GAO Design, Implementation, and Evaluation of Training at Selected Agencies

United States General Accounting Office

GAO

Testimony

For Release on Delivery
Expected at
10:00 a.m., EDT
on Thursday
May 18, 2000

HUMAN CAPITAL

Before the Subcommittee on Oversight of Government
Management, Restructuring, and the District of Columbia
Committee on Governmental Affairs
U.S. Senate

Design, Implementation,
and Evaluation of Training
at Selected Agencies
Statement of Michael Brostek, Associate Director
Federal Management and Workforce Issues
General Government Division

GAO/T-GGD-00-131

Statement

Human Capital: Design, Implementation, and
Evaluation of Training Programs at Selected
Agencies
Mr. Chairman and Members of the Subcommittee:
I am pleased to be here today to discuss how training programs have been
designed, implemented, and evaluated at four federal agencies. As social,
economic, and technological changes continue to affect the way in which
the government does business, agencies will need to place special
emphasis on how they develop their employees—or human capital—in
order to maximize their ability to successfully perform their missions and
achieve their strategic goals. Training programs play a key role in how
agencies develop their human capital and improve performance. Agencies
must design and implement these programs to address any identified gaps
in the knowledge and skills that agencies believe are needed to achieve
their missions and goals. Agencies must also evaluate their training
programs to ensure that they are indeed increasing workforce knowledge
and skills and improving individual and agency performance.
During the 1990s, many federal agencies cut back on hiring new staff in
order to reduce the number of employees and meet downsizing goals. As a
result, these agencies also reduced the influx of new people with new
knowledge and skills that agencies needed to help build and sustain
excellence. Moreover, anecdotal evidence regarding overall federal
expenditures on training indicates that, in trying to save on workforcerelated costs, agencies cut back on the training investments needed if their
smaller workforces were to make up for institutional losses in knowledge
and skills. Agencies may need to take a fresh look at their training
resource needs. If additional resources are indeed needed and cannot be
secured through the appropriations process, agencies may need to explore
budget-neutral options, such as reprogramming resources from other
operations accounts, for providing adequate training for their employees.
As part of your Subcommittee’s efforts to improve federal agencies’ human
capital management, you requested that we provide information on
(1) how high-performing organizations approach the design and
implementation of their training and development programs and (2) the
design, implementation, and evaluation of training and development
programs at four federal agencies—the Defense Finance and Accounting
Service (DFAS), the Health Care Financing Administration (HCFA), the
Immigration and Naturalization Service (INS), and the Department of State
(State).

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My statement makes four main points:
• First, high-performing organizations we contacted consistently approached
the design and implementation of their training and development programs
by (1) identifying the knowledge, skills, abilities, and behaviors employees
need to support organizational missions and goals, and measuring the
extent to which employees actually possess those competencies; (2)
designing and implementing training programs to meet any identified gaps
in those needs; and (3) evaluating the extent to which training programs
actually increase employees’ individual competencies and performance
levels as well as overall organizational performance.
• Second, the four agencies we reviewed recognized the importance of
identifying the knowledge and skills needed by their employees to support
the agencies’ missions and strategic goals. The agencies told us that they
were developing a comprehensive approach for identifying mission critical
competencies and measuring the extent to which all of their employees
had these competencies. However, each agency’s progress in this effort
varied. The agencies used or planned to use this information to design (or
update) their training programs in order to address any gaps between
needed and existing knowledge and skills.
• Third, the four agencies all had training curricula for developing employee
skills in selected occupations; required or recommended that employees
complete training on specific topics or meet a minimum number of training
hours; and made training slots available each year on the basis of
estimated needs, priorities, and available resources. The agencies
generally gave higher priority to entry-level employees because of limited
resources (in terms of training funds as well as coverage of employees’
work duties while they were attending training).
• Finally, the four agencies each recognized the importance of measuring the
extent to which their training programs contributed to increased employee
skills and improved support of agency missions and strategic goals.
However, the agencies generally relied on standard end-of-course
evaluations to collect information on participant satisfaction rather than
increased knowledge and skills. Most were still developing more
comprehensive evaluation techniques to determine the extent to which
training was actually increasing employees’ knowledge, skills, and job
performance.
My statement today is based on our interviews with officials from the four
agencies and our review of relevant training documents provided by those

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agencies. As agreed with the Subcommittee staff, the four agencies
included in this review represent a subset of the agencies being directly
contacted by the Subcommittee regarding federal training practices. Their
training policies and practices may not be typical and are not generalizable
to all federal agencies. We also reviewed information from our previous
work on training and development programs and human capital
management in high-performing public and private sector organizations.
We did not collect quantitative data related to these training programs,
since the Subcommittee collected this data directly from these and other
agencies. We performed our review in Washington, D.C., between
December 1999 and April 2000, in accordance with generally accepted
government auditing standards.

Background

The Defense Finance and Accounting Service is responsible for making all
payments, including payroll and contracts, and for maintaining the core
finance and accounting records for the Department of Defense (DOD).
DFAS is also responsible for the consolidation, standardization, upgrading,
and integration of DOD’s central finance and accounting operations,
procedures, and systems. DFAS is headquartered in Arlington, VA, and
also has 5 centers and 20 operating locations that employed approximately
18,000 people as of January 2000.
The Health Care Financing Administration is an agency within the
Department of Health and Human Services responsible for administering
much of the federal government’s multibillion-dollar investment in health
care—primarily the Medicare and Medicaid programs. As of January 2000,
HCFA had about 4,500 employees, approximately 65 percent of whom
were located in HCFA’s central office in Baltimore, MD, and the remainder
in the agency’s 10 regional offices. In addition to its workforce, HCFA
oversees Medicare claims administration contractors.
The Immigration and Naturalization Service is an agency of the
Department of Justice responsible for both administering immigrationrelated services and enforcing immigration laws and regulations. INS is
headquartered in Washington, D.C., and administers its functions through a
network of 3 regional offices, 33 district offices, and 21 Border Patrol
sectors throughout the United States. As of January 2000, INS had about
31,500 employees and was working to hire at least 1,000 new border patrol
agents each year through 2001. INS trains its border patrol agents at the
Border Patrol Academy in Glynco, GA, and at a temporary training facility
in Charleston, SC.

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The Department of State is the principal agency for advancing and
protecting U.S. interests overseas. State maintains a worldwide network
of operations at over 250 overseas locations to support its mission and
those of about 35 other U.S. agencies that operate overseas. As of January
2000, State had about 31,000 employees. State’s Foreign Service Institute
is the federal government’s primary training institution for officers and
support personnel of the foreign affairs community. In addition to State,
the Institute provides training for employees from more than 40 other
government agencies. State’s Diplomatic Security Training Center also
provides specialized training for diplomatic security agents to supplement
training they receive from the Institute.

Training and
Development
Programs in HighPerforming
Organizations

High-performing organizations we contacted recognize the need to invest
in their human capital to achieve their missions and strategic goals. One
fundamental form of that investment consists of providing continuous
training and development opportunities that support personal
development as well as organizational results. Based upon our previous
human capital work, we found that, while their actual programs, policies,
and practices varied, high-performing organizations generally follow
certain key steps in developing training programs they believe to be
1
effective. Specifically, as shown in the following figure, these
organizations
• identify the competencies—commonly defined as knowledge, skills,
abilities, and behaviors—needed to achieve organizational missions and
goals, and measure the extent to which their employees possess these
competencies,
• implement training and development programs to address any identified
competency gaps, and
• evaluate the extent to which their programs actually increase employees’
individual competencies and performance levels as well as the
organization’s overall performance.
We examined the training programs of the four agencies included in this
review in light of these key steps to developing effective training programs.

1

For examples of our previous work noting the human capital management practices of highperforming organizations, see Human Capital: Managing Human Capital in the 21st Century (GAO/TGGD-00-77, Mar. 9, 2000), Human Capital: Key Principles From Nine Private Sector Organizations
(GAO/GGD-00-28, Jan. 31, 2000), Human Capital: A Self-Assessment Checklist for Agency Leaders—
Discussion Draft (GAO/GGD-99-179, Sept. 1999), and Transforming the Civil Service: Building the
Workforce of the Future—Results of a GAO-Sponsored Symposium (GAO/GGD-96-35, Dec. 20, 1995).

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Figure 1: Key Steps in Developing
Training Programs

Identifying and
Measuring the
Knowledge and Skills
Needed to Support
Missions and Goals

The four agencies included in our review recognized that identifying and
measuring the knowledge and skills needed by their employees to support
missions and goals were important steps in developing their training
programs. The degree to which the agencies had actually completed these
steps for all of their employees varied. The agency officials described
several tools that they were developing or using to identify and measure
their employees’ knowledge and skills, including workforce planning
models, needs assessments, knowledge and skills inventories, and
individual development plans (IDP). Officials from each of the agencies
told us that they planned to work with the Office of Personnel
Management (OPM) or outside contractors to assess the reliability and
validity of these tools.
Federal agencies may encounter certain challenges in their efforts to
identify and measure the knowledge and skills that their employees must

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possess to support missions and goals. For example, the four agencies in
our review employed individuals across diverse occupations, some of
which required knowledge and skills that may be more easily measured
than others. For example, border patrol agents could be tested for certain
knowledge and skills, such as their foreign language proficiency, physical
fitness, and marksmanship, whereas some of the knowledge and skills
needed to be an effective contract administrator might not be so readily
determined. Another challenge for agencies may be finding the staff and
resources needed to identify what knowledge and skills are needed for
high performance and to measure in a reliable, valid, and comprehensive
manner the extent to which employees have those competencies.

DFAS

As noted in the agency’s current career development and training plan, in
1996 GAO as well as the Department of Defense (DOD) Inspector General
found that DFAS lacked a comprehensive strategy or program for training
its employees to support the financial and accounting needs of DOD. As a
result, the Office of the Secretary of Defense provided DFAS with
additional training funds and directed that the agency develop and
implement a centralized training program to respond to the developmental
needs of its employees. DFAS officials told us that the agency now uses its
strategic plan, human resources directors’ performance contracts, and an
annual training needs assessment to identify the knowledge and skills that
employees must possess to support the agency’s mission and goals.
Moreover, the officials said that DFAS was piloting a new process to
identify which knowledge and skills gaps could be addressed through
training. This pilot involved assessing training needs 5 years into the
future; systematically collecting managers’ and supervisors’ views on
training needs using interviews, focus groups, and surveys; and requiring
all employees to complete IDPs. To this end, DFAS developed detailed
career development plans for all its occupations that (1) outline the
knowledge and skills employees must possess to support the agency’s
mission and goals, and (2) guide employees as they identify and prioritize
their own training and developmental needs.

HCFA

Last year, we testified that HCFA’s staff had not been sufficiently trained
to effectively support its missions and goals to provide services to
Medicare and Medicaid beneficiaries, as well as to promote the fiscal
2
integrity of those programs. The agency officials told us that HCFA
developed a learning plan for its employees that established training needs
and priorities on the basis of input collected from managers and focus
2

HCFA Management: Agency Faces Multiple Challenges in Managing Its Transition to the 21st Century
(GAO/T-HEHS-99-58, Feb. 11, 1999).

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groups from across the agency. Moreover, HCFA officials stated that the
agency was developing a workforce planning process that would identify
the knowledge and skills employees must possess to support strategic
staffing and training and development that would be aligned with the
agency’s mission and goals. The officials said that the agency was using
guidance from the Department of Health and Human Services, the Office
of Management and Budget, and our human capital self-assessment
checklist, to develop a workforce planning process consisting of four
phases: analyzing the current and future workload, developing current and
future competency frameworks, identifying existing workforce
competencies, and conducting an analysis of any gaps between current
3
and future requirements and the existing workforce.

INS

Agency officials told us that, in an attempt to ensure that employees have
the knowledge and skills needed to administer immigration-related
services and enforce immigration laws and regulations, INS made an effort
to identify and measure the knowledge and skills that border patrol agents,
investigators, and immigration specialists must possess to execute the
tasks INS considers necessary for mission accomplishment. According to
the officials, every 5 years, INS’ research and evaluation unit reviewed the
knowledge and skills that these employees must possess and determined
whether the agency was providing the training and development
opportunities needed to ensure that those core skills were developed. The
agency’s most recent review was completed in 1998. The officials said that
the agency primarily relied upon post-training tests to determine the extent
to which employees actually possessed the identified core skills. The
officials also said that they did not make similar efforts to identify and
measure the knowledge and skills needed for headquarters, administrative,
and other support staff, because the agency did not have the staff or
resources to do so.

State

Agency officials told us that, to identify and measure the knowledge and
skills State’s foreign service officers and diplomatic security agents must
possess to support the agency’s mission of advancing and promoting U.S.
interests overseas, the agency completed (1) a job analysis of its foreign
service generalist corps in 1998 to identify the tasks and activities
performed by those employees as well as the human attributes and foreign
language proficiency required for high performance, and (2) a formal
baseline needs assessment for its diplomatic security agents in the mid1980s, which has been informally updated in the intervening years. The
agency officials also said that State had adopted OPM’s leadership
3

GAO/GGD-99-179.

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competencies for senior executives. State now measures employees’
existing knowledge and skills by testing periodically for language
proficiency, requiring certain employees to pass tests to fulfill agency
certification requirements, and providing leaders access to 360-degree selfassessment instruments that allowed them to identify areas where they
may need further development. New diplomatic security agents are
required to achieve certain baseline test scores at the completion of their
training programs. State is also developing competency-based models for
several occupations—including passport agents, information technology
support staff, and human resource management occupations—that will
identify the competencies needed for high performance, measurement
methods for determining the extent to which staff have these
competencies, and suggested training courses and developmental
activities.

Implementing Training
Programs That
Develop Employees’
Knowledge and Skills

The four agencies we reviewed had training curricula for developing
employee knowledge and skills in selected occupations, and the agencies
generally required that employees complete training on specific topics
(and/or complete a specified minimum number of training hours) included
in those curricula. The agencies generally made training slots available
each year on the basis of estimated needs, priorities, and available
resources. All of the agencies’ training budgets were funded at least in
part from the central agency budget, and all but DFAS also funded a
portion of their training programs by offering courses on a fee-for-service
basis (i.e., explicitly charging organizational units or other agencies an
established fee for each unit of training provided to their employees).
Officials of the four agencies in our review told us that their agencies had
encountered certain challenges to implementing training programs that
strategically developed the knowledge and skills of all of their employees.
For example, agency officials indicated that limited training resources
often necessitated prioritizing the training for new employees (who may
need training to understand an agency’s unique missions, goals, and job
performance expectations) over training for more senior employees.
Moreover, some of the officials also told us that current staffing levels
prevented them from offering employees more training opportunities
because the agencies believed that their staffing levels did not allow for
proper coverage of the employees’ mission-related job responsibilities
while they were attending training.

DFAS

DFAS officials told us that the agency had multiple training programs with
curricula that were specifically focused on increasing the skills of
particular groups of employees. For example, the agency’s largest

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program focused on financial management and financial systems skills.
The agency also had a career development curriculum focused on
professional and executive development and managerial skills. The
agency also had a goal (but not a requirement) that each employee
4
complete 40 hours of training each fiscal year. DFAS asked first-line
supervisors to determine what their employees’ training needs were, and
this information was incorporated into the development of the agency’s
training needs assessment as well as decisions on how many training slots
should be funded each year. DFAS training was centrally funded out of its
operations and maintenance and defense working capital funds
appropriations.

HCFA

HCFA officials told us that the agency had identified curricula that
included basic skills, desktop computer skills, program policy and
operations, management development, and contract/grants certification.
However, according to the officials, much of this core knowledge and
many of these skills were learned by employees before they obtained
employment at HCFA and were maintained through such continuing
education efforts as attending conferences, reading professional literature,
and belonging to professional associations. Thus, training requirements
varied by occupation. For example, systems administrators and
contract/grants officers had specific training requirements, and new
managers were required to receive 40 hours of training upon being
promoted. The agency estimated its training budget needs on the basis of
prior years’ needs and projected needs. The agency funded central
training from its administrative budget, and also provided agency units
with discretionary funds that allowed them the flexibility to purchase
external training or additional internal training slots on a fee-for-service
basis.

INS

INS officials told us that the agency had a curriculum for its border patrol
and other law enforcement employees, but not for the agency’s
nonspecialist employees. Specifically, new border patrol agents were sent
to the Border Patrol Academy for a required 19-week basic training
program, where employees received training in six subjects—physical
training, firearms, driving, operations, law, and Spanish. The agency
required managers and supervisors to complete basic management training
classes, and also developed advanced training courses for experienced
4

In 1998, we recommended that DFAS adopt minimum training requirements, particularly for financial
management employees, because such requirements would help ensure that as many employees as
possible were provided the up-to-date, technical training needed to carry out their responsibilities. See
Financial Management: Training of DOD Financial Managers Could Be Enhanced (GAO/AIMD-98-126,
June 24, 1998).

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(journeyman) special agents. According to INS officials, the agency
ensured that it had sufficient slots for new-hire training by developing
modular costs for budgeting that included the cost of recruiting, hiring,
and training each new hire. The officials told us that the agency could not
provide the same assurance of sufficient slots for journeyman agents;
however, the agency was considering making greater use of distance
learning where appropriate or feasible (firearms training, for example,
could not be offered through distance learning) to ensure that employees
received the training they need while also being able to continue their on5
the-job assignments—a concern of agency supervisors. INS’ fixed training
costs (which represented about 25 percent of the training budget) were
funded from the agency’s central budget, while the remaining variable
costs were funded by providing courses to INS units and divisions on a feefor-service basis.

State

State officials told us that the agency had an extensive training curriculum,
which included profession-specific areas of study (e.g., acquisitions) and
training on foreign languages, information technology, overseas briefings,
leadership and management, and diplomatic security. The agency also
required certain employees to complete specific training courses. For
example, new diplomatic security agents received approximately 24 weeks
of training in such areas as firearms, criminal investigations, and the law.
According to the officials, the agency made initial or entry level training a
higher priority than advanced training for foreign service and diplomatic
security agents, because of a concern that extensive training requirements
could cause experienced employees to be called in from their field
assignments and thus endanger the agency’s ability to accomplish its
mission. The officials told us that the agency determined the number of
training slots to be offered by looking at hiring plans, past enrollments,
assignment projections, and available resources. Each organization within
the agency determined its own training budget, and the agency’s primary
training unit was funded by a direct budget allocation and fees from
agency units and other agencies that sent employees to State training
classes.

5

In 1998, INS contracted out for an assessment of the advanced training needs of its journey-level
employees, including border patrol agents and immigration inspectors. The assessment included a
survey of journeyman-level employees and their supervisors; however, the response rates were fairly
low for border patrol agents and immigration inspectors, at 23 percent and 32 percent, respectively.
The assessment showed that the agency’s competency models for both occupations were valid, the
percentage of employees who received training varied greatly by job classification, and significant
performance gaps existed for several competencies and tasks. Both supervisors and journeyman-level
employees selected training as the best solution for eliminating most of the performance gaps.

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Evaluating Training
Programs

The four agencies we reviewed each recognized the importance of
measuring the extent to which its training programs contributed to
increased employee knowledge and skills and improved mission
accomplishment; however, the agencies’ primary means of evaluation
generally consisted of using end-of-course evaluations to collect
information on participant satisfaction for specific training courses. On a
more positive note, the agencies either had or were developing more
comprehensive evaluation techniques to determine the extent to which (1)
training courses taught employees new knowledge and skills; (2) these
knowledge and skills were actually being applied on the job; and (3)
training courses had any long-term impact on overall agency performance.
The agencies also told us that they used central databases to track the
training that their employees had completed.
The four agencies included in our review have encountered several
challenges to evaluating their training and development programs, which
may be attributed in part to the general difficulty associated with
measuring the impact of training on individual and organizational
performance for any organization. Measurement difficulties aside,
agencies may also lack the staff and resources needed to complete indepth evaluations. Moreover, even in those instances where an agency
might have staff and resources to complete training evaluations, low
participation on the part of employees and managers in surveys and focus
groups may limit an agency’s access to the data needed to complete valid,
useful evaluations.

DFAS

DFAS officials told us that they evaluated their training programs by
asking participants to complete end-of-course evaluations. The agency
was also developing an evaluation model that would allow it to determine
more comprehensively the effectiveness of its various training programs.
The officials described this model as including the means to collect not
only information on participant satisfaction with training courses, but also
information on the extent to which participants had acquired specific
knowledge and skills, improved their performance on the job, and
contributed to improved business results. The officials stated that the
agency had contracted with OPM to help it develop valid measurement
instruments for its financial management training efforts in order to pilot
its new training evaluation model. The officials also stated that the agency
used a central database to track the specific training completed by
employees.

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HCFA

HCFA officials stated that the agency generally used end-of-course
evaluations to determine the extent to which their training courses
improve individual and organizational performance and mission
accomplishment. Additionally, the officials stated that the agency
developed an annual learning plan process that included a qualitative
review of the effectiveness of existing training classes and career
development programs. However, the officials also stated that the agency
recognized the need for improving its evaluation of on-the-job and longterm impacts of its training courses on employee and organizational
performance. As a result, the officials stated that they were working with
a contractor to develop additional tools and guidance for evaluating
training courses and career development programs. For example, the
officials told us that the agency was purchasing a software application that
would provide an automated means for conducting customized end-ofcourse and follow-up evaluations that addressed the value of training and
subsequent performance improvements. The officials also told us that the
agency had a database to track all employee training that was at least 1 day
in length, and that those units that had established a training requirement
also tracked the extent to which their employees had completed those
requirements.

INS

INS officials told us that their agency evaluated and validated their training
and development programs for border patrol agents, investigators, and
immigration specialists at several levels. First, the officials stated that INS
administered end-of-course evaluations to training participants that
allowed them to assess participants’ views on the training facilities,
materials, and instructors. They also said that INS administered tests and
practical exercises as part of its training programs that allowed the agency
to make general assessments as to the participants’ increase in knowledge
or skills as a result of the training. For example, border patrol agents were
tested on their physical fitness, marksmanship, foreign language abilities,
and reaction times. Finally, the agency officials stated that INS used
operations data and feedback collected through periodic surveys and focus
groups to determine the effectiveness of training programs in preparing
participants to perform specific tasks. While INS evaluated the training and
development of its border patrol agents, investigators, and immigration
specialists, the officials stated that the agency did not comprehensively
evaluate the training and development that headquarters, administrative,
and other support staff receive due to staff and resources limitations. INS
told us that they used a database to track the specific training completed
by its employees.

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State

State officials told us that the agency regularly sought input and feedback
from its various units as well as from other agencies that used its training
services to determine whether the courses met their training needs and
were believed to have improved individual and organizational
performance. The officials stated that the agency asked its employees to
complete end-of-course evaluations not only for State training, but also for
external training they attended. The officials also told us that State’s
Inspector General was responsible for inspecting and auditing training
programs as part of their overall mission. Diplomatic security officials
said that they had previously completed long-term course evaluations, but
because of downsizing within their training operations, this capability was
now limited. To improve the extent to which State can evaluate on-the-job
and long-term individual and organizational benefits of training courses on
mission accomplishment, the agency was developing methods to obtain
post-training assessment data from both participants and their supervisors.
The officials indicated that State was also working on explicitly linking
training to the agency’s mission and strategic goals. The agency used a
registration and enrollment database to track internal and external
training—a similar, but separate database was used to track diplomatic
security agents’ training and certifications.

Conclusions

As part of adopting more strategic and performance-based management
practices, agencies must be prepared to focus on how best to invest in
their people, or human capital, to achieve high performance of their
missions and strategic goals. To achieve this high performance, agencies
may need to place particular emphasis on the training and development of
their employees to ensure that they have the competencies—knowledge,
skills, abilities, and behaviors--needed to successfully perform and
contribute to agencies’ mission-critical activities. To design and
implement effective training programs, agencies must (1) identify the
competencies needed to achieve their specific mission and goals and
measure the extent to which their employees exhibit those competencies;
(2) identify training and development needs to be addressed; and once
those training opportunities are in place; (3) evaluate the extent to which
their programs are actually increasing employees’ individual competencies
and individual and overall organization performance levels.
Our review of the training programs of DFAS, HCFA, INS, and the State
Department suggests that agencies recognize the importance of, and are in
the early stages of seeking to improve, their training and development
programs using these basic steps. However, these agencies also face a
number of challenges that could make the execution and completion of
these steps difficult, including a reported lack of staff and resources

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needed to apply the steps across all groups of employees and with
sufficient rigor. If agencies determine that additional training resources
are needed and they are unable to obtain these resources through the
appropriations process, they may need to consider budget neutral options,
such as reprogramming resources from other operations accounts, for
providing adequate training for all of their employees.
Mr. Chairman and Members of the Subcommittee, this concludes my
prepared statement. At this time, I would be pleased to answer any
questions you may have.

GAO Contacts and
Acknowledgements

For further information regarding this testimony, please contact Michael
Brostek, Associate Director, Federal Management and Workforce Issues,
at (202) 512-8676. Individuals making key contributions to this testimony
included Charlesetta Bailey, Jennifer Cruise, and Thomas Fox.

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