Questions for the Record Related to Military Compensation
Gao ID: GAO-10-803R June 3, 2010GAO testified before a Congressional subcommittee on April 28, 2010, to discuss current issues related to military compensation. This letter responds questions for the record from the hearing. (1) Is the ECI an appropriate index to use to adjust military basic pay rates annually? If not, is there a benchmark that is more appropriate? (2) Please explain what the impact on the Defense budget would be if Congress directed an increase in the pay raise by one percent, or half a percent without offsets. (3) Is there a better metric than the ECI to gauge what an annual pay raise should be? (4) Does the current pay table need adjustment? (5) What do you think the effect of reducing the requirement for entitlement to retired pay below 20 years would be on the ability to retain the personnel we need in leadership positions in the Armed Forces? (6) Last year, the Navy Exchange Service Command generated more than $45 million in dividends. These figures seem to indicate that commissary and exchange benefits are not especially costly to DOD and that service members place a high value on these benefits. How can these figures inform the Department in maintaining a competitive cash and non-cash compensation package for service members and providing it in such a way that is affordable to the Department?
(1) In our April 1, 2010 report, we noted that using the Employment Cost Index (ECI) for the purpose of determining the amount of the annual basic pay raise for servicemembers has both strengths and weaknesses, but is generally reasonable to use to adjust such pay annually. It should also be noted that basic pay is just onecomponent of the total military compensation package. (2) Any increase in basic pay--whether it is equivalent to the ECI or some percentage above the ECI--results in additional near-term and long-term costs to compensate servicemembers. In recent years, the additional one-half percentage point has been added in order to reduce a perceived gap between military and private-sector pay. However, as our recent work comparing military and civilian compensation asserts, we do not believe that comparing changes in the ECI with changes in the rates of basic pay shows there is a difference, or "pay gap," between the two, or that such comparisons facilitates the assessment of how military pay rates compare with what civilian employers provide. (3) As we have reported and as noted above, using the ECI for the purpose of determining the amount of the annual basic pay raise for servicemembers has both strengths and weaknesses but is generally reasonable to use to adjust such pay annually. It should also be noted that basic pay is just one component of the total military compensation package. (4) While we have not previously assessed whether the current pay table needs adjustment, we have for over three decades reported that the current military compensation package has been the result of piecemeal changes and adjustments over time and lacks overall guiding principles. Regarding targeted changes to pay, we have reported that across-the-board pay increases fail to target resources where they are most needed and they affect a variety of other costs--such as retired pay. Rather, the targeted use of compensation--such as special pays and bonuses for particular occupational skills--tends to maximize limited resources and help make recruiting and retention gains in needed areas. (5) In the absence of any identified weaknesses in the overall recruiting and retention rates, it is difficult to determine if problems exist that would be best corrected through changes to the current retirement system. Further, our prior work has shown that benefits, especially deferred benefits like retirement, are a relatively inefficient way to influence recruiting and retention, as compared with cash pay. (6) While these figures are informative in terms of servicemember use of the commissary and the cost of operating the commissary, in the absence of additional data and information on how servicemembers value the commissary, these figures cannot appropriately inform DOD on affordably maintaining a competitive cash and noncash compensation package for servicemembers.
GAO-10-803R, Questions for the Record Related to Military Compensation
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GAO-10-803R:
United States Government Accountability Office:
Washington, DC 20548:
June 3, 2010:
The Honorable Jim Webb:
Chairman:
Subcommittee on Personnel:
Committee on Armed Services:
United States Senate:
Subject: Questions for the Record Related to Military Compensation:
Dear Mr. Chairman:
It was a pleasure to appear before your subcommittee on April 28,
2010, to discuss current issues related to military compensation.
[Footnote 1] This letter responds to your request that I provide
answers to questions for the record from the hearing. The questions,
along with my responses, follow.
Questions from Chairman Webb:
Use of Employment Cost Index as Benchmark Index for Military Basic Pay:
1. Dr. Murray and Ms. Farrell, in Dr. Murray's prepared statement, she
stated that using the Employment Cost Index (ECI) as the benchmark
index for annual military pay raises had its limitations, since it
measured a population that tended to be older and college-educated, a
population whose pay has increased more rapidly over the past decade
than younger high school graduates. Is the ECI an appropriate index to
use to adjust military basic pay rates annually? If not, is there a
benchmark that is more appropriate?
In our April 1, 2010 report,[Footnote 2] we noted that using the
Employment Cost Index (ECI) for the purpose of determining the amount
of the annual basic pay raise for servicemembers has both strengths
and weaknesses, but is generally reasonable to use to adjust such pay
annually. It should also be noted that basic pay is just one component
of the total military compensation package. In addition to basic pay,
servicemembers also receive allowances, tax advantages, as well as
deferred and in-kind compensation.
The ECI is a measure of changes in wages and employer costs for
employee benefits. Created in the mid-1970s, the ECI is published
quarterly by the Bureau of Labor Statistics and is part of the
bureau's National Compensation Survey program, which provides measures
of occupational wages, employment cost trends, and benefit incidence
and detailed plan provisions. Organizations use the ECI to inform
their decision making in a variety of ways--including adjusting their
wage rates to keep pace with what their competitors' pay or to adjust
wage rates in collective bargaining agreements. In addition, the
federal government uses the ECI to inform its decision making. For
example, Congress included a provision in the National Defense
Authorization Act for Fiscal Year 2004 tying the annual basic pay
raise for military personnel to the ECI.[Footnote 3] The law contains
a provision allowing the President to propose alternative pay
adjustments to Congress, in certain circumstances, if the President
deems the standard increase required by the law to be inappropriate.
As noted, our recent work[Footnote 4] has found that using the ECI to
adjust military basic pay annually has both strengths and weaknesses.
For example, its strengths include the following: the ECI is a
nationally representative measure of labor costs for the civilian
economy; it is also produced in a consistent fashion,[Footnote 5]
using a transparent methodology; and it provides separate data series
for different occupational groups, industries, and geographic areas.
With regard to its weaknesses, the ECI is not tailored to the specific
segments of the civilian economy most relevant to the Department of
Defense (DOD)--for example, those occupations and industries that the
military services primarily compete with for workers. Also, because
the ECI is constructed from data collected from surveys of employers,
it does not provide data about the demographics of the civilian
workforce--such as workers' education and experience, both of which
are important factors that are often taken into account when setting
employee pay. Nevertheless, we, as well as the Congressional Budget
Office (CBO),[Footnote 6] have previously reported[Footnote 7] on the
challenges of creating more tailored indexes. Further, none of the
experts with whom we consulted, nor any reports published by other
organizations that we reviewed during the course of our review,
suggested that any other existing indexes or data series would provide
more useful data than those provided by the ECI.
Questions from Senator Graham:
Sufficiency of Pay Raise and the Pay Table:
1. Mr. Carr, Ms. Farrell, Dr. Murray, and Dr. Hosek, the proposed pay
raise for Fiscal Year (FY) 2011 is 1.4 percent, but this matches last
year's rise in the ECI. Increasing this percentage would cost an
additional $350 million in FY11, and much more over time, as you have
all noted in your testimony. Please explain what the impact on the
Defense budget would be if Congress directed an increase in the pay
raise by one percent, or half a percent without offsets.
Any increase in basic pay--whether it is equivalent to the ECI or some
percentage above the ECI--results in additional near-term and long-
term costs to compensate servicemembers. The National Defense
Authorization Act for Fiscal Year 2004[Footnote 8] included a
provision tying the annual basic pay raise to the annual percentage
increase in the ECI and, for fiscal years 2004, 2005, and 2006, the
law required that servicemembers' basic pay increase be equal to the
annual percentage increase in the ECI plus an additional one-half
percentage point. That law also contains a provision allowing the
President to propose alternative pay adjustments to Congress, in
certain circumstances, if the President deems the standard increase
required by the law to be inappropriate. For fiscal year 2011, the
President and DOD have requested a 1.4 percent increase, which is
equivalent to the percentage increase in the ECI.
In recent years, the additional one-half percentage point has been
added in order to reduce a perceived gap between military and private-
sector pay. However, as our recent work comparing military and
civilian compensation asserts, we do not believe that comparing
changes in the ECI with changes in the rates of basic pay shows there
is a difference, or "pay gap," between the two, or that such
comparisons facilitates the assessment of how military pay rates
compare with what civilian employers provide. In our view, and as
officials at CBO noted,[Footnote 9] such a comparison does not reveal
a pay gap because, among other reasons, it assumes that basic pay is
the only component of military compensation that should be compared
with changes in civilian pay. While basic pay represents the largest
portion of military compensation, servicemembers may also receive
allowances for housing and subsistence. By excluding these allowances,
comparing changes in the ECI with changes in the rates of basic pay
simply illustrates how a portion of military compensation--basic pay--
has changed over time.
2. Mr. Carr, Ms. Farrell, Dr. Murray, and Dr. Hosek, is there a better
metric than the ECI to gauge what an annual pay raise should be?
As we have reported[Footnote 10] and as noted above, using the ECI for
the purpose of determining the amount of the annual basic pay raise
for servicemembers has both strengths and weaknesses but is generally
reasonable to use to adjust such pay annually. It should also be noted
that basic pay is just one component of the total military
compensation package. In addition to basic pay, servicemembers also
receive allowances, tax advantages, as well as deferred and in-kind
compensation.
The ECI is a nationally representative measure of labor costs for the
civilian economy and is used by businesses and other organizations to,
among other things, adjust wage rates to keep pace with competitors.
In our view, using the ECI to determine the amount of the annual basic
pay raise has both strengths and weaknesses, but it is generally
reasonable to use it to adjust basic pay annually. As mentioned
earlier, the strengths include the following: the ECI is a nationally
representative measure of labor costs for the civilian economy; it is
produced in a consistent fashion,[Footnote 11] using a transparent
methodology; and it provides separate data series for different
occupational groups, industries, and geographic areas. However, the
ECI is not tailored to the specific segments of the civilian economy
most relevant to DOD--for example, those occupations and industries
that the military services primarily compete with for workers. Also,
because the ECI is constructed from data collected from surveys of
employers, it does not provide data about the demographics of the
civilian workforce--such as workers' education and experience, both of
which are important factors that are often taken into account when
setting employee pay. Nevertheless, we, as well as CBO,[Footnote 12]
have previously reported[Footnote 13] on the challenges of creating
more tailored indexes. Further, none of the experts whom we consulted
nor any reports published by other organizations that we reviewed
during the course of our review suggested that any other existing
indexes or data series would provide more useful data than those
provided by the ECI.
3. Mr. Carr, Ms. Farrell, Dr. Murray, and Dr. Hosek, several years
ago, the Department proposed targeted changes to the pay in certain
grades with certain longevity, which was designed to relieve pay
compression, and provide greater incentives for promotion. Does the
current pay table need adjustment?
While we have not previously assessed whether the current pay table
needs adjustment, we have for over three decades reported[Footnote 14]
that the current military compensation package has been the result of
piecemeal changes and adjustments over time and lacks overall guiding
principles. Specifically, in 1979, we evaluated DOD's military
compensation system and concluded that piecemeal adjustments and a
lack of overall guiding principles of compensation were a problem in
establishing a basis for evaluating changes to the total compensation
system. More recently, in 2005, we noted that some of the same
underlying problems that we identified in 1979--including a lack of
explicit compensation principles and difficulty in making major
changes to compensation--still existed.
In discussions with DOD, officials indicated that the department
previously adjusted the basic pay table in order to make pay at all
ranks and years of service more in line with the 70th percentile--as
recommended by the 9th Quadrennial Review of Military Compensation
(2004). That review recommended that regular military compensation be
set to equal the 70th percentile of comparable civilian compensation.
At that time, the department found that for some ranks and years-of-
service, compensation was close to the 70th percentile, but for other
ranks and years-of-service it was not so close. As a result, according
to DOD officials, the department relied on targeted pay increases to
raise the level of pay for certain ranks and years-of-service in the
pay table from about the year 2000 through 2005. However, according to
one of these officials, 2005 was the first year in which pay for all
ranks and years of service was increased in lockstep to bring pay more
in line with the 70th percentile.
Regarding targeted changes to pay, we have reported that across-the-
board pay increases fail to target resources where they are most
needed and they affect a variety of other costs--such as retired pay.
Rather, the targeted use of compensation--such as special pays and
bonuses for particular occupational skills--tends to maximize limited
resources and help make recruiting and retention gains in needed
areas. Our prior work[Footnote 15] recognizes DOD's ability to use the
more than 60 different special and incentive pays--including
reenlistment bonuses and hazardous duty pay, as well as other pays for
specific duties like aviation and medical, and incentives for
servicemembers to take certain assignments, among others. Because most
compensation is determined by factors such as tenure, rank, location,
and dependent status, these special pays and allowances are the
primary monetary incentives DOD has for servicemembers other than
promotions and are used to influence certain behaviors, such as
extending a service contract or filling critical shortage occupations.
Effects of Cliff Vesting:
4. Mr. Carr, Ms. Farrell, Dr. Murray, and Dr. Hosek, various study
groups in recent years have questioned the wisdom of the military's
traditional 20-year requirement to earn retired pay, suggesting that
vesting at an earlier milestone in a career--say 10 years--would more
effectively help to achieve DOD's personnel goals. However, assuring
retention of mid-level personnel beyond their first or second terms of
service--especially in wartime--would seem to justify reliance on this
approach. What do you think the effect of reducing the requirement for
entitlement to retired pay below 20 years would be on the ability to
retain the personnel we need in leadership positions in the Armed
Forces?
In the absence of any identified weaknesses in the overall recruiting
and retention rates, it is difficult to determine if problems exist
that would be best corrected through changes to the current retirement
system. Further, our prior work[Footnote 16] has shown that benefits,
especially deferred benefits like retirement, are a relatively
inefficient way to influence recruiting and retention, as compared
with cash pay. Efficiency, as defined by DOD, is the amount of
military compensation--no higher or lower than necessary--that is
required to fulfill the basic objective of attracting, retaining, and
motivating the kinds and numbers of active duty servicemembers needed.
However, the efficiency of some benefits is difficult to assess
because the value that servicemembers place on them is different and
highly individualized. Therefore, understanding the effect of reducing
the vesting requirement below 20 years requires an understanding of
how servicemembers value retirement benefits, in general. Because the
current military retirement benefit is (1) a defined benefit plan with
a 20-year cliff vesting requirement and (2) a promise of future
retirement payments made over the remainder of the servicemember's
lifetime, calculating the value today--the present value--is
difficult. In calculating the present value of the retirement benefit,
two factors are critically important: the probability of staying in
the military until retirement and the discount rate used to calculate
the present value of retirement.
DOD's current retirement system is meant to create a strong incentive
for military personnel who stay beyond 8 to 10 years to complete 20
years and leave soon thereafter. Specifically, under DOD's current
retirement system, according to the department's Office of the
Actuary, only 15 percent of enlisted and 47 percent of officers become
eligible to receive retirement under the current plan that requires 20
years of service to vest.
If a military career is viewed as a continuum, retention rates will
typically rise just before the point at which servicemembers may vest,
and will subsequently decline on the far side of that point. As noted,
under the current retirement system, servicemembers vest after 20
years and may immediately retire. Thus, moving the vesting milestone
from 20 years to 10 years makes sense if the perceived challenge is
getting people, who otherwise might have left after 5 years, to stay
until 10 years, and/or getting people to leave after 10 years.
However, moving the vesting requirement would eliminate a major
incentive for servicemembers with 10 years of service to stay on until
20 years. Therefore, retention rates of experienced servicemembers
with 10 years-of-service or more may decline. Lastly, vesting
servicemembers at 10 years is likely to be less powerful in affecting
behavior because the stakes are lower--specifically, a servicemember
who leaves the service at 9 years-of-service under 10-year vesting
forfeits much less than someone who leaves after 19 years-of-service
under 20-year vesting. However, these effects may differ based on the
extent to which changes are made to the retirement system--for
example, if changes are made solely to the vesting requirement but not
to the number of years required to reach retirement eligibility.
Another approach that would yield different results would maintain the
immediate retirement standard at 20 years, but allow servicemembers to
vest at an earlier point in their careers (e.g., 10 years) and make it
a deferred vested benefit that servicemembers would receive at, for
example, 65 years of age.
It is important, however, to consider all potential effects[Footnote
17] of such a change. For example, reducing the requirement for
vesting eligibility would potentially result in higher percentages of
officers and enlisted servicemembers vesting and thus receiving a
retirement pension, which could have significant cost implications for
the department in the future. Furthermore, the uniformed services are
unlike nearly all other organizations in that (1) they have closed
personnel systems--that is, DOD relies almost exclusively on accession
at the entry level (E-1 or O-1), and on its higher-ranking members
being retained and promoted from lower ranks; and (2) according to
DOD, there is no private-sector labor market from which the military
can hire for certain unique occupations--such as an infantry battalion
commander. By contrast, most other organizations can and do hire from
the outside at all levels. Thus, the failure to meet recruiting or
retention goals at lower levels in a given year can have significant
consequences for a service's ability to produce experienced leaders
for years to come.
Questions from Senator Collins:
Commissary Benefits:
1. Ms. Farrell, according to a Pentagon survey, 90 percent of military
personnel utilize commissary benefits. Last year, the Navy Exchange
Service Command generated more than $45 million in dividends. These
figures seem to indicate that commissary and exchange benefits are not
especially costly to DOD and that service members place a high value
on these benefits. How can these figures inform the Department in
maintaining a competitive cash and non-cash compensation package for
service members and providing it in such a way that is affordable to
the Department?
While these figures are informative in terms of servicemember use of
the commissary and the cost of operating the commissary, in the
absence of additional data and information on how servicemembers value
the commissary, these figures cannot appropriately inform DOD on
affordably maintaining a competitive cash and noncash compensation
package for servicemembers. We have previously reported[Footnote 18]
that military compensation includes a mix of cash, noncash benefits,
and deferred compensation, and has been one of the primary tools used
by DOD to recruit and retain servicemembers since the military
transitioned to an all-volunteer force in 1973. The commissary benefit
is just one of the noncash benefits available to servicemembers. In
our recent report,[Footnote 19] we noted that 90 percent of military
personnel responding to the 2007 Status of Forces Survey for Active
Duty Personnel indicated that they utilize commissary benefits.
However, while these survey results show that 90 percent--a large
majority--of respondents reportedly used the commissary, the survey
does not contain a question that asks about the value the individual
places on the commissary benefit; therefore, the results of the survey
could not take into account the value that an individual servicemember
places on the commissary benefit.
In addition, the Navy Exchange Service Command is meant to provide
quality goods and services at a savings and to support quality of life
programs by providing dividends to Navy Morale, Welfare and Recreation
(MWR). In 2008, the Navy Exchange Service Command had total annual
sales of $2.52 billion and generated more than $45 million in
dividends for MWR quality of life programs. While this figure gives an
indication of the command's profitability, it does not take into
account the value that a servicemember places on the benefit. Further,
as we reported in 2005, servicemembers may not understand the full
extent (i.e., the value) of their benefits--in this case, the
commissary benefit.
As noted previously, DOD's compensation package is a mix of cash and
noncash benefits--the commissary benefit being one of the noncash
benefits available to servicemembers. However, in 2005,[Footnote 20]
we reported that DOD's mix of compensation (i.e., the ratio of cash to
noncash to deferred benefits) was highly inefficient for meeting near-
term recruiting and retention needs. We further reported that cash pay
in the present is generally accepted as a far more efficient tool than
future cash or benefits for recruiting and retention.
We are sending copies of this report to the appropriate congressional
committees. In addition, the report will be available at no charge on
the GAO Web site at [hyperlink, http://www.gao.gov].
If you or your staff have any questions on the matters discussed in
this report, please contact me at (202) 512-3604 or farrellb@gao.gov.
Contact points for our Offices of Congressional Relations and Public
Affairs may be found on the last page of this report. GAO staff who
made key contributions are listed in enclosure I.
Signed by:
Brenda S. Farrell:
Director, Defense Capabilities and Management:
[End of section]
Enclosure 1: GAO Contact and Staff Acknowledgment:
GAO Contact:
Brenda S. Farrell, (202) 512-3604 or farrellb@gao.gov:
Acknowledgments:
In addition to the individual named above, Marion A. Gatling,
Assistant Director; Timothy J. Carr; Patrick M. Dudley; K. Nicole
Harms; Susan C. Langley; Charles W. Perdue; Jennifer L. Weber; and
Cheryl A. Weissman made key contributions to this report.
[End of section]
Footnotes:
[1] GAO, Military Personnel: Comparisons between Military and Civilian
Compensation Can be Useful, but Data Limitations Prevent Exact
Comparisons, [hyperlink, http://www.gao.gov/products/GAO-10-666T]
(Washington, D.C.: Apr .28, 2010).
[2] GAO, Military Personnel: Military and Civilian Pay Comparisons
Present Challenges and Are One of Many Tools in Assessing
Compensation, [hyperlink, http://www.gao.gov/products/GAO-10-561R]
(Washington, D.C.: Apr. 1, 2010).
[3] Pub. L. No. 108-136, § 602 (2003), codified at 37 U.S.C. § 1009.
Specifically, the law requires that all eligible servicemembers'
monthly basic pay be increased annually by the annual percentage
increase in the ECI, except for in fiscal years 2004, 2005, and 2006
when the law required that servicemembers' basic pay increase be equal
to the annual percentage increase in the ECI, plus an additional one-
half percentage point.
[4] [hyperlink, http://www.gao.gov/products/GAO-10-561R].
[5] We do note, however, that adjustments to the methodology have been
made from time to time. For example, in 2006 the Bureau of Labor
Statistics changed the way the ECI classified industries and
occupations to reflect new industry and occupational classification
systems and rebased the index, among other changes.
[6] Congressional Budget Office, Evaluating Military Compensation
(Washington, D.C.: June 2007),
[7] [hyperlink, http://www.gao.gov/products/GAO-10-561R]; GAO, Poverty
Measurement: Adjusting for Geographic Cost-of-Living Difference,
[hyperlink, http://www.gao.gov/products/GAO/GGD-95-64] (Washington,
D.C.: March 9, 1995); and GAO, Developing a Consumer Price Index for
the Elderly, [hyperlink, http://www.gao.gov/products/GAO/T-GGD-87-22]
(Washington, D.C.: June 29, 1987).
[8] Pub. L. No 108-136, § 602 (2003), codified at 37 U.S.C. §1009.
[9] Congressional Budget Office, Statement of Carla Tighe Murray:
Evaluating Military Compensation, CBO (Washington, D.C., Apr. 28,
2010); CBO, Evaluating Military Compensation (Washington, D.C. June
2007); and CBO, What Does the Military "Pay Gap" Mean? (Washington,
D.C., June 1999).
[10] [hyperlink, http://www.gao.gov/products/GAO-10-561R].
[11] There are adjustments in the methodology from time to time. For
example, in 2006 the Bureau of Labor Statistics changed the way the
ECI classified industries and occupations to reflect new industry and
occupational classification systems and rebased the index, among other
changes.
[12] Congressional Budget Office, Statement of Carla Tighe Murray:
Evaluating Military Compensation (Washington, D.C., Apr. 28, 2010) and
Evaluating Military Compensation (Washington, D.C., June 2007).
[13] [hyperlink, http://www.gao.gov/products/GAO-10-561R], [hyperlink,
http://www.gao.gov/products/GAO/GGD-95-64], and [hyperlink,
http://www.gao.gov/products/GAO/T-GGD-87-22].
[14] GAO, Military Personnel: DOD Needs to Improve the Transparency
and Reassess the Reasonableness, Appropriateness, Affordability, and
Sustainability of Its Military Compensation System, [hyperlink,
http://www.gao.gov/products/GAO-05-798] (Washington, D.C.: July 19,
2005) and The Congress Should Act To Establish Military Compensation
Principles, [hyperlink, http://www.gao.gov/products/GAO/FPCD-79-11]
(Washington, D.C.: May 9, 1979).
[15] [hyperlink, http://www.gao.gov/products/GAO-10-666T], [hyperlink,
http://www.gao.gov/products/GAO-10-561R], Military Personnel: DOD
Needs to Establish a Strategy and Improve Transparency over Reserve
and National Guard Compensation to Manage Significant Growth in Cost,
[hyperlink, http://www.gao.gov/products/GAO-07-828] (Washington, D.C.:
June 20, 2007), and [hyperlink,
http://www.gao.gov/products/GAO-05-798].
[16] [hyperlink, http://www.gao.gov/products/GAO-05-798].
[17] In 2005 and 2007, we provided Matters for Consideration that
asked Congress to consider the long-term affordability and
sustainability of any additional changes to pay and benefits for
military personnel and veterans, including the long-term implications
for the deficit and military readiness. Such a change to the current
retirement system would most certainly have long-term implications for
affordability and sustainability. See [hyperlink,
http://www.gao.gov/products/GAO-05-798] and [hyperlink,
http://www.gao.gov/products/GAO-07-828].
[18] [hyperlink, http://www.gao.gov/products/GAO-10-666T], [hyperlink,
http://www.gao.gov/products/GAO-10-561R], [hyperlink,
http://www.gao.gov/products/GAO-07-828], and [hyperlink,
http://www.gao.gov/products/GAO-05-798].
[19] [hyperlink, http://www.gao.gov/products/GAO-10-561R].
[20] [hyperlink, http://www.gao.gov/products/GAO-05-798].
[End of section]
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