April 1, 2006 - September 30, 2006
October 27, 2006
The Honorable Naomi C. Earp
Chair
Equal Employment Opportunity Commission
Washington, D.C. 20507
Dear Madam Chair:
The Office of Inspector General’s (OIG) Semiannual Report to Congress, summarizing our activities for the six-month period of April 1, 2006 through September 30, 2006, is provided for your review. The Inspector General Act of 1978, as amended, Public Law 95-451, Section 5(B), requires that you submit this report to the Congress within 30 days of receipt.
During this reporting period, the OIG issued five audit and evaluation reports, completed six investigations, and received 310 investigative inquiries. Highlights include assessment of the National Contact Center, information security, and the adequacy of internal controls. Important ongoing work includes determining the reliability of key EEOC performance data; assessing Agency compliance with the Federal Manager’s Financial Integrity Act; auditing the Agency’s FY 2006 Financial Statement, and investigating destruction of records, false claims against the government, misuse of the Agency seal, and falsification of government records. The report also includes information on the challenges confronting management as the Agency proceeds in its repositioning initiatives.
The Office of Inspector General is dedicated to promoting government integrity, accountability, transparency and excellence. OIG staff thanks EEOC employees for their continued cooperation and support of our mission to prevent and detect fraud, waste and abuse within the Agency.
Sincerely,
Aletha L. Brown
Inspector General
Introduction
The Equal Employment Opportunity Commission
The Office of Inspector General
Summary of Significant Management Challenges
The Audit and Evaluation Program
Completed Projects
Ongoing Audit and Evaluation Projects
Other Audit and Evaluation Activities
The Investigative Program
Investigative Inquiries
Completed Investigations
Ongoing Investigative Activity
Appendices
Appendix I OIG Audit and Evaluation Reports
Appendix II Index of Reporting Requirements
Appendix III Single Audit Act Reports
This report summarizes significant audit, evaluation and investigation activities of the Office of Inspector General (OIG) during the six-month period ending September 30, 2006. The report also summarizes the challenges facing management in implementing Agency repositioning.
OIG completed audit, evaluation and investigative projects including:
Work in progress includes: assessing Agency compliance with the Federal Manager’s Financial Integrity Act; auditing the Agency’s FY 2006 Financial Statement; and assessing the reliability of key EEOC performance data. OIG’s ongoing investigations involve destructions of records, false claims against the government, misuse of the Agency seal, prohibited personnel practices, conflict of interest, impersonation of a federal official, sexual harassment, and falsification of government records.
The EEOC is the federal agency responsible for enforcement of: Title VII of the Civil Rights Act of 1964, as amended; the Equal Pay Act of 1963; the Age Discrimination in Employment Act of 1967 (ADEA); in the Federal sector only, section 501 of the Rehabilitation Act of 1973; Title I of the Americans with Disabilities Act of 1990 (ADA); and the Civil Rights Act of 1991. These statutes prohibit employment discrimination based on race, sex, color, religion, national origin, age, or disability. The EEOC is also responsible for carrying out Executive Order 12067, which promotes coordination and minimizes conflict and duplication among Federal agencies that administer statutes or regulations involving employment discrimination.
EEOC is a bipartisan Commission comprised of five presidentially appointed members, including the Chair, Vice Chair and three Commissioners. The Chair is responsible for the administration and implementation of policy for the Commission and for the financial management and organizational development of the Commission. The Vice Chair and the Commissioners equally participate in the development and approval of the policies of the Commission, issue charges of discrimination where appropriate, and authorize the filing of lawsuits. Additionally, the President appoints a General Counsel to support the Commission and provide direction, coordination, and supervision to EEOC’s litigation program.
The United States Congress established an Office of Inspector General (OIG) at the EEOC through the 1988 amendment of the Inspector General Act of 1978, which expanded authority to independent agencies and federal entities to create Offices of Inspector General. OIG’s primary responsibility is to assist the EEOC by ensuring integrity, efficiency, and accountability in the Agency’s programs to enforce laws against discrimination in the workplace. Specifically, OIG supports the Agency by carrying out its mandate to independently and objectively conduct and supervise audits, evaluations and investigations; prevent and detect fraud, waste, and abuse; and promote economy and efficiency in programs and operations. The OIG keeps EEOC’s Chair and the Congress fully and currently informed about problems, recommends corrective action(s), and monitors the EEOC’s progress in implementing such action.
The OIG is under the supervision of the Inspector General (IG), who provides overall direction, coordination, and leadership to staff. The OIG includes a deputy inspector general, an audit and evaluation staff, an investigative staff, an independent counsel, and an administrative staff. The Deputy Inspector General serves as alter ego of the Inspector General and has the responsibility for providing overall program guidance, direction and supervision to audit, evaluation and investigative staffs. The audit program provides assurance to the Chair and Congress that EEOC programs are working efficiently and effectively. The audit staff conducts performance and financial audits, as well as special reviews and evaluations. These audits focus on management controls, administrative and program operations, transaction processing and financial and other information systems. Special reviews and evaluations assess program performance and information security and consider the implications of EEOC programs, operations and policies.
The mission of the investigative program is to perform investigative activities related to the integrity of the EEOC’s programs. Most of OIG’s investigations focus on violations of law or misconduct by Agency employees, as well as, allegations of irregularities or abuses in operations and programs. When needed, OIG’s investigators work in concert with other law enforcement entities. Over half of the investigative inquiries result from employees and the public calling OIG’s 24-hour telephone (hotline) to report wrongdoing. A significant amount of these calls concern EEOC’s discrimination complaint process and are referred to the appropriate program office.
The following subsections summarize issues the Inspector General considers the most serious management challenges facing the Equal Employment Opportunity Commission. These matters require the commitment of significant Agency resources, sound decision-making by the leadership, and continued oversight by the Office of Inspector General.
Change in EEOC Management
Effective September 1, 2006, Naomi C. Earp was appointed by President George W. Bush to the position of Chair of the Equal Employment Opportunity Commission. Formerly, she served as the Vice Chair of the Commission. Among the management challenges confronting the Chair are issues of declining budget, Headquarters and Field Office repositioning, and decisions related to the National Contact Center.
Chair Earp is faced with ensuring that the Agency’s limited resources are used in the most effective and efficient manner to deter, detect, and litigate violations of the Nation’s civil rights laws. The U.S. Senate appropriators have taken the extraordinary step of identifying in the language of their committee report specific uses for the Agency’s FY 2007 funds. The new Chair has the challenge of rebuilding the confidence of congressional appropriators in the leadership and judgment of the EEOC to ensure adequate funding of the Agency.
Reorganization of EEOC Headquarters’ Operation
Planning for EEOC Headquarters’ reorganization is underway. Efforts towards reorganization include an analysis of options, in consultation with the General Services Administration, for the Headquarters building lease and conduct of an early retirement/buy-out program during the third quarter of FY 2006.
On May 18, 2006, former EEOC Chair Cari Dominguez announced that the Office of Personnel Management and the Office of Management and Budget gave EEOC authority to offer “early out” and “buy out” opportunities to retirement-eligible employees. This program was undertaken to initiate a shift of resources from Headquarters to the field, where it is most needed. The Chair’s long-range goal was to reduce Headquarters by 20 percent or 100 employees. This effort resulted in the retirement of 33 Headquarters employees and 48 field employees by June 30, 2006.
The Headquarters’ building lease expires in 2008, and it will be necessary to fund either relocation and build out, or significant remodeling of the current space (consolidate from ten to seven floors) in fiscal years 2007 and 2008. The space build-out decision includes considering the relocation of the information technology hardware, software and communications central operations from Headquarters to a shared services location to reduce the overall cost of operations and the risks associated with the current downtown Washington D.C. location.
Cost considerations for the Headquarters building lease are critical. Newly appointed Chair Naomi Earp, the Commission, and management must be prepared to make the Agency’s largest ever investment decision which will affect EEOC’s budget for the next decade. The Office of Inspector General will review the draft analysis and recommendation which will be prepared by the Office of Chief Financial Officer during the first quarter of fiscal year 2007. A decision on the lease should be made by January 2007.
Repositioning of Agency’s Field Structure
The process of repositioning EEOC’s field structure led to reducing the number of District Offices from 23 to 15, enlarging many of the districts and reassigning 15 directors and 15 regional attorneys to these offices, and realigning administrative, human resources and budget functions to support this structure. No offices were closed and no employees lost their jobs. The current structure is 15 District offices, 9 Field Offices, 15 Area Offices, and 14 Local Offices. Two of the Local Offices are new offices established to respond to the growing population of workers in Mobile, Alabama and Las Vegas, Nevada. Appointments to most of the senior positions were made during the reporting period.
The Agency’s field structure requires evaluation to determine its impact on staffing/workload and the delivery of core services to the public. Evaluation may also determine cost savings attributable to the repositioning and identify opportunities to create efficiencies that may result from the current field structure, such as centralization of administrative, human resources and budget functions.
National Contact Center
The Office of Inspector General issued its report on the Evaluation of the National Contact Center (NCC) Pilot on June 29, 2006. OIG found that the NCC “has the potential to make a significant contribution to the EEOC; however, as presently operated, it is not effective.” OIG reported inefficiencies due to lack of call volume, poor data capture, and deficient communications between the NCC and EEOC. NCC contract costs were $1.8 million in FY 2006. Estimated FY 2007 contract costs are $2.6 million.
Congress has shown much interest in the call center and its impact on the Agency’s ability to deliver service to the public. The House Appropriations Committee requested that the EEOC vote on extending the pilot and postpone consideration of making the center permanent until the National Academy of Public Administration (NAPA) could complete an evaluation to supplement the OIG study of the call center. On July 13, 2006, the Commission voted 3-2 to extend the NCC contract with Pearson Government Solutions for one year to September 2007, during which time NAPA will conduct its evaluation. Shortly thereafter, the Senate Committee on Appropriations’ issued report language, accompanying Committee passage of the appropriations bill, eliminating funding for the call center, citing the findings of the Inspector General evaluation. Differences in the House and Senate Appropriation Committee reports will be resolved by a conference committee after Senate passage of the legislation and finalization of the Senate report language.
Phase I of the NAPA evaluation began in September 2006 and includes assessment of the plan to achieve full implementation of NCC, and estimation of the costs of replicating NCC operations within EEOC. In light of the NCC report issued by the OIG in June 2006 and the time required to implement the recommendations accepted by the Commission to improve the NCC, the benefits to be derived from the existing and other subsequent study may not justify the costs associated with Phase II of the work. The House Appropriations Committee report for FY 2007 did not provide funding for the Phase I or Phase II. Agency officials and U.S. Senate Committee on Appropriations members are concerned about the EEOC’s ability to fund Phase II in FY 2007.
The Audit and Evaluation Program supports OIG’s strategic goal to improve the economy, efficiency, and effectiveness of EEOC programs, operations, and activities.
Independent Evaluation of the National Contact Center (OIG Report Number 2005-11-AMR)
In 2004, the Equal Employment Opportunity Commission established a National Contact Center (NCC) to accomplish three objectives: upgrading customer service; improving human capital effectiveness, and delivering accurate and consistent service. On June 29, 2006, the OIG issued an evaluation of the NCC. OIG oversaw the evaluation, performed by Job Performance Systems, Inc. (JPS), of Alexandria, Virginia.
Data gathering and analysis included: review of background documents; interviews at EEOC Headquarters, seven Field Offices, and the NCC; focus groups and surveys of field personnel; documentation of the NCC's work processes and the technology used to support them; review of a variety of metrics; remote call monitoring; and observations about Customer Service Representatives.
The JPS Team stated that the NCC has the potential to make a significant contribution to the EEOC; however, as presently operated, it is not effective. Key findings and conclusions are that:
Therefore, the JPS team recommended that the EEOC continue with the NCC only if significant changes are made to:
At the July 2006 Commission meeting, the Chair and the Director of the Office of Field Programs generally endorsed the report’s recommendations. At the same meeting, the Commission voted to extend its National Contact Center contract with Pearson Government Solutions for one year through September 2007. NCC contract costs were $1.8 million in FY 2006. Estimated FY 2007 contract costs are $2.6 million.
Independent Evaluation of the Agency’s Compliance with the Federal Information Security Management Act (FISMA) (OIG Report Number 2006-06-AEP)
To ensure compliance with the E-Government Act of 2002 (Pub. L. No. 107-347) and other federal guidelines, the Office of Inspector General contracted with Richard S. Carson & Associates, Inc. (Carson), to conduct an independent evaluation of the EEOC’s information security program and posture. The independent evaluation identified several information security program weaknesses that showed little progress toward remediation and/or did not adhere to Office of Management and Budget policy (OMB).
It is OIG’s opinion that the combination of these weaknesses resulted in a significant deficiency in EEOC’s Information Security Program. These major weaknesses are:
The Office of Technology generally concurred with the report findings and recommendations. However, the Office of Information Technology disagreed with the “significant deficiency” determination.
Office of Management and Budget Memorandum 06-16: Protection of Sensitive Agency Information (OIG Report Number 2006-08-AEP)
Following numerous incidents involving the compromise or loss of sensitive personal information by federal agencies, the Office of Management and Budget (OMB) issued memorandum M-06-16, on June 23, 2006. It requires agencies to take certain actions to ensure that safeguards are in place and appropriately reviewed within 45 days (August 7, 2006) from the issuance of the memorandum. OMB asked the Inspectors General community to review these items/actions to ensure that federal agencies are properly safeguarding the information the American taxpayer has entrusted to them.
We found that the Agency took the following steps to protect sensitive personal information:
OIG also found that the Agency needs to improve:
FY 2006 Review of Internal Controls (OIG Report Number 2006-02-FIN)
The Office of Inspector General contracted with Kearney & Co. CPAs to evaluate the adequacy of internal controls relating to the Agency’s significant financial cycles including payroll, time and attendance, cost reporting, and the State and Local Programs. Kearney concluded that overall, EEOC’s internal control structure is well designed; operating effectively, appropriately updated to meet changing conditions, and provides reasonable assurance that the objectives of the Agency are being achieved. No material weaknesses were identified.
The Agency concurred with the report’s recommendations for EEOC to:
Review of the Equal Employment Opportunity Commission Katrina FEMA Mission Assignment (OIG Report Number OIG-SP-003)
At the request of the Department of Homeland Security’s Office of Inspector General, OIG assessed how well the Federal Emergency Management Agency’s (FEMA) Mission Assignment process worked at EEOC during the Katrina disaster relief effort. A Mission Assignment is a work order issued by FEMA to another Federal agency which directs completion by that agency of a specific task. FEMA issued a Mission Assignment to the EEOC for $200,000 to augment the FEMA response to the Hurricane Katrina disaster.
Our September 15, 2006 assessment provided the following key observations from our data gathering (including a survey of the EEOC’s FEMA volunteers):
FY 2006 Financial Statement Audit of the EEOC OIG contracted with Cotton & Co. LLP to perform the financial statement audit of the EEOC. This audit is required by the Accountability of Tax Dollars Act of 2002. Field work is currently in progress. It is expected that the audit opinion will be issued in time to meet the reporting deadline of November 15, 2006 and for inclusion in the Agency’s 2006 Performance and Accountability Report. Additionally, shortly after the financial statement audit is issued, OIG will issue a Management Letter Report identifying any internal control weaknesses found.
Assessment of EEOC’s Performance and Results Reporting (OIG Report Number 2005-02-AMR) In FY 2005, OIG began a data reliability assessment project covering selected Agency performance data. Two factors have caused a revision in project schedule—OIG oversaw an independent assessment of EEOC’s National Contact Center (oversight completed in July 2006) and the data provided to OIG contained much unusable information, causing unanticipated work by the Evaluator. Data gathering and analysis were complete during this reporting period. The issuance of draft and final reports will occur in the next reporting period.
Agency Compliance with the Federal Manager’s Financial Integrity Act (FMFIA) (OIG Report Number 2006-09-AIC)
The purpose of OIG’s independent assessment is to show if the Agency’s management control evaluation was conducted in accordance with OMB’s standards. EEOC Order 195.001, Internal Control Systems requires OIG to annually provide the Chair a written advisory on whether EEOC’s management control evaluation process complied with OMB guidelines. To make this determination, OIG is reviewing:
It is expected that the letter to the Chair will be issued by November 14, 2006 to meet the reporting deadline of November 15, 2006 and for inclusion in the Agency’s 2006 Performance and Accountability Report.
Review of Single Audit Act Reports
During the reporting period, OIG reviewed 34 audit reports issued by public accounting firms concerning Fair Employment Practices Agencies (FEPAs) that have work-sharing agreements with EEOC. There were no audit findings directed to FEPAs which were related to EEOC funds (See Appendix III). The Single Audit Act of 1984 requires recipients of federal funds to arrange for audits of their activities. Federal agencies that award these funds must receive annual audit reports to determine whether prompt and appropriate corrective action has been taken in response to audit findings.
Program Assessment Rating Tool (PART) Review
The Agency underwent its first PART review during the spring 2006. OMB has not officially released the Agency’s PART ratings nor posted them to their website. EEOC managers anticipate that the Agency will receive a rating of “Results Not Demonstrated” since the Agency did not collect enough data to support its performance goals. A “Results Not Demonstrated” rating is one that requires timely improvement. Once the Agency’s results are released, the Agency will be challenged to meet the requirements of an OMB developed program improvement plan to improve the Agency’s PART rating.
Audit Follow-Up
As required by Section 5(a)(3) of the Inspector General Act of 1978, as amended, semiannual reports shall provide the status of each significant recommendation previously reported where corrective action has been completed. OIG has no reports with recommendations previously reported to which corrective action has not been completed. Section 5(a)(1) of the Inspector General Act of 1978, as amended, requires that semiannual reports shall include a summary of each audit report issued before the commencement of the reporting period for which no management decision has been made by the end of the reporting period. OIG has no audit or evaluation reports that were issued before commencement of the reporting period for which no management decision has been made by the end of the reporting period.
The Investigation Program supports OIG’s strategic goal to focus limited investigative resources on issues that represent the greatest risk and offer the maximum opportunity to detect and prevent fraud, waste and abuse in EEOC programs and operations. OIG received 310 inquiries in the reporting period.
Number of Investigative Inquiries Received April 1 – September 30, 2006
| Type of Inquiry | Number of Investigative Inquiries Received April 1- September 30, 2006 |
|---|---|
| Charge Processing and Potential Charges (Title VII) | 159 |
| Other Statutes | 74 |
| Theft (including lost or missing IDs) | 59 |
| Backgrounds of Former and Current EEOC Employees | 8 |
| Fraud | 5 |
| Other Criminal Violations | 3 |
| Ethics Violation | 1 |
| Mismanagement | 1 |
| TOTALS | 310 |
Security Breach/Information Loss
OIG conducted an investigation into an allegation that, after the former New Orleans Office was vacated due to Hurricane Katrina, case files and other personal information, including confidential information, had been left open to public access. An OIG Agent traveled to New Orleans, securing the old office space and data. The data and other items from the old office were released to Agency Officials for appropriate disposal and transportation from the site.
Minority Publication Fraud Scheme Task Force
OIG Investigators participated in the investigation of a Minority Publication Fraud Scheme which led to the conviction of an individual for violations of wire fraud, tax evasion, and mail fraud. The individual solicited businesses to pay for advertisements in nonexistent publications. In doing so, the individual used material misrepresentations and concealment of material facts. The individual represented that the businesses were required by the EEOC to advertise in publications. In fact, there is no EEOC requirement that companies advertise in publications.
Misuse of Government Travel Card
OIG completed an investigation of an allegation that an Agency employee had misused the Government Travel Card prior to his retirement from the Agency. A review of the material facts indicated that the individuals did misuse the travel card. However, based on prosecutorial guidelines, the violation did not rise to a level to warrant referral for prosecution. The matter was referred back to the Government Card Provider for collection. An audit of travel card issues is planned for FY 2007.
Willful Destruction of Government Documents
OIG completed an investigation of the knowing and willful destruction of Government documents required for legal proceedings. OIG determined there was no willful and knowing act to destroy Government documents. The OIG found all parties failed to act in preserving the documents. However, no criminal violations were found.
Investigation of Time & Attendance Fraud
OIG completed an investigation of alleged violations of time and attendance falsification by management officials for employees working in remote locations and outside the location commuting area. OIG found no evidence regarding falsification of time and attendance records.
Inappropriate Behavior and Disclosure of Confidential Information
The Office of Inspector General completed the investigation of an allegation that an EEOC investigator sexually harassed a charging party. The charging party accused the investigator of making inappropriate comments to her, and disclosing confidential information regarding her EEOC charge to the public. When asked to provide evidence to support the claim, the charging party refused to disclose the information to the OIG. While investigating the matter, OIG Agents determined that the investigator had been disciplined for the inappropriate conduct by the Field Office management. Because of the charging party’s refusal to cooperate with the OIG investigation, OIG concluded its investigation of this matter due to insufficient evidence.
OIG is investigating allegations of false claims against the government, misuse of the Agency seal, prohibited personnel practices, conflict of interest, impersonation of a federal official, sexual harassment, and falsification of government records.
Frequent Telework Pilot Program
The OIG successfully concluded the implementation of its Frequent Telework Pilot Program. The frequent telework program required selecting staff to work at an alternate worksite for two or more days per week to determine if frequent telework could result in a reduction of OIG real estate costs. OIG found no loss in productivity or efficiency during the Pilot. In the next reporting period, OIG will issue a report with a recommendation on whether EEOC could reduce OIG real estate space requirements based upon use of frequent telework when EEOC obtains a new lease in 2008.
PCIE/ECIE Award for Audit and Inspection Excellence
The Audit and Inspection Team: the four person team (two auditors, a management analyst, and an evaluator) was selected for an ECIE Group Award for Excellence. The Audit and Inspection Team members have devised a support system whereby projects receive the benefit of each member's expertise and shared commitment to ensure success. It is an approach that the team itself developed and includes project planning, implementation, selected fieldwork and quality assurance. In the last year, the team was responsible for issuing nine audit and evaluation products.
Career Development and Internship Program for Historically Black Colleges and Universities (HBCUs)
The OIG is currently in the process of developing policies and procedures for implementing the Office of Inspector General Career Development and Internship Program. Completion is scheduled for first quarter fiscal year 2007. OIG’s goals and objectives are to:
Professional Development Activities
OIG participated in the President’s Council on Integrity and Efficiency and Executive Council on Integrity and Efficiency activities and completed formal courses that included:
The Inspector General served on leadership panels at courses offered by the Federal Executive Institute and the Inspector General School of Management.
APPENDIX I – FINAL OIG AUDIT AND EVALUATION REPORTS
| Report Title | OIG Report Number | Date Issued | Questioned Costs | Funds Put To Better Use | Unsupported Costs |
|---|---|---|---|---|---|
| Independent Evaluation of the National Contact Center | 2005-11-AMR | 06/29/06 | $0 | $0 | $0 |
| EEOC’s Katrina FEMA Mission | 2006-003- SP | 09/15/06 | 0 | 0 | 0 |
| Independent Evaluation of the Agency’s Compliance with FISMA | 2006-06-AEP | 09/22/06 | 0 | 0 | 0 |
| FY 2006 Review of Internal Controls | 2006-02-FIN | 09/29/06 | 0 | 0 | 0 |
| Protection of Sensitive Agency Information | 2006-08-AEP | 09/30/06 | 0 | 0 | 0 |
| Totals | $0 | $0 | $0 |
APPENDIX – II – FINAL OIG AUDIT AND EVALUATION REPORTS
| IG ACT CITE | REPORTING REQUIREMENTS | PAGE |
|---|---|---|
| Section 4 (a)(2) | Review of Legislation and Regulations | N/A |
| Section 5 (a)(1) | Significant Problems, Abuses and Deficiencies | 6-13 |
| Section 5 (a)(2) | Recommendations With Respect to Significant Problems Abuses and Deficiencies | 6-9 |
| Section 5 (a)(3) | Significant Recommendations Included in Previous Reports on Which Corrective Action Has Not Been Completed | N/A |
| Section 5 (a)(4) | Matters Referred to Prosecutive Authorities | N/A |
| Section 5 (a)(5) | Summary of Instances Where Information Was Refused | N/A |
| Section 5 (a)(6) | List of Audit Reports | 16 |
| Section 5 (a)(7) | Summary of Significant Reports | 6-9 |
| Section 5 (a)(8) | Questioned and Unsupported Costs | N/A |
| Section 5 (a)(9) | Recommendations That Funds Be Put to Better Use | N/A |
| Section 5 (a)(10) | Summary of Audit Reports Issued Before the Commencement of the Reporting Period for Which No Management Decision Has been Made | N/A |
| Section 5 (a)(11) | Significant Management Decisions That Were Revised During the Reporting Period | N/A |
| Section 5 (a)(12) | Significant Management Decisions With Which the OIG Disagreed | N/A |
APPENDIX III – SINGLE AUDIT ACT REPORTS
| The State of Georgia, June 30, 2005 | The State of New Hampshire, June 30, 2005 |
| The State of Kentucky, June 30, 2005 | The Government of the District of Columbia, June 30, 2005 |
| The State of Oregon, June 30, 2005 | The State of Pennsylvania, June 30, 2005 |
| The State of Maine, June 30, 2005 | The State of Iowa, June 30, 2005 |
| The State of Washington, June 30, 2005 | The State of Minnesota, June 30, 2005 |
| The State of New Jersey, June 30, 2004 | The State of Vermont, June 30, 2005 |
| The State of Delaware, June 30, 2005 | The Fond Du Lac Bank of Lake Superior Chippewa, September 30, 2005 |
| The Commonwealth of Virginia, June 30, 2005 | The State of Florida, June 30, 2005 |
| The State of Missouri, June 30, 2005 | The Commonwealth of Massachusetts, June 30, 2005 |
| The State of North Carolina, June 30, 2005 | The State of California, June 30, 2005 |
| The State of Nebraska, June 30, 2005 | The State of Oklahoma, June 30, 2005 |
| The State of Rhode Island and Providence Plantations, June 30, 2005 | The State of West Virginia, June 30, 2005 |
| The State of Nebraska, June 30, 2004 | The State of Tennessee, June 30, 2005 |
| The State of Arizona, June 30, 2005 | The State of Colorado, June 30, 2005 |
| The White Mountain Apache Tribe, April 30, 2004 | The State of Nevada, June 30, 2005 |
| The State of Montana, June 30, 2005 | The Chippewa Cree Tribe, September 30, 2004 |
| The State of Wisconsin, June 30, 2005 | The State of Connecticut, June 30, 2004 |
To report suspected fraud, waste and abuse
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