Inspector General's Assessment of Management and Performance Challenges
Deputy Inspector General,
The Reports Consolidation Act of 2000 requires that the Department's Performance and Accountability Report include a statement by the Inspector General that summarizes the most serious management and performance challenges facing the Department and briefly assesses the progress in addressing them. The Office of Inspector General (OIG) considers the most serious management and performance challenges for the Department to be in the following areas:
- Protection of People and Facilities
- Contract and Procurement Management
- Information Security and Management
- Financial Management
- Military to Civilian-Led Transitions-Iraq and Afghanistan
- Foreign Assistance Coordination and Oversight
- Public Diplomacy
- Consular Operations
1. Protection of People and Facilities
Protecting Department employees and facilities overseas remains a significant management challenge. An OIG audit of five high-threat overseas posts found that they were not always in compliance with physical and procedural security standards.1 A separate audit examined whether selected embassies in Africa complied with current physical security standards.2 Here too, OIG identified common physical and procedural security deficiencies. Some deficiencies occurred because embassies did not receive the resources necessary to address known deficiencies while awaiting relocation to new embassy compounds, leaving them vulnerable for three or more years during construction. In addition, OIG found that some personnel were permanently located in off-compound facilities that did not meet physical security standards.
The tragic loss of life in Benghazi underscored a significant challenge the Department faces when considering when to open and close diplomatic facilities and whether to maintain diplomatic facilities in certain locations at all. When assessing risk, the Department must consider not only the benefit of having a presence, but also the threat environment, mitigating measures and cost, and the willingness and ability of the host nation to provide security support under terms of the Vienna Convention. Recent OIG recommendations highlight this challenge.3
The Department established a High Threat Post (HTP) directorate in the Bureau of Diplomatic Security. The Department will need to review continually the designation of HTPs, noting emergent conditions that significantly change the risk of operating there. Identifying high-threat posts is not enough, however. The Department also needs to accelerate security upgrades at high-threat posts. Several OIG reports over the past decade recommended needed physical security upgrades; the Department has implemented some but not all of these recommendations.
2. Contract and Procurement Management
The Department continues to face challenges with the proper management, oversight, and accountability of contracts and procurements, including grants and cooperative and interagency agreements.
Department procurement activities, which increased from $1.8 billion in FY 2001 to $8.2 billion in FY 2012, are largely directed by the Bureau of Administration, Office of Logistics Management, Office of Acquisitions Management (A/LM/AQM). A/LM/AQM charges bureaus and offices a one-percent fee to administer contracts and grants; a fee intended to provide improved services. OIG found that while A/LM/AQM had used some of these fees as intended,4 at least $26 million was used to subsidize other activities. In addition, A/LM/AQM did not have a mechanism to track procurement goals. Without measuring performance, A/LM/AQM cannot assess whether it is providing improved services.
An OIG audit of Task Order 5 of the Worldwide Protective Services contract in Baghdad determined that the contracting officer's representative (COR) approved contractor invoices totaling $1.8 million that included unallowable, unsupported, or erroneous costs because the COR had not verified the contractor's invoices against supporting documentation or had not verified that contract goods and services had been received. OIG also found that the Department had not analyzed staffing requirements prior to awarding the task order, resulting in extraneous staffing. The Department took action to de-scope the task order, enabling it to save and put to better use approximately $362 million over the life of the contract.5
Proper closeout of grants is the critical final step in the grant life cycle and is an essential part of the grants oversight process. Although the Department had updated and reinforced closeout procedures, OIG found that three bureaus were responsible for 865 of 955 expired grants, totaling $67.4 million in unspent funds that had not been closed. OIG sampled 51 of 865 grants and determined that, if proper closeout procedures were applied, the Department could put $9.4 million in unspent funds to better use.6
OIG inspections continue to find shortcomings in the design and oversight of information technology contracts. In some cases, contractors perform inherently governmental functions. OIG also found instances of poor oversight. For example, FSI used time and materials task orders awarded against five blanket purchase agreements to support its system modernization projects. These task orders reduced the contractors' incentive to perform in a timely manner and to control costs. OIG also found that the Bureau of Information Resources Management, Office of Information Assurance (IRM/IA) lacked adequate controls to monitor its contracts, task orders, and blanket purchase agreements, valued at $79 million.
3. Information Security and Management
The Department still faces difficulties meeting the requirements of the Federal Information Security Management Act of 2002 (FISMA) and implementing a fully effective information security management program. During the FY 2013 FISMA audit, OIG determined that the Department had not effectively implemented the National Institute for Standards and Technology requirements for risk management, continuous monitoring management, account management and remote access, or the FISMA and Office of Management and Budget (OMB) requirements for a Plan of Actions and Milestones process. These conditions have existed over several years and OIG considers the collective security weaknesses a significant deficiency.
In FY 2013, OIG found that the Department had not effectively followed and administered proper classification policies and procedures as required by Executive Order 13526, "Classified National Security Information." Specifically, the Department overstated-by as many as 2.4 million-the classification decisions reported in its annual submission to the National Archives and Records Administration, Information Security Oversight Office.7
OIG's inspections also found weaknesses in the management of information security. IRM/IA, established to address information security requirements outlined in Title III of the E-Government Act of 2002, was not fulfilling all of these requirements. The absence of a single bureau responsible for the information systems security officer program resulted in confusion and led to wasted resources. IRM/IA's mishandling of the certification and accreditation process contributed to expired authorizations to operate 52 of the Department's 309 systems.
The re-emergence of multiple dedicated Internet network connections at overseas missions represents another information security deficiency.8 A few years ago, the Department sought to improve information security by limiting the number of network connections at missions and issuing strict approval procedures for establishing such connections. However, OIG has seen a proliferation of dedicated Internet network connections, including 10 at one mission. These networks introduce additional vectors of attack for those who would seek to compromise U.S. Government networks.
Inspections of the Foreign Service Institute (FSI) and the Bureau of International Information Programs (IIP) highlighted the complexity of systems development.9 At FSI, OIG found weaknesses in project management, contracting, and budgeting, all of which resulted in poor tracking of major application development costs and timelines. FSI did not ensure accountability through use of consistent control gates, decision points, and deliverables for projects ranging in cost from $500,000 to $23 million. Similarly, IIP did not track the cost of developing individual projects and was unable to provide OIG the amount of money spent. IIP also did not define the scope of various projects or user requirements.
Cloud computing is a continuing challenge. Although cloud computing is the Department's second highest information technology goal,10 the Department has not yet made key decisions and promulgated standards related to its implementation. IRM's Systems and Integration Office, the lead office in the Department developing cloud technology, has developed a plan to implement cloud computing requirements by 2014. However, future progress by IRM's Systems and Integration Office depends on strategic and business requirements outlined by Department's senior officials.
4. Financial Management
The Department made progress in resolving financial management concerns but considerable challenges remain. In FY 2012, the Department took steps to address a potentially material issue related to after-employment benefits for locally employed staff that had led to a qualified opinion on its FY 2011 financial statements. These actions resulted in the restatement of FY 2011 Foreign Service National after-employment balances, and the Department received an unqualified opinion on its FY 2012 and FY 2011 financial statements. These corrective actions reduced the risk of significant misstatements, but several deficiencies remained, including an inaccurate list of posts with after-employment plans and inaccurate personnel information. The audit also identified other serious concerns related to financial reporting, property and equipment, budgetary accounting, un-liquidated obligations, and information technology.11
Improper payments represent another management challenge. OIG reported12 that the Department had taken steps to prevent improper payments, such as performing risk assessments for programs with significant changes, developing risk assessment policies, and considering qualitative risk factors. However, the methods the Department used to identify significant changes and to perform qualitative assessments needed improvement. The Department implemented internal controls to prevent, detect, and recapture improper payments and identified $11.1 million in improper payments in FY 2012, but it excluded a significant number of payments from its recapture audits.
OIG inspections determined that the Department has had some success using technology to lower costs. For example, e-mail, travel, procurement, and accounting systems now allow for remote and lower cost voucher processing. The Charleston Global Financial Service Center processes vouchers for $12 per strip code, well below the worldwide average of $34. More missions are using Charleston but OIG continues to identify missions that process their own vouchers even when there are lower cost options.
5. Military to Civilian-led Transitions-Iraq and Afghanistan
The United States completed a transition from a military-led to a civilian-led presence in Iraq in December 2011 and is planning a similar transition in Afghanistan in 2014. The Department needs to apply lessons learned from the Iraq transition to the pending transition in Afghanistan.
Iraq: On January 1, 2012, the Department became solely responsible for the U.S. Mission-Iraq (USM-I) and its associated foreign policy goals, which are designed to foster a sustainable economy and stronger democracy in Iraq. Embassy Baghdad, the Bureau of Near Eastern Affairs, and the Bureau of the Comptroller and Global Financial Services have made substantial progress establishing consulates and other support facilities and sustaining programs and operations. Nonetheless, the Department continues to experience challenges sustaining and rightsizing USM-I as security remains volatile and the Iraqi government's commitment to the U.S. presence and its programs remains unclear for security. In 2012, USM-I required $3.38 billion solely for Iraq operations.13
In August 2013, OIG reported that USM-I had taken and planned significant steps to reduce the U.S. presence in Iraq by closing nine sites and reducing staff by 61 percent, from approximately 16,200 to 6,320.14 In addition, USM-I ended a police development program that the Government of Iraq had not supported, and significantly reduced security assistance and cooperation activities. The process for determining staffing requirements did not include a systematic analysis that fully considered U.S. foreign policy priorities.15 As a result, there is no assurance that the reduced staff of 6,320 would provide the proper number or skill mix of personnel needed to meet priorities while minimizing security risk and optimizing costs.
The Baghdad Master Plan was prepared to guide USM-I when it assumed facilities management responsibilities at military-operated facilities after the transition to a civilian-led mission. However, the plan was based on the continuation of the U.S. presence for approximately 16,200 staff and became obsolete as USM-I reduced its staffing. The Bureau of Overseas Buildings Operations has worked with USM-I to consolidate staff onto existing facilities in Baghdad and Erbil and to address infrastructure needs in Basrah. But the frequent rotation of construction project directors, a lack of consistent oversight, poor contractor performance, delays in material shipments, and weak coordination among projects have negatively affected construction quality and delayed critical security projects.
Afghanistan: The Department continues to face challenges in supporting and sustaining the civilian presence in Afghanistan as the U.S. military withdraws. OIG plans to report on the effectiveness of the Department's and Embassy Kabul's planning for the transition to a reduced U.S. military presence in Afghanistan in October 2013. OIG and the Special Inspector General for Afghanistan Reconstruction have reported that security remains a primary challenge. Low literacy levels and lack of basic vocational skills have hindered the development of the Afghan National Security Forces. The Department continues to face significant costs and security issues related to convoy protection and movement security and monitoring private security contractors. Most Afghanistan Infrastructure Fund projects are experiencing acquisition and funding delays, causing interruptions in project execution schedules. The uncertainty of the size and composition of the Afghan security forces over the next few years could result in inefficient and costly procurements if not closely managed.
A bilateral security agreement, which will outline the status and role of U.S. military forces after the North Atlantic Treaty Organization (NATO) combat mission ends December 31, 2014, has not been completed, and as of August 28, 2013, negotiations for the agreement were suspended. The completion of the agreement is necessary for the mission to plan for both the number and locations of staff outside Kabul since security issues greatly affect provincial operations. The Department will need to react quickly once decisions are made regarding the agreement and post-2014 U.S. or NATO troop levels.
Establishing additional facilities in Afghanistan increases the Department's costs as it becomes responsible for supplies and all services. Adequate oversight and monitoring of funds will be especially important as the transition takes place. In addition, it will become steadily more difficult for both implementing and oversight agencies to monitor projects in Afghanistan, even as the United States plans to increase direct assistance to Afghanistan.
6. Foreign Assistance Coordination and Oversight
The Department continues to face obstacles in oversight and coordination of foreign assistance. OIG continues to find opportunities to coordinate assistance programs better.16 For example, the U.S. Special Envoy for Sudan and South Sudan does not routinely coordinate its $10 million in programs with the embassy and other agencies. It is therefore unclear whether the programs duplicate or complement other programs in country valued at $1.2 billion. In Kyiv, there is no consolidated tally of U.S. Government spending on nonproliferation and related assistance. Assistance coordination in Rabat and Baghdad need strengthening. At some missions,17 ambassadors make a concerted effort to inventory and coordinate all assistance programs. Although the Office of U.S. Foreign Assistance Resources' goal of coordinating all assistance programs has yet to be achieved, a recent OMB bulletin directing all agencies to report on their foreign assistance programs should further this effort.18 The Office of U.S. Foreign Assistance Resources continues to improve a tracking system designed to inventory all State and USAID programs.
Identifying officers with the skills needed to oversee assistance programs has proven challenging. At four missions in 2013,19 OIG found that officers overseeing foreign assistance did not have appropriate training or required certifications. Insufficient staffing prevented Embassies Juba and Khartoum from properly monitoring refugee and other humanitarian programs.20 Embassy Baghdad failed to verify that Iraqi government employees attending Department-funded antiterrorism training remained in their positions for a minimum of two years, a condition designed to ensure that the $5 million in annual antiterrorism assistance builds host-country capacity. Four additional inspections recommended the Department develop more effective assistance monitoring plans.21
The Department has taken steps to better monitor and evaluate foreign assistance. In 2012, it issued guidance requiring bureaus to conduct periodic evaluations of their highest cost programs. In 2013, the Department awarded a contract to facilitate these evaluations. The Department also issued guidance requiring that certified grant officer representatives oversee all grants worth more than $100,000.22
Budget cuts, likely to continue in the future, highlight the importance of designing sustainable assistance programs. A number of OIG reports address this challenge.23 In Khartoum, activities to further women's peace and security are unlikely to continue when U.S. funding runs out, significantly reducing the impact of this $470,000 grant. In Abuja, where the United States provided almost $480 million in AIDS assistance in 2012, the Nigerian government is not on track to meet funding commitments it made. In Baghdad, OIG noted that only three of 29 projects included cost-sharing provisions.
7. Public Diplomacy
Public diplomacy is an important diplomatic tool and is increasingly using social media. While the Department has embraced social media (all missions employ social media through Facebook, Twitter, or other media), more oversight is needed. OIG continues to find missions and bureaus that focus too much on raising fan numbers or general engagement statistics rather than specific public diplomacy goals.24 The Bureau of International Information Programs spent $630,000 on two campaigns that succeeded in increasing the number of its English Facebook page fans. OIG found the bureau could reduce spending and increase its strategic impact by focusing advertising on specific public diplomacy goals. The Department's social media working group has recognized this challenge and endorsed "judicious and targeted use of paid advertising."25 Recent guidance advocates "selective use of social media advertising" in a "strategically planned, well-targeted" campaign with preset goals and evaluation.26
A number of missions, bureaus, and functional bureaus use social media to discuss the same event. OIG raised concerns about duplication, cost effectiveness, and policy coordination. For example, in 2011 OIG recommended the Department clarify roles and responsibilities of various bureaus in clearing social media content.27 The Department has not yet clarified these responsibilities.28
Management oversight of exchange visitor programs, especially the Summer Work Travel program, is a continuing challenge and a significant deficiency. The Bureau of Educational and Cultural Affairs has taken steps to provide better oversight.29 OIG recommended additional measures in 201330 including requiring U.S. sponsors to disclose all sponsor fees charged to exchange visitors; conduct an annual independent audit of sponsors of all J visa programs; and submit a proposal to the Deputy Secretary of State for Management and Resources to determine the viability of ending or transferring its responsibility for physician, au pair, intern, teacher, and trainee categories.
8. Consular Operations
Demand for American visas has increased dramatically and slow visa processing can be detrimental to bilateral relations. Because of the positive impact foreign visitors have on U.S. travel and tourism industries, President Obama instructed the Department to increase its non-immigrant visa (NIV) processing capacity in Brazil and China by 40 percent over the ensuing year, and to ensure that 80 percent of NIV applicants were interviewed within three weeks of receipt of an application.31 OIG inspected both operations. Embassy Brasilia met the President's goals by increasing staffing using first and second-tour officers and the limited non-career appointment (LNA) mechanism that hires language-qualified officials for 18-month periods.32 The LNA mechanism allowed Embassy Brasilia to increase its workforce quickly and could prove helpful if immigration legislation is passed that requires additional visa adjudicators. Embassy Moscow has sufficient staff and resources to meet its visa workload, but has not met the three-week goal because consular managers have not adequately trained staff or monitored operations.33
The Department recently awarded a worldwide contract, valued at $2.8 billion over 10 years, to provide visa applicants with information, make appointments, collect biometrics and fees, and deliver documents. The contract is designed to improve customer service.34 In Brazil, where contract payments could reach $186 million over six years, OIG found consular managers do not have access to contract documents and therefore cannot determine whether contractors were meeting service standards.35
Maintaining excellence in the Department's top leadership positions remains a challenge. OIG identified significant leadership problems in two domestic bureaus in 2013. In the Bureau of International Information Programs, the front office created an atmosphere that lead to poor policy implementation, low morale, and wasteful practices, including potential problems with more than half the front office's travel vouchers.36 The Bureau of Information Resource Management, Office of Information Assurance was not fulfilling its role of providing effective oversight of cybersecurity.37
OIG's FY 2013 overseas inspections generally found positive leadership but also identified deficiencies including failure to communicate goals, lack of feedback, and micromanagement.38 In 2010 and 2012,39 OIG sent memoranda to the Department aimed at improving mission leadership. The 2012 report stated that, while most ambassadors and deputy chiefs of mission were performing well, approximately 25 percent had weaknesses that negatively impacted effectiveness and morale. OIG recommended the Department institute a system to assess performance that included (1) a confidential survey of staff and (2) a provision that assistant secretaries follow up with corrective actions. Department officials are piloting such a system in the Bureau of South and Central Asian Affairs.40 Such a system is particularly important because OIG inspection teams no longer produce evaluation reports on Department leaders during routine inspections.
OIG continues to find examples of the Department assigning tasks to overseas personnel when those tasks could be performed less expensively from the United States. Consequently, more employees and their families face security risks associated with being overseas. Annual costs for overseas positions average $232,000 more per person than domestic positions; establishing a new position overseas costs $361,547 more than establishing a new position domestically.41
In 2012, OIG found regional positions that the Department could eliminate or place in the United States or a more cost-effective location.42 For example, 99 regional information management officer positions are located overseas to provide services requiring an immediate response. However, the majority of support they provide is routine or could be provided remotely from the United States. OIG recommended reducing these information management positions by 80 percent, which could yield more than $18 million annual cost savings. More importantly, the reductions could limit the risk to employees, including the eight posted to Cairo. Regional procurement agent salaries in Frankfurt are among the highest in the world; relocating those functions to a lower cost mission could save $1 million annually.
The OIG found no compelling reasons to maintain a consulate in Casablanca, less than 60 miles from Embassy Rabat. Embassy Rabat could absorb the workload and five positions could be eliminated, for a savings of more than $2.5 million per year. The Department could also forgo construction of a new consulate building in Casablanca, estimated at $170 million. OIG has recommended closing a number of consulates over the last five years. Reviewing potential consulate closures is a task associated with the Quadrennial Diplomacy and Development Review (QDDR) goal of "Working Smarter."43 A list of potential consulate closures is under review in the Deputy Secretary's office.44
1 Audit of Department of State Compliance With Physical and Procedural Security Standards at Selected High Threat Level Posts (AUD-SI-13-32, June 2013). (back to text)
2 Audit of Department of State Compliance with Physical Security Standards at Selected Posts within the Bureau of African Affairs (AUD-HCI-13-40, September 2013). (back to text)
3 Special Review of the Accountability Review Board Process (ISP-I-13-44A) (ISP-S-13-44A). (back to text)
4 Audit of Department of State Application of the Procurement Fee to Accomplish Key Goals of Procurement Services (AUD-FM-13-29, May 2013). (back to text)
5 Audit of Bureau of Diplomatic Security Worldwide Protective Services Contract - Task Order 5 for Baghdad Movement Security (AUD-MERO-13-25, March 2013). (back to text)
6 Audit of Grant Closeout Processes for Selected Department of State Bureaus (AUD-CG-13-31, June 2013). (back to text)
7 Evaluation of Department of State Implementation of Executive Order 13526, Classified National Security Information (AUD-SI-13-22, March 2013). (back to text)
8 Dedicated Internet Networks are non-OpenNet Plus connections to the Internet. (back to text)
9 Inspections of the Bureau of International Information Programs (ISP-I-13-28) and the Foreign Service Institute (ISP-I-13-22). (back to text)
10 Department of State IT Strategic Plan, Fiscal Years 2011-2013. (back to text)
11 Independent Auditor's Report on the U.S. Department of State 2012 and 2011 Financial Statements (AUD-FM-13-08, November 2012). (back to text)
12 Audit of Department of State FY 2012 Compliance With Improper Payments Requirements (AUD-FM-13-23, March 2013). (back to text)
13 Audit of the U.S. Mission Iraq Staffing Process (AUD-MERO-13-33, August 2013). (back to text)
14 Ibid. (back to text)
15 Inspection of Embassy Baghdad and Constituent Posts (ISP-I-13-25A). (back to text)
16 Inspections of Embassies Juba, South Sudan (ISP-I-13-29A), Kyiv, Ukraine (ISP-I-13-45A), Rabat, Morocco (ISP-I-13-30A), and Baghdad, Iraq (ISP-I-13-25A). (back to text)
17 Inspection of Embassy Phnom Penh, Cambodia (ISP-I-13-08A). (back to text)
18 Inspection of the Office of the Director of U.S. Foreign Assistance (ISP-I-11-57), 1 FAM 033, March 2006 National Security Strategy; OMB Bulletin 12-01, Guidance on Collection of Foreign Assistance Data. (back to text)
19 Inspections of Embassies Baghdad, Iraq (ISP-I-13-25A), Bangui, Central African Republic (ISP-I-13-13A), Kyiv, Ukraine (ISP-I-13-45A), and Moscow, Russia (ISP-I-13-48A). (back to text)
20 Inspections of Embassies Khartoum, Sudan (ISP-I-13-37A) and Juba, South Sudan (ISP-I-13-29A). (back to text)
21 Inspections of the Office to Monitor and Combat Trafficking in Persons (ISP-I-12-37), Office of the Global AIDS Coordinator (ISP-I-13-47), and Embassies Manila, Philippines (ISP-I-13-10A) and Baghdad, Iraq (ISP-I-13-25A). (back to text)
22 Grants Policy Directive Number 16, Revision 3. (back to text)
23 Inspections of Embassies Bangui, Central African Republic (ISP-I-13-13A), Abuja, Nigeria (ISP-I-13-16A), and Baghdad, Iraq (ISP-I-13-25A). (back to text)
24 Inspection of the Bureau of International Information Programs (ISP-I-13-28). (back to text)
25 Social Media Working Group Report, November 23, 2012, Memo for Tara Sonenshine. (back to text)
26 13 State 06411 Social Media Guidance Cable #1: Social Media Advertising. (back to text)
27 Inspection of the Bureau of Near Eastern Affairs (ISP-I-11-49A). (back to text)
28 Report of the Social Media Working Group, DTD November 2012. (back to text)
29 Compliance Follow-up Review, Bureau of Educational and Cultural Affairs (ISP-C-13-51). (back to text)
30 Ibid. (back to text)
31 Executive Order 13597. (back to text)
32 Inspection of Embassy Brasilia and Constituent Posts, Brazil (ISP I-13-40A). (back to text)
33 Inspection of Embassy Moscow and Constituent Posts, Russia (ISP-I-13-48A). (back to text)
34 Ibid. (back to text)
35 Inspection of Embassy Brasilia and Constituent Posts, Brazil (ISP-I-13-40A). (back to text)
36 Inspection of the Bureau of International Information Programs (ISP-I-13-28). (back to text)
37 Inspection of the Bureau of Information Resource Management, Office of Information Assurance (ISP-I-13-38). (back to text)
38 Inspections of Embassies Khartoum, Sudan (ISP-I-13-37A), Rabat, Morocco (ISP-I-13-30A), and Bangui, Central African Republic (ISP-I-13-13A). (back to text)
39 Implementation of a Process to Assess and Improve Leadership and Management of Department of State Posts and Bureaus (ISP-I-10-68), Improving Leadership at Posts and Bureaus (ISP-I-12-48). (back to text)
40 Improving Leadership at Posts and Bureaus (ISP-I-12-48) and Compliance Analysis 13 MDA 7772. (back to text)
41 Inspection of Regional Information Management Centers (ISP-I-13-14), The Bureau of Budget and Planning's FY 2014 New Position Cost Model. (back to text)
42 Inspections of Regional Information Management Centers (ISP-I-13-14), Regional Procurement Support Offices, Frankfurt, Germany, and Fort Lauderdale, United States (ISP-I-13-34), and Regional Support Center Frankfurt, Germany (ISP-I-13-32). (back to text)
43 Appendix I of the 2011 QDDR Implementation Guidance related to "Working Smarter". (back to text)
44 July 25, 2012 compliance correspondence related to ISP-I-11-64A. (back to text)