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May 31, 2007: 

Congressional Committees: 

Subject: Improper Payments Information Act of 2002: Department of 
Defense Travel Expenditure Reporting: 

In November 2002, the Congress passed the Improper Payments Information 
Act of 2002[Footnote 1] (IPIA). The major objective of the legislation 
was to enhance the accuracy and integrity of federal payments. This 
legislation, in conjunction with implementing guidance[Footnote 2] from 
the Office of Management and Budget (OMB), requires executive branch 
agency heads to review their programs and activities annually, identify 
those that may be susceptible to significant improper payments, 
estimate amounts improperly paid, and report on the amounts of improper 
payments and actions to reduce them. Since passage of IPIA, the 
Department of Defense (DOD) has continued to expand its annual 
disclosures in its performance and accountability reports (PAR) and 
currently discloses some detail of improper payment estimates for six 
programs or activities, including civilian pay, commercial pay, travel 
pay, military retirement, military health benefits, and military pay. 
DOD has reported improper payment information since 2003. The Congress 
mandated that we consider one facet of this reporting related to DOD-- 
travel pay. The DOD Office of the Inspector General (OIG) first 
reported on whether the department complied with IPIA in fiscal year 
2006 and identified several significant flaws in DOD's efforts to 
comply with IPIA. 

Over the past several years, GAO has issued numerous reports that 
highlighted problems with DOD travel practices that resulted in 
wasteful spending of millions of dollars, including weak controls over 
first class travel, unused airline tickets, and the accuracy of 
travelers' claims.[Footnote 3] Conference Report 109-676[Footnote 4] 
accompanying the Department of Defense Appropriations Act, 
2007[Footnote 5] included a requirement for GAO to assess the reasons 
why DOD is not fully in compliance with IPIA related to travel 
expenditures and make any needed recommendations for corrective action. 
In response, this initial report provides an overview of DOD's IPIA 
reporting for fiscal years 2003 through 2006 and a discussion of the 
reasons reported by the DOD OIG that DOD was not in compliance with 
IPIA for fiscal year 2006. To further respond to this mandate, we plan 
to issue a separate report later this year that will include the 
results of a more comprehensive review of (1) the scope and methodology 
DOD used in its IPIA travel-related improper payments assessment and 
(2) DOD's internal control over travel-related IPIA reporting 
disclosures. Our follow-on report will also include recommendations for 
any needed corrective actions. 

To complete this work, we reviewed DOD's PAR for fiscal years 2003, 
2004, 2005, and 2006. We also reviewed prior GAO reports, applicable 
federal laws, prior DOD OIG reports, and OMB implementing guidance 
found in OMB Circular No. A-123, Appendix C.[Footnote 6] We did not 
independently validate the improper payment data reported by DOD. 
However, we are providing this agency-reported data as descriptive 
information that will inform interested parties about DOD improper 
payments and other improper payment-related information. We believe the 
data to be sufficiently reliable for this purpose. We also did not 
independently assess whether DOD was in compliance with IPIA related to 
travel expenditures. We performed our work from November 2006 through 
April 2007 in accordance with generally accepted government auditing 
standards. We requested comments on a draft of this report from the 
Secretary of Defense or his designee. Written comments from DOD's 
Acting Deputy Chief Financial Officer are reprinted in enclosure I. 

Results in Brief: 

In fiscal year 2003, DOD began improper payment reporting in its annual 
PAR. As required under OMB Circular No. A-11,[Footnote 7] it reported 
improper payments for military health benefits and military retirement. 
In fiscal year 2004, DOD reported that its improper payment 
survey[Footnote 8] did not identify any programs or activities that 
were susceptible to risk of significant improper payments for purposes 
of IPIA. As in the prior year, DOD provided additional information for 
military retirement and military health benefits. In fiscal year 2005, 
DOD reported that none of its programs or activities met OMB's criteria 
for risk of significant improper payments under IPIA. Its survey, 
however, did find military pay susceptible to significant risk of 
improper payments. DOD's fiscal year 2005 reporting included 
information on statistical sampling and corrective action plans for its 
military retirement, military health benefits, and military pay 
programs. 

In its most recent PAR for fiscal year 2006, DOD continued to expand 
its annual reporting, including information in varying levels of detail 
concerning improper payment estimates for civilian pay, commercial pay, 
travel pay, military retirement, military health benefits, and military 
pay. In total, DOD identified $875.5 million in improper payments. 
Specifically, for travel pay for fiscal year 2006, DOD estimated about 
$8 million in improper payments. For fiscal year 2006, the DOD OIG 
reported that the department did not fully comply with the requirements 
of IPIA and implementing OMB guidance. The DOD OIG cited, for example, 
an inadequate control process at the Defense Finance and Accounting 
Service as well as control weaknesses identified in GAO's prior 
assessments demonstrating that programs related to military pay, 
travel, property, contract payments, and automated systems may be at 
risk of making significant improper payments. The DOD OIG also reported 
on steps the department was taking to improve IPIA compliance, 
including the establishment of a Project Officer for Improper Payments 
and Recovery Auditing. 

Background: 

IPIA was enacted in November 2002 with the major objective of enhancing 
the accuracy and integrity of federal payments. IPIA requires executive 
branch agency heads to review their programs and activities annually 
and identify those that may be susceptible to significant improper 
payments. OMB provided implementing guidance for reporting under IPIA 
in Appendix C of OMB Circular No. A-123. The OMB guidance defines 
significant improper payments[Footnote 9] as those in any particular 
program exceeding both 2.5 percent of program payments and $10 million 
annually.[Footnote 10] In addition, the guidance provides that agency 
programs that were included in former section 57 of OMB Circular No. A- 
11 must estimate improper payments even if the estimate does not exceed 
$10 million and 2.5 percent of program payments. 

In its guidance, OMB may also determine, on a case-by-case basis, 
whether certain programs should be reported even if those programs do 
not meet established thresholds. For all programs and activities 
susceptible to significant improper payments, agencies are to determine 
an annual estimated amount of improper payments made in those programs 
and activities. If the estimate of improper payments exceeds $10 
million, the agency must implement a plan to reduce the amount of such 
erroneous payments. Agencies that have identified programs or 
activities that may be susceptible to significant improper payments are 
also required to include the amount of estimated improper payments in 
their annual PAR, regardless of whether they meet the $10 million 
threshold. 

DOD IPIA Reporting for Fiscal Years 2003 through 2006: 

DOD has continued to expand its annual reporting on improper payments 
in its PAR. Its most recent report covering fiscal year 2006 included 
varying levels of detail concerning improper payment estimates for 
civilian pay, commercial pay, travel pay, military retirement, military 
health benefits, and military pay. The following provides an overview 
of DOD's reporting for fiscal years 2003 through 2006, with special 
emphasis on fiscal year 2006. 

Fiscal Year 2003. In fiscal year 2003, DOD began reporting information 
as required under IPIA and OMB Circular No. A-11 in its annual 
PAR.[Footnote 11] DOD reported on improper payments for military health 
benefits and military retirement. DOD also reported it "is reviewing 
all programs and activities and identifying those which are susceptible 
to significant improper payments." The department went on to describe 
its planned actions, including estimating the amount of improper 
payments and establishing goals to reduce the amounts of these 
payments. DOD also provided further detail on the projected improper 
payments and approximate error rate for military health benefits and 
military retirement. 

Fiscal Year 2004. In its fiscal year 2004 PAR,[Footnote 12] DOD 
reported that its improper payments survey did not identify any 
programs or activities where erroneous payments exceeded the 
established thresholds, nor were any found to be susceptible to 
significant risk. Further, DOD described the risk assessments performed 
on nine programs/activities that the department identified as being 
susceptible to improper payments. As a result of this assessment, DOD 
determined that none of the programs/activities were susceptible to 
high risk. Further, for two programs--military retirement and military 
health benefits--DOD described the statistical sampling process, 
planned corrective actions, reduction outlook, existence of information 
systems, and other infrastructure needed to reduce improper payments, 
as well as the statutory or regulatory barriers that might limit 
corrective action. 

Fiscal Year 2005. In its fiscal year 2005 PAR,[Footnote 13] DOD 
reported that its survey did not identify any programs or activities 
where payments met OMB's criteria for reporting as "significant" 
improper payments. DOD reported that its survey, however, did find 
military pay susceptible to significant risk of improper payments. DOD 
reported information on statistical sampling and corrective action 
plans related to its military retirement, military health benefits, and 
military pay programs. DOD also provided information on information 
systems, accountability for improper payments, and recovery auditing at 
the department. 

Fiscal Year 2006. In its fiscal year 2006 PAR,[Footnote 14] DOD 
reported that its current IPIA review did not identify any programs or 
activities at risk of "significant erroneous payments" in accordance 
with OMB criteria. However, the department also reported that civilian, 
commercial, and travel pay potentially were susceptible to improper 
payments in excess of $10 million and reported estimated improper 
payments information for these programs. Further, the department again 
reported on its sampling and corrective actions concerning its military 
retirement, military health benefits, and military pay programs. Table 
1 shows the information DOD reported on estimated improper payments for 
six programs in its fiscal year 2006 PAR. 

Table 1: DOD's Reported Improper Payment Estimates for Fiscal Year 
2006: 

Program: Commercial Pay; 
Estimated improper payments (in millions): $550.0; 
Improper payments as a percentage of total program payments: 0.2%. 

Program: Military Health Benefits; 
Estimated improper payments (in millions): 140.0; 
Improper payments as a percentage of total program payments: 2.0. 

Program: Military Pay; 
Estimated improper payments (in millions): 65.9; 
Improper payments as a percentage of total program payments: 0.1. 

Program: Civilian Pay; 
Estimated improper payments (in millions): 62.8; 
Improper payments as a percentage of total program payments: 0.1. 

Program: Military Retirement; 
Estimated improper payments (in millions): 48.8; 
Improper payments as a percentage of total program payments: 0.1. 

Program: Travel Pay; 
Estimated improper payments (in millions): 8.0; 
Improper payments as a percentage of total program payments: 1.0. 

Total; 
Estimated improper payments (in millions): $875.5; 
Improper payments as a percentage of total program payments: [Empty]. 

Source: DOD fiscal year 2006 PAR. 

[End of table] 

Further, DOD described the risk assessment process for each of the 
programs or activities that addressed the strength of the internal 
controls in place to prevent improper payments and reported on the 
results in its disclosure. DOD also described the statistical sampling 
and corrective action plans for these six programs or activities. 
Additionally, DOD summarized the improper payment reduction outlook for 
the military retirement, military health benefits, and military pay 
programs. Finally, DOD described its improper payments auditing, 
accountability information, information system usage, and statutory and 
regulatory barriers limiting the department's corrective actions. 

With regard to improper payments reporting related to its travel 
program in DOD's fiscal year 2006 PAR, the department described the 
process in place to conduct monthly random postpayment reviews of 
travel records settled through the Defense Travel System (DTS) and 
Integrated Automated Travel System (IATS). DOD reported that these 
random reviews were designed to produce annual estimates of improper 
payments, with a probability of 95 percent and sample precision of plus 
or minus 2.5 percent, at the component level (e.g., Army, Navy, Air 
Force, and Marine Corps). Further, at the U.S. Army Corps of Engineers, 
DOD reported that all temporary duty travel (TDY) and permanent change 
of station vouchers greater than or equal to $2,500 were subject to 
postaudit review, and a sample of every 366TH TDY voucher less than 
$2,500 was also reviewed. 

DOD's fiscal year 2006 PAR also described the risk assessment DOD 
completed for several programs, including travel, to address the 
strength of internal controls in place to prevent improper payments, 
system weaknesses identified internally or by outside audit activities, 
and voluntary returns of overpayments. In Section 4 of its fiscal year 
2006 PAR, DOD described its corrective action plans regarding improper 
payments, including specific information on travel. In this section, 
the department only reported information on travel processed through 
DTS, although DOD uses other systems, such as IATS, to process travel 
in addition to DTS. In its PAR, DOD reported that in fiscal year 2006, 
over 783,000 trip records with a total settlement dollar value of 
$823.6 million were processed through DTS. However, based on our 
ongoing work, this amounted to only 11 percent of the $7.483 billion of 
DOD travel obligations reported for fiscal year 2006 in the 2008 Budget 
of the U.S. Government.[Footnote 15] DOD reported that as of September 
30, 2006, the department had randomly selected and reviewed 30,100 
settled trip records related to DTS transactions, with a value 
exceeding $32.6 million. Based on these reviews, DOD projected that 
improper payments accounted for .968 percent of the tested sample and 
thus DOD projected that improper payments in the population of DTS 
settlements could approach $7.97 million. 

The DOD OIG Raised Concerns with DOD's IPIA Reporting for Fiscal Year 
2006: 

DOD's independent auditor, the DOD OIG, determined that the 
department's fiscal year 2006 reporting did not fully comply with the 
requirements of IPIA and implementing OMB guidance. The auditors 
reported that their conclusion was based, in part, on an inadequate 
control process at the Defense Finance and Accounting Service as well 
as control weaknesses identified in GAO's prior assessments 
demonstrating that programs related to military pay, travel, property, 
contract payments, and automated systems may be at risk of making 
significant improper payments. 

The DOD OIG also reported that the department had taken steps to 
resolve some previously identified issues regarding the methodologies 
and processes used in reporting improper payments. Further, the OIG 
reported that DOD had recently established a Project Officer for 
Improper Payments and Recovery Auditing. The project officer's reported 
responsibilities include (1) reviewing DOD's statistical methodologies 
and processes to verify that DOD's reported information is accurate, 
complete, and meets or exceeds OMB minimum reporting requirements; and 
(2) establishing an Improper Payments and Recovery Auditing working 
group to help DOD modify improper payment methodologies and processes 
as needed. 

Agency Comments and Our Evaluation: 

We requested comments on a draft of this report from the Secretary of 
Defense or his designee. The Acting Deputy Chief Financial Officer of 
DOD provided written comments, which are reprinted in enclosure I. 
DOD's comments correctly noted that this report does not contain any 
audit conclusions or recommendations, but does provide a summary of the 
DOD OIG's conclusions contained in DOD's fiscal year 2006 PAR that the 
department did not fully comply with IPIA for fiscal year 2006. DOD 
commented that our report would achieve a more balanced reporting of 
the department's compliance with IPIA if it included the positive 
comments made by the DOD OIG, also included in the fiscal year 2006 
PAR, as well as an acknowledgement of DOD's ongoing efforts to 
continually improve oversight and reporting of improper payments. 
Inasmuch as the mandate to which this report responds specifically 
required GAO to assess the reasons why DOD is not fully in compliance 
with IPIA related to travel expenditures, our draft report necessarily 
focused on the noncompliance aspects of the DOD OIG's fiscal year 2006 
reporting. Nonetheless, we have modified the report to include the 
positive steps DOD had taken, as reported by the DOD OIG. Further, 
while we agree that DOD is taking steps intended to improve IPIA 
reporting, including holding an IPIA conference and continuing to work 
with OMB, the scope of our initial review did not include assessing the 
effectiveness of such steps. 

DOD's comments also included a status update on the department's 
efforts to reconcile the amount of its travel payments reported in the 
fiscal year 2006 PAR, which represents 11 percent of the $7.483 billion 
of DOD travel obligations reported in object class 21 (travel and 
transportation of persons) in the fiscal year 2008 Budget of the U.S. 
Government. We appreciate DOD's ongoing efforts to reconcile the 
disparate amounts reported in its PAR and fiscal year 2008 budget for 
travel and will assess the results of these efforts as part of our 
ongoing work. 

We are sending copies of this report to other interested congressional 
committees. Copies will be made available to others upon request. In 
addition, this report will also be available at no charge on GAO's Web 
site at http://www.gao.gov. 

If you or your staffs have any questions regarding this report, please 
contact me at (202) 512-9095 or at williamsm1@gao.gov. Contact points 
for our Offices of Congressional Relations and Public Affairs may be 
found on the last page of this report. Major contributors to this 
report include Dianne Guensberg, Assistant Director; Heather Dunahoo; 
and Bradley Klingsporn. 

Signed by: 

McCoy Williams: 
Director, Financial Management and Assurance: 

List of Congressional Committees: 

The Honorable Carl Levin: 
Chairman: 
The Honorable John McCain: 
Ranking Member: 
Committee on Armed Services: 
United States Senate: 

The Honorable Daniel K. Inouye: 
Chairman: 
The Honorable Ted Stevens: 
Ranking Member: 
Subcommittee on Defense: 
Committee on Appropriations: 
United States Senate: 

The Honorable Thomas R. Carper: 
Chairman: 
The Honorable Tom Coburn: 
Ranking Member: 
Subcommittee on Federal Financial Management, Government Information, 
Federal Services, and International Security: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

The Honorable Ike Skelton: 
Chairman: 
The Honorable Duncan L. Hunter: 
Ranking Member: 
Committee on Armed Services: 
House of Representatives: 

The Honorable John P. Murtha: 
Chairman: 
The Honorable C.W. Bill Young: 
Ranking Member: 
Subcommittee on Defense: 
Committee on Appropriations: 
House of Representatives: 

[End of section] 

Enclosure I: Comments from the Department of Defense: 

Office Of The Under Secretary Of Defense: 
Comptroller: 
1100 Defense Pentagon: 
Washington, DC 20301-1100: 

May 16 2007: 

Mr. McCoy Williams: 
Director: 
Financial Management and Assurance: 
U.S. Government Accountability Office: 
441 G Street, N.W. 
Washington, DC 20548: 

Dear Mr. Williams: 

This is the Department of Defense (DoD) response to the GAO draft 
report 07-767R, "Improper Payments Information Act Of 2002: Department 
of Defense Travel Expenditure Reporting," dated April 26, 2007 (GAO 
Code 195105). The draft report is comprised of a brief overview of the 
Department of Defense (DoD) Improper Payments Implementation Act (IPIA) 
reporting in the Performance and Accountability Report (PAR) for fiscal 
years (FY) 2003 through 2006. 

The draft GAO report contained no audit conclusions or made any 
recommendations to DoD. The draft report did, however, reiterate a 
portion of the DoD, Office of Inspector General (OIG) conclusions 
contained in the FY 2006 PAR that the Department did not fully comply 
with the requirements of IPIA and implementing Office of Management and 
Budget (OMB) guidance. Included as part of the OIG's conclusions, but 
not cited by GAO in the draft report, was the acknowledgment that DoD 
worked closely with them in addressing previously identified reporting 
issues, including recently establishing a Project Officer for Improper 
Payments and Recovery Auditing (IPRA) reporting. In addition, the OIG 
noted that the DoD Project Officer was establishing an ongoing IPRA 
working group, comprised of representatives from the numerous 
Departmental IPIA reporting elements, to further improve compliance of 
DoD's IPIA reporting. We request your final report include a discussion 
of the additional DoD OIG comments in the FY 2006 PAR and the 
Department's ongoing actions to improve oversight and reporting of 
improper payments. 

We also note that as part of the Department's ongoing actions to 
improve the IPIA reporting, we are holding an IPIA conference on May 16 
and 17, where subject matter experts from OMB and DoD, OIG will provide 
training and knowledge sharing to attendees throughout the Department's 
IPIA reporting community. Additionally, the Department is working 
closely with OMB in implementing plans, agreed upon with OMB as part of 
the President's Management Agenda, towards eliminating improper 
payments. For the past year, OMB has scored the Department's progress 
as "green" to represent the Department's continued success and positive 
steps taken towards eliminating improper payments. 

We are actively researching the GAO's comment that the amount of travel 
payments reported in the FY 2006 PAR amount to only 11 percent of the 
$7.483 billion of DoD travel obligations reported in Object Class 21, 
"Travel and transportation of persons," in the "Fiscal Year 2008 Budget 
of the U.S. Government." The $7.483 billion includes obligations for 
types of travel beyond the travel payments reported in the FY 2006 PAR, 
primarily comprised of employee authorized travel costs. The OMB 
Circular A-11, Section 83, Object Class 21 includes not only travel and 
transportation obligations for Government employees and other persons 
while in an authorized travel status, but also includes "Contracts to 
transport people from place to place, by land, air, or water," such as 
commercial transportation charges; rental or lease of passenger cars; 
charter of trains, buses, vessels, or airplanes; ambulance service or 
hearse service; and expenses incident to the operation of rented or 
chartered conveyances." We are reviewing Department vendor and 
commercial pay databases to identify the amount of payments for 
contracts covering personnel transportation that may further bridge the 
difference between the obligations reported under Object Class 21 in 
the budget report, and the amount of employee travel payments reported 
in the FY 2006 PAR. Once this reconciliation is complete, we will 
advise you of our results. 

In summary, we believe the GAO would achieve a more balanced reporting 
of the Department's compliance with IPIA if the report included the 
positive comments made by the DoD, OIG in the FY 2006 PAR, as well as 
the Department's ongoing efforts to continually improve oversight and 
reporting of improper payments. We appreciate the opportunity to 
provide comments to your draft report. My point of contact is Mr. Wayne 
Goff, who can be contacted by telephone at 703-697-0831 or e-mail at: 
wayne.goff@osd.mil. 

Sincerely, 

Signed by: 

Robert P. McNamara: 
Acting Deputy Chief Financial Officer: 

[End of section] 

Related GAO Products: 

DOD Business Transformation: Defense Travel System Continues to Face 
Implementation Challenges. GAO-06-18. Washington, D.C.: January 18, 
2006. 

Army National Guard: Inefficient, Error-Prone Process Results in Travel 
Reimbursement Problems for Mobilized Soldiers. GAO-05-400T. Washington, 
D.C.: March 16, 2005. 

Army National Guard: Inefficient, Error-Prone Process Results in Travel 
Reimbursement Problems for Mobilized Soldiers. GAO-05-79. Washington, 
D.C.: January 31, 2005. 

DOD Travel Cards: Control Weaknesses Led to Millions of Dollars of 
Improper Payments. GAO-04-576. Washington, D.C.: June 9, 2004. 

DOD Travel Cards: Control Weaknesses Led to Millions in Fraud, Waste, 
and Improper Payments. GAO-04-825T. Washington, D.C.: June 9, 2004. 

DOD Travel Cards: Control Weaknesses Led to Millions of Dollars Wasted 
on Unused Airline Tickets. GAO-04-398. Washington, D.C.: March 31, 
2004. 

Travel Cards: Internal Control Weaknesses at DOD Led to Improper Use of 
First and Business Class Travel. GAO-04-229T. Washington, D.C.: 
November 6, 2003. 

Travel Cards: Internal Control Weaknesses at DOD Led to Improper Use of 
First and Business Class Travel. GAO-04-88. Washington, D.C.: October 
24, 2003. 

(195105): 

FOOTNOTES 

[1] Pub. L. No. 107-300, 116 Stat. 2350 (Nov. 26, 2002). 

[2] Appendix C to OMB Circular No. A-123, Requirements for Effective 
Measurement and Remediation of Improper Payments (Aug. 10, 2006). 

[3] See the Related GAO Products section at the end of this 
correspondence. 

[4] H.R. Conf. Rep. No. 109-676, at 94 (Sept. 25, 2006). 

[5] Pub. L. No. 109-289, 120 Stat. 1257 (Sept. 29, 2006). 

[6] Appendix C to OMB Circular A-123 consolidates three memorandums 
previously issued by OMB. These memorandums are: M-03-07, "Programs to 
Identify and Recover Erroneous Payments to Contractors" (Jan. 16, 
2003); M-03-12, "Allowability of Contingency Fee Contracts for Recovery 
Audits" (May 8, 2003); and M-03-13, "Improper Payments Information Act 
of 2002 (Public Law 107-300)" (May 21, 2003). 

[7] Prior to the executive branchwide IPIA reporting requirements, 
beginning with fiscal year 2004, former section 57 of OMB Circular No. 
A-11 required certain agencies to submit similar information, including 
estimated improper payment target rates, target rates for future 
reductions in these payments, the types and causes of these payments, 
and variances from targets and goals established. In addition, these 
agencies were to provide a description and assessment of the current 
methods for measuring the rate of improper payments and the quality of 
data resulting from these methods. 

[8] DOD conducts an annual survey of all programs and activities that 
may be susceptible to improper payments. The survey requires 
identification of underpayments and overpayments and a description of 
the methodology used to estimate improper payments. 

[9] "Improper payment" and "erroneous payment" have the same meaning 
under Appendix C of OMB Circular No. A-123. 

[10] IPIA does not include a similar threshold for defining significant 
improper payments. 

[11] DOD, Performance and Accountability Report: Fiscal Year 2003 (Dec. 
23, 2003). 

[12] DOD, Performance and Accountability Report: Fiscal Year 2004 (Nov. 
15, 2004). 

[13] DOD, Performance and Accountability Report: Fiscal Year 2005 (Nov. 
15, 2005). 

[14] DOD, Performance and Accountability Report: Fiscal Year 2006 (Nov. 
15, 2006). 

[15] Fiscal Year 2008 Budget of the U.S. Government, Object Class 
Analysis (Feb. 5, 2007).

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