative costs have
fluctuated from the first full year of the program in fiscal year 1993
through the end of fiscal year 2000. 16 In fiscal year 2000, RECP employed a
staff of 11.1 FTEs. Administrative costs were $2.1 million in fiscal year
1993, $1.1 million in fiscal year 1999, and $1.3 million for fiscal year
2000. Costs as measured by the average number of applications processed per
FTE staff member and the average administrative cost for processing each
application has shown substantial variation for fiscal years 1993 through
2000. 17 The average number of applications processed per FTE ranged from 61
in fiscal year 1998 to 210 in fiscal year 1993. The average cost for
processing applications per FTE ranged from $725 in fiscal year 1993 to
$1,667 in fiscal year 1998.
16 Administrative costs include items such as personnel compensation and
benefits, travel, rent, communications, utilities, printing and
reproduction, supplies and materials, and equipment.
17 We excluded fiscal year 1992 because RECP was in effect for less than 1
year. DOJ?s Administrative Costs
Fluctuated
Page 19 GAO- 01- 1043 Radiation Exposure Compensation
Table 6: Average FTE Staff Levels and Administrative Costs for Processing
RECA Claims for Fiscal Years 1992 Through 2000 Fiscal year 1992 a 1993 1994
1995 1996 1997 1998 1999 2000
FTE staff 7. 6 13.8 15.4 11.8 11.2 11.8 10.9 10.4 11.1 Administrative costs
(dollars in millions) $1.0 $2.1 $2.0 $1.5 $1.5 $1.2 $1.1 $1.1 $1.3
Applications processed during fiscal year b 1,898 2,897 2,091 1,417 1,092
803 660 705 1,179 Average applications processed per FTE staff member 250
210 136 120 98 68 61 68 106 Average cost for processing RECA applications
$527 $725 $956 $1,059 $1,374 $1,494 $1,667 $1,560 $1,103
a Because RECP was implemented in April 1992, the FTE staff levels and
administrative costs for fiscal year 1992 only reflect the April 1992 to
September 30, 1993, time frame. b Includes approved, denied, and pending
applications. Because applications may not be completely processed in the
year that they were received, they are counted for each year that they
continue to be processed. This explains why the total number of applications
shown in the table as being processed from fiscal years 1992 through 2000
(12,742), exceeds the total number of applications filed during the same
period (7, 819).
Source: GAO?s analysis of information from DOJ?s Civil Division?s case
histories database and information provided by OPB& E.
RECP officials said that the average cost for processing RECA applications
fluctuated because many of the claims RECP received when the program began
in 1992 were more complete than those received later. RECP officials told us
that these later claims were typically far more complex than those initially
processed, and RECP staff spent more time in assisting claimants with
establishing eligibility.
RECP officials told us that as a result of the RECA 2000 amendments, claims
are being received at a record pace, far exceeding even the initial phase of
operations in 1992. The officials said that RECP has also received an
unprecedented number of telephone and written inquiries and requests for
claim forms, program information, and information regarding the status of
claims. According to RECP officials, staff responding to a significant
number of inquiries regarding the status of funding to pay approved RECA
claims has stretched RECP?s operational resources further. The officials
told us that, to date, RECP has not received an increase in administrative
funds to accommodate its increased workload.
Justice has procedures in place to certify that funds are appropriately
disbursed from the Trust Fund. Our review of the payment documentation for
30 randomly selected RECA cases, where compensation was awarded, indicated
that all payments were made as authorized. Certification of the
Trust Fund Payments Appears Adequate
Page 20 GAO- 01- 1043 Radiation Exposure Compensation
According to the law, moneys on deposit in the Trust Fund are to be used
solely to pay compensation to eligible RECA claimants. Treasury is to
disburse payments from the Trust Fund on the basis of authorization and
certification from Justice.
Justice has established procedures for authorizing and certifying the
payment of awarded claims from the Trust Fund. When a claim is approved,
according to Justice officials, RECP authorizes payment to the eligible
applicants. OPB& E obligates the funds, and JMD certifies the approved claim
for payment on the basis of the supporting documents. JMD then
electronically submits a request for payment to Treasury?s Disbursement
Center. Treasury confirms to JMD on a daily basis that it has received the
request and made payment as directed. A JMD official told us that payment is
generally made within 24 hours of JMD?s electronic submission. At the end of
each month, Treasury sends a list of disbursements made for that month back
to JMD, which then reconciles the list with its own records.
On the basis of our review of a random sample of 30 of the approximately
1,592 RECA payments made from fiscal years 1996 through 2000 where
compensation was awarded by RECP (from the Trust Fund) to eligible
individuals, we found that the payments were made as authorized to these
individuals. We obtained and examined the financial authorization and
certification documents for each of these 30 RECA payments from OPB& E.
Using these documents, we traced RECA payments from authorization by RECP,
through obligation by OPB& E, certification by JMD, and disbursement by
Treasury. The monthly list of disbursements submitted by Treasury to JMD
contains the schedule payment numbers for both electronic direct deposit and
Treasury payments and also the Treasury check number. Financial summary
information from this database allowed us to verify that all payments from
our sample were made as authorized. As a result, at the 95- percent level of
statistical confidence, we estimate that no more than 9 percent of the
approximately 1,592 individual payments from which the sample was drawn
could have resulted in unauthorized payments.
To identify and inform people of their potential eligibility for
compensation under the program and to help them apply for compensation, RECP
engages in three primary outreach activities. We spoke with 11 organizations
that assist potential RECA claimants. These groups had mixed comments about
the extent of RECP?s outreach efforts. Justice Has Procedures in
Place to Certify that Payments Are Made Appropriately
Trust Fund Appears to be Used Appropriately
Views on RECP?s Outreach Activities Are Mixed
Page 21 GAO- 01- 1043 Radiation Exposure Compensation
RECP has established an Internet website, conducts onsite visits, and
operates a toll- free telephone number for program queries.
Internet website- According to RECP officials, the Internet website was
launched in November 1999 and is linked to Justice?s main website. Claimants
can download background information about RECA and related programs,
statistical information dealing with awards and payments, and application
forms. Claimants can also e- mail questions and requests for information
through the website. In calendar year 2000, there were 3,727
?hits? to the RECP website.
Onsite visits- Based on a review of travel records, RECP officials have
identified at least 36 outreach- related onsite visits that they have made
from fiscal years 1992 through 2000. The officials told us that in many
cases they did not maintain historical records of the specific organizations
or groups they visited or the nature of their outreach activities during
these visits. However, the summary information that RECP was able to provide
shows that these onsite visits were primarily made to the five western
states covered under the act- Arizona, Colorado, Nevada, New Mexico, and
Utah. To inform potential applicants of planned onsite visits, officials
told us that they place advertisements on local radio stations and in local
newspapers. During these visits, the officials provide candidates with
program regulations, instruction booklets, and applications. The officials
told us that they explain the program, the application process, and assist
the candidates with completing the forms. RECP does not produce any
leaflets, flyers, or brochures that explain the RECA program for public
distribution.
Toll- free telephone Number- RECP maintains a toll- free number for queries
about the program and assigns a staff member and two alternates to answer
the telephone. 18 RECP officials told us that contract personnel assist with
answering the telephone and routing the calls to the appropriate staff
members. According to RECP officials, the toll- free number is included on
RECP correspondence, applications, instruction booklets, and the website,
and it is also provided to potential applicants by health- related
organizations that may come into contact with them. Over the life of the
program, most of the queries have dealt with requests for claims forms and
the status of claims in process.
18 The toll- free telephone number is 1- 800- 729- RECP (7327). RECP Engages
in Outreach
Activities
Page 22 GAO- 01- 1043 Radiation Exposure Compensation
RECP officials told us that they initiated their outreach activities in
1991, when they announced through press releases that RECP would be
conducting town hall meetings at various sites in Colorado, Nevada, Utah,
and Wyoming. RECP said that these first outreach meetings were an attempt to
reach wide audiences and inform them about RECA. Also, RECP told us that
they compiled mailing lists from meeting attendance sheets, which were later
used as the basis for mailing claims applications packages to the meeting
participants.
According to RECP officials, because a large percentage of the uranium mine
employee population were members of the Navajo Nation and because of the
language and cultural barriers, RECP began to focus its outreach efforts on
the Navajo Nation. RECP told us that from mid- 1992 through mid- 1994, RECP
staff went out to various chapter houses of the Navajo Nation in Arizona and
New Mexico to conduct outreach meetings. The attendance at these meetings
varied from as few as 20 people up to 100 people. The RECP officials
informed us that in May 1994, RECP staff set up an office at the facilities
of the Office of Navajo Uranium Mine Workers in Shiprock, New Mexico. They
said that this outreach office was used by RECP until 1997. During this
time, according to the officials, RECP outreach efforts were concentrated in
Shiprock and at the various Navajo Nation fairs in Arizona and New Mexico.
According to RECP officials, they have also contacted organizations such as
the Health and Human Services? National Institute of Occupational Safety and
Health; St. Mary?s Hospital in Grand Junction, Colorado; the University of
New Mexico Health Clinic in Albuquerque, New Mexico; and the Miners? Colfax
Medical Center in Raton, New Mexico, to help publicize the program. Program
officials also reported that since RECP?s inception, they have publicized
the program through press releases.
We conducted structured telephone interviews with representatives from 11
NGOs that are involved with RECA- related activities in order to gather
their views on RECP?s outreach efforts. The NGOs that we contacted included
medical research institutes, Native American assistance groups, an atomic
veteran?s association, a uranium workers council, a RECA reform coalition,
an association of radiation survivors, and downwinders? associations. Our
interviews focused on the NGOs' experiences with respect to RECP?s outreach
efforts to inform potential applicants about the program and how helpful
RECP was in assisting claimants with the application process.
Nongovernmental
Organizations Express Mixed Views on Effectiveness of Outreach Activities
Page 23 GAO- 01- 1043 Radiation Exposure Compensation
The NGOs were generally mixed in their comments about RECP?s efforts to
inform them about the compensation program.
Five of the 11 NGOs told us that RECP had made an effort to inform them
about potential eligibility for compensation under the program, but 8 of the
11 said that RECP had made no attempt to coordinate its outreach efforts
with their organizations.
Six of the groups said that RECP had succeeded in informing potential
claimants about the program from some extent to a great extent.
Five groups said that RECP was somewhat to very responsive to their
written requests for information.
Eight groups said that RECP was somewhat to very responsive to their
telephone calls.
Four groups told us that RECP was somewhat to very responsive to their e-
mail queries. 19
Eight organizations were familiar RECP?s website and had used the website
to gather general program information and six used the website to obtain
claims applications.
The NGOs? views of RECP?s efforts to assist potential claimants with the
application process also varied. Six of the organizations believed that RECP
was of little to no help in explaining the requirements for documentation to
substantiate applicant claims, but five believed that RECP was generally to
very helpful. However, six organizations claimed that RECP was somewhat to
very helpful in explaining the eligibility criteria for RECA compensation,
while four believed that RECP was not very helpful. Regarding our telephone
interviews with the NGOs, RECP officials told us that they are looking into
the concerns the NGOs raised and are actively exploring new techniques for
meeting the needs of claimants and others interested in the program.
We provided a draft of this report to the Attorney General for review and
comment. On August 28, 2001, we met with a Department of Justice RECP
official (an Assistant Director of the Civil Division?s Torts Branch), who
provided us with consolidated comments from RECP. The Assistant Director
said that RECP generally agreed with our draft report. In addition, the
Assistant Director provided technical comments, which have been incorporated
in this report where appropriate.
19 These responses only include those NGOs that have Internet access. Agency
Comments
and Our Evaluation
Page 24 GAO- 01- 1043 Radiation Exposure Compensation
Copies of this report are being sent to the Attorney General; the Director,
Office of Management and Budget; and any other interested parties. We will
also make copies available to others upon request.
If you or your staffs have any questions about this report, please contact
James M. Blume or me at (202) 512- 8777 or at jonesp@ gao. gov. Key
contributors to this report are acknowledged in appendix II.
Paul L. Jones Director, Justice Issues
Page 25 GAO- 01- 1043 Radiation Exposure Compensation List of Congressional
Committees
The Honorable Patrick J. Leahy Chairman The Honorable Orrin G. Hatch Ranking
Minority Member Committee on the Judiciary United States Senate
The Honorable Edward M. Kennedy Chairman The Honorable Judd Gregg Ranking
Minority Member Committee on Health, Education, Labor and Pensions United
States Senate
The Honorable F. James Sensenbrenner, Jr. Chairman The Honorable John
Conyers, Jr. Ranking Minority Member Committee on the Judiciary House of
Representatives
The Honorable W. G. ?Billy? Tauzin Chairman The Honorable John D. Dingell
Ranking Minority Member Committee on Energy and Commerce House of
Representatives
Appendix I: Data on Refiled and Appealed Claims
Page 26 GAO- 01- 1043 Radiation Exposure Compensation
Applicants whose claims are denied may refile their applications with
Justice?s Radiation Compensation Program (RECP), appeal the denial to a
separate official within Justice?s Civil Division, or appeal the denial in
U. S. district courts. Claimants who choose to refile must provide
documentation to correct the deficiency previously noted by RECP. Also,
according to RECP, claims may be refiled by providing documentation to
establish eligibility (1) as a result of regulatory or legislative changes
to eligibility requirements subsequent to the denied application (e. g.,
changes mandated by the Radiation Exposure Compensation Amendments of 2000
and/ or those required by the July 1, 1999, Attorney General regulations),
or (2) under a different claim category (e. g., filing a downwinder- based
claim after being denied compensation on an onsite participant- based
claim).
Our analysis of the RECA case- related information from the case histories
database showed that from April 1992 through the end of fiscal year 2000, a
total of 496 applicants refiled claims- 395 were uranium mine employeebased
claims, 70 were downwinder- based claims, and 31 were onsite participant-
based claims. Of these refiled claims, 250 were awarded compensation, 116
were denied compensation, and the remaining 130 were still pending
resolution, at the time of our analysis. Of the 116 denied claims, 28
applicants refiled for a second time- all of these were uranium mine
employee- based claims. Of the 28 denied claims, 21 were awarded
compensation and the remaining 7 were still pending at the time of our
review.
Applicants may also administratively appeal denied claims to a separate
official (an Appeals Officer) within the Department of Justice?s Civil
Division. The applicants must do so within 60 days of the denial. Of the
3,568 claims denied by RECP, 710 (or about 20 percent) of the applicants
administratively appealed the decision to Justice, as shown in table 7. In
553 of these cases (or 78 percent of the cases), the Appeals Officer
affirmed the denials. Appendix I: Data on Refiled and Appealed
Claims
Appendix I: Data on Refiled and Appealed Claims
Page 27 GAO- 01- 1043 Radiation Exposure Compensation
Table 7: Results of Appealed RECP Decisions for Fiscal Years 1992 Through
2000 Type of claim Appeal Uranium mine employees Downwinders Onsite
participants Total
Number Percentage Number Percentage Number Percentage Number Percentage
Denials reversed 104 31 22 10 15 10 141 20 Denials affirmed 220 66 196 89
137 87 553 78 Pending 9 3 2 1 5 3 16 2 Total 333 100 220 100 157 100 710 100
Note: Approved, denied, and pending appeal data were at the time of our
review. Source: GAO?s analysis of RECA claims data from DOJ?s Civil
Division?s case histories database.
Uranium miner claimants represented about 47 percent of the administratively
appealed cases, downwinders about 31 percent, and onsite participants the
remaining 22 percent. The denials were affirmed upon appeal for the vast
majority of these cases.
According to RECP, once claimants exhaust their administrative remedies
within Justice, they may appeal their cases in U. S. district courts. RECP
records showed that from program inception in 1992 through July 3, 2001,
eight claims denied by RECP have been appealed to the district courts. Two
of these appeals were consolidated into one court case. The courts affirmed
RECP?s denials in three of the seven cases and remanded three of the cases
back to RECP for readjudication. RECP again denied one of these three
remanded cases, approved the claim in the second case, and the third case
was still pending RECP review, as of July 3, 2001. In the seventh case, RECP
reassessed and approved the claim.
Appendix II: GAO Contacts and Staff Acknowledgments
Page 28 GAO- 01- 1043 Radiation Exposure Compensation
Paul L. Jones, (202) 512- 8777 James M. Blume, (202) 512- 8643
Michael G. Kassack, Bethany L. Letiecq, David P. Alexander, E. Anne Laffoon,
Geoffrey R. Hamilton, Robert C. DeRoy, and Bassel Alloush made key
contributions to this report. Appendix II: GAO Contacts and Staff
Acknowledgments GAO Contacts Acknowledgments
(182102)
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