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Report to the Chairman, Committee on Commerce, Science, and 
Transportation, U.S. Senate:

July 2003:

Professional Boxing:

Issues Related to the Protection of Boxers' Health, Safety, and 
Economic Interests:

GAO-03-699:

GAO Highlights:

Highlights of GAO-03-699, a report to the Chairman, Committee on 
Commerce, Science, and Transportation, U.S. Senate 

Why GAO Did This Study:

The Professional Boxing Safety Act of 1996 established minimum health 
and safety standards for professional boxing and provided for limited 
federal oversight by the Department of Justice and the Federal Trade 
Commission. In 2000, the Muhammad Ali Boxing Reform Act amended the 
act to better protect boxers’ economic well-being and enhance the 
integrity of the sport. However, reports of problems continue, 
including permanent and sometimes fatal injuries, economic 
exploitation, and corruption.

GAO was asked to (1) identify fundamental elements considered 
important to protect professional boxers and enhance the integrity of 
the sport; (2) assess the extent to which provisions of the 
Professional Boxing Safety Act of 1996, as amended (the act), cover 
these elements and determine whether selected state and tribal boxing 
commissions have documentation indicating compliance with the act’s 
provisions; (3) determine whether selected states and tribes have 
provisions that cover additional elements; and (4) identify federal 
actions taken under the act. 

What GAO Found:

Based on GAO’s review of congressional testimonies and national 
studies dating from 1994 through 2002, GAO identified 15 fundamental 
elements that are considered important to protect boxers’ health, 
safety, and economic well-being and to enhance the integrity of the 
sport. 

The act addresses 10 of the 15 fundamental elements that GAO 
identified. The 8 (of 46) state and 2 (of 8) tribal boxing commissions 
that GAO selected for review accounted for 49 percent of the fights in 
2001 and varied in the extent to which they had documentation 
indicating compliance with the 10 provisions of the act related to the 
fundamental elements. For example, all 10 commissions had 
documentation indicating compliance at least 75 percent of the time 
for 3 provisions—requiring prefight medical exams, disclosure of 
purses and payments, and registration of boxers—but only 2 commissions 
had documentation indicating compliance at least 75 percent of the 
time for a provision prohibiting conflicts of interest. Commissions 
either gave no reason for the lack of documentation, cited privacy or 
liability concerns, or said they were unaware of the federal 
provision. 

The eight states and two tribes that GAO reviewed vary in the extent 
to which they adopted additional provisions that cover elements not 
covered by the act’s provisions. The number of such provisions ranges 
from 10 (California) to 4 (Missouri). For example, the states have 
provisions requiring the filing of postfight medical reports, uniform 
boxing and scoring rules, and boxing commission officials’ knowledge 
of the sport. 

Federal actions taken under the act have been limited. The Department 
of Justice said it has not exercised its authority to prosecute cases 
because none have been referred to it by federal law enforcement 
authorities. Furthermore it noted that violations under the act are 
misdemeanors, and it generally applies its resources to prosecuting 
felonies. The Federal Trade Commission periodically checks the Web 
sites of the organizations that sanction professional boxing events to 
see whether they have posted the information that they are required to 
make available to the public and has found them to be adequate. 
Legislation was recently introduced to significantly amend the act by, 
among other things, creating a new organization within the Department 
of Labor that would provide oversight and enforcement of boxing laws. 
This new federal organization is intended to facilitate more uniform 
enforcement of federal requirements aimed at enhancing boxers’ health, 
safety, and general interests as well as the integrity of the sport. 

The Department of Justice and the Federal Trade Commission provided 
only technical comments on our report. The Association of Boxing 
Commissions and five state and tribal commissions had concerns about 
the lack of existing federal enforcement and the economic impact of 
any additional federal requirements. 

www.gao.gov/cgi-bin/getrpt?GAO-03-699.

To view the full product, including the scope and methodology, click 
on the link above. For more information, contact Bernard Ungar, (202) 
512-4232, ungarb@gao.gov.

[End of section]

Contents:

Letter:

Results in Brief:

Fundamental Elements Considered Important to Address Health and Safety 
and Economic Problems Facing Professional Boxing:

The Act's Provisions Fully or Partially Cover 10 Fundamental Elements, 
and Selected Commissions Varied in the Extent to Which They Had 
Documentation Indicating Compliance:

Selected States and Tribes Vary in the Extent to Which Their Provisions 
Cover Additional Fundamental Elements:

Federal Action under the Act Has Been Limited:

Concluding Observations:

Agency Comments and Our Evaluation:

Appendixes:

Appendix I: Professional Boxing Events Held in the United States during
Calendar Year 2001: 

Appendix II: Fundamental Elements to Address Health and Safety,
Economic, and Integrity Problems in Professional Boxing: 

Health and Safety 23

Economic Protection 26

Integrity of the Sport 28

Appendix III: Selected Boxing Commissions’ Documentation of
Compliance with the Act’s Provisions 31

Appendix IV: State and Tribal Provisions That Cover Additional Health,
Safety, Economic, and Integrity Elements

Conduct Postfight Medical Examinations, Including Neurological 
Testing:

Monitor Training Injuries:

File Postfight Medical Reports:

Require Health and Life Insurance Before and After Fights:

Enforce Suspensions for Training Injuries:

Require Pension Plans:

Require Disclosure of All Purses and Payments to Trainers and Boxers:

Prohibit Conflicts of Interest for Judges and Referees:

Require Registration and Training for Trainers, Managers, Promoters, 
and Physicians:

Preclude Sanctioning Organizations from Exercising Undue Influence:

Select Uniform Boxing and Scoring Rules:

Require Boxing Knowledge for Commission Officials:

Appendix V: Objectives, Scope, and Methodology: 

Appendix VI: Comments from the Association of Boxing Commissions: 

Appendix VII: Comments from the Missouri Office of Athletics: 

Appendix VIII: Comments from the Miccosukee Athletic Commission: 

Appendix IX: Comments from the Mohegan Tribal Gaming Commission
Athletic Unit: 

Appendix X: Comments from the Pennsylvania Athletic Commission: 

Appendix XI: Comments from the Texas Department of Licensing and
Regulations: 

Appendix XII: Contacts and Contributors: 

Contact: 

Contributors: 

Tables 

Table 1: Fundamental Elements Considered Important to Address
Major Problems Facing Professional Boxing: 

Table 2: Extent to Which the Act’s Provisions Cover Fundamental
Elements to Help Address Major Problems in Professional Boxing: 

Figures 

Figure 1: Selected Boxing Commissions’ Documentation of
Compliance with the Act’s Provisions Related to: 

Fundamental Elements: 

Figure 2: Extent to Which State and Tribal Provisions Cover
Additional Fundamental Elements: 

Figure 3: Selected Commissions’ Documentation of Compliance
with the Act’s Provisions for Boxing Events Held in 2001: 

Figure 4: Evaluate Medical Information and Assess Risks: 

Figure 5: Require Minimum Uniform Contractual Terms: 

Figure 6: Require Standards for Rating Boxers to Protect against
Mismatches: 

Figure 7: Conduct Prefight Medical Examinations: 

Figure 8: Ensure Presence of Medical Personnel and Equipment: 

Figure 9: Require Health Insurance During Matches: 

Figure 10: Honor Suspensions Imposed by Other Commissions: 

Figure 11: Require Disclosure of Purses and Payments to Promoters
and Judges: 

Figure 12: Prohibit Conflicts of Interest for Boxers, Promoters, and
Commission Representatives: 

Figure 13: Require Registration for Boxers and Certification and
Approval for Ring Officials: 

Abbreviations: 

ABC: Association of Boxing Commissions:

FTC: Federal Trade Commission:

NAAG: National Association of Attorneys General:

USBA: United States Boxing Administration :

Letter July 21, 2003:

The Honorable John McCain 
Chairman, 
Committee on Commerce, Science, and Transportation 
United States Senate:

Dear Mr. Chairman:

Congress has recognized that boxing is the only major professional 
sport in the United States without a central regulatory authority that 
establishes and enforces uniform rules, business practices, and ethical 
standards. There is no other major professional sport in which the 
rules and regulations--and their enforcement--vary so widely. As a 
result, the sport has been plagued with reports of permanent and 
sometimes fatal injuries, the economic exploitation of boxers, and 
corruption. The Association of Boxing Commissions, a 15-year-old 
nonprofit organization representing 46 state and 8 tribal boxing 
commissions located throughout the United States,[Footnote 1] promotes 
uniform health and safety provisions for professional boxing, but has 
no enforcement authority over its members, and its effectiveness in 
regulating boxing depends on mutual cooperation.

In 1996, because the states and tribes, which are primarily responsible 
for establishing provisions to regulate professional boxing, were not 
uniformly protecting the health and safety of professional boxers, 
Congress enacted the Professional Boxing Safety Act of 1996. This act 
established minimum health and safety standards and licensing 
provisions, along with enforcement responsibilities and penalties for 
violations. In 2000, Congress amended the 1996 act by passing the 
Muhammad Ali Boxing Reform Act, which established provisions to protect 
boxers from economic exploitation and to enhance the integrity of the 
sport.

The 1996 act, as amended (the act), authorizes the Department of 
Justice to investigate and prosecute violations of the law and it 
provides for state and civil remedies as well as federal criminal 
prosecution. Within the Department of Justice, the Federal Bureau of 
Investigation is responsible for investigating violations of the law. 
Generally, the U.S. Attorneys are responsible for prosecuting 
violations of laws. The act further provides that organizations 
sanctioning boxing matches[Footnote 2] annually provide certain 
information to the Federal Trade Commission or otherwise make such 
information available to the public through the Internet. The Federal 
Trade Commission is required to make the information provided to it 
available to the public.

This report responds to your request that we review current efforts to 
protect the health, safety, and economic well-being of professional 
boxers and to enhance the integrity of the sport. As agreed with your 
office, we addressed the following questions:

* What fundamental elements are considered important to address major 
health and safety, economic, and integrity problems facing professional 
boxing?

* To what extent do the act's provisions cover these elements, and to 
what extent do selected state and tribal boxing commissions have 
documentation indicating compliance with the act's provisions?

* To what extent have the selected states and tribes adopted provisions 
that cover fundamental elements that are not covered in the act?

* What actions have the Department of Justice and the Federal Trade 
Commission taken under the act?

To identify the fundamental elements that are considered important to 
address major health and safety, economic, and integrity problems 
facing professional boxing, we reviewed congressional testimony and 
studies on professional boxing conducted by a task force of the 
National Association of Attorneys General, the Department of Health and 
Human Services, and the Department of Labor. From these sources, which 
documented problems in the boxing industry and recommended actions to 
address them, we identified major problems facing the sport and 
consolidated the recommendations into 15 fundamental elements that are 
considered important in helping to provide an adequate level of health, 
safety, and economic protection to boxers and enhance the integrity of 
the sport. We discussed these elements with the Association of Boxing 
Commissions, which agreed that the elements could help provide the 
desired protection and enhancement.

To assess the extent to which the act covers the elements we 
identified, we analyzed the act's provisions and determined how many 
address the fundamental elements, either fully or partially. To assess 
the extent to which selected state and tribal boxing commissions have 
documented their compliance with the act's provisions, we selected 
8[Footnote 3] of the 46 state boxing commissions and 2[Footnote 4] of 
the 8 tribal boxing commissions for review. These 10 commissions 
accounted for 383, or 49 percent, of the 777 professional boxing events 
held in the United States in 2001. (See app. I for a listing of the 
professional boxing events held by state and tribal commissions in 
2001.) At 2 state (Indiana and Michigan) and the 2 tribal (Miccosukee 
and Mohegan Sun) commissions, we reviewed the case files for all 
professional boxing events held in 2001, the most recent year for which 
we could obtain complete information, and at the remaining commissions, 
we randomly selected a sample of case files for review. From our 
reviews of these case files, we determined the extent to which each of 
the 8 state and 2 tribal boxing commissions had documentation 
indicating compliance in 2001 with provisions in the act that related 
to the fundamental elements. We did not independently verify that the 
provisions were met. Our findings for these 10 commissions cannot be 
generalized to all 46 state and 8 tribal boxing commissions.

To assess the extent to which selected states and tribes have 
provisions that cover fundamental elements in addition to those covered 
in the act, we reviewed the boxing provisions of the eight states and 
two tribes and identified fundamental elements that do not appear in 
the act. We confirmed with the boxing commissions of these states and 
tribes that they agreed with our analysis of their provisions. We did 
not assess the extent to which the states and tribes had implemented or 
enforced the provisions that cover the additional fundamental elements.

To determine what actions the Department of Justice and the Federal 
Trade Commission have taken under the act, we asked Justice officials 
whether they had initiated any civil enforcement proceedings or 
criminal prosecutions of potential violators of the act in the eight 
states and two tribal jurisdictions covered by our review. We also 
reviewed the department's central case management system for possible 
cases prosecuted during fiscal years 1996 through 2002. To determine 
whether the sanctioning organizations were making the information they 
are required to provide available to the public, we reviewed the 
Internet Web sites of 14 sanctioning organizations to see whether the 
required information was posted.

We conducted our review from September 2002 through July 2003 in 
accordance with generally accepted government auditing standards. 
Appendix V provides further details about our objectives, scope, and 
methodology.

Results in Brief:

From our review of congressional testimonies and national studies 
dating from 1994 through 2002, we identified 15 fundamental elements 
that are considered important to protect boxers' health, safety, and 
economic well-being and enhance the integrity of the sport. Six of 
these elements address health and safety issues, four establish 
economic protections for boxers, and five would help prevent 
corruption.

The act's provisions cover 10 of the fundamental elements that we 
identified--1 fully and 9 partially. For example, one provision fully 
covers the element requiring evaluations of medical information on 
boxers and assessments of the risks involved in allowing them to fight 
before each match, but only partially covers the element requiring 
prefight and postfight medical examinations, including neurological 
testing. (The provision requires prefight examinations, but not 
postfight examinations or neurological testing.) The 8 state and 2 
tribal boxing commissions that we reviewed varied in the extent to 
which they had documentation indicating compliance with the act's 10 
provisions. All 10 commissions had documentation indicating compliance 
at least 75 percent of the time for 3 provisions--those requiring 
prefight medical exams, disclosure of purses and payments, and 
registration of boxers--but only 2 commissions had documentation at 
least 75 percent of the time for the provision prohibiting conflicts of 
interest. The commissions' documentation for the remaining 6 provisions 
varied within this range. When asked why they did not document their 
compliance with particular provisions, the commissions often did not 
provide a reason, but when they did, they generally identified 
conflicts between state and federal law, said they were unaware of the 
federal provision, or said they thought documentation was not needed.

The eight states and two tribes that we reviewed vary in the extent to 
which they have adopted provisions that cover health and safety, 
economic, and integrity elements in addition to those covered by the 
act's provisions. Each of these states and tribes has some provisions 
that cover additional elements. The number of additional elements 
enacted by an individual state or tribe ranges from 10 (California) to 
4 (Missouri). All 10 states and tribes have enacted the element 
requiring uniform boxing and scoring rules, but California was the only 
state that enacted 3 additional elements--for monitoring injuries 
sustained during training, suspending boxers for debilitating training 
injuries, and providing pension plans for boxers. The primary reason 
provided by the states and tribes for not enacting elements in addition 
to those covered by the act was that the elements would be too costly 
to implement.

Federal action under the act has been limited. According to the 
Department of Justice, it has not exercised its authority to prosecute 
cases because no cases have been referred to it by federal law 
enforcement authorities. The department said there were no records of 
cases brought by the U.S. Attorneys' offices under the federal boxing 
legislation during fiscal years 1996 through 2002 and that no referrals 
from law enforcement agencies were made. Justice officials also said 
violations of the boxing statutes are misdemeanors and the department 
generally applies its resources to prosecuting felonies. The 
Association of Boxing Commissions, in commenting on a draft of this 
report, said it had made two referrals to U.S. Attorneys' offices, 
which were not prosecuted. The association said one referral was 
dismissed because the issue was subsequently resolved and the 
association had not received a response to the other referral. The 
Federal Trade Commission's responsibility under the act is limited to 
making the information it receives from sanctioning organizations 
available to the public. The commission said it periodically checks the 
various sanctioning organizations' Web sites to assess whether the 
required information has been made available to the public. Our review 
of the Web sites of 14 sanctioning organizations found that this 
information was posted on the Internet. Legislation was recently 
introduced to significantly amend the act by, among other things, 
creating a new organization within the Department of Labor that would 
provide oversight and enforcement of the federal boxing laws. This new 
federal organization is intended to facilitate more uniform enforcement 
of federal requirements aimed at enhancing boxers' health, safety, and 
economic interests as well as the integrity of the sport.

The Department of Justice and the Federal Trade Commission had only 
technical comments on our draft report. In commenting on our report, 
the president of the Association of Boxing Commissions said much needs 
to be done to achieve uniformity in the regulation of boxing. Some of 
the states and tribes who commented on our report would welcome federal 
involvement while others said they are concerned about the costs of 
implementing any new measures. Some also noted that no federal agency 
is enforcing the existing federal laws protecting professional boxers.

Fundamental Elements Considered Important to Address Health and Safety 
and Economic Problems Facing Professional Boxing:

According to our review of congressional testimonies[Footnote 5] and 
national studies on professional boxing dating from 1994 through 
2002,[Footnote 6] 15 fundamental elements are considered important in 
helping address the sport's major problems. Six elements could help to 
protect the health and safety of professional boxers, four could help 
to protect their economic interests, and five could help to correct 
problems affecting the integrity of the sport.

The six elements that could help to protect the health and safety of 
boxers would provide:

* medical examinations, including neurological testing;

* monitoring of training injuries;

* assessments of medical risks;

* health and life insurance;

* the presence of appropriate medical personnel and equipment; and:

* enforcement of suspensions for injuries.

According to the testimonies and studies, these elements are important 
because, although the overall rate of injury is lower in professional 
boxing than in many other sports, the risk of severe or permanent brain 
injury is greater. Neurological testing may be needed to detect such 
injury. Furthermore, because injuries may occur during training and 
sparring as well as during boxing events, monitoring during training 
was recommended, and health and life insurance may be needed before and 
after as well as during events. In some instances, the treatment a 
fighter receives in the initial minutes after an injury determines 
whether the fighter recovers or sustains permanent damage or death. 
Having an ambulance and qualified medical personnel on-site, rather 
than on call, can be critical. Enforcement of suspensions imposed by 
boxing commissions in other states is important to prevent injured 
boxers from trying to fight outside the states in which they are 
registered before their injuries have healed.

The four elements that could help to protect boxers' economic interests 
would:

* require pension plans for boxers,

* require full disclosure of purses and payments,

* require minimum uniform contractual terms between boxers and 
promoters, and:

* prohibit conflicts of interest.

Without a union to represent their economic interests, boxers have 
often been exploited, and although the sport has generated enormous 
wealth for others, many professional boxers have been left penniless. 
Comprehensive pension plans for boxers are almost nonexistent, and 
boxers have sometimes been left to pay trainers out of their share of 
the fight purse when the financial responsibilities of promoters and 
managers were not disclosed in advance. Conflicts of interest between 
promoters and managers and long-term contracts with promoters have also 
disadvantaged boxers.

The 5 elements that could help to correct problems affecting the 
integrity of the sport would:

* require registration and training for judges, referees, and others;

* prevent sanctioning organizations from exercising undue influence in 
the selection of judges;

* establish uniform boxing and scoring rules;

* require reviews of sanctioning organizations' rankings of boxers; 
and:

* require knowledge of the sport for commission officials.

Reports of unqualified officials, last-minute changes in the procedures 
for selecting judges, nonstandard boxing and scoring rules, fraudulent 
rankings that have resulted in injury and even death for weaker boxers, 
and political appointments to boxing commissions have undermined the 
integrity of the sport.

Table 1 sets forth the 15 elements we identified. For more detailed 
information on the problems discussed in the testimonies and studies 
and the recommendations made to address these problems, see appendix 
II.

Table 1: Fundamental Elements Considered Important to Address Major 
Problems Facing Professional Boxing:

Health and safety: 1. Conduct prefight and postfight medical 
examinations, including neurological testing; Economic protection: 7. 
Require pension plans for boxers; Integrity of the sport: 11. Require 
registration and training for boxers, trainers, managers, promoters, 
physicians, and other ring officials.

Health and safety: 2. Monitor injuries sustained during gym training 
(e.g., sparring) before events; Economic protection: 8. Require full 
and open disclosure of all purses and costs of bouts, breaking out 
amounts paid to promoters, sanctioning bodies, judges, trainers, 
boxers, and others; Integrity of the sport: 12. Ensure that 
sanctioning organizations do not influence the selection of judges.

Health and safety: 3. Evaluate medical information on boxers and assess 
the risks involved before allowing a boxer to fight; Economic 
protection: 9. Prohibit conflicts of interest for boxers, promoters, 
managers, judges, referees, state boxing commission representatives, 
and sanctioning organization representatives; Integrity of the sport: 
13. Require uniform boxing and scoring rules for events, such as the 
championship rules of the Association of Boxing Commissions (ABC).

Health and safety: 4. Ensure the presence of appropriate medical 
personnel and equipment during and after each match and require the 
filing of postfight medical reports; Economic protection: 10. Require 
minimum uniform contractual terms between boxers and promoters; 
Integrity of the sport: 14. Require standards for rating boxers, 
considering their records of wins and losses, weight differentials, 
caliber of opponents, and number of past fights.

Health and safety: 5. Require health and life insurance for boxers 
before, during, and after each match; Economic protection: [Empty]; 
Integrity of the sport: 15. Require officials serving on boxing 
commissions to have knowledge of professional boxing.

Health and safety: 6. Honor other states' suspensions of boxers; 
monitor training injuries in real time, and suspend boxers who sustain 
debilitating training injuries; Economic protection: [Empty]; 
Integrity of the sport: [Empty].

Source: GAO.

Note: Our identification of the fundamental elements is based on the 
congressional testimonies and national studies that we reviewed. Some 
of these elements have multiple effects and may be related to more than 
one category (e.g., health and safety, economic protection, or 
integrity of the sport). For example, the element prohibiting conflicts 
of interest not only affects the economic interests of boxers but may 
also be related to the integrity of the sport.

[End of table]

The Act's Provisions Fully or Partially Cover 10 Fundamental Elements, 
and Selected Commissions Varied in the Extent to Which They Had 
Documentation Indicating Compliance:

The act's provisions fully or partially cover 10 of the elements that 
we identified as important to address the health and safety, economic, 
and integrity problems facing professional boxing. Our analysis shows 
that one of the act's provisions fully covers the element that requires 
evaluations of medical information on boxers and assessments of the 
risks involved in allowing them to fight before each match. The act's 
provisions partially cover 9 elements. For example, one provision 
partially covers the element requiring medical examinations, including 
neurological testing, before and after a fight. (The provision requires 
prefight, but not postfight, examinations and no neurological testing.) 
Another provision partially covers the element requiring the presence 
of medical personnel and equipment at fights and the filing of 
postfight medical reports. (It requires the presence of medical 
personnel and equipment, but not the filing of postfight medical 
reports.) Table 2 sets forth our analysis of the extent to which the 
act's provisions cover the fundamental elements we identified.

Table 2: Extent to Which the Act's Provisions Cover Fundamental 
Elements to Help Address Major Problems in Professional Boxing:

Act's provision: Health and safety:

Act's provision: Require prefight medical examinations; Fundamental 
element: Health and safety: Conduct prefight and postfight medical 
examinations, including neurological testing; Extent to which the act 
covers the element: Health and safety: Partially--the act's provision 
does not require a postfight medical examination or any neurological 
testing.

Act's provision: Evaluate medical information on boxers and assess the 
risks involved before allowing a boxer to fight; Fundamental element: 
Health and safety: Evaluate medical information on boxers and assess 
the risks involved before allowing a boxer to fight; Extent to which 
the act covers the element: Health and safety: Fully.

Act's provision: Ensure the presence of appropriate medical personnel 
and equipment during and after each match; Fundamental element: Health 
and safety: Ensure the presence of appropriate medical personnel and 
equipment during and after each match and require the filing of 
postfight reports; Extent to which the act covers the element: Health 
and safety: Partially--the act's provision does not require the filing 
of postfight medical reports.

Act's provision: Require health insurance for boxers during each 
match; Fundamental element: Health and safety: Require health and life 
insurance for boxers before, during, and after each match; Extent to 
which the act covers the element: Health and safety: Partially--the 
act's provision does not require health insurance for boxers before and 
after each match, and it does not require life insurance.

Act's provision: Honor other states' suspensions of boxers; 
Fundamental element: Health and safety: Honor other states' suspensions 
of boxers, monitor training injuries in real time, and suspend boxers 
who sustain debilitating training injuries; Extent to which the act 
covers the element: Health and safety: Partially--the act's provision 
does not require states to monitor training injuries in real time or 
suspend boxers who sustain debilitating training injuries.

Act's provision: Economic protection:

Act's provision: Require full and open disclosure of all purses and 
costs of bouts, breaking out amounts paid to promoters and judges; 
Fundamental element: Health and safety: Require full and open 
disclosure of all purses and costs of bouts, breaking out amounts paid 
to promoters, judges, trainers, boxers, and others; Extent to which 
the act covers the element: Health and safety: Partially--the act's 
provision does not require such disclosure for boxers and trainers.

Act's provision: Prohibit conflicts of interest for promoters and 
commission representatives; Fundamental element: Health and safety: 
Prohibit conflicts of interest for boxers, promoters, managers, judges, 
referees, state boxing commission representatives, and sanctioning 
organization representatives; Extent to which the act covers the 
element: Health and safety: Partially--the act's provision does not 
prohibit conflicts of interest for judges and referees.

Act's provision: Recommend minimum uniform contractual terms between 
boxers and promoters; Fundamental element: Health and safety: Require 
minimum uniform contractual terms between boxers and promoters; Extent 
to which the act covers the element: Health and safety: Partially--the 
act's provision establishes guidelines for, but does not require such 
terms.

Act's provision: Integrity of the sport:

Act's provision: Require registration for boxers and certification and 
approval for ring officials; Fundamental element: Health and safety: 
Require registration and training for boxers, trainers, managers, 
promoters, physicians, and other ring officials; Extent to which the 
act covers the element: Health and safety: Partially--the act's 
provision does not require registration for trainers, managers, 
promoters or physicians, and it does not require training for any 
parties.

Act's provision: Recommend standards for rating boxers, considering 
their records of wins and losses, weight differentials, caliber of 
opponents, and number of past fights; Fundamental element: Health and 
safety: Require standards for rating boxers, considering their records 
of wins and losses, weight differentials, caliber of opponents, and 
number of past fights; Extent to which the act covers the element: 
Health and safety: Partially--the act's provision establishes 
guidelines for, but does not require, such standards.

Source: GAO.

[End of table]

On March 13, 2003, the Senate Committee on Commerce, Science, and 
Transportation approved S. 275, a bill that would further amend the 
act. If enacted, the proposed legislation would expand the act's 
coverage of four fundamental elements--those dealing with the 
evaluation of medical information, minimum contractual terms, the 
selection of judges, and reviews of rankings. In addition, the proposed 
legislation would establish the United States Boxing Administration 
(USBA) within the Department of Labor and empower it to consider other 
fundamental elements in addressing professional boxers' health, safety, 
and other concerns. USBA would be responsible for providing oversight, 
administering the federal boxing laws, and issuing minimum standards to 
protect the health, safety, and general interests of professional 
boxers. Its responsibilities would also include licensing boxers, 
promoters, managers, and sanctioning organizations and maintaining a 
registry of medical records and medical suspension information on all 
boxers. USBA would also be authorized to conduct investigations and to 
suspend or revoke licenses for misconduct after providing notice and 
hearing.

Selected Boxing Commissions' Documentation of Compliance Varied:

The 8 state and 2 tribal boxing commissions that we reviewed varied in 
the extent to which they had documentation indicating compliance with 
the 10 provisions of the act related to the fundamental elements we 
identified. The act does not require the commissions to document their 
compliance. However, because documentation constituted the only 
verifiable evidence of compliance, we reviewed all available 
documentation in the commissions' event files, including pre-and post-
fight medical examination check sheets, insurance coverage forms, 
copies of contracts between boxers and promoters, event sheets 
identifying boxers' registration numbers, promoters' revenue reports to 
commissions, and statements of independence signed by ring officials.

All 10 commissions had documentation indicating compliance at least 75 
percent of the time for three provisions--those that require prefight 
medical examinations, disclosure of amounts paid to promoters, and 
registration of boxers--but only 2 commissions had documentation at 
least 75 percent of the time for the provision prohibiting conflicts of 
interest. (See fig. 1.) Five of the commissions said they usually 
complied with this provision but did not document their compliance. The 
10 commissions' documentation for the remaining six provisions varied 
within this range. (See table 4 in app. 3 for the results of our 
analysis of the commissions' documentation.) When asked why they did 
not always document their compliance with the provisions, the 
commissions often did not provide a reason, but when they did, they 
generally pointed to privacy or liability concerns, said they were 
unaware of the federal provisions, or said they thought documentation 
was not needed. For details on the reasons the commissions provided for 
not documenting compliance, see appendix III.

Figure 1: Selected Boxing Commissions' Documentation of Compliance with 
the Act's Provisions Related to 10 Fundamental Elements:

[See PDF for image]

Note: The figure represents the number of commissions that had 
documentation indicating compliance at least 75 percent to 100 percent 
of the time for the respective provisions.

[End of figure]

Selected States and Tribes Vary in the Extent to Which Their Provisions 
Cover Additional Fundamental Elements:

The eight states and two tribes that we reviewed vary in the extent to 
which their provisions cover health and safety and economic elements in 
addition to those covered in the act. Each of these states and tribes 
has some provisions that cover additional fundamental elements or 
portions of fundamental elements. The number of such provisions enacted 
by an individual Commission ranges from 10 (California) to 4 
(Missouri). All 10 states and tribes have provisions fully covering the 
additional element that requires uniform boxing and scoring rules, and 
eight states or tribes have provisions fully covering the additional 
element that requires the filing of postfight medical reports. 
California was the only state with provisions fully covering 3 other 
additional elements--for monitoring injuries sustained during 
training, enforcing suspensions for debilitating training injuries, and 
providing pension plans for boxers. Four states or tribes have 
provisions that go beyond the act in requiring postfight medical 
examinations, but none of these states or tribes requires neurological 
testing. Similarly, three states or tribes have provisions that go 
beyond the act in requiring that boxers be provided with health 
insurance before and after, as well as during, each match, but none of 
these states or tribes requires life insurance. Figure 2 summarizes the 
results of our analysis. The primary reason provided by the states and 
tribes for not having provisions covering additional elements was that 
the provisions would be too costly to implement. For more details, see 
appendix IV.

Figure 2: Extent to Which State and Tribal Provisions Cover Additional 
Fundamental Elements:

[See PDF for image]

[End of figure]

Federal Action under the Act Has Been Limited:

Actions taken by the Department of Justice under the act have been 
limited. Justice officials said the department does not prosecute cases 
unless they are referred to it by federal law enforcement agencies. 
There were no records of cases brought by U.S. Attorneys under the 
federal boxing legislation during fiscal years 1996 through 2002, and 
there were no referrals from law enforcement agencies. Because the act 
provides for state and civil remedies in addition to federal criminal 
prosecution, Justice officials said that cases could be referred to 
state authorities rather than to U.S. Attorneys. Furthermore, the 
officials said, violations of the act are misdemeanors, and U.S. 
Attorneys generally pursue only felony cases, although they would 
prosecute a misdemeanor if circumstances warranted.[Footnote 7]

In commenting on a draft of this report, the president of ABC said that 
ABC had made two referrals to U.S. Attorneys' offices. The first, made 
in October 2002, concerned the World Boxing Association's ratings of a 
boxer. According to the ABC president, the referral was dismissed 
because the World Boxing Association provided the U.S. Attorney with a 
copy of its rating criteria and the boxers were well known. The ABC 
president said that the other referral, made to the Arkansas U.S. 
Attorney in 2001, reported that professional boxing was occurring in 
bars without the supervision of the Arkansas boxing commission. The ABC 
president said that ABC had not received a response to the referral and 
the case had not been prosecuted.

The Federal Trade Commission's (FTC) responsibility under the act is 
limited to making available to the public the information it receives 
from sanctioning organizations. FTC has no responsibility for enforcing 
compliance or verifying the accuracy of the information.[Footnote 8] 
FTC officials said they periodically check the sanctioning 
organizations' Web sites to assess whether the required information has 
been made available to the public and has found the Web sites to be 
adequate. Our review of the Web sites of 14 sanctioning organizations 
found that this information was posted on the Internet. FTC officials 
also said they had not received any consumer complaints related to the 
boxing industry.

In February 2003, legislation was introduced in the Senate that would 
amend the act by, among other things, creating a new organization 
within the Department of Labor to provide oversight and enforcement of 
the federal boxing laws. The purpose of this new federal organization 
is to facilitate more uniform enforcement of federal requirements 
designed to enhance boxers' health, safety, and economic interests as 
well as the integrity of the sport. This organization would have the 
authority to issue regulations, including requirements for 
documentation; to monitor and oversee the commissions' compliance with 
the existing federal protections for professional boxers; and to 
establish additional protections, if necessary.

Concluding Observations:

Although our review was limited to eight state and two tribal boxing 
commissions, the uneven documentation of compliance we found with the 
act's provisions to protect the health, safety, and economic well-being 
of professional boxers does not provide adequate assurance that 
professional boxers are receiving the minimum protections established 
in federal law. Without complete and accurate information on the extent 
to which the act is being enforced and without a federal agency to 
proactively ensure nationwide compliance, there is little assurance of 
compliance. While the Justice Department has the authority to prosecute 
violations of the act, it focuses its limited resources on prosecuting 
felonies, is not responsible for monitoring compliance, and would 
prosecute a case only if it received a referral from a federal law 
enforcement agency. Since 1996, it has received no referrals from 
federal law enforcement agencies and pursued no cases of violation of 
the act. If enacted, the legislation would create a new organization 
within the Department of Labor that could address this gap in the 
oversight and enforcement of the federal boxing laws.

Agency Comments and Our Evaluation:

We requested comments on a draft of this report from the Department of 
Justice, the Federal Trade Commission, and the Association of Boxing 
Commissions (ABC). The Department of Justice's GAO liaison and the 
Federal Trade Commission's GAO liaison and Office of General Counsel 
provided only oral technical comments, which we incorporated as 
appropriate. The president of ABC provided written comments, which are 
reproduced in appendix VI. We also provided the boxing commissions of 
the eight states and two tribes that we reviewed with the opportunity 
to review and comment on the facts in the report that related to their 
operations. We received written comments from the Missouri, Miccosukee, 
Mohegan Sun, Pennsylvania and Texas boxing commissions; these comments 
appear in appendixes VII through XI. As of July 16, 2003, we had 
received no comments from the California, Florida, Indiana, Michigan, 
and Nevada boxing commissions.

In his written comments, provided on June 30, 2003, the president of 
ABC said that while ABC has had some successes, much work needs to be 
done to achieve uniformity in the regulation of boxing. He said that 
feedback from ABC's membership on federal involvement in regulating 
professional boxing is mixed: many members regard such involvement as 
intervention, while others welcome it. He also said that some members 
believe that making certain types of testing (e.g., neurological 
testing) mandatory would have a negative impact on their jurisdictions 
because of the cost. According to the president, ABC is frustrated with 
the lack of enforcement of the Professional Boxing Safety Act of 1996. 
He said that violations of the act occur frequently, yet no government 
agency has been willing to enforce the current laws. The president said 
that he hopes the members can use the act's 10 provisions as a starting 
point for standardizing the regulation of boxing.

The Administrator of the Missouri Office of Athletics, who is also the 
president of ABC, provided written comments on the portion of a draft 
of this report applicable to Missouri on June 30, 2003 (see app. VII). 
While noting that the Missouri Office of Athletics encourages the 
standardized regulation of boxing, he said he also recognizes that any 
actions taken will have an economic impact on the sport that will have 
to be considered. In addition, he questioned who would enforce any new 
federal boxing provisions and stated the current law is not being 
enforced. He said that both state and tribal boxing commissions, 
through ABC, should work to standardize the regulation of boxing in the 
areas discussed in our report. He also made some technical comments, 
which we incorporated in the body of the report.

The Miccosukee, Mohegan Sun, Pennsylvania and Texas boxing commissions 
also provided written comments, which appear in appendixes VIII, IX, X, 
and XI, respectively. In their comments, they expressed appreciation of 
our work, indicating, for example, that our report helps to clarify 
issues related to the protection of boxers' health, safety, and 
economic interests. In addition, the Miccosukee and Pennsylvania boxing 
commissions cited tribal or state regulations that cover portions of 
some of 15 the elements we identified in the report as fundamental to 
protecting boxers' health, safety, and economic interest and to 
enhancing the integrity of the sport. In some instances, the Miccosukee 
and Pennsylvania boxing commissions noted that it would be difficult 
for them to implement certain elements because of personnel and 
budgetary constraints or because of their limited jurisdiction. For 
example, the Miccosukee commission said that it could not monitor 
training injuries because it would not be feasible for the Miccouskee 
commission or any other boxing commission to send representatives to 
gyms throughout the United States and other countries to monitor real 
time training injuries. The Miccosukee commission also indicated that 
in the future it could complete and file checklists in event files to 
document its compliance with certain provisions, such as the one 
requiring the presence of appropriate medical personnel and equipment 
during and after events. The commission said that the lack of 
documentation in its files does not adequately reflect its compliance 
with this provision. The Pennsylvania commission noted the diversity 
among various boxing commissions in implementing the federal law. 
Finally, the Texas commission said it lacked authority to implement 
several of the 15 fundamental elements identified in the report.

We recognize that boxing commissions vary in their approach to 
regulating boxing because of differences in their laws or regulations, 
local situations, and available budgetary and personnel resources. 
Furthermore, we recognize in our report that a lack of documentation 
does not necessarily mean that a requirement was not met. However, we 
had no other practical means to assess the extent to which the federal 
requirements were being addressed. Additionally, we agree with the 
Miccosukee commission that appropriately completed checklists would 
help to document compliance. Finally, we believe that our findings, 
along with the comments we received on our draft report, should provide 
Congress with useful information as it considers S. 275.

As agreed with your office, unless you publicly announce its contents 
earlier, we plan no further distribution of this report until 5 days 
after the date of this letter. At that time, we will provide copies of 
the report to the Ranking Minority Member, Senate Committee on 
Commerce, Science, and Transportation, and the Chairman and Ranking 
Minority Member, House Energy and Commerce. Copies of the report will 
also be sent to the Attorney General, the Chairman of the Federal Trade 
Commission, the Secretary of Labor, the Association of Boxing 
Commissions, the California State Athletic Commission, the Florida 
State Athletic Commission, the Indiana Boxing Commission, the Michigan 
Bureau of Commercial Services, the Missouri Office of Athletics, the 
Nevada Athletic Commission, the Pennsylvania Athletic Commission, the 
Texas Boxing and Wrestling Program, the Miccosukee Athletic Commission, 
and the Mohegan Tribal Gaming Commission Athletic Unit, and to others 
on request. In addition, the report will be available at no charge on 
the GAO Web site at http://www.gao.gov.

Key contributors to this report are listed in appendix XI. If you or 
your staff have any questions, please contact me on (202) 512-2834 or 
ungarb@gao.gov.

Sincerely yours,

Bernard L. Ungar, Director Physical Infrastructure Issues:

Signed by Bernard L. Ungar: 

[End of section]

Appendixes:

Appendix I: Professional Boxing Events Held in the United States during 
Calendar Year 2001:

State or Indian tribal commission: California[B]; Number of events 
held[A]: 85; Percentage of total events: 11%.

State or Indian tribal commission: Texas[B]; Number of events held[A]: 
62; Percentage of total events: 8%.

State or Indian tribal commission: Nevada[B]; Number of events held[A]: 
55; Percentage of total events: 7%.

State or Indian tribal commission: Pennsylvania[B]; Number of events 
held[A]: 52; Percentage of total events: 7%.

State or Indian tribal commission: Missouri[B]; Number of events 
held[A]: 40; Percentage of total events: 5%.

State or Indian tribal commission: Florida[B]; Number of events 
held[A]: 33; Percentage of total events: 4%.

State or Indian tribal commission: New York; Number of events held[A]: 
28; Percentage of total events: 4%.

State or Indian tribal commission: Illinois; Number of events held[A]: 
25; Percentage of total events: 3%.

State or Indian tribal commission: Colorado; Number of events held[A]: 
24; Percentage of total events: 3%.

State or Indian tribal commission: Mississippi; Number of events 
held[A]: 22; Percentage of total events: 3%.

State or Indian tribal commission: Indiana[B]; Number of events 
held[A]: 22; Percentage of total events: 3%.

State or Indian tribal commission: Ohio; Number of events held[A]: 21; 
Percentage of total events: 3%.

State or Indian tribal commission: Tennessee; Number of events held[A]: 
19; Percentage of total events: 2%.

State or Indian tribal commission: New Jersey; Number of events 
held[A]: 19; Percentage of total events: 2%.

State or Indian tribal commission: Michigan[B]; Number of events 
held[A]: 18; Percentage of total events: 2%.

State or Indian tribal commission: Puerto Rico; Number of events 
held[A]: 15; Percentage of total events: 2%.

State or Indian tribal commission: Arizona; Number of events held[A]: 
15; Percentage of total events: 2%.

State or Indian tribal commission: West Virginia; Number of events 
held[A]: 14; Percentage of total events: 2%.

State or Indian tribal commission: Virginia; Number of events held[A]: 
14; Percentage of total events: 2%.

State or Indian tribal commission: Oklahoma; Number of events held[A]: 
14; Percentage of total events: 2%.

State or Indian tribal commission: Massachusetts; Number of events 
held[A]: 14; Percentage of total events: 2%.

State or Indian tribal commission: Washington; Number of events 
held[A]: 13; Percentage of total events: 2%.

State or Indian tribal commission: Georgia; Number of events held[A]: 
13; Percentage of total events: 2%.

State or Indian tribal commission: Kentucky; Number of events held[A]: 
10; Percentage of total events: 1%.

State or Indian tribal commission: Iowa; Number of events held[A]: 10; 
Percentage of total events: 1%.

State or Indian tribal commission: South Carolina; Number of events 
held[A]: 9; Percentage of total events: 1%.

State or Indian tribal commission: Miccosukee (FL)[B]; Number of events 
held[A]: 9; Percentage of total events: 1%.

State or Indian tribal commission: Maryland; Number of events held[A]: 
8; Percentage of total events: 1%.

State or Indian tribal commission: Wisconsin; Number of events held[A]: 
7; Percentage of total events: 1%.

State or Indian tribal commission: Utah; Number of events held[A]: 7; 
Percentage of total events: 1%.

State or Indian tribal commission: Mohegan Sun (CT)[B]; Number of 
events held[A]: 7; Percentage of total events: 1%.

State or Indian tribal commission: Louisiana; Number of events held[A]: 
7; Percentage of total events: 1%.

State or Indian tribal commission: New Mexico; Number of events 
held[A]: 6; Percentage of total events: 1%.

State or Indian tribal commission: Mashantucket Pequot (CT); Number of 
events held[A]: 6; Percentage of total events: 1%.

State or Indian tribal commission: Hawaii; Number of events held[A]: 6; 
Percentage of total events: 1%.

State or Indian tribal commission: Delaware; Number of events held[A]: 
6; Percentage of total events: 1%.

State or Indian tribal commission: Rhode Island; Number of events 
held[A]: 5; Percentage of total events: 1%.

State or Indian tribal commission: North Dakota; Number of events 
held[A]: 5; Percentage of total events: 1%.

State or Indian tribal commission: Arkansas; Number of events held[A]: 
5; Percentage of total events: 1%.

State or Indian tribal commission: Washington, D.C; Number of events 
held[A]: 4; Percentage of total events: 1%.

State or Indian tribal commission: Idaho; Number of events held[A]: 4; 
Percentage of total events: 1%.

State or Indian tribal commission: Oregon; Number of events held[A]: 3; 
Percentage of total events: 0%.

State or Indian tribal commission: North Carolina; Number of events 
held[A]: 3; Percentage of total events: 0%.

State or Indian tribal commission: Nebraska; Number of events held[A]: 
3; Percentage of total events: 0%.

State or Indian tribal commission: Saginaw Chippewa (MI); Number of 
events held[A]: 2; Percentage of total events: 0%.

State or Indian tribal commission: Pueblo de San Juan (NM); Number of 
events held[A]: 2; Percentage of total events: 0%.

State or Indian tribal commission: Oneida (NY); Number of events 
held[A]: 2; Percentage of total events: 0%.

State or Indian tribal commission: Yakahama Nation (WA); Number of 
events held[A]: 1; Percentage of total events: 0%.

State or Indian tribal commission: New Hampshire; Number of events 
held[A]: 1; Percentage of total events: 0%.

State or Indian tribal commission: Connecticut; Number of events 
held[A]: 1; Percentage of total events: 0%.

State or Indian tribal commission: Alaska; Number of events held[A]: 1; 
Percentage of total events: 0%.

State or Indian tribal commission: Total; Number of events held[A]: 
777; Percentage of total events: 100%.

Source: Fight Fax, Inc.

[A] An event is a meeting of boxers at a place such as a casino or 
sports arena where one or more bouts (matches between two boxers) are 
held on a particular day.

[B] The state and tribal boxing commissions we selected for our review.

Note: We did not verify the information we received from Fight Fax, 
Inc., the official record-keeping body of the Association of Boxing 
Commissions.

[End of table]

[End of section]

Appendix II: Fundamental Elements to Address Health and Safety, 
Economic, and Integrity Problems in Professional Boxing:

For each of the 15 fundamental elements that we identified, this 
appendix provides a summary of a major problem in professional boxing 
that the element is designed to address. The summaries are based on the 
congressional testimony and national studies--by the National 
Association of Attorneys General (NAAG) Task Force, the Department of 
Health and Human Services, and the Department of Labor--that we 
reviewed. The summaries also include recommendations made at the 
hearings and in the studies to address the problems. The problems are 
divided into three categories: health and safety, economic protection, 
and integrity of the sport.

Health and Safety:

Conduct Medical Examinations, Including Neurological Testing:

In June 1998, the U.S. Department of Health and Human Services reported 
the results of a study mandated by Congress on health, safety, and 
equipment standards for boxing.[Footnote 9] The study found that 
although the overall rate of injury is lower in professional boxing 
than in many other sports, the risk of sustaining a severe or permanent 
brain injury is greater in boxing because fighters are exposed to 
repeated blows to the head. Head injuries account for a significant 
portion of all boxing injuries. Factors such as poor boxing ability, 
reduced supervision, and small stature are thought to increase the 
likelihood of traumatic head injury. Similarly, the length of a boxer's 
career and the total number of bouts in training, sparring, and 
competition combined have been linked to the severity of neurological 
damage. Because neurological damage is not always detected during 
routine medical examinations, neurological testing may be necessary to 
identify it.

Monitor Training Injuries:

According to a professional boxing trainer with over 25 years of 
experience whom we interviewed, boxers are required to train and spar 
in the gym daily for months in preparation for a fight. He said that 
during the sparring sessions, many boxers sustain injuries that are not 
reported to the boxing commissions. As a result, some of the boxers 
participate in events with pre-existing injuries, exposing themselves 
to further injury or harm. In an effort to protect the health and 
safety of professional boxers, the NAAG task force recommended in 2000 
that state inspectors inspect boxing gyms if adequate funding and staff 
are available.

Evaluate Medical Information and Assess Risks:

To help protect the health and safety of boxers, the NAAG task force 
recommended that all commissions implement a medical classification 
system that would establish risk levels for boxing injuries. For a 
fighter whose record included any element of a high-risk classification 
(e.g., repeated knockouts), the task force further recommended that 
commissions be required to impose a temporary suspension until the 
fighter received a medical clearance or required examination, such as a 
neurological examination conducted by a neurologist using magnetic 
resonance imaging and an electrocardiogram.

Ensure Presence of Medical Personnel and Equipment and File Postfight 
Reports:

In 2001, a representative of the Nevada Attorney General 
testified[Footnote 10] that although common sense dictates that an on-
site ambulance is needed for all boxing matches and should be available 
to transport an injured boxer to a hospital, many promoters would 
prefer to call 911 if an ambulance is needed. The representative said 
that while this arrangement may be more cost-effective for the 
promoter, the treatment of a fighter in the initial minutes after an 
injury--whether waiting for an ambulance to arrive or receiving 
immediate and appropriate medial care--is critical in determining 
whether the fighter will recover or suffer permanent damage or death. 
Similarly, in 1983, the World Medical Association[Footnote 11] said 
that professional boxing events should be held in locations where:

* adequate neurosurgical facilities are immediately available for 
emergency treatment of an injured boxer,

* a portable resuscitator with oxygen equipment and appropriate 
endotracheal tubes are available at ringside, and:

* an ambulance is continuously on-site to transport any seriously 
injured boxer to a hospital immediately.

The Professional Boxing Safety Act of 1996, as amended (the act), 
requires the continuous presence of a ringside physician and an 
ambulance or medical personnel with appropriate resuscitation equipment 
at each boxing event, unless equivalent protection is required by the 
boxing commission's provisions.

A Pennsylvania Athletic Commission official testified[Footnote 12] in 
May 2001 that boxing commissions should be required to develop criteria 
for licensing professional boxers, which should include reviews of 
boxers' fight records (i.e., wins, losses, knockouts) and suspensions, 
and a centralized database of medical examination information on all 
licensed boxers. He said that the database should be accessible only to 
boxing commission officials and would provide boxing commissions with 
an additional screening mechanism to use in their license determination 
process.

Require Health and Life Insurance:

The president of the Association of Boxing Commissions (ABC) told us 
that current insurance provisions require promoters to provide health 
insurance coverage only during a boxing event. However, he said such 
coverage does not protect boxers in other instances when they may need 
medical treatment but do not have health insurance or the financial 
resources to pay for treatment. For example, boxers may sustain 
injuries during an event but not recognize until later that they have 
been injured and need treatment. Many boxers also sustain injuries 
during training or sparring. In 1996, a New Jersey Boxing Commission 
representative testified[Footnote 13] that boxers spend far more time 
sparring in gyms than competing in events; as a result, they are more 
likely to sustain injuries during this period. The representative said 
that to prevent injuries to the head and other parts of the body, the 
amount and intensity of sparring should be monitored. A trainer we 
interviewed said that boxers should have health and life insurance 
coverage throughout the training period, as well as before, after, and 
during an event, in order to address any medical conditions or 
injuries. However, he said many insurance companies do not offer boxers 
health and life insurance at affordable prices.

Enforce Suspensions:

In 2002, the president of ABC testified before the Senate Committee on 
Commerce, Science, and Transportation on the need for the uniform 
enforcement of all suspensions imposed by boxing commissions. 
Currently, such enforcement is applicable only to suspensions imposed 
on boxers for recent knockouts or for a series of consecutive losses 
and medical reasons. The president said that in some instances, 
commissions have suspended boxers for falsifying documents or other 
types of inappropriate behavior and that to avoid serving the imposed 
suspensions, some boxers have traveled to other states and obtained a 
license to continue boxing.

Economic Protection:

Require Pension Plans for Boxers:

Professional boxing offers no long-term financial protection for its 
participants, although purses for the big events are in the millions of 
dollars and televised worldwide, often on a pay-per-view basis. The New 
York State Attorney General testified in 1999[Footnote 14] that the 
boxing industry has generated enormous wealth for virtually everyone 
except professional boxers. He added that over the decades, the 
interests of professional boxers have been ignored, leaving many 
penniless and medically at risk. In 1996, Congress mandated that the 
Secretary of Labor undertake a study on the feasibility of establishing 
a pension plan for professional boxers. According to the 
study,[Footnote 15] apart from programs run by the California 
commission and by the International Boxing Federation for its 
championship fights, comprehensive pensions for boxing are virtually 
nonexistent. The study concluded that a comprehensive program, if 
implemented for professional boxers, would consist of a charitable 
trust, a defined contribution plan, a defined benefit plan, and a 
disability income and survivor's benefit program.

Disclose Purses and Break Out Payments:

In 1997, a reporter testified[Footnote 16] that in 1986 a boxer was 
guaranteed $300,000, with up to another $100,000 in training fees, for 
a fight. Out of a potential $400,000, the boxer was paid about $99,000. 
The manager did not pay the trainer and the boxer paid the trainer out 
of his share of the purse, leaving the boxer with $69,000. To address 
problems such as this, the NAAG task force study recommended that a 
model contract be developed to outline contractual disclosure 
requirements between the promoters, managers, and boxers. The model 
contract should specify the rights and responsibilities of all parties, 
such as the contest requirements, compensation (including a full 
accounting and disclosure of all deductions from a boxer's purse), 
licenses, and remedies for lack of good faith, collusion, or breach of 
contract, including arbitration provisions.

Prohibit Conflicts of Interest:

A Texas Boxing and Wrestling Program official cited reports of fights 
in which a manager managed both boxers and the manager and promoter 
were related. Such business arrangements limited the boxers' chances of 
receiving fair payment. The official said that in theory, a manager is 
supposed to negotiate the most favorable economic terms for the 
fighter, while the promoter is supposed to make the largest possible 
profit on the event.

Establish Uniform Contractual Terms:

There are frequent reports of boxers' economic exploitation. For 
example, in January 2003, officials of the Mohegan Tribe Department of 
Athletic Regulations reported that a boxer had been fighting for more 
than a year and had never received payment for participating in events 
throughout the United States, although the manager was receiving the 
boxer's fight purses. For this violation, the commission revoked the 
manager's license for an indefinite period. In 2001, a Pennsylvania 
Athletic Commission official said that for years fighters have been 
contractually tied to promoters for a series of boxing events, limiting 
their ability and opportunities to pursue other promoters and to box in 
other events. The official said that the Muhammad Ali Boxing Reform 
Act, which limits the contracts between the boxer and promoter to 1 
year, is a step in the right direction to correct this problem.

Integrity of the Sport:

Require Registration and Training for Judges, Referees, and Others:

A Nevada State Athletic Commission official testified in 1994[Footnote 
17] that boxing referees have to decide in a split second which fighter 
has won a bout. Accordingly, he said, judges should have the ability to 
closely observe the fighters and base their decisions on consistent 
scoring criteria. The NAAG task force made recommendations to help 
enhance the integrity of the sport, including the following:

* ABC should develop a standardized testing program to be administered 
to judges and referees.

* Judges and referees should be required to pass this examination 
before they receive their licenses.

* To be licensed as a referee, an individual should have prior 
experience officiating in amateur competition or in other states or 
jurisdictions.

* All referees should be required to receive training and attend a 
minimum of two medical training seminars each year.

* To be licensed as a judge, an applicant should be proficient in the 
rules and regulations of boxing and have prior experience officiating 
in amateur competition or in other ABC states or jurisdiction.

* To be licensed as a ringside physician, a physician should have a 
state medical license, be in good standing in the respective state, and 
have experience as a licensed physician for a minimum of 2 years.

* Ringside physicians should be required to receive training in 
ringside medicine.

* Promoters and managers should be licensed and regulated.

Prevent Undue Influence:

The president of ABC testified in 2002[Footnote 18] on the need for 
standards to prevent sanctioning organizations from interfering with 
boxing commissions' selection of judges and referees. According to the 
president, that need was demonstrated during a nationally televised 
championship fight in 2001. He said that several weeks before the 
scheduled event, the sanctioning organization and the state boxing 
commission agreed that the sanctioning organization would designate the 
referee and one judge and the commission would designate the remaining 
two judges. However, less than 5 minutes before the event was to begin, 
a representative from the sanctioning organization threatened to 
withdraw the organization's sanction--an action that would reduce the 
status of the fight to a nontitled event--if the commission did not 
agree to replace one of the judges selected by the commission with a 
judge designated by the sanctioning organization. The commission agreed 
to the sanctioning organization's demands in order to retain the title 
status of the fight. Because the sanctioning organization was allowed 
to select two of the three judges, the president of ABC said the 
outcome of the event might have been compromised.

Require Uniform Boxing and Scoring Rules:

In June 1996, a former Nevada Athletic Commission official 
testified[Footnote 19] that every boxing match in the United States 
should be conducted under the same boxing and scoring rules. While 
noting that ABC has established Unified Championship Rules for title 
bouts, he said that some commissions do not implement the same rules. 
The official said that standardizing boxing and scoring rules is 
important because fighters can have difficulty concentrating on 
protecting themselves in the ring when they are trying to remember 
whether a particular state uses a rule. Similarly, it is difficult for 
referees to focus on a bout if they are worrying about changes in the 
rules for different bouts.

Review Sanctioning Organizations' Rankings:

The NAAG task force study reported that sanctioning organizations' 
rankings often are not based on objective assessments of talent or 
records of fighters' wins and losses. Instead, according to the study, 
boxers associated with certain promoters may be highly ranked 
regardless of their skill and ability. The study reported that this 
creates fraud that can have deadly consequences. For example, a fight 
advertised as a major championship battle may turn out to be a 
mismatch, as was a bout held on November 13, 1982, between Ray "Boom-
Boom" Mancini and Duk Koo Kim of South Korea. Mancini knocked out Kim, 
who never regained consciousness and died. The World Boxing Association 
had rated Kim as a top contender, even though he was not among Korea's 
top 40 fighters.

Require Knowledge of Professional Boxing for Commission Officials:

In 2002, an entertainment manager testified[Footnote 20] that state 
boxing commissions are generally underfunded and dominated by political 
appointees with limited knowledge of the sport. He said that many of 
these officials do not understand the boxing industry well enough to 
regulate it.

[End of section]

Appendix III: Selected Boxing Commissions' Documentation of Compliance 
with the Act's Provisions:

This appendix presents the results of our analysis of the eight state 
and two tribal boxing commissions' documentation of compliance with the 
act's provisions and provides information on the reasons given by the 
commissions for not having documentation. Figure 3 summarizes the 
results of our analysis of the commissions' documentation.

Figure 3: Selected Commissions' Documentation of Compliance with the 
Act's Provisions for Boxing Events Held in 2001:

[See PDF for image]

Note: This analysis reflects (1) actual percentages for Indiana, 
Michigan, and the Miccosukee and Mohegan Sun tribal jurisdictions, 
where we examined documentation for all events held in 2001, and (2) 
estimated percentages for California, Florida, Missouri, Nevada, 
Pennsylvania, and Texas, where we examined documentation for a 
statistical sample of all events held in 2001. Typically, one boxing 
event consists of 6 to 10 bouts, each of which may have its own 
documentation.

[A] The California and Indiana commissions said they complied with the 
provision but did not provide documentation for our review, citing 
privacy or other concerns. A California official sought higher-level 
approval for our review, but it was not obtained until after we had 
completed our work at the commission.

[B] The California commission said it usually complied with this 
provision but did not document its compliance.

[C] The California, Indiana, Missouri, Nevada, Pennsylvania, and 
Miccosukee commissions said they usually or always complied with this 
provision but did not document their compliance.

[D] The Indiana commission did not provide documentation for our 
review.

[E] The California, Michigan, and Nevada commissions said they usually 
complied with this provision but did not document their compliance.

[F] In figure 1 (p. 14), we categorized two commissions (Pennsylvania 
and the Miccosukee Tribe) as having documentation for this provision at 
least 75 percent of the time.

[G] The California, Florida, Indiana, Nevada, and Texas commissions 
said they complied with this provision but did not document their 
compliance. In commenting on a draft of this report, the Missouri 
Office of Athletics said that Missouri does not have a commission, but 
is staffed by 3 officials. Since Missouri does not have procedures to 
prohibit conflicts of interest for the 3 officials, we considered the 3 
officials as a commission that did not have documentation evidencing 
compliance with this provision.

[H] The California commission said it had purged its documentation for 
this provision from its files, and the Indiana commission said it was 
experiencing computer problems and could not provide the documentation.

[End of figure]

The remainder of the appendix provides information on the extent to 
which the 10 boxing commissions had documentation indicating compliance 
with each of the act's provisions related to a fundamental element. For 
the commissions that did not have or did not provide documentation for 
our review, the appendix also includes the reasons given by the 
commissions for not having or providing the documentation. When a 
reason is not specified, the commission did not provide a reason.

Figure 4: Evaluate Medical Information and Assess Risks:

[See PDF for image]

[End of figure]

Four of the 10 state and tribal boxing commissions (California, 
Indiana, Michigan, and Missouri) provided us with documentation of 
compliance less than 50 percent of the time with the act's provision 
requiring the evaluation before each match of medical information and 
the assessment of risks involved in allowing a boxer to fight. The 
Missouri boxing commission said that it does not collect and maintain 
medical information because state law concerning confidentiality, 
disclosure, and civil liability issues prohibited them from doing so. 
The Michigan boxing commission said that they were advised by its legal 
counsel to limit the amount of medical information collected due to the 
commission's limited authority to collect and protect such information. 
The Indiana Boxing Commission said it maintained medical information on 
professional boxers, but would not provide that information for review 
because of confidentiality and civil liability concerns. A Texas 
official said that the Texas Boxing and Wrestling Program used 
prelicense and prefight examinations, along with information obtained 
from Fight Fax, Incorporated,[Footnote 21] detailing a boxer's record 
of wins and losses and medical suspensions, to assess the risks 
involved in allowing a boxer to fight before each match. This official 
added that when reported information indicated that a boxer's physical 
condition was questionable, the commission might require the boxer to 
undergo additional medical tests to ensure that he or she was not 
participating in an event with a pre-existing injury. According to the 
official, the Texas Boxing and Wrestling Program does not disclose 
medical information it maintains on boxers to other commissions because 
of confidentiality and civil liability concerns. The California State 
Athletic Commission said it maintained medical information, such as the 
results of annual physicals and any neurological tests, on professional 
boxers registered in California, but it did not make this information 
available for review during our visit to the commission.

Figure 5: Require Minimum Uniform Contractual Terms:

[See PDF for image]

[End of figure]

Seven of the 10 state or tribal boxing commissions (Florida, Michigan, 
Nevada, Pennsylvania, Texas, Miccosukee, and Mohegan Sun) had 
documentation at least 75 percent of the time for the provision 
requiring minimum uniform contractual terms between boxers and 
promoters; the Indiana Commission had documentation 50 to 74 percent of 
the time; and the California and Missouri commissions had documentation 
less than 50 percent of the time. The Director of the Indiana Boxing 
Commission said that the commission's representatives were responsible 
for obtaining copies of all contracts between promoters and boxers 
before an event and for ensuring that boxers were paid in accordance 
with the contractual terms. However, contracts between the promoters 
and boxers were missing from most of the commission's event files. The 
director said that in some cases boxers forgot to forward their bout 
agreements to the commission after the matches. The Executive Officer 
of the California State Athletic Commission said that the contractual 
agreements between boxers and promoters were submitted to the 
commission before events and no events were held unless copies of the 
agreements were on file. However, many of the 2001 event files that we 
reviewed had no documentation of contractual agreements between boxers 
and promoters. No reason was given for the missing contracts. According 
to a Missouri Office of Athletics official, its legal counsel advised 
the commission against requiring boxing contracts because such 
agreements involved civil matters that were outside the jurisdiction of 
the Missouri Office of Athletics.

Figure 6: Require Standards for Rating Boxers to Protect against 
Mismatches:

[See PDF for image]

[End of figure]

Nine of the state and tribal boxing commissions (Florida, Indiana, 
Michigan, Missouri, Nevada, Pennsylvania, Texas, Miccosukee, and 
Mohegan Sun) that we reviewed had documentation at least 75 percent of 
the time for the provision requiring standards for rating boxers', 
considering their records of wins and losses, weight differentials, 
caliber of opponents, and numbers of past fights, to protect against 
mismatches. The California State Athletic Commission was the only 
commission we reviewed that lacked documentation for this provision. 
According to the Executive Officer, the commission reviewed the reports 
of Fight Fax, Incorporated, and the commission's chief inspector 
determined whether boxers were matched in accordance with their boxing 
skill levels, but the commission did not maintain any records on this 
process.

Figure 7: Conduct Prefight Medical Examinations:

[See PDF for image]

[End of figure]

All 10 of the state and tribal boxing commissions had documentation at 
least 75 percent of the time for the provision requiring medical 
examinations before fights.

Figure 8: Ensure Presence of Medical Personnel and Equipment:

[See PDF for image]

[End of figure]

Six of the 10 state and tribal boxing commissions (California, Indiana, 
Missouri, Nevada, Pennsylvania, and Miccosukee) had documentation less 
than 50 percent of the time for the provision requiring the presence of 
appropriate medical personnel and equipment during and after each 
match. Officials from these 6 commissions said that no fight would 
proceed without emergency medical service and an ambulance on-site 
during events, but they did not document their compliance with this 
requirement. Furthermore, in commenting on a draft of this report, the 
Administrator of the Missouri Office of Athletics noted that the act 
does not require such documentation. The Florida, Michigan, Texas, and 
Mohegan Sun boxing commissions documented the presence of emergency 
medical personnel and equipment during the events at least 75 percent 
of the time.

Figure 9: Require Health Insurance During Matches:

[See PDF for image]

[End of figure]

Three of the 10 state and tribal boxing commissions (Florida, Indiana, 
and Michigan) lacked documentation at least 75 percent of the time for 
the provision requiring health insurance for boxers during matches. The 
Florida State Athletic Commission said that it had not documented 
boxers' health insurance because of a clerical mistake. The Director of 
the Indiana Boxing Commission said that many of the commission's 2001 
event files were missing documentation of health insurance coverage 
because in Indiana, a majority of the professional boxing events were 
organized by the same promoters, who usually secured an annual policy 
covering all of the events for the year. We asked the official for 
documentation of health insurance coverage for the events whose files 
were missing such documentation. However, this documentation was not 
made available during our review.

Figure 10: Honor Suspensions Imposed by Other Commissions:

[See PDF for image]

[End of figure]

Three of the 10 state and tribal boxing commissions (California, 
Michigan, and Nevada) had documentation less than 50 percent of the 
time indicating that they had enforced suspensions of boxers imposed by 
other commissions. Officials from these 3 commissions said that before 
approving fights, they reviewed the suspension information received 
from Fight Fax and the national suspension list to ensure that boxers 
were not participating in events while serving suspensions imposed by 
other commissions. The officials added that although this information 
was reviewed, they did not maintain a record of the information in the 
event files.

Figure 11: Require Disclosure of Purses and Payments to Promoters and 
Judges:

[See PDF for image]

[End of figure]

All 10 of the state and tribal boxing commissions we reviewed had 
documentation at least 75 percent of the time for the provision 
requiring the disclosure of all purses and amounts paid to promoters. 
Two of the 10 commissions (Indiana and Missouri) had documentation less 
than 75 percent of the time for the provision requiring the disclosure 
of amounts paid to judges. The Director of the Indiana Boxing 
Commission said that the commission verified all forms of payment 
before events and ensured that all payments were made immediately after 
the events, but the commission did not make this information available 
during our review. The Missouri Office of Athletics said that the 
commission did not always document amounts paid to judges because 
Missouri law did not require the disclosure of such information. The 
official added that the promoters usually pay the judges by check 
through the Missouri Office of Athletics for tax purposes.

Figure 12: Prohibit Conflicts of Interest for Boxers, Promoters, and 
Commission Representatives:

[See PDF for image]

[End of figure]

The Miccosukee Athletic Commission was the only boxing commission with 
documentation at least 75 percent of the time for the provision that 
calls for ensuring that there are no conflicts of interest for boxers 
and promoters. Officials from the Michigan, Missouri, and Mohegan Sun 
boxing commissions said they were unaware that the provision had been 
enacted in federal law. The Director of the Indiana Boxing Commission 
said Indiana had not experienced any problems with boxers and promoters 
relating to conflicts of interest; therefore, the commission felt 
documentation for this provision was unnecessary.

The Pennsylvania Athletic Commission was the only boxing commission 
with documentation at least 75 percent of the time for the provision 
that calls for ensuring that there are no conflicts of interest for 
boxers and commission representatives. Officials from the Michigan, 
Missouri, and Mohegan Sun commissions said they were unaware that the 
provision had been enacted in federal law, and officials from the 
California, Florida, Indiana, Nevada, and Texas[Footnote 22] 
commissions said they did not maintain documentation for this provision 
because they believed these issues were addressed through discussions.

Figure 13: Require Registration for Boxers and Certification and 
Approval for Ring Officials:

[See PDF for image]

[End of figure]

All 10 of the state and tribal boxing commissions we reviewed had 
documentation at least 75 percent of the time for the provision 
requiring boxers to be registered. Two of the 10 commissions 
(California and Indiana) had documentation less than 50 percent of the 
time for the provision requiring ring officials to be certified and 
approved. The Executive Officer of the California State Athletic 
Commission said the commission documented only current registrations 
and had purged the 2001 data from its files. During our review, the 
Director of the Indiana Boxing Commission said the commission was 
experiencing computer problems and could not provide us with the list 
of ring officials certified and approved in 2001.

[End of section]

Appendix IV: State and Tribal Provisions That Cover Additional Health, 
Safety, Economic, and Integrity Elements:

This appendix provides information on the extent to which the 10 states 
and tribes that we reviewed had provisions covering health, safety, 
economic, and integrity elements in addition to those covered by the 
act. The appendix also provides the states' and tribes' reasons for not 
having provisions covering certain elements. When reasons are not 
specified, the commissions did not provide them.

Conduct Postfight Medical Examinations, Including Neurological 
Testing:

None of the 10 state and tribal commissions we reviewed had provisions 
requiring postfight medical examinations, including neurological 
testing, for all boxers who participate in events outside their own 
jurisdictions. Three of the commissions said they did not have 
provisions requiring postfight medical examinations or neurological 
testing because they did not have the financial resources to administer 
such requirements and it would not be feasible to require small 
promoters or boxers to pay for them. However, the California, Indiana, 
Nevada, Texas, and Pennsylvania boxing commissions said they required 
postfight medical examinations when a commission requested that a 
previously injured boxer obtain a medical release before being allowed 
to fight.

Monitor Training Injuries:

California was the only commission that required the monitoring of 
injuries sustained during training before events. Five of the state and 
tribal boxing commissions (Indiana, Missouri, Mohegan Sun, 
Pennsylvania, and Texas) agreed that from a safety perspective, 
monitoring boxers' gym activities was a good concept, but they said 
they did not have the personnel or financial resources to monitor local 
gym activities. The Executive Director of the Pennsylvania Athletic 
Commission said that Pennsylvania did not require the monitoring of gym 
injuries before events, but he personally visited each local gym once 
or twice a year to monitor gym activities.

File Postfight Medical Reports:

Eight of the state and tribal commissions (California, Indiana, 
Michigan, Missouri, Nevada, Pennsylvania, Texas, and Mohegan Sun) 
required the filing of postfight medical reports. The Executive 
Director of the Florida State Athletic Commission said Florida did not 
require the filing of postfight medical reports because the commission 
and the small promoters and boxers did not have the financial resources 
to pay for physicians to conduct such examinations. The official added 
that in many cases the small promoters struggled to pay for the 
physicians needed to conduct the required prefight examinations. The 
Executive Director of the Miccosukee Athletic Commission said that the 
commission did not require the filing of postfight medical reports; 
however, he said a medical referral might be given to a boxer if the 
ringside physician suspected that the boxer had been injured and a 
follow-up examination or observation was needed.

Require Health and Life Insurance Before and After Fights:

None of the state and tribal commissions require that boxers be 
provided with health and life insurance before and after each match. 
Generally, the commissions required the promoters to secure health 
insurance during a match, as the act requires. Some of the policies 
provided extended coverage for medical and accidental death and 
dismemberment for up to 1 year following the match. Four of the 
commissions (Michigan, Missouri, Pennsylvania, and Texas) said that 
providing coverage to boxers before or between matches--that is, during 
training--would be too costly. They stated that it is not the 
commissions' responsibility to provide coverage, since boxers are 
independent contractors.

Enforce Suspensions for Training Injuries:

California was the only state that required its commission to suspend 
boxers for training injuries. All of commissions agreed that suspending 
boxers for gym injuries was not feasible because many of the 
commissions were experiencing personnel and budgetary constraints and 
did not have the resources to monitor gym activities.

Require Pension Plans:

California was the only state that required pension plans for 
professional boxers. Officials at the other nine commissions said that 
this was a positive initiative; however, six of the commissions 
(Indiana, Miccosukee, Michigan, Missouri, Pennsylvania, and Texas) 
questioned the contribution sources and basis for qualification. The 
Boxing Administrator of the Texas Boxing and Wrestling Program said 
that the problems associated with pension and retirement plans were 
similar to those attending the health insurance issue and that they 
were social rather than professional boxing issues. According to the 
Director of the Indiana Boxing Commission, pension plans would benefit 
boxers a great deal, particularly if boxers were older and nearing 
retirement, younger and intending to make a career of professional 
boxing, or injured and without an alternative source of income. The 
official said that problems would arise with funding, because promoters 
have little incentive to fund pension plans for boxers and might be 
unable to afford the additional expense. He said that deducting money 
from each boxer's purse would also be difficult, because most boxers do 
not earn more than a few hundred dollars per bout.

According to the Executive Director of the Pennsylvania Athletic 
Commission, the commission is pursuing funding for pension plans. The 
official added that in 1992, the commission attempted to use its budget 
surplus to start a trust for professional boxers; however, because of 
shortfalls elsewhere in the state's budget, the funds were expended on 
other projects. The commission is initiating a charitable trust under 
ABC that has received some voluntary contributions thus far. The goal 
is to reach $500,000 in principal and operate the program using the 
account's interest. The official said that because professional boxers 
are not unionized, a traditional pension fund would not be feasible.

The Enforcement Division Director of the Michigan Bureau of Commercial 
Services said that the commission views operating a pension plan as 
outside the state's role to protect the consumer. In addition, the 
official said, promoters operating in Michigan would not be willing to 
fund a pension plan. Officials from the Missouri Office of Athletics 
and the Miccosukee Athletic Commission supported the establishment of a 
pension plan; however, they questioned the feasibility of doing so, 
since boxers are independent contractors.

Require Disclosure of All Purses and Payments to Trainers and Boxers:

Two of the state and tribal boxing commissions (Florida and Mohegan 
Sun) required full and open disclosure of all purses and costs of 
bouts, with the amounts paid to trainers and boxers broken out. 
According to the Executive Officer of the California State Athletic 
Commission, California has no provision requiring the disclosure of all 
purses and costs to trainers, but does require that the amounts paid 
and costs assessed to boxers be disclosed. The Enforcement Division 
Director of the Michigan Bureau of Commercial Services said that the 
commission did not have a provision requiring the disclosure of all 
purses and costs to trainers and boxers because the commission did not 
enforce any such agreements between these parties, as directed by their 
legal counsel. The Boxing Administrator of the Texas Boxing and 
Wrestling Program said that Texas only had provisions requiring the 
disclosure of all purses and costs to promoters and boxers. However, 
the Texas official said that the organization documented information on 
the fees that the trainers were paid from the boxer's purse, although 
there was no requirement for such documentation.

Prohibit Conflicts of Interest for Judges and Referees:

Eight state and tribal commissions (Florida, Indiana, Michigan, Nevada, 
Pennsylvania, Texas, Miccosukee, and Mohegan Sun) prohibited conflicts 
of interest for judges and referees. According to the Missouri Office 
of Athletics official, the commission has provisions for ensuring that 
there are no conflicts of interest for state boxing commission 
representatives. The official did not explain why the provisions do not 
address conflicts of interest for managers, judges, and referees. The 
Enforcement Division Director of the Michigan Bureau of Commercial 
Services said that a number of state officials resigned after the act 
established conflict of interest standards.

Require Registration and Training for Trainers, Managers, Promoters, 
and Physicians:

Missouri was the only commission we reviewed with a provision requiring 
trainers, managers, promoters, and physicians to be registered and 
receive training. Officials from six of the commissions (California, 
Florida, Indiana, Miccosukee, Pennsylvania, and Texas) said that they 
had provisions requiring these occupations to be registered, but 
because of limited financial resources, the provisions governing 
training were applicable only to physicians and ring officials.

Preclude Sanctioning Organizations from Exercising Undue Influence:

Seven of the 10 state and tribal commissions (California, Florida, 
Missouri, Nevada, Pennsylvania, Texas, and Mohegan Sun) we reviewed had 
provisions for selecting judges and ensuring that sanctioning 
organizations do not influence the selection process.

Select Uniform Boxing and Scoring Rules:

All 10 of the commissions we reviewed had provisions for selecting the 
boxing and scoring rules for events, such as ABC's rules for 
championship events.

Require Boxing Knowledge for Commission Officials:

Seven of the 10 commissions (California, Florida, Michigan, Nevada, 
Pennsylvania, Texas, and Miccosukee) had provisions that require 
officials who serve on boxing commissions to have knowledge of 
professional boxing. According to the Administrator of the Missouri 
Office of Athletics, the governor appoints the officials serving on the 
state's boxing commission, and, as a result, some of these officials 
may not have a professional boxing background or knowledge. Similarly, 
representatives of the Mohegan Tribe appoint the officials serving on 
the Mohegan Tribal Gaming Commission Athletic Unit and therefore, 
according to the unit's legal counsel, some of the officials may not 
have an extensive background in boxing. However, this has not been the 
commission's experience, the counsel said.

[End of section]

Appendix V: Objectives, Scope, and Methodology:

In analyzing the adequacy of efforts to protect the health, safety, and 
economic well-being of professional boxers and to enhance the integrity 
of the sport, our objectives were to (1) identify fundamental elements 
considered important to address the major health and safety, economic, 
and integrity problems facing professional boxing; (2) assess the 
extent to which the act's provisions cover these elements and whether 
selected state and tribal boxing commissions have documentation 
indicating compliance with the act's provisions; (3) assess the extent 
to which selected states and tribes have adopted provisions that cover 
fundamental elements in addition to those covered in the act; and (4) 
determine what actions the Department of Justice and the Federal Trade 
Commission (FTC) have taken under the act.

To identify fundamental elements that are considered important to 
address the major health and safety, economic, and integrity problems 
facing professional boxing, we reviewed recent congressional testimony 
and studies conducted by a task force of the National Association of 
Attorneys General, the Department of Health and Human Services, and the 
Department of Labor. From these sources, which documented problems in 
the boxing industry and made recommendations to address them, we 
identified major problems facing the sport and consolidated the 
recommendations into 15 fundamental elements that, if implemented, 
could provide an adequate level of health, safety, and economic 
protection to boxers and help enhance the integrity of the sport. We 
discussed these elements with the Association of Boxing Commissions, 
which agreed that the elements could provide the desired protection and 
enhancement.

To assess the extent to which the act's provisions cover the 
fundamental elements we identified, we analyzed the act's provisions 
and determined how many cover fundamental elements, either fully or 
partially. To assess the extent to which selected state and tribal 
boxing commissions have documented their compliance with the act's 
provisions, we identified 8 of the 46 state boxing commissions and 2 of 
the 8 tribal boxing commissions for review. We looked at provisions in 
the act that were related to the 15 fundamental elements. The eight 
states are California, Florida, Indiana, Michigan, Missouri, Nevada, 
Pennsylvania, and Nevada; the two tribes are the Mohegan Sun 
(Connecticut) and the Miccosukee (Florida). We selected California, 
Florida, Missouri, Nevada, Pennsylvania, and Texas because they held 
the largest number of professional boxing events in calendar year 2001, 
the most recent year for which complete data were available. We 
selected Michigan and Indiana to represent states that held a smaller 
number of events in calendar year 2001 than the other states selected. 
We selected the Miccosukee and Mohegan Sun tribes because they were the 
Indian tribes that held the largest number of professional boxing 
events in calendar year 2001. The state and tribal commission we 
selected accounted for 49 percent of all professional boxing events 
held in the United States during calendar year 2001.

At the Indiana, Michigan, Miccosukee, and Mohegan Sun commissions, we 
reviewed the cases files for all professional boxing events held in 
2001, and at the remaining commissions, we reviewed the case files for 
a random selection of professional boxing events held in 2001. Because 
we randomly selected boxing events in these states for review, our 
sample for each of these states is just one of many samples we could 
have drawn. Since each sample could have produced a different estimate, 
we express our confidence in the precision of the estimates for our 
particular samples using 95 percent confidence intervals. These are 
ranges within which we are confident that 95 out of 100 samples drawn 
from these particular events would include the true value for all the 
events in the state. All the estimates based on sample data in table 3 
have 95 percent confidence intervals not exceeding plus or minus 10 
percentage points, unless otherwise indicated. To present the results 
of our case file reviews, we divided the actual or estimated 
percentages of cases with documentation into three compliance 
categories: 75 to 100 percent, 50 to 74 percent, and below 50 percent. 
We did not independently verify the documented compliance, and the 
results of our reviews at these 10 commissions cannot be generalized to 
all boxing events held nationwide during 2001.

The documentation that we reviewed at the selected commissions varied. 
Because the act does not require documentation and the commissions have 
no uniform record-keeping standards, we considered all types of 
documentation maintained and provided to us by the commissions for our 
review. Such documentation included pre-and post-fight medical 
examination check sheets, insurance coverage forms, copies of contracts 
between boxers and promoters, event sheets identifying boxers' 
registration numbers, promoters' revenue reports to commissions, and 
statements of independence signed by ring officials.

To assess the extent to which selected states and tribes have adopted 
provisions that cover fundamental elements in addition to those covered 
in the act, we reviewed the boxing provisions enacted by the eight 
states and two tribes and identified provisions that cover fundamental 
elements or portions of fundamental elements that the act does not 
cover. We confirmed with the boxing commissions of these states and 
tribes that they agreed with our analysis of their provisions, and we 
asked these officials why their state or tribe had not enacted 
provisions covering additional fundamental elements. Our findings for 
these selected states and tribes cannot be generalized to all 46 states 
and eight tribes. We did not assess the extent to which the states and 
tribes had implemented or enforced the provisions that cover additional 
fundamental elements.

To determine what actions the Department of Justice and FTC have taken 
under the act, we determined the role that each is assigned under the 
act. We then met with Justice officials to identify whether any 
investigations or prosecutions had been conducted under the act in the 
jurisdictions of the eight state and two tribal commissions in 2001. In 
addition, we reviewed Justice's central case management system for 
possible cases prosecuted during fiscal years 1996 through 2002. We 
also met with FTC officials to determine whether they had received 
consumer complaints related to the boxing industry. Furthermore, to 
determine that the sanctioning organizations were making the required 
information available to the public, we reviewed the Internet Web sites 
of 14 sanctioning organizations.

We performed our work in accordance with generally accepted government 
auditing standards from September 2002 through July 2003 in Washington, 
D.C., and at the following state or tribal boxing commission locations: 
California State Athletic Commission, Sacramento, California; Florida 
State Athletic Commission, Tallahassee, Florida; Indiana Boxing 
Commission, Indianapolis, Indiana; Michigan Bureau of Commercial 
Services, Lansing, Michigan; Missouri Office of Athletics, Jefferson 
City, Missouri; Nevada Athletic Commission, Las Vegas, Nevada; 
Pennsylvania Athletic Commission, Harrisburg, Pennsylvania; Texas 
Boxing and Wrestling Program, Austin, Texas; Miccosukee Athletic 
Commission, Miami, Florida; and the Mohegan Tribal Gaming Commission 
Athletic Unit, Uncasville, Connecticut.

[End of section]

Appendix VI: Comments from the Association of Boxing Commissions:

Association of Boxing Commissioners: 

June 30, 2003:

Bernard L. Ungar, Director Physical Infrastructure Issues General 
Accounting Office Washington, DC 20548:

Re: Professional Boxing: Issues Related to the Protection of Boxers' 
Health, Safety and Economic Interests. (GAO 03-699):

Dear Director Ungar:

Thank you for the opportunity to respond to the above report on behalf 
of the Association of Boxing Commissions, (ABC). The ABC draws its 
membership from state and tribal boxing commissions from around the 
country. It has long been an organization, which has attempted to 
standardize the regulation of boxing in the United States. The ABC has 
had some successes, however, much work needs to be done to continue to 
improve how each of its members uniformly regulate boxing. These 
comments are being made after reviewing a draft copy of the report for 
only two hours. It was very unfortunate that I was unable to retain a 
draft copy in order to formulate my response on behalf of the ABC.

The ABC's membership comes from a wide spectrum of members, in that 
some members regulate in excess of 60 boxing shows per year while other 
members regulate as few as one or two boxing shows per year. As you 
could imagine the feedback that I receive from the membership is very 
mixed. There are many who do no want federal intervention, while other 
welcome it. Yet there are other that are very concerned with economic 
impact to their jurisdiction with the discussion of the mandatory 
implementation of neurological testing and HIV and Hepatitis testing 
prior to each bout. There are still others who are not concerned with 
the cost of these types of exams.

Some commissions will suffer and the number of boxing shows will be 
greatly reduced if these medical exams become law.

The ABC is frustrated at the lack of enforcement of the Professional 
Boxing Safety Act of 1996. The ABC has made two referrals to the United 
States Attorney General's office, but each complaint was turned down 
and not prosecuted. There are violations on a monthly basis, by 
promoters, sanctioning organizations, managers and yes, even boxing 
commissions. However, no governmental agency is willing to stick their 
neck out to enforce the current laws. Quite often the ABC is scolded by 
the media and other for not taking action, however, the ABC has no 
power. It is a "toothless tiger.":

I hope the membership can use the ten areas outlined in this report as 
a starting point to begin the process of standardizing there 
regulations of boxing across the board.

Sincerely,

Timothy J. Lueckenhoff 
President:

Signed by Timothy J. Lueckenhoff: 

[End of section]

Appendix VII: Comments from the Missouri Office of Athletics:

MISSOURI DEPARTMENT OF ECONOMIC DEVELOPMENT

Bob Holden Governor:

OFFICE OF ATHLETICS 3605 Missouri Boulevard P.O. Box 1335:

Jefferson City, MO 65102-1335 Telephone 573-751-0243:

Fax 573-751-5649:

800-735-2966 TTY Relay Missouri 800-735-2466 Voice Relay Missouri:


Division of Professional Registration 

June 30, 2003:

Bernard L. Ungar, Director Physical Infrastructure Issues General 
Accounting Office Washington, DC 20548:

Re: Professional Boxing: Issues Related to the Protection of Boxers' 
Health, Safety and Economic Interests. (GAO 03-699):

Dear Director Ungar:

Thank you for the opportunity to respond to the above report on behalf 
of the Missouri Office of Athletics. First, I would like to commend 
both Fredrick Lyles and Bernice Benta for their professionalism in the 
treatment of myself and the staff of our office. These comments are 
being made after reviewing a draft copy of the report for only two 
hours. It was very unfortunate that I was unable to retain a draft copy 
in order to formulate my response.

I must say that the results of the report are not shocking to this 
office and I somewhat expected the findings contained herein. The 
Missouri Office of Athletics prides itself on compliance with the state 
and federal laws and its close relationship to the Association of 
Boxing Commissions. The Missouri Office of Athletics encourages the 
standardized regulation of boxing across the country. However, everyone 
involved must understand that any actions taken will come at a cost to 
the profession of boxing. Therefore, the recommendations that are made 
in this report, must also consider the economic impact to the sport of 
boxing.

It is noted in this report that the Missouri Office of Athletics failed 
to document that appropriate medical personnel was present at each and 
every boxing event. I will assure you that prior to May 2002, medical 
personnel with resuscitation equipment were present at each boxing 
event. In May of 2002, the Missouri Office of Athletics 
enacted an administrative rule, which requires the presence of an 
ambulance and crew at each boxing and martial arts event promoted in 
Missouri.

The report noted that the Missouri Office of Athletics does not have 
procedures to prohibit conflicts of interest for commission members. 
The Missouri Office of Athletics does not have a commission; it is 
staffed by the Division Director, Executive Director and the 
Administrator.

The report also notes that neurological testing should be completed 
before and after a boxing match. I agree with these types of testing, 
however, to implement such a requirement would surely drastically 
decrease the number of club shows. Avenues should be researched to 
assist club show boxers with the means to obtain these medical exams at 
a reduced rate.

The report further suggests that medical insurance should be provided 
before, during and after a boxing event. The office certainly agrees 
that the promoter should provide medical insurance and death benefit 
insurance for boxers, however, the office would oppose insurance to be 
provided for boxers before an event.

The bottom line with all of the suggestions contained with this report 
are, who is going to enforce these new laws, if passed? Currently, the 
federal law is not enforced. Considerations must also be made for the 
economic impact of the sport.

Both state and tribal boxing commission through the Association of 
Boxing Commissions should work to standardize the regulation of boxing 
in the areas outlined in this report.

Sincerely,

Timothy J. Lueckenhoff 
Administrator:

Signed by Timothy J. Lueckenhoff: 

[End of section]

Appendix VIII: Comments from the Miccosukee Athletic Commission:

MICCOSUKEE ATHLETIC COMMISSION:

7700 NORTH KENDALL DRIVE SUITE 303 MIAMI, FLORIDA 33156 Te1ephone: 
(305) 279-4596 - Fax: (305) 279-1365 

June 30, 2003:

SENT VIA FAX AND U.S. MAIL Bernard L. Ungar, Director Physical 
Infrastructure Issues United States General Accounting Office 
Washington, D.C. 20548:

Re: Professional Boxing Draft Report on Issues Relating to the 
Protection of Boxers' Health, Safety, and Economic Interests (GAO-03-
699):

Dear Mr. Ungar:

Thank you for providing information extracted from the above-referenced 
report pertaining to the Miccosukee Athletic Commission ("MAC"), for 
our review. We welcome the opportunity to offer additional comments.

Please be advised that many of the issues raised in your draft report 
were addressed through correspondence to Mr. Frederick Lyles, Jr., 
dated January 6, 2003, and subsequent discussions between Mr. Lyles and 
Don Hazelton, MAC Executive Director. We hope the additional comments 
provided herein will assist your office in adequately addressing and 
clarifying some of the preliminary findings pertaining to MAC's 
treatment of the elements identified in the draft report.

1. DOCUMENTATION OF COMPLIANCE[NOTE 1]:

1. Provision - Ensure the presence of appropriate medical personnel and 
equipment during and after each match.

Comments - MAC General Rules of Boxing, Section 1.006 2(b) provides 
that " [A] seat for each physician shall be located adjacent to each 
participant's corner in such location and at such height that each 
physician shall have a clear and unobstructed view of the ring, ring 
floor, the participant's corner and the referee." Subsection (c) 
provides that no match shall begin or continue unless at least one 
physician is located in his/her designated seat.

Moreover, Section 1.006 further provides:

(3) Emergency Medical Equipment and Services.

(a) It shall be the responsibility of the promoter to provide the 
following: 1. A portable resuscitator with all additional equipment 
necessary for its operation;

2. An ambulance with two qualified attendants;

3. A clean stretcher and clean blanket, to be located along with the 
ambulance attendants, at a location determined by the executive 
director.

(b) No match shall begin or continue unless such equipment and personnel 
are on the premises, in a state of readiness and in a pre-designated 
readily accessible location known to the referee, physicians and the 
Commission representative.

As attested by Executive Director, Don Hazelton, in his discussions 
with Mr. Lyles, no match under the jurisdiction of the Commission has 
commenced or continued, without the continuous presence, on site, of an 
ambulance, emergency personnel and equipment, and at least one 
physician. In fact, MAC Rules require the presence of two (2) 
physicians at all of its professional boxing matches, who are required 
to remain on the premises until released by the Executive Director. 
_See MAC Rules, Section 1.010 (2) (a) and (g). Moreover, the Boxing 
Program Results form (MAC-464), which is transmitted via facsimile to 
the National Boxing Registry ("Fight Fax") following each boxing event, 
identifies the names of the physicians present at the match.

A finding that there was no "documentation" concerning the above-
mentioned requirement, does not adequately reflect MAC's compliance 
therewith. To the extent documentation is found to be necessary, this 
concern can be addressed by generating an additional "check-list" type 
form identifying the medical and emergency personnel and equipment and 
times of arrival and departure and including said form in each boxing 
event file.

2. Provision - Prohibit conflict of interest for commission 
representatives.

Comments - MAC General Rules of Boxing Section 1.0023, provides, in 
pertinent part, as follows:

(9) No member or employee of the Commission shall have any direct or 
indirect financial or pecuniary interest in any person under the 
jurisdiction of the Commission.

(10) No member or employee of the Commission shall be a member of, 
belong to, contract with, or receive any compensation from, any person 
or entity who sanctions, arranges, or promotes professional boxing or 
who otherwise has a financial interest in an active boxer currently 
registered with a boxing registry.

Pursuant to MAC Rules, Section 1.002 (8), the commission 
representative, inspector and time-keeper are considered employees of 
the Commission. The General Application for License form (MAC-450), 
which is required to be completed and submitted annually by MAC 
inspectors, time-keepers, and officials, such as, judges and referees, 
requires the applicant to disclose the identity of any persons under:

the jurisdiction of any boxing commission or similar governmental 
authority, in which the applicant has a financial interest. This 
disclosure requirement identifies potential conflict of interest issues 
with respect to officials (e.g. judges, referees), commission employees 
(e.g. inspectors, time-keepers), and others. Following each match all 
MAC Officials (e.g. judges and referees) are required to complete and 
submit a Disclosure Statement for Officials form (MAC-500), which 
additionally identifies any potential conflict of interest issues.

Moreover, due to the structure of the MAC, and the fact that boxing 
matches held under its jurisdiction are limited in number and location, 
generally the Executive Director has not found it necessary to appoint 
a "Commission Representative" to perform the duties and 
responsibilities outlined in MAC Rules, Section 1.0027. Many of those 
duties are carried out by the Executive Director himself, the chief 
inspector and the inspectors.

2. EXTENT TO WHICH TRIBAL PROVISIONS COVER ADDITIONAL ELEMENTS[NOTE 
2]:

1. Element - Conduct medical post-fight medical examinations, including 
neurological testing.

Comments - With regard to neurological examination, MAC General Rules 
of Boxing, Section 1.005 (2) provides:

(1) The executive director shall, if he has cause to believe that a 
participant may have suffered cardiac or neurological injury, direct 
the participant to undergo an EKG, EEG, or CAT scan. The interpretation 
and diagnosis shall be filed with the Commission. It is the 
responsibility of the promoter to ensure that this requirement is 
satisfied.

Section 1.012 (d) further provides, in pertinent part, that no person 
shall be licensed as a participant and the license of any participant 
shall be suspended or revoked if such person:

5. Has suffered cerebral hemorrhage or any other serious head injury. 
The Commission representative shall, if he has cause to believe that a 
participant may have suffered neurological injury, direct the 
participant to undergo an EKG or CAT scan, and the interpretation and 
diagnosis shall be filed with the Commission.

Furthermore, the MAC Rules specifically address post-match physical 
examinations. For example, Section 1.037, entitled: "Post-Match 
Physical Requirements; Suspensions," provides, in pertinent part, as 
follows:

(1) As a result of injuries or suspected injuries sustained or suspected 
to have been sustained in any match, the executive director or 
Commission representative shall order a medical examination to be given 
to any participant or referee at any time, if he has cause to believe 
that the health or safety of the participant or referee is in jeopardy.

As illustrated by the foregoing provisions, the MAC has regulations 
which adequately address post-match physical and neurological 
examinations.

2. Element - Monitor training injuries.

Comments - Given the limited jurisdiction of the MAC, as well as its 
structure and manpower, it would not be feasible for MAC, or any other 
boxing commission for that matter, to send representatives to 
gymnasiums throughout the United States and other countries to monitor 
real time training injuries. The best method to monitor such injuries 
is by conducting a thorough pre-match physical examination. In that 
regard, MAC General Rules for Boxing, Section 1.004 (3) entitled "Pre-
Match Physical of Participant and Referee", evaluates such things as 
recent wounds and injuries.

3. Element - Filing of post-fight medical reports.

Comments - The MAC Rules and Regulations do not require the filing of 
post-fight medical reports, but address the issue of post-fight 
physical examinations. See Comments set-forth at Section B (1) above. 
To the extent it is determined that a post-fight medical report should 
be generated, this can be accomplished by producing an appropriate form 
to be included in each boxing event folder.

4. Element - Health and life insurance before and after fights.

Comments - MAC regulations do not specifically require promoters to 
provide pre-match and/or post-match health and life insurance coverage 
to boxers. However, MAC Rules, Section 1.0035 (4) provide that "the 
promoter shall provide additional insurance coverage as may be required 
by the commission", thereby giving the Commission discretion to require 
either pre-match and/or post-match health and life insurance. While, 
from a regulatory stand point, it may be feasible to enforce this 
requirement, its practical effect would be to impose an undue financial 
burden on small promoters.

5. Element - Enforce suspensions for training injuries.

Comments - As noted by the comments of the Executive Director Don 
Hazelton in the draft report at page 13, and as stated in Section B 2 
above, suspensions, and enforcement thereof, for training injuries 
would not be feasible because most commissions do not have the 
experienced personnel and budget to monitor training activities 
throughout the United States or other countries. However, if a 
suspension is issued by any commission for training injuries and filed 
with the National Boxing Registry, it should be honored and enforced by 
other commissions just like any other suspension.

6. Element - Require pension plans.

Comments - As noted in the comments of the MAC Executive Director, as 
outlined in the report at page 13 - 14, as a general principle MAC is 
not opposed to establishment of pension plans for boxers. However, this 
issue needs to be carefully studied and considerations be given to such 
things as sources of contribution, basis for qualification, etc. 
Moreover, the boxers' status as "independent contractors" may affect 
the appropriateness of requiring pension plans.

7. Element - Require disclosure of all purses and payments to trainers 
and boxers.

Comments - MAC General Rules for Boxing, Section 1.005 provides 
disclosure requirements for promoters and requires acknowledgment of 
such disclosures by the boxer. See Mac Rules Section 1.005 (3)(a) (c). 
Both promoter and boxer are required to submit to the Commission 
documentation 
of compliance. See Promoter Disclosure Statement (MAC-501) and 
Acknowledgment of Disclosure by Promoter (MAC-502).

8. Element - Prohibit conflicts of interest for Judges and Referees.

Comments - MAC General Rules for Boxing Section 1.013 (1) provides, in 
pertinent part:

(b) A judge shall not also be licensed as a booking agent, manager, 
matchmaker, participant, representative of a booking agent, second or 
trainer.

(c) No judge shall have a financial or pecuniary interest in any 
participant.

(d) No judge shall also serve as a supervisor or serve on the ratings 
committee for a sanctioning body.

Section 1.019 provides, in pertinent part:

(c) No person who has financial or pecuniary interest in any participant 
shall be granted a referee license.

(d) No referee shall also be licensed as a booking agent, manager, 
matchmaker, participant, representative of a booking agent, second or 
trainer and shall not act as a booking agent, manager, matchmaker, 
participant, representative of a booking agent, second or trainer.

(e) No referee shall also serve as a supervisor or serve on the ratings 
committee for a sanctioning body. The applicant must have a 
demonstrated record and evidence that he\she has the ability to perform 
the duties outlined below. The executive director may issue a temporary 
license pending final action by the Commission.

The General Application for License form (MAC-450), which is required 
to be completed and submitted annually by MAC judges and referees, 
requires the applicant to disclose the identity of any persons under 
the jurisdiction of any boxing Commission or similar governmental 
authority, in which the applicant has a financial interest. This 
disclosure requirement identifies potential conflict of interest issues 
with respect to judges and referees. Moreover, pursuant to MAC Rules, 
Section 1.013 (3) and Section 1.019 (3), judges and referees are 
required to complete and submit a Disclosure Statement for Officials 
form (MAC-500), which documents compliance with conflict of interest 
concerns.

9. Element - Require registration and training for trainers, managers, 
promoters and physicians.

Comments - MAC General Rules for Boxing Sections 1.005, 1.010, 1.011, 
and 1.023 require licensing (registration) for promoters, physicians, 
managers and trainers. The license application for seconds, trainers 
and managers asks the applicant to provide information which qualifies 
the applicant for the license being sought. This information is used to 
evaluate the individuals' experience and training in this area. The 
training of promoters, managers and trainers is certainly an 
aspirational goal, however enforcement of minimum training requirements 
may not be feasible. With regard to ring officials, the MAC Rules 
provide for training and certification requirements. See MAC Rules, 
Section 1.013 (1)(e) and (f); and Section 1.019 (1)(f), (2)(d).

10. Element - Preclude sanctioning organizations from exercising undue 
influence.

Comments - Pursuant to MAC Rules Section 1.0025 (a) it is the duty and 
responsibility of the Executive Director to ensure that all matches are 
conducted in accordance with the MAC Rules and Regulations. By 
implication, this provision precludes sanctioning organizations from 
exercising undue influence over the decisions of the Executive Director 
concerning appointment of match officials, approving/disapproving a 
match, and other matters relating to the conduct ofprofessional boxing 
matches held under the jurisdiction of the Commission. MAC agrees that 
sanctioning organizations should be prohibited from engaging in any 
attempt to exercise undue influence over regulatory decisions of state 
and tribal boxing commissions.

In conclusion, we would note that the GAO report helped to clarify the 
issues related to the protection of boxers' health, safety and economic 
interests. In that regard, we commend the efforts of' Frederick Lyles 
whose professionalism and fairness facilitated our ability to candidly 
express our concerns on the impact of current and future federal 
legislation.

The foregoing represents the Miccosukee Athletic Commission's comments 
concerning the preliminary findings contained in the draft report. 
Again, we appreciate the opportunity to provide input for your office's 
final report. If you have any questions concerning these comments, 
please contact Don Hazelton at (850) 878-7725 or the undersigned at the 
number listed above.

Very truly yours,

Don F. Hazelton 
Executive Director, 
Miccosukee Athletic Commission:

Juan M. Vargas, Esq.

Legal Counsel to the Commission:

Signed by Don F. Hazelton and Juan M. Vargas: 

cc: Frederick Lyles:

NOTES: 

[1] It should be noted that under Florida and federal law 
"documentation" of compliance is not required.

[2] It should be noted that compliance with these additional elements 
or documentation thereof, is not presently required under Florida or 
federal law.

[End of section]

Appendix IX: Comments from the Mohegan Tribal Gaming Commission 
Athletic Unit:

June 23, 2003:

Mr. Bernard L. Ungar, Director Physical Infrastructure Issues U.S. 
General Accounting Office Room 2T23, 441 G Street, N.W. Washington, DC 
20548:

Dear Mr. Ungar:

I have received a copy of the draft report titled, Professional Boxing: 
Issues Related To the Protection of Boxers' Health, Safety and Economic 
Interests (GAO-03-699). As requested, I have reviewed the report and 
appreciate the opportunity to make the following comments:

In regards to the monitoring of boxer training injuries and suspensions 
for such, the Mohegan Tribe purposely does not engage in such oversight 
for an obvious reason. There are no training facilities or gyms (public 
or private) within its 247-acre reservation.

Boxers who compete on the reservation prepare for their bouts off site 
and, obviously, beyond our jurisdiction. Therefore, monitoring of 
training session injuries is beyond the purview of our department. If 
a. boxer sustains a training injury, for his protection we can only 
hope that a) he or his camp notifies us directly o`f such, b) the 
regulatory body with oversight of the training location notifies us of 
the injury or subsequent suspension or c) the injury is detected by our 
physicians during the pre-fight medical examination.

I would like to commend the General Accounting Office for the 
professional effort put forth during the research phase of the report. 
In particular, Misters John Vocino and Frederick Lyles displayed 
genuine interest in the subject matter and an understanding of the 
current issues surrounding the sport of professional boxing. It was a 
pleasure assisting them during their visit to the reservation.

Jerome F. Boyle 
Manager 
Department of Athletic Regulations:

THE MOHEGAN TRIBE:

Signed by Jerome F. Boyle: 

[End of section]

Appendix X: Comments from the Pennsylvania Athletic Commission:

COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF STATE STATE ATHLETIC 
COMMISSION 2601 NORTH 3rD STREET HARRISBURG, PA 17110:

Gregory P. Sirb Telephone: (717) 787-5720:

Executive Director Fax; (717) 783-0824:

DATE: June 26, 2003:

SUBJECT: GAO Report-Professional Boxing:

TO: Bernard L. Unger, Director, Physical Infrastructure Issue;

FROM: Gregory P. Sirb, Executive Director Pennsylvania State Athletic 
Commission:

Thank you very much for the opportunity to provide comment on the 
Pennsylvania portions of your draft report, Professional Boxing: Issues 
Related To The Protection of Boxers' Health, Safety and Economic 
Interests (GAO-03.699). Our Commissions comments are as follows:

* Ensure Presence of Medical Personnel/Equipment (p. 9). Please note 
that Section 707 of the State Athletic Code, 5 Pa-C.S. § 707, requires 
that an ambulance with appropriate equipment be at ringside at all 
times.. (Act 32-1992, Section 707). This is verified by the ringside 
doctors, the Executive Director and the Inspectors assigned to the 
event. There has never been a professional boxing event held in 
Pennsylvania without an ambulance and medical personnel present.

* Conduct post fight exams (p. 12). In Pennsylvania, ringside physicians 
are required to complete a Post bout exam/report of each boxer 
competing. These reports are on file with the Commission. When 
completing these reports the doctors can include any type of:

follow-up medical testing (including neurological) if the doctor feels 
it is necessary for the over-all well-being of the boxer.

Require health and life insurance for boxers before and after each 
match (p.12). In Pennsylvania, all boxers are covered by insurance. 
This covers them for any and all injuries sustained in a match. This 
coverage is good for one (1) year after the match so that a boxer is 
covered for a year for, any injury sustained in a boxing event held in 
Pennsylvania.

Enforce Suspensions for Training Injuries (p. 12). Although this does 
occur at times, because of personnel and budgetary restraints it is 
very difficult to be at all the training facilities monitoring all the 
boxers. Often boxers or their trainers will contact the Commission 
regarding an injury suffered before an event at which case a 
Commission-approved physician will follow up with a physical exam to 
determine this boxer's over-All physical health.

Require Pension Plans (p.13). Because professional boxers are not 
unionized, creating a national pension plan similar to the other 
professional sports would be very difficult. The Association of Boxing 
Commissions (ABC) created a Charitable Trust Fund for those boxers that 
have suffered injuries during an event. This is solely funded by 
voluntary contributions. Pennsylvania is examining the feasibility of 
having a Commission funded Pension/Trust program for all Pennsylvania 
boxers.

In closing, let me state that I was impressed with the thoroughness and 
professionalism of how this survey/study was conducted. This report, 
particularly in the format it has been presented, definitely shows the 
diversity amongst the various athletic commissions and how they have 
implemented the federal law.


[End of section]

Appendix XI: Comments from the Texas Department of Licensing and 
Regulations:

TEXAS DEPARTMENT OF LICENSING AND REGULATION:

Executive Offices P.O. Box 12157 9 Austin, Texas 78711 * (512) 463-3173 
9 (800) 803-9202 0 fax (512) 475-2874 Web site: 
www.license.state.tx.us:

Mr. Bernard L. Ungar, Director July 15, 2003 Physical Infrastructure 
Issues:

United States General Accounting Office Washington, DC 20548:

Dear Mr. Ungar,

Thank you for the opportunity to review and comment on the portion of 
your draft report, Professional Boxing: Issues related to the 
Protection of Boxer's Health, Safety, and Economic Interests, relating 
to our Texas program. We also want to take this opportunity to commend 
the GAO staff, particularly Frederick Lyles, John Vocino and Bernice 
Benta, for their extensive and very professional study of the health, 
safety and economic interests of the sport of professional boxing.

Texas is proud of its efforts to ensure the safety of boxers in this 
state. Nevertheless, we continuously seek to improve our combatant 
safety program, our standards for licensing combatants, and our 
oversight of boxing events. We welcome any recommendations that can 
help improve the operation of our program.

As requested, we have reviewed the draft information and offer the 
following comments:

* Prohibit conflicts of interest for commission representatives.

* The Department's enabling statute requires each member of the 
Commission to be a representative of the general public and prohibits a 
Commissioner or their spouse from having an interest in any business 
entity or organization regulated by the Department. Further, they may 
not be affiliated with a trade association in a field regulated by the 
Department and may not be a lobbyist for a profession related to the 
operation of the Commission or Department. These are a part of the 
statutory requirements for eligibility for Commission membership.

* All Department employees are required to sign a document certifying 
that they have read and understood all requirements of the Department 
personnel manual, which includes a section on employee ethics. This 
section includes provisions on "Conflicts of Interest," which prohibits 
any activities that create or even seem to create "conflicts of 
interest with our public duties or responsibilities." This provision 
extends to all employees in all of their Department duties, including 
any activities related to all boxing activities overseen by the 
Department.

* For these reasons, we believe that the Program complies with this 
provision for 100 percent of the boxing events it oversees.

Prohibit conflicts of interest for boxers and promoters.

* We currently have no statutory authority to address conflicts of 
interest relative to boxers or promoters.

* Evaluate Medical Information and Assess Risks.

* We agree with the findings under this heading, but wish to offer this 
additional information:

* As noted, the commission may require the boxer to undergo additional 
medical tests, which by program rule includes neurological and other 
medical testing.

* Although we are prohibited from disclosing protected personal medical 
information, we do share with other Commissions such information as 
results and terms of medical suspensions issued by our Commission.

Conduct post-fight medical examinations, including neurological 
testing.

o The commission may require additional medical examinations, including 
neurological and other medical testing. These examinations can be 
recommended by the ringside physician immediately following a bout, and 
may be required as part of the minimum criteria for lifting a medical 
suspension.

* Monitor Training Injuries; Enforce Suspensions for Training Injuries.

o The Department has no statutory authority to monitor or inspect boxing 
gyms. We will, however, be investigating the feasibility of requiring 
licensed boxers and managers to report training injuries to the 
Department.

* Require health and life insurance for boxers before and after each 
match.

o The Department does require promoters to provide health and life 
insurance for boxers for the day of the fight and the day following the 
event, and for up to one year for injuries sustained during an event. 
However, we have no statutory authority to provide this insurance 
through the State.

* Require Pension Plans.

o The Department has no statutory authority to require or to provide 
pension plans for boxers.

* Require Disclosure of All Purses and Payments to Trainers and Boxers.

* The Department has no statutory authority to require this information 
from trainers. However, we do provide this information to the boxers 
when it is provided to us, such as when these payments are documented 
as a deduction in a boxer's contract.

* Require Registration and Training for Trainers, Managers, Promoters, 
and Physicians.

o We currently have statutory authority to license managers and 
promoters, although we are prohibited from making continuing education 
a mandatory requirement for licensees. Recent statutory changes will 
allow the Department to register ringside physicians starting September 
1, 2003. These statutory changes will also give the Commission the 
authority to establish a medical advisory committee to advise the 
Department concerning health issues for boxing event contestants.

Once again, thank you for selecting Texas to participate in this 
comprehensive study of issues related to the protection of boxers' 
health, safety, and economic interests. We look forward to continuing 
to work with you and your staff to help improve the safety of boxing in 
Texas and nationwide. We also ask that you provide us with a copy of 
your final report.

Sincerely,

William H. Kuntz, Jr. Executive Director:

Signed by William H. Kuntz, Jr.: 

Cc: Brian E. Francis, Deputy Director:

Richard J. Cole, Program Administrator, Texas Combative Sports Program:

Greg Alvarez, Assistant Program Administrator, Texas Combative Sports 
Program George W. Ferrie, Director Code Review and Inspections 
Division:

[End of section]

Appendix XII: Contacts and Contributors:

Contact:

John S. Baldwin, Sr. (202) 512-2834:

Contributors:

Frederick Lyles, Jr., John Vocino, Bernice Benta, Christopher Factor, 
Elizabeth Eisenstadt, Jerry Sandau, Brandon Haller, Bert Japikse, and 
Sidney Schwartz:

(543027):


FOOTNOTES

[1] These commissions are state or tribal organizations that are 
responsible for regulating professional boxing within their 
jurisdictions, including implementing and enforcing federal and state 
or tribal provisions related to boxing. 

[2] Sanctioning organizations are private entities that designate the 
champion and rank challengers for each weight class. These 
organizations are required to identify their rating officials and to 
annually disclose their criteria and policies for rating boxers, as 
well as their sanctioning fees, by-laws, and procedures for appealing 
ratings. 

[3] California, Florida, Indiana, Michigan, Missouri, Nevada, 
Pennsylvania, and Texas.

[4] The Mohegan Sun (Connecticut) and Miccosukee (Florida) tribes.

[5] Senate Committee on Commerce, Science, and Transportation, 
Subcommittee on Consumer Affairs, Foreign Commerce, and Tourism: 
Hearing on the Federal Regulation of Boxing (Washington, D.C.: May 22, 
2002); Senate Committee on Commerce, Science, and Transportation, 
Testimony on Boxing and Federal Laws (Washington, D.C.: May 23, 2001); 
Senate Committee on Commerce, Science, and Transportation: Hearing on 
Reform of Professional Boxing Industry (Washington, D.C.: Apr. 22, 
1999); Senate Committee on Commerce, Science, and Transportation, 
Hearing on Professional Boxing (Washington, D.C.: May 22, 1997); House 
Economic and Educational Opportunities Committee Workforce Protections 
Subcommittee and the House Committee on Commerce Subcommittee on 
Commerce Trade and Hazardous Materials, The Professional Boxing 
Corporation Act of 1995 (Washington, D.C.: June 11, 1996); Senate 
Committee on Commerce, Hearing on Health and Safety of Professional 
Boxing (Washington, D.C.: Jan. 20, 1994). 

[6] National Association of Attorneys General Boxing Task Force, Office 
of New York State Attorney General Eliot Spitzer, May 2000; Department 
of Health and Human Services, Professional Boxing Safety Act of 1996: 
National Institute for Occupational Safety and Health Report to 
Congress, Study on Health, Safety, and Equipment Standards for Boxing 
(Washington, D.C.: June 1, 1998); and Department of Labor, Pension 
Plans for Professional Boxers: A Study Prepared by the Segal Company 
for the Secretary of Labor as Mandated by Congress (Washington, D.C.: 
December 1997).

[7] Our report focuses on enforcement of the Professional Boxing Safety 
Act only. Criminal violations under the act are punishable only as 
misdemeanors. When violations of the act are also violations of other 
criminal statutes, prosecution of the felony may overshadow punishment 
of the misdemeanor. 

[8] Sanctioning organizations are required to identify their rating 
officials and to annually disclose their criteria and policies for 
rating boxers, as well as their sanctioning fees, by-laws, and 
procedures for appealing ratings. They can send this information to FTC 
or post it on the Internet. 

[9] Professional Boxing Safety Act of 1996: National Institute for 
Occupational Safety and Health Report to Congress, Study on Health, 
Safety, and Equipment Standards for Boxing (June 1, 1998).

[10] Senate Committee on Commerce, Science, and Transportation, 
Testimony on Boxing and Federal Laws, (Washington, D.C.: May 23, 2001).

[11] The World Medical Association is an international organization 
created to ensure the independence of physicians and to work for the 
highest possible standards of ethical behavior and care by physicians.

[12] Senate Committee on Commerce, Science, and Transportation: 
Testimony on Boxing and Federal Laws (Washington, D.C.: May 23, 2001).

[13] House Economic and Educational Opportunities Committee Workforce 
Protections Subcommittee and the House Committee on Commerce 
Subcommittee on Commerce Trade and Hazardous Materials, The 
Professional Boxing Corporation Act of 1995 (Washington, D.C.: June 11, 
1996).

[14] Senate Committee on Commerce, Science, and Transportation: Hearing 
on Reform of Professional Boxing Industry (Washington, D.C.: Apr. 22, 
1999). 

[15] Pension Plans for Professional Boxers: A Study Prepared by the 
Segal Company for the Secretary of Labor as Mandated by Congress 
(December 1997).

[16] Senate Committee on Commerce, Science, and Transportation, Hearing 
on Professional Boxing (Washington, D.C.: May 22, 1997).

[17] Senate Committee on Commerce, Hearing on Health and Safety of 
Professional Boxing (Washington, D.C.: Jan. 20, 1994). 

[18] Senate Committee on Commerce, Science, and Transportation, 
Subcommittee on Consumer Affairs, Foreign Commerce, and Tourism: 
Hearing on the Federal Regulation of Boxing (Washington, D.C.: May 22, 
2002).

[19] Senate Committee on Commerce, Science, and Transportation, Hearing 
on Effective Regulation of the Boxing Industry: A Cooperative Effort 
(Washington, D.C.: May 23, 2001).

[20] Senate Committee on Commerce, Science, and Transportation, 
Subcommittee on Consumer Affairs, Foreign Commerce, and Tourism: 
Hearing on Federal Regulation of Boxing (Washington, D.C.: May 22, 
2002).

[21] Fight Fax, Incorporated, is the official record-keeping body of 
ABC. 

[22] In commenting on a draft of this report, the Texas Department of 
Licensing and Regulation said that all of its employees are required to 
sign a certification that they have read the department's conflict of 
interest policies. However, when we met with the Texas boxing 
commission officials they said there was no documentation of this for 
us to review.

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