Semiannual Report to Congress
October 1, 1999 through March 31, 2000

• Inspector General Letter

• Agency Profile

• Office of Inspector General

• Audit Program

• Investigations Program

• Legislation, Regulations, and Policy

• Liaison Activities

• Information Required by the Act

• Audit Reports by Subject Matter

• Reports with Questioned Costs

• Reports with Recommendations that Funds be put to Better Use

Inspector General

National Labor Relations Board

Washington, DC 20570

I hereby submit this Semiannual Report: October 1, 1999 - March 31, 2000, which summarizes the major activities and accomplishments of the Office of Inspector General (OIG) of the National Labor Relations Board (NLRB or Agency). The submission of this report is in accordance with the Inspector General Act of 1978, as amended (IG Act). Section 5 of the IG Act requires that the Chairman transmit this report to the appropriate committees or subcommittees of the Congress within 30 days of its receipt.

OIG issued two audit reports and two inspection memoranda. In the investigations program, OIG processed 72 contacts, initiated 12 cases, and closed 15 cases. The investigations resulted in one personnel action this period, and $1,760 in funds put to better use. We commented on five bills, three documents related to law enforcement authority, and two Agency regulations. Details on these accomplishments can be found in the body of this report.

Several OIG accomplishments involved implementation of the Government Performance and Results Act. OIG evaluated the adequacy of NLRB plans and preparations to accurately report on the performance measures and the achievement of Agency goals. The Inspector General participated in a retreat for Agency management to develop a revised Strategic Plan. The OIG Strategic Plan was also reviewed and a decision reached to include these goals and objectives in the Agency Strategic Plan.

An external quality control review was conducted of OIG audit operations for a three-year period. The report stated that a system of internal controls was in place and operating effectively, and the audits were performed in accordance with standards.

Outreach efforts this period included finalizing three brochures on OIG operations. We continued work on developing a web page as part of the Agency's official web site.

I appreciate the support of all Agency employees in achieving the accomplishments set forth in this report.

s/Jane E. Altenhofen

April 28, 2000

AGENCY PROFILE

The National Labor Relations Board (NLRB or Agency) is an independent federal agency established in 1935 to administer the National Labor Relations Act (NLRA). The NLRA is the principal labor relations law of the United States, and its provisions generally apply to private sector enterprises engaged in, or to activities affecting, interstate commerce. NLRB jurisdiction includes health care institutions and the U.S. Postal Service (other government entities, railroads, and airlines are not within NLRB’s jurisdiction.)

The NLRB seeks to serve the public interest by reducing interruptions in commerce caused by industrial strife. It does this by providing orderly processes for protecting and implementing the respective rights of employees, employers, and unions in their relations with one another. The NLRB has two principal functions: (1) to determine and implement, through secret ballot elections, the free democratic choice by employees as to whether they wish to be represented by a union in dealing with their employers and, if so, by which union; and (2) to prevent and remedy unlawful acts, called unfair fair labor practices, by either employers or unions or both.

NLRB authority is divided by law and delegation. The five-member Board primarily acts as a quasi-judicial body in deciding cases on formal records. The General Counsel investigates and prosecutes unfair labor practices before administrative law judges, whose decisions may be appealed to the Board; and, on behalf of the Board, conducts secret ballot elections to determine whether employees wish to be represented by a labor organization.

The NLRB Board consists of the Chairman and four members who are appointed by the President with the advice and consent of the Senate. Board Members serve staggered terms of five years each. The General Counsel is also appointed by the President with the advice and consent of the Senate and serves a four-year term. The present Board Members have served throughout this reporting period. Sarah Fox received a recess appointment to serve as a Board Member and was sworn in on December 17, 1999. She served under a previous recess appointment from January 19, 1996, to November 8, 1997, when she was confirmed by the Senate for a term expiring December 16, 1999.

Fred Feinstein, the previous General Counsel, ended his term when Congress adjourned on November 19, 1999. Leonard Page received a recess appointment to serve as General Counsel and was sworn in on November 29, 1999.

NLRB received an appropriation of $206,500,000 for Fiscal Year (FY) 2000, of which $783,000 was rescinded, to fund 1,947 full-time equivalents.

NLRB Headquarters is at 1099 14^th Street, NW Washington, DC. In addition to the Headquarters building, employees are located in 51 field offices throughout the country. The field offices include 33 regional offices, 16 resident offices, and 2 sub-regional offices. Three satellite offices for the Administrative Law Judges are located in Atlanta, San Francisco, and New York.

Additional information about NLRB can be found on the web site www.NLRB.gov.

The NLRB established the Office of Inspector General (OIG) pursuant to the 1988 amendments to the Inspector General Act of 1978 (IG Act).

The FY 2000 OIG budget was $775,800 for operations, of which $65,000 was for contract services. In addition to the Inspector General, the OIG consists of a Counsel/Assistant Inspector General for Investigations, Assistant Inspector General for Audits, Special Agent, two Auditors, and a Staff Assistant.

Bridgette Hicks was selected for an Auditor position and entered on duty November 14, 1999. She filled a position that had been vacant since March 1999.

Dave Zielinski transferred to the Department of Justice (DOJ) on March 26, 2000. During his tenure with the Agency from May 1, 1994, he had served the OIG in the dual capacity of Chief Counsel/Assistant Inspector General for Investigations. He significantly contributed to the accomplishments of the OIG by providing legal counsel and services needed to carry out the statutory responsibilities imposed by the IG Act.

AUDIT PROGRAM

The Inspector General is to provide policy direction for and is to conduct, supervise, and coordinate audits relating to program operations of the Agency. We issued two audit reports and two inspection memoranda, and successfully completed a peer review.

We issued Audit Report OIG-AMR-29-00-01, Evaluation of Time and Attendance Practices, on February 29, 2000. At the Board's request, OIG determined whether management controls provided reasonable assurances that time and attendance (T&A) transactions were properly authorized and approved, and associated records were complete and accurate. For nine Board-side offices, we found:

Employees administering leave and attendance were not delegated responsibilities in writing, and inappropriate employees were often administering leave and attendance.

No offices had designated timekeepers and alternates in writing. In seven offices, the timekeeper and alternate shared passwords. Also, passwords were not changed periodically in seven offices.

Except for employees working a compressed work schedule, techniques providing timekeepers reasonable assurance regarding employee presence or absence to record T&A data for Board employees did not exist.

Six offices did not maintain work schedules indicating planned work times and hours per day. Two additional offices maintained schedules, but there was no evidence of supervisor approval.

Two offices did not prepare and maintain necessary documentation for approval and use of annual and sick leave. Seven offices claimed to prepare and maintain documentation, but three offices excluded the office head and documentation was missing in all offices for a significant portion of transactions.

Five offices tracked compensatory time and credit hours informally rather than in the payroll system.

No offices properly approved T&A reports. Most significantly, T&A reports were not approved in one office; and in six offices, timekeepers, alternates, or another support staff member approved T&A reports even though these employees were all non-supervisory personnel specifically prohibited from approving T&A reports.

Advances of sick leave had pervasive problems. Advanced sick leave was not requested in accordance with Agency policy, not approved at the designated level, and not adequately documented.

Board-side offices did not comply with Agency policies on authorization and approval of T&A transactions, maintenance of T&A records, and regular reviews of procedures.

OIG made 11 recommendations. The Director of Personnel agreed with all but one of the recommendations. OIG accepted the alternative action proposed as it effectively implemented the remaining recommendation.

We issued Audit Report OIG-AMR-26-00-02, Review of Board Casehandling Timeliness on March 31, 2000. We reviewed unfair labor practice cases appealed to the Board for a decision and determined whether: controls over case handling were effective, the database was accurate, and Board decisions were issued in a timely manner.

In 1991 the Board established an unofficial time standard that set six months as the length of time a case should be at each of three decision stages and two years as the outside limit for a case to be at the Board. Over a ten-year period, some cases always exceeded the established time standards.

Board Member turnover was the factor most often identified as having a significant impact on the timeliness of case processing. Staff reductions were also frequently cited as a reason for an increase in pending cases and the median days to process cases.

Multiple options for expediting a case are currently available to Board Members. These include establishing case priorities, scheduling Board meetings, redirecting staff assignments/duties, requesting that a case be reassigned to another Board Member, foregoing a dissenting or separate opinion, or limiting the length of decisions. No one option will fit every situation. Board Members individually and as a group must assess each situation and determine what is necessary to ensure timely action on cases.

We found that key elements in the electronic database of cases at the Board were accurate, with few exceptions. However, system edits were not in place to prevent the system's acceptance of illogical data.

This report was not intended to detract from the current Board's efforts to reduce the pending caseload, particularly the oldest cases. The Board's accomplishment in issuing the oldest cases is commendable, but does not negate the fact that many cases still exceed the agency standards in every stage and overall.

The Board will most likely continue to experience turnover and vacancies, and Board Members need to adjust how they handle cases in order to meet timeliness standards. The Board's accomplishments support our finding that the casehandling process has the flexibility to allow different solutions to be applied to the specific circumstances of each case. Further, the difficulties encountered indicated a systemic solution cannot be dictated by policy.

We recommended that the Executive Secretary:

• Revise Board policy to include current time standards for case processing;

• Cancel unused policies designed to promote timeliness, and implement recommendations made by the Committee; and

• Develop appropriate edits for the electronic database.

The Executive Secretary agreed with all three recommendations.

We issued Inspection Report No. OIG-INS-4-00-01: Review of NLRB's Compliance with the Federal Managers' Financial Integrity Act of 1982 on December 21, 2000. This review covered the fiscal year ended September 30, 1999.

We found that the evaluation of the system of internal accounting and administrative control had been carried out in a reasonable and prudent manner. During the review, nothing came to our attention that would indicate that the Board did not substantially comply with applicable laws and regulations.

We identified two actions to better implement the requirements for financial management systems.

• The Agency should prepare plans following the Financial Management 5-Year Plan guidance.
• The review methodology used by Agency systems managers should document consideration of financial management system requirements.

The Deputy Director of Administration, who serves as the Chairman of both the Management Controls Planning Committee and the Financial Planning Committee, agreed with our conclusions and incorporated a suggestion to include results of significant reviews conducted into a revised draft report from the Director of Administration.

We issued Inspection Report No. OIG-INS-05-00-02, Update of Results Act Implementation on March 16, 2000. The OIG evaluated the adequacy of NLRB plans and preparations for measuring performance in accordance with the Government Performance and Results Act of 1993. We specifically reviewed the Agency's ability to accurately report on the performance measures and the achievement of its goals to date.

We found that 16 of 48 goals were not defined or expressed as tangible, measurable objectives. Support was missing or not readily available for some performance measures. A revised performance plan for FY 1999 was not prepared in a timely or clear manner. The results in the draft performance reports did not include specific data on some measures or comments necessary for readers to understand the data, and most significantly, that periods of time or cases were excluded from the results.

We made four suggestions relating to the strategic plan. The verification and validation description, in either the strategic plan or a supporting document, should include the following information for each performance measure.

• Assign responsibility for accumulating and reporting the data, which may be different than who is responsible for the accomplishment.
• Define clearly the factors used in the measurement, particularly the beginning and ending dates and any case universe.
• Identify the systems that will be used to gather the data and ways the data will be checked for accuracy and completeness.
• Establish what and where supporting data will be maintained for annual performance reports, and identify where underlying support is maintained.

We also suggested that the Agency adopt a policy to prepare an interim performance report for internal purposes. This report would alert the Agency at six months of any problems in gathering data, and allow adjustments in work priorities if needed to meet goals in the Strategic Plan.

The Agency substantially revised the strategic plan, annual performance plan, and annual performance report based on input from the OIG.

As of March 31, 1999, the one ongoing audit was of NLRB's Fiscal Year 1999 Accounting and Reporting Systems. A request for bids was issued for a Review of Information Security.

The IG Act provides that each Inspector General shall comply with standards established by the Comptroller General of the United States. One of the standards states that organizations conducting government audits should have an external quality control review at least once every three years.

The Inspector General arranged for the Inspector General of the Farm Credit Administration (FCA) to conduct an external quality review of the OIG. The FCA Inspector General completed the review in accordance with the bylaws for peer review evaluations adopted by the inspectors general of the designated agencies of the ECIE.

In his report, issued on March 3, 2000, the FCA Inspector General concluded that a system of internal controls was in place and operating effectively, and that audits performed by the OIG and by contractors were being carried out in accordance with Government Auditing Standards.

INVESTIGATIONS PROGRAM

The Inspector General is to provide policy direction for and is to conduct, supervise, and coordinate investigations relating to the programs and operations of the Agency. OIG processed 72 contacts, initiated 12 cases, and closed 15 cases. The investigations resulted in one personnel action and $1,760 in funds put to better use.

Software Licensing Violation. A company notified OIG that the Agency may have been violating a licensing agreement that authorized 50 employees access to the Daily Labor Report (DLR). Employees were allegedly downloading issues of DLR for distribution to routing lists. The Agency promptly notified users that DLR is copyrighted material, and provided a summary of the restrictions in the license agreement. Further guidance was subsequently provided to reflect permission from the company for each authorized user to print one hard copy for routing purposes. (OIG-I-245)

Conflict of Interest and Mismanagement. An employee notified OIG of a supervisory employee's potential conflict of interest and other inappropriate conduct in a regional office. OIG coordinated with the Designated Agency Ethics Officer, who determined the relationship in question was not a conflict of interest.

OIG determined the supervisor stored alcoholic beverages in the office refrigerator on one occasion and shared the beverages with staff. OIG informed the Regional Director that government regulations do not permit alcohol to be brought onto, or consumed within, government property except as authorized for celebratory occasions. The Regional Director notified the supervisor of this prohibition. OIG also informed the Regional Office that an unofficial system for recording compensatory time was improper. (OIG-I-246)

Unsecured Privacy Act Information. An Agency employee gave a computer printout to an OIG employee. The printout was part of several pallets of material, some in open boxes. The pallets were stored overnight in a public area pending pick-up by a contractor for destruction. The printout was a list of agency employees with personal information including the social security numbers and other data covered by the Privacy Act.

The Privacy Act Officer implemented a new policy, effective immediately, that sensitive material must be placed in boxes with lids, secured with tape, and stored in a secure area. (OIG-I-261)

Travel Voucher Fraud.On February 29, 2000, OIG reported that an Agency attorney had filed an improper claim for lodging obtained from a family member. The attorney also participated in a similar fraud perpetrated by his wife who was also an Agency attorney. As a result of agreements to settle these two cases, the attorney made full restitution of $5,311 for the false claim, and the Government agreed to not pursue criminal or civil prosecution, with the understanding that administrative sanctions might be taken. The Agency is currently in the process of determining what those actions will be. (OIG-I-150)

Workers' Compensation Overpayment. As part of a continuing investigation, OIG found that an employee improperly received compensation for a month after returning to work, and at a higher rate than was allowed after her dependent turned 18 years old. The Department of Labor advised the employee in January 2000 that benefits were overpaid in the amount of $1,760.51. (OIG-I-198)

Outside Employment and Improper Use of Government Resources. An allegation of misconduct by a regional employee was initially reviewed by the Division of Operations-Management. The Division found the employee had not received written approval for outside employment, did not comply with Agency leave policies, and used Agency resources for personal business on more than a de minimis basis. The employee was notified of a proposed 5-day suspension for this misconduct. OIG is investigating other aspects of this allegation. (OIG-I-252)

Employees and members of the public with information on fraud, waste and abuse are encouraged to contact the OIG. A log of telephone calls to a nationwide toll free number or the regular office numbers and a log of information received via mail and facsimile are maintained. All information received, regardless of the method used, is collectively referred to as HOTLINE contacts.

The information received over the hotline is the basis for the initial review for potential investigations. The information is analyzed to determine if further inquiry is warranted. Most HOTLINE contacts are calls from members of the public seeking help on an employment related problem or issues outside OIG and/or Agency jurisdiction. As appropriate, OIG refers these callers to: the NLRB office; local, state, or federal agency; or private resource that is able to provide assistance.

During this reporting period, OIG received 72 hotline contacts, of which 52 were telephone calls and 17 were in writing. Ten contacts resulted in OIG investigations.

LEGISLATION, REGULATIONS, AND POLICY

The Inspector General is to review existing and proposed legislation and regulations relating to programs and operations of the Agency and is to make recommendations concerning the impact of such legislation or regulations. Similarly, we review Agency and OIG policy. We commented on five bills, three documents related to law enforcement authority, and two Agency regulations.

S. 870 IG Act Amendments of 1999. A bill to amend the IG Act to increase the efficiency and accountability of OIGs within Federal departments. April 22, 1999.

OIG participated in developing a letter, dated March 21, 2000, that was sent to the Chairman of the Permanent Subcommittee on Investigations, Senate Committee on Governmental Affairs. The letter expressed concerns about the consolidation proposal and provisions that did not provide comparable treatment throughout the IG community.

S. 1707 IG Act Amendments. A bill to amend the IG Act to provide for the appointment of inspectors general of designated federal entities by the President. October 7, 1999.

H.R. 2013 Amendments to the IG Act of 1978 to provide for the appointment of the Inspector General of certain federal entities by the President of the United States. June 7, 1999.

OIG provided input to a response addressing S. 1707 and H.R. 2013. OIG commented that increasing the number of appointments requiring the action of both the President and the Senate would unduly burden that system and exacerbate the current problem of extended periods of time without an incumbent inspector general.

S. 1993 Government Information Security Act of 1999. A bill to reform Government information security by strengthening information security practices throughout the Federal Government. November 19, 1999.

OIG recommended two changes to the Act. First, that inspectors general should determine which reviews to perform and not be required to perform information system reviews annually. Second, annual reviews, if conducted, should be performed in accordance with generally accepted Government auditing standards.

H.R. 305 Office of Inspector General Oversight Council Act of 1999. A bill, which was referred to the Committee on Government Reform, to amend the IG Act of 1978 to establish an Office of Inspector General Oversight Council. January 6, 1999.

OIG commented that the Integrity Committee, as established by the President, performs the functions that the bill would assign to a new entity.

In late September 1999, an Arizona District Court Judge found that Department of Transportation (DOT) OIG's criminal investigative authority was limited to those investigative targets who are grantees, contractors, recipients of DOT funds, or whose employees fraudulently colluded with DOT employees. In October 1999, OIG provided input to the DOT OIG supporting a recommendation for DOJ to appeal the Court Order and reporting the number and type of investigations that could be affected by the Order.

In January 2000, OIG concurred with a legislative referral memorandum by DOJ transmitting a draft bill to amend the IG Act. This bill would grant agents of 23 presidentially-appointed inspectors general the authority to carry firearms, make warrantless arrests, and seek and execute warrants, without prior deputation by the DOJ. The bill would retain some DOJ oversight of the exercise of these additional powers.

In March 2000, the Inspector General participated in signing a memorandum from the inspector general community to the Chairman of the Senate Committee on Governmental Affairs. This memorandum urged the Chairman to favorably consider the proposed legislation.

Public Law 104-132, Antiterrorism and Effective Death Penalty Act of 1996, provided for the establishment of a Commission on the Advancement of Federal Law Enforcement. The Commission was asked to report to Congress and the American people on a wide variety of matters related to Federal law enforcement. The Commission's report was issued in January 2000 and suggested that law enforcement authority be removed from the OIGs and assigned to other federal law enforcement agencies, such as the Federal Bureau of Investigation and Customs Service.

OIG participated in developing the response by the inspector general community that categorically disagreed with the recommendations of the Commission as they apply to the inspector general community.

The Counsel to the Inspector General was a member of the Rules Revision Committee which develops changes to Agency procedural regulations. The Committee continued to work on proposed changes to existing Agency regulations developed in the prior period. The changes implement the Freedom of Information Act (FOIA) mandated requirements for electronic communications and clarify how FOIA requests to the Inspector General for OIG documents are processed.

In January 2000, OIG reviewed a draft Notice of Proposed Rulemaking distributed to Committee members for initial review. The draft proposal was to amend the rules to implement a requirement that all interest awarded on backpay and other monetary awards be compounded daily. OIG concurred with the draft Notice.

OIG continued to coordinate with the Agency records management officer and the National Archives and Records Administration (NARA) on a records schedule which authorizes the disposal of OIG files.

We initiated a major review of OIG investigative files in accordance with the revised schedule and Agency policy. A NARA official reviewed some records, tentatively identified to be permanently retained, and confirmed that the records met the draft criteria.

LIAISON ACTIVITIES

The Inspector General is to recommend policies for, and is to conduct, supervise, or coordinate relationships between the Agency and other Federal agencies, State and local governmental agencies, and nongovernmental entities. The Inspector General is to give particular regard to the activities of the Comptroller General of the United States, as head of the General Accounting Office (GAO). Similarly, we encourage OIG staff members to participate in Agency programs and activities. OIG staff members are active in the inspector general community, agency activities, and select non-governmental entities. OIG met with GAO staff. The OIG Strategic Plan was revised.

Inspector General Community

The Inspector General is a member of the Executive Council on Integrity and Efficiency (ECIE), which consists primarily of the inspectors general at the Federal entities designated in the 1988 amendments to the IG Act. She participated in activities sponsored by the President's Council on Integrity and Efficiency (PCIE), which consists primarily of the Presidentially-appointed inspectors general.

The Inspector General attended the ECIE/PCIE conference in March 2000. She was a member of an ECIE ad hoc committee addressing issues on auditor independence.

The Counsel participated fully in the Council of Counsels to Inspectors General and the National Association of Bar Counsel. As Assistant Inspector General for Investigations, he was active in the Association of Inspectors General for Investigations, and was one of two ECIE representatives on the PCIE Investigations Advisory Subcommittee of the Investigations Committee. He was the chair of a working group on developing the Qualitative Assessment Process for Investigations, a process similar to audit peer review. Additionally, he was an instructor for the Government Training Institute.

The Assistant Inspector General for Audits participated in the PCIE Government Performance and Results Act Group and the Office of Inspectors General Statistical Sampling Work Group.

The Assistant Inspector General for Audits attended the FY 1999 Financial Planning Committee (FPC) meeting in December 1999. The FPC consists of Agency financial and program managers and meets annually to discuss financial system planning and management techniques.

An OIG Auditor is the NLRB Recreation and Welfare Association Treasurer. The Association sponsors a variety of social and philanthropic activities for Agency employees. In addition to serving as the financial administrator, he helped coordinate activities including receptions for the kick-off of the Combined Federal Campaign, the new General Counsel, and a Cherry Blossom marathon.

The OIG Special Agent, as the Deputy Assistant Inspector General for Investigations, is the principal liaison officer to the federal law enforcement community. He is a member of the Liaison Officers Association, and currently serves on its executive board. The Association is composed of designated liaison officers of all federal law enforcement agencies as well as foreign police attaches. He is a member of the working group on Affirmative Civil Enforcement organized by the U. S. Attorneys Office in Baltimore.

The IG Act states that each inspector general shall give particular regard to the activities of the Comptroller General of the United States with a view toward avoiding duplication and ensuring effective coordination and cooperation. In March 2000, the Inspector General and Assistant Inspector General for Audits met with GAO Acting Associate Director of Health, Education, and Human Services Division, who has responsibility for audits of NLRB programs and activities.

The Inspector General requested that the office be informed of GAO reviews involving NLRB. GAO has one ongoing review which is utilizing NLRB information. The objective of the review is to determine the extent to which businesses with labor unrest are being inspected by the Occupational Safety and Health Administration.

As recommended in a 1992 GAO report, OIG developed a 5-year Strategic Plan for FYs 1994 - 1999. Subsequent feedback from the Office of Management and Budget and congressional committees indicated that an OIG could be part of the Agency strategic plan. The Agency updated its Strategic Plan this period, and the Inspector General decided to include the OIG in the Agency plan. The draft Agency Strategic Plan for FYs 2000 - 2006 includes a chapter for OIG.

In addition, the inspector general community initiated a project to develop a strategic plan. The Inspector General participated in the process to develop the plan and intends to adopt the final plan.

Certain information and statistics based on the activities accomplished during this period are required by section 5(a) of the IG Act to be included in the semiannual reports. These are set forth below:

(1),(2),(7) OIG did not identify any significant problems, abuses or deficiencies relating to the administration of programs. For the purpose of this section, we used the definition of significant as set forth in the Federal Managers' Financial Integrity Act.

(3) Corrective action has been completed on all significant recommendations which were described in the previous semiannual reports.

(4) No matters were referred to prosecutorial authorities. There were no prosecutions or convictions.

(5) No reports were made to the Chairman that information or assistance requested by the Inspector General was unreasonably refused or not provided.

(6) A listing by subject matter is located on page 21.

(8),(9) Two audit reports were issued during this period; the reports had no recommendations on questioned costs or funds that could be put to better use. See Tables 1 and 2.

(10) There are no audit reports issued before the commencement of the reporting period for which no management decision has been made by the end of the reporting period.

(11) No significant revised management decisions were made during the reporting period.

(12) There were no significant management decisions with which I am in disagreement.

Table 1    REPORTS WITH QUESTIONED COSTS

Table 2    REPORTS WITH RECOMMENDATIONS THAT FUNDS BE PUT TO BETTER USE