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Testimony: 

Before the Subcommittee on Oversight and Investigations, Committee on 
Veterans' Affairs, House of Representatives: 

United States Government Accountability Office: 

GAO: 

For Release on Delivery Expected at 2:00 p.m. EDT: 

Tuesday, July 24, 2007: 

Veterans Affairs: 

Lack of Accountability and Control Weaknesses over IT Equipment at 
Selected VA Locations: 

Statement of McCoy Williams, 
Director, Financial Management and Assurance: 

GAO-07-1100T: 

GAO Highlights: 

Highlights of GAO-07-1100T, a testimony before the Subcommittee on 
Oversight and Investigations, Committee on Veterans’ Affairs, House of 
Representatives 

Why GAO Did This Study: 

In July 2004, GAO reported that the six Department of Veterans Affairs 
(VA) medical centers it audited lacked a reliable property control 
database and had problems with implementation of VA inventory policies 
and procedures. Fewer than half the items GAO selected for testing 
could be located. Most of the missing items were information technology 
(IT) equipment. In light of these concerns and recent thefts of laptops 
and data breaches at VA, this testimony focuses on (1) the risk of 
theft, loss, or misappropriation of IT equipment at selected locations; 
(2) whether selected locations have adequate procedures in place to 
assure accountability and physical security of IT equipment in the 
excess property disposal process; and (3) what actions VA management 
has taken to address identified IT inventory control weaknesses. GAO 
statistically tested inventory controls at four case study locations. 

What GAO Found: 

A weak overall control environment for VA IT equipment at the four 
locations GAO audited poses a significant security vulnerability to the 
nation’s veterans with regard to sensitive data maintained on this 
equipment. GAO’s Standards for Internal Control in the Federal 
Government requires agencies to establish physical controls to 
safeguard vulnerable assets, such as IT equipment, which might be 
vulnerable to risk of loss, and federal records management law requires 
federal agencies to record essential transactions. However, GAO found 
that current VA property management policy does not provide guidance 
for creating records of inventory transactions as changes occur. GAO 
also found that policies requiring annual inventories of sensitive 
items, such as IT equipment; adequate physical security; and immediate 
reporting of lost and missing items have not been enforced. GAO’s 
statistical tests of physical inventory controls at four VA locations 
identified a total of 123 missing IT equipment items, including 53 
computers that could have stored sensitive data. The lack of user-level 
accountability and inaccurate records on status, location, and item 
descriptions make it difficult to determine the extent to which actual 
theft, loss, or misappropriation may have occurred without detection. 
The table below summarizes the results of GAO’s statistical tests at 
each location. 

Table: Current IT Inventory Control Failures at Four Test Locations: 

Control failures: Missing items; 
Washington, D.C.: 28%; 
Indianapolis: 6%; 
San Diego: 10%; 
VA HQ offices: 11%. 

Control failures: Incorrect user organization; 
Washington, D.C.: 80%; 
Indianapolis: 69%; 
San Diego: 70%; 
VA HQ offices: 11%. 

Control failures: Incorrect location; 
Washington, D.C.: 57%; 
Indianapolis: 23%; 
San Diego: 53%; 
VA HQ offices: 44%. 

Control failures: Recordkeeping errors; 
Washington, D.C.: 5%; 
Indianapolis: 0%; 
San Diego: 5%; 
VA HQ offices: 3%. 

Source: GAO analysis. 

Note: Each of these estimates has a margin of error, based on a two- 
sided, 95 percent confidence interval, of +/- 10 percent or less. 

[End of table] 

GAO also found that the four VA locations reported over 2,400 missing 
IT equipment items, valued at about $6.4 million, identified during 
physical inventories performed during fiscal years 2005 and 2006. 
Missing items were often not reported for several months and, in some 
cases, several years. It is very difficult to investigate these losses 
because information on specific events and circumstances at the time of 
the losses is not known. GAO’s limited tests of computer hard drives in 
the excess property disposal process found hard drives at two of the 
four case study locations that contained personal information, 
including veterans’ names and Social Security numbers. GAO’s tests did 
not find any remaining data after sanitization procedures were 
performed. However, weaknesses in physical security at IT storage 
locations and delays in completing the data sanitization process 
heighten the risk of data breach. Although VA management has taken some 
actions to improve controls over IT equipment, including strengthening 
policies and procedures, improving the overall control environment for 
sensitive IT equipment will require a renewed focus, oversight, and 
continued commitment throughout the organization. 

What GAO Recommends: 

GAO’s companion report (GAO-07-505), released with this testimony, 
includes12 recommendations to improve VA-wide policies and procedures 
with respect to controls over IT equipment, including recordkeeping 
requirements, physical inventories, user-level accountability, and 
physical security. VA agreed with GAO’s findings, noted significant 
actions under way, and concurred on the 12 recommendations. 

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-1100T]. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact McCoy Williams at (202) 
512-9095 or williamsm1@gao.gov. 

[End of section] 

Mr. Chairman and Members of the Subcommittee: 

Thank you for the opportunity to discuss our recent audit of controls 
over information technology (IT) equipment at the Department of 
Veterans Affairs (VA). In light of reported weaknesses in VA inventory 
controls and reported thefts of laptop computers and data breaches, the 
adequacy of such controls has been an ongoing concern. Today, I will 
summarize the results of our recent work, the details of which are 
included in our audit report, which the Subcommittee is releasing 
today.[Footnote 1] This audit followed a July 2004 report[Footnote 2] 
in which we identified weak practices and lax implementation of 
controls over equipment at the six VA medical centers we audited. As a 
result, personnel at the VA medical centers located fewer than half of 
the 100 items we selected for testing at each of five medical centers 
and 62 of 100 items at the sixth medical center. Most of the items that 
could not be located were computer equipment. 

For today's testimony, I will provide the highlights of our current 
findings related to: 

* the risk of theft, loss, or misappropriation[Footnote 3] of IT 
equipment[Footnote 4] at selected VA locations; 

* whether selected VA locations have adequate procedures in place to 
assure physical security and accountability over IT equipment in the 
excess property disposal process;[Footnote 5] and: 

* what actions VA management has taken to address identified IT 
equipment inventory control weaknesses. 

My statement is based on our report on VA IT inventory controls, which 
you are releasing today.[Footnote 6] As part of our audit, we 
statistically tested IT equipment inventory at selected case study 
locations. In addition, our investigator inspected physical security at 
IT equipment storage sites. We performed our audit procedures in 
accordance with generally accepted government auditing standards, and 
we performed our investigative procedures in accordance with quality 
standards for investigators as set forth by the President's Council on 
Integrity and Efficiency. 

Summary: 

Our statistical tests of IT equipment inventory controls at our four VA 
case study locations identified a total of 123 missing IT equipment 
items, including 53 computers that could have stored sensitive data. 
Our estimates of the percentage of inventory control failures related 
to these missing items ranged from 6 percent at the Indianapolis 
medical center to 28 percent at the Washington, D.C., medical 
center.[Footnote 7] In addition, we determined that VA property 
management policy does not establish accountability with individual 
users of IT equipment. Consequently, our control tests identified a 
pervasive lack of user-level accountability across the four case study 
locations and significant errors in recorded IT inventory information 
concerning user organization and location. As a result, we concluded 
that for the four case study locations we audited, essentially no one 
was accountable for IT equipment. 

Our analysis of the results of physical inventories performed by the 
current four case study locations[Footnote 8] identified over 2,400 
missing IT equipment items, with a combined original acquisition value 
of about $6.4 million. In addition, the five other locations we 
previously audited had reported over 8,600 missing IT equipment items 
with a combined original acquisition value of over $13.2 million. 
Further, we found that missing IT items were often not reported for 
several months and, in some cases, several years, because most of the 
case study locations had not consistently performed physical 
inventories or completed Reports of Survey[Footnote 9] promptly. 

Our limited tests of computer hard drives in the excess property 
disposal process at the four case study locations found no data on 
those hard drives that were certified as sanitized.[Footnote 10] 
However, file dates on the hard drives we tested indicated that some of 
them had been in the disposal process for several years without being 
sanitized, creating an unnecessary risk of compromising sensitive 
personal and medical information. We also found numerous unofficial IT 
equipment storage locations in VA headquarters area office buildings 
that did not meet VA physical security requirements. For example, at 
some VA headquarters locations, excess computer equipment was stored in 
open or unsecured areas. 

Since our July 2004 report, VA management has taken some actions and 
has other actions under way to strengthen controls over IT equipment, 
including clarifying property management policies[Footnote 11] and 
centralizing functional IT units under the new Chief Information 
Officer (CIO) organization. Even with these improvements, the 
department had not yet established and ensured consistent 
implementation of effective controls for accountability of IT equipment 
inventory, and IT inventory responsibilities are not well-defined. 
Until these shortcomings are addressed, VA will continue to face major 
challenges in safeguarding IT equipment and sensitive personal data on 
this equipment from loss, theft, and misappropriation. Our companion 
report released today includes 12 recommendations to VA to improve the 
overall control environment and strengthen key internal control 
activities and to increase attention to protecting IT equipment used in 
VA operations. VA generally agreed with our findings, noted significant 
actions under way, and concurred on the 12 recommendations. 

Inadequate IT Inventory Control and Accountability Pose Risk of Loss, 
Theft, and Misappropriation: 

Our tests of IT equipment inventory controls at four case study 
locations, including three VA medical centers and VA headquarters, 
identified a weak overall control environment and a pervasive lack of 
accountability for IT equipment items across the locations we tested. 
As summarized in table 1, our statistical tests of key IT inventory 
controls at our four case study locations found significant control 
failures. None of the case study locations had effective controls to 
safeguard IT equipment from loss, theft, and misappropriation. 

Table 1: Current IT Equipment Inventory Control Failure Rates at Four 
Test Locations: 

Control failures: Missing items in sample; 
Washington, D.C., medical center: 28%; 
Indianapolis medical center: 6%; 
San Diego medical center: 10%; 
VA headquarters offices: 11%. 

Control failures: Incorrect user organization; 
Washington, D.C., medical center: 80%; 
Indianapolis medical center: 69%; 
San Diego medical center: 70%; 
VA headquarters offices: 11%. 

Control failures: Incorrect user location; 
Washington, D.C., medical center: 57%; 
Indianapolis medical center: 23%; 
San Diego medical center: 53%; 
VA headquarters offices: 44%. 

Control failures: Recordkeeping errors; 
Washington, D.C., medical center: 5%; 
Indianapolis medical center: 0%; 
San Diego medical center: 5%; 
VA headquarters offices: 3%. 

Source: GAO analysis. 

Notes: Each of these estimates has a margin of error, based on a two- 
sided, 95 percent confidence interval, of +/-10 percent or less. 
Because the four test locations did not record all IT equipment items 
in their inventory records, our estimated failure rates relate to 
current (recorded) inventory and not the population of all IT equipment 
at those locations. 

[End of table] 

Our statistical tests identified a total of 123 lost and missing IT 
equipment items across the four case locations, including 53 IT 
equipment items that could have stored sensitive personal information. 
Such information could include names and Social Security numbers 
protected under the Privacy Act of 1974[Footnote 12] and personal 
health information accorded additional protections from unauthorized 
release under the Health Information Portability and Accountability Act 
of 1996 (HIPAA) and implementing regulations.[Footnote 13] Although VA 
property management policy[Footnote 14] establishes guidelines for 
holding employees and supervisors pecuniarily (financially) liable for 
loss, damage, or destruction because of negligence and misuse of 
government property, except for a few isolated instances, none of the 
case study locations assigned user-level accountability for IT 
equipment. Instead, these locations relied on information about user 
organization and user location, which was often incorrect and 
incomplete. Under this lax control environment, missing IT equipment 
items were often not reported for several months and, in some cases 
several years, until the problem was identified during a physical 
inventory. 

Inventory Tests Identified Significant Numbers of Missing Items: 

Our statistical tests of IT equipment existence at the four case study 
locations identified a total of 123 missing IT equipment items. The 123 
missing IT equipment items included 44 at the Washington, D.C., medical 
center; 9 at the Indianapolis medical center; 17 at the San Diego 
medical center; and 53 at VA headquarters. Our statistical tests of 
missing equipment found that none of the four test locations had 
effective controls. 

Missing IT equipment items pose not only a financial risk but also a 
security risk associated with compromising sensitive personal data 
maintained on computer hard drives. The 123 missing IT equipment items 
included 53 that could have stored sensitive personal information, 
including 19 from the Washington, D.C., medical center; 3 from the 
Indianapolis medical center; 8 from the San Diego medical center; and 
23 from VA headquarters. Because of a lack of user-level accountability 
and the failure to consistently update inventory records for inventory 
status and user location changes, VA officials at our test locations 
could not determine the user or type of data stored on this equipment 
and therefore the risk posed by the loss of these items. 

Pervasive Lack of User-Level Accountability for IT Equipment at Case 
Study Locations: 

VA management has not enforced VA property management policy and has 
generally left implementation decisions up to local organizations, 
creating a nonstandard, high-risk environment. Although VA property 
management policy establishes guidelines for user-level 
accountability,[Footnote 15] the three medical centers we tested 
assigned accountability for most IT equipment to their information 
resource management (IRM) or IT Services organizations, and VA 
headquarters organizations tracked IT equipment items through their IT 
inventory coordinators. However, because these personnel did not have 
possession (physical custody) of all IT equipment under their purview, 
they were not held accountable for IT equipment determined to be 
missing during physical inventories. Because of this weak overall 
control environment, we concluded that at the four case study locations 
essentially no one was accountable for IT equipment. 

Absent user-level accountability, accurate information on the using 
organization and location of IT equipment is critical to maintaining 
effective asset visibility and control over IT equipment items. 
However, as table 1 shows, we identified high failure rates in our 
tests for correct user organization and location of IT equipment. 
Because property management system inventory records were inaccurate, 
it is not possible to determine the timing or events associated with 
lost IT equipment as a basis for holding individual employees 
accountable. 

Although our Standards for Internal Control in the Federal 
Government[Footnote 16] requires timely recording of transactions as 
part of an effective internal control structure and safeguarding of 
sensitive assets, we found that VA's property management 
policy[Footnote 17] neither specified what transactions were to be 
recorded for various changes in inventory status nor provided criteria 
for timely recording. Further, IRM and IT Services personnel 
responsible for installation, removal, and disposal of IT equipment did 
not record or assure that transactions were recorded by property 
management officials when these events occurred. 

Errors in IT Equipment Inventory Status and Item Description 
Information: 

We found errors related to the accuracy of other information in IT 
equipment inventory records, including equipment status (e.g., in use, 
turned-in, disposal), serial numbers, model numbers, and item 
descriptions. As shown in table 1, estimated overall error rates for 
recordkeeping were lower than the error rates for the other control 
attributes we tested. Even so, the errors we identified affect 
management decision making and create waste and inefficiency in 
operations. Many of these errors should have been detected and 
corrected during annual physical inventories. 

Physical Inventories by Case Study Locations Identified Thousands of 
Missing IT Equipment Items Valued at Millions of Dollars: 

To assess the effect of the lax control environment for IT equipment, 
we asked VA officials at the case study locations covered in both our 
current and previous audits to provide us with information on the 
results of their physical inventories performed after issuance of 
recommendations in our July 2004 report, including Reports of Survey 
information on identified losses of IT equipment. As of February 28, 
2007, the four case study locations covered in our current audit 
reported over 2,400 missing IT equipment items with a combined original 
acquisition value of about $6.4 million as a result of inventories they 
performed during fiscal years 2005 and 2006. Based on information 
obtained through March 2, 2007, the five case study locations we 
previously audited had identified over 8,600 missing IT equipment items 
with a combined original acquisition value of over $13.2 million, $12.4 
million of which was identified at the Los Angeles medical center. 
Because inventory records were not consistently updated as changes in 
user organization or location occurred and none of the locations we 
audited required accountability at the user level, it is not possible 
to determine whether the missing IT equipment items represent 
recordkeeping errors or the loss, theft, or misappropriation of IT 
equipment. Further, missing IT equipment items were often not reported 
for several months and, in some cases, several years. Although physical 
inventories should be performed over a finite period, at most of the 
case study locations, these inventories were not completed for several 
months or even several years while officials performed extensive 
searches in an attempt to locate missing items before preparing Reports 
of Survey to write them off. According to VA Police and security 
specialists,[Footnote 18] it is very difficult to conduct an 
investigation after significant amounts of time have passed because the 
details of the incidents cannot be determined. 

The timing and scope of the physical inventories performed by the case 
study locations varied. For example, the Indianapolis medical center 
had performed annual physical inventories in accordance with VA policy 
for several years. The Washington, D.C., medical center performed a 
wall-to-wall physical inventory in response to our July 2004 report. In 
this case, inventory results reflected several years of activity 
involving IT inventory records that had not been updated and lost and 
missing IT equipment items that had not previously been identified and 
reported. In addition, the San Diego and Houston medical centers had 
not followed VA policy for including sensitive items, such as IT 
equipment valued at less than $5,000, in their physical inventories. 

Physical Security Weaknesses Increase Risk of Loss, Theft, and 
Misappropriation of IT Equipment and Sensitive Data: 

Our investigator's inspection of physical security at officially 
designated IT warehouses and storerooms at our four case study 
locations that held new and used IT equipment found that most of these 
storage facilities met the requirements in VA Handbook 0730/1, Security 
and Law Enforcement. However, not all of the formally designated 
storage locations at two medical centers had required motion detection 
alarm systems and special door locks. We also found numerous instances 
of informal IT storage areas at VA headquarters that did not meet VA 
physical security requirements. In addition, although VA requires that 
hard drives of IT equipment and medical equipment be sanitized prior to 
disposal to prevent unauthorized release of sensitive personal and 
medical information, we found weaknesses in the disposal process that 
pose a risk of data breach related to sensitive personal information 
residing on hard drives in the property disposal process that have not 
yet been sanitized. 

Weaknesses in Procedures for Controlling Excess Computer Hard Drives: 

VA requires that hard drives of excess computers be sanitized prior to 
reuse or disposal because they can store sensitive personal and medical 
information used in VA programs and activities, which could be 
compromised and used for unauthorized purposes. For example, our 
limited tests of excess computer hard drives in the disposal process 
that had not yet been sanitized found hundreds of unique names and 
Social Security numbers on VA headquarters computers and detailed 
medical histories with Social Security numbers on computer hard drives 
at the San Diego medical center. Our limited tests of hard drives that 
were identified as having been subjected to data sanitization 
procedures did not find data remaining on these hard drives. However, 
our limited tests identified some problems that could pose a risk of 
data breach with regard to sensitive personal and medical information 
on hard drives in the disposal process that had not yet been sanitized. 
For example, our IT security specialist noted excessive delays--up to 6 
years--in performing data sanitization once the computer systems had 
been identified for disposal, posing an unnecessary risk of losing the 
sensitive personal and medical information contained on those systems. 

Physical Security Weaknesses at IT Storage Locations Pose Risk of Data 
Breach: 

VA Handbook 0730/1, Security and Law Enforcement, prescribes physical 
security requirements for storage of new and used IT equipment, 
requiring storerooms to have walls to ceiling height, overhead 
barricades that prevent "up and over" access from adjacent rooms, 
motion intrusion detection alarm systems, and special key control, 
meaning room door lock keys and day lock combinations that are not 
master keyed for use by others. Most of the designated IT equipment 
storage facilities at the four case study locations met VA IT physical 
security requirements; however, we identified deficiencies related to 
lack of intrusion detection systems at the Washington, D.C., and San 
Diego medical centers and inadequate door locks at the Washington, 
D.C., medical center. In response to our findings, these facilities 
initiated actions to correct these weaknesses. 

We also found numerous informal, undesignated IT equipment storage 
locations that did not meet VA physical security requirements. For 
example, at the VA headquarters building, our investigator found that 
the physical security specialist was unaware of the existence of IT 
equipment in some storerooms. Consequently, these storerooms had not 
been subjected to required physical security inspections. Further, 
during our statistical tests, we observed one IT equipment storeroom in 
the VA headquarters building IT Support Services area that had a 
separate wall, but no door. The wall opening into the storeroom had 
yellow tape labeled "CAUTION" above the doorway. The storeroom was 
within an IT work area that had dropped ceilings that could provide "up 
and over" access from adjacent rooms, and it did not meet VA's physical 
security requirements for motion intrusion detection and alarms and 
secure doors, locks, and special access keys. In another headquarters 
building, we observed excess IT equipment stacked in the corners of a 
large work area that had multiple doors and open access to numerous 
individuals. We also found that VA headquarters IT coordinators used 
storerooms and closets with office-type door locks and locked filing 
cabinets in open areas to store IT equipment that was not currently in 
use. The failure to provide adequate security leaves the information 
stored on these computers vulnerable to data breach. 

Status of VA Actions to Improve IT Equipment Management: 

Mr. Chairman, although VA strengthened existing property management 
policy[Footnote 19] in response to recommendations in our July 2004 
report, issued several new policies to establish guidance and controls 
for IT security, and reorganized and centralized the IT function within 
the department under the CIO, additional actions are needed to 
establish effective control in this area. For example, pursuant to 
recommendations made in our July 2004 report, VA updated its property 
management policy to clarify that IT equipment valued at under $5,000 
is to be included in annual inventories. However, as noted in this 
testimony and described in more detail in our companion report, VA had 
not taken action to assure that these items were, in fact, subjected to 
physical inventory. In addition, the new CIO organization has no formal 
responsibility for medical equipment that stores or processes patient 
data and does not address roles or necessary coordination between IRM 
and property management personnel with regard to inventory control of 
IT equipment. The Assistant Secretary for Information and Technology, 
who serves as the CIO, told us that the new CIO organization structure 
will include a unit that will have responsibility for IT equipment 
asset management once it becomes operational. However, this unit has 
not yet been funded or staffed. To assure accountability and 
safeguarding of sensitive IT equipment, effective implementation will 
be key to the success of VA IT policy and organizational changes. 

Our companion report released today made 12 recommendations to VA to 
strengthen accountability of IT equipment and minimize the risk of 
theft, loss, misappropriation, and compromise of sensitive data. These 
included recommendations for revising policies related to recordkeeping 
requirements to document essential inventory events and transactions, 
ensuring that physical inventories are performed in accordance with VA 
policy, enforcing user-level accountability for IT equipment, and 
strengthening physical security of IT equipment storage locations. VA 
management agreed with our findings and concurred with all 12 
recommendations. In VA's written comments provided to us, it noted 
actions planned or under way to address our recommendations. 

Concluding Remarks: 

Poor accountability and a weak control environment have left the four 
VA case study organizations vulnerable to continuing theft, loss, and 
misappropriation of IT equipment and sensitive personal data. To 
provide a framework for accountability and security of IT equipment, 
the Secretary of Veterans Affairs needs to establish clear, 
sufficiently detailed mandatory agencywide policies rather than leaving 
the details of how policies will be implemented to the discretion of 
local VA organizations. Keys to safeguarding IT equipment are effective 
internal controls for the creation and maintenance of essential 
transaction records; a disciplined framework for specific, individual 
user-level accountability, whereby employees are held accountable for 
property assigned to them, including appropriate disciplinary action 
for any lost equipment; and maintaining adequate physical security over 
IT equipment items. Although VA management has taken some actions to 
improve inventory controls, strengthening the overall control 
environment and establishing and implementing specific IT equipment 
controls will require a renewed focus, oversight, and continuing 
commitment throughout the organization. We appreciate VA's positive 
response to our current recommendations and planned actions to address 
them. If effectively implemented, these actions will go a long way to 
assuring that the weaknesses identified in our last two audits of VA IT 
equipment will be effectively resolved in the near future. 

Mr. Chairman and Members of the Subcommittee, this concludes my 
statement. I would be pleased to answer any questions that you may have 
at this time. 

Contacts and Acknowledgments: 

For further information about this testimony, please contact McCoy 
Williams at (202) 512-9095 or williamsm1@gao.gov. Contact points for 
our Offices of Congressional Relations and Public Affairs may be found 
on the last page of this statement. Major contributors to this 
testimony include Gayle L. Fischer, Assistant Director; Andrew 
O'Connell, Assistant Director and Supervisory Special Agent; Abe 
Dymond, Assistant General Counsel; Monica Perez Anatalio; James D. 
Ashley; Francine DelVecchio; Lauren S. Fassler; Dennis Fauber; Jason 
Kelly; Steven M. Koons; Christopher D. Morehouse; Lori B. Tanaka; Chris 
J. Rodriguez; Special Agent Ramon J. Rodriguez; and Danietta S. 
Williams. In addition, technical expertise was provided by Keith A. 
Rhodes, Chief Technologist, and Harold Lewis, Assistant Director, 
Information Technology Security, Applied Research and Methods. 

FOOTNOTES 

[1] GAO, Veterans Affairs: Inadequate Controls over IT Equipment at 
Selected VA Locations Pose Continuing Risk of Theft, Loss, and 
Misappropriation, GAO-07-505 (Washington, D.C.: July 16, 2007). 

[2] GAO, VA Medical Centers: Internal Control over Selected Operating 
Functions Needs Improvement, GAO-04-755 (Washington, D.C.: July 21, 
2004). 

[3] As used in this testimony, theft and misappropriation both refer to 
the unlawful taking or stealing of personal property, with 
misappropriation occurring when the wrongdoer is an employee or other 
authorized user. 

[4] For the purpose of our test work, we defined IT equipment as any 
equipment capable of processing or storing data, regardless of how VA 
classifies it. Therefore, medical devices that would typically not be 
classified as IT equipment, but may capture, process, or store patient 
data, were considered IT equipment for this audit. 

[5] As used in this testimony, the term excess property refers to 
property that a federal agency leases or owns that is not required to 
meet either the agency's needs or any other federal agency's needs. 

[6] GAO-07-505. 

[7] Each of these estimates has a margin of error, based on a two- 
sided, 95 percent confidence interval, of +/-7 percent or less. 

[8] The Washington, D.C., medical center was covered in both audits. 

[9] The Report of Survey system is the method used by VA to obtain an 
explanation of the circumstances surrounding loss, damage, or 
destruction of government property other than through normal wear and 
tear. 

[10] VA information resource management (IRM) personnel and contractors 
follow National Institute of Standards and Technology (NIST) Special 
Publication 800-88 guidelines as well as more stringent Department of 
Defense (DOD) policy in DOD 5220.22-M, National Industrial Security 
Program Operating Manual, ch. 8, § 8-301, which requires performing 
three separate erasures for media sanitization. 

[11] VA Handbook 7127/4 § 5302.3, "Inventory of Equipment in Use." 

[12] Privacy Act of 1974, codified, as amended, at 5 U.S.C. § 552a. 

[13] HIPAA, Pub. L. No. 104-191, § 264, 110 Stat. 1936, 2033-34 (Aug. 
21, 1996). The Secretary of Health and Human Services has prescribed 
standards for safeguarding medical information in the HIPAA Medical 
Privacy Rule. See 45 C.F.R. pt. 164. 

[14] VA Handbook 7125, Materiel Management General Procedures, § 5003 
(Oct. 11, 2005). 

[15] VA Handbook 7125, Materiel Management General Procedures, § 5003. 

[16] GAO, Standards for Internal Control in the Federal Government, 
GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999). 

[17] VA Handbook 7127/3, Material Management Procedures, pt. 1, § 5002- 
2.3, and VA Handbook 7127/4, Material Management Procedures, pt. 4, § 
5302.3. 

[18] VA medical centers and other facilities have a VA Police Service, 
which provides law enforcement and physical security services, 
including security inspections and criminal investigations. The VA 
headquarters building does not have a police service. VA headquarters 
law enforcement duties are the responsibility of the Federal Protective 
Service. 

[19] VA Handbook 7127/4, Materiel Management Procedures (Oct. 11, 
2005). 

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