Background The Veterans Access, Choice, and Accountability Act of 2014 provided up to $10 billion in funding for veterans to obtain health care services from community providers through the Choice Program when veterans faced long wait times, lengthy travel distances, or other challenges accessing care at VA medical facilities. The temporary authority and funding for the Choice Program was separate from other previously existing programs through which VA has the option to purchase care from community providers. Legislation enacted in April, August, and December of 2017 and June 2018 extended the Choice Program and provided an additional $9.4 billion for the Veterans Choice Fund. Authority for the Choice Program will sunset on June 6, 2019. Responsibilities of the Choice Program’s Third Party Administrators In October 2014, VA modified its existing contracts with two contractors— referred to as third party administrators (TPA)—that were administering another VA community care program to add certain administrative responsibilities associated with the Choice Program. For the Choice Program, each of the two TPAs—Health Net and TriWest—was responsible for managing networks of community providers who deliver care in a specific multi-state region. Specifically, the TPAs were responsible for establishing networks of community providers, scheduling appointments with community providers for eligible veterans, and paying community providers for their services. Health Net’s contract for administering the Choice Program ended on September 30, 2018, with TriWest continuing to administer the Choice Program in its region and the region previously administered by HealthNet until the program ends. Process for Choice Program Appointment Scheduling Through policies and standard operating procedures for VA medical facilities and contracts with the TPAs, VA established processes for referring and scheduling appointments through the Choice Program: one process for time-eligible veterans and another for distance-eligible veterans. Table 1 provides an overview of the appointment scheduling process that applies when a veteran is referred to the Choice Program because the veteran is time-eligible—that is, the next available medical appointment with a VA clinician is more than 30 days from the veteran’s preferred date or, in the absence of such a date, the date the veteran’s physician determines he or she should be seen. When veterans reside more than 40 miles from a VA medical facility or meet other travel-related criteria, VA uses the appointment scheduling process it developed for distance-eligible veterans. The process for distance-eligible veterans differs from that for time-eligible veterans in that VA medical facilities do not prepare a referral and send it to the TPA. Instead, distance-eligible veterans contact the TPA directly to request Choice Program care. Choice Program Claim Processing and Payment VA’s Choice Program TPA processes claims it receives from community providers for the care they deliver to veterans and pays providers for approved claims. Figure 1 provides an overview of the steps the TPA follows for processing claims and paying community providers. To be reimbursed for its payments to providers, the TPA in turn submits electronic invoices—or requests for payment—to VA. The TPA generates an invoice for every claim it receives from community providers and pays. VA reviews the TPA’s invoices and either approves or rejects them. Invoices may be rejected, for example, if care provided was not authorized. Approved invoices are paid, whereas rejected invoices are returned to the TPA. Under the Prompt Payment Act, VA is required to pay its TPAs within 30 days of receipt of a clean Choice Program invoice. VA’s Planned Veterans Community Care Program The VA MISSION Act of 2018, among other things, requires VA to establish a permanent community care program no later than 1 year after passage of the Act (June 6, 2019) and authorizes VA to utilize a TPA for claims processing. VA refers to the consolidated program as the VCCP. In December 2016, prior to enactment of the VA MISSION Act of 2018, VA issued a request for proposals for contractors to help administer the VCCP. The VCCP will be similar to the current Choice Program in certain respects. For example, under the VCCP, TPAs will be responsible for establishing regional networks of community providers and processing and paying those providers’ claims. However, unlike the Choice Program, under the VCCP, VA is planning to have medical facilities—not the TPAs—generally be responsible for scheduling veterans’ appointments with community providers. VA awarded contracts for administering the VCCP in three of six regions on December 28, 2018. As of April 3, 2019, VA had not yet awarded contracts for the remaining three regions. Generally, all veterans enrolled in the VA health care system would be able to qualify for care through the VCCP when (1) VA does not offer the care or service required by the veteran; (2) the veteran resides in a state without a full-service VA medical facility; (3) the veteran would have been eligible under the 40-mile criterion of the Choice Program before June 6, 2018; (4) VA cannot provide the veteran with care and services that comply with its designated access standards; or (5) the veteran and the veteran’s referring clinician agree that it is in the best interest of the veteran to receive care in the community. In January 2019, VA proposed new access standards for the VCCP based on average drive times and wait times: For primary care, mental health, and non-institutional extended care services, VA is proposing a 30-minute average drive time standard. For specialty care, VA is proposing a 60-minute average drive time standard. VA is proposing appointment wait-time standards of 20 days for primary care, mental health care, and non-institutional extended care services, and 28 days for specialty care from the date of request with certain exceptions. Eligible veterans who cannot access care within those standards would be able to choose between eligible community providers and care at a VA medical facility. VA expects to issue the final regulation establishing access standards for the VCCP by June 2019. VA Needs to Address Various Factors That Adversely Affected Veterans’ Access to Care through the Choice Program to Help Ensure Timely Care under the VCCP In June 2018, we reported that numerous factors adversely affected veterans’ timely access to care through the Choice Program and could affect implementation of the VCCP. These factors included the following: (1) administrative burden caused by complexities of VA’s referral and appointment scheduling processes; (2) poor communication between VA and its medical facilities; and (3) inadequacies in the networks of community providers established by the TPAs, including an insufficient number, mix, or geographic distribution of community providers. VA has taken steps to help address these factors; however, not all access factors have been fully addressed. For example, to help address administrative burden and improve the process of coordinating veterans’ Choice Program care, VA established a secure e-mail system and a mechanism for TPAs and community providers to remotely access veterans’ VA electronic health records. However, these mechanisms only facilitate a one-way transfer of necessary information. They do not provide a means by which VA medical facilities or veterans can view the TPAs’ step-by-step progress in scheduling appointments or electronically receive medical documentation associated with Choice Program appointments. We made five recommendations to VA to address the factors that adversely affected veterans’ access to Choice Program care. VA agreed or agreed in principle with all five recommendations. Our recommendations and the steps, if any, VA has taken in response to these recommendations are described in table 2. VA Needs Complete and Reliable Data to Effectively Monitor Veterans’ Access to Care under the VCCP In June 2018, we reported that VA cannot systematically monitor the timeliness of veterans’ access to Choice Program care because it lacks complete, reliable data to do so. VA will need to address these data limitations in order to effectively monitor the care delivered to veterans through the VCCP. The data limitations we identified included the following: A lack of data on the timeliness of accepting referrals and opting veterans in to the program. We found that the data VA uses to monitor the timeliness of Choice Program appointments do not capture the time it takes VA medical facilities to prepare veterans’ referrals and send them to the TPAs, nor do they capture the time spent by the TPAs in accepting VA medical facilities’ referrals and opting veterans in to the Choice Program. VA had implemented an interim solution to monitor overall wait times that relies on VA medical facility staff consistently and accurately entering unique identification numbers on VA clinicians’ requests for care and on Choice Program referrals, a process that is prone to error. Inaccuracy of clinically indicated dates. We found that clinically indicated dates (used to measure the timeliness of care) are sometimes changed by VA medical facility staff before they send Choice Program referrals to the TPAs, which could mask veterans’ true wait times. We found that VA medical facility staff entered later clinically indicated dates on referrals for about 23 percent of the 196 authorizations we reviewed. It is unclear if VA medical facility staff mistakenly entered incorrect dates manually, or if they inappropriately entered later dates when the VA medical facility was delayed in contacting the veteran, compiling relevant clinical information, and sending the referral to the TPA. Unreliable data on the timeliness of urgent care. We found that VA medical facilities and TPAs do not always categorize Choice Program referrals and authorizations in accordance with the contractual definition for urgent care. According to the contracts, a referral is to be marked as “urgent,” and an appointment is to take place within 2 business days of the TPA accepting it, when a VA clinician has determined that the needed care is (1) essential to evaluate and stabilize the veteran’s condition, and (2) if delayed would likely result in unacceptable morbidity or pain. We reviewed a sample of 53 urgent care authorizations and determined that about 28 percent of the authorizations were originally marked as routine care authorizations but were changed to urgent by VA medical facility or TPA staff, in an effort to administratively expedite appointment scheduling. We made five recommendations to VA on improving the completeness and accuracy of data on veterans’ wait times for care. VA agreed with four of the five recommendations. Our recommendations and the steps VA has taken in response to these recommendations are described in table 3. Further Improvements Are Needed to Help Ensure Timely Payments to Community Providers In September 2018, we reported that three key factors affected timeliness of payments to community providers under the Choice Program and that if unaddressed could affect provider payment timeliness for the VCCP. These factors included the following: (1) VA’s untimely payments to TPAs, which in turn extended the length of time TPAs took to pay community providers’ claims; (2) Choice Program reimbursement requirements, which led to claim denials; and (3) inadequate provider education on filing claims. We reported that VA has taken some actions to address these factors. For example, VA updated its payment system and related processes to pay TPAs more quickly. According to VA data, as of July 2018, VA was paying at least 90 percent of the TPAs’ invoices within 7 days, a significant increase from the 50 percent timely payments VA made to TPAs between November 2014 and September 2016. In addition, VA and the TPAs had taken steps to amend certain reimbursement requirements and improve provider education to help providers resolve claims processing issues. However, we found that VA has not fully addressed two of these factors. First, with respect to reimbursement requirements, VA does not have complete data allowing it to effectively monitor adherence with its policy for VA medical facilities to perform timely reviews and approvals of secondary authorization requests. Community providers request secondary authorization requests when veterans need health care services that exceed the period or scope of the original authorization. Incomplete data impacted VA’s ability to meet the requirement. When VA medical facilities delay these reviews and approvals, community providers may have to delay care or deliver care that is not authorized, which in turn increases the likelihood that the providers’ claims will be denied and the providers will not be paid. Second, with respect to provider education on filing claims, VA requires the TPAs to establish a customer call center to respond to calls from veterans and non-VA providers. However, VA does not enforce the contractual requirement for responding to calls from community providers and allows the TPAs to prioritize calls from veterans over calls from community providers. Consequently, VA is not collecting data, monitoring, or enforcing compliance with its contractual requirements for the TPAs to provide timely customer service to providers. As a result, VA does not have information on the extent to which community providers face challenges when contacting the TPAs about claims payment issues, which could contribute to the amount of time it takes to receive reimbursement for services. To address remaining factors that affect provider payment timeliness, we made two recommendations to VA. VA agreed with both recommendations. Our recommendations and the steps VA has taken in response to these recommendations are described in table 4. In summary, consolidating its existing community care programs into the VCCP and launching this new program in June 2019 is a large and complex undertaking, which comes with many risks and challenges for VA. Heeding the lessons learned from its implementation and management of the Choice Program will better position VA to ensure veterans receive timely access to care under the VCCP and avoid past challenges such as delays in scheduling appointments and untimely payments to community providers. Continued oversight of VA’s implementation of the VCCP will be critical given the scale of change and the associated risks. We stand ready to assist this Committee with this continued oversight. Chairman Isakson, Ranking Member Tester, and Members of the Committee, this concludes my prepared statement. I would be pleased to respond to any questions you may have. GAO Contacts and Staff Acknowledgments If you or your staff members have any questions concerning this testimony, please contact me at (202) 512-7114 or silass@gao.gov. Contact points for our Office of Congressional Relations and Public Affairs may be found on the last page of this statement. Other individuals who made key contributions to this testimony include Marcia Mann (Assistant Director), Michael Zose (Analyst-in-Charge), Jacquelyn Hamilton, Christina Ritchie, Kate Tussey, and Emilie Weisser. This is a work of the U.S. government and is not subject to copyright protection in the United States. The published product may be reproduced and distributed in its entirety without further permission from GAO. However, because this work may contain copyrighted images or other material, permission from the copyright holder may be necessary if you wish to reproduce this material separately.


Background The boards that oversee the Social Security and Medicare trust funds are technically separate entities under the Social Security Act, but the same set of trustees have served as board members for each trust fund and the boards meet concurrently. For each board, four of the trustees are ex officio, i.e. members by virtue of their office and position: the Secretary of the Treasury, Secretary of Labor, Secretary of Health and Human Services, and the Commissioner of Social Security. The remaining two trustees are members of the public, nominated by the President, confirmed by the Senate, and the public trustees must not be from the same political party as one another. The public trustee positions were established in 1983; they have been vacant since 2015. The boards issue two separate Trustees reports each year, one on the Social Security trust funds and one on the Medicare trust funds. Under the Social Security Act, these reports are due by April 1 of each year. The Trustees reports provide information on the present and projected statuses of the trust funds, including their projected balances over the next 10 years (short-term), the next 75 years (long-term), and the assumptions and methods used to make these projections. The reports provide estimates of the projected costs and incomes of the trust funds, and any dates that the boards project the trust funds’ reserves to become depleted, among other information about the programs. Because projections are inherently uncertain, the reports include three projection scenarios: intermediate, low-cost, and high-cost alternatives, along with other information about uncertainty. The intermediate scenario is based on assumptions that reflect the boards’ best estimate of future experience. The low-cost scenario makes assumptions that are relatively more favorable with respect to the projected statuses of the trust funds, while the high-cost scenario does the opposite. For example, the low-cost scenario assumes more workers will pay into the trust funds and fewer beneficiaries will receive benefits, while the high-cost scenario assumes fewer workers and more beneficiaries. Agency Officials and Trustees Follow a Collaborative Process Each Year to Develop the Trustees Reports Agency Officials and Trustees Determine the Economic, Demographic, and Programmatic Assumptions Prior to Drafting the Trustees Reports Officials in the Social Security Administration Office of the Chief Actuary (SSA OCACT) and the Centers for Medicare & Medicaid Services Office of the Actuary (CMS OACT) work with other agency officials and trustees to develop assumptions and draft and revise the Trustees reports in an annual cycle, according to agency officials and the board meeting minutes and report development schedules we reviewed (see fig. 1). At the end of each cycle, the boards have established a working group that is largely responsible for overseeing the day-to-day development of the next year’s report. This working group consists of officials in the four agencies that are led by the ex officio trustees (Treasury, DOL, HHS, and SSA), officials from SSA OCACT and CMS OACT, and the public trustees, when confirmed. All of the working group’s discussions and agreements are subject to the approval of the boards. The Secretary of the Treasury serves as the Managing Trustee and Chairperson of the boards. Treasury staff has historically coordinated the report development process, including organizing the development schedule and hosting the working group and boards’ meetings. The reports are drafted by SSA and CMS. SSA OCACT and CMS OACT officials we interviewed said they work to update the assumptions—both long-term and short-term—they propose as the basis for the trust fund projections in the reports. Assumptions are the demographic, economic, and program-specific factors that the actuaries use to model the future financial status of the trust funds (see appendix I). For each assumption, SSA OCACT and CMS OACT go through a process of updating the values for the 75-year projection period as needed and use those updated values as inputs in their models to project future costs and income for the trust funds. As a part of this process, the working group discusses issues that inform the assumptions proposed by SSA OCACT and CMS OACT. The work on assumptions is divided according to the specializations and expertise of the two actuarial offices, and is developed by staff from a range of disciplines, including actuaries, demographers, and economists. SSA OCACT develops the demographic and economic assumptions that are common to both reports, including rates for fertility, mortality, and growth in gross domestic product. SSA OCACT also prepares the programmatic assumptions for Social Security, such as the numbers of retirement and disability beneficiaries and the anticipated income into the trust funds from payroll taxes. CMS OACT prepares the programmatic assumptions that are specific to Medicare, such as the number of Medicare beneficiaries and expected growth in health care costs. SSA OCACT and CMS OACT officials update assumptions and revise their methodologies based on recent data, if a change is warranted. For example, the 2017 Social Security Trustees report projected an increase in the total fertility rate. Information collected in the subsequent year showed that fertility rates had not risen as expected, so officials reduced the fertility rate assumptions for the 2018 report. SSA OCACT officials told us that they look at both the reasonableness of the assumptions individually and in the aggregate, as some assumptions interrelate. According to agency officials we interviewed, the assumptions generally undergo gradual or no changes from year to year, unless there are significant policy changes. SSA OCACT and CMS OACT also update their models by incorporating more recent data into them. For example, in the 2017 Social Security Trustees report, the model for projecting average age benefit levels of retired worker and disabled worker beneficiaries who are newly entitled to benefits used a sample of these beneficiaries from 2013. In the 2018 report, this model was updated to use a sample from 2015. The Working Group Discusses and Works Toward Consensus on Assumptions The working group considers and works towards consensus on the assumptions proposed by SSA OCACT and CMS OACT. Members of the working group meet periodically to discuss the assumptions and come to an agreement on the values for them. In these meetings, the working group often hears presentations from internal or external experts on specific topics. For example, in one meeting, SSA staff led a presentation and discussion on Disability Insurance, and DOL staff led a presentation and discussion on how globalization might affect long-term economic trends. To inform their discussions, the working group may also review reports from technical panels or invite panel members to discuss their findings and recommendations at a working group meeting. For example, in September 2012, the working group discussed a Medicare technical panel recommendation that the board continue to present alternative projections in which average Medicare spending per beneficiary rises faster than the current law baseline; the working group and board agreed to implement this recommendation. Throughout the working group’s activities, the members representing the ex officio trustees generally serve as a liaison between the trustee for their agency and the working group. When confirmed, public trustees participate directly on the working group. After consideration, the working group finalizes long-term assumptions at a fall board meeting. The long-term assumptions serve as the basis for the short-term assumptions and the 75-year trust fund projections. For each long-term assumption, the boards set the “ultimate value”, i.e. the constant rate or number that is projected to be met in a particular year (within 10 years in most cases) and then continued through the remainder of the 75-year projection period. For example, for the 2019 Trustees reports, the boards set the ultimate value for the annual change in covered earnings as a percent of total labor compensation for each year beginning in 2028 and continuing through 2093. In most cases, according to agency officials we interviewed, the working group achieves consensus on the assumptions before the fall board meeting. However, when the working group is unable to reach consensus, the boards settle any outstanding issues and tend to either make no changes or incremental changes over time to avoid major swings in year-to-year projections, according to some agency officials we interviewed. Once the long-term ultimate values are set by the boards, the working group then discusses the short-term assumptions that bridge the gap between current data and the ultimate values. The working group first considers and works toward agreement on the short-term economic assumptions and then the health assumptions. Short-term economic assumptions can vary during the early years of the projection period. The projection of Medicare’s HI Trust Fund depletion date is based on detailed short-term growth rate assumptions for individual types of Medicare services, such as inpatient hospital care. SSA OCACT and CMS OACT Draft the Trustees Reports Once the assumptions are set, officials at SSA OCACT develop the projections that determine the actuarial status and then draft the Social Security Trustees report, and officials at CMS OACT do the same for the Medicare Trustees report. The reports include information on and values of the assumptions, projected financial statuses of the trust funds and programs, actuarial analyses and estimates, and technical information on the methodologies and projections. In addition, the reports note changes to the assumptions, methodology, and projections from prior reports, and explain the implications for the trust funds. The reports also include statements of opinion by the relevant agency’s Chief Actuary regarding whether the techniques and methodologies used are generally accepted within the actuarial profession and whether the assumptions used and the resulting actuarial estimates are reasonable. The Working Group Comments and Develops Consensus on Reports When the drafts are completed, SSA OCACT and CMS OACT circulate them to the working group for comments and agreement. According to one former public trustee, these comments are mostly related to the presentation of the information, such as word choices, as members have previously agreed to the assumptions. SSA OCACT or CMS OACT officials respond to these comments, and make revisions to the reports in several rounds, engaging with the working group for comment on each new version of the reports. As with the earlier round when the working group worked toward consensus on the assumptions, the working group members that represent the ex officio trustees can brief the trustee from their agency and bring any input back to the working group to help ensure that the trustees agree with the reports. The Boards Approve and Issue Trustees Reports The final drafts of the Trustees reports are presented and approved at the annual spring meeting of the boards. Under the boards’ bylaws, members of the boards must be present at these meetings to approve the reports. During the meeting, agency officials provide an overview of the reports to the trustees and other attendees, and explain changes in the overall projections from the previous year’s reports. For those trust funds with an estimated depletion date, agency officials explain the estimated dates of depletion and the potential implications for beneficiaries. After any discussion, the trustees sign the reports and the boards formally issue them to Congress. Public Trustees Can Play Unique Roles in Developing and Presenting the Trustees Reports Public trustees, when confirmed, play unique roles as members of the boards and also the working group that develops the Trustees reports. Former public trustees we interviewed said their role was to represent the public in the report development process, independent of the ex officio trustees and other agency officials in the administration. To become members of the board, public trustees must be nominated by the President and confirmed by the Senate, and the public trustee cannot both be from the same political party. Those we interviewed stressed the importance of not allowing personal and political opinions to influence their work on the Trustees reports. As a result, according to both agency officials and former public trustees, having public trustees in place lends credibility to the reports. Former public trustees stated that they worked closely with their counterpart public trustee to coordinate their comments and input to the working group. Historically, public trustees sometimes questioned or encouraged changes to some assumptions used in the reports, according to former public trustees and some agency officials. When in place, public trustees regularly attend working group meetings, whereas ex officio trustees do not. According to the former public trustees we interviewed, they saw part of their role as facilitating conversations as leaders and moving the group towards consensus on assumptions. Additionally, former public trustees and some agency officials said trustees are more hesitant to change the assumptions in the reports when there are no public trustees in place, out of concern that any change could be viewed as politically motivated. For example, in 2017 the boards discussed whether or not to change the long-range real interest rate assumption from the rate used in the previous year’s Trustees reports. The boards decided to keep the assumptions unchanged, in part because there were no public trustees in place. When they are in place, public trustees can also help communicate the message of the Trustees reports to policy makers and the public. As an example, the Trustees reports can be technical and difficult to understand; to address this, the public trustees introduced a summary of the reports in 1991, which presented the reports’ findings in a way that is more accessible to the general public. Former public trustees said they were able to inform policy makers on the contents of the reports through congressional testimony and direct conversations with congressional staff. One former public trustee reported that he was a resource for the media, spending hours on the phone providing his perspective and explaining the reports’ implications for policy decisions. In addition, public trustees published a separate message that allowed them to present what they believe to be the main idea of the reports. The Boards Have Frequently Missed the Statutory Deadline and Have Not Effectively Managed the Report- Development Schedule Trustees Reports Have Been Issued Late in Part to Allow More Time for Updating Reports and Due to Scheduling Issues The boards issued the Trustees reports to Congress after the April 1 statutory deadline in 17 of the 25 years from 1995 to 2019, including every year from 2009 through 2019 (see fig. 2). Since 2009, the boards have issued the reports at least 2 months late six times; they only issued the reports this late one time in the 14 years from 1995 to 2008. Agency officials and former public trustees provided a number of reasons why the Trustees reports have been late in recent years. Agency officials and former public trustees said they may delay reports in order to include the impact of late-breaking legislation or policy changes on the assumptions or data. SSA OCACT told us that this decision is based on (1) if the policy change results in substantial changes to assumptions and (2) if the policy change affects a policy that is directly governing a trust fund. For example, agency officials and former public trustees stated that the Patient Protection and Affordable Care Act (PPACA), enacted on March 23, 2010, significantly contributed to the 2010 reports being issued August 5, 2010, over 4 months past the deadline. PPACA significantly affected many of the factors that were the basis for the Medicare Trustees report projections, such as reducing projected Medicare expenditures through various policy changes, including a change to the payment formula for the Medicare Advantage program—the private health plan alternative to traditional Medicare. According to one former public trustee, if the boards had issued a report that did not reflect the changes made by PPACA, it would not have been applicable to the current outlook of the Medicare trust funds and therefore not as useful to Congress and the public. Agency officials have also reported that there have been instances of waiting for more complete or recent data sets to become available before calculating the actuaries’ projections. According to CMS officials, a tradeoff exists between updating data and meeting the deadline. For example, Treasury officials told us that because the working group decided that CMS OACT should not wait for January 2019 Medicare Advantage enrollment data, the 2019 Trustees reports were issued earlier (April 22) than they would have been if they had waited for the complete end of year data, as they had in previous years. Agency officials and public trustees also cited difficulties in scheduling the spring board meetings as a factor that contributed to delays in issuing the Trustees reports. The boards’ bylaws require the annual reports to be adopted by a majority of the trustees who are present and voting. However, sometimes Treasury staff experienced difficulty scheduling the meeting. According to Treasury officials responsible for scheduling the meeting, they generally wait until the first drafts of the Trustees reports are completed before they schedule the spring board meeting to avoid having to reschedule the meeting if the draft reports are provided after the working group’s internal deadline. For the last 15 years (2005-2019), report development schedules from SSA OCACT indicated that the draft reports were provided to the working group after the internal deadline 12 times. In the other 3 years, the report development schedules did not show the actual date that the draft reports were provided. As a result of scheduling the meeting later in the process, Treasury staff has sometimes not been able schedule a meeting that all of the Trustees can attend prior to the statutory deadline of April 1. Other challenges that contribute to delays include government shutdowns and staff having conflicting concurrent responsibilities, according to some agency officials or former public trustees. When the government shut down for 11 business days in October 2013, the board meeting minutes show that it affected the timelines for the 2014 Trustees reports. However, according to HHS, government shutdowns have never materially delayed the release dates for the Trustees reports. Some former public trustees and one agency official we spoke to stated that agency officials involved in the report process sometimes had other duties competing for their time, which could result in delaying their work on the Trustees reports, while other agency officials stated this was not a factor. The Process for Managing the Schedule for Developing the Trustees Reports Does Not Reflect Best Practices Agency officials’ scheduling process is inconsistent with GAO’s guide on best practices for schedule management. Agency officials and former public trustees said they attempted to meet the statutory deadline each year, but did not believe issuing the report after the deadline created serious negative consequences. As a result, agency officials and former public trustees involved with developing the reports in recent years said they developed a schedule designed to meet the deadline knowing it would most likely not be met. Several agency officials and former public trustees described the schedule as “ambitious” and difficult to achieve. If the schedule is unrealistic from the start of the process, and if involved parties view it as an unlikely goal, rather than the expected outcome, then the schedule does not serve as a useful tool for managing the timely development of the Trustees reports. In addition to designing an unrealistic Trustees reports schedule, agency officials did not always document actual progress in meeting scheduled dates or modify the schedule in a way that would allow them to overcome early setbacks. Treasury officials, who organize the schedule for developing the Trustees reports, stated that the initial proposed schedule is updated only once during the report process, after the first drafts of the reports are completed. According to best practices, the schedule should be updated regularly with actual progress and remaining work. Without doing so, it could be difficult to respond to actual events while still meeting set deadlines. Treasury has not regularly archived the final version of the schedule with the dates that milestones were actually met. According to best practices, the final iteration of the schedule that was actually followed should be archived and used to inform and improve future schedules. Treasury officials were able to provide us with the archived, updated schedules for only 6 of the last 25 years, and these schedules were incomplete. While these updated schedules showed the actual dates that the draft reports were provided and the planned dates for later milestones, they did not include the dates for milestones before the draft reports were provided or the actual dates for the later milestones, including the reports’ issuance dates. Further, although the boards have regularly missed the statutory deadline, the initial report-development schedules have not significantly changed in recent years. Based on the proposed schedules for the Trustees reports that are presented in the spring board meeting minutes we reviewed, the initial schedules for each milestone in the report development process, such as obtaining agreement on assumptions or circulating drafts, has not significantly changed in the last 6 years, although the schedules have consistently proven difficult to meet (see table 1). Without recording the actual report production schedule that was followed, participating officials do not have the historical data that would assist them in making meaningful and effective changes to future schedules. Finally, according to best practices, it is important that stakeholders, including decision makers, have access to information on the progress of the project. Agency officials and former public trustees stated that they do not have a policy or practice of informing Congress of delays or changes to the schedules for the Trustees reports, even in years when the board issues the reports months after the deadline. Given this, Congress, the recipient of the Trustees reports, remains uninformed of the reports’ release date or the factors contributing to a delay in any given year. This uncertainty may hinder Congress from planning legislative sessions in advance that would use the findings of the Trustees reports. For example, congressional committees of jurisdiction may be hindered in scheduling hearings on or around the time of the reports’ release date and having access to the latest data from the reports to inform their oversight. Conclusions Trustees and agency officials set out at the start of each report cycle with a schedule to meet the statutory deadline to issue the Social Security and Medicare reports each year by April 1. However, over the past 25 years, they have mostly issued the reports after the deadline. Some of the factors contributing to the boards delivering the reports late may seem reasonable to agency officials and trustees. For example, investing time to make the report consistent with new legislation impacting Social Security or Medicare programs, or waiting for end of year data to be available, may make the report more useful than if it contained older information. However, other factors related to the management of the schedule for developing the reports, such as not formally tracking the reports’ progress or adjusting the schedule based on lessons learned in prior years, may have contributed to delays. Taking steps to improve the management of the report-development schedule would better position the trustees and agency officials to anticipate and plan for scheduling the spring boards meeting and to meet the statutory deadline in future years. Additionally, recognizing that there may continue to be instances in which the issuance of the reports will be delayed, establishing a policy to inform Congress of potential delays and factors contributing to those delays would enhance Congress’s ability to conduct oversight and make decisions about these important programs. Recommendations for Executive Action We are making the following two recommendations to the Secretary of the Treasury: The Secretary of the Treasury, as Chairperson of the Boards of Trustees, should work with the other trustees to take steps—in consultation with the chief actuaries of SSA and CMS—to improve the management of the report development schedule in order to provide the Trustees reports to Congress by the statutory deadline. These steps could include regularly updating the schedule using actual progress and archiving the final iteration of the schedules. (Recommendation 1) The Secretary of the Treasury, as Chairperson of the Boards of Trustees, should work with the other trustees to establish a policy to inform Congressional committees of jurisdiction when the trustees determine that the reports are expected to miss the issuance deadline. This outreach should include 1) the factors that are contributing to delays, and 2) the reports’ expected issuance dates. (Recommendation 2) Agency Comments and Our Evaluation We provided a draft of this report to the Secretary of the Treasury, the Secretary of Health and Human Services, the Secretary of Labor, and the Commissioner of Social Security for review and comment. Treasury and SSA provided formal written comments, and both agencies agreed with our recommendations. (See appendixes II and III.) Treasury, SSA, and HHS provided technical comments, which we incorporated as appropriate. DOL had no comments. As agreed with your office, unless you publicly announce the contents of this report earlier, we plan no further distribution until 30 days from the report date. At that time, we will send copies to the appropriate congressional committees, the Secretary of the Treasury, the Secretary of Health and Human Services, the Secretary of Labor, the Commissioner of Social Security, and other interested parties. In addition, the report will be available at no charge on the GAO website at http://www.gao.gov. If you or your staff have any questions about this report, please contact Elizabeth Curda at (202) 512-7215 or curdae@gao.gov or James Cosgrove at (202) 512-7114 or cosgrovej@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 to this report are listed in appendix IV. Appendix I: Assumptions Discussed in the 2019 Social Security and Medicare Trust Fund Reports Appendix II: Comments from the Department of the Treasury Appendix III: Comments from the Social Security Administration Appendix IV: GAO Contacts and Staff Acknowledgments GAO Contacts Staff Acknowledgments: In addition to the contact named above, Mark Glickman (Assistant Director), Gregory Giusto (Assistant Director), Paul Schearf (Analyst-in- Charge), Christie Enders, and Samuel Gaffigan made key contributions to this report. Additional assistance was provided by Bill Boutboul, Juana Collymore, Robert Dacey, Alex Galuten, Yvette Gutierrez, Janice Latimer, Emei Li, Sheila R. McCoy, Art Merriam, Mimi Nguyen, Stacy Ouellette, Oliver Richard, Joseph Silvestri, Dawn Simpson, Ardith Spence, Almeta Spencer, Frank Todisco, and Walter Vance.


Background The chemical industry relies on the use of natural resources as inputs to make chemical products, and the industry’s outputs, in turn, can have an impact on the environment. The International Trade Administration of the Department of Commerce identifies the chemical industry as one of the largest manufacturing industries in the United States, with more than 10,000 companies producing more than 70,000 products. The term ‘sustainability’ can have many interpretations depending on the context in which it is used. Sustainability may refer to economic, environmental, or social sustainability. Achieving all three—a concept known as the “triple bottom line”—has become a goal of some businesses, including many in the chemical industry. Mitigating the potential negative health and environmental consequences of chemical production requires thoughtful design and evaluation throughout the life cycle of chemical processes and products —that is, a thorough assessment of effects resulting from stages of the life cycle such as sourcing the raw materials, processing raw materials into products, handling and disposal of by-products and industrial waste, product use, and end-of-life disposal or recycling (see fig. 1). Attempting to improve one stage of the life cycle without considering the others runs the risk of moving sustainability problems around rather than solving them. Analyzing the full life cycle of a process or product can reveal benefits as well as trade-offs or unintended consequences of different choices along the way. Legal Framework Consistent with the goals of sustainable chemistry, which include making chemicals in a purposefully more environmentally benign way, several federal requirements and directives address chemical and other risks to public health and the environment. For example, EPA’s ability to effectively implement its mission of protecting public health and the environment is critically dependent on credible and timely assessments of the risks posed by chemicals. Such assessments are the cornerstone of scientifically sound environmental decisions, policies, and regulations under a variety of statutes, such as the Toxic Substances Control Act (TSCA) (as amended), which provides EPA with authority to obtain information on chemicals and to regulate those that it determines pose unreasonable risks; the Safe Drinking Water Act (SDWA) (as amended), which authorizes EPA to regulate contaminants in public drinking water systems; and the Federal Food, Drug, and Cosmetic Act (as amended), which authorizes the Food and Drug Administration to oversee the safety of food, drugs, medical devices, and cosmetics. The Federal Acquisition Regulation generally requires that federal agencies advance sustainable acquisition by ensuring that 95 percent of new contract actions for the supply of products and for the acquisition of services meet certain sustainability goals. Supply, Demand, and Economics Various economic factors influence the development of sustainable products. Consumers are increasingly seeking products that help them reduce their own environmental footprints, and companies are responding by developing products made with safer chemicals and by increasing the use of recycled, biobased, and renewable materials. The supply of such products can be influenced by the costs of production, competitive advantage, and reputational effects. For example, if a more sustainable product or process helps a firm differentiate from another firm and creates a competitive advantage that consumers recognize and value, it will enable firms to create more sustainable products. There are a number of inherent challenges in the market for sustainable products in the industry. For example, substantial upfront costs coupled with uncertainty about consumer demand may be a barrier to entering the market. If the benefits of taking a more sustainable approach are valued by consumers, companies may be able to recoup the higher costs by charging higher prices without reducing demand. However, if the benefits are not easily understood and measureable (e.g., long-term health benefits), or are external to consumers (e.g., broad environmental impacts), then consumers may not be willing to pay higher prices for more sustainable products. In addition to market incentives that encourage firms to produce more sustainable products, government entities can, when appropriate, take actions such as subsidies, award programs, or tax credits, or limits, bans, and taxes. Governments may also provide environmental and health- related information to help guide the choices of consumers, workers, downstream users, and investors. For new markets and investments to be realized, sufficient information is needed on the environmental damage and health hazards that can be associated with some chemicals and the possibilities that exist to develop alternatives that overcome these challenges. Stakeholders Vary in How They Define and Assess the Sustainability of Chemical Processes and Products In February 2018, we reported that stakeholders vary in (1) how they define sustainable chemistry, (2) how they assess sustainability, and (3) which environmental and health factors they considered most important. Most companies that responded to our survey agreed that a standardized set of factors for assessing sustainability would be useful. Definitions of Sustainable Chemistry Stakeholders do not agree on a single definition of sustainable chemistry. In total, we asked 71 representatives of stakeholder organizations how they or their organization defines sustainable chemistry. The most common response we received was that sustainable chemistry includes minimizing the use of non-renewable resources. Other concepts that stakeholders commonly associated with sustainable chemistry included minimizing the use of toxic or hazardous chemicals, considering trade- offs between various factors during each phase of the life cycle, minimizing energy and water use, and increasing biodegradability or recyclability. Based on a review of the literature and stakeholder interviews, we identified several common themes underlying what sustainable chemistry strives to achieve, including: improve the efficiency with which natural resources—including energy, water, and materials—are used to meet human needs for chemical products while avoiding environmental harm; reduce or eliminate the use or generation of hazardous substances in the design, manufacture, and use of chemical products; protect and benefit the economy, people, and the environment using consider all life cycle stages including manufacture, use, and disposal (see fig. 1) when evaluating the environmental impact of a product; and minimize the use of non-renewable resources. Approaches for Assessing Sustainability Stakeholders such as chemical companies, federal agencies, and others use many different approaches for assessing the sustainability of chemical processes and products. While the varying approaches provide flexibility to meet the priorities of the user, the lack of a standardized approach makes it very difficult for customers, decision makers, and others to compare the sustainability of various products to make informed decisions. Some companies and organizations design their own approaches for assessing chemical sustainability and use those approaches to make internal decisions on product design and processing, while others use metrics, chemical selection guides, or third-party certifications and assessment tools that are common to their industry. For example, chemical companies use several established metrics to measure their efficiency in using materials to generate products. The variety of metrics used—and variation in the underlying factors included in their calculation—hinders the ability of companies and others to compare the sustainability of chemical processes or products. In addition to common metrics, some sectors have developed guides that companies and others can use to compare the sustainability of materials used in chemical processes, including solvent selection guides and reagent guides. Solvent selection guides assess solvents based on a variety of sustainability criteria, such as environmental, health, and safety impacts; recyclability; and regulatory concerns. One pharmaceutical company reported a 50 percent decrease in the use of certain hazardous solvents after the introduction of a solvent selection guide. NGOs, federal agencies, and professional associations are also developing product certification programs and assessment tools. Certification programs set minimum criteria that products must meet to be certified, such as biodegradability, toxicity, performance, or water usage. Certifying bodies make databases of certified products publicly available and allow manufacturers to affix certification labels or logos to their products. Environmental and Health Factors Considered Most Important Companies prioritize various environmental and health factors differently when assessing sustainability, according to our survey of 27 companies. We asked respondents to indicate the relative importance their company gives to each of 13 environmental and health factors by comparing a pair of factors and selecting the factor they considered more important to optimize, even if that benefit came at the expense of the other factor. For example, a company might compare “energy use” with “water use” and determine that it was more important to their company to maximize the sustainability benefit relative to the “energy use” of a process even if it resulted in less sustainable use of water. We found that, overall, “toxicity of the product” was the most important factor for the companies surveyed and “percentage of renewable or biobased content” was the least important factor when making trade-offs (see fig. 2). However, there were sizable differences between companies and sectors regarding which factors they considered most important to optimize. For a more detailed description of our analysis, see our report Chemical Innovation: Technologies to Make Processes and Products More Sustainable. The Importance of a Standard Definition and Metrics for Sustainability The literature and the results of our interviews and survey indicate that the lack of a standard definition for sustainable chemistry, combined with the lack of standard ways of measuring or assessing sustainability, hinder the development and adoption of more sustainable chemistry technologies. It is difficult for consumers, purchasers, policymakers, and even manufacturers to compare the sustainability of one process or product with another when such processes and products are assessed using different metrics that incorporate different factors. In addition, while there were sizable differences between the companies that responded to our survey with regard to which environmental and health factors they considered most important to prioritize, most agreed that it would be useful to have a standardized set of factors for assessing sustainability across their industry sector and (to a lesser degree) across the entire industry. Technologies Can Make Chemical Processes and Products More Sustainable There are many technologies available and in development that can improve chemical sustainability at each stage of the chemical life cycle. Our February 2018 report focused on three categories: catalysts, solvents, and continuous processing. Because each chemical process or product has unique requirements, there is no one-size-fits-all solution to sustainability concerns. Catalysts Catalysts are used to make chemical processes run faster or use less material. One common application is the catalytic converter in an automobile, where the catalyst converts pollutant gases in the exhaust into harmless chemicals. Without catalysts, many everyday items such as medicines, fibers, fuels, and paints could not be produced in sufficient quantities to meet demand. Unfortunately, the most common catalysts— including those used in automobile catalytic converters—are rare, nonrenewable metals such as platinum and palladium. Researchers are working to replace such metals with alternatives, including abundant metals (e.g., iron and nickel) and metal-free catalysts (such as biocatalysts) where possible. For example, in 2016, Newlight Technologies won a Presidential Green Chemistry Challenge Award for developing and commercializing a biocatalyst technology that captures methane (a potent greenhouse gas) and combines it with air to create a material that matches the performance of petroleum-based plastics at a lower cost. Several companies are now using this material to make a range of products, including packaging, cell phone cases, and furniture. Solvents Solvents are key components in chemical reactions. They are used to dissolve other substances so reactions can occur, to separate and purify chemicals, and to clean the equipment used in chemical processes, among other uses. Solvents constitute a large portion of the total volume of chemicals used in industrial chemical processes. However, many conventional solvents are considered hazardous, both to the environment and to human health. There are a variety of alternatives that can be used in some situations, including biobased solvents, less hazardous solvents such as water or ethanol, and solvent-free or reduced-solvent technologies. For example, biobased solvents called citrus terpenes, which are extracted from citrus peel waste, can be used as flavoring agents or fragrances in cleaning products. According to a representative from Florida Chemical, citrus terpenes may be a low-toxicity alternative compared to traditionally used petroleum-based products for the hydraulic fracturing industry’s concerns about contamination of source and groundwater. However, the regionality and seasonality of the citrus supply can present a challenge to production. Continuous Processing Historically, industrial chemicals have been produced mainly using an approach known as batch processing, where the starting materials are combined in a closed vessel or vat and allowed to react, then transferred to the next vat for the next stage of processing while the first vat is cleaned, and the process is repeated with the next batch. This approach can use significant amounts of solvents for cleaning the vats between batches, consume considerable energy, result in potentially long wait times, and create safety risks. An alternative to batch processing is continuous processing, which allows chemical reactions to occur as the reaction mixture is pumped through a series of pipes or tubes where reactions take place continuously. This approach can improve product yield, product quality, reaction time, and process safety while reducing waste and costs. For example, researchers developed a process for manufacturing the active ingredient in medications including Benadryl® and Tylenol® PM using microreactors that minimized waste, reduced the number of purification steps, and reduced production times compared to traditional batch processing. Roles of the Federal Government and Other Stakeholders in Supporting the Development and Use of More Sustainable Chemical Processes and Products The federal government and other stakeholders play a number of roles, sometimes in collaboration, to advance the development and use of more sustainable chemical processes and products. Federal programs support research on the impacts of chemicals on human and environmental health, support the development of more sustainable chemical processes and their commercialization, and aid the expansion of markets for products manufactured with more sustainable chemicals and processes. Other stakeholders play similar roles and some additional roles that contribute to the development and use of more sustainable chemical processes and products. Federal Programs Support Research on the Impacts of Chemicals on Human and Environmental Health Federal programs conduct and fund basic research on the characteristics and biological effects of chemicals, which underpins the development and use of more sustainable chemistry products and processes. Decision makers must have a scientific understanding of the potential harmful impacts of exposure to chemicals in order to effectively minimize the harmful effects of chemicals through regulations and other means, and to assess the regulated community’s compliance with them. Industry needs this information to make informed decisions about the selection, design, and use of more sustainable chemicals in their products and processes, including their impact on workers. Federal programs fund and study the impacts of chemicals on human health and the environment, develop new methodologies for testing and predicting these effects, award grants for research on chemicals and new methodologies, identify more sustainable chemical alternatives, and evaluate the risks of chemicals. (See table 1.) Federal Programs Support the Development and Commercialization of More Sustainable Chemistry Technologies Federal programs also seek to support the development and facilitate the commercialization of new, more sustainable chemistry processes by conducting and funding basic and applied research to develop more sustainable processes and products; providing loan guarantees, grants, and technical assistance to researchers and companies; and recognizing innovative technologies through an award program, among other programs. (See table 2.) Federal Programs Aid Market Growth for Products Made with Sustainable Chemicals and Processes Federal programs also aid market growth for products made with sustainable chemicals and processes by informing consumers about these products and by facilitating their purchase by federal offices. It can be challenging for consumers seeking out more sustainably manufactured products to identify them or verify company claims. Federal programs can help companies seeking to manufacture more sustainable products strive to ensure that their products are differentiated from less sustainable products in order to reach these consumers. For example, federal programs conduct evaluations of the chemical content of products, manage product certification and labeling programs, provide information to consumers and federal purchasers on the chemical content of products, and develop purchasing and sustainability plans to support agency purchase and use of more sustainable products. EPA’s Safer Choice voluntary certification and labeling program helps consumers make informed purchasing decisions and incentivizes manufacturers to select more sustainable chemical alternatives so they can differentiate their products in the market. Industry, Academic Institutions, States, Companies, and Other Stakeholders Support More Sustainable Chemistry Other stakeholders—such as the chemical manufacturing industry, companies and retailers, state governments, academic institutions, and NGOs—also seek to influence the development and use of more sustainable chemistry processes and products through activities such as supporting workforce development and developing tools and resources for industry. These stakeholders may work on collaborative efforts, such as sustainability initiatives and developing industry-specific standards. The chemical industry conducts and supports research into more sustainable chemistry technologies and other activities. Companies and retailers, such as Kaiser Permanente and Target, create demand for more sustainable products from their suppliers by setting sustainability criteria for purchases. Academic institutions conduct research on the impacts of chemicals and sustainable chemistry technologies and train the next generation of chemists and engineers. States seek to protect public health by regulating chemicals in products. NGOs also play a diverse range of roles such as supporting workforce development, facilitating collaboration between other stakeholders, and developing tools and resources for industry. Strategic Implications in the Field of Sustainable Chemistry Sustainable chemistry is an emerging field within the chemical sciences that has the potential to inspire new products and processes, create jobs, and enhance benefits to human health and the environment. Stakeholders offered a range of potential options to realize the full potential of these technologies. However, there are a number of challenges to implementing more sustainable chemistry technologies, including technological, business, and industry-wide and sector-specific challenges. Opportunities The field of sustainable chemistry has the potential to inspire new products and processes, create jobs, and enhance benefits to human health and the environment. Stakeholders noted that much more work is needed to realize its full promise and offered a range of potential options to realize the full potential of these technologies, including the following: Breakthrough technologies in sustainable chemistry and a new conceptual framework could transform how the industry thinks about performance, function, and synthesis. An industry consortium, working in partnership with a key supporter at the federal level, could help make sustainable chemistry a priority and lead to an effective national initiative or strategy. Integrating sustainable chemistry principles into educational programs could bolster a new generation of chemists, encourage innovation, and advance achievement in the field. A national initiative that considers sustainable chemistry in a systematic manner could encourage collaborations among industry, academia, and the government, similar to the National Nanotechnology Initiative. There are opportunities for the federal government to address industry-wide challenges such as developing standard tools for assessment and a robust definition of sustainable chemistry. Federal agencies can also play a role in demonstrating, piloting, and de- risking some technology development efforts. Challenges Stakeholders noted that there are a number of challenges to implementing more sustainable chemistry technologies, including (1) technological and business challenges, (2) industry-wide and sector- specific challenges, and (3) challenges with coordination between stakeholders. One example of a technological challenge is the fact that alternatives to current solvent use can sometimes pose the same inherent toxicity and volatility risks as their conventional counterparts. Alternatives can also vary in supply and quality and can be expensive. Less toxic solvents, such as water, may require specialized equipment, greater energy input, or elevated pressure, and they can be difficult to scale up for industrial use. Companies told us they face many business challenges in implementing sustainable chemistry technologies, including the need to prioritize product performance; weigh sustainability trade-offs between various technologies; risk disruptions to the supply chain when switching to a more sustainable option; and consider regulatory challenges, among others. Stakeholders also noted the challenge of overturning proven conventional practices and acknowledged that existing capital investments in current technologies can create barriers for new companies to enter a field full of well-established players. Our survey and interviews also found that there are several industry-wide and sector-specific challenges to implementing more sustainable chemistry technologies, such as the lack of a standard definition for sustainable chemistry and lack of agreement on standard ways of measuring or assessing it. Without a standard definition that captures the full range of activities within sustainable chemistry, it is difficult to define the universe of relevant players. Without agreement on how to measure the sustainability of chemical processes and products, companies may be hesitant to invest in innovation they cannot effectively quantify, and end users are unable to make meaningful comparisons that allow them to select appropriate chemical products and processes. There is no mechanism for coordinating a standardized set of sustainability factors across the diverse range of stakeholders at present, despite the motivation of some specific sectors to do so. Moreover, although the federal government has worked with stakeholders through its research support, technical assistance, certification programs, and other efforts, there are still gaps in understanding. Many stakeholders told us that without such basic information as a standardized approach for assessing the sustainability of chemical processes and products, better information on product content throughout the supply chain, and more complete data on the health and environmental impacts of chemicals throughout their life cycle, they cannot make informed decisions that compare the sustainability of various products. Sector-specific challenges exist as well. For example, pharmaceutical sector representatives told us that changing the manufacturing process for an already marketed drug triggers a new FDA review, which can result in delays and additional costs—thus discouraging innovation that could make their chemical processes more sustainable. In conclusion, according to stakeholders, transitioning toward the use of more sustainable chemistry technologies requires that industry, government, and other stakeholders work together. As they and others noted, there is a need for new processes that make more efficient use of the resources that are available, reuse products or their components during manufacturing, and account for impacts across the entire life cycle of chemical processes and products. Furthermore, they highlight the importance of disseminating environmental and health-related information to help guide the choices of consumers, chemists, workers, downstream users, and investors to facilitate further progress. They also indicated that momentum in this field will require national leadership in order to realize the full potential of sustainable chemistry technologies. Chairwoman Stevens, Ranking Member Baird, and Members of the Committee, this completes my prepared statement. 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