Fraud Detection Systems
Additional Actions Needed to Support Program Integrity Efforts at Centers for Medicare and Medicaid Services Gao ID: GAO-11-822T July 12, 2011This testimony discusses the Centers for Medicare and Medicaid Services' (CMS) efforts to protect the integrity of the Medicare and Medicaid programs, particularly through the use of information technology to help improve the detection of fraud, waste, and abuse in these programs. CMS is responsible for administering the Medicare and Medicaid programs and leading efforts to reduce improper payments of claims for medical treatment, services, and equipment. Improper payments are overpayments or underpayments that should not have been made or were made in an incorrect amount; they may be due to errors, such as the inadvertent submission of duplicate claims for the same service, or misconduct, such as fraud or abuse. The Department of Health and Human Services reported about $70 billion in improper payments in the Medicare and Medicaid programs in fiscal year 2010. Operating within the Department of Health and Human Services, CMS conducts reviews to prevent improper payments before claims are paid and to detect claims that were paid in error. These activities are predominantly carried out by contractors who, along with CMS personnel, use various information technology solutions to consolidate and analyze data to help identify the improper payment of claims. For example, these program integrity analysts may use software tools to access data about claims and then use those data to identify patterns of unusual activities by matching services with patients' diagnoses. In 2006, CMS initiated activities to centralize and make more accessible the data needed to conduct these analyses and to improve the analytical tools available to its own and contractor analysts. At the Subcommittee's request, we have been reviewing two of these initiatives--the Integrated Data Repository (IDR), which is intended to provide a single source of data related to Medicare and Medicaid claims, and the One Program Integrity (One PI) system, a Web-based portal and suite of analytical software tools used to extract data from IDR and enable complex analyses of these data. According to CMS officials responsible for developing and implementing IDR and One PI, the agency had spent approximately $161 million on these initiatives by the end of fiscal year 2010. This testimony, in conjunction with a report that we are releasing today, summarizes the results of our study--which specifically assessed the extent to which IDR and One PI have been developed and implemented and CMS's progress toward achieving its goals and objectives for using these systems to detect fraud, waste, and abuse.
In 2006, CMS initiated the One PI program with the intention of developing and implementing a portal and software tools that would enable access to and analysis of claims, provider, and beneficiary data from a centralized source. The agency's goal for One PI was to support the needs of a broad program integrity user community, including agency program integrity personnel and contractors who analyze Medicare claims data, along with state agencies that monitor Medicaid claims. To achieve its goal, agency officials planned to implement a tool set that would provide a single source of information to enable consistent, reliable, and timely analyses and improve the agency's ability to detect fraud, waste, and abuse. These tools were to be used to gather data from IDR about beneficiaries, providers, and procedures and, combined with other data, find billing aberrancies or outliers. For example, an analyst could use software tools to identify potentially fraudulent trends in ambulance services by gathering the data about claims for ambulance services and medical treatments, and then use other software to determine associations between the two types of services. If the analyst found claims for ambulance travel costs but no corresponding claims for medical treatment, it might indicate that further investigation could prove that the billings for those services were fraudulent. According to agency program planning documentation, the One PI system was also to be developed incrementally to provide access to IDR data, analytical tools, and portal functionality. CMS planned to implement the One PI portal and two analytical tools for use by program integrity analysts on a widespread basis by the end of fiscal year 2009. The agency engaged contractors to develop the system. While CMS has shown some progress toward meeting the programs' goals of providing a centralized data repository and enhanced analytical capabilities for detecting improper payments due to fraud, waste, and abuse, the current implementation of IDR and One PI does not position the agency to identify, measure, and track financial benefits realized from reductions in improper payments as a result of the implementation of either system. For example, program officials stated that they had developed estimates of financial benefits expected to be realized through the use of IDR. The most recent projection of total financial benefits was reported to be $187 million, based on estimates of the amount of improper payments the agency expected to recover as a result of analyzing data provided by IDR. With estimated life-cycle program costs of $90 million through fiscal year 2018, the resulting net benefit expected from implementing IDR was projected to be $97 million. However, as of March 2011, program officials had not identified actual financial benefits of implementing IDR.
GAO-11-822T, Fraud Detection Systems: Additional Actions Needed to Support Program Integrity Efforts at Centers for Medicare and Medicaid Services
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United States Government Accountability Office: GAO:
Testimony:
Before the Subcommittee on Federal Financial Management, Government
Information, Federal Service, and International Security, Committee on
Homeland Security and Government Affairs, U.S. Senate:
For Release on Delivery:
Expected at 2:30 p.m. EDT:
Tuesday, July 12, 2011:
Fraud Detection Systems:
Additional Actions Needed to Support Program Integrity Efforts at
Centers for Medicare and Medicaid Services:
Statement of Joel C. Willemssen:
Managing Director, Information Technology:
GAO-11-822T:
Mr. Chairman and Members of the Subcommittee:
I am pleased to participate in today's hearing on the Centers for
Medicare and Medicaid Services' (CMS) efforts to protect the integrity
of the Medicare and Medicaid programs, particularly through the use of
information technology to help improve the detection of fraud, waste,
and abuse in these programs. As you are aware, CMS is responsible for
administering the Medicare and Medicaid programs[Footnote 1] and
leading efforts to reduce improper payments of claims for medical
treatment, services, and equipment. Improper payments are overpayments
or underpayments that should not have been made or were made in an
incorrect amount; they may be due to errors, such as the inadvertent
submission of duplicate claims for the same service, or misconduct,
such as fraud or abuse. The Department of Health and Human Services
reported about $70 billion in improper payments in the Medicare and
Medicaid programs in fiscal year 2010.
Operating within the Department of Health and Human Services, CMS
conducts reviews to prevent improper payments before claims are paid
and to detect claims that were paid in error. These activities are
predominantly carried out by contractors who, along with CMS
personnel, use various information technology solutions to consolidate
and analyze data to help identify the improper payment of claims. For
example, these program integrity analysts may use software tools to
access data about claims and then use those data to identify patterns
of unusual activities by matching services with patients' diagnoses.
In 2006, CMS initiated activities to centralize and make more
accessible the data needed to conduct these analyses and to improve
the analytical tools available to its own and contractor analysts. At
the Subcommittee's request, we have been reviewing two of these
initiatives--the Integrated Data Repository (IDR), which is intended
to provide a single source of data related to Medicare and Medicaid
claims, and the One Program Integrity (One PI) system, a Web-based
portal[Footnote 2] and suite of analytical software tools used to
extract data from IDR and enable complex analyses of these data.
According to CMS officials responsible for developing and implementing
IDR and One PI, the agency had spent approximately $161 million on
these initiatives by the end of fiscal year 2010.
My testimony, in conjunction with a report that we are releasing
today,[Footnote 3] summarizes the results of our study--which
specifically assessed the extent to which IDR and One PI have been
developed and implemented and CMS's progress toward achieving its
goals and objectives for using these systems to detect fraud, waste,
and abuse. All work on which this testimony is based was conducted at
CMS's headquarters in Baltimore, Maryland, between June 2010 and July
2011, in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives.
Background:
Like financial institutions, credit card companies, telecommunications
firms, and other private sector companies that take steps to protect
customers' accounts, CMS uses information technology to help detect
cases of improper claims and payments. For more than a decade, the
agency and its contractors have used automated software tools to
analyze data from various sources to detect patterns of unusual
activities or financial transactions that indicate payments could have
been made for fraudulent charges or improper payments. For example, to
identify unusual billing patterns and support investigations and
prosecutions of cases, analysts and investigators access information
about key actions taken to process claims as they are filed and the
specific details about claims already paid. This would include
information on claims as they are billed, adjusted, and paid or
denied; check numbers on payments of claims; and other specific
information that could help establish provider intent.
CMS uses many different means to store and manipulate data and, since
the establishment of the agency's program integrity initiatives in the
1990s, has built multiple, disparate databases and analytical software
tools to meet the individual and unique needs of various programs
within the agency. In addition, data on Medicaid claims are stored by
the states in multiple systems and databases, and are not readily
available to CMS. According to agency program documentation, these
geographically distributed, regional approaches to data storage result
in duplicate data and limit the agency's ability to conduct analyses
of data on a nationwide basis. As a result, CMS has been working for
most of the past decade to consolidate its databases and analytical
tools.
CMS's Initiative to Develop a Centralized Source of Medicare and
Medicaid Data:
In 2006, CMS officials expanded the scope of a 3-year-old data
modernization strategy to not only modernize data storage technology,
but also to integrate Medicare and Medicaid data into a centralized
repository so that CMS and its partners could access the data from a
single source. They called the expanded program IDR.
According to program officials, the agency's vision was for IDR to
become the single repository for CMS's data and enable data analysis
within and across programs. Specifically, this repository was to
establish the infrastructure for storing data related to Medicaid and
Medicare Parts A, B, and D claims processing,[Footnote 4] as well as a
variety of other agency functions, such as program management,
research, analytics, and business intelligence.
CMS envisioned an incremental approach to incorporating data into IDR.
Specifically, it intended to incorporate data related to paid claims
for all Medicare Part D data by the end of fiscal year 2006, and for
Medicare Parts A and B data by the end of fiscal year 2007. The agency
also planned to begin to incrementally add all Medicaid data for the
50 states in fiscal year 2009 and to complete this effort by the end
of fiscal year 2012.
Initial program plans and schedules also included the incorporation of
additional data from legacy CMS claims-processing systems that store
and process data related to the entry, correction, and adjustment of
claims as they are being processed, along with detailed financial data
related to paid claims. According to program officials, these data,
called "shared systems" data, are needed to support the agency's plans
to incorporate tools to conduct predictive analysis of claims as they
are being processed, helping to prevent improper payments. Shared
systems data, such as check numbers and amounts related to claims that
have been paid, are also needed by law enforcement agencies to help
with fraud investigations. CMS initially planned to have all the
shared systems data included in IDR by July 2008.
CMS's Initiative to Develop and Implement Analytical Tools for
Detecting Fraud, Waste, and Abuse:
Also in 2006, CMS initiated the One PI program with the intention of
developing and implementing a portal and software tools that would
enable access to and analysis of claims, provider, and beneficiary
data from a centralized source. The agency's goal for One PI was to
support the needs of a broad program integrity user community,
including agency program integrity personnel and contractors who
analyze Medicare claims data, along with state agencies that monitor
Medicaid claims. To achieve its goal, agency officials planned to
implement a tool set that would provide a single source of information
to enable consistent, reliable, and timely analyses and improve the
agency's ability to detect fraud, waste, and abuse. These tools were
to be used to gather data from IDR about beneficiaries, providers, and
procedures and, combined with other data, find billing aberrancies or
outliers. For example, an analyst could use software tools to identify
potentially fraudulent trends in ambulance services by gathering the
data about claims for ambulance services and medical treatments, and
then use other software to determine associations between the two
types of services. If the analyst found claims for ambulance travel
costs but no corresponding claims for medical treatment, it might
indicate that further investigation could prove that the billings for
those services were fraudulent.
According to agency program planning documentation, the One PI system
was also to be developed incrementally to provide access to IDR data,
analytical tools, and portal functionality. CMS planned to implement
the One PI portal and two analytical tools for use by program
integrity analysts on a widespread basis by the end of fiscal year
2009. The agency engaged contractors to develop the system.
IDR and One PI Are in Use, but Lack Data and Functionality Essential
to CMS's Program Integrity Efforts:
IDR has been in use by CMS and contractor program integrity analysts
since September 2006 and currently incorporates data related to claims
for reimbursement of services under Medicare Parts A, B, and D.
According to program officials, the integration of these data into IDR
established a centralized source of data previously accessed from
multiple disparate system files.
However, although the agency has been incorporating data from various
sources since 2006, IDR does not yet include all the data that were
planned to be incorporated by the end of 2010 and that are needed to
support enhanced program integrity initiatives. Specifically, although
initial program integrity requirements included the incorporation of
the shared systems data by July 2008, these data have not yet been
added to IDR. As such, analysts are not able to access certain data
from IDR that would help them identify and prevent payment of
fraudulent claims. According to IDR program officials, the shared
systems data were not incorporated as planned because funding for the
development of the software and acquisition of the hardware needed to
meet this requirement was not approved until the summer of 2010. Since
then, IDR program officials have developed project plans and
identified user requirements, and told us that they plan to
incorporate shared systems data by November 2011.
In addition, IDR does not yet include the Medicaid data that are
critical to analysts' ability to detect fraud, waste, and abuse in
this program. While program officials initially planned to incorporate
20 states' Medicaid data into IDR by the end of fiscal year 2010, the
agency had not incorporated any of these data into the repository as
of May 25, 2011. Program officials told us that the original plans and
schedules for obtaining Medicaid data did not account for the lack of
funding for states to provide Medicaid data to CMS, or the variations
in the types and formats of data stored in disparate state Medicaid
systems. Consequently, the officials were not able to collect the data
from the states as easily as they expected and did not complete this
activity as originally planned.
In December 2009, CMS initiated another agencywide program intended
to, among other things, identify ways to collect Medicaid data from
the many disparate state systems and incorporate the data into a
single data store. As envisioned by CMS, this program, the Medicaid
and Children's Health Insurance Program Business Information and
Solutions (MACBIS) program, is to include activities in addition to
providing expedited access to current data from state Medicaid
programs. According to agency planning documentation, as a result of
efforts to be initiated under the MACBIS program, CMS expects to
incorporate Medicaid data for all 50 states into IDR by the end of
fiscal year 2014. This enterprisewide initiative is expected to cost
about $400 million through fiscal year 2016.
However, program officials have not defined plans and reliable
schedules for incorporating the additional data into IDR that are
needed to support the agency's program integrity goals. Yet, doing so
is essential to ensuring that CMS does not repeat mistakes of the past
that stand to jeopardize the overall success of its current efforts.
In this regard, more than a decade ago, we reported on the agency's
efforts to replace multiple claims processing systems with a single,
unified system.[Footnote 5] Among other things, that system was
intended to provide an integrated database to help the agency in
identifying fraud and abuse. However, as the system was being
developed, we reported repeatedly that the agency was not applying
effective investment management practices to its planning and
management of the project. Further, we reported that the agency had no
assurance that the project would be cost-effective, delivered within
estimated timeframes, or even improve the processing of Medicare
claims. Lacking these vital project management elements, CMS
subsequently halted that troubled initiative without delivering the
intended system--after investing more than $80 million over 3-and-a-
half years.
Until the agency defines plans and reliable schedules for
incorporating the additional data into IDR, it cannot ensure that
current development, implementation, and deployment efforts will
provide the data and technical capabilities needed to enhance CMS's
efforts to detect potential cases of fraud, waste, and abuse.
Beyond the IDR initiative, CMS program integrity officials have not
yet taken appropriate actions to ensure the use of One PI on a
widespread basis for program integrity purposes. According to program
officials, the system was deployed in September 2009 as originally
planned and consisted of a portal that provided Web-based access to
software tools used by CMS and contractor analysts to retrieve and
analyze data stored in IDR. As currently implemented, the system
provides access to two analytical tools. One tool is a commercial off-
the-shelf decision support tool that is used to perform data analysis
to, for example, detect patterns of activities that may identify or
confirm suspected cases of fraud, waste, or abuse. The second tool
provides users with extended capabilities to perform more complex
analyses of data. For example, it allows the user to customize and
create ad hoc queries of claims data across the different parts of the
Medicare program.
However, while program officials deployed the One PI portal and two
analytical tools, the system is not being used as widely as planned
because CMS and contractor analysts have not received the necessary
training for its use. In this regard, program planning documentation
from August 2009 indicated that One PI program officials had planned
for 639 analysts to be trained and using the system by the end of
fiscal year 2010; however, CMS confirmed that by the end of October
2010, only 42 of those intended users had been trained to use One PI,
with 41 actively using the portal and tools. These users represent
fewer than 7 percent of the users originally intended for the program.
Program officials responsible for implementing the system acknowledged
that their initial training plans and efforts had been insufficient
and that they had consequently initiated activities and redirected
resources to redesign the One PI training plan in April 2010; they
began to implement the new training program in July of that year. As
of May 25, 2011, One PI officials told us that 62 additional analysts
had signed up to be trained in 2011 and that the number of training
classes for One PI had been increased from two to four per month.
Agency officials, in commenting on our report, stated that since
January 2011, 58 new users had been trained; however, they did not
identify an increase in the number of actual users of the system.
Nonetheless, while these activities indicate some progress toward
increasing the number of One PI users, the number of users expected to
be trained and to begin using the system represents a small fraction
of the population of 639 intended users. Moreover, as of late May
2011, One PI program officials had not yet made detailed plans and
developed schedules for completing training of all the intended users.
Agency officials concurred with our conclusion that CMS needs to take
more aggressive steps to ensure that its broad community of analysts
is trained. Until it does so, the use of One PI may remain limited to
a much smaller group of users than the agency intended, and CMS will
continue to face obstacles in its efforts to deploy One PI for
widespread use throughout its community of program integrity analysts.
CMS Is Not Yet Positioned to Identify Financial Benefits or to Fully
Meet Program Integrity Goals and Objectives through the Use of IDR and
One PI:
Because IDR and One PI are not being used as planned, CMS officials
are not yet in a position to determine the extent to which the systems
are providing financial benefits or supporting the agency's
initiatives to meet program integrity goals and objectives. As we have
reported, agencies should forecast expected benefits and then measure
actual financial benefits accrued through the implementation of
information technology programs.[Footnote 6] Further, the Office of
Management and Budget (OMB) requires agencies to report progress
against performance measures and targets for meeting them that reflect
the goals and objectives of the programs.[Footnote 7] To do this,
performance measures should be outcome-based and developed with
stakeholder input, and program performance must be monitored,
measured, and compared to expected results so that agency officials
are able to determine the extent to which goals and objectives are
being met. In addition, industry experts describe the need for
performance measures to be developed with stakeholders' input early in
a project's planning process to provide a central management and
planning tool and to monitor the performance of the project against
plans and stakeholders' needs.
While CMS has shown some progress toward meeting the programs' goals
of providing a centralized data repository and enhanced analytical
capabilities for detecting improper payments due to fraud, waste, and
abuse, the current implementation of IDR and One PI does not position
the agency to identify, measure, and track financial benefits realized
from reductions in improper payments as a result of the implementation
of either system. For example, program officials stated that they had
developed estimates of financial benefits expected to be realized
through the use of IDR. The most recent projection of total financial
benefits was reported to be $187 million, based on estimates of the
amount of improper payments the agency expected to recover as a result
of analyzing data provided by IDR. With estimated life-cycle program
costs of $90 million through fiscal year 2018, the resulting net
benefit expected from implementing IDR was projected to be $97
million. However, as of March 2011, program officials had not
identified actual financial benefits of implementing IDR.
Further, program officials' projection of financial benefits expected
as a result of implementing One PI was most recently reported to be
approximately $21 billion. This estimate was increased from initial
expectations based on assumptions that accelerated plans to integrate
Medicare and Medicaid data into IDR would enable One PI users to
identify increasing numbers of improper payments sooner than
previously estimated, thus allowing the agency to recover more funds
that have been lost due to payment errors.
However, the current implementation of One PI has not yet produced
outcomes that position the agency to identify or measure financial
benefits. CMS officials stated at the end of fiscal year 2010--more
than a year after deploying One PI--that it was too early to determine
whether the program has provided any financial benefits. They
explained that, since the program had not met its goal for widespread
use of One PI, there were not enough data available to quantify
financial benefits attributable to the use of the system. These
officials said that as the user community is expanded, they expect to
be able to begin to identify and measure financial and other benefits
of using the system.
In addition, program officials have not developed and tracked outcome-
based performance measures to help ensure that efforts to implement
One PI and IDR meet the agency's goals and objectives for improving
the results of its program integrity initiatives. For example, outcome-
based measures for the programs would indicate improvements to the
agency's ability to recover funds lost because of improper payments of
fraudulent claims. However, while program officials defined and
reported to OMB performance targets for IDR related to some of the
program's goals, they do not reflect the goal of the program to
provide a single source of Medicare and Medicaid data that supports
enhanced program integrity efforts. Additionally, CMS officials have
not developed quantifiable measures for meeting the One PI program's
goals. For example, performance measures and targets for One PI
include increases in the detection of improper payments for Medicare
Parts A and B claims. However, the limited use of the system has not
generated enough data to quantify the amount of funds recovered from
improper payments.
Because it lacks meaningful outcome-based performance measures and
sufficient data for tracking progress toward meeting performance
targets, CMS does not have the information needed to ensure that the
systems are useful to the extent that benefits realized from their
implementation help the agency meet program integrity goals. Further,
until CMS is better positioned to identify and measure financial
benefits and establishes outcome-based performance measures to help
gauge progress toward meeting program integrity goals, it cannot be
assured that the systems will contribute to improvements in CMS's
ability to detect fraud, waste, and abuse in the Medicare and Medicaid
programs, and prevent or recover billions of dollars lost to improper
payments of claims.
Given the critical need for CMS to improve the management of and
reduce improper payments within the Medicare and Medicaid programs,
our report being released today recommends a number of actions that we
consider vital to helping CMS achieve more widespread use of IDR and
One PI for program integrity purposes. Specifically, we are
recommending that the Administrator of CMS:
* finalize plans and develop schedules for incorporating additional
data into IDR that identify all resources and activities needed to
complete tasks and that consider risks and obstacles to the IDR
program;
* implement and manage plans for incorporating data in IDR to meet
schedule milestones;
* establish plans and reliable schedules for training all program
integrity analysts intended to use One PI;
* establish and communicate deadlines for program integrity
contractors to complete training and use One PI in their work;
* conduct training in accordance with plans and established deadlines
to ensure schedules are met and program integrity contractors are
trained and able to meet requirements for using One PI;
* define any measurable financial benefits expected from the
implementation of IDR and One PI; and:
* with stakeholder input, establish measurable, outcome-based
performance measures for IDR and One PI that gauge progress toward
meeting program goals.
In commenting on a draft of our report, CMS agreed with these
recommendations and indicated that it plans to take steps to address
the challenges and problems that we identified during our study.
In summary, CMS's success toward meeting its goals to enhance program
integrity will depend upon the agency's incorporation of all needed
data into IDR as well as the effective use of the systems by the
agency's broad community of program integrity analysts. In addition, a
vital step will be the identification of measurable financial benefits
and performance goals expected to be attained through improvements in
the agency's ability to prevent and detect fraudulent, wasteful, and
abusive claims and resulting improper payments. In taking these steps,
the agency will better position itself to determine whether these
systems are useful for enhancing CMS's ability to identify fraud,
waste, and abuse and, consequently, reduce the loss of funds resulting
from improper payments of Medicare and Medicaid claims.
Mr. Chairman, this concludes my prepared statement. I would be pleased
to answer any questions you or other Members of the Subcommittee may
have.
GAO Contacts and Staff Acknowledgments:
If you have questions concerning this statement, please contact Joel
C. Willemssen, Managing Director, Information Technology Team, at
(202) 512-6253 or willemssenj@gao.gov; or Valerie C. Melvin, Director,
Information Management and Human Capital Issues, at (202) 512-6304 or
melvinv@gao.gov. Other individuals who made key contributions include
Teresa F. Tucker (Assistant Director), Sheila K. Avruch (Assistant
Director), April W. Brantley, Clayton Brisson, Neil J. Doherty, Amanda
C. Gill, Nancy Glover, Kendrick M. Johnson, Lee A. McCracken, Terry L.
Richardson, Karen A. Richey, and Stacey L. Steele.
[End of section]
Footnotes:
[1] Medicaid is a joint federal-state program for certain low-income
individuals.
[2] The One PI portal is a Web-based user interface that enables a
single login through centralized, role-based access to the system.
[3] GAO, Fraud Detection Systems: Centers for Medicare and Medicaid
Services Needs to Ensure More Widespread Use, [hyperlink,
http://www.gao.gov/products/GAO-11-475] (Washington, D.C.: June 30,
2011).
[4] Medicare Part A provides payment for inpatient hospital, skilled
nursing facility, some home health, and hospice services, while Part B
pays for hospital outpatient, physician, some home health, durable
medical equipment, and preventive services. Further, all Medicare
beneficiaries may purchase coverage for outpatient prescription drugs
under Medicare Part D.
[5] GAO, Medicare Automated Systems: Weaknesses in Managing
Information Technology Hinder Fight Against Fraud and Abuse,
[hyperlink, http://www.gao.gov/products/GAO/T-AIMD-97-176]
(Washington, D.C.: September 29, 1997). At the time of this report,
CMS was known as the Health Care Financing Administration.
[6] GAO, Secure Border Initiative: DHS Needs to Reconsider Its
Proposed Investment in Key Technology Program, [hyperlink,
http://www.gao.gov/products/GAO-10-340] (Washington, D.C.: May 5,
2010) and DOD Business Systems Modernization: Planned Investment in
Navy Program to Create Cashless Shipboard Environment Needs to be
Justified and Better Managed, [hyperlink,
http://www.gao.gov/products/GAO-08-922] (Washington, D.C.,: Sept. 8,
2008).
[7] OMB, Guide to the Performance Assessment Rating Tool.
[End of section]
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Washington, D.C. 20548:
