Skip to main content

B-151309, NOV. 5, 1965, 45 COMP. GEN. 238

B-151309 Nov 05, 1965
Jump To:
Skip to Highlights

Highlights

IS FOR APPLICATION ONLY TO MIDSHIPMEN APPOINTED ON OR PRIOR TO JUNE 25. WHO WAS IMPROPERLY CREDITED FOR A PERIOD OF DUAL ENLISTED MIDSHIPMAN SERVICE IN ESTABLISHING THE RATE OF HIS ACTIVE DUTY BASIC PAY DOES NOT COME WITHIN THE SCOPE OF THE RELIEF PROVISIONS OF THE 1964 ACT. 1965: FURTHER REFERENCE IS MADE TO LETTER OF SEPTEMBER 13. THE REQUEST WAS ASSIGNED SUBMISSION NO. WAS APPOINTED A MIDSHIPMAN IN THE UNITED STATES NAVAL RESERVE WITHOUT TERMINATION OF THE ENLISTMENT CONTRACT. (B) WAS THEREAFTER ERRONEOUSLY CREDITED IN THE COMPUTATION OF HIS BASIC PAY WITH A PERIOD OF ENLISTED SERVICE ON AND AFTER THE DATE OF APPOINTMENT. IS RELIEVED OF ALL LIABILITY TO REFUND TO THE UNITED STATES THE AMOUNTS.

View Decision

B-151309, NOV. 5, 1965, 45 COMP. GEN. 238

PAY - SERVICE CREDITS - CADET, MIDSHIPMAN, ETC. - CONCURRENT ENLISTED RESERVE SERVICE THE RELIEF PROVIDED IN THE ACT OF OCTOBER 2, 1964, FROM LIABILITY TO REFUND OVERPAYMENTS RECEIVED PRIOR TO MARCH 15, 1961, BY ENLISTED MEMBERS OF THE NAVAL RESERVE APPOINTED AS MIDSHIPMEN WITHOUT TERMINATION OF THEIR ENLISTMENT CONTRACT, PURSUANT TO THE ACT OF JUNE 25, 1956, AND ERRONEOUSLY CREDITED IN THE COMPUTATION OF BASIC PAY WITH A PERIOD OF ENLISTED SERVICE ON AND AFTER THE DATE OF APPOINTMENT, IS FOR APPLICATION ONLY TO MIDSHIPMEN APPOINTED ON OR PRIOR TO JUNE 25, 1956, SECTION 4 OF THE ACT PRECLUDING CREDIT FOR ANY PERIOD OF SERVICE IN AN ENLISTMENT OR PERIOD OF OBLIGATED SERVICE WHILE ALSO SERVING AS A CADET OR A MIDSHIPMAN UNDER AN APPOINTMENT ACCEPTED AFTER JUNE 25, 1956, IN THE COMPUTATION OF LENGTH OF SERVICE FOR ANY PURPOSE, NOT HAVING BEEN REPEALED OR MODIFIED BY THE 1964 ACT; THEREFORE, AN OFFICER APPOINTED AS A MIDSHIPMAN IN THE NAVAL RESERVE AFTER JUNE 25, 1956, AND INFORMED OF THE PROHIBITION IN THE 1956 ACT, WHO WAS IMPROPERLY CREDITED FOR A PERIOD OF DUAL ENLISTED MIDSHIPMAN SERVICE IN ESTABLISHING THE RATE OF HIS ACTIVE DUTY BASIC PAY DOES NOT COME WITHIN THE SCOPE OF THE RELIEF PROVISIONS OF THE 1964 ACT.

TO THE SECRETARY OF THE NAVY, NOVEMBER 5, 1965:

FURTHER REFERENCE IS MADE TO LETTER OF SEPTEMBER 13, 1965, AND ENCLOSURES, FROM THE UNDER SECRETARY OF THE NAVY, REQUESTING DECISION AS TO APPLICABILITY OF PUBLIC LAWS 88-614, OCTOBER 2, 1964, 78 STAT. 993, IN THE CIRCUMSTANCES SET FORTH BELOW. THE REQUEST WAS ASSIGNED SUBMISSION NO. SS-N-869 BY THE DEPARTMENT OF DEFENSE MILITARY PAY AND ALLOWANCE COMMITTEE.

PUBLIC LAW 88-614 PROVIDES:

THAT ANY MEMBER OR FORMER MEMBER OF THE NAVAL SERVICE WHO---

(A) AS AN ENLISTED MEMBER OF THE UNITED STATES NAVAL RESERVE, WAS APPOINTED A MIDSHIPMAN IN THE UNITED STATES NAVAL RESERVE WITHOUT TERMINATION OF THE ENLISTMENT CONTRACT; AND

(B) WAS THEREAFTER ERRONEOUSLY CREDITED IN THE COMPUTATION OF HIS BASIC PAY WITH A PERIOD OF ENLISTED SERVICE ON AND AFTER THE DATE OF APPOINTMENT;

IS RELIEVED OF ALL LIABILITY TO REFUND TO THE UNITED STATES THE AMOUNTS, WHICH WERE OTHERWISE CORRECT, RECEIVED BY HIM PRIOR TO MARCH 15, 1961, AS A RESULT OF THE ERRONEOUS CREDIT FOR SERVICE. ANY PERSON WHO HAS AT ANY TIME REPAID TO THE UNITED STATES ANY AMOUNT PAID TO HIM BASED UPON AN ERRONEOUS CREDIT FOR SERVICE AS CITED IN THIS SECTION IS ENTITLED TO HAVE REFUNDED TO HIM THE AMOUNT REPAID.

SEC. 2. IN THE AUDIT AND SETTLEMENT OF THE ACCOUNTS OF ANY CERTIFYING OR DISBURSING OFFICER OF THE UNITED STATES FULL CREDIT SHALL BE GIVEN FOR THE AMOUNT FOR WHICH LIABILITY IS RELIEVED BY THIS ACT.

SEC. 3. APPROPRIATIONS AVAILABLE FOR THE PAY AND ALLOWANCES OF MEMBERS OF THE NAVAL SERVICE ARE AVAILABLE FOR REFUNDS UNDER THIS ACT.

IN CONNECTION WITH THE APPLICATION OF THE PROVISIONS OF PUBLIC LAW 88- 614, CONSIDERATION MUST BE GIVEN TO THE ACT OF JUNE 25, 1956, CH.439, 70 STAT. 333, THE PERTINENT PROVISIONS OF WHICH ARE NOW CONTAINED IN SECTIONS 516 AND 971, TITLE 10, U.S.C. (1964 ED.).

SECTION 516 GOVERNING THE EFFECT UPON ENLISTED STATUS OF ACCEPTANCE OF APPOINTMENT AS A CADET OR MIDSHIPMAN IS AS FOLLOWS:

(A) THE ENLISTMENT OR PERIOD OF OBLIGATED SERVICE OF AN ENLISTED MEMBER OF THE ARMED FORCES WHO ACCEPTS AN APPOINTMENT AS A CADET AT THE UNITED STATES MILITARY ACADEMY, THE UNITED STATES AIR FORCE ACADEMY,

OR THE UNITED STATES COAST GUARD ACADEMY, OR AS A MIDSHIPMAN AT THE UNITED STATES NAVAL ACADEMY OR IN THE NAVAL RESERVE, MAY NOT BE TERMINATED BECAUSE OF THE ACCEPTANCE OF THAT APPOINTMENT. HOWEVER, WHILE SERVING AS A CADET OR MIDSHIPMAN AT AN ACADEMY, HE IS ENTITLED ONLY TO THE PAY, ALLOWANCES, COMPENSATION, PENSIONS, AND OTHER BENEFITS PROVIDED BY LAW FOR SUCH A CADET OR MIDSHIPMAN OR, IF HE IS A MIDSHIPMAN IN THE NAVAL RESERVE, TO THE COMPENSATION AND EMOLUMENTS OF A MIDSHIPMAN IN THE NAVAL RESERVE.

SECTION 971, PERTAINING TO SERVICE CREDIT, PROVIDES:

THE PERIOD OF SERVICE UNDER AN ENLISTMENT OR PERIOD OF OBLIGATED SERVICE WHILE ALSO SERVING AS A CADET AT THE UNITED STATES MILITARY ACADEMY, THE UNITED STATES AIR FORCE ACADEMY, OR THE UNITED STATES COAST GUARD ACADEMY, OR AS A MIDSHIPMAN AT THE UNITED STATES NAVAL ACADEMY OR IN THE NAVAL RESERVE, UNDER AN APPOINTMENT ACCEPTED AFTER JUNE 25, 1956, MAY NOT BE COUNTED IN COMPUTING, FOR ANY PURPOSE, THE LENGTH OF SERVICE OF AN OFFICER OF AN ARMED FORCE.

DECISION IS REQUESTED AS TO WHETHER PUBLIC LAW 88-614 IS APPLICABLE "TO ALL MEMBERS OR FORMER MEMBERS OF THE NAVAL SERVICE WHO, AS ENLISTED MEMBERS OF THE UNITED STATES NAVAL RESERVE, WERE APPOINTED MIDSHIPMEN IN THE UNITED STATES NAVAL RESERVE AT ANY TIME PRIOR TO MARCH 15, 1961, WITHOUT TERMINATION OF THE ENLISTMENT CONTRACT" AND WHO WERE THEREAFTER ERRONEOUSLY CREDITED IN THE COMPUTATION OF THEIR ACTIVE DUTY BASIC PAY WITH A PERIOD OF ENLISTED SERVICE FOR THE PERIOD THAT THEY ACTUALLY SERVED AS MIDSHIPMEN IN THE UNITED STATES NAVAL RESERVE. IF PUBLIC LAW 88-614 IS HELD AS NOT BEING APPLICABLE TO ALL THE MEMBERS REFERRED TO IN THE PRECEDING QUESTION, THE ADDITIONAL QUESTION IS SUBMITTED AS TO WHETHER THE CITED LAW IS APPLICABLE (1) TO ANY MEMBER "WHO WAS APPOINTED A MIDSHIPMAN, USNR, PRIOR TO THE ENACTMENT" OF THE ACT OF JUNE 25, 1956, OR (2) ONLY TO "THOSE MEMBERS WHO WERE APPOINTED MIDSHIPMEN, USNR, DURING OR IMMEDIATELY FOLLOWING THE ESTABLISHMENT OF THE NAVAL RESERVE OFFICERS' TRAINING CORPS IN AUGUST 1946?

IN ENACTING PUBLIC LAW 88-614, CONGRESS WAS ADVISED BY THE DEPARTMENT OF THE NAVY (SEE PAGES 3 AND 4, S.REPT. NO. 1579, TO ACCOMPANY H.R. 5042, 88TH CONG., WHICH, ON OCTOBER 2, 1964, BECAME PUBLIC LAW 88-614) THAT THE PURPOSE OF THE PROPOSED LEGISLATION WAS TO RELIEVE 40 OR SO NAVAL OFFICERS FROM THE OBLIGATION OF REPAYING TO THE UNITED STATES OVERPAYMENTS TO THEM WHICH HAD OCCURRED AS A RESULT OF INCORRECTLY COMPUTING THEIR SERVICE FOR ACTIVE DUTY PAY PURPOSES. AS EXPLAINED BY THE NAVY, THE NAVY COLLEGE TRAINING PROGRAM (V-12) WAS TERMINATED ON JUNE 30, 1946. MEMBERS IN THAT PROGRAM WHO DID NOT DESIRE TO BE DISCHARGED, BUT WHO WISHED TO CONTINUE THEIR EDUCATION UNDER NAVY SPONSORSHIP, WERE ENLISTED IN AN INACTIVE DUTY STATUS IN THE NAVAL RESERVE PENDING ESTABLISHMENT OF THE NAVAL RESERVE OFFICERS' TRAINING CORPS AUTHORIZED IN THE ACT OF AUGUST 13, 1946, CH. 962, 60 STAT. 1057, 34 U.S.C. 1020 (1952 ED.) WHEN THE LATTER PROGRAM WAS ESTABLISHED IN AUGUST 1946, THE 40 OR SO NAVAL OFFICERS, ABOVE REFERRED TO, WERE APPOINTED MIDSHIPMEN IN THE UNITED STATES NAVAL RESERVE OFFICERS' TRAINING CORPS WITHOUT TERMINATING THEIR ENLISTMENT CONTRACTS. THE NAVY DEPARTMENT FURTHER REPORTED THAT, AS A CONSEQUENCE, THE NAVAL RECORDS OF THESE INDIVIDUALS SHOWED A PERIOD OF TIME RANGING FROM A FEW MONTHS UP TO A YEAR--- PRIOR TO BEING COMMISSIONED--- THAT THEY WERE APPRENTICE SEAMEN IN THE INACTIVE NAVAL RESERVE, WHICH IS CREDITABLE SERVICE IN THE COMPUTATION OF BASIC PAY, AND AT THE SAME TIME THAT THEY WERE MIDSHIPMEN IN THE NAVAL RESERVE, WHICH IS NOT CREDITABLE SERVICE IN COMPUTING BASIC PAY.

IN DECISION OF FEBRUARY 23, 1961, 40 COMP. GEN. 473, IT WAS HELD THAT THE APPOINTMENTS OF PERSONS--- APPARENTLY THE 40 OR SO NAVAL OFFICERS MENTIONED ABOVE--- AS MIDSHIPMEN IN THE UNITED STATES NAVAL RESERVE (IT WILL BE NOTED THAT THE APPOINTMENTS CONCERNED WERE ALL MADE IN 1946 NEARLY 10 YEARS PRIOR TO THE ACT OF JUNE 25, 1956) TERMINATED EACH APPOINTEE'S ENLISTED STATUS IN THE UNITED STATES NAVAL RESERVE AND THAT THERE WAS NO AUTHORITY OF LAW PERMITTING THEM TO INCLUDE THE PERIOD OF TIME THEY HAD SERVED AS MIDSHIPMEN IN THE NAVAL RESERVE IN THE COMPUTATION OF THEIR ACTIVE DUTY BASIC PAY AS OFFICERS IN THE NAVAL SERVICE. IN VIEW OF THE PARTICULAR CIRCUMSTANCES THERE PRESENTED COVERING OVERPAYMENTS WHICH EXTENDED BACK FOR A PERIOD OF MANY YEARS PRIOR TO THE DECISION OF FEBRUARY 23, 1961, COLLECTION ACTION WAS NOT PRESSED BY THIS OFFICE, PENDING THE ENACTMENT OF RELIEF LEGISLATION AS NOW PROVIDED IN PUBLIC LAW 88-614. THE RECORDS INDICATE THAT THE INDIVIDUAL PAY ACCOUNTS OF THE OFFICERS CONCERNED WERE ADJUSTED BY THE DEPARTMENT OF THE NAVY TO THE PROPER BASIS EFFECTIVE FROM MARCH 15, 1961, AND PUBLIC LAW 88-614 RELIEVED THOSE OFFICERS OF ALL LIABILITY TO REFUND TO THE UNITED STATES THE AMOUNTS, WHICH WERE OTHERWISE CORRECT, RECEIVED BY THEM "PRIOR TO MARCH 15, 1961, AS A RESULT OF THE ERRONEOUS CREDIT FOR SERVICE.'

IT SEEMS CLEAR THAT IN CONSIDERING H.R. 5042, 88TH CONG., WHICH BECAME PUBLIC LAW 88-614, THE ATTENTION OF CONGRESS WAS FOCUSED ON THE OVERPAYMENT STATUS OF THE 40 OR SO NAVAL OFFICERS MENTIONED BY THE NAVY DEPARTMENT WHO, AS THE RESULT OF OUR DECISION OF FEBRUARY 23, 1961, WERE FOUND TO HAVE BEEN OVERPAID BY REASON OF THE IMPROPER CREDITING OF THE PERIOD THEY HAD SERVED AS MIDSHIPMEN IN THE UNITED STATES NAVAL RESERVE DURING 1946 AND 1947 IMMEDIATELY FOLLOWING ESTABLISHMENT OF THE NAVAL RESERVE OFFICERS' TRAINING CORPS PROGRAM AUTHORIZED BY THE ACT OF AUGUST 13, 1946. IT SEEMS EQUALLY APPARENT THAT IN ENACTING PUBLIC LAW 88-614 CONGRESS WAS NOT REPEALING OR IN ANY MANNER MODIFYING THE PROVISIONS OF THE ACT OF JUNE 25, 1956, SECTION 4 OF WHICH (NOW CODIFIED AS 10 U.S.C. 971 (1964 ED.) ( EXPRESSLY PRECLUDES CREDIT FOR ANY PERIOD OF SERVICE UNDER AN ENLISTMENT OR PERIOD OF OBLIGATED SERVICE WHILE ALSO SERVING AS A CADET OR MIDSHIPMEN UNDER AN APPOINTMENT ACCEPTED AFTER JUNE 25, 1956, IN COMPUTING, FOR ANY PURPOSE, THE LENGTH OF SERVICE OF AN OFFICER OF AN ARMED FORCE.

ACCORDINGLY, THE FIRST QUESTION IS ANSWERED IN THE NEGATIVE AS TO THOSE OFFICERS OF THE UNIFORMED SERVICES WHO WERE APPOINTED MIDSHIPMEN IN THE UNITED STATES NAVAL RESERVE AFTER JUNE 25, 1956. THE ANSWER TO THE SECOND QUESTION IS IN THE AFFIRMATIVE AS TO ANY OFFICER OF THE UNIFORMED SERVICES WHO WAS APPOINTED AS A MIDSHIPMAN IN THE UNITED STATES NAVAL RESERVE ON OR PRIOR TO JUNE 25, 1956. WHILE THIS LATTER CONCLUSION MAY EXTEND THE BENEFITS OF PUBLIC LAW 88-614 TO MORE NAVAL OFFICERS THAN THE PARTICULAR GROUP MENTIONED IN ITS LEGISLATIVE HISTORY, SUCH ADDITIONAL OFFICERS COME WITHIN THE LITERAL TERMS OF THAT ACT AND THE LANGUAGE OF 10 U.S.C. 971 GOVERNS ONLY IN CASES WHERE THE APPOINTMENT AS A CADET OR MIDSHIPMAN WAS EFFECTED SUBSEQUENT TO JUNE 25, 1956.

CORRESPONDENCE IN THE CASE OF LIEUTENANT THOMAS H. OSWALD, JR., USN (FILE NO. 600981), WAS FORWARDED WITH THE LETTER OF SEPTEMBER 13, 1965, AS AN EXAMPLE OF AN OFFICER WHO WAS APPOINTED A MIDSHIPMAN IN THE UNITED STATES NAVAL RESERVE SUBSEQUENT TO JUNE 25, 1956. THE RECORD SHOWS THAT LIEUTENANT OSWALD ENLISTED IN THE UNITED STATES NAVAL RESERVE ON APRIL 27, 1955; THAT HE BECAME A CONTRACT NROTC STUDENT ON SEPTEMBER 26, 1955 (WHICH DID NOT AFFECT HIS ENLISTED STATUS IN THE UNITED STATES NAVAL RESERVE); THAT ON SEPTEMBER 24, 1956, HE WAS APPOINTED A MIDSHIPMAN IN THE UNITED STATES NAVAL RESERVE AND ON JUNE 3, 1959, HE BECAME AN ENSIGN IN THE REGULAR NAVY. IT APPEARS THAT UPON ACCEPTANCE OF APPOINTMENT AS A MIDSHIPMAN IN THE UNITED STATES NAVAL RESERVE ON SEPTEMBER 24, 1956, HE WAS FULLY ADVISED CONCERNING THE EFFECT OF THE ACT OF JUNE 25, 1956 (NOW 10 U.S.C. 516 AND 971 (1964 ED.) (, WITH RESPECT TO THE CONTINUATION OF HIS ENLISTED STATUS WHILE SERVING AS A MIDSHIPMAN IN THE UNITED STATES NAVAL RESERVE. THEREFORE, HIS APPOINTMENT AS A MIDSHIPMAN, UNITED STATES NAVAL RESERVE, WAS ACCEPTED WITH THE FULL AND COMPLETE UNDERSTANDING ON HIS PART THAT NOTWITHSTANDING HIS ENLISTMENT CONTRACT THE PERIOD OF TIME SERVED AS A MIDSHIPMAN UNDER THE APPOINTMENT OF SEPTEMBER 24, 1956, WOULD NOT BE CREDITABLE IN SUBSEQUENTLY COMPUTING, FOR ANY PURPOSE, HIS LENGTH OF SERVICE AS AN OFFICER OF THE UNIFORMED SERVICES. THE RECORD SHOWS THAT CONTRARY TO THE SPECIFIC PROVISIONS OF THE ACT OF JUNE 25, 1956, LIEUTENANT OSWALD WAS IMPROPERLY CREDITED FOR THE PERIOD OF HIS DUEL ENLISTED-MIDSHIPMAN SERVICE (SEPTEMBER 24, 1956 TO JUNE 2, 1959) IN ESTABLISHING THE RATE OF HIS ACTIVE DUTY BASIC PAY DURING THE PERIOD JUNE 3, 1959 THROUGH DECEMBER 31, 1963. THE ENCLOSURES RECEIVED WITH THE LETTER OF SEPTEMBER 13, 1965, INCLUDE A LETTER DATED MAY 12, 1965 ADDRESSED TO YOUR DEPARTMENT BY LIEUTENANT OSWALD IN WHICH HE INDICATES THAT HE CONSIDERS HIMSELF AS WITHIN THE SCOPE OF PUBLIC LAW 88-614 AND HENCE THAT HE SHOULD BE RELIEVED OF ALL LIABILITY TO REFUND TO THE UNITED STATES THE AMOUNTS OVERPAID HIM DURING THE PERIOD JUNE 3, 1959 TO MARCH 14, 1961, INCLUSIVE.

AS PREVIOUSLY STATED, THE CONGRESS IN ENACTING PUBLIC LAW 88-614 WAS CONCERNED WITH THE PROBLEM OF THE 40 OR SO OFFICERS OR FORMER OFFICERS OF THE NAVAL SERVICE WHOSE STATUS FELL WITHIN THE SCOPE OF OUR DECISION OF FEBRUARY 23, 1961. IT MAY BE ASSUMED (AS DOES LIEUTENANT OSWALD IN HIS LETTER OF MAY 12, 1965) THAT THE CONGRESS, IN CONSIDERING AND TAKING FAVORABLE ACTION ON THE BILL, H.R. 5042, 88TH CONG., WHICH BECAME PUBLIC LAW 88-614, WAS FULLY AWARE OF THE EXPRESS PROHIBITION CONTAINED IN SECTION 4 OF THE ACT OF JUNE 25, 1956 (NOW 10 U.S.C. 971 (1964 ED.) (--- A STATUTORY PROHIBITION WHICH HAD THEN BEEN IN FORCE FOR MORE THAN 8 YEARS. HOWEVER, NO MENTION OR REFERENCE TO THE 1956 ACT IS FOUND IN THE LEGISLATIVE HISTORY OF PUBLIC LAW 88 614. CONGRESS WAS NOT ASKED TO GRANT RELIEF IN PUBLIC LAW 88-614 TO ANY OFFICER WHOSE STATUS CAME WITHIN THE PURVIEW OF THE PROHIBITION CONTAINED IN THE 1956 LAW. IN SUCH CIRCUMSTANCES IT IS OUR VIEW THAT IN ENACTING PUBLIC LAW 88-614 CONGRESS DID NOT CONTEMPLATE EXTENDING THE SAME RELIEF TO OFFICERS WITHIN THE PROHIBITION PRESCRIBED IN THE 1956 ACT AS WAS BEING GRANTED TO THOSE 40 OR SO OFFICERS WHOSE DUAL ENLISTED-MIDSHIPMAN STATUS HAD OCCURRED IN THE 1946 -1947 PERIOD IMMEDIATELY FOLLOWING ESTABLISHMENT OF THE NAVAL RESERVE OFFICERS' TRAINING CORPS PROGRAM UNDER THE ACT OF AUGUST 13, 1946. VIEW OF THE CLEAR PROVISIONS OF THE 1956 ACT, IT SEEMS EVIDENT THAT CONGRESS FELT THAT NO PROBLEM EXISTED OR COULD ARISE WITH RESPECT TO ANY OFFICERS APPOINTED AS CADETS OR MIDSHIPMEN AFTER JUNE 25, 1956. LIEUTENANT OSWALD WAS FULLY ADVISED AS TO HIS RIGHTS UNDER THE 1956 ACT UPON ACCEPTING APPOINTMENT AS A MIDSHIPMAN ON SEPTEMBER 24, 1956. TO HOLD THAT THE RELIEF PROVISIONS OF THE 1964 ACT INTENDED THAT HE BE RELIEVED OF HIS OBLIGATION TO REFUND THE AMOUNT ERRONEOUSLY PAID TO HIM WOULD BE INCONSISTENT WITH THE LEGISLATIVE HISTORY OF THAT ACT AND WITH THE PROVISIONS OF THE ACT OF JUNE 25, 1956, AND THUS WOULD NOT REPRESENT A REASONABLE APPLICATION OF THOSE PROVISIONS.

GAO Contacts

Office of Public Affairs