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November 4, 2008 DOL Home > About DOL > Annual Report 2004 > Strategic Goal 2 |
DOL Annual Report, Fiscal Year 2004 Strategic Goal 2: A Secure Workforce Promote the Economic Security of Workers and Families Protecting workers' wages and working conditions, providing unemployment compensation and other benefits when workers are unable to work, and retirement and health benefit security are central to the DOL mission. This strategic goal captures these priorities and consists of two outcome goals: Increase Compliance With Worker Protection Laws, which focuses on safeguarding employees' wages, working conditions, and union democracy and financial integrity; and Protect Worker Benefits, which deals with relief in the form of unemployment, disability, and pension and health care insurance benefits. Agencies supporting this strategic goal are the Employment and Training Administration (ETA), the Employment Standards Administration (ESA), the Employee Benefits Security Administration (EBSA), and the Pension Benefits Guaranty Corporation (PBGC). Outcome goals 2.1 and 2.2 contain six performance goals (see table below), of which two were achieved, two substantially achieved and two not achieved in FY 2004. The Department performed well, with significant progress in improving worker protection and union compliance, recovery of erroneous payment of unemployment benefits, improved effectiveness of pension and health benefit plan enforcement and workers' compensation program administration. Results for several performance indicators were shy of their targets but there were no major disappointments or reversals in our workforce security performance this past year.
The following charts illustrate DOL's strategic goal net costs in FY 2004, with A Secure Workforce shares set apart. The first allocates total Departmental costs of $56.676 billion; the second allocates an adjusted net cost of $11.102 billion that excludes major non-discretionary items associated with this goal.15 Net costs of this goal in FY 2003 (less Income Maintenance) were $1.969 billion. The decrease occurred in part because of relocation of the WIA Dislocated Worker and TAA programs from Goal 2 to Goal 1; together, these two programs cost approximately $2 billion annually.
The outcome goals and programs listed above, along with their results, costs, and future challenges are discussed in more detail on the following pages. 15The excluded costs are referred to as Income Maintenance unemployment benefit payments to individuals who are laid off or out of work and seeking employment ($41.424 billion) plus disability benefit payments to individuals who suffered injury or illness on the job ($4.150 billion). Outcome Goal 2.1 Increase Compliance with Worker Protection Laws In a global economy, the Employment Standard Administration's (ESA) primary challenge in building a competitive workforce is to ensure that protections for workers are appropriate for and keep pace with the changes occurring in the American workforce. Virtual workplaces, aging workers, more women and minorities in the workforce, immigration, organized labor, the growth of small businesses, and the ongoing shift from a manufacturing to a service economy will all be important factors as U.S. businesses strive to comply with worker protection laws in the future. Under the Fair Labor Standards Act, the Migrant and Seasonal Agricultural Worker Protection Act, the Family and Medical Leave Act and the Service Contract Act, ESA's Wage and Hour Division (WHD) administers standards for wages and working conditions: the minimum wage, overtime, youth employment, and field sanitation standards in the agriculture industry. Under the Davis-Bacon Act, WHD determines prevailing wages in the construction industry. The key to ensuring worker protections is to focus on industries and employers with the most persistent and serious violations; to quickly resolve employee complaints; and to ensure accuracy in established wage rates. ESA's Office of Labor-Management Standards (OLMS) ensures union transparency, financial integrity, and democracy by administering and enforcing the Labor-Management Reporting and Disclosure Act (LMRDA). OLMS responsibilities under the Act include compliance assistance; civil and criminal investigations and enforcement; union compliance audits; and reports/public disclosure administration. OLMS' strategies are aimed at improving timeliness and quality of union reports filed for public disclosure and strengthening LMRDA compliance through union audits and outreach efforts.
Net Cost of Programs
Results Summary DOL reached both of its union financial integrity targets. OLMS established a fraud baseline of nine percent of those unions filing reports under LMRDA; and the percentage of union reports meeting standards of acceptability increased in to 92 percent. Better union public disclosure reports resulted from agency compliance assistance efforts and increasing use of electronic reporting formats. Future Challenges Performance success in the wage determination program depends on upgrades in information technology. WHD is working to combine the DBA Wage Determination Generation and Automated Survey Distribution Systems into one automated data processing system that should greatly enhance the program's ability to obtain, store and distribute construction wage determinations. Protect Workers' Wages Covered American workplaces legally, fairly, and safely employ and compensate their workers. Indicators Reducing employer recidivism by increasing the percentage of prior violators who achieved and maintained FLSA compliance following a full FLSA investigation; Increasing compliance in industries with chronic violations; and Ensuring timely and accurate prevailing wage determinations. Program Perspective The key to ensuring worker protections is to focus on industries and employers with the most persistent and serious violations; to resolve employee complaints expeditiously; and to ensure that established wage rates are accurate. By focusing compliance efforts in low-wage industries like agriculture, health care, and garment manufacturing, WHD seeks to protect those low-wage workers most likely to be paid less than legally required or unsafely housed. By reducing repeat violations, WHD can achieve lasting compliance on behalf of many employees. WHD ensures responsiveness by reducing the time it takes to resolve employee complaints. Timely and accurate prevailing wage determinations encourage efficiency and help ensure government contract workers receive the wages to which they are entitled. A number of external factors influence WHD's program outcomes. As the supply of vulnerable immigrant workers increases, the potential for violations increases. Compliance levels in many low-wage industries are also heavily influenced by competitive pressures and by subcontracting arrangements in which smaller companies have little opportunity to influence market prices. Results, Analysis and Future Plans
WHD also reached its timely and accurate prevailing wage determinations targets, establishing a baseline of 1491 wage determination data submission forms processed per 1,000 hours, and issuing 86 percent (13 of 15) wage surveys within 60 days, against a target of 80 percent. WHD improved customer service responsiveness by updating complaint intake procedures, regular review of complaint inventories, streamlining procedures to ensure early contact with complainants, and through good fact development. WHD has established three key effective strategies to increase compliance in industries with a history of chronic FLSA violation: compliance assistance, enforcement and collaborative partnerships. In garment manufacturing, monitoring through unannounced visits, payroll record and timecard reviews, employee interviews have all proven effective. In the long-term care industry, compliance assistance, partnerships and enforcement have been effective in increasing FLSA compliance. Across the board, compliance assistance has been effective dissemination of industry-specific fact sheets and employee rights cards, face-to-face employer consultations, and entering into compliance partnerships with several major nursing homes. In the agricultural industry, targeted compliance assistance and compliance partnerships have worked especially well. A FY 2004 partnership with the Tennessee Farm Bureau accounts for the greatest increase of employers impacted by a compliance partnership, with just over 500,000 members. Over the last several years, the DBA wage determination program took steps to improve the accuracy and timeliness of prevailing wage determinations for the construction industry. Following OMB's PART review of the DBA wage determination program, WHD added timeliness and accuracy performance indicators the two aspects of the DBA wage survey program that significantly impact wage determination performance. WHD is using a new complaint indicator in FY 2005 and will concentrate on the number of days it takes to resolve violation complaints. This will prevent any unintentional emphasis on speed at the cost of finding and correcting violations. To reduce FLSA violation recidivism, WHD will promote long-term compliance among employers through detailed compliance agreements outlining agreed-upon steps for compliance; and reinvestigating cases where future compliance is uncertain. WHD will continue its transition to goals and measures that more fully capture compliance in a broad spectrum of low-wage industries. As a result, there will not be specific indicators for the health care and agriculture industries. However, WHD will continue its targeted compliance assistance programs and enforcement activities to promote housing and transportation compliance. Performance success in the wage determination program depends on upgrades in information technology. WHD is working to combine the DBA Wage Determination Generation and Automated Survey Distribution Systems into one automated data processing system. This software development will greatly enhance the program's ability to obtain, store and distribute construction wage determinations. Management Issues WHD has undertaken four program evaluations in FY 2004 focusing on: (1) identifying new compliance measures in low-wage industries; (2) integrating budget and performance information; (3) conducting a cost/benefit analysis of recommendations to update the Youth Employment Hazardous Occupations rules; and (4) an assessment of WHD compliance assistance efforts. WHD will undertake two new evaluations next year: 1) the development of models to employ common compliance strategies across low-wage industries; and 2) an evaluation of the agency's compliance assistance web information. In the spring of 2004, the Office of Inspector General issued a final report on WHD's Davis-Bacon Act wage determination program. A summary of the findings is included in Appendix 2 (Study 5). In the spring of 2003, WHD's Davis Bacon wage determination program was assessed through a Program Assessment Rating Tool (PART) review. The assessment found that the program did not demonstrate results. In response, WHD has developed overarching goals to ensure program performance improvements in determining and issuing prevailing wage rates with specific numeric targets. In addition, WHD contracted with an outside company to evaluate the Davis Bacon wage survey process.
Union Financial Integrity and Transparency Advance safeguards for union financial integrity and democracy and the transparency of union operations. Indicators Increasing union transparency. The percentage of union reports meeting standards of acceptability for public disclosure will increase to 75%. Program Perspective Results, Analysis and Future Plans Union Financial Integrity Union Transparency Management Issues Maintaining effective union outreach and a visible audit presence will be essential to increasing union financial integrity. Timely, accurate union financial reports are essential to promoting union democracy and financial integrity. Completeness and accuracy of union reports are markedly increasing as a result of compliance assistance efforts and increasing use of the electronic union annual reporting. Timely public disclosure reporting remains a continuing challenge in spite of OLMS' comprehensive program efforts to correct a persistent delinquent report problem. To address this challenge, DOL supports amendment of the LMRDA to authorize civil monetary penalties for late filing. Outcome Goal 2.2 Protect Worker Benefits Protecting the benefits earned and promised to U.S. workers is a central feature of DOL's secure workforce strategic goal. DOL helps increase the economic security of America's working families by temporary protecting wages for the unemployed; protecting private employee pension plans, health plans and other benefits plans against fraud and abuse; protecting Federal and certain other workers from the economic effects of work-related injuries and illness; and protecting against lost or interrupted pension payments of workers whose companies terminate their defined benefit plan. Three DOL agencies and one government corporation chaired by the Secretary of Labor create a more secure U.S. workforce by protecting worker benefits the Employment and Training Administration (ETA), the Employee Benefits Security Administration (EBSA), the Employment Standards Administration (ESA), and the Pension Benefit Guaranty Corporation (PBGC). ETA temporarily replaces the wages of the unemployed through the Unemployment Insurance (UI) program, which provides grants to State-operated programs and manages the Unemployment Trust Fund. ETA ensures that States' programs are administered efficiently according to Federal standards and requirements, and manages the trust fund to provide a buffer to volatile cycles in tax revenues and benefit claims. EBSA protects private employee pension plans, health plans and other benefits plans against fraud and abuse by enforcing Title I of the Employee Retirement Income Security Act of 1974, as amended (ERISA); through compliance assistance, and through education. Where there has been malfeasance, EBSA restores benefits and assets by bringing civil and criminal cases. ESA protects Federal and certain other workers from the economic effects
of work-related injuries and illness's through the Office of Workers' Compensation
Programs' (OWCP) four disability compensation programs. OWCP provides
wage replacement and cash benefits, medical treatment, vocational rehabilitation,
and other benefits to covered workers, their dependents and survivors. PBGC
protects the pension benefits of participants in defined benefit plans that
have been terminated, usually due to the sponsoring employer's bankruptcy,
by serving as both insurer and administrator. As an insurer, PBGC collects
insurance premiums from employers that sponsor insured pension plans. As
an administrator, PBGC pays monthly retirement benefits to the participants
in terminated plans.
Net Cost of Programs FY 2004 program costs decreased by approximately $11 billion, or 20%, from FY 2003. Unemployment Insurance program costs account for the entire decrease in costs and account for 93 percent of FY 2004 expenditures for this outcome goal. UI Program costs are largely driven by average weekly insured unemployment (AWIU) the average number of people filing claims for continuing UI benefits each week. The AWIU figure decreased from 3.646 million in FY 2003 to an estimated 3.167 million in FY 2004. UI benefits paid decreased from $54.0 billion in FY 2003 to an estimated $42.1 billion in FY 2004. The considerable decreased costs for Outcome Goal 2.2 were minimally offset by increased costs to ESA's Black Lung program. In FY 2004, the Special Benefits for Disabled Coal Miners was transferred to ESA from the Social Security Administration. The amount apportioned for this account in FY 2004 is $403 million.
Results Summary Meeting its performance goal, EBSA saw its ratios for successful civil and criminal cases improve. Success in the case ratio indicators demonstrates EBSA's improved selection and conduct of investigations. A successful closed civil investigation is one in which rightful assets are protected or returned to plans and participants. A successful criminal investigation is one that is referred for prosecution. While PBGC managed to improve its customer service score for participants in trusteed plans, it did not reach its target for improving customer service to plan sponsors. Future Challenges Other challenges for DOL's workforce compensation programs include increasing medical costs and a large expected influx of claimants. As general medical costs continue to rise in line with expanding medical technologies, the compensation programs' medical costs will also rise. DOL strives to ensure that the inflation rate for these medical costs increases more slowly than the comparable national healthcare rate. The number of Defense Base Act Longshore claims from injured civilian contractors in Iraq and Afghanistan is increasing, and could increase dramatically should the potentially large pool of Iraqi civilians employed by American contractors begin to file claims. PBGC continues to face an unprecedented influx of terminated plans. Meanwhile, participants' and practitioners' expectations for speed and accuracy of services continue to rise, specifically in the demand for electronic transactions and information. PBGC will identify opportunities to improve customer service in the face of an increased customer base that demands improved speed, accuracy, and information. Pay Unemployment Insurance Claims Accurately and Promptly Make timely and accurate benefit payments to unemployed workers, facilitate the reemployment of Unemployment Insurance (UI) claimants, and set up unemployment tax accounts promptly for new employers. Indicators Payment Accuracy: Establish for recovery at least 59% of the amount of estimated overpayments that the States detect; Facilitate Reemployment: A method for establishing an entered-employment rate for UI claimants was pilot tested in FY 2003, and a baseline will be established using pilot data; and Establish Tax Accounts Promptly: 82.2% of determinations about Unemployment Insurance tax liability of new employers will be made within 90 days of the end of the first quarter they become liable for the tax. Program Perspective Economic conditions and the resulting program workloads affect many aspects of UI performance. For example, when unemployment rises, more claims are filed, and UI payment timeliness generally declines. On the other hand, slower new business creation reduces the number of new employer tax accounts, and the timeliness of tax liability determinations generally goes up. Higher levels of claims and payments tend to increase the number/dollar amount of overpayments often temporarily outpacing detection and recovery efforts. Results, Analysis and Future Plans
The UI system performed extremely well in the face of high claims workloads. The number of beneficiaries, 8.7 million, was lower than in FY 2003 (10.3 million), but one million of them received over $4 billion in extended benefits mostly Temporary Extended Unemployment Compensation as well as regular benefits. Benefit payments totaled $40.8 billion, down from $53.3 billion in FY 2003. States maintained first payment and new employer status determinations timeliness at a high level and improved detection of overpayments. ETA continues to emphasize payment integrity. In March, 2004, ETA signed a memorandum of understanding with the Social Security Administration (SSA) to allow State Workforce Agencies (SWAs) and SSA to exchange data in real time. SWAs that have met the system security requirements and have established a data-sharing agreement will have access to SSA data to verify personal information, such as name, social security number, and date of birth for those applying for unemployment benefits. In August, the President signed a law giving States access to the National Directory of New Hires, an additional tool for swiftly detecting and preventing payments to claimants who have returned to work. For FY 2005, targets for all indicators will be raised. Management Issues In its FY 2004 report listing DOL's top management challenges, the Office of Inspector General (OIG) listed identity theft, UI overpayments, and State UI trust fund solvency. OIG recommended that ETA enhance investigative training for State UI personnel to focus on fraud prevention and detection. ETA provided funding to States to: (1) implement data exchanges with the Social Security Administration for the purpose of matching Social Security Numbers to identify false numbers; and (2) access data from other States to verify identities. ETA also provided States with a written alert suggesting action that States could take to combat identity theft problems. A recent OIG study found that the new hire detection method is better for establishing UI overpayments than the wage/UI benefit cross-match (Study 6 in Appendix 2). In response to OIG's recommendation, ETA provided funds and encouraged States to access their new hire directories and other State databases. In August 2004, the President signed into law a bill giving States access to the National Directory of New Hires, thereby removing a critical barrier to improved overpayment detection. ETA is pilot testing cross-matching of its Benefit Accuracy Measurement (BAM) investigation case database against State wage records to more completely detect overpayments. If this process proves cost-effective, it will be incorporated into the BAM methodology. OIG remains concerned that States' trust funds may not have adequate reserves to meet projected UI compensation demands. ETA has developed and regularly publishes various measures of State solvency to help inform and guide State decisions on tax rates. In the short term, the system loans funds to States that have encountered serious cash flow problems, thus enhancing UI's impact as an automatic economic stabilizer. DOL also commissioned a study, Internet Initial Claims Evaluation (Study 22 in Appendix 2) that evaluated service delivery; security; fraud and abuse controls; and cost effectiveness, and concluded that Internet initial claims filing is a convenient and cost-effective method of claims taking, and that there is no evidence that this method leads to increased erroneous payments or system security breaches. In its 2003 Program Assessment Rating Tool (PART) review, the Administration concluded that the UI program is effectively managed. Among recommendations was completion of efforts to reduce the overpayment rate. As noted above, the Department has made significant progress in this area. Provide for Secure Pension and Health Plans Enhance Pension and Health Benefit Security Indicator Achieve greater than a 25% ratio of criminal cases referred for prosecution to total criminal cases; and Participant Assistance Program Perspective EBSA has steadily improved its performance in the respective areas improving from a civil ratio of 46 percent in FY 1999 to 69 percent in FY 2004, a criminal ratio of 26 percent in FY 2001 to a 45 percent in FY 2004 and a customer satisfaction baseline of 53 in FY 2001 to a satisfaction score of 62 in FY 2004. EBSA oversees benefit security for nearly seven million plans, 150 million participants and beneficiaries, and in excess of $4 trillion in assets. Externalities, such as the economy and tax policy, have a significant impact on whether employers opt to offer benefits, and whether employees choose to participate and to what extent.
Results, Analysis, Future Plans
In addition to long-term targets for our civil and criminal ratios, we have added annual targets to reflect our success with respect to national enforcement initiatives, consistent with national priorities, which may change from year-to-year, taking into account new enforcement problems. EBSA has worked with Gallup to refine the long-term target consistent with other industry standards and experience. EBSA also added a internal compliance assistance measure that will demonstrate success in voluntary compliance programs such as the Voluntary Fiduciary Correction Program and our Delinquent Filer Voluntary Correction Program. EBSA has also developed an efficiency measure that will provide, as a ratio, costs per enforcement result.
Management Issues EBSA has acted on recommendations from its PART assessments in FY 2004 and FY 2005 by establishing proactive evaluation initiatives and a regulatory review program. Specifically, EBSA is conducting a follow-up of its FY 1995 audit quality study to determine the level of compliance of pension plan audits to professional accounting standards. In FY 2005, EBSA expects results from the investigative portion of a baseline compliance study being conducted to measure ERISA compliance in contributory pension plans, focusing on the timeliness and remittance of employee contributions. In FY 2004, OIG completed audits of EBSA's participant and compliance assistance program and of the process used by EBSA to identify and correct substandard audits of employee benefit plans (Studies 2 and 3 in Appendix 2). Also, EBSA concluded program evaluations of its participant assistance and enforcement programs with the assistance of The Gallup Organization and Mathematica Policy Research, respectively (Studies 16 and 17 in Appendix 2). In FY 2005 Gallup will perform a follow-up study of EBSA's participant assistance program. EBSA is establishing a regulatory review program that will: (a) set forth a process for identifying initiatives for review, (b) provide for cost and benefit evaluation of identified regulations and exemptions and, (c) explore modifying or eliminating those rules for which costs and administrative burdens outweigh benefits. EBSA and DOL's Assistant Secretary for Policy are developing a Departmental Federal Register notice to seek public input on which pension and benefit regulations should be reviewed. Reduce the Consequences of Work-Related Injuries Minimize the human, social, and financial impact of work-related injuries for workers and their families. Indicators For FECA cases of All Other Governmental Agencies, reduce the lost production days rate (LPD per 100 employees) by 1% from the FY 2003 baseline; Increase FECA Vocational Rehabilitation placements with new employers for injured USPS employees by 15% over FY 2002; Through use of Periodic Roll Management, produce $38 million in cumulative (FY 2003-FY 2004) first-year savings in the FECA program; The trend in the indexed cost per case of FECA cases receiving medical treatment will remain below the comparable measure for nationwide health care costs; Meet 60% of the annual targets for five communications performance areas; Reduce by 4% over the FY 2002 established baseline the average time required to resolve disputed issues in Longshore and Harbor Worker's Compensation Program contested cases; Increase by 8% over the FY 2001 established baseline the percentage of Black Lung benefit claims filed under the revised regulations for which, following an eligibility decision by the district director, there are no requests for further action from any party pending one year after receipt of the claim; 77% of Initial Claims for benefits in the Energy Program; and 77% of Final Decisions in the Energy Program are processed within standard timeframes Program Perspective
Results, Analysis and Future Plans Returning Injured Federal Employees to Work The majority of injured workers who return to work do so with their previous employers, but that has been made more difficult with declining employment levels at USPS. So, beginning in FY 2003, OWCP began emphasizing placement of injured postal workers with new employers. In FY 2004 OWCP reached the target for placing USPS employees who participate in the vocational rehabilitation program into new jobs, placing 62 USPS workers compared to a target of 56. The emphasis on assistance to Postal Service employees will continue in FY 2005. Reducing Program Expenses DOL also reached its target of keeping the inflation of Federal Employees' Compensation Act (FECA) medical costs below the Nation's rate of healthcare inflation (according to the Milliman USA Health Cost Index, which is updated quarterly). FECA experienced a medical cost inflation of 2.4 percent, while the Milliman Index predicts a national rate of healthcare inflation of 8.8 percent. Responding to recent medical care cost increases, in August 2003 FECA converted medical bill processing from district offices to a centralized operation under contract to Lockheed Martin. More stringent bill reviews under this system are expected to further reduce average FECA medical costs. 16In FY 2004, OWCP changed the way it measures LPD, and thereby changed its FY 2003 baseline data for the USPS and all other government agencies' lost production days rate measures. LPD's are now measured in real-time rather than with accumulated data, as they were in the past. Please see Appendix 1 for the changes to the baseline data. Customer Service For FY 2005, OWCP will have a more ambitious target for communications with customers: reaching four of the five sub-targets. Strategies are in place to improve communications with customers through greater Internet access for claims purposes. The indicator for timely Longshore and Harbor Worker's dispute resolution is intended to measure OWCP's success in serving as mediator injured workers and their employers. To continue the positive trend in this indicator, OWCP will provide claims staff with further training to improve mediation skills. The revised regulations for Black Lung benefit claims did not change eligibility requirements, but were designed to produce faster and fairer final benefit determinations. The result has been an increase in the number of stakeholders who accept the district director's initial decision and decide not to pursue the claim further. The Energy Program's success in efficient initial claims processing and final decisions results from attention to customer communications, accurate claims processing, and automated data processing. We are committed to improving the employment verification process by obtaining access to former worker program records, sharing more data for dual claims and enhancing working relationships with DOE facility contacts. Based on performance that far exceeded targets, the Energy Program has set more ambitious targets of seven percent increases for both indicators in FY 2005. Management Issues A FY 2003 Office of Inspector General financial audit found ineffective medical evidence controls (Study 4 in Appendix 2). To remedy this, in December 2004 DOL will begin using an automated tracking mechanism that will alert claims staff when medical evaluations are due. ICF Consulting recently completed a broad review of the FECA program's effectiveness (Study 18 in Appendix 2). OWCP is currently reviewing its recommendations. Provisions which create disincentives for returning to work as opposed to remaining on full disability are built into the Federal Employees' Compensation Act, which has not been significantly amended in 30 years. DOL has developed a legislative proposal which would reform these provisions. The number of Defense Base Act Longshore claims from injured civilian contractors in Iraq and Afghanistan is increasing, and this trend is projected to continue. There is also a potentially very large pool of Iraqi civilians employed by American contractors who may not be reporting injuries or may not be aware they are entitled to coverage. Should this group begin to file claims, Longshore cases could increase dramatically. Provide Timely and Responsive Services to Customers PBGC will improve customer satisfaction according to the American Customer Satisfaction Index (ACSI). Indicators Achieve an ACSI of 77 for participants in trusteed plans who have contacted PBGC for assistance Program Perspective Results, Analysis and Future Plans Overall, the scores for components that PBGC has tracked in the past three years are all performing very well. By using the ACSI, PBGC can identify the service elements that have a greater impact on customer satisfaction. For example, there is a direct correlation between satisfaction and customer complaints, meaning that as satisfaction increases, the rate of complaints would likely decrease. PBGC experienced a significant decrease in complaints in 2004 over the previous two years through improved responsiveness to customers. Management Issues
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