Statistical Agencies: A Comparison of the U.S. and Canadian Statistical
Systems (Letter Report, 08/01/96, GAO/GGD-96-142).

Pursuant to a congressional request, GAO compared the decentralized
federal statistical system to Canada's centralized statistical system,
focusing on differences in the: (1) systems' organizational and budget
structures; (2) systems' legal frameworks that govern privacy concerns,
data confidentiality, and data sharing; and (3) position and authority
of the chief statisticians of the United States and Canada.

GAO found that: (1) the U.S. statistical system consists of about 70
agencies, with 11 agencies having statistical activities as their
primary missions; (2) the Office of Management and Budget oversees and
coordinates the U.S. statistical system, but each agency has its own
separate budget; (3) one Canadian agency is responsible for virtually
all government statistics activities and provides statistical services
to all federal departments and provincial governments under a single
budget; (4) in each system, regulatory agencies and state, provincial,
and local governments also provide data to statistical agencies on
particular topics; (5) the legal framework of the U.S. statistical
system consists of several laws, policies, and regulations, some of
which are agency-specific, that govern the collection, use, and
confidentiality of statistical data and which also limit data sharing
among agencies; (6) in Canada, the central statistical agency is
authorized to access all government as well as private records for
statistical purposes and provides for broader data sharing and
confidentiality and privacy protection; (7) both countries have
designated a Chief Statistician to coordinate their systems; (8) the
U.S. Chief Statistician does not produce or redirect resources among
statistical agencies; and (9) the Canadian Chief Statistician has the
rank of deputy minister, coordinates both the federal and provincial
statistical systems, produces statistical information, controls the
system's budget, and can redirect resources within the system.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  GGD-96-142
     TITLE:  Statistical Agencies: A Comparison of the U.S. and Canadian 
             Statistical Systems
      DATE:  08/01/96
   SUBJECT:  Statistical data
             Interagency relations
             Data collection operations
             Privacy law
             Mission budgeting
             Confidential records
             Information dissemination operations
             Disclosure law
             Foreign governments
             Economic indicators
IDENTIFIER:  Council of Economic Advisors Economic Statistics Initiative
             National Performance Review
             National Income Account
             National Product Account
             BLS Consumer Expenditure Survey
             Census Bureau Current Population Survey
             Consumer Price Index
             National Population Health Survey (Canada)
             National Longitudinal Survey of Children (Canada)
             Bureau of the Census Standard Statistical Establishment List
             
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Cover
================================================================ COVER


Report to Congressional Requesters

August 1996

STATISTICAL AGENCIES - A
COMPARISON OF THE U.S.  AND
CANADIAN STATISTICAL SYSTEMS

GAO/GGD-96-142

Statistical Agencies

(243062)


Abbreviations
=============================================================== ABBREV

  ACS - Assistant Chief Statistician
  BEA - Bureau of Economic Analysis
  BLS - Bureau of Labor Statistics
  OIRA - Office of Information and Regulatory Affairs
  OMB - Office of Management and Budget

Letter
=============================================================== LETTER


B-261870

August 1, 1996

The Honorable John Kasich
Chairman, Committee on the Budget
House of Representatives

The Honorable Stephen Horn
Chairman, Subcommittee on Government Management,
 Information and Technology
Committee on Government Reform and Oversight
House of Representatives

Congressional consideration of proposals to consolidate some or all
of the agencies comprising the federal statistical system has drawn
attention to the centralized Canadian statistical system.  This
report responds to your request for information on the Canadian
statistical system and Statistics Canada, that nation's statistical
agency, for comparison with the U.S.  statistical system.  Our
objective was to identify differences between the U.S.  and Canadian
statistical systems in

  -- their organizational and budget structures;

  -- their legal frameworks that govern privacy concerns, data
     confidentiality, and the ability to share data; and

  -- the position and authority of the Chief Statisticians of the
     United States and Canada. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

The federal statistical systems in the United States and Canada are
based on different organizational approaches.  The U.S.  statistical
system is highly decentralized, with statistical activities in
approximately 70 agencies--11 of which have the collection, analysis,
and production of statistics as their primary missions.  While
oversight and coordination of the U.S.  statistical system is the
responsibility of the Office of Management and Budget (OMB), each
agency in the system has its own separate budget. 

In contrast to the U.S.  statistical system, the Canadian statistical
system is highly centralized.  Statistics Canada produces and
disseminates virtually all broadly used official government
statistics and is responsible for providing statistical services to
support all the departments of the Canadian federal government.  In
some cases, these statistics are based on data collected by other
Canadian departments and agencies.  Statistics Canada also provides
statistical support to provincial governments, either directly or via
a designated provincial organization.  Statistics Canada has a single
budget. 

The legal frameworks for the U.S.  and Canadian statistical systems
are also different.  In the United States, statistical agencies
generally operate under a number of laws, policies, or regulations
governing the collection, use, and confidentiality of the statistical
information for which they are responsible.  Some of these laws,
policies, and regulations apply only to a specific agency.  The legal
framework for the U.S.  statistical system also limits the extent of
data sharing among agencies because statutes exist to protect the
confidentiality of data providers and, in many instances, allow only
the agency collecting the data to have access to them.  Access by
statistical agencies to data that the government has collected for
regulatory or program administrative purposes is also limited.  For
example, statistical agencies' access to tax return data for
statistical purposes is strictly limited by law. 

In Canada, a single law, the Statistics Act of 1971, provides a
mandate for Statistics Canada to be the central statistical agency. 
This law also provides Statistics Canada with the authority to access
all government as well as private records for statistical purposes,
enables it to share data among its different components under
strictly controlled conditions, and requires the confidentiality and
privacy of individual data providers to be protected. 

In both the United States and Canada, a Chief Statistician has been
designated to coordinate the statistical system.  Each Chief
Statistician occupies a position that is at the top of each nation's
career civil service and operates under safeguards to protect
independence from political interference.  Although they share
similar responsibilities for coordinating the statistical systems of
their nations, there are differences between the two positions.  In
the United States, the Chief Statistician occupies a career Senior
Executive Service position, is organizationally located in OMB, and
reports to the Administrator of the Office of Information and
Regulatory Affairs (OIRA).  The U.S.  Chief Statistician heads OIRA's
Statistical Policy Branch, which, among other things, is charged with
coordinating the federal statistical system but is not responsible
for producing statistical information.  The U.S.  Chief Statistician
also participates in OMB reviews of statistical agency budgets but
cannot redirect staff and other resources from one statistical agency
to another.  In Canada, the Chief Statistician is selected by the
Prime Minister, has the rank of deputy minister,\1 heads Statistics
Canada, and reports to the Minister of Industry.  The Canadian Chief
Statistician is charged with coordinating the Canadian statistical
system at both the federal and provincial levels as well as producing
statistical information.  The Canadian Chief Statistician also is
responsible for the budget of Statistics Canada and has authority to
redirect resources within Statistics Canada. 


--------------------
\1 A deputy minister is roughly equivalent in rank to the
undersecretary of a cabinet department in the United States. 


   BACKGROUND
------------------------------------------------------------ Letter :2

In the United States, the approximately 70 agencies that have funding
of at least $500,000 in a fiscal year for statistical activities are
considered by OMB to be part of the federal statistical system.  In
fiscal year 1995, 72 agencies met this criterion.  For many years,
proposals have been made to consolidate various combinations of these
agencies into a single statistical agency or strengthen the
coordination of the decentralized system.  For example, Janet
Norwood, the former Commissioner of Labor Statistics, proposed
centralizing three statistical agencies and the coordinating function
from OMB into a single "superagency."\2 As a means of improving the
coordination of the decentralized system, proposals also have been
made, as recently as June 1996, to allow greater data sharing among
federal statistical agencies to enable agencies to use the same data
and avoid duplicative data collection efforts.\3 In advocating the
consolidation of the U.S.  statistical system, some commentators have
pointed to the example of the centralized Canadian statistical
system. 

Several differences between the United States and Canada affect the
work performed by the nations' statistical systems.  The United
States has a much larger population than Canada has.  The United
States' population is 264 million, and Canada's population is 29
million.  Measured by respective gross domestic products, the U.S. 
economy, at over $7 trillion, is also much larger than the Canadian
economy, at $611 billion (both amounts measured in U.S.  dollars). 

The U.S.  economy is also substantially more complicated than the
Canadian economy.  An example of this is seen in the financial
sectors of the two economies.  Nearly 10,000 domestic banks operate
in the United States.  The Canadian banking and financial services
systems are much more centralized, with six domestic banks. 
Financial markets in the United States are also more complex.  New
York and Chicago are major international financial centers.  U.S. 
financial markets often pioneer the use of sophisticated financial
instruments, such as derivatives, that make the value of trading
particularly difficult to measure. 

Canada's parliamentary government can provide a more unified source
of direction to its departments and agencies, including Statistics
Canada, than can the system of government in the United States.  In
the Canadian system of government, agencies are directed by members
of the Cabinet, who are also members of the majority party in
Parliament.  As Canada's Chief Statistician noted, "significant
issues are decided collectively by the cabinet [on] the basis of
discussion papers setting out options." Statistics Canada must, under
the Canadian Constitution, also respond to provincial governments'
statistical needs; by policy, it seeks to meet the public information
needs of the private sector.  In the United States, the direction of
statistical agencies is affected by the constitutional separation of
the executive and legislative branches of the U.S.  government and
the dispersal of congressional authority among authorizing,
appropriation, and oversight committees, which can provide multiple
sources of program and budget decisions that affect the U.S. 
statistical system.  Canada's Chief Statistician noted that
Statistics Canada also receives guidance from multiple sources,
including provincial governments and the private sector. 

The two countries also differ in the relative amount of trust each
country places in having one centralized entity control statistical
information.  As Janet Norwood pointed out in her book, statistical
agencies in the United States were created over time as the need for
different information arose, but little attention was given to
coordinating or integrating the resulting system.  Dr.  Norwood
further commented that "the history of official statistics in the
United States has clearly been affected by the country's opposition
to centralized power in the hands of the federal government."\4

For example, the Bureau of the Census has studied the declining
response rate to its surveys and found that one reason individuals
fail to return census surveys is the popular misperception that
Census will share the information it collects on individuals with
U.S.  regulatory agencies.  One consequence of this "opposition to
centralized power" has been multiple confidentiality provisions that
limit data sharing.  Canada, however, has a single Statistics Act
that provides "blanket access" for a single agency, Statistics
Canada, to all government records. 


--------------------
\2 Janet Norwood, Organizing to Count (Washington, D.C.:  The Urban
Institute Press, 1995). 

\3 The Economic Statistics Initiative in 1991 and the National
Performance Review in 1993 recommended legislation to enable limited
sharing of confidential information for statistical purposes.  See
Economic Statistics:  Status Report on the Initiative to Improve
Economic Statistics (GAO/GGD-95-98, July 7, 1995).  OMB and the
Department of the Treasury recently sent to Congress a pair of
legislative proposals that would enable limited sharing of
confidential information for statistical purposes among nine
statistical agencies. 

\4 Organizing to Count, p.  54. 


   SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :3

To accomplish our objective, we reviewed the literature on (1) the
U.S.  statistical system, including studies that discussed
consolidating it, and (2) the Canadian statistical system, including
documents prepared by Statistics Canada, such as its Policy Manual. 
We interviewed the U.S.  Chief Statistician and other officials at
OMB, executives at the 11 principal agencies in the U.S.  statistical
system,\5 and cognizant experts in academia and the private sector. 
We also interviewed the Chief Statistician of Canada, key executives
of Statistics Canada, and Canadian federal government officials who
are users of Statistics Canada's services.  It is important to note
that this report is not an evaluation of the effectiveness of
Statistics Canada, the Canadian statistical system, or the U.S. 
federal statistical system.  Therefore, we did not seek to interview
a representative sample of data providers or users.  We conducted our
interviews with Canadian officials and data users to understand the
Canadian statistical system rather than to evaluate Statistics
Canada.  Staff from Canada's Office of the Auditor General
participated in many of the interviews with Canadian officials. 

We did not verify information from Statistics Canada on the extent to
which it produces official statistics or the extent to which other
Canadian federal agencies do.  Our description of Canadian laws was
based on the interpretations of Canadian government officials and our
review of selected portions of these laws. 

Throughout this report, we refer to statistical data as data that
agencies collect to develop an aggregate description of a group of
persons or businesses.  We refer to administrative records as those
records produced in the normal course of an agency's business that
relate to a course of action that affects a particular person or
business, such as an income tax filing, a criminal investigative
report, or a license application. 

We did our work between July 1995 and March 1996 in Washington, D.C.,
and in Canada, in Ottawa, Ontario; Hull, Quebec; and Montreal,
Quebec, in accordance with generally accepted government auditing
standards

We sent a draft of this report to the Canadian Chief Statistician and
to the Director of OMB for comment.  Their comments are discussed at
the end of this report. 


--------------------
\5 These agencies are the National Agricultural Statistics Service
and the Economic Research Service, Department of Agriculture; the
Bureau of the Census and the Bureau of Economic Analysis, Department
of Commerce; the National Center for Education Statistics, Department
of Education; the Energy Information Administration, Department of
Energy; the National Center for Health Statistics, Department of
Health and Human Services; the Bureau of Justice Statistics,
Department of Justice; the Bureau of Labor Statistics, Department of
Labor; the Bureau of Transportation Statistics, Department of
Transportation; and the Statistics of Income Division of the Internal
Revenue Service, Department of the Treasury. 


   DIFFERENCES IN THE U.S.  AND
   CANADIAN STATISTICAL SYSTEMS
------------------------------------------------------------ Letter :4

The federal statistical systems in the United States and Canada are
based on different organizational and budget structures.  The U.S. 
statistical system is highly decentralized, while the Canadian system
is centralized.  Due to the decentralized nature of the U.S. 
statistical system, each U.S.  statistical agency receives current
year appropriations, either as a specific line item in the budget or
through allocations from its parent organization's budget.  Canada,
however, has a single budget for Statistics Canada. 


      DIFFERENCES IN
      ORGANIZATIONAL STRUCTURES
      AFFECT HOW EACH COUNTRY
      CARRIES OUT STATISTICAL
      ACTIVITIES
---------------------------------------------------------- Letter :4.1

In the United States, responsibility for producing federal social and
economic statistics is divided among approximately 70 agencies. 
Eleven agencies, located in 9 departments, have statistical
activities (collecting, analyzing, producing, and disseminating
statistical data) as their primary missions.\6 According to OMB,
about 60 other agencies also spend at least $500,000 annually on
statistical activities.  In general, these activities are undertaken
to provide information for program oversight, regulation, or
administrative purposes in direct support of the primary functions of
the departments or agencies in which they are located. 

U.S.  federal statistical agencies often cooperate with each other in
collecting and using data.  For example, estimates of the National
Income and Product Accounts,\7 which are produced by the Bureau of
Economic Analysis (BEA), are based on data generated by other
agencies.  Also, because Census has a comparative advantage in
conducting household surveys, the Bureau of Labor Statistics (BLS)
relies on Census to conduct the Consumer Expenditure Survey--a key
component in BLS' program to update the market basket that it uses in
determining the Consumer Price Index--as well as the Current
Population Survey--the source of monthly data on employment and
unemployment.  BLS reimburses Census for conducting these surveys. 
Similar cooperative endeavors are carried out by various agencies in
the federal statistical system.  Statistical agencies also rely on
some administrative records to produce statistics.  Census, for
example, compiles international trade statistics on the basis of
trade documents collected by the U.S.  Customs Service.  The result
of agencies using data collected or generated by other agencies is a
federal statistical system that is highly interrelated yet
decentralized, so there is a need to coordinate the system's
activities. 

Some data used by the agencies in the U.S.  statistical system also
come from state and local government records.  For example, quarterly
estimates of employment and wages produced by BLS are gathered from
unemployment insurance reports compiled by state employment security
agencies.  Most of the principal federal statistical agencies have
their own cooperative agreements with state and local governments for
obtaining and disseminating statistical data on particular topics,
such as agriculture, health, and education.  There is no single
process or protocol for data sharing between federal and state
governments. 

Congressional recognition of the need for strong oversight and
coordination of the decentralized federal statistical system extends
back at least as far as the Budget and Accounting Procedures Act of
1950.  The Paperwork Reduction Act of 1980, as amended in 1986 and
amended and recodified in 1995,\8 assigns to the Director of OMB and
the Administrator of OIRA the responsibility for overseeing the
federal statistical system and coordinating its activities.  The
Paperwork Reduction Act also created in law the position of Chief
Statistician and directed that the person appointed to that position
be "a trained and experienced professional statistician."

Thus, the U.S.  statistical system has a highly decentralized
structure, with OMB's role being to coordinate the system's
activities rather than to directly manage them.  Many statistical
activities conducted by the agencies in the system are outgrowths of
the activities related to the missions of their parent departments,
and the system's decentralization reflects those activities.  Various
commissions have reviewed the federal statistical system and
subsequently urged greater coordination but generally have not
recommended statistical agency consolidation. 

U.S.  statistical agency officials cited advantages to having
separate statistical agencies that are governed by their own
statutes.  For example, OIRA's Administrator has testified that
"[O]ne of the particular advantages of our current organizational
structure is that it places statistical agencies within the cabinet
departments with related responsibilities.  This means, for example,
that those who are collecting agricultural, energy, or health
statistics know what the issues are in their particular area and
where statistics are needed."\9

OMB officials told us that although the U.S.  statistical system is
decentralized, it has been able to achieve at least some of the
efficiencies associated with a centralized system such as Canada's. 
For example, they noted that the U.S.  has "centralized" much of the
collection of data from households through the use of reimbursable
agreements between Census and other federal agencies.  Through the
use of these agreements, Census collects data for agencies that they
would otherwise have to collect themselves; the agencies reimburse
Census for this work.  As another example, OMB officials said that
the recently established White House "home page" on the Internet can
provide users immediate access to some statistical data produced by
several agencies and easy access to other data, thus establishing a
vehicle for "one stop shopping" for its users. 

In contrast to the U.S.  statistical system, the Canadian statistical
system is centralized.  A single agency, Statistics Canada, describes
itself as "the core of Canada's socio-economic information system."
Statistics Canada's legislative mandate is "to collect, compile,
analyze and publish statistical information on the economic, social,
and general conditions of the country and its citizens."\10 According
to Statistics Canada, it

     "presents a comprehensive picture of the national economy
     through statistics on manufacturing, agriculture, exports and
     imports, retail sales, services, prices, productivity changes,
     trade, transportation, employment and unemployment, and
     aggregate measures, such as gross domestic product.  It also
     presents a comprehensive picture of social conditions through
     statistics on demography, health, education, justice, culture,
     and household incomes and expenditures.  This economic and
     social information is produced at the national and provincial
     levels and, in some cases, for major population centres and
     other sub-provincial or 'small' areas."\11

By having broad access to government records, Statistics Canada can
use, for statistical purposes, data that are collected by other
government agencies in fulfilling their missions.  Statistics Canada
produces statistical information based on such data, if the
information is of broad interest.  Statistics Canada also conducts
surveys for other government agencies and funds these surveys by
recovering its costs from the agencies that requested them.  The
Chief Statistician noted that when agencies request Statistics Canada
to conduct such surveys, the agencies must be prepared for public
dissemination of the results. 

According to the Canadian Chief Statistician, Statistics Canada is
well prepared to address the statistical needs of other government
agencies, including those that do not fit neatly within the
jurisdiction of a single department or agency.  In addition, with
respect to meeting the requirements of policy departments, the Chief
Statistician emphasized "the effectiveness of two primary approaches: 
intensive bilateral working relationships between Statistics Canada
and major policy departments; and a strong capacity to carry out cost
recovered surveys to meet the priority statistical needs of
departments if they cannot be accommodated with the budget of
Statistics Canada."

The Chief Statistician also noted what he considered the main
advantages of Canada's centralized statistical system: 

     "a high level of efficiency, achieved by avoiding the
     duplication of expensive infrastructure; flexibility to
     reallocate resources according to system-wide requirements; a
     high level of conceptual coordination and harmonization that
     ensures that the different parts and aspects of the economy are
     measured without gaps and overlaps; respondent benefits, by
     ensuring the lowest possible level of reporting burden through
     an intensive internal sharing and exploitation of all data that
     are collected; and, last but not least, a high level of client
     convenience through 'one stop shopping.'"


--------------------
\6 The missions of the 11 principal statistical agencies are
described in Federal Statistics:  Principal Statistical Agencies'
Missions and Funding (GAO/GGD-96-107, July 1, 1996). 

\7 The National Income and Product Accounts provide estimates of the
level of output produced by the economy, such as the estimate of
gross domestic product, or of income in the economy, such as personal
income estimates. 

\8 P.L.  104-13, 44 U.S.C.  3501-3520. 

\9 Hearings on H.R.  2521 Before the Subcommittee on Government
Management, Information and Technology of the House Committee on
Government Reform and Oversight 104th Cong., 2nd Sess.  (1996)
(Statement of Sally Katzen, Administrator, OIRA). 

\10 Statistics Canada:  1996-97 Estimates-Expenditure Plan Part III
(Ottawa, Canada; 1996), p.  15. 

\11 Statistics Canada:  1996-97 Estimates-Expenditure Plan Part III,
p.  13. 


         STRUCTURE OF STATISTICS
         CANADA
-------------------------------------------------------- Letter :4.1.1

Statistics Canada is headed by the Chief Statistician of Canada, who
reports to the Minister of Industry,\12 and is organized by
activities or fields.  There are six fields, each of which is headed
by an assistant chief statistician (ACS).  Three of these fields
produce statistical information, while the other three support this
production.  Among the three production fields is the Social,
Institutions, and Labor Statistics field, whose responsibilities
include the census of the population, household surveys, demographic
estimates, and income statistics.  The functions of this field are
similar to the demographic activities of the Census and the labor
market activities of BLS.  The Business and Trade Statistics field of
Statistics Canada compiles statistics on the production of Canada's
manufacturing and service industries.  The field also produces
statistics on Canada's trade with other countries.  The field is
roughly equivalent to the section of the Census responsible for
economic and merchandise trade statistics.  Similar to how Census in
the United States relies on the U.S.  Customs Service for trade data,
the field relies on customs data reported by Canada Customs.  The
responsibilities of the National Accounts and Analytical Studies
field of Statistics Canada are similar to those of BEA in that it
compiles information on the economic performance of Canada and
produces such key statistics as the gross domestic product estimate. 

The fields in Statistics Canada are divided into branches that are
responsible for several related statistical programs.  For example,
within the Business and Trade Statistics field there are two
branches:  Industry, Trade, and Price Statistics and Resources,
Technology, and Services Statistics.  Within branches are divisions,
which are responsible for specific statistical programs.  For
example, the Resources, Technology, and Services Statistics branch
has five divisions:  (1) Services, Science, and Technology; (2)
Industrial Organization and Finance; (3) Agriculture; (4) Investment
and Capital Stock; and (5) Small Business and Special Surveys. 

According to Statistics Canada officials, they work closely with the
other departments and agencies of the Canadian government that use
statistics produced by Statistics Canada.  Specific data collection
or analytical tasks within Statistics Canada are often conducted by
project teams that work closely with other Canadian government
agencies.  For instance, the Agriculture Division of Statistics
Canada works closely with staff from Agriculture and Agri-Food Canada
to assist them in specifying their data requirements. 

Statistics Canada also provides information on health care (e.g.,
data on hospital admissions and accident victims, characteristics of
disabled and handicapped citizens, and a National Population Health
Survey) and education (e.g., enrollment, graduates, personnel,
programs, revenues and expenditures of Canadian educational
institutions, and a National Longitudinal Survey of Children).  In
the United States, such programs would involve or be the
responsibility of the National Center for Health Statistics in the
Department of Health and Human Services and the National Center for
Education Statistics in the Department of Education, respectively. 
Similarly, Statistics Canada houses the Canadian Centre for Justice
Statistics, which it describes as "the focal point of federal and
provincial initiatives to provide national justice statistics and
information." In the United States, the Bureau of Justice Statistics
in the Department of Justice has a comparable role.  While noting
that the mandate of Statistics Canada includes responsibilities that
are assigned to several agencies in the United States, Canada's Chief
Statistician also said that this does not mean that the scope or
coverage of the two nations' statistical systems was identical. 

The Informatics and Methodology field, the Communications and
Operations field, and the Management Services field support the work
of the statistical production fields within Statistics Canada.  For
example, the Informatics and Methodology field is to ensure that all
surveys used in Statistics Canada are methodologically valid and
statistically efficient.  These functions parallel the OMB review and
clearance process in the United States and statistical agency
responsibilities for ensuring data quality.  The Informatics and
Methodology field also is to manage information processing for all of
Statistics Canada.  (Fig.  1 summarizes the organizational structure
of Statistics Canada.)

   Figure 1:  Organization of
   Statistics Canada

   (See figure in printed
   edition.)



   (See figure in printed
   edition.)

   Source:  Statistics Canada.

   (See figure in printed
   edition.)


--------------------
\12 A minister in the Canadian parliamentary government has executive
responsibilities similar to a cabinet secretary in the U.S. 
government, although ministers are also members of Parliament. 


         ROLE OF OTHER CANADIAN
         GOVERNMENT AGENCIES AND
         PROVINCIAL GOVERNMENTS
-------------------------------------------------------- Letter :4.1.2

Other departments and agencies also play a role in collecting data
that Statistics Canada uses.  Departments and agencies collect such
data principally to be able to carry out their administrative or
regulatory mandates, but Statistics Canada can use those data to
produce broadly used statistical information.  For example, Canada
Customs collects merchandise trade data using documents that
importers and exporters must file, such as cargo control documents,
commercial invoices, and import accounting coding forms.  The
Statistics Act authorizes Statistics Canada to have access to these
records, which form the basis for statistical information on Canada's
international trade.  (This is analogous to how the U.S.  Customs
Service's data are used by Census in compiling trade data.)

Like U.S.  federal statistical agencies, Statistics Canada also
relies heavily on data from records maintained by provincial and
local governments.  In Canada, provinces have primary responsibility
for administering education, health, and justice programs and supply
their data to Statistics Canada, which in turn compiles statistics on
such areas as criminal justice, medical care outcomes, and literacy. 
According to the Canadian Chief Statistician, the mandate of
Statistics Canada includes meeting the needs of the provinces for
statistical information.  Each of the 10 Canadian provinces has a
statistical office that works with Statistics Canada.  In addition,
Statistics Canada sponsors a Federal Provincial Consultative Council
on Statistical Policy, which is the vehicle for coordinating policy
on data exchanges between Statistics Canada and the provinces.  Each
province has a member on the council appointed by the province's
premier.\13 The council is chaired by the Chief Statistician.  In
addition to supplying data, the provinces are also heavy users of
data produced by Statistics Canada, particularly data relating to
provincial economic and social conditions. 


--------------------
\13 A premier is the provincial equivalent of the Prime Minister. 


      SINGLE BUDGET FOR STATISTICS
      CANADA ALLOWS RESPONSE TO
      CHANGING PRIORITIES THROUGH
      INTERNAL REALLOCATIONS
---------------------------------------------------------- Letter :4.2

Statistics Canada has a single statistical budget of Can$479 million
(equivalent to U.S.  $349 million) for fiscal year 1996-1997 and is
able to reallocate its resources internally when the need for
information or the resources that are available for statistical
activities change.  Reallocations of resources within the U.S. 
statistical system may require moving resources among different
agencies and departments, a considerably more difficult undertaking. 
OMB prepares an annual report that lists amounts agencies requested
to fund statistical activities, but there is no consolidated budget
for statistical activities in the United States that would be
comparable to Statistics Canada's single budget.  According to OMB,
the total funding in fiscal year 1995 for all statistical activities
was $2.6 billion, including almost $1.1 billion for the 11 principal
statistical agencies.\14 All 11 principal statistical agencies
received at least some funding from congressional appropriations. 
These appropriations included amounts listed as line items in the
federal budget and amounts allocated from the agencies' parent
departments. 

OMB's Statistical Policy Branch is responsible for ensuring that the
activities of statistical agencies are in line with federal
statistical policy by such means as (1) coordinating agency budget
requests, (2) issuing statistical standards, (3) coordinating
interagency working groups on statistical issues, and (4) evaluating
the performance of statistical programs.  The branch, along with
other parts of OIRA, is responsible for reviewing agencies'
information collection requests.  In many cases, such as revising the
economic or industrial classification system used to define
industries for reporting their production, OMB works through an
interagency process, with working groups representing relevant
agencies tasked to develop recommended approaches to resolve issues. 

We and others have reported that coordinating the federal statistical
system has been a long-standing issue.  In 1980, a commission
appointed by President Carter to study the reorganization of the
federal statistical system reported that the statistical policy staff
lacked the capacity to coordinate the system because of its small
size.  More recently, in our August 1995 report, we noted that many
observers commented that the branch does not have a staff large
enough to do an effective job of coordinating federal statistical
policy.\15 As of June 1996, the branch was authorized to have five
full-time equivalent professional positions.  In our 1995 report, we
said that although the branch currently reviews budget submissions
for the principal statistical agencies and participates in OMB's
review of their parent departments' budgets, it often does not issue
its report on the budget for all federal statistical activities until
after Congress has started to determine agency budgets.  We further
noted that to adequately coordinate the systemwide activities of
federal statistical agencies, the branch would need to closely review
the budgets of smaller statistical agencies to identify such
inefficiencies as duplication of effort and to help ensure that the
limited federal funds for statistical activities are spent as
effectively as possible. 

According to Statistics Canada, its budget funds most government data
collection for statistical purposes as well as activities to produce
statistical information that is based on data collected from
government administrative records.  The majority of Statistics
Canada's funding comes from its own appropriations from Parliament. 
Statistics Canada also relies on costs that it recovers from agencies
for which it does work.  (This is similar to the practice of U.S. 
statistical agencies reimbursing other agencies, particularly Census,
for collecting data.) Statistics Canada's budget has two components: 
appropriations for the Census of the Population and appropriations
for the rest of its statistical programs.\16

The Canadian Chief Statistician told us that having a single budget
and the ability to reallocate resources provide Statistics Canada
with considerable ability to coordinate the Canadian statistical
system.  In a recent paper, he noted that

     "The purpose of coordination is to permit the components of the
     statistical system to act as a coherent system.  Such coherence
     includes the ability to mobilize budgetary resources to meet
     broad priorities, to deploy people according to overall needs,
     to exploit possible synergies (e.g., creating new information
     through record linkage), to take advantage of possible
     efficiencies (e.g., using common tools, registers, field
     staffs), to ensure that the outputs of the system are coherent
     where they need to be, and to defend the system against
     political interference."\17

The Canadian Chief Statistician said that having the ability to draw
data together from a variety of sources, including linking or
matching data on individuals in one statistical database with data on
those same individuals in other databases to form a single composite
record for statistical analysis, better positions Statistics Canada
to be more responsive to new government needs than would be the case
if it were not centralized.  According to Statistics Canada's Policy
Manual, record linkage using tax data "can replace some survey work
by use of tax data, particularly for small businesses for whom survey
reporting would otherwise be a heavy burden."\18

Finally, Statistics Canada officials told us that their ability to
avoid duplication of effort and to profit from "possible synergies,"
particularly those resulting from the linking of data across a
variety of areas is essential to their ability to control costs. 
Statistics Canada's ability to control costs may also entail
redeploying staff to reflect changes in priorities and maintaining
the essential operational and professional capacity for responding to
client needs.  According to Statistics Canada, through efforts such
as linking data, it also has been able to reduce the burden that its
efforts to collect data impose on business data providers.\19


--------------------
\14 See GAO/GGD-96-107, July 1, 1996. 

\15 Statistical Agencies:  Adherence to Guidelines and Coordination
of Budgets (GAO/GGD-95-65, Aug.  9, 1995), p.  3. 

\16 There are three ways these noncensus programs are funded:  (1)
core programs are funded completely through appropriations that
Statistics Canada allocates to these programs; (2) federal
departments supplement the appropriations for some programs to make
them statistically richer for their own purposes; and (3) federal
departments pay the full costs for activities not normally performed
by Statistics Canada, such as special surveys or improved sample
sizes needed for more detailed analysis. 

\17 I.  Fellegi, "Characteristics of an Effective Statistical
System," Morris Hansen Lecture presented before the Washington
Statistical Society (Oct.  25, 1995). 

\18 Statistics Canada, Policy Manual, Policy No.  4.1; May 7, 1986. 

\19 Statistics Canada measures the response burden on those providing
data through survey responses by calculating an annual index, which
is a composite of the estimated time to complete each business
survey; the frequency of surveys; and the number of respondents. 


   DIFFERENCES IN U.S.  AND
   CANADIAN LEGAL FRAMEWORKS
   AFFECT ABILITY TO SHARE AND
   ACCESS DATA
------------------------------------------------------------ Letter :5

U.S.  statistical activities are authorized by many different laws
and regulations, rather than a single statute.  Provisions of law
designed to protect the confidentiality of individual data providers
limit the extent of data sharing among the agencies in the federal
statistical system.  Although data sharing occurs among the
statistical agencies, it occurs under arrangements that are specific
to the agencies involved rather than under a single authorizing
statute.  The activities of the federal statistical system, including
the data sharing that does occur, are to be coordinated under
provisions of the Paperwork Reduction Act of 1980, as amended. 
Statistical agencies are also subject to the Privacy Act of 1974, as
amended,\20 and the Freedom of Information Act of 1966, as
amended.\21

In Canada, a single law, the Statistics Act, provides the authority
for all activities of Statistics Canada, including the coordination
of those parts of the Canadian statistical system not included in
Statistics Canada, and applies to all components of Statistics
Canada.  Under the Statistics Act, Statistics Canada has broad access
to administrative records, the authority to use data from several
sources to construct composite records, and the authority to share
data among different components of Statistics Canada.  The Statistics
Act also provides for the protection of the confidentiality of
individual data providers, as does Canada's Access to Information Act
and Privacy Act. 


--------------------
\20 5 U.S.C.  552a. 

\21 5 U.S.C.  552. 


      THE UNITED STATES HAS MANY
      STATUTES GOVERNING
      STATISTICS, WHILE CANADA HAS
      ONE
---------------------------------------------------------- Letter :5.1

In the United States, each statistical agency was created to respond
to particular needs.  Census, for instance, can trace its history
back to the Constitution, which requires a census of the
population.\22 One of the earliest tasks for BLS was to provide
information on employment and unemployment.  Its mission grew to
include the preparation of information on prices in order to measure
the rate of inflation.  Other agencies were created to produce other
data.  As a result, there are now numerous statutes authorizing the
activities of agencies that have statistics as their primary missions
and numerous other statutes and programs that require the use of
statistical data.\23

In many cases, statistical agencies operate under authority derived
from the operating authority granted to their parent departments.  No
single law sets out the standards and requirements that are to govern
federal statistical activities.  However, OMB is empowered to
establish statistical policy for the executive branch.  The Committee
on National Statistics of the National Academy of Sciences has also
published guidelines that are intended to be �best practices� and
consistent with current laws and statistical theory.\24

In addition, U.S.  statistical agencies operate under governmentwide
legislation affecting privacy and access to data.  The Privacy Act
provides protection for individuals with regard to individually
identifiable records.  The Privacy Act embodies privacy principles
regarding disclosure, access, and due process for individually
identifiable information.  Both the Privacy Act and the Freedom of
Information Act regulate the disclosure of documents or other records
of federal agencies, including statistical records.  The Freedom of
Information Act generally permits public access to federal records,
such as surveys, but provides for exceptions to such access when it
would disclose data that could identify individuals.  The Privacy Act
restricts public access to information about individuals but makes
exceptions for disclosure under specific circumstances.  In addition
to providing for coordination of the federal statistical system, the
Paperwork Reduction Act is intended to reduce the burden on those
responding to federal requests for data.  This act, for instance,
requires OMB to approve federal data collection instruments or other
federal requests for data. 

Statistics Canada has one statute that covers nearly all aspects of
data collection, data dissemination, and statistical system
organization.  In 1918, the Canadian Parliament began the process of
consolidating the country's statistical activities by passing the
legislation that created the Dominion Bureau of Statistics.  As a
result of this legislation, statistical activities that were in
several government departments were transferred into the bureau.  The
Statistics Act of 1971 further consolidated Canadian statistical
activities.  The act changed the name of the Dominion Bureau of
Statistics to Statistics Canada and gave it broad authority as the
primary agency for the collection and dissemination of government
statistics and the coordination of the statistical activities of
other federal agencies as well as provincial agencies involved in
these activities.  The act applies uniformly to all components of
Statistics Canada.  Statistics Canada is also subject to Canada's
Access to Information Act and Privacy Act.  The latter intends, among
other things, to protect the confidentiality of data on individuals. 

Canadian officials cited several advantages to having virtually all
statistical activities governed by one statute.  First, the act gives
Statistics Canada blanket access to all data that are collected by
the government, including administrative records.  According to the
Canadian Chief Statistician, this access provides information that is
of higher quality or that costs less to produce than would be the
case without such authority.  For example, Statistics Canada has
access to tax records maintained by Revenue Canada (Canada's
equivalent to the U.S.  Internal Revenue Service) that Statistics
Canada can use as a primary source of information or to supplement
information it collects through surveys.  According to Statistics
Canada officials, this access has been a major reason that Statistics
Canada has been able to reduce the reporting burden it imposes on
Canadian businesses by a cumulative total of 66 percent between 1978
and 1995. 

Second, the Canadian Chief Statistician also noted that the legal
authority and responsibility to collect or supervise the collection
of all official government data enables Statistics Canada to ensure
data consistency.  For example, Statistics Canada can collect data
from businesses in a format that can be readily used for its periodic
reports on business performance as well as for its National Accounts,
which are used to produce the measure of gross domestic product. 


--------------------
\22 This requirement is codified at 13 U.S.C.  141. 

\23 See Statistical Agencies:  Statutory Requirements Affecting
Government Policies and Programs (GAO/GGD-96-106, July 17, 1996). 

\24 Principles and Practices for a Federal Statistical Agency
(Washington, D.C.:  National Academy Press, 1992). 


      CANADA'S CONFIDENTIALITY
      STATUTES ALLOW MORE DATA
      SHARING THAN THOSE OF THE
      UNITED STATES
---------------------------------------------------------- Letter :5.2

Confidentiality requirements limit the extent to which U.S. 
statistical agencies can share data among themselves or link together
different administrative records.  Some argue that these constraints
are necessary to protect the privacy of data providers.  Statistics
Canada does not face such constraints because it is a single agency
operating under a single law that governs confidentiality
requirements, is granted access to any government administrative
record, and is permitted to match records on individuals in different
databases for statistical purposes (i.e., link records).  It does
have strong provisions that are designed to ensure data
confidentiality, however, and rigorous review and approval procedures
governing records linkage. 

In the decentralized U.S.  statistical system, data sharing among
statistical agencies does occur; however, it is constrained and
sometimes precluded by confidentiality laws.  In the United States,
governmentwide laws and policies are intended to ensure the privacy
of data providers.  At least one confidentiality or disclosure
provision (or, in the case of BLS, a Commissioner's Order) applies to
each of the 11 principal statistical agencies, and most of these
provisions strictly protect the confidentiality of data providers.\25
However, because most of the confidentiality provisions only apply to
a single agency, the agency initially collecting data is often
limited in what it can share with other agencies.  For example, BLS
must compile its own list of business establishments, thus
duplicating to some degree what Census does, in part, because Census'
confidentiality provisions do not permit BLS to have access to
Census' Standard Statistical Establishment List.  Also, because of
these confidentiality provisions limiting access to Census' records,
other statistical agencies at times had only limited access to data
that the agencies had paid Census to collect if those data could
identify data providers.  For instance, BLS does not have full access
to the Consumer Expenditure Survey data that it uses to update the
Consumer Price Index, although it reimburses Census for conducting
the survey.  Since 1979, we have recommended changes to existing
statutes that would enable statistical agencies to share data.\26

Over the past decade, OMB has sought legislative changes that would
allow greater sharing of data and information on data sources among
statistical agencies.  On January 29, 1996, OMB published a Federal
Register notice requesting comments on a draft administrative order
that would establish a uniform policy for protecting confidential
statistical information in any executive branch agency.  That order,
however, would not remove any limits imposed by law on data sharing
arrangements.  In April 1996, OMB sent to Congress proposed
legislation that would establish policies and procedures intended to
guarantee the consistent and uniform application of the
confidentiality of data provided for statistical purposes.  The
legislation would also authorize limited sharing of data for
statistical purposes among statistical agencies.  In June 1996, the
Department of the Treasury sent to Congress proposed complementary
legislation that would permit limited sharing of tax information
among designated statistical agencies for statistical purposes
subject to procedural safeguards contained in the proposal. 

Earlier reluctance to ease confidentiality provisions that would
allow a greater sharing of data among agencies can be explained, in
part, by the strong traditions in the United States for protecting
the privacy of individuals.  Restricting access to data that
individuals and businesses supply to agencies is intended to provide
some protection against the potential misuse of these data by the
government whether these are demographic data collected by the Census
or tax data obtained by the Internal Revenue Service. 

Statistics Canada depends on data that are collected from
administrative records and used by Canadian program departments as
well as the provinces.  In carrying out its responsibilities,
Statistics Canada has access to all administrative records held by
the Canadian government, including tax return data held by Revenue
Canada.  Statistics Canada also has the ability to match or link data
on individuals from different administrative records and other data
sources.  Canada's Statistics Act allows the sharing of data from
surveys with federal, provincial, and local governments.  This
sharing does not apply to administrative records that Statistics
Canada uses to produce statistical information.  According to the
Chief Statistician, the Statistics Act "provides blanket access for
Statistics Canada to all records held by the governments, and
specifically identifies all taxation and customs records, as well as
records of the courts." He said that in his view, this access makes
it possible for Statistics Canada to obtain as good or better
information than would otherwise be the case. 

Canada's Statistics Act imposes confidentiality on data that could
identify the providers of those data.  These data providers must be
advised when data are to be shared with another body and may object
to such an arrangement.  Canada's Privacy Act governs how and when
personal information can be collected and how it can be used.  In
addition, the act includes provisions intended to ensure the
protection of that information.  As a matter of policy, Statistics
Canada lists, in an annual report to Parliament on the implementation
of the Privacy Act, the linkages that it carried out in a given year. 


--------------------
\25 GAO/GGD-96-106, July 17, 1996. 

\26 After Six Years, Legal Obstacles Continue to Restrict Government
Use of the Standard Statistical Establishment List (GGD-79-17, May
25, 1979). 


   SIMILARITIES AND DIFFERENCES
   EXIST IN THE POSITIONS OF THE
   CHIEF STATISTICIANS IN THE
   UNITED STATES AND CANADA
------------------------------------------------------------ Letter :6

In the United States and Canada, a Chief Statistician has been
designated to lead the federal statistical system.  In several
aspects, the positions are similar.  Both are tasked with
coordinating the work of their statistical systems.  Both hold
positions that are at the top of each nation's career civil service. 
Both operate under safeguards intended to provide independence from
political interference.  However, there are also differences between
the two positions.  Canada's Chief Statistician, while a career civil
servant, is a deputy minister selected by the Prime Minister.  The
U.S.  Chief Statistician holds a career Senior Executive Service
position, reporting to the Administrator of OIRA in OMB.  Canada's
Chief Statistician, as the head of Statistics Canada, is responsible
for producing and disseminating most of the nation's official
statistical information.  The U.S.  Chief Statistician heads OMB's
Statistical Policy Branch and is responsible for coordinating the
federal statistical system but does not have direct responsibility
for producing or disseminating statistical information. 


      THE CHIEF STATISTICIANS HAVE
      PROTECTION AGAINST POLITICAL
      INTERFERENCE
---------------------------------------------------------- Letter :6.1

Both Chief Statisticians have noted that their positions are intended
to provide independence from political influence.  In the United
States, the Chief Statistician is a career position, rather than a
political appointment.  In Canada, although the Chief Statistician is
selected by and serves at the pleasure of the Prime Minister, the
Chief Statistician has pointed to two factors tending to provide
effective protection against political interference.  One, he said,
is a long-standing Canadian tradition that deputy ministers,
including the Chief Statistician, retain their positions through
changes in government.  The other is that the Prime Minister's
instructions to the Minister of Industry direct that the Minister
maintain an arm's-length relationship to Statistics Canada.  One
example of the Chief Statistician's independence is that the Chief
Statistician cannot be overruled by the Minister of Industry on
issues of confidentiality.  The Chief Statistician also noted that
the Chief Statistician traditionally defends the budget for
Statistics Canada before Parliament; the Chief Statistician noted
that deputy ministers in most other departments will accompany the
responsible minister rather than appear alone.\27


--------------------
\27 The U.S.  Chief Statistician does not testify before Congress
because of an OMB policy that reserves authorization to testify to
officers confirmed by the Senate. 


      APPROACHES TO THE
      COORDINATION ROLE OF THE
      CHIEF STATISTICIANS DIFFER
---------------------------------------------------------- Letter :6.2

In both the United States and Canada, the Chief Statistician is
charged with coordinating the federal statistical system.  However,
given differences in the designs of the two systems, the manner in
which they are to carry out their responsibilities differs.  Under
the Paperwork Reduction Act, the U.S.  Chief Statistician is to
coordinate statistical policy through such means as oversight of the
agency budgets, issuance of policies and directives to the
statistical agencies, and leadership of an interagency process.  The
Chief Statistician told us that coordination generally occurs through
a collaborative process involving the statistical agencies, although
OMB retains the authority to mandate actions to coordinate
statistical agencies.  The U.S.  Chief Statistician does not have
authority to direct a reallocation of staff or budgets for
statistical activities.  However, the Chief Statistician's position
in OMB provides the opportunity to contribute to administration
decisions on staff years or budgets of statistical agencies that are
proposed in the President's budgets.  A recent example is the
proposal in the President's fiscal year 1997 budget to shift the
responsibility for the Census of Agriculture from Census to the
National Agricultural Statistics Service in the Department of
Agriculture. 

In practice, although the U.S.  Chief Statistician has the
legislative authority to coordinate statistical policy and
statistical agency budgets, many observers have commented that the
Chief Statistician has lacked the staff and resources to effectively
exercise this authority.  For instance, one expert on the U.S. 
statistical system recently noted that "since 1947, the real or
inflation adjusted dollar budget for federal statistics has increased
19 times over while the number of professionals assigned to the Chief
Statistician in OMB for statistical policy and coordination of the
system fell from about 65 to 5."\28 Similarly, Janet Norwood noted
that

     "The workload involved in coordination and planning for the 10
     statistical agencies alone--to say nothing about the statistical
     work done elsewhere in the government--is too large for the
     staff currently assigned to SP [the Statistical Policy Branch in
     OMB].  Of necessity, therefore, the statistical policy group has
     focused its attention only on program issues of major
     importance."\29

As we noted in our 1995 report, according to Statistical Policy
Branch officials, the branch is sometimes required to adjust its
priorities on the basis of such factors as new administration
initiatives or staff shortages.\30

In Canada, the Chief Statistician's role is much different than it is
in United States, due largely to the centralized structure of the
Canadian system and the Chief Statistician's position and rank as a
deputy minister.  As head of Statistics Canada, the Chief
Statistician has direct control over the agency's budget and
personnel.  Therefore, the Chief Statistician can make and implement
resource allocation decisions and coordinate statistical activities. 
The Chief Statistician said that, in practice, he periodically meets
with staff from Canadian agencies to discuss needs and priorities and
that he bases his decisions on priorities for Statistics Canada
largely on those discussions.  According to Statistics Canada
officials, the Chief Statistician's control over Canada's statistical
budget and rank as a deputy minister provide considerable leverage in
negotiations with agencies that either supply data to Statistics
Canada or use the statistics produced by it. 

Statistics Canada officials noted that the Chief Statistician's
authority for coordinating statistical activities of other Canadian
agencies is modest compared to the Chief Statistician's authority
over Statistics Canada.  They said that this reflects the small role
played by agencies outside of Statistics Canada in producing or
disseminating official statistical data. 


--------------------
\28 Hearing on H.R.  2521 Before the Subcommittee on Government
Management, Information, and Technology of the House Committee on
Government Reform and Oversight, 104th Cong., 2nd Sess.  (1996)
(Statement of James T.  Bonnen, Professor, Michigan State
University). 

\29 Organizing to Count, p.  54.  In 1995, OMB identified 10 agencies
as the principal statistical agencies.  We added the Department of
the Treasury's Statistics of Income Division in counting principal
statistical agencies because its mission is also primarily
statistical.  OMB's Chief Statistician and principal statistical
agency officials agreed with this classification.  All 11 agencies
are listed in footnote 5. 

\30 GAO/GGD-95-65, August 9, 1995. 


   AGENCY COMMENTS
------------------------------------------------------------ Letter :7

We received written comments on this report from the Chief
Statistician of Canada who agreed with its contents.  On June 24,
1996, we met with the U.S.  Chief Statistician in OMB who generally
agreed with the report's contents and suggested various technical
changes, which we incorporated into the report, as appropriate. 


---------------------------------------------------------- Letter :7.1

We are sending copies of this report to the Director of OMB, the U.S. 
Chief Statistician, the Canadian Chief Statistician, the Canadian
Auditor General, and other interested parties.  Copies will also be
made available to others upon request. 

If you have any questions concerning this report, please call me on
(202) 512-4232.  Major contributors to this report are listed in the
appendix. 

Bernard L.  Ungar
Associate Director, Federal Management
and Workforce Issues


MAJOR CONTRIBUTORS TO THIS REPORT
==================================================== Appendix Appendix

GENERAL GOVERNMENT DIVISION,
WASHINGTON, D.C. 

James McDermott, Assistant Director
Anthony L.  Hill, Project Manager
Angelia Collier, Evaluator

LOS ANGELES FIELD OFFICE,

Edward Laughlin, Senior Evaluator


*** End of document. ***