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Report to the Committee on Energy and Natural Resources, U.S. Senate: 

United States Government Accountability Office: 

GAO: 

December 2006: 

U.S. Insular Areas: 

Economic, Fiscal, and Financial Accountability Challenges: 

U.S. Insular Areas: 

GAO-07-119: 

GAO Highlights: 

Highlights of GAO-07-119, a report to Committee on Energy and Natural 
Resources, U.S. Senate

Why GAO Did This Study: 

The U.S. insular areas of American Samoa, the Commonwealth of the 
Northern Mariana Islands (CNMI), Guam, and the U.S. Virgin Islands 
(USVI), face long-standing economic, fiscal, and financial 
accountability challenges. GAO was requested to identify and report on 
the (1) economic challenges facing each government, including the 
effect of changing tax and trade laws on their economies; (2) fiscal 
condition of each government; and (3) financial accountability of each 
government, including compliance with the Single Audit Act, which 
applies to nonfederal entities that receive $500,000 or more a year in 
federal funding. 

What GAO Found: 

The governments of the U.S. insular areas of American Samoa, the 
Commonwealth of the Northern Mariana Islands, Guam, and the U.S. Virgin 
Islands face serious economic, fiscal, and financial accountability 
challenges. The economic challenges stem from dependence on a few key 
industries, scarce natural resources, small domestic markets, limited 
infrastructure, shortages of skilled labor, and reliance on federal 
grants to fund basic services. To help diversify and strengthen their 
economies, OIA sponsors conferences and missions to the areas to 
attract U.S. businesses; however, there has been little formal 
evaluation of these efforts. 

After fiscal year 2001, government spending in the CNMI, Guam, and USVI 
exceeded revenues through fiscal year 2004 (the most recent year for 
which there is complete data on all four areas). As a result, their 
fiscal conditions weakened further during this period. CNMI and USVI 
ended fiscal year 2004 with negative net government assets. For 
American Samoa the picture was mixed, with more stability than the 
other areas in the period 2001 through 2003, but a downturn in the 
balance of governmental funds by the end of fiscal year 2004. 

Efforts to meet formidable fiscal challenges and build strong economies 
are hindered by delayed and incomplete financial reporting that does 
not provide timely and complete information to management and oversight 
officials for decision making. The insular area governments have had 
long-standing financial accountability problems, including the late 
submission of required single audits, the receipt of disclaimer or 
qualified audit opinions, and the reporting of many serious internal 
control weaknesses. These problems have resulted in numerous federal 
agencies designating these governments as “high-risk” grantees. The 
Department of the Interior and the federal agencies are working to help 
these governments improve their financial accountability, but greater 
coordination among the agencies would increase the effectiveness of 
their efforts. 

Figure: Map Showing Location of Four U.S. Insular Areas (CNMI, Guam, 
American Samoa, and U.S. Virgin Islands): 

[See PDF for Image] 

Source: GAO and MapArt(map). 

[End of Figure] 

What GAO Recommends: 

The Secretary of the Interior should direct the Deputy Assistant 
Secretary for Insular Affairs to  (1) coordinate with other federal 
grant-making agencies on issues related to the insular area 
governments; (2) conduct periodic evaluations of the Department of the 
Interior’s Office of Insular Affairs conferences and business-
opportunities missions; (3) develop a framework for conducting site 
visits to help ensure objectives are achieved, information is shared, 
and monitoring is more efficient and effective; and (4) implement 
procedures for evaluation of  progress made by the insular areas in 
resolving audit findings and set a time frame for achieving clean audit 
opinions. DOI agreed with GAO’s recommendations. 

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-119].

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Jeanette Franzel at (202) 
512-9471 or franzelj@gao.gov.

[End of Section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

Scope and Methodology: 

Narrow Economic Base and Intrinsic and External Factors Limit Economic 
Progress in the U.S. Insular Areas: 

Weakened Fiscal Condition in Three Insular Areas: 

Financial Accountability Remains Weak in the U.S. Insular Areas: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Matters Leading to Qualified Audit Opinions: 

Appendix II: Internal Control Weaknesses and Compliance with 
Requirements Applicable to Major Federal Programs: 

Appendix III: DOI Inspector General Reports on Four Insular Areas for 
Calendar Years 2000--2005: 

Appendix IV: Comments from the Department of the Interior: 

Appendix V: GAO Contacts and Staff Acknowledgments: 

Tables: 

Table 1: Demographic and Economic Characteristics of American Samoa, 
CNMI, Guam, and USVI, 2000: 

Table 2: Political Characteristics of American Samoa, CNMI, Guam, and 
USVI: 

Table 3: Federal Grant Expenditures of the Insular Areas for Fiscal 
Year 2004: 

Table 4: Fiscal Condition by Year--American Samoa: 

Table 5: Fiscal Condition by Year--CNMI: 

Table 6: Fiscal Condition by Year--Guam: 

Table 7: Fiscal Condition by Year--USVI: 

Table 8: Single Audit Act Report Submissions, Fiscal Years 1997 through 
2004: 

Table 9: Financial Statement Audit Opinions for Fiscal Years 1997 
through 2004: 

Table 10: Opinions Rendered on Compliance with Requirements for Major 
Federal Programs for Fiscal Years 1997 through 2004: 

Table 11: Reported Weaknesses in Internal Control over Financial 
Reporting Identified in the Auditors' Reports for Fiscal Year 2004: 

Table 12: Material Weaknesses and Reportable Conditions Relating to 
Compliance with Requirements for Major Federal Programs for Fiscal Year 
2004: 

Table 13: OIA Funding for Technical Assistance from the USDA Graduate 
School: 

Table 14: American Samoa--Matters Leading to Qualified Audit Opinions 
on the Financial Statements for Fiscal Years 2001 through 2004: 

Table 15: CNMI--Matters Leading to Qualified Audit Opinions on the 
Financial Statements for Fiscal Years 2001 through 2004: 

Table 16: Guam--Matters Leading to the Qualified Audit Opinions on the 
Financial Statements for Fiscal Years 2001 through 2004: 

Table 17: USVI--Matters Leading to the Qualified Audit Opinions on the 
Financial Statements for Fiscal Years 2001 through 2004: 

Table 18: American Samoa--Reported Weaknesses Identified in the 
Auditors' Reports for Fiscal Years 2001 through 2004: 

Table 19: CNMI--Reported Weaknesses Identified in the Auditors' Reports 
for Fiscal Years 2001 through 2004: 

Table 20: Guam--Reported Weaknesses Identified in the Auditor's Reports 
for Fiscal Years 2001 through 2004: 

Table 21: USVI--Reported Weaknesses Identified in the Auditors' Reports 
for Fiscal Years 2001 through 2004: 

Figure: 

Figure 1: Map Showing Location of Four U.S. Insular Areas: 

Abbreviations: 

ACC: Annual Contributions Contract: 

ACF: Administration of Children and Families: 

AJCA: American Jobs Creation Act: 

APIPA: Association of Pacific Islands Public Auditors: 

ATPA: Andean Trade Preference Act: 

CDC: Centers for Disease Control and Prevention: 

CHC: Commonwealth Health Center: 

CNMI: Commonwealth of the Northern Mariana Islands: 

DOD: Department of Defense: 

DOI: Department of the Interior: 

DOL: Department of Labor: 

DOT: Department of Transportation: 

EDC: Economic Development Commission: 

EMO: Emergency Management Office: 

FAC: Federal Audit Clearinghouse: 

FMCSA: Federal Motor Carrier Safety Administration: 

FMS: Financial Management System: 

FNS: Food and Nutrition Service: 

GAAP: Generally Accepted Accounting Principles: 

GASB: Governmental Accounting Standards Board: 

GDP: Gross Domestic Product: 

GHURA: Guam Housing and Urban Renewal Authority: 

HHS: Department of Health and Human Services: 

HUD: Department of Housing and Urban Development: 

IG: Inspector General: 

IGFOA: Island Government Finance Officers Association: 

IGIA: Interagency Group on Insular Areas: 

JAL: Japan Airlines: 

MCSAP: Motor Carrier Safety Assistance Program: 

MOU: Memorandum of Understanding: 

NAFTA: North American Free Trade Agreement: 

OIA: Office of Insular Affairs: 

OMB: Office of Management and Budget: 

P&S: Division of Procurement and Supply: 

PHAS: Public Housing Assessment System: 

PITI: Pacific Islands Training Initiative: 

SAMHSA: Substance Abuse and Mental Health Services Administration: 

SARS: Severe Acute Respiratory Syndrome: 

SEMAP: Section Eight Management Assessment Program: 

U.S. United States: 

USDA: Department of Agriculture: 

USVI: U.S. Virgin Islands: 

VIHA: Virgin Islands Housing Authority: 

VIHFA: Virgin Islands Housing Finance Authority: 

VITI: Virgin Islands Training Initiative: 

WIC: Women, Infants, and Children: 

WTO: World Trade Organization: 

United States Government Accountability Office: 
Washington, DC 20548: 

December 12, 2006: 

The Honorable Pete V. Domenici: 
Chairman: 
The Honorable Jeff Bingaman: 
Ranking Member Committee on Energy and Natural Resources: 
United States Senate: 

The U.S. insular areas[Footnote 1] of American Samoa, Commonwealth of 
the Northern Mariana Islands (CNMI), Guam, and the United States Virgin 
Islands (USVI) face key economic, fiscal, and financial accountability 
challenges. The three Pacific insular areas--American Samoa, CNMI, and 
Guam--are between 4,100 and 6,000 miles from the U.S. mainland. The 
fourth insular area, the USVI, is located in the Caribbean Sea about 
1,000 miles southeast of Miami. All four governments face common 
challenges to strengthening their economy, fiscal condition, and 
financial accountability. As you requested, we are reporting on the (1) 
economic challenges facing each government, including the effect of 
changing tax and trade laws on their economies; (2) fiscal condition of 
each government; and (3) financial accountability, including compliance 
with the Single Audit Act, as amended (Single Audit Act).[Footnote 2] 

The economic and fiscal conditions of these insular areas are affected 
by destructive climatic events such as typhoons, cyclones, and 
hurricanes, as well as their economies' general dependence on a few key 
industries and their governments' reliance on federal grants to provide 
basic services to their citizens. In addition, although progress has 
been made in improving financial accountability, the insular area 
governments continue to have serious internal control and 
accountability problems that increase their risk of fraud, waste, 
abuse, and mismanagement. 

Results in Brief: 

The governments of the insular areas of American Samoa, CNMI, Guam, and 
USVI face serious economic, fiscal, and financial accountability 
challenges. The insular area governments' abilities to strengthen their 
economies have been constrained by their lack of diversification in 
industries, scarce natural resources, small domestic markets, limited 
infrastructure, and shortages of skilled labor. The few key industries 
in each area were established partially due to favorable U.S. federal 
government trade and tax policies and are vulnerable to changes in 
these policies that would restrict such benefits. These key industries 
are also affected by various other external factors, such as 
fluctuations in the economies of the nearby countries; events such as 
the effect of the September 11, 2001, terrorist attacks in the United 
States on tourism in these areas; and U.S. Department of Defense (DOD) 
decisions to expand or reduce the number of troops at military bases, 
specifically on Guam. To help diversify and strengthen their economies, 
the Department of the Interior's (DOI) Office of Insular Affairs 
(OIA)[Footnote 3] has in the last 3 years sponsored conferences in the 
United States and business opportunities missions in the insular areas 
to attract American businesses to these insular areas. However, the 
effectiveness of these conferences and business opportunities missions 
is uncertain due to the lack of formal evaluation of these efforts. 

The governments of CNMI, Guam, and USVI experienced worsening fiscal 
conditions during fiscal years 2001 to 2004,[Footnote 4] while in 
American Samoa the picture was mixed, with increases in government 
funds and assets during fiscal years 2001 through 2003 but a decrease 
in government funds by the end of fiscal year 2004. In CNMI and Guam, 
the fund balance[Footnote 5] of total governmental funds declined as 
government spending rose. In CNMI, net assets[Footnote 6] declined for 
fiscal years 2001-2004, and in Guam, net assets declined for fiscal 
years 2001-2003. The USVI government maintained positive balances of 
total government funds and reduced its negative balance of net assets 
by increased borrowing during the period. American Samoa's increase in 
government funds for fiscal years 2002 and 2003 was due to 2 years of 
strong surpluses of revenues over expenditures, stemming from an 
insurance settlement of claims from Hurricane Val, which hit the 
insular area in 1991. The audited financial statements used to analyze 
the fiscal condition of the four insular areas are subject to 
limitations cited by their auditors, which are discussed in the 
financial accountability section of this report. 

The governments of the four insular areas have long-standing financial 
accountability problems, including the late submission of the reports 
required by the Single Audit Act, the inability to achieve unqualified 
("clean") audit opinions on their financial statements, and numerous 
material weaknesses in internal control over financial reporting and 
compliance with laws and regulations governing federal grant awards. 
Several federal agencies have designated the insular areas as high-risk 
grantees due to their failure to submit the single audit reports by the 
statutory deadline and serious ongoing audit findings. The findings in 
the single audit reports clearly show that the insular area governments 
lacked effective internal controls to provide reasonable assurance that 
transactions are properly recorded; assets are safeguarded from fraud, 
waste, abuse, and mismanagement; and federal funds are expended in 
accordance with grant requirements. As a result, there is limited 
accountability over federal grants to the insular areas. Increased 
coordination between OIA officials and federal grant-making agencies on 
issues of common concern related to the insular area governments--such 
as late single audit reports, high-risk designations, and deficiencies 
in financial management systems and practices--would increase the 
effectiveness of their efforts. 

Multiple federal offices oversee the insular areas' efforts to improve 
their financial accountability, including the OIA and DOI's Office of 
the Inspector General (IG), as well as inspectors general from other 
federal agencies that provide grants. OIA provides funding for 
technical assistance provided by the Graduate School of the Department 
of Agriculture (USDA) to the insular area governments as well as direct 
grants to these governments to obtain technical assistance. The insular 
areas also have local auditing authorities that provide oversight over 
the governments' activities. While multiple entities oversee the 
insular areas' efforts to improve their financial accountability, there 
appears to be limited coordination of financial assistance programs and 
grants management across the many federal grant-making agencies. 

To help the insular area governments improve their financial 
accountability, we are making recommendations for increased 
coordination between OIA and other federal grant-making agencies on 
issues of common concern related to the insular areas, and the 
implementation by OIA of formal, periodic evaluations of the 
effectiveness of its efforts to improve the economy of the insular 
areas. We are also making recommendations for OIA to (1) monitor the 
insular areas' progress in improving financial accountability by 
setting a time frame for the governments to achieve clean audit 
opinions and (2) implement a framework for site visits to help ensure 
that monitoring objectives are achieved. 

We received written comments from DOI on a draft of this report. DOI 
agreed with our conclusions and recommendations and stated that the 
four recommendations are consistent with OIA's top priorities and 
ongoing activities. The focus of our draft report, according to DOI's 
comments, reflects OIA's top two priorities for the insular areas-- 
private sector economic development and accountability. DOI officials 
stated that progress is not easily achieved for these two priorities. 
DOI also provided examples of its current activities that it believes 
are directed at making the improvements that were the focus of our 
recommendations. We have reprinted DOI's comments, with our responses, 
in appendix IV. 

Background: 

The U.S. insular areas of American Samoa, CNMI, and Guam are located in 
the Pacific Ocean, between 4,100 and 6,000 miles from the U.S. 
mainland. USVI is located about 1,000 miles southeast of Miami in the 
Caribbean Sea, as shown in figure 1. 

Figure 1: Map Showing Location of Four U.S. Insular Areas: 

[See PDF for image] 

Source: GAO and MapArt(map). 

[End of figure] 

According to U.S. Census Bureau data for 2000, the population of the 
U.S. insular areas ranges from about 57,000 in American Samoa, to about 
155,000 in Guam. Residents born in CNMI, Guam, and USVI are citizens of 
the United States. Residents born in American Samoa are 
nationals[Footnote 7] of the United States, but may become naturalized 
U.S. citizens. The population of both American Samoa and CNMI, which 
control their own immigration, included significant percentages of 
people who were foreign nationals. 

According to U.S. Census Bureau data for 2000, median household incomes 
in the four insular areas ranged from less than half of the U.S. median 
household income of almost $41,000 for American Samoa to nearly equal 
for Guam, as shown in table 1. The percentage of individuals in poverty 
ranged from a low in Guam of 23 to a high in American Samoa of 61. 
Guam's 23 percent is nearly twice the rate of the continental U.S. rate 
of 12 percent. 

Table 1: Demographic and Economic Characteristics of American Samoa, 
CNMI, Guam, and USVI, 2000: 

Population; 
American Samoa: 57,291; 
CNMI: 69,221; 
Guam: 154,805; 
Virgin Islands[A]: 108,612. 

Percentage who were non-U.S. citizens or nationals; 
American Samoa: 35.3; 
CNMI: 56.5; 
Guam: 18.1; 
Virgin Islands[A]: 12.0. 

Median household income; 
American Samoa: $18,219; 
CNMI: $22,898; 
Guam: $39,317; 
Virgin Islands[A]: $24,704. 

Per capita income; 
American Samoa: $4,357; 
CNMI: $9,151; 
Guam: $12,722; 
Virgin Islands[A]: $13,139. 

Percentage of individuals in poverty; 
American Samoa: 61.0; 
CNMI: 46.0; 
Guam: 23.0; 
Virgin Islands[A]: 32.5. 

Economic base; 
American Samoa: Manufacturing (tuna processing); 
CNMI: Manufacturing (apparel), tourism; 
Guam: Military bases, tourism; 
Virgin Islands[A]: Tourism, manufacturing (oil refining), business/ 
financial services. 

Employment (percentage): Government; 
American Samoa: 29.9; 
CNMI: 11.7; 
Guam: 26.5; 
Virgin Islands[A]: 24.5. 

Employment (percentage): Manufacturing; 
American Samoa: 35.3; 
CNMI: 40.7; 
Guam: 2.0; 
Virgin Islands[A]: 5.9. 

Employment (percentage): Tourism[B]; 
American Samoa: 3.7; 
CNMI: 13.6; 
Guam: 18.0; 
Virgin Islands[A]: 15.8. 

Source: U.S. Census Bureau, "Population and Housing Profile: 2000" and 
GAO analysis. 

[A] The USVI Bureau of Economic Research reports per capita personal 
income of $16,567 in 2000; the share of government in total employment 
(nonagricultural) is estimated at approximately 30 percent; and the 
share of tourism at around 20 percent. See U.S. Virgin Islands Annual 
Economic and Tourism Indicators available at [Hyperlink, 
http://www.usviber.org/publications.html]. 

[B] "Tourism" corresponds to the U.S. Census Bureau category "Arts, 
entertainment, recreation, accommodation and food services." This 
category is presented as a proxy for tourism's role in the insular area 
economies. 

[End of table] 

While the United States exercises sovereignty over the insular areas, 
each administers its local government functions through popularly 
elected governors. As shown in table 2, American Samoa and CNMI are 
self-governed under locally adopted constitutions. Guam and USVI have 
not adopted local constitutions and remain under organic acts[Footnote 
8] approved by Congress. Because each of the insular areas is an 
unincorporated territory,[Footnote 9] its residents--although they have 
many of the rights of citizens of the 50 states--cannot vote in 
national elections and do not have voting representation in the final 
approval of legislation by the full Congress. 

Table 2: Political Characteristics of American Samoa, CNMI, Guam, and 
USVI: 

American Samoa; 
Relationship to United States: Unorganized territory[A]; 
Constitutional development: Has a constitution; 
Citizenship status: U.S. nationals; 
Representation in Congress: Nonvoting delegate to House of 
Representatives[B]. 

CNMI; 
Relationship to United States: Commonwealth[C]; 
Constitutional development: Has a constitution; 
Citizenship status: U.S. citizens; 
Representation in Congress: Resident representative[D]. 

Guam; 
Relationship to United States: Organized territory[E]; 
Constitutional development: Does not have a constitution; 
Citizenship status: U.S. citizens; 
Representation in Congress: Nonvoting delegate to House of 
Representatives[B]. 

U.S. Virgin Islands; 
Relationship to United States: Organized territory[E]; 
Constitutional development: Does not have a constitution; 
Citizenship status: U.S. citizens; 
Representation in Congress: Nonvoting delegate to House of 
Representatives[B]. 

Source: Congressional Research Service, CRS Report for Congress: U.S. 
Insular Areas and Their Political Development (Washington, D.C.: 
Library of Congress, 1996). 

[A] An unorganized territory is an unincorporated U.S. insular area for 
which the U.S. Congress has not enacted an organic act. 

[B] The nonvoting delegates for American Samoa, Guam, and USVI may vote 
in committees and party caucuses but not on the House floor. 

[C] A commonwealth is an organized U.S. insular area that has 
established a more highly developed relationship--usually embodied in a 
written mutual agreement--with the federal government. The agreement 
between CNMI and the U.S. government was enacted by Pub. L. No. 94-241. 

[D] CNMI's elected "Resident Representative to the United States," 
unlike the delegates from American Samoa, Guam, and USVI, is not a 
member of Congress. 

[E] An organized territory is a U.S. insular area for which Congress 
has enacted an organic act. Guam and USVI are organized under, 
respectively, 48 USC §§1421 et. seq. and 48 USC §§ 1541 et. seq. 

[End of table] 

The insular areas receive substantial amounts in federal grants from a 
variety of federal agencies, as shown in table 3. Recipients that 
expend $500,000 or more a year[Footnote 10] in federal awards under 
more than one federal program are required by the Single Audit Act to 
undergo a single audit. Single audits are audits of the recipient 
organization--the government in the case of the insular areas--that 
focus on the recipient's internal controls and its compliance with laws 
and regulations governing federal awards.[Footnote 11] As nonfederal 
entities expending more than $500,000 a year in federal awards, the 
insular areas are required to submit single audit reports[Footnote 12] 
each year to comply with the Single Audit Act. One of the objectives of 
the act is to promote sound financial management, including effective 
internal controls,[Footnote 13] with respect to federal awards 
administered by nonfederal entities. Single audits also provide key 
information about the federal grantee's financial management and 
reporting. 

Recipient organizations are required by the act to submit their single 
audits reports to the Federal Audit Clearinghouse (FAC).[Footnote 14] 
The single audit reporting package sent to the FAC includes (1) the 
auditor's reports; (2) the entity's audited financial statements and 
related notes; (3) the schedule of expenditures of federal awards, 
related notes, and the auditor's report on the schedule; (4) a schedule 
of findings and questioned costs; (5) reports on internal controls over 
financial reporting, and compliance with laws and regulations; and (6) 
a summary schedule of prior audit findings. The reporting package also 
includes corrective actions for findings identified for the current 
year as well as unresolved findings from prior fiscal years. Table 3 
below shows the total amount of federal funds provided to each insular 
area and the largest five federal grant agencies for each insular area. 

Table 3: Federal Grant Expenditures of the Insular Areas for Fiscal 
Year 2004: 

U.S. insular area and largest grantor agencies: American Samoa; 
* Department of the Interior; 
* Department of Education; 
* Department of Agriculture; 
* Department of Transportation; 
* Department of Health and Human Services; 
Total federal expenditure amount (dollars in millions): $140.2. 

U.S. insular area and largest grantor agencies: CNMI; 
* Department of the Interior; 
* Department of Agriculture; 
* Department of Homeland Security; 
* Department of Health and Human Services; 
* Department of the Treasury; 
Total federal expenditure amount (dollars in millions): $62.3. 

U.S. insular area and largest grantor agencies: Guam; 
* Department of Agriculture; 
* Department of Health and Human Services; 
* Department of Homeland Security; 
* Department of Transportation; 
* Department of the Interior; 
Total federal expenditure amount (dollars in millions): $163.4. 

U.S. insular area and largest grantor agencies: USVI; 
* Department of Health and Human Services; 
* Department of Education; 
* Department of Agriculture (nonmonetary programs); 
* Department of Labor; 
* Department of Agriculture (monetary programs); 
Total federal expenditure amount (dollars in millions): $158.4. 

Source: Schedule of Expenditures of Federal Awards, Single Audit 
Reports for fiscal year 2004 for each of the four insular areas. 

[End of table] 

The Secretary of the Interior has administrative responsibility over 
the insular areas for all matters that do not fall within the program 
responsibility of another federal department or agency. DOI's OIA and 
IG carry out the Secretary's responsibilities. OIA was established to 
foster the efficiency and effectiveness of the insular area governments 
and to provide technical and financial assistance. In this role, OIA 
coordinates activities with other federal agencies in the development 
and implementation of programs and policies pertaining to the insular 
areas. DOI's IG has the authority to audit all insular area accounts 
pertaining to revenue and receipts and all expenditures; may report all 
findings of government failures to collect amounts owed; and may report 
improper and illegal expenses to the Secretary.[Footnote 15] DOI's IG 
has issued many audit reports covering issues on individual insular 
areas. See appendix III for a list of reports on the insular areas 
issued by the DOI IG between calendar years 2000 and 2005. 

Scope and Methodology: 

To identify the economic challenges the insular areas face, we reviewed 
relevant literature dealing with economic conditions in the insular 
areas, including the potential impact of recent changes in tax and 
trade laws. We also interviewed officials at OIA and specialists at the 
U.S. Census Bureau and analyzed various documents and studies from 
these agencies, including estimates of gross domestic product (GDP). We 
reviewed analyses prepared by the U.S. Department of Labor (DOL) of the 
tuna industry in American Samoa and gathered military personnel data 
from DOD. In addition, we obtained economic data from insular area 
officials, such as CNMI plant closings, employment statistics, and 
tourism indicators. 

We studied the fiscal condition of each of the insular area governments 
by identifying and analyzing the revenues, expenditures, government 
fund balances, and net assets data, as reported in their single audit 
reports issued for fiscal years 2001 through 2004. We used benchmark 
estimates of 2002 GDP, prepared by the U.S. Census Bureau for each of 
the insular areas, to calculate revenues and expenditures as a 
percentage of GDP. After our work was completed, American Samoa, CNMI, 
and Guam issued their single audit reports for fiscal year 2005. We did 
not update our information on the insular areas' fiscal conditions 
because the USVI single audit report for fiscal year 2005 had not been 
issued. 

We reviewed the financial accountability of the insular area 
governments by (1) determining the timeliness of submission of the 
single audit reports, (2) analyzing the contents of the single audit 
reports issued for fiscal years 2001-2004,[Footnote 16] (3) identifying 
those insular area governments designated as high-risk grantees through 
U.S. federal agency contacts, (4) obtaining information about OIA's 
efforts to help the insular areas improve financial management, and (5) 
identifying the relevant auditing organizations at the federal and 
local levels. We determined the timeliness of submission of the single 
audit reports using the FAC's "Form Date," which is the most recent 
date that a required SF-SAC data collection form[Footnote 17] or a 
revised form was received by the FAC. We did note that the "Form Date" 
is updated if revised SF-FACs for that same fiscal year are 
subsequently filed. Our review of the contents of the single audit 
reports identified the auditors' opinions on the financial statements, 
matters cited by the auditors in their qualified opinions, the numbers 
and nature of material weaknesses and reportable conditions reported by 
the auditors, and the status of corrective actions. We interviewed OIA 
officials to identify their role in assisting the insular area 
governments in efforts to improve financial accountability, including 
training and technical assistance funded by OIA and provided by the 
USDA's Graduate School. To identify the federal and local auditing 
authorities with oversight over the four insular area governments, we 
reviewed the information on the authorities' Web sites and reports that 
had been recently issued. 

Because high-risk designations are made at the individual agency or 
program level, and this information is not consolidated at the federal 
government level, we contacted officials at the largest five federal 
grant agencies for each insular area to determine whether they had 
designated any of these four insular area governments or agencies of 
these governments as high-risk grantees, and whether special conditions 
had been placed on them. We used the schedules of expenditures of 
federal awards included in the fiscal year 2004 single audit reports to 
identify the largest five federal grant agencies for each insular area. 

We conducted our work from September 2005 through August 2006 in 
accordance with U.S. generally accepted government auditing standards. 

Narrow Economic Base and Intrinsic and External Factors Limit Economic 
Progress in the U.S. Insular Areas: 

Several factors common to all four U.S. insular areas constrain their 
economic potential. These factors include lack of diversification, 
scarce natural resources, small domestic markets, limited 
infrastructure, and shortages of skilled labor. The labor markets of 
all four insular areas face competition with U.S. mainland wage levels 
because natives from the insular areas are free to migrate to the 
United States.[Footnote 18] Therefore, the insular areas' private and 
public sectors face chronic difficulties retaining well-trained and 
highly educated workers. Two of the insular areas, American Samoa and 
CNMI, control their own immigration and have developed industries that 
depend on foreign labor paid a minimum wage below that of the United 
States. Although geographic isolation is frequently mentioned as a 
factor restraining economic progress in the insular areas, it does not 
appear to apply to CNMI, Guam, or USVI. CNMI and Guam are well 
positioned to integrate with the regional economies of East Asia; and 
USVI is surrounded by the Caribbean Basin countries and the United 
States. On the other hand, American Samoa is more geographically 
isolated, with Australia, more than 2,000 miles away, and New Zealand, 
1,600 miles away, as the closest large economies. 

Although the type of industries and extent of dependence varies, the 
local economies of the insular areas rely on one or two primary 
industries. The result of this dependence is economies that are 
vulnerable to changes in international trade agreements, tax laws, and 
other external events. For example, American Samoa's private sector is 
largely based on two tuna canneries. Although these tuna canneries have 
been an integral part of American Samoa's private sector for decades, 
they are likely to face increased foreign competition from existing and 
pending trade agreements established to advance free trade, which could 
have a serious negative effect on them. Similarly, CNMI's economy is 
highly dependent on the garment manufacturing industry, which is facing 
the challenge of remaining internationally competitive against low-wage 
nations given recent changes in trade agreements. Guam's economy 
depends on two main sectors--tourism and the provision of services to 
the U.S. military. Guam's tourism sector is currently stable, but has 
been affected by several external events, such as the terrorist attacks 
on the United States on September 11, 2001, and the Severe Acute 
Respiratory Syndrome (SARS) epidemic. The stability of the sector that 
provides services to the U.S. military is tied to Guam's status as a 
strategic U.S. military base. USVI has a more diverse economy than 
American Samoa, CNMI, or Guam, with several sources of revenue-- 
primarily tourism, petroleum refining, and international business and 
financial services. However, USVI's tourist sector, like that of CNMI 
and Guam, has experienced volatility due to the terrorist attacks on 
the United States on September 11, 2001, and the impact of hurricanes. 
USVI is also facing challenges resulting from recent tax law changes 
that could cause a reduction in U.S. businesses operating in the 
insular area. 

American Samoa: 

American Samoa's economy depends primarily on the tuna canning 
industry.[Footnote 19] The industry is the insular area's largest 
source of income and, with the government sector, one of its two 
largest sources of employment. According to DOL, the two tuna canneries 
in the insular area employ about one-third of the workforce, with 
another one-third employed by other businesses, many of which support 
the tuna industry. The government sector in American Samoa accounts for 
about 20 percent of the insular area's GDP and employs around one-third 
of its labor force.[Footnote 20] Noncitizens make up a large portion of 
the canneries' employees, about 80 percent in 2000.[Footnote 21] 
Several changes in federal trade and tax law may adversely affect the 
American Samoa tuna industry, in turn affecting the insular area's 
economy and government. 

Trade Law Changes: 

Since the 1950s, tuna canned in American Samoa has been permitted to 
enter the United States duty free. However, changes scheduled to take 
effect in existing free trade agreements, as well as several pending 
agreements, are likely to increase competition for the tuna canneries 
in American Samoa. For example, according to a DOL study,[Footnote 22] 
the elimination of tuna tariffs in 2008 for Mexico under the North 
American Free Trade Agreement (NAFTA) could, in concert with other 
factors, result in Mexico's becoming a major exporter of canned tuna to 
the United States. Likewise, the Andean Trade Preference Act (ATPA), as 
amended in 2002,[Footnote 23] allows the U.S. President to exempt 
Bolivia, Colombia, Ecuador, and Peru from paying U.S. tariffs on 
shipments of pouched tuna, which is expected to gain market share in 
the United States.[Footnote 24] According to DOL, Congress may choose 
to gradually eliminate tariffs on canned tuna for these countries in 
the future. In that case, Ecuador--ATPA's major tuna exporter--could 
become, like Mexico, a significant supplier of canned tuna to the 
United States.[Footnote 25] In addition, the U.S.-Thailand Free Trade 
Agreement now being negotiated could further challenge the American 
Samoa tuna industry if it grants Thailand--the biggest exporter of tuna 
to the United States--the right to ship canned tuna to the United 
States duty free. 

Tax Law Changes: 

The canneries in American Samoa have benefited from possession tax 
credits under section 936 of the Internal Revenue Code,[Footnote 26] 
which is designed to encourage U.S. corporations to invest in the U.S. 
insular areas and create jobs by reducing the federal taxes on income 
earned by qualifying U.S. corporations.[Footnote 27] However, the 
credit expired for taxable years beginning after December 31, 2005. 
Although the House passed legislation to extend the credit for American 
Samoa for 1 year,[Footnote 28] the provision was removed in conference 
and was not included in the final version of the bill, which was signed 
by the President on May 17, 2006.[Footnote 29] According to the DOL 
study,[Footnote 30] the loss of the federal income tax credit will 
reduce the canneries' after-tax profitability and could prompt them to 
move to countries with a lower minimum wage.[Footnote 31] The economic 
and social impact associated with a significant downturn in its major 
industry may be severe in American Samoa because the large foreign 
workforce has relatively strong roots in the insular area and, as a 
result, may remain in the insular area even if unemployed.[Footnote 32] 

CNMI: 

The CNMI economy depends on two industries, garment manufacturing and 
tourism, for its employment, production, and exports. These two 
industries rely heavily on a noncitizen workforce that represents more 
than three quarters of the labor pool.[Footnote 33] The garment 
industry, for example, uses textiles and labor imported mostly from 
China. Garment manufacturing and tourism account for about 85 percent 
of CNMI's total economic activity and 96 percent of its 
exports.[Footnote 34] Recent estimates of CNMI's GDP suggest that, in 
2002, the garment industry contributed to roughly 40 percent of CNMI's 
GDP and 47 percent of payroll.[Footnote 35] The rapid growth of tourism 
between 1988 and 1996, with visitor arrivals rising from over 245,000 
to over 735,000, an average annual increase of 14.7 percent, fueled 
economic expansion. However, recent alterations in trade law have 
increased foreign competition for CNMI's garment industry and caused 
its exports to fall, while other external events have negatively 
impacted its tourism sector. 

Trade Law Changes: 

Several recent developments in international trade law have affected 
CNMI's garment industry. Historically, while other garment exports 
faced quotas and duties in shipping to the U.S. market, CNMI's garment 
industry benefited from quota-free and duty-free access to U.S. markets 
for shipments of goods in which 50 percent of the value was added in 
CNMI.[Footnote 36] Recently, however, U.S. agreements with other 
textile-producing countries have liberalized the textile and apparel 
trade. For example, in January 2005, in accordance with one of the 1994 
World Trade Organization (WTO) Uruguay Round agreements, the United 
States eliminated quotas on textile and apparel imports from other 
textile-producing countries, leaving CNMI's apparel industry to operate 
under stiffer competition, especially from low-wage countries such as 
China.[Footnote 37] With its trade advantage lessened, CNMI's garment 
industry has shrunk. According to a DOI official, more than 3,800 
garment jobs were lost between April 2004 and the end of July 2006, 
with 10 out of 27 garment factories closing.[Footnote 38] U.S. 
Department of Commerce data show that the value of CNMI shipments of 
garments to the United States dropped by more than 16 percent between 
2004 and 2005, from about $807 million to $677 million, and down from a 
peak of $1 billion in 1999-2000. In the first 7 months of 2006, garment 
exports to the United States dropped by more than 27 percent compared 
to the same period in 2005, with sales declining from $419 million to 
$305 million. Given that the taxes and fees from the garment industry 
account for about 35 to 40 percent of the insular area's revenues, 
these developments will likely have significant financial and economic 
impacts, according to OIA officials. 

Other Events: 

Various external events have affected CNMI's tourism industry in recent 
years. Due to CNMI's proximity to Asia, Asian economic trends have a 
direct impact on CNMI's economy. For example, tourism in CNMI 
experienced a sharp decline in the late 1990s with the Asian financial 
crisis. According to the Marianas Visitors Authority, total visitor 
arrivals dropped from a peak of 736,117 in 1996 to 501,788 in 1999. 
After a modest recovery in 2000, tourism faltered again with the 
September 11, 2001, terrorist attacks on the United States, bringing 
the number of visitors to 444,284 in 2001. In 2003, according to CNMI 
officials, tourism slowed--with a double-digit decline in arrivals for 
several months--in reaction to the SARS epidemic, which originated in 
Asia, and the war in Iraq. At the same time, CNMI has experienced an 
influx of Chinese tourists in recent years, with the potential to 
reenergize the industry. The Chinese share of visitors increased 
significantly from 0.4 percent in 1997 to 6.5 percent in 2005. CNMI 
officials are optimistic that the trend will continue in the future, 
especially on the island of Tinian, which already has gambling and 
hotel facilities owned and operated by Chinese interests from Hong 
Kong. 

Tourism in CNMI is also subject to changes in airline practices. For 
example, Japan Airlines (JAL) withdrew its direct flights between Tokyo 
and Saipan in October 2005, raising concerns because roughly 30 percent 
of all tourists and 40 percent of Japanese tourists arrive in CNMI on 
JAL flights, according to CNMI and DOI officials. The Marianas Visitors 
Authority's June 2006 data show that the downward trend in Japanese 
arrivals is not being offset by the growth in other tourism markets 
such as China and South Korea, with the total number of foreign 
visitors dropping from 43,115 in June 2005 to 38,510 a year 
later.[Footnote 39] A mitigating factor is Northwest Airlines' new 
daily nonstop flights between Osaka and Saipan, which are expected to 
replace about 40 percent of the seats lost from JAL's action.[Footnote 
40] 

Guam: 

Guam's economy is dominated by two sectors--tourism and government. 
Tourism provided about 65 percent of business activity in 2004, 
according to the Guam Economic Development and Commerce Authority 
Administrator. A 2002 U.S. Census Bureau study indicates that the 
government sector of Guam represented more than 36 percent of the 
island's GDP.[Footnote 41] The U.S. military accounted for more than 40 
percent of total government expenditures and about 90 percent of U.S. 
federal expenditures in Guam. 

Although Guam's tourism sector is currently stable, it has been 
affected by several external events since the late 1990s. The 
government sector, which is projected to grow in the near future, has 
historically been sensitive to significant changes in the U.S. military 
presence. 

Factors Affecting Tourism: 

Guam's tourism sector is vulnerable to external events. In 1997-1998, 
the Asian financial crisis and a severe typhoon slowed tourist 
arrivals. According to the Guam Visitors Bureau data, tourist arrivals 
dropped by almost 18 percent from 1.38 million in 1997 to 1.14 million 
the following year.[Footnote 42] After a modest recovery in 1999-2000, 
the terrorist attacks on the United States in September 2001, two more 
typhoons in 2002, and the SARS epidemic in 2003 caused further setbacks 
in the tourism sector.[Footnote 43] However, in 2004, with the economic 
recovery in Japan and a resulting increase in Japanese tourists--which 
make up the bulk of foreign visitors--tourism on the island increased 
to about 100,000 arrivals per month, according to Guam's Visitors 
Bureau. 

Military Decisions: 

Although the number of active-duty military personnel in Guam is 
currently increasing, the island's economy is vulnerable to policy 
changes regarding the U.S. military presence. Even though military 
personnel in Guam remained relatively stable from 1978 to 1992, 
averaging around 8,400, it declined by about 60 percent between 1992 
and 2002, according to DOD. A 2003 economic report[Footnote 44] states 
that this decline in the numbers of military personnel may have 
contributed to Guam's GDP shrinking by as much as 25 to 35 percent over 
the same period. Military spending, aimed primarily at repairing aging 
facilities and those damaged by typhoons, rose in 2004. In addition, 
DOD, in October 2005, announced its plans to transfer 7,000 Marines 
from Okinawa, Japan, to Guam over the next 6 years, a move that would 
more than triple the number of military personnel and raise the amount 
of DOD's spending in the insular area. 

USVI: 

With several sources of revenue, primarily tourism, petroleum refining, 
and international business and financial services, USVI has a more 
diversified economy than American Samoa, CNMI, or Guam.[Footnote 45] 
Tourism accounts for more than one half of USVI's income and, according 
to 2002 data from the USVI Bureau of Economic Research, over 20 percent 
of USVI employment.[Footnote 46] Exports of refined petroleum, reaching 
$4.8 billion in 2003, made up almost 90 percent of USVI's total 
exports.[Footnote 47] Companies selling international services benefit 
from a special tax incentive program established by the USVI government 
in 2001. They accounted for about 29 percent of all USVI corporate and 
individual income receipts in 2003, but less than 2 percent of USVI 
employment.[Footnote 48] 

While it is diversified, USVI's economy faces several challenges. 
First, recent U.S. tax law changes may negatively affect businesses 
operating in the insular area. Second, the tourism sector, which 
experienced several setbacks in 2001 through 2004, may be experiencing 
increased volatility as a result of local tourism trends and other 
factors. 

U.S. Tax Law Changes: 

As a result of tax changes that ensued from the American Jobs Creation 
Act of 2004 (AJCA),[Footnote 49] a growing number of U.S. businesses 
are projected to suspend operations in USVI, thus reducing local 
government revenues and jobs. U.S. businesses operating in USVI 
calculate their income under a coordinated U.S. and USVI income tax 
policy, but pay their taxes exclusively to the USVI government, if 
certain requirements are met. These coordinated rules allow the USVI 
government to reduce the amount of taxes payable to the USVI government 
provided the businesses are bona fide USVI residents whose income is 
derived from sources within USVI or is effectively connected with the 
conduct of a trade or business in USVI. For example, qualifying 
businesses receive a 90 percent exemption from USVI income taxes and a 
100 percent exemption from property and gross receipts taxes under this 
program operated by USVI's Economic Development Commission (EDC). Such 
provisions are designed to encourage economic development in the 
insular area. Effective January 2005, however, AJCA imposed stricter 
requirements on U.S. businesses for establishing residency and limited 
the types of income eligible for the program's tax exemptions, which 
will likely reduce the tax incentives for U.S. businesses operating in 
USVI.[Footnote 50] 

Tourism Trends and Other Factors: 

Security concerns and natural disasters have affected USVI's tourism 
industry in the past 5 years. The total number of visitors to USVI 
declined after the terrorist attacks of September 11, 2001, on the 
United States, although in 2004 a record number of tourists--2.6 
million--visited the islands, according to the USVI Bureau of Economic 
Research. Three-quarters of these visitors in 2004 were cruise 
passengers and one-quarter were overnight visitors. According to an OIA 
official, cruise ship visitors are increasingly affected by problems 
associated with crime, especially in St. Croix. Finally, the danger of 
hurricanes threatens USVI's tourist industry each year, imposing 
significant costs.[Footnote 51] 

Programs to Promote Economic Development in the Insular Areas: 

In the last few years, DOI has organized a number of initiatives, such 
as conferences in the United States and business opportunity missions 
to the four insular areas, to attract American businesses to these 
insular areas.[Footnote 52] The main goal of these efforts is to 
facilitate interaction and the exchange of information between U.S. 
firms and top government and business officials from the insular areas, 
and to spur new investment in a variety of industries. OIA recognizes 
that the natural economic partners of the Pacific insular areas are 
neighboring Asian and Pacific countries. However, OIA does not have a 
foreign affairs component that could actively promote economic 
relations between the insular areas and foreign countries in the 
region. Further, OIA believes it needs to promote partnership with U.S.-
based firms before foreign ones. 

In 2003, a 1-day Secretary's Investment Development Conference in 
Washington, D.C. attracted approximately 500 participants, while the 
second 2-day Secretary's Conference on Business Opportunities in the 
Islands in 2004 drew over 1,200 participants to Los Angeles. The 2004 
conference had 248 attendees from the four insular areas. About half of 
the participants from USVI, Guam, and American Samoa came from 
government. More than 80 percent of CNMI's participants were from 
government. The largest number of participants from the U.S. mainland 
came from California and Hawaii with a large majority from the private 
sector, but 26 other states and the District of Columbia were also 
represented. Individuals from the People's Republic of China, the 
Philippines, and Australia took part as well.[Footnote 53] In addition 
to the conferences, OIA organized three trade missions in the past 
year.[Footnote 54] Between 11 and 14 U.S. companies, both small and 
large, participated in each of these missions. 

OIA notes that many mission participants from the mainland did return 
to the insular areas for follow-up visits. According to OIA, several 
projects and business deals resulted from contacts made at conferences 
and missions. For example, OIA indicates that a California-based 
company is developing a nurse-training facility in CNMI and an 
entrepreneur from southern California started a software company in 
American Samoa. Innovative projects such as setting up a production/ 
mass mailing facility in CNMI aimed at the Japanese market are reported 
to be underway. Although the list does not include new large business 
enterprises with significant employment impact, it appears that OIA's 
initiatives have brought new firms and jobs to the insular areas, 
albeit on a modest scale. While some of these business activities may 
have taken place anyway, the OIA conferences and missions seem to have 
helped create linkages and joint projects between the business 
communities in the mainland and in the insular areas. Some of the new 
firms may just be displacing local ones or are interested in selling 
products and services rather than investing; however, others are likely 
to benefit the insular areas' economies by building local capacity and 
increasing competition and productivity if investments are realized. 
Many business deals are apparently still in the planning stages, with 
companies expressing interest, holding talks, and doing preliminary 
work. 

Whether and to what extent OIA's conferences and missions have 
contributed to stronger economies in the insular areas is difficult to 
discern because OIA does not carry out formal impact evaluations of its 
conferences and missions. It does obtain some feedback through informal 
surveys conducted with participants. But OIA would benefit from an in- 
depth analysis of how effective its initiatives are in attracting 
investment to the islands. Further, OIA could, by learning the extent 
to which U.S. firms are partnering with foreign investors already 
operating in the insular areas, discover further opportunities for 
partnership. For example, many Asian-owned businesses are currently 
contributing entrepreneurial skills and capital: many garment factories 
in CNMI and one of the two canneries in American Samoa are Asian-owned. 
Much of the insular areas' economic development may be dependent on 
relationships with Asian companies, yet OIA does not actively seek to 
reach firms outside of the U.S. mainland. 

Weakened Fiscal Condition in Three Insular Areas: 

With the exception of American Samoa, the fiscal condition of the 
insular area governments steadily weakened from fiscal year 2001 
through fiscal year 2004, the most recent year for which audited 
financial statements were available for all four insular areas. In CNMI 
and Guam, the fund balance of total governmental funds declined as 
government spending rose faster than revenues. CNMI's net assets at 
fiscal year-end declined for fiscal years 2001-2004. The USVI 
government maintained positive balances of total government funds and 
reduced its negative balance of net assets by increased borrowing 
during the period. American Samoa showed an increase in government 
funds until fiscal year 2004, due to 2 years of strong surpluses of 
revenues over expenditures, stemming from an insurance settlement of 
claims from Hurricane Val, which hit the insular area in 1991. In 
fiscal year 2004, the increases in government funds reversed, although 
it is not yet known if this is a new trend. American Samoa's net assets 
increased during the entire 4 fiscal years. 

American Samoa: 

For fiscal years 2001 through 2003, American Samoa's fund balance of 
total governmental funds increased steadily from a deficit of $23.1 
million at the beginning of fiscal year 2001 to a positive $43.2 
million at the end of fiscal year 2003 before dropping to $37.8 million 
in fiscal year 2004. From 2001 to 2003, total annual revenues rose by 
over $15 million, while annual spending fell by almost $12 million, 
contributing to significant surpluses for fiscal years 2002 and 2003. 
However, included in the revenues for 2002 and 2003 were proceeds 
attributable to an insurance settlement of claims from Hurricane Val. 
Without the receipt of these insurance proceeds, American Samoa's 
spending would have exceeded its revenues for those years. In fiscal 
year 2004, the increases in government funds apparently reversed, 
although it is not yet known if this is a new trend. For fiscal year 
2004, revenue fell $9 million while spending increased $22 million. 

As shown in table 4, net assets almost tripled to $211 million during 
fiscal years 2001 through 2004. In fiscal year 2002, American Samoa's 
government revenues, including the U.S. federal government's 
contributions, were higher as a share of GDP, 38 percent, than the 
revenues of any of the other three insular areas. The U.S. federal 
government also contributed a higher proportion of these revenues--60 
percent in fiscal year 2004. 

Table 4: Fiscal Condition by Year--American Samoa: 

Data: Population; 
American Samoa: 2001: 57,529; 
American Samoa: 2002: 57,716; 
American Samoa: 2003: 57,844; 
American Samoa: 2004: 57,902. 

Data: Population: Own source revenue; 
American Samoa: 2001: 92,595,156; 
American Samoa: 2002: 116,164,151; 
American Samoa: 2003: 100,406,184; 
American Samoa: 2004: 74,916,915. 

Data: Population: Federal contributions; 
American Samoa: 2001: 89,621,049; 
American Samoa: 2002: 95,366,789; 
American Samoa: 2003: 97,530,861; 
American Samoa: 2004: 113,960,653. 

Data: Total revenues; 
American Samoa: 2001: $182,216,205; 
American Samoa: 2002: $211,530,940; 
American Samoa: 2003: $197,937,045; 
American Samoa: 2004: 188,877,568. 

Data: Total expenditures; 
American Samoa: 2001: 182,410,239; 
American Samoa: 2002: 180,541,130; 
American Samoa: 2003: 170,748,872; 
American Samoa: 2004: 192,421,535. 

Data: Revenues less expenditures [surplus/(deficit)]; 
American Samoa: 2001: (194,034); 
American Samoa: 2002: 30,989,810; 
American Samoa: 2003: 27,188,173; 
American Samoa: 2004: (3,543,967). 

Data: Total net other financing[A]; 
American Samoa: 2001: 4,953,273; 
American Samoa: 2002: 734,881; 
American Samoa: 2003: 2,196,503; 
American Samoa: 2004: (2,371,449). 

Data: Special adjustment; 
American Samoa: 2001: [Empty]; 
American Samoa: 2002: [Empty]; 
American Samoa: 2003: (1,381,333)[B]; 
American Samoa: 2004: 505,552[B]. 

Data: Governmental funds beginning of year balanced; 
American Samoa: 2001: (23,141,403); 
American Samoa: 2002: (16,491,517)[C]; 
American Samoa: 2003: 15,233,174; 
American Samoa: 2004: 43,236,519. 

Data: Governmental funds end of year balance; 
American Samoa: 2001: (18,382,164); 
American Samoa: 2002: 15,233,174; 
American Samoa: 2003: 43,236,520; 
American Samoa: 2004: 37,826,655. 

Data: Net assets, end of year[E]; 
American Samoa: 2001: 74,580,312; 
American Samoa: 2002: 141,209,273; 
American Samoa: 2003: 200,835,235; 
American Samoa: 2004: 211,696,176. 

Data: Change in net assets; 
American Samoa: 2001: --; 
American Samoa: 2002: 66,628,961; 
American Samoa: 2003: 59,625,962; 
American Samoa: 2004: 10,860,941. 

Calculations: 

Data: Federal contributions as a percent of revenues; 
American Samoa: 2001: 49.2; 
American Samoa: 2002: 45.1; 
American Samoa: 2003: 49.3; 
American Samoa: 2004: 60.3. 

Data: Government revenue per capita; 
American Samoa: 2001: $3,167; 
American Samoa: 2002: $3,665; 
American Samoa: 2003: $3,422; 
American Samoa: 2004: $3,262. 

Data: Government expenditures per capita; 
American Samoa: 2001: 3,171; 
American Samoa: 2002: 3,128; 
American Samoa: 2003: 2,952; 
American Samoa: 2004: $3,323. 

Data: Government revenue as percent of GDP[F]; 
American Samoa: 2001: --; 
American Samoa: 2002: .38; 
American Samoa: 2003: --; 
American Samoa: 2004: --. 

Data: Government expenditures as percent of GDP; 
American Samoa: 2001: --; 
American Samoa: 2002: .32; 
American Samoa: 2003: --; 
American Samoa: 2004: --. 

Source: GAO analysis of Single Audit Reports covering Fiscal Years 
2001, 2002, 2003, and 2004; The estimate of GDP, in the amount of 
$558,755,669, came from Final Trip Report on Benchmark Estimates of 
2002 Gross Domestic Product in American Samoa, U.S. Census Bureau, Nov. 
29, 2005. 

[A] Other financing includes loan proceeds and transfers in and out 
from other funds. 

[B] Adjustments made to reflect changes in reserve for inventory. 

[C] The end of year fund balance for the prior fiscal year may not 
agree with the beginning of year fund balance for the succeeding fiscal 
year due to amounts being restated in subsequent financial statements. 
We could not readily identify explanations for these restatements 
because comparative information was not always available or disclosures 
were not made in subsequent financial statements. 

[D] Governmental funds finance most of the basic services provided by 
the government. 

[E] Net assets are capital assets and other assets, such as cash and 
receivables, less liabilities. 

[F] GDP estimates are not available for 2001, 2003, and 2004. 

[End of table] 

The financial data in table 4 were extracted from American Samoa's 
audited financial statements, which received qualified opinions from 
the outside auditors. Therefore, these figures are subject to the 
limitations cited by the auditors in their opinions and to the material 
internal control weaknesses identified. These limitations and other 
accountability issues are discussed in a separate section of this 
report. Also, restatements of the financial statements may occur, so 
the numbers shown in table 4 may be different in subsequently issued 
single audit reports. 

CNMI: 

CNMI's total government funds balance declined from a positive $3.5 
million at the beginning of 2001 to a deficit of $49.2 million by the 
end of 2004 as total government spending rose more rapidly than 
revenues, which, as shown in table 5, caused a decline in the 
government's total net assets over the period. CNMI is distinct among 
the four insular areas in that it has been stable in terms of revenue 
per capita, although spending per capita has fluctuated. Like USVI, it 
receives a significantly lower proportion of its revenues from the 
federal government than do American Samoa or Guam. 

Table 5: Fiscal Condition by Year--CNMI: 

Data: Population; 
Commonwealth of the Northern Mariana Islands: 2001: 71,868; 
Commonwealth of the Northern Mariana Islands: 2002: 74,003; 
Commonwealth of the Northern Mariana Islands: 2003: 76,129; 
Commonwealth of the Northern Mariana Islands: 2004: 78,252. 

Data: Own source revenue; 
Commonwealth of the Northern Mariana Islands: 2001: 227,709,651; 
Commonwealth of the Northern Mariana Islands: 2002: 215,650,986; 
Commonwealth of the Northern Mariana Islands: 2003: 225,412,808; 
Commonwealth of the Northern Mariana Islands: 2004: 235,754,891. 

Data: Federal contributions; 
Commonwealth of the Northern Mariana Islands: 2001: 49,348,134; 
Commonwealth of the Northern Mariana Islands: 2002: 71,964,627; 
Commonwealth of the Northern Mariana Islands: 2003: 57,560,034; 
Commonwealth of the Northern Mariana Islands: 2004: 63,006,595. 

Data: Total revenues; 
Commonwealth of the Northern Mariana Islands: 2001: $277,057,785; 
Commonwealth of the Northern Mariana Islands: 2002: $287,615,613; 
Commonwealth of the Northern Mariana Islands: 2003: $282,972,842; 
Commonwealth of the Northern Mariana Islands: 2004: $298,761,486. 

Data: Total expenditures; 
Commonwealth of the Northern Mariana Islands: 2001: 258,177,431; 
Commonwealth of the Northern Mariana Islands: 2002: 314,985,333; 
Commonwealth of the Northern Mariana Islands: 2003: 303,986,379; 
Commonwealth of the Northern Mariana Islands: 2004: 352,488,419. 

Data: Revenues less expenditures [surplus/(deficit)]; 
Commonwealth of the Northern Mariana Islands: 2001: 18,880,354; 
Commonwealth of the Northern Mariana Islands: 2002: (27,369,720); 
Commonwealth of the Northern Mariana Islands: 2003: (21,013,537); 
Commonwealth of the Northern Mariana Islands: 2004: (53,726,933). 

Data: Total net other financing[A]; 
Commonwealth of the Northern Mariana Islands: 2001: 6,511,003; 
Commonwealth of the Northern Mariana Islands: 2002: 3,510,667; 
Commonwealth of the Northern Mariana Islands: 2003: 0; 
Commonwealth of the Northern Mariana Islands: 2004: 39,493,350. 

Data: Governmental funds beginning year balance[C]; 
Commonwealth of the Northern Mariana Islands: 2001: 3,540,878; 
Commonwealth of the Northern Mariana Islands: 2002: 19,609,305[B]; 
Commonwealth of the Northern Mariana Islands: 2003: (4,249,748); 
Commonwealth of the Northern Mariana Islands: 2004: (35,011,807)[B]. 

Data: Governmental funds end of year balance; 
Commonwealth of the Northern Mariana Islands: 2001: 17,219,852; 
Commonwealth of the Northern Mariana Islands: 2002: (4,249,748); 
Commonwealth of the Northern Mariana Islands: 2003: (25,263,285); 
Commonwealth of the Northern Mariana Islands: 2004: (49,245,390). 

Data: Net assets, end of year[D]; 
Commonwealth of the Northern Mariana Islands: 2001: 40,575,181; 
Commonwealth of the Northern Mariana Islands: 2002: 30,760,955[E]; 
Commonwealth of the Northern Mariana Islands: 2003: 15,596,170; 
Commonwealth of the Northern Mariana Islands: 2004: (18,656,437). 

Data: Change in net assets; 
Commonwealth of the Northern Mariana Islands: 2001: --; 
Commonwealth of the Northern Mariana Islands: 2002: (9,814,226); 
Commonwealth of the Northern Mariana Islands: 2003: (15,164,785); 
Commonwealth of the Northern Mariana Islands: 2004: (34,252,607). 

Data: Calculations; 
Commonwealth of the Northern Mariana Islands: 2001: [Empty]; 
Commonwealth of the Northern Mariana Islands: 2002: [Empty]; 
Commonwealth of the Northern Mariana Islands: 2003: [Empty]; 
Commonwealth of the Northern Mariana Islands: 2004: [Empty]. 

Data: Federal contributions as a percent of revenues; 
Commonwealth of the Northern Mariana Islands: 2001: 17.8; 
Commonwealth of the Northern Mariana Islands: 2002: 25.0; 
Commonwealth of the Northern Mariana Islands: 2003: 20.3; 
Commonwealth of the Northern Mariana Islands: 2004: 21.1. 

Data: Government revenue per capita; 
Commonwealth of the Northern Mariana Islands: 2001: $3,855; 
Commonwealth of the Northern Mariana Islands: 2002: $3,887; 
Commonwealth of the Northern Mariana Islands: 2003: $3,717; 
Commonwealth of the Northern Mariana Islands: 2004: $3,818. 

Data: Government expenditures per capita; 
Commonwealth of the Northern Mariana Islands: 2001: 3,592; 
Commonwealth of the Northern Mariana Islands: 2002: 4,256; 
Commonwealth of the Northern Mariana Islands: 2003: 3,993; 
Commonwealth of the Northern Mariana Islands: 2004: 4.505. 

Data: Government revenue as percent of GDP[F]; 
Commonwealth of the Northern Mariana Islands: 2001: --; 
Commonwealth of the Northern Mariana Islands: 2002: .30; 
Commonwealth of the Northern Mariana Islands: 2003: --; 
Commonwealth of the Northern Mariana Islands: 2004: --. 

Data: Government expenditures as percent of GDP; 
Commonwealth of the Northern Mariana Islands: 2001: --; 
Commonwealth of the Northern Mariana Islands: 2002: .33; 
Commonwealth of the Northern Mariana Islands: 2003: --; 
Commonwealth of the Northern Mariana Islands: 2004: --. 

Source: GAO analysis of Single Audit Reports covering Fiscal Years 
2001, 2002, 2003, and 2004; The estimate of GDP, in the amount of 
$946,854,877, came from Final Trip Report on Benchmark Estimates of 
2002 Gross Domestic Product in the Commonwealth of the Northern Mariana 
Islands, U.S. Census Bureau, Feb. 11, 2005. 

[A] Other financing includes transfers in and out from other funds. 

[B] The end of year fund balance for the prior fiscal year may not 
agree with the beginning of year fund balance for the succeeding fiscal 
year due to amounts being restated in subsequent financial statements. 
We could not readily identify explanations for these restatements 
because comparative information was not always available or disclosures 
were not made in subsequent financial statements. 

[C] Governmental funds finance most of the basic services provided by 
the government. 

[D] Net assets are capital assets and other assets, such as cash and 
receivables, less liabilities. 

[E] Amount reported is the restated amount from 2003 Single Audit 
Report, corrected because of excluded and misstated amounts. 

[F] GDP estimates are not available for 2001, 2003, and 2004. 

[End of table] 

The financial data in table 5 were taken from the audited financial 
statements, which received qualified opinions from the outside 
auditors. Therefore, these figures are subject to the limitations cited 
by the auditors in their opinions and to the material internal control 
weaknesses identified. These limitations and other accountability 
issues are discussed in a separate section of this report. Also, 
restatements of the financial statements may occur, so the numbers 
shown in table 5 may be different in subsequently issued single audit 
reports. 

Guam: 

Guam's total government funds balance declined from a positive of $74.4 
million at the beginning of 2001 to a deficit of $198.7 million by the 
end of 2004 as total government spending rose more rapidly than 
revenues. Guam's reported net assets at fiscal year-end also fell from 
the amount shown in fiscal year 2001, as shown in table 6. (The 
substantial drop in net assets for fiscal year 2002 reflected a 
correction of previously misstated amounts.) During fiscal year 2004, 
net assets increased, after decreases in fiscal years 2002 and 2003. 
The federal government has contributed a smaller proportion of Guam's 
total revenues than it has for American Samoa, but larger proportions 
than for CNMI and USVI. 

Table 6: Fiscal Condition by Year--Guam: 

Data: Population; 
Guam: 2001: 158,330; 
Guam: 2002: 161,057; 
Guam: 2003: 163,593; 
Guam: 2004: 166,090. 

Data: Own source revenue; 
Guam: 2001: 478,700,351; 
Guam: 2002: 331,879,876; 
Guam: 2003: 441,437,973; 
Guam: 2004: 438,980,593. 

Data: Federal contributions; 
Guam: 2001: 138,623,945; 
Guam: 2002: 156,342,400; 
Guam: 2003: 216,567,613; 
Guam: 2004: 219,041,228. 

Data: Total revenues; 
Guam: 2001: $617,324,296; 
Guam: 2002: $488,222,276; 
Guam: 2003: $658,005,586; 
Guam: 2004: $658,021,821. 

Data: Total expenditures; 
Guam: 2001: 571,537,586; 
Guam: 2002: 604,745,053; 
Guam: 2003: 703,708,399; 
Guam: 2004: 685,336,581. 

Data: Revenues less expenditures [surplus/(deficit)]; 
Guam: 2001: 45,786,710; 
Guam: 2002: (116,522,777); 
Guam: 2003: (45,702,813); 
Guam: 2004: (27,314,760). 

Data: Total net other financing[A]; 
Guam: 2001: (42,753,202); 
Guam: 2002: (12,792,574); 
Guam: 2003: (1,736,294); 
Guam: 2004: (3,066,133). 

Data: Special adjustment; 
Guam: 2001: [Empty]; 
Guam: 2002: [Empty]; 
Guam: 2003: (50,000,000)[B]; 
Guam: 2004: 23,887,350b. 

Data: Governmental funds beginning of year balance[D]; 
Guam: 2001: 74,424,223; 
Guam: 2002: 78,493,488[C]; 
Guam: 2003: (94,284,682)[C]; 
Guam: 2004: (192,180,886). 

Data: Governmental funds end of year balance; 
Guam: 2001: 77,457,731; 
Guam: 2002: (50,821,863); 
Guam: 2003: (191,723,789); 
Guam: 2004: (198,674,429). 

Data: Net assets, end of year[E]; 
Guam: 2001: 386,002,829; 
Guam: 2002: 137,005,745[F]; 
Guam: 2003: 39,397,026; 
Guam: 2004: 88,491,287. 

Data: Change in net assets; 
Guam: 2001: --; 
Guam: 2002: (248,997,084); 
Guam: 2003: (97,608,719); 
Guam: 2004: 49,094,261. 

Calculations; 

Data: Federal contributions as a percent of revenues; 
Guam: 2001: 22.5; 
Guam: 2002: 32.0; 
Guam: 2003: 32.9; 
Guam: 2004: 33.3. 

Data: Government revenue per capita; 
Guam: 2001: $3,899; 
Guam: 2002: $3,031; 
Guam: 2003: $4,022; 
Guam: 2004: $3,962. 

Data: Government expenditures per capita; 
Guam: 2001: 3,610; 
Guam: 2002: 3,755; 
Guam: 2003: 4,302; 
Guam: 2004: 4,126. 

Data: Government revenue as percent of GDP[G]; 
Guam: 2001: --; 
Guam: 2002: .14; 
Guam: 2003: --; 
Guam: 2004: --. 

Data: Government expenditures as percent of GDP; 
Guam: 2001: --; 
Guam: 2002: .18; 
Guam: 2003: --; 
Guam: 2004: --. 

Source: GAO analysis of Single Audit Reports covering Fiscal Years 
2001, 2002, 2003, and 2004; The estimate of GDP, in the amount of 
$3,427,882,005, came from Final Trip Report on Benchmark Estimates of 
2002 Gross Domestic Product in Guam, U.S. Census Bureau, March 10, 
2005. 

[A] Other financing includes transfers in and out from other funds. 

[B] Special adjustments made for fiscal year 2003 to reflect earned 
income tax credit refunds and overprovisioning for tax refunds and gain 
from tax drawback settlement in fiscal year 2004. 

[C] The end of year fund balance for the prior fiscal year may not 
agree with the beginning of year fund balance for the succeeding fiscal 
year due to amounts being restated in subsequent financial statements. 
We could not readily identify explanations for these restatements 
because comparative information was not always available or disclosures 
were not made in subsequent financial statements. 

[D] Governmental funds finance most of the basic services provided by 
the government. 

[E] Net assets are capital assets and other assets, such as cash and 
receivables, less liabilities. 

[F] Amount reported is the restated amount from 2003 Single Audit 
Report, corrected because of excluded and misstated amounts. 

[G] GDP estimates are not available for 2001, 2003, and 2004. 

[End of table] 

The financial data in table 6 were taken from the audited financial 
statements, which received qualified opinions from the outside 
auditors. Therefore, these figures are subject to the limitations cited 
by the auditors in their opinions and to the material internal control 
weaknesses identified. These limitations and other accountability 
issues are discussed in a separate section of this report. Also, 
restatements of the financial statements may occur, so the numbers 
shown in table 6 may be different in subsequently issued single audit 
reports. For example, the figures shown for net assets as of the end of 
fiscal year 2004 and the change in net assets were restated in 
comparative information provided for fiscal year 2004 in Guam's fiscal 
year 2005 single audit report.[Footnote 55] 

USVI: 

USVI's balance of total government funds remained positive throughout 
the period and grew from $215.5 million at the beginning of 2001 to 
$463.7 million at the end of 2004. However, this growth was made 
possible only through increased government borrowing. Spending grew 
more rapidly than revenues during this period and exceeded revenues by 
$99.1 million in 2004. Although USVI's negative net assets figures 
appear to have improved over the period, the trend is due to the 
recording of assets not previously recorded. At the end of fiscal year 
2004, USVI still had a significant negative value for net government 
assets, as shown in table 7. 

Table 7: Fiscal Condition by Year--USVI: 

Data: Population; 
USVI: 2001: 108,749; 
USVI: 2002: 108,810; 
USVI: 2003: 108,814; 
USVI: 2004: 108,775. 

Data: Own source revenue; 
USVI: 2001: 628,466,000; 
USVI: 2002: 608,535,000; 
USVI: 2003: 653,573,000; 
USVI: 2004: 738,388,000. 

Data: Federal contributions; 
USVI: 2001: 146,137,000; 
USVI: 2002: 151,322,000; 
USVI: 2003: 163,859,000; 
USVI: 2004: 160,671,000. 

Data: Total revenues; 
USVI: 2001: $774,603,000; 
USVI: 2002: $759,857,000; 
USVI: 2003: $817,432,000; 
USVI: 2004: 899,059,000. 

Data: Total expenditures; 
USVI: 2001: 673,254,000; 
USVI: 2002: 865,733,000; 
USVI: 2003: 870,807,000; 
USVI: 2004: 998,122,000. 

Data: Revenues less expenditures [surplus/(deficit)]; 
USVI: 2001: 101,349,000; 
USVI: 2002: (105,876,000); 
USVI: 2003: (53,375,000); 
USVI: 2004: (99,063,000). 

Data: Total net other financing[A]; 
USVI: 2001: (63,579,000); 
USVI: 2002: 22,267,000; 
USVI: 2003: 120,982,000; 
USVI: 2004: 271,245,000. 

Data: Governmental funds beginning year balance[C]; 
USVI: 2001: 215,547,000; 
USVI: 2002: 307,532,000[B]; 
USVI: 2003: 223,923,000; 
USVI: 2004: 291,530,000. 

Data: Governmental funds end of year balance; 
USVI: 2001: 253,317,000; 
USVI: 2002: 223,923,000; 
USVI: 2003: 291,530,000; 
USVI: 2004: 463,712,000. 

Data: Net assets, end of year[D]; 
USVI: 2001: (394,436,000); 
USVI: 2002: (431,586,000); 
USVI: 2003: (300,083,000); 
USVI: 2004: (272,303,000). 

Data: Change in net assets; 
USVI: 2001: --; 
USVI: 2002: (37,150,000); 
USVI: 2003: 131,503,000; 
USVI: 2004: 27,780,000. 

Calculations; 

Data: Federal contributions as a percent of revenues; 
USVI: 2001: 18.9; 
USVI: 2002: 19.9; 
USVI: 2003: 20.0; 
USVI: 2004: 17.9. 

Data: Government revenue per capita; 
USVI: 2001: $7,123; 
USVI: 2002: $6,983; 
USVI: 2003: $7,512; 
USVI: 2004: $8,265. 

Data: Government expenditures per capita; 
USVI: 2001: 6,191; 
USVI: 2002: 7.956; 
USVI: 2003: 8,003; 
USVI: 2004: 9,176. 

Data: Government revenue as percent of GDP[E]; 
USVI: 2001: --; 
USVI: 2002: .27; 
USVI: 2003: --; 
USVI: 2004: --. 

Data: Government expenditures as percent of GDP; 
USVI: 2001: --; 
USVI: 2002: .31; 
USVI: 2003: --; 
USVI: 2004: --. 

Source: GAO analysis of Single Audit Reports covering Fiscal Years 
2001, 2002, 2003, and 2004; The estimate of GDP, in the amount of 
$2,809,187,000, came from Final Trip Report on Benchmark Estimates of 
2002 Gross Domestic Product in the U.S. Virgin Islands, U.S. Census 
Bureau, June 1, 2005. 

[A] Other financing includes: bond anticipation note issued, bonds 
issued, premium on bonds issued, and transfers in and out from other 
funds. 

[B] The end of year fund balance for the prior fiscal year may not 
agree with the beginning of year fund balance for the succeeding fiscal 
year due to amounts being restated in subsequent financial statements. 
We could not readily identify explanations for these restatements 
because comparative information was not always available or disclosures 
were not made in subsequent financial statements. 

[C] Governmental funds finance most of the basic services provided by 
the government. 

[D] Net assets are capital assets and other assets, such as cash and 
receivables, less liabilities. 

[E] GDP estimates are not available for 2001, 2003, and 2004. 

[End of table] 

The financial data in table 7 were taken from the audited financial 
statements, which received qualified opinions from the outside 
auditors. Therefore, these figures are subject to the limitations cited 
by the auditors in their opinions and to the material internal control 
weaknesses identified. These limitations and other accountability 
issues are discussed in a separate section of this report. Also, 
restatements of the financial statements may occur, so the numbers 
shown in table 7 may be different in subsequently issued single audit 
reports. 

Financial Accountability Remains Weak in the U.S. Insular Areas: 

The governments of the four U.S. insular areas have had long-standing 
financial accountability problems, including the late issuance of the 
reports required by the Single Audit Act, inability to achieve 
unqualified ("clean") audit opinions on their financial statements, and 
numerous material weaknesses in internal controls over financial 
operations and compliance with laws and regulations governing federal 
grant awards. The findings in the single audit reports clearly point 
out that the insular area governments have lacked effective internal 
controls to provide reasonable assurance that transactions are properly 
recorded; assets are safeguarded from fraud, waste, abuse, and 
mismanagement; and federal funds are being expended in accordance with 
grant requirements. As a result, there has been limited accountability 
over the use of federal funds. Multiple agencies oversee the insular 
areas' efforts to improve their financial accountability and several 
federal agencies have designated the insular areas as high-risk under 
the Grants Management Common Rule.[Footnote 56] Under the rule, federal 
grant awarding agencies may designate a grantee as high-risk if the 
grantee has a history of unsatisfactory performance, is not financially 
stable, has an inadequate management system, has not conformed to the 
terms and conditions of previous awards, or is otherwise not properly 
managing federal funds. OIA and DOI's IG, other federal inspectors 
general, and local auditing authorities provide oversight and 
assistance to the insular area governments. 

Single Audit Reports for Fiscal Years 2001-2004 Were Not Issued on 
Time: 

For fiscal years 1997 through 2004, the insular areas did not submit 
their single audit reports to the FAC by the due date, which is 
generally no later than 9 months after the fiscal year end.[Footnote 
57] As shown in table 8, American Samoa and Guam have improved on the 
timeliness of their audit reports since 1997. Although they were still 
unable to submit their single audit reports on time for fiscal year 
2004, the last year of the review period for all four areas, American 
Samoa and Guam both submitted their fiscal year 2005 single audit 
reports to the FAC by the June 30, 2006, due date. The timeliness of 
CNMI[Footnote 58] and USVI governments' single audit submissions did 
not improve for fiscal years 1997 through 2004. However, CNMI submitted 
its fiscal year 2005 single audit report to the FAC less than 1 month 
late. As of September 27, 2006, the USVI government had not submitted 
its fiscal year 2005 single audit report to the FAC. 

Table 8: Single Audit Act Report Submissions, Fiscal Years 1997 through 
2004: 

Fiscal year-end: 09/30/1997; 
Number of months late[A]: American Samoa[B]: 71; 
Number of months late[A]: CNMI[B]: 14; 
Number of months late[A]: Guam[B]: 13; 
Number of months late[A]: USVI: Not applicable[C]. 

Fiscal year-end: 09/30/1998; 
Number of months late[A]: American Samoa[B]: 51; 
Number of months late[A]: CNMI[B]: 2; 
Number of months late[A]: Guam[B]: 2; 
Number of months late[A]: USVI: 13. 

Fiscal year-end: 09/30/1999; 
Number of months late[A]: American Samoa[B]: 43; 
Number of months late[A]: CNMI[B]: 4; 
Number of months late[A]: Guam[B]: 6; 
Number of months late[A]: USVI: 13. 

Fiscal year-end: 09/30/2000; 
Number of months late[A]: American Samoa[B]: 31; 
Number of months late[A]: CNMI[B]: 16; 
Number of months late[A]: Guam[B]: 8; 
Number of months late[A]: USVI: 8. 

Fiscal year-end: 09/30/2001; 
Number of months late[A]: American Samoa[B]: 25; 
Number of months late[A]: CNMI[B]: 11; 
Number of months late[A]: Guam[B]: 9; 
Number of months late[A]: USVI: 6. 

Fiscal year-end: 09/30/2002; 
Number of months late[A]: American Samoa[B]: 23; 
Number of months late[A]: CNMI[B]: 13; 
Number of months late[A]: Guam[B]: 1; 
Number of months late[A]: USVI: 12. 

Fiscal year-end: 09/30/2003; 
Number of months late[A]: American Samoa[B]: 14; 
Number of months late[A]: CNMI[B]: 12; 
Number of months late[A]: Guam[B]: 5; 
Number of months late[A]: USVI: 11. 

Fiscal year-end: 09/30/2004; 
Number of months late[A]: American Samoa[B]: 8; 
Number of months late[A]: CNMI[B]: 22; 
Number of months late[A]: Guam[B]: 1; 
Number of months late[A]: USVI: 12. 

Source: Single Audit Act, Federal Audit Clearinghouse, and GAO 
analysis. 

[A] Calculated based on the submission form date. The numbers of months 
late were computed without regard to extensions granted to the insular 
area governments or the August 2002 memorandum of agreement between OIA 
and American Samoa. 

[B] The Form Dates for submission of the fiscal year 2005 single audit 
reports were June 30, 2006, for American Samoa and Guam, and July 19, 
2006, for CNMI. 

[C] For fiscal year 1997, USVI contracted for certain agreed-upon 
procedures in lieu of the required single audit. 

[End of table] 

Single audits are a key control for the oversight and monitoring of the 
insular area governments' use of federal awards. The late submission of 
single audit reports means that federal government agencies have 
information on the insular area governments' accountability over 
federal funds that is not up to date and whose usefulness is therefore 
limited. 

Audit Opinions on Financial Statements and Compliance Were Disclaimed 
or Qualified: 

Auditors are required by OMB Circular No. A-133 to provide opinions (or 
disclaimers of opinion, as appropriate) as to whether the (1) financial 
statements are presented fairly in all material respects in conformity 
with generally accepted accounting principles (GAAP)[Footnote 59] and 
(2) auditee complied with laws, regulations, and the provisions of 
contracts or grant agreements which could have a direct and material 
effect on each major federal program. 

When reporting on the fairness of the presentation of financial 
statements, auditors can issue an unqualified opinion, a qualified 
opinion, an adverse opinion, or a disclaimer of opinion. Auditors 
express an unqualified ("clean") opinion on financial statements when 
they have determined, based on sufficient review work, that the 
financial statements are presented fairly in all material respects, in 
accordance with GAAP.[Footnote 60] Auditors render a qualified opinion 
when they identify one or more specific matters that impact the fair 
presentation of the financial statements. The effect of a specific 
matter on the auditors' qualified opinion can be significant enough to 
reduce the usefulness of the financial statements. Adverse opinions are 
expressed on financial statements when the auditors have sufficiently 
definitive data to conclude that the financial statements are not 
fairly presented in conformity with GAAP. A disclaimer of opinion 
states that the auditor does not express an opinion on the financial 
statements. Auditors may decline to express an opinion due to scope or 
data limitations when they are unable to conclude about the fairness of 
the financial statements in conformity with GAAP. 

In accordance with OMB Circular No. A-133, auditors are required to 
determine and express an opinion as to whether the auditee has complied 
with laws, regulations, and the provisions of contracts or grant 
agreements that may have a direct and material effect on each of its 
major federal programs. Auditors are to identify the applicable 
compliance requirements to be tested and reported on in a single audit. 
OMB's Compliance Supplement lists and describes the 14 types of 
compliance requirements and related audit objectives and suggested 
audit procedures that auditors should consider in single audits 
conducted in accordance with OMB Circular No. A-133.[Footnote 61] 

Opinions on the Insular Areas' Financial Statements: 

The four insular area governments have been unable to achieve 
unqualified ("clean") audit opinions on their financial statements, 
receiving either disclaimers or qualified opinions on the financial 
statements issued for fiscal years 1997 through 2004 as shown in table 
9. 

Table 9: Financial Statement Audit Opinions for Fiscal Years 1997 
through 2004: 

Fiscal year: 1997; 
Type of opinion: American Samoa: Disclaimer; 
Type of opinion: CNMI: Qualified; 
Type of opinion: Guam: Qualified; 
Type of opinion: USVI: Not applicable[A]. 

Fiscal year: 1998; 
Type of opinion: American Samoa: Disclaimer; 
Type of opinion: CNMI: Qualified; 
Type of opinion: Guam: Qualified; 
Type of opinion: USVI: Qualified. 

Fiscal year: 1999; 
Type of opinion: American Samoa: Disclaimer; 
Type of opinion: CNMI: Qualified; 
Type of opinion: Guam: Qualified; 
Type of opinion: USVI: Qualified. 

Fiscal year: 2000; 
Type of opinion: American Samoa: Disclaimer; 
Type of opinion: CNMI: Qualified; 
Type of opinion: Guam: Qualified; 
Type of opinion: USVI: Qualified. 

Fiscal year: 2001; 
Type of opinion: American Samoa: Qualified; 
Type of opinion: CNMI: Qualified; 
Type of opinion: Guam: Qualified; 
Type of opinion: USVI: Qualified. 

Fiscal year: 2002; 
Type of opinion: American Samoa: Qualified; 
Type of opinion: CNMI: Qualified; 
Type of opinion: Guam: Qualified; 
Type of opinion: USVI: Qualified. 

Fiscal year: 2003; 
Type of opinion: American Samoa: Qualified; 
Type of opinion: CNMI: Qualified; 
Type of opinion: Guam: Qualified; 
Type of opinion: USVI: Qualified[B] Disclaimer. 

Fiscal year: 2004; 
Type of opinion: American Samoa: Qualified; 
Type of opinion: CNMI: Qualified; 
Type of opinion: Guam: Qualified; 
Type of opinion: USVI: Qualified[B] Disclaimer. 

Source: SF-FAC forms and single audit reports for the insular areas 
from the FAC database. 

Note: American Samoa, CNMI, and Guam have submitted their fiscal year 
2005 single audit reports and all three received qualified opinions on 
their financial statements. 

[A] For fiscal year 1997, USVI contracted certain agreed-upon 
procedures in lieu of the required single audit. 

[B] Auditors are permitted to express multiple opinions in a single 
audit; opinions are rendered based on opinion units. Generally, the 
opinion units in a government's basic financial statements include the 
governmental activities, business-type activities, aggregate discretely 
presented component units, and the major governmental and enterprise 
funds. For fiscal year 2003, the USVI government received unqualified 
opinions on its Public Financing Authority debt service fund and West 
Indian Company enterprise fund; qualified opinions on its governmental 
activities, discretely presented component units, general fund, 
unemployment insurance enterprise fund, and aggregate remaining fund 
information; and a disclaimer on its business-type activities. The 
opinions rendered on USVI's fiscal year 2004 financial statements were 
the same as in fiscal year 2003 with the addition of an unqualified 
opinion on the Public Financing Authority capital projects fund. 

[End of table] 

American Samoa has made progress in reducing the number of matters that 
caused the auditors to render qualified opinions on the financial 
statements, but, for fiscal year 2004, the auditors could not obtain 
sufficient information about the following items in the American Samoan 
primary government:[Footnote 62] (1) the amount of funds owed to or 
from the other funds--pooled cash;[Footnote 63] (2) the physical 
inventory records; and (3) the accuracy of the beginning fund balances. 
The auditors also could not obtain the information needed to attest to 
the fairness of the information presented for the discretely presented 
component units.[Footnote 64] Specifically, the auditors could not 
obtain the information needed concerning (1) the cost of property, 
plant, and equipment in accordance with U.S. generally accepted 
accounting principles and the operating revenues of the American Samoa 
Telecommunication Authority and (2) the financial position and activity 
of the American Samoa Medical Center Authority - Lyndon B. Johnson 
Tropical Medical Center. 

CNMI has also made progress in addressing the matters that resulted in 
the qualified opinions on its financial statements for fiscal years 
2001 through 2003. However, the auditors identified the following 
issues in fiscal year 2004 as matters leading to the qualified audit 
opinion: (1) inadequacies in the accounting records regarding taxes 
receivable and receivables from agencies, advances, accounts payable, 
tax rebates payable, other liabilities and accruals, amounts owed to 
component units, and the reserve for continuing appropriations and (2) 
inadequacies in accounting records and internal controls regarding the 
capital assets of the Northern Marianas College, and in accounting 
records and internal controls in inventory, federal agencies 
receivables, utility plant, accounts payable, and obligations under 
capital lease of the Commonwealth Utilities Corporation. 

Guam has made progress in reducing the number of matters associated 
with the auditors' qualified opinions rendered on the government's 
financial statements for fiscal years 2001 through 2004. The auditors 
cited the following matters associated with its qualified opinion for 
fiscal year 2004: (1) inability to access tax-related balances, (2) 
lack of audited financial statements for Guam Memorial Hospital 
Authority, and (3) lack of audited financial statements for the Guam 
Visitors Bureau. 

Although USVI has made progress in addressing some of the matters that 
were previously cited as leading to the auditors' qualified opinions, 
the auditors have identified new matters for fiscal year 2004. The 
auditor's qualified opinion on the general fund, governmental 
activities, and discretely presented component units was due to the 
following: (1) lack of accounting records for corporate income tax 
receivables for tax year 2002 in the general fund and governmental 
activities, (2) failure to record a provision for landfill closure and 
postclosure costs in governmental activities, and (3) inability to 
determine whether capital assets and land held for sale by the Virgin 
Islands Housing Authority (VIHA) and the Virgin Islands Housing Finance 
Authority (VIHFA) were fairly stated. The auditors issued a disclaimer 
on the USVI government's business-type activities because (1) the 
financial statements as of September 30, 2003, did not include a 
receivable for unemployment insurance contributions due to inadequate 
records;[Footnote 65] and (2) liability for Workers' Compensation 
claims was not included. 

Opinions on Insular Areas' Compliance with Requirements for Major 
Federal Programs: 

Auditors for the four insular areas rendered qualified opinions, 
disclaimers, or adverse opinions on the insular area governments' 
compliance with the requirements for each major federal award program. 
When auditors identify instances of noncompliance, they are required to 
report whether the noncompliance could have a direct and material 
effect on a major federal program.[Footnote 66] The audit opinions 
rendered on the insular area governments' compliance with the 
requirements for major federal programs for the fiscal years under 
review are shown in table 10. 

Table 10: Opinions Rendered on Compliance with Requirements for Major 
Federal Programs for Fiscal Years 1997 through 2004: 

Fiscal year: 1997; 
Type of opinion: American Samoa: Disclaimer; 
Type of opinion: CNMI: Qualified; 
Type of opinion: Guam: Qualified; 
Type of opinion: USVI: Not applicable[A]. 

Fiscal year: 1998; 
Type of opinion: American Samoa: Disclaimer; 
Type of opinion: CNMI: Qualified; 
Type of opinion: Guam: Qualified; 
Type of opinion: USVI: Not provided. 

Fiscal year: 1999; 
Type of opinion: American Samoa: Disclaimer; 
Type of opinion: CNMI: Qualified; 
Type of opinion: Guam: Qualified; 
Type of opinion: USVI: Qualified. 

Fiscal year: 2000; 
Type of opinion: American Samoa: Disclaimer; 
Type of opinion: CNMI: Qualified; 
Type of opinion: Guam: Qualified; 
Type of opinion: USVI: Unqualified. 

Fiscal year: 2001; 
Type of opinion: American Samoa: Disclaimer; 
Type of opinion: CNMI: Qualified; 
Type of opinion: Guam: Qualified; 
Type of opinion: USVI: Qualified. 

Fiscal year: 2002; 
Type of opinion: American Samoa: Disclaimer; 
Type of opinion: CNMI: Qualified; 
Type of opinion: Guam: Qualified; 
Type of opinion: USVI: Qualified Adverse[B]. 

Fiscal year: 2003; 
Type of opinion: American Samoa: Disclaimer; 
Type of opinion: CNMI: Qualified; 
Type of opinion: Guam: Qualified; 
Type of opinion: USVI: Qualified Adverse. 

Fiscal year: 2004; 
Type of opinion: American Samoa: Disclaimer; 
Type of opinion: CNMI: Qualified; 
Type of opinion: Guam: Qualified; 
Type of opinion: USVI: Unqualified Qualified Adverse. 

Source: SF-FACs and single audit reports from the Federal Audit 
Clearinghouse database. 

[A] For fiscal year 1997, USVI contracted for certain agreed-upon 
procedures to be done in lieu of the required single audit. 

[B] For fiscal years 2002, 2003, and 2004, auditors for the USVI 
government issued adverse opinions on compliance with requirements for 
some programs,while rendering qualified opinions for the reports as a 
whole. An adverse opinion, in this context, means that the USVI 
government did not comply in all material respects with the compliance 
requirements described in OMB Circular No. A-133. 

[End of table] 

Number and Significance of Reported Internal Control Weaknesses 
Indicate Inadequate Internal Control over Financial Reporting and 
Inadequate Compliance with Requirements for Major Federal Programs: 

The large number and the significance of reported internal control 
weaknesses raise serious questions about the integrity and reliability 
of the insular area governments' financial statements and their 
compliance with requirements of major federal programs. The auditors, 
in their reports on internal control over financial reporting and on 
compliance with federal requirements for major federal programs, 
disclosed many internal control weaknesses. 

Material Weaknesses and Reportable Conditions in Internal Control over 
Financial Reporting: 

The insular area governments' 29 reported internal control material 
weaknesses and reportable conditions for fiscal year 2004 indicate a 
lack of sound internal control over financial reporting needed to 
provide adequate assurance that transactions are properly recorded, 
assets are properly safeguarded, and controls are adequate to prevent 
or detect fraud, waste, abuse, and mismanagement. Reportable conditions 
over financial reporting are matters that come to an auditors' 
attention related to significant deficiencies in the design or 
operation of internal controls that could adversely affect the entity's 
ability to produce financial statements that fairly represent the 
entity's financial condition. Material weaknesses in financial 
reporting are reportable conditions in which the design or operation of 
internal controls does not reduce to a relatively low level the risk 
that misstatements caused by error or fraud--material in relation to 
the financial statements being audited--may occur and not be detected 
in a timely period by employees in the normal course of performing 
their duties. Table 11 shows the number of material weaknesses and 
reportable conditions for each of the four insular areas, for fiscal 
year 2004. 

Table 11: Reported Weaknesses in Internal Control over Financial 
Reporting Identified in the Auditors' Reports for Fiscal Year 2004: 

Internal control over financial reporting: Material weaknesses; 
American Samoa: 6; 
CNMI: 8; 
Guam: 4; 
USVI: 3; 
Total: 21. 

Internal control over financial reporting: Reportable conditions; 
American Samoa: 0; 
CNMI: 5; 
Guam: 3; 
USVI: 0; 
Total: 8. 

Internal control over financial reporting: Total reported weaknesses; 
American Samoa: 6; 
CNMI: 13; 
Guam: 7; 
USVI: 3; 
Total: 29. 

Source: Single audit reports for the four insular areas for fiscal year 
2004. 

[End of table] 

The reported internal control weaknesses revealed serious deficiencies 
in internal controls over financial reporting. For example, auditors 
for the American Samoa government reported for fiscal years 2001 
through 2004 that accountants and clerks doing the general accounting 
were not adequately trained and supervised. The auditors also reported 
that account reconciliations, journal entries, and other basic 
transactions were not adequately performed and summarized, a material 
weakness that casts doubt on the integrity and reliability of the 
financial information presented in the single audit report. Another 
internal control weakness reported by the auditors was that the 
government records had not been maintained in an organized manner due 
to a lack of formal procedures for the maintenance and storage of 
records. Due to this material internal control weakness, documentation 
may be misplaced, lost, or destroyed without being detected. 

One of the internal control weaknesses that the auditors reported for 
CNMI's government for fiscal year 2004 involved liabilities recorded in 
the General Fund. Due to the lack of detailed subsidiary ledgers, the 
auditors could not determine the propriety of these account balances, 
and whether the negative balances in the accounts, as in prior years, 
also included prepaid items. The recording of prepaid items as 
expenditures will cause expenditures to be overstated and the related 
liabilities to be understated. One of the control activities[Footnote 
67] mentioned in GAO's Standards for Internal Control in the Federal 
Government[Footnote 68] is accurate and timely recording of 
transactions and events. This control activity is applicable to the 
entire process or life cycle of a transaction or event from the 
initiation and authorization of a transaction through its final 
classification in summary records. CNMI's auditors also reported as an 
internal control weakness, in at least two of its single audit reports, 
a Commonwealth Health Center (CHC) receivable balance that represented 
accounts outstanding in excess of 120 days due to inadequate billing 
and collection procedures. According to the auditors, the effect of 
this weakness was a possible misstatement of CHC's receivable balances, 
partially mitigated by a corresponding uncollectible account balance of 
the same amount. The auditors recommended that the uncollectible 
accounts be written off, and that the CHC implement procedures for 
processing all billings on a timely basis and for following up on aged 
accounts. 

In Guam, the lack of required physical inventories of government 
equipment and the lack of uniform maintenance procedures to keep 
equipment in good condition were cited as material weaknesses by 
auditors for fiscal years 2003 and 2004. The auditors also stated that 
the government of Guam did not perform a comprehensive inventory of its 
capital assets, including infrastructure.[Footnote 69] According to 
Guam's single audit report for fiscal year 2004, the government was 
working to tag all of its equipment with bar code property 
identification labels so that it would be able to conduct a physical 
inventory. Another internal control weakness was reported in the 
accounts payable-trade account: accounts payable that had aged 2 or 
more years remained in the accounts payable listing while more current 
balances were liquidated. Moreover, the auditors reported that all nine 
of the general ledger liability accounts tested included invalid 
accruals. The auditors attributed these problems--which could result in 
a potential misstatement of accounts payable--to poor internal control 
over the filing of supporting documentation of recorded transactions. 
Unreconciled differences in the combined cash balances for some 
governmental funds for fiscal year 2004 were reported by the auditors. 
The auditors attributed these differences to the lack of timeliness of 
the performance of bank reconciliations, which does not appear to have 
been monitored--the effect being a misstatement of cash balances. GAO's 
Standards for Internal Control in the Federal Government highlights 
reconciliation as a key control activity. 

Auditors for USVI reported that the reconciliations of all USVI 
government bank accounts as of September 30, 2003 (fiscal 2003 year- 
end) were not completed until June 2004. The auditors stated that 
performing timely and accurate reconciliation of bank accounts is a key 
control over cash receipts and disbursements, and that the lack of 
timely reconciliation of all bank accounts may result in errors or 
irregularities in cash transactions to not be promptly detected. USVI's 
auditors attributed the failure to prepare timely bank reconciliations 
to a lack of established procedures. Auditors also reported this 
material weakness in the single audit report for fiscal year 2004 for 
USVI and stated that the reconciliations of all USVI government bank 
accounts as of September 30, 2004, were not completed until July and 
August of 2005. Auditors also found weaknesses in the government's 
ability to quantify and record certain key financial activity, such as 
a workers' compensation claims liability, due to the lack of complete 
and accurate financial data. During 2004, as in previous years, the 
government experienced delays in its year-end closing process and in 
the preparation of complete and accurate financial statements in 
accordance with GAAP. In numerous year-end closing entries that, in 
some instances, represented corrections to routine transactions that 
occurred throughout the year, auditors found their nature, timing, and 
extent indicative of weaknesses in controls over financial reporting. 

Material Weaknesses and Reportable Conditions in Compliance with 
Requirements for Major Federal Programs: 

Auditors reported material weaknesses and reportable conditions in the 
insular area governments' compliance with requirements for major 
federal programs and the internal controls intended to ensure 
compliance with these requirements. In the context of compliance, 
reportable conditions are matters that come to an auditor's attention 
related to significant deficiencies in the design or operation of 
internal controls over compliance that could adversely affect the 
entity's ability to operate a major federal program within the 
applicable requirements of laws, regulations, contracts, and grants. 
Material weaknesses in this context are reportable conditions in which 
internal controls do not reduce to a relatively low level the risk of 
noncompliance with applicable requirements of laws, regulations, 
contracts, and grants that would be material to the major federal 
program being audited and undetected in a timely way by employees in 
the normal course of performing their duties. 

Table 12: Material Weaknesses and Reportable Conditions Relating to 
Compliance with Requirements for Major Federal Programs for Fiscal Year 
2004: 

Internal control over compliance with major-program requirements: 
Material weaknesses; 
American Samoa: 9; 
CNMI: 2; 
Guam: 8; 
USVI: 28; 
Totals: 47. 

Internal control over compliance with major-program requirements: 
Reportable conditions; 
American Samoa: 13; 
CNMI: 31; 
Guam: 17; 
USVI: 3; 
Totals: 64. 

Internal control over compliance with major-program requirements: Total 
findings; 
American Samoa: 22; 
CNMI: 33; 
Guam: 25; 
USVI: 31; 
Totals: 111. 

Source: Single audit reports for the four insular areas for fiscal year 
2004. 

[End of table] 

American Samoa: 

As shown in table 12, auditors reported nine material weaknesses in 
compliance with requirements for major federal programs for the 
American Samoa government for fiscal year 2004. One of these weaknesses 
involved a receiving report that showed that an item purchased with 
2004 grant funds was not received until August 31, 2005, the end of the 
2005 grant year. The effect of this delay was that the government 
received and expended from the 2004 grant, but did not complete the 
transaction and receive the goods from the vendor until 1 year later. 
The auditors attributed this weakness to the vendor's requirement of 
advance payment for this purchase and lack of follow up to determine 
whether the goods that had been paid for had been delivered. For fiscal 
year 2004, another reported internal control weakness in compliance 
with requirements for major federal programs involved delays in the 
completion of the single audit, which did not occur within 9 months of 
the fiscal year end, as required by the Single Audit Act. The auditors 
stated that the cause of the missed single audit due date was (1) a 
failure of the accounting system and (2) the lack of trained, 
qualified, and competent personnel. These two factors resulted in a 
delay in closing the accounting records. 

CNMI: 

One of the two internal control weaknesses affecting compliance with 
major federal programs reported for CNMI's government for fiscal year 
2004 was the failure to record expenditures for the Medical Assistance 
Program when they were incurred. In one instance, the auditor 
identified expenditures for billings from service providers for 
services rendered in previous years. The auditors attributed this 
weakness to the lack of policies and procedures regarding the timely 
recognition of expenditures at the time services are rendered. The 
effect of this weakness is that expenditures reported to the grantor 
agency, the U.S. Department of Health and Human Services (HHS), are 
based on the paid date and not, as required, the service date. In 
addition, actual expenditures incurred during the year are not properly 
accrued and therefore, current year expenditures and unrecorded 
liabilities are understated. The other internal control weakness 
related to the lack of adherence to established policies and procedures 
regarding physical inventory counts of property and equipment and the 
lack of reconciliation between the Division of Procurement and Supply's 
(P&S) master listing and the listings of several CNMI divisions and 
offices. For example, CNMI's Emergency Management Office (EMO) provided 
a list of equipment acquired with Office of Domestic Preparedness 
grants, but the listing did not include the serial number or other 
identification of the equipment or its condition. Moreover, a physical 
inventory was not conducted in the past 2 years by either the EMO or 
P&S. As a result, CNMI's government was not in compliance with federal 
property standards and its own property management policies and 
procedures. 

Guam: 

In prior-year single audits and the fiscal year 2004 report, Guam's 
auditors stated that the government was in noncompliance with 
applicable procurement requirements. The auditor noted, in the fiscal 
year 2004 report, that there was insufficient documentation on file 
supporting the procurement for four of seven transactions tested 
related to a DOL grant. For two additional transactions, Guam's Chief 
Procurement Officer determined that the lease of space from a vendor 
was an unauthorized procurement because the lease agreement had 
expired. The method of procurement, selection of contract type, 
contractor selection or rejection, and the basis for the contract price 
are to be included in the procurement records, according to applicable 
procurement requirements. The auditor attributed this weakness to a 
lack of internal control over compliance with applicable procurement 
requirements. Noncompliance with applicable procurement requirements 
was also noted for transactions related to U.S. Environmental 
Protection Agency and HHS grants. The auditors also reported that the 
government of Guam may have been noncompliant with earmarking 
requirements associated with an HHS block grant for maternal and child 
health services. According to federal law, 30 percent of the total 
grant payments must be used for preventive and primary care services 
for children, 30 percent must be used for services for children with 
special health care needs, and not more than 10 percent of the allotted 
funds can be used by a grantee for administrative expenses. The 
government of Guam did not provide the auditors with documents that 
demonstrated compliance with these requirements for its 2004 Maternal 
and Child Health Services Block Grant. The auditors reported that they 
could not determine whether the government of Guam was in compliance 
with these earmarking requirements due to weak internal control over 
recordkeeping. 

USVI: 

Auditors reported that for fiscal years 2003 and 2004, the USVI 
government failed to provide accurate, current, and complete disclosure 
of financially assisted activities as required by U.S. Department of 
Agriculture (USDA) grants. In one instance, auditors found that 
financial reports prepared by the USVI Department of Health for the 
Women, Infants, and Children (WIC) Program did not reconcile with the 
USVI government's financial management system (FMS). The auditors 
identified the cause of this weakness to be due to current procedures, 
which do not require a reconciliation of WIC Program records with the 
FMS. This lack of reconciliation could result in incorrectly posted 
transactions going undetected and uncorrected and therefore also 
incorrect financial information being reported to USDA. The lack of 
reconciliation between the government's records and its FMS was also 
noted as a weakness related to a DOL grant for unemployment insurance. 
In its fiscal year 2004 single audit report, the auditors noted that 
the USVI Department of Education did not fully comply with 12 of the 18 
requirements for the second year of the compliance agreement with the 
U.S. Department of Education. For example, the auditors reported that 
the inventory management system, which was to be fully implemented by 
December 31, 2004, was not implemented by that date. According to the 
auditors, failure to fully comply with the compliance agreement by the 
specified deadlines was due to a lack of the necessary resources. 

High-Risk Designations and Receiverships: 

The late submission of single audit reports combined with ongoing, 
significant audit findings, have been key reasons for the designation 
of the insular area governments as high-risk grantees by several 
federal agencies. Under the Grants Management Common Rule, federal 
awarding agencies may designate a grantee as high-risk if the grantee 
has a history of unsatisfactory performance, is not financially stable, 
has an inadequate management system, has not conformed to the terms and 
conditions of previous awards, or is otherwise not properly managing 
federal funds. Federal agencies that designate a grantee as high-risk 
may impose special conditions including (1) issuing funds on a 
reimbursement basis; (2) withholding authority to proceed to the next 
phase until receipt of evidence of acceptable performance within a 
given funding period; (3) requiring additional, more detailed financial 
reports; (4) requiring the grantee to obtain technical or management 
assistance; or (5) establishing additional prior approvals for 
expenditures of federal funds. Agencies, in carrying out their 
regulations associated with the Grants Management Common Rule, can 
place special conditions either at the agencywide level or at the 
individual program level. 

American Samoa: 

OIA designated the government of American Samoa as a high-risk grantee 
in June 2005, as GAO had recommended in its report on American Samoa's 
accountability for key federal grants.[Footnote 70] In making this 
designation, OIA recognized that the government of American Samoa had 
made significant progress in improving its financial accountability, 
and stated that the high-risk designation was to encourage other 
federal agencies to support American Samoa's fiscal reform process. OIA 
placed several special conditions on the American Samoan government, 
including the completion of single audits by the statutory deadline and 
having balanced budgets for 2 consecutive years--without considering 
nonrecurring windfalls such as insurance settlements. 

The American Samoa government or its agencies have also been designated 
as high-risk by the departments or components of USDA, Education, HHS, 
and the U.S. Department of Transportation (DOT). USDA's Food and 
Nutrition Service (FNS) has also designated American Samoa as a high- 
risk grantee. According to a USDA official, GAO's prior recommendation 
that DOI designate American Samoa as a high-risk grantee influenced the 
FNS decision in February 2006 to designate American Samoa as a high- 
risk grantee for three of its programs. Some of the reasons cited by 
FNS officials for the high-risk designation include delinquent audits, 
noncompliance with laws and regulations, failure to resolve audit 
findings or to follow up on review findings, incurring unallowable or 
questionable costs, and weak systems for monitoring the programs and 
managing program data. In a letter to the Governor of American Samoa, 
FNS officials also stated that they were concerned that other serious 
problems might exist but had not been identified due to weaknesses and 
inadequate controls described in the letter. FNS officials further 
stated that the additional requirements associated with a high-risk 
designation would help to determine whether other serious but 
unidentified problems exist. 

While the U.S. Department of Education initially designated American 
Samoa as a high-risk grantee in 2003 due to the lack of timely and 
complete single audits, American Samoa has now submitted its single 
audits through fiscal year 2005. The American Samoan government remains 
a high-risk grantee for the U.S. Department of Education due to 
continuing concerns about weaknesses and internal control issues 
identified in the single audits. One of HHS's operating divisions, the 
Substance Abuse and Mental Health Services Administration (SAMHSA), 
designated American Samoa as a high-risk grantee due to the 
government's delinquent single audits.[Footnote 71] The insular area 
remains a high-risk grantee of SAMHSA, due to several older audits that 
were late and audit issues identified in submitted single audit 
reports. SAMHSA also designated American Samoa's Department of Human 
and Social Services as a high-risk grantee due to the lack of 
compliance of its financial management system with federal regulations. 
DOT's Federal Motor Carrier Safety Administration (FMCSA) has 
considered American Samoa to be a high-risk grantee for its Motor 
Carrier Safety Assistance Program (MCSAP) due to past performance 
problems, although no formal designation was made in writing and no 
special conditions were imposed. DOT officials provided an example of a 
past performance problem for American Samoa: the insular area justified 
purchase of a vehicle for MCSAP purposes, but the vehicle was provided 
to the Governor's office. Instead of a formal high-risk designation, 
FMCSA provided additional oversight and required American Samoa to 
submit additional supporting documentation for all progress and final 
vouchers. American Samoa cooperated voluntarily by submitting the 
documentation and accepting the disallowed costs. 

CNMI: 

The U.S. Department of Education designated CNMI as a high-risk grantee 
in 2003 because CNMI's Department of Education was unable to provide 
timely and complete single audits for 4 consecutive years. In September 
2004, the U.S. Department of Education removed the high-risk 
designation based on site visits and the completion of the fiscal year 
2003 single audit for CNMI with few audit findings. 

Guam: 

Guam was designated as a high-risk grantee by the U.S. Department of 
Education in 2003 because Guam's Public School System was unable to 
provide timely and complete single audits for 5 consecutive years. As 
of October 27, 2006, Guam remained as a high-risk grantee for the U.S. 
Department of Education. Additional special conditions have been placed 
by U.S. Department of Education officials on its grants to Guam 
requiring them to demonstrate improved management stability and 
effective fiscal controls. DOT's FMCSA has considered Guam to be a high-
risk grantee for its MCSAP due to past performance problems, although 
no formal designation was made in writing and no special conditions 
were imposed. DOT officials provided an example of a past performance 
problem for Guam--two vehicle inspectors paid by MSCAP funds were 
accepting payments for themselves in exchange for inspection decals. 
Instead of a formal high-risk designation, FMCSA provided additional 
oversight and required Guam to submit an action plan detailing 
corrective actions. The government of Guam cooperated voluntarily by 
submitting the action plan and proof that the inspectors' employment 
had been terminated. 

The U.S. Department of Housing and Urban Development (HUD) has 
designated the Guam Housing and Urban Renewal Authority (GHURA) as a 
high risk agency because of its poor performance under both the Public 
Housing Assessment System (PHAS) and Section Eight Management 
Assessment Program (SEMAP). HUD's Real Estate Assessment Center sent 
staff to Guam in 2006 to perform a quality assurance review of the 
auditor and a report of its review is expected soon. A memorandum of 
agreement is being developed to set targets and strategies for 
improving GHUR's performance. 

USVI: 

The U.S. Department of Education, HHS, and HUD have designated the USVI 
government (or its components) as a high-risk grantee. The USVI 
government was designated as a high-risk grantee by the U.S. Department 
of Education in 1999. Although USVI was already designated as a high- 
risk grantee, the U.S. Department of Education entered into a 
comprehensive 3-year compliance agreement with USVI on September 23, 
2002, due to serious and recurring deficiencies in USVI's 
administration of the U.S. Department of Education programs. In fiscal 
year 2005, U.S. Department of Education officials determined that the 
USVI government would be unable to meet all of the terms of the 
compliance agreement by its expiration on September 23, 2005.[Footnote 
72] In a letter dated June 17, 2005, U.S. Department of Education 
notified the USVI government that, in accordance with the terms of the 
compliance agreement, it would apply special conditions to its grant 
awards, requiring the USVI government to procure the services of a 
third-party fiduciary to perform the financial management duties for 
all U.S. Department of Education grant awards made to USVI. As of 
August 25, 2006, all contract terms between the USVI government and the 
recommended third party fiduciary had been settled, the contract had 
been signed, and the fiduciary has begun work. 

The Centers for Disease Control and Prevention (CDC), a component of 
HHS, designated USVI's Department of Health as a high-risk grantee in 
January 2006 due to the lack of compliance with financial management 
standards. According to the letter to USVI's Department of Health, one 
of the criteria for removing the high-risk designation is the 
establishment of appropriate internal controls to safeguard federal 
funds. The Administration of Children and Families (ACF), another 
component of HHS, placed USVI's Department of Human Services as a high- 
risk grantee in April 1997 for delinquent single audits. According to 
an April 9, 1997, letter, the USVI government had not submitted single 
audits, other than one received for the 2-year period beginning October 
1, 1988, and ending September 30, 1990. Subsequent updates to the high- 
risk listing have referred to the USVI government's chronically late 
single audits. 

In August 2003, HUD designated the Virgin Islands Housing Authority 
(VIHA)[Footnote 73] as a high-risk grantee, and shortly thereafter 
placed VIHA into receivership. VIHA had been under examination for 
several years due to its failure to submit balanced budgets, a 
violation of HUD financial reporting requirements, and the general 
deterioration of management operations. VIHA's Board of Directors was 
unable to provide adequate oversight of housing authority programs, 
including the Section 8 program. VIHA also had failed to submit timely 
audited financial statements for fiscal years 2001 and 2002. VIHA's 
failure to submit timely verifiable financial information had adversely 
affected HUD's ability to verify that federal funds were being used 
properly and in accordance with program requirements and regulations. A 
preliminary review done by HUD indicated that VIHA was operating under 
a budget deficit of approximately $3.5 million. Moreover, HUD officials 
discovered that VIHA was improperly funding a Virgin Islands government 
nursing home for elderly residents in one of its public housing 
developments. VIHA was also cited for providing rent rebates of $3 
million annually to public housing residents in violation of HUD 
regulations. In its audits of VIHA's fiscal year 2001 and 2002 single 
audits, the independent public auditor found that VIHA had serious 
deficiencies in financial reporting, financial analysis, and financial 
management systems. For example, the auditor noted that VIHA maintained 
incompatible accounting systems that precluded effective recording and 
reporting processes. Therefore, VIHA's accounting records did not 
reflect an accurate or complete accounting of the financial position 
and, in addition, VIHA was unable to track and identify expenditures of 
federal funds. According to HUD officials, serious fiscal 
irregularities and ineffective VIHA Board leadership, factors such as 
VIHA staff with insufficient skills, VIHA's inability to adequately 
manage programs, and its failure to improve and correct other 
operational problems, all pointed to a breakdown in the management of 
VIHA. 

On August 1, 2003, HUD notified VIHA that it was in substantial default 
of Section 15 under the Annual Contributions Contract (ACC)[Footnote 
74] for failure to produce reliable financial statements. Violations of 
Section 15 (A) of the ACC were based on the numerous deficiencies noted 
in the authority's books and records identified by VIHA's independent 
auditors and late submission of financial reports. All of these actions 
identified VIHA as a high-risk agency. On August 20, 2003, HUD imposed 
an administrative receivership, assuming VIHA's decision-making 
authority and management by sending in a recovery team to stabilize the 
authority's operations. As of August 15, 2006, VIHA was still in 
receivership. While HUD officials told us that no special conditions 
have been placed on VIHA, HUD will look for the following actions to be 
completed before ending the receivership: 

* improvement in Public Housing Assessment System (PHAS) scores for a 
sustained period in the areas in which the authority was failing; 

* evidence that VIHA has put in place an advisory board to begin taking 
management control of the authority; 

* evidence that key personnel have been hired, such as an executive 
director, chief financial officer, and managers in areas such as 
procurement, maintenance, construction/development, information 
technology, occupancy, and resident services; 

* evidence that the VIHA has established policies and procedures that 
conform to HUD requirements, staff has been trained in these policies 
and procedures, and these policies and procedures are being followed; 

* timely and accurate submission of required HUD reports; and: 

* unqualified audit opinion on both the financial statements and 
compliance with OMB Circular No. A-133 for major programs. 

HUD is currently evaluating the conditions at VIHA and expects new PHAS 
scores in early 2007. All recent required HUD reports have been 
submitted by VIHA in a timely and accurate manner. In 2006, VIHA 
revised its procurement policy and, according to HUD officials, 
implemented the new policy successfully. VIHA has also instituted new 
financial internal controls and procedures to correct the financial 
oversight deficiencies that have been noted in the past. VIHA received 
an unqualified financial audit for fiscal year ending December 31, 
2005. In November 2006, VIHA hired a new Chief Financial Officer with a 
background in housing authority finance. HUD and VIHA are considering 
hiring additional experienced permanent staff for the housing authority 
in 2007. Also, HUD and VIHA are currently evaluating additional changes 
to various policies and procedures in order to improve oversight and 
efficiency throughout the housing authority. 

Efforts to Assist the Insular Areas in Improving Financial 
Accountability: 

DOI's OIA and IG, other federal inspectors general, and local auditing 
authorities assist or oversee the insular areas' efforts to improve 
their financial accountability.[Footnote 75] OIA monitors the progress 
of completion and issuance of the single audit reports as well as 
providing general technical assistance funds to provide training for 
insular area employees and funds to enhance financial management 
systems and processes. DOI's IG has audit oversight responsibilities 
for federal funds in the insular areas.[Footnote 76] In addition, the 
IG evaluates the effectiveness of OIA programs. Each insular area's 
cognizant agency[Footnote 77] for the single audit monitors the 
submissions of the insular area government's single audit report for 
the insular area and considers extensions requested for submitting the 
report. The insular areas' cognizant agencies for fiscal years 2001- 
2005 were DOI for American Samoa and CNMI, HHS for Guam, and USDA for 
USVI. According to an OMB official, DOI will be the cognizant agency 
for all four insular areas for the fiscal year 2006-2010 single audits. 
When the single audit report is completed, the Office of Inspector 
General of the cognizant agency reviews the report to determine whether 
it meets applicable reporting standards and the requirements of OMB 
Circular No. A-133 for implementing the Single Audit Act. The 
inspectors general of other federal grant-making agencies perform 
audits of the insular area governments' implementation of federal 
programs to assess whether federal funds are used for intended purposes 
and effectively and efficiently. Local auditing authorities audit, 
assess, and analyze the insular area governments' activities for 
improving accountability, effectiveness, and efficiency of government 
operations. Interagency groups, such as IGIA, and other less formal 
groups also have worked to improve the financial accountability of the 
insular areas. 

Interior's OIA and Federal IGs: 

A key part of OIA's mission is to promote sound financial management 
processes in the insular area governments. To accomplish this mission, 
OIA has increased its focus on bringing the insular area governments 
into compliance with the Single Audit Act. For example, OIA created an 
incentive for the insular areas to comply with the act by stating that 
an insular area cannot receive capital funding unless its government is 
in compliance with the act or has presented a plan, approved by OIA 
that is designed to bring the government into compliance by a certain 
date. In addition, OIA provides general technical assistance funds for 
training and other direct assistance, such as grants, to help the 
insular area governments comply with the act and to improve their 
financial management systems and environments. 

The Graduate School of the USDA has been working with OIA for over a 
decade through its Pacific Islands and Virgin Islands Training 
Initiatives (PITI and VITI) to provide training and technical 
assistance.[Footnote 78] In fiscal year 2004, OIA began a joint program 
with the Graduate School to address the long-standing problem of audit 
findings and resolutions that had not been addressed by the insular 
area governments. The USDA Graduate School also works with the Island 
Government Finance Officers Association (IGFOA)[Footnote 79] to promote 
improved financial management in the insular areas. Table 13 shows OIA 
funding of USDA Graduate School activities. 

Table 13: OIA Funding for Technical Assistance from the USDA Graduate 
School: 

Fiscal year: 2001; 
PITI/VITI (dollars in millions): $1.3. 

Fiscal year: 2002; 
PITI/VITI (dollars in millions): 1.3. 

Fiscal year: 2003; 
PITI/VITI (dollars in millions): 1.3. 

Fiscal year: 2004; 
PITI/VITI (dollars in millions): 1.3. 

Fiscal year: 2005; 
PITI/VITI (dollars in millions): 1.5. 

Fiscal year: 2006; 
PITI/VITI (dollars in millions): 1.5. 

Fiscal year: 2007 (projected); 
PITI/VITI (dollars in millions): 1.5. 

Source: OIA officials. 

[End of table] 

In addition to funding the training and other services provided by the 
USDA Graduate School, OIA makes direct grants using its general 
technical assistance funds. Some of these grants are targeted at the 
resolution of specific financial management and reporting problems. 

OIA has staff members in headquarters and field representatives in 
American Samoa and CNMI who make site visits to the insular areas. 
According to an OIA official, the office does not use a standard 
framework to write up the results of these site visits, although staff 
members do make notes while they are visiting the insular area. 
Establishing a routine procedure of writing up the results of site 
visits in a standard framework would help ensure that (1) all staff 
members making site visits are consistent in their focus on overall 
accountability objectives and (2) OIA staff has a mechanism for 
recording and following up on the unique situations facing each of the 
insular area governments. 

DOI's IG performs the functions and duties that were once the 
responsibility of government comptrollers for the four insular areas. 
In this role, the IG has audit oversight responsibilities for the 
insular areas. It is also responsible for reviewing and following up on 
single audits for American Samoa and CNMI due to its role as the 
cognizant agency for the two insular areas for the single audits for 
fiscal years 2001-2005. For fiscal years 2006-2010, DOI's IG will be 
responsible for reviewing and following up on the single audits for all 
four insular areas because DOI will be the cognizant agency for all 
four. The IG also evaluates the effectiveness of OIA's programs and has 
issued three reports in 2002 and 2003 that addressed the use of federal 
funds in the four insular areas. One of the reports, dated March 1, 
2002,[Footnote 80] identified what the IG believed to be the top 
management challenges for the U.S. insular areas and compact 
states.[Footnote 81] The report included assessments for each of the 
insular areas regarding the following four challenges: (1) overall 
financial management, (2) internal audit capabilities, (3) audit 
resolution issues, and (4) areas for improvement. In its evaluation 
report of oversight and follow up on audit findings and recommendations 
related to the insular area governments' use of federal funds provided 
by DOI,[Footnote 82] the IG stated that the single audit report 
findings were not sufficiently addressed, due to a lack of federal 
control over the funds and DOI's lack of adequate audit follow-up 
procedures. Noting OIA's lack of enforcement authority over subsidies 
and entitlement-type funding, the IG stated that OIA should increase 
its oversight of these findings by encouraging the insular areas to 
address them and to monitor the implementation of corrective actions. 
In September 2003,[Footnote 83] the IG issued a report about grants OIA 
administers for the insular areas. The IG reported that OIA had 
properly processed awards and distributed grant funds, but needed to 
improve the control process used to monitor grants. 

In accordance with the Reports Consolidation Act of 2000,[Footnote 84] 
DOI's IG also submits annual summaries of issues that it has determined 
to be the most significant management and performance challenges facing 
the department. One of the challenges the IG listed, in DOI's fiscal 
year 2005 performance and accountability report, related to the insular 
areas.[Footnote 85] The IG noted in describing this challenge that 
these governments have long-standing financial and program management 
deficiencies. The IG has also issued many audit reports covering issues 
on individual insular areas. Since January 2000, it has issued 2 audit 
reports on American Samoa, 1 on CNMI, 8 on Guam, and 29 relating to the 
government of USVI.[Footnote 86] The citations for these reports are in 
appendix III. 

Inspectors general of other federal agencies that provide grants also 
conduct audits and evaluations on issues related to the insular areas' 
use of awarded funds. The U.S. Department of Education's IG has 
recently issued several reports--including reports on the USVI 
government's administration of funds under Title IV of the Higher 
Education Act and grant funds for the Infants and Toddlers program--as 
well as the previously mentioned report on the USVI government's lack 
of progress in meeting the terms of the compliance agreement. 

Local Authorities: 

In addition to U.S. federal government audit organizations, each of the 
four insular areas has its own local auditing authorities. The USVI has 
its Office of Inspector General; Guam and CNMI, the Offices of the 
Public Auditor; and American Samoa, the Territorial Audit 
Office.[Footnote 87] All four of these audit authorities have the 
authority to review their governments' use of federal grant funds. 
These audit authorities also determine whether government operations 
are efficient and effective and government assets are properly 
safeguarded and protected from fraud, waste, abuse, and mismanagement. 

All of these local audit authorities are members of the Association of 
Pacific Islands Public Auditors (APIPA), formed in January 1988 through 
a memorandum of understanding (MOU) executed by the heads of the audit 
organizations of five Pacific island nations.[Footnote 88] APIPA was 
formed to achieve several objectives, including (1) the establishment 
of an organized body to promote efficiency and accountability in the 
use of public resources of emerging nations of the Pacific and (2) 
sponsorship of auditing and accounting training workshops. APIPA has an 
annual conference to provide continuing education for its members. 

Interagency Coordination: 

While multiple entities oversee the insular areas' efforts to improve 
their financial accountability, in 1999 and 2003 the White House 
recognized the need to improve coordination of federal programs as they 
relate to insular areas and established the Interagency Group on 
Insular Areas (IGIA)[Footnote 89] consisting of representatives from 
several federal agencies. This group is responsible for identifying 
issues that affect the insular areas and for making recommendations to 
the President and other appropriate officials regarding these issues. 
Executive agencies were to coordinate significant decisions or 
activities relating to the insular areas with the IGIA. The most recent 
meeting of the IGIA was in February 2006 to discuss ongoing issues, 
such as fiscal management, and work done during 2005 in the areas of 
economic and tax policy, infrastructure financing, and healthcare. We 
were unable to obtain information concerning the outcome of IGIA 
efforts. Furthermore, there appears to be limited joint monitoring or 
coordination of financial assistance programs and grants management 
across the many federal grant-making agencies as evident from 
discussions held with agency officials we contacted. With increased 
coordination, the federal agencies could collectively share key 
information, such as high-risk designations, and work with the insular 
area governments to substantially improve their financial 
accountability. 

Insular Areas' Corrective Action Plans: 

Under the Single Audit Act and OMB Circular No. A-133, auditees, when 
the audit is completed, are to prepare corrective action plans to 
address each audit finding in the current year's single audit report. 
Corrective actions are defined in OMB Circular No. A-133 as action 
taken by the auditee that (1) corrects identified deficiencies, (2) 
produces recommended improvements, or (3) demonstrates that audit 
findings are invalid or do not warrant action by the auditee.[Footnote 
90] The corrective action plan should provide the names of the contact 
persons responsible for corrective actions, the corrective actions 
planned, and the anticipated completion date. 

American Samoa: 

In its corrective action plan for fiscal year 2004, American Samoa 
government managers acknowledged the auditor's finding that there were 
significant failures in the operation of the internal control structure 
related to general accounting and grants administration. Management 
commented in its corrective action plan that 7 years had passed since 
the implementation of the new computer system and the hiring of new 
staff. According to the corrective action plan, new internal control 
policies and procedures have been implemented. In this same corrective 
action plan, American Samoa government managers stated that they 
disagree with the finding that government records have not been 
maintained in an organized manner due to the lack of formal procedures 
regarding the maintenance and storage of records. According to the 
plan, the American Samoan government has made progress in the Grants 
Division by assigning grants analysts to specific departments to work 
with the grants program administrator to ensure that expenditures are 
allowable under the program. 

CNMI: 

In its corrective action plan for fiscal year 2004, CNMI officials 
responded to the auditor's finding that due to the lack of detailed 
subsidiary ledgers, the auditors could not determine the propriety of 
two liability account balances and whether the negative balances in the 
accounts, as in prior years, also included prepaid items. CNMI 
government officials stated that the negative balances may not have 
been properly closed for prepaid items. According to the corrective 
action plan, balances are being reviewed and adjusted as needed and new 
procedures for receiving procurements were implemented, and 
reconciliation procedures will be developed. In its corrective action 
plan for the Commonwealth Health Center's (CHC) receivable balance with 
accounts outstanding in excess of 120 days, management stated that they 
agreed with the findings, but management also asserted that it had made 
major progress in correcting the problems. According to management, the 
cause of the problem is a combination of the inefficiency of the 
present computer billing system, an inadequate number of staff in the 
Billing and Collection Office, nonpayment of bills by the Government 
Health Insurance program, and the inclusion of Medicaid expenditures 
beyond the annual cap as receivables. 

Guam: 

In its corrective action plan for fiscal year 2004, government of Guam 
officials responded to the auditor's finding of the lack of the 
required physical inventories of equipment by reporting that GASB No. 
34, Basic Financial Statements and Management's Discussion and Analysis 
for State and Local Governments, was being adopted using a two-stage 
approach. The first stage is to record all capital assets such as 
buildings and infrastructure. The second stage is to compile all fixed 
asset records. For the findings related to noncompliance with 
procurement requirements, the government of Guam stated that GSA will 
continue to improve the processes and to uphold the integrity of the 
procurement activities of the government. 

USVI: 

In response to the auditors' repeated findings about single audit 
compliance, the USVI government stated that it is committed to 
completing and submitting its single audit reports within 9 months 
after the end of the fiscal year in accordance with federal laws and 
regulations. However, the government plans to request and obtain a 
written extension from its cognizant agency if the audit cannot be 
completed within the 9-month deadline. For fiscal years 2003 and 2004, 
the auditor recommended that the USVI Department of Finance develop 
procedures to accelerate the bank reconciliation process and establish 
procedures that include the review and approval of the reconciliations 
by a member of management. The government responded that it will hire 
employees to assist with the reconciliation process, and it will change 
its policies and procedures for recording and handling deposits. At the 
2006 IGFOA Conference held in May 2006, USVI government officials 
reported that with the implementation of a new Enterprise Resource 
Planning System, they expect timely reporting, reconciliations, 
information to decision makers, and completion of single audits, as 
well as a reduction or elimination of audit findings. 

Conclusions: 

American Samoa, CNMI, Guam, and USVI face daunting economic, fiscal, 
and financial accountability challenges. The viability of their 
economies depends on a few key industries. While Guam will benefit from 
DOD's decision to reassign troops from Japan to Guam, changes in 
treaties, tax laws, and other external events have or will likely 
negatively affect the other insular areas' key industries. OIA has a 
number of initiatives underway to promote economic development in the 
insular areas. OIA's efforts in helping create linkages between the 
business communities in the U.S. states and the insular areas are key 
to helping meet some of these challenges. Nevertheless, the islands 
would benefit from formal periodic OIA evaluation of its conferences 
and business-opportunity missions, including assessments of the cost 
and benefit of its activities and the extent to which these efforts are 
creating partnerships with the economies of other nations. 

A healthy private sector can improve the insular areas' fiscal 
condition by increasing local tax revenues. The fiscal condition of 
three of the four insular areas generally worsened during fiscal years 
2001 to 2004, with the fourth--American Samoa--showing a more stable 
trend than the other insular areas. 

Efforts to meet formidable fiscal challenges and build strong economies 
in the insular areas are hindered by delayed and incomplete financial 
reporting that does not provide officials with the timely and complete 
information they need for effective decision making. Questions about 
the reliability and completeness of the reporting have prevented 
auditors from issuing unqualified, or "clean," opinions on the island 
governments' financial statements. Auditors also identified many 
weaknesses likely to have a material, detrimental effect on the insular 
area governments' accountability over federal funds in their reviews of 
internal controls over financial reporting and compliance with major 
federal grant requirements. 

OIA officials monitor the insular area governments' progress in 
submitting single audit reports, and OIA provides funding to improve 
financial management. Other agencies that provide funding for the 
insular areas provide their own oversight, such as their monitoring of 
entities with high-risk designations. Yet, progress has been slow and 
inconsistent, leaving the insular areas in current economic, fiscal, 
and financial difficulty. The benefit to the insular areas of past and 
current assistance is unclear, as is the way toward prosperity and 
fiscal stability. Federal agencies and the insular area governments 
have sponsored and participated in conferences, training sessions, and 
other programs to improve accountability, but knowing what has and 
hasn't been effective and drawing the right lessons from this 
experience is hampered by a lack of formal evaluation and data 
collection, the diffusion of responsibility with little coordination 
between agencies, and no central access to information. The 
conscientious yet disparate efforts of many federal agencies now 
individually engaged in improving the insular areas' economic 
development, fiscal stability, and financial accountability could make 
more efficient use of government and human resources. In a planned and 
well-coordinated effort, and with feedback mechanisms for continuing 
improvement of that effort, federal agencies can help the insular areas 
achieve the economic, fiscal, and financial conditions expected by 
nationals and citizens of a developed nation. 

Recommendations for Executive Action: 

We recommend that the Secretary of the Interior direct the Deputy 
Assistant Secretary for Insular Affairs to: 

* Increase coordination activities with officials from other federal 
grant-making agencies on issues of common concern relating to the 
insular area governments, such as late single audit reports, high-risk 
designations, and deficiencies in financial management systems and 
practices. 

* Conduct formal periodic evaluation of OIA's conferences and business 
opportunities missions, assessing their impact on creating private 
sector jobs and increasing insular area income. 

* Develop a framework for OIA employees to use in conducting site 
visits to help ensure objectives are achieved, to assure that relevant 
information is shared with the responsible officials, and to allow more 
efficient and effective monitoring of issues. 

* Develop and implement procedures for formal evaluations of progress 
made by the insular areas to resolve accountability findings and set a 
time frame for achieving clean audit opinions. 

Agency Comments and Our Evaluation: 

We received written comments on a draft of this report from DOI. In 
commenting on a draft of this report, DOI officials agreed with our 
conclusions and recommendations, stating that our recommendations are 
consistent with OIA's top priorities and ongoing activities. DOI's 
specific comments on each recommendation are summarized below. 

DOI officials agreed with our recommendation to increase coordination 
with officials from other federal grant-making agencies on issues of 
common concern. While DOI officials noted that it currently has 
processes to promote coordination with other federal agencies, 
additional coordination efforts are underway. Specifically, DOI 
officials stated that in fiscal year 2005, OIA began preparations for a 
conference to be held in June 2007 that will bring together officials 
from the federal grantor agencies and the insular areas, to coordinate 
efforts to address issues related to material findings identified in 
single audit reports and other financial management issues, including 
high-risk designations. We encourage OIA to utilize the planned 
conference to address accountability issues of common concern and use 
the results of the conference as a basis for regularly scheduled 
ongoing monitoring and followup on these issues. 

DOI officials commented that they agree with our recommendation that 
OIA conduct periodic evaluation of its conferences and business 
opportunities missions because such evaluation of all federal 
activities is worthwhile. DOI officials added that while these 
conferences and missions are the primary activities through which OIA 
pursues its top priority for the insular areas, the costs associated 
with these activities are only a fraction of a percent of OIA's budget. 
Nevertheless, OIA supports evaluating these activities. 

DOI officials agreed with our recommendation that a framework be 
developed for OIA employees to use in conducting site visits to ensure 
objectives are achieved, assure that relevant information is shared 
with responsible officials, and to allow more effective monitoring of 
issues. In its comments, DOI officials referred to a form in its 
Financial Assistance Manual, that was modified during fiscal year 2006, 
to better ensure that the required grant and project information is 
included in the project file after each site visit. While inclusion of 
this information for individual grants or projects should be valuable, 
our recommendation envisions developing a broader framework that would 
include information beyond that dealing with individual OIA grants or 
projects to include information about each of the insular areas' 
financial accountability environments. The information to be collected 
in this broader framework would include the status of required single 
audit reports, the progress of actions to resolve reported internal 
control weaknesses, and current needs for technical assistance, 
capacity building, and staff level expertise. This information should 
also be integrated into a comprehensive monitoring process. 

DOI officials also agreed with our recommendation that OIA develop and 
implement procedures for formal evaluations of progress made by the 
insular areas to resolve accountability findings and set a time frame 
for achieving clean audit opinions. In its comments, DOI officials 
noted that it has a formal process for monitoring and tracking the 
insular areas' resolution of audit findings in place. DOI officials 
also indicated that they will consider establishing a timetable for 
achieving unqualified ("clean") audit opinions after the insular areas 
have had sufficient time to fully implement corrective actions to 
resolve material findings identified in the fiscal year 2004 and 2005 
single audits. While these actions directed at improved monitoring and 
resolution of audit findings are a step in the right direction, they do 
not specifically address the broader accountability issues highlighted 
in our draft report. In this regard, the inability of the insular areas 
to achieve unqualified audit opinions over a number of years indicates 
the need for more attention and formal evaluation of progress toward to 
resolving accountability problems as called for by our recommendation 
in this area. 

In addition to providing copies of this report to your office, we will 
send copies of this report to other appropriate committees. We will 
also provide copies of this report to interested Congressional 
Committees and to the Secretary of the Interior as well as to the 
governors and delegates of the insular areas. We will also make copies 
available to other interested parties upon request. In addition, the 
report will be available at no charge on the GAO Web site at 
[Hyperlink, http://www.gao.gov]. 

If you or your staff have any questions regarding this report, please 
contact Jeanette Franzel, Director, Financial Management and Assurance 
at (202)512-9471 or Franzelj@gao.gov, or David Gootnick, Director, 
International Affairs and Trade at (202)512-4128 or gootnickd@gao.gov. 

Contact points for our Offices of Congressional Relations and Public 
Affairs may be found on the last page of this report. GAO staff that 
made major contributions to this report are listed in appendix V. 

Signed by: 

Jeanette Franzel: 
Director: 
Financial Management and Assurance: 

Signed by: 

David Gootnick: 
Director: 
International Affairs and Trade: 

[End of section] 

Appendix I: Matters Leading to Qualified Audit Opinions: 

Table 14: American Samoa--Matters Leading to Qualified Audit Opinions 
on the Financial Statements for Fiscal Years 2001 through 2004: 

Description of matter: Unable to verify the accuracy of the due to/from 
other funds--pooled cash due to the lack of reliance on the internal 
control system; 
Fiscal year: 2001: X; 
Fiscal year: 2002: X; 
Fiscal year: 2003: X; 
Fiscal year: 2004: X. 

Description of matter: Unable to verify the amount due from other 
governments and advances from grantors of the Special Revenue Fund due 
to the condition of the insular area's records; 
Fiscal year: 2001: X; 
Fiscal year: 2002: [Empty]; 
Fiscal year: 2003: [Empty]; 
Fiscal year: 2004: [Empty]. 

Description of matter: Unable to confirm the $182,320 due from American 
Samoa Medical Center Authority--Lyndon B. Johnson Tropical Medical 
Center (Medical Center) since another auditor disclaimed their opinion 
on the Medical Center; 
Fiscal year: 2001: X; 
Fiscal year: 2002: [Empty]; 
Fiscal year: 2003: [Empty]; 
Fiscal year: 2004: [Empty]. 

Description of matter: Unable to verify the accuracy of the physical 
inventory records; 
Fiscal year: 2001: X; 
Fiscal year: 2002: X; 
Fiscal year: 2003: X; 
Fiscal year: 2004: X. 

Description of matter: Unable to ensure the physical presence and cost 
of recorded fixed assets and the records were incomplete; 
Fiscal year: 2001: X; 
Fiscal year: 2002: [Empty]; 
Fiscal year: 2003: [Empty]; 
Fiscal year: 2004: [Empty]. 

Description of matter: Unable to obtain sufficient audit evidence to 
determine if bank overdrafts represented held checks (accounts payable) 
or actual overdrafts. No adjustments had been made to accounts payable; 
Fiscal year: 2001: X; 
Fiscal year: 2002: [Empty]; 
Fiscal year: 2003: [Empty]; 
Fiscal year: 2004: [Empty]. 

Description of matter: Unable to obtain and test detailed schedules of 
the immigration deposits; 
Fiscal year: 2001: X; 
Fiscal year: 2002: X; 
Fiscal year: 2003: X; 
Fiscal year: 2004: X. 

Description of matter: Unable to obtain from the Territory's Attorney 
General an adequate discussion, evaluation, or estimation of pending or 
threatened litigation; 
Fiscal year: 2001: X; 
Fiscal year: 2002: [Empty]; 
Fiscal year: 2003: X; 
Fiscal year: 2004: [Empty]. 

Description of matter: Unable to obtain from the Attorney General any 
information on settlement negotiations with its former workers' 
compensation carrier; 
Fiscal year: 2001: X; 
Fiscal year: 2002: X; 
Fiscal year: 2003: X; 
Fiscal year: 2004: [Empty]. 

Description of matter: Sufficient auditing procedures could not be 
performed on the compensated balances recorded as of September 30, 
2001; 
Fiscal year: 2001: X; 
Fiscal year: 2002: [Empty]; 
Fiscal year: 2003: [Empty]; 
Fiscal year: 2004: [Empty]. 

Description of matter: In accordance with GASB 33, the insular area 
didn't restate the beginning fund balance of the general fund for 
amounts that would have been deferred as of September 30, 2000; 
Fiscal year: 2001: X; 
Fiscal year: 2002: [Empty]; 
Fiscal year: 2003: [Empty]; 
Fiscal year: 2004: [Empty]. 

Description of matter: Unable to be satisfied as to the amounts due 
from other governments and advances from grantors of the Special 
Revenue Fund as of September 30, 2001, due to the conditions of the 
American Samoa Community College records; 
Fiscal year: 2001: X; 
Fiscal year: 2002: [Empty]; 
Fiscal year: 2003: [Empty]; 
Fiscal year: 2004: [Empty]. 

Description of matter: Unable to satisfy the validity of the amounts 
due from taxpayers due to the state of the insular area's records; 
Fiscal year: 2001: [Empty]; 
Fiscal year: 2002: X; 
Fiscal year: 2003: [Empty]; 
Fiscal year: 2004: [Empty]. 

Description of matter: Accuracy of the beginning fund balance due to 
noted evidence of a failure of identified controls in preventing or 
detecting misstatements of accounting information and a lack of 
appropriate management oversight and review and approval of 
transactions; 
Fiscal year: 2001: [Empty]; 
Fiscal year: 2002: X; 
Fiscal year: 2003: X; 
Fiscal year: 2004: [Empty]. 

Description of matter: The insular area did not record a liability for 
workers' compensation claims that occurred prior to 9/30/2003; 
Fiscal year: 2001: [Empty]; 
Fiscal year: 2002: [Empty]; 
Fiscal year: 2003: X; 
Fiscal year: 2004: [Empty]. 

Description of matter: Auditors disclaimed an opinion on the American 
Samoa Telecommunication Authority because the entity did not maintain 
accurate inventory records and was unable to reconcile the general 
ledger to the physical inventory, cost of PP&E was no longer available, 
and the account receivable subsidiary records include sufficient 
discrepancies causing the system to be unreliable; 
Fiscal year: 2001: X; 
Fiscal year: 2002: X; 
Fiscal year: 2003: [Empty]; 
Fiscal year: 2004: [Empty]. 

Description of matter: In the opinion of the American Samoa 
Telecommunication Authority's auditor, PP&E not recorded at cost to 
conform with U.S. GAAP and the lack of evidence available to test the 
beginning of the year accounts receivable balance caused the auditors 
to be unable to form an opinion on the amount of operating revenues; 
Fiscal year: 2001: [Empty]; 
Fiscal year: 2002: [Empty]; 
Fiscal year: 2003: X; 
Fiscal year: 2004: X. 

Description of matter: Auditors disclaimed an opinion on the American 
Samoa Medical Center Authority--Lyndon B. Johnson Tropical Medical 
Center because the entity could not locate documentation supporting 
accounting records and auditors were unable to satisfy themselves 
regarding inventory quantities; 
Fiscal year: 2001: X; 
Fiscal year: 2002: X; 
Fiscal year: 2003: [Empty]; 
Fiscal year: 2004: [Empty]. 

Description of matter: The financial statements of the Medical Center 
were not audited; 
Fiscal year: 2001: [Empty]; 
Fiscal year: 2002: [Empty]; 
Fiscal year: 2003: X; 
Fiscal year: 2004: X. 

Sources: American Samoa Single Audit Reports for fiscal years 2001 
through 2004. 

[End of table] 

Table 15: CNMI--Matters Leading to Qualified Audit Opinions on the 
Financial Statements for Fiscal Years 2001 through 2004: 

Description of matter: Inability to obtain response from CNMI's 
Attorney General regarding litigation, claims, and assessments; 
Fiscal years: 2001: X; 
Fiscal years: 2002: [Empty]; 
Fiscal years: 2003: X; 
Fiscal years: 2004: [Empty]. 

Description of matter: Inability to determine the propriety of fixed 
assets and fund equity of the General Fixed Assets Account Group; 
Fiscal years: 2001: X; 
Fiscal years: 2002: [Empty]; 
Fiscal years: 2003: [Empty]; 
Fiscal years: 2004: [Empty]. 

Description of matter: Omission of the Northern Marianas College from 
the university and college fund type--Higher Education Fund; 
Fiscal years: 2001: X; 
Fiscal years: 2002: [Empty]; 
Fiscal years: 2003: [Empty]; 
Fiscal years: 2004: [Empty]. 

Description of matter: Omission of the Public School System from the 
component unit--School District; 
Fiscal years: 2001: X; 
Fiscal years: 2002: [Empty]; 
Fiscal years: 2003: [Empty]; 
Fiscal years: 2004: [Empty]. 

Description of matter: Omission of the Commonwealth Government 
Employees Credit Union from the component unit--Governmental Fund; 
Fiscal years: 2001: X; 
Fiscal years: 2002: [Empty]; 
Fiscal years: 2003: [Empty]; 
Fiscal years: 2004: [Empty]. 

Description of matter: Lack of recognition of certain tax revenues as 
nonexchange transactions; 
Fiscal years: 2001: X; 
Fiscal years: 2002: [Empty]; 
Fiscal years: 2003: [Empty]; 
Fiscal years: 2004: [Empty]. 

Description of matter: The propriety of receivables from federal 
agencies for the Fiduciary Fund Type--Agency Fund; and other 
receivables and accounts payable of the Northern Mariana Islands 
Government Health and Life Insurance Trust Fund. Unable to express an 
opinion on the General Long-Term Debt Account Group; 
Fiscal years: 2001: X; 
Fiscal years: 2002: [Empty]; 
Fiscal years: 2003: [Empty]; 
Fiscal years: 2004: [Empty]. 

Description of matter: Omission of the Commonwealth Utilities 
Corporation from the component units--Proprietary Funds; 
Fiscal years: 2001: X; 
Fiscal years: 2002: X; 
Fiscal years: 2003: [Empty]; 
Fiscal years: 2004: [Empty]. 

Description of matter: Inability to determine the propriety of 
receivables from federal and other agencies, advances, other 
liabilities and accruals, and reserve for continuing appropriations and 
their effect on the determination of revenues and expenditures for all 
governmental fund types; 
Fiscal years: 2001: X; 
Fiscal years: 2002: X; 
Fiscal years: 2003: X; 
Fiscal years: 2004: X. 

Description of matter: Inability to determine if the due to component 
units was fairly stated for all government funds due to inadequacies in 
the accounting records; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2002: X; 
Fiscal years: 2003: X; 
Fiscal years: 2004: X. 

Description of matter: Inadequacies in the accounting records regarding 
accounts payable; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2002: [Empty]; 
Fiscal years: 2003: X; 
Fiscal years: 2004: X. 

Description of matter: Inability to determine the propriety of 
inventory and capital assets of the Northern Marianas College; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2002: X; 
Fiscal years: 2003: [Empty]; 
Fiscal years: 2004: [Empty]. 

Description of matter: Inability to determine the propriety of taxes 
receivable; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2002: X; 
Fiscal years: 2003: X; 
Fiscal years: 2004: X. 

Description of matter: Inability to determine the propriety of 
inventory, due from grantor agencies, utility plant and obligations 
under capital lease of the Commonwealth Utilities Corporation; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2002: [Empty]; 
Fiscal years: 2003: X; 
Fiscal years: 2004: [Empty]. 

Description of matter: Inadequacies in the accounting records regarding 
tax rebates payable; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2002: [Empty]; 
Fiscal years: 2003: [Empty]; 
Fiscal years: 2004: X. 

Description of matter: Inadequacies in the accounting records regarding 
capital assets of the Northern Marianas College and inventory, federal 
agencies receivables, utility plant, accounts payable, and obligations 
under capital lease of the Commonwealth Utilities Corporation; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2002: [Empty]; 
Fiscal years: 2003: [Empty]; 
Fiscal years: 2004: X. 

Sources: CNMI Single Audit Reports for fiscal years 2001 through 2004. 

[End of table] 

Table 16: Guam--Matters Leading to the Qualified Audit Opinions on the 
Financial Statements for Fiscal Years 2001 through 2004: 

Description of matter: Inability to access tax-related records or 
perform procedures as to the effectiveness of the systems tax-related 
balances; 
Fiscal years: 2001: X; 
Fiscal years: 2002: X; 
Fiscal years: 2003: X; 
Fiscal years: 2004: X. 

Description of matter: Incomplete inclusion of the Guam Department of 
Education within the general fund due to nonavailability of information 
from the Department; 
Fiscal years: 2001: X; 
Fiscal years: 2002: X; 
Fiscal years: 2003: [Empty]; 
Fiscal years: 2004: [Empty]. 

Description of matter: Incomplete presentation of the General Fixed 
Assets Account Group or incomplete presentation of capital assets; 
Fiscal years: 2001: X; 
Fiscal years: 2002: X; 
Fiscal years: 2003: [Empty]; 
Fiscal years: 2004: [Empty]. 

Description of matter: Accounting records inadequate to support capital 
assets amounts, net of accumulated depreciation; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2002: [Empty]; 
Fiscal years: 2003: X; 
Fiscal years: 2004: [Empty]. 

Description of matter: Incomplete presentation of the General Long-Term 
Debt Account Group; 
Fiscal years: 2001: X; 
Fiscal years: 2002: [Empty]; 
Fiscal years: 2003: [Empty]; 
Fiscal years: 2004: [Empty]. 

Description of matter: Lack of audited financial statements for the 
Tourist Attraction Fund, Territorial Highway Fund, the Port Authority 
of Guam, and the Guam Waterworks Authority; 
Fiscal years: 2001: X; 
Fiscal years: 2002: X; 
Fiscal years: 2003: [Empty]; 
Fiscal years: 2004: [Empty]. 

Description of matter: Lack of audited financial statements for or 
omission of the Guam Telephone Authority; 
Fiscal years: 2001: X; 
Fiscal years: 2002: X; 
Fiscal years: 2003: [Empty]; 
Fiscal years: 2004: [Empty]. 

Description of matter: Lack of audited financial statements for or 
omission of the Guam Memorial Hospital Authority; 
Fiscal years: 2001: X; 
Fiscal years: 2002: X; 
Fiscal years: 2003: X; 
Fiscal years: 2004: X. 

Description of matter: Omission of the Pension Trust Fund or lack of 
audited financial statements for the Government of Guam Retirement 
Fund; 
Fiscal years: 2001: X; 
Fiscal years: 2002: X; 
Fiscal years: 2003: X; 
Fiscal years: 2004: [Empty]. 

Description of matter: Omission of the Guam Council on the Arts and 
Humanities Agency, a Special Revenue Fund; 
Fiscal years: 2001: X; 
Fiscal years: 2002: [Empty]; 
Fiscal years: 2003: [Empty]; 
Fiscal years: 2004: [Empty]. 

Description of matter: Lack of audited financial statements for or 
omission of the Guam Community College; 
Fiscal years: 2001: X; 
Fiscal years: 2002: X; 
Fiscal years: 2003: X; 
Fiscal years: 2004: [Empty]. 

Description of matter: Lack of audited financial statements for or 
omission of the Guam Visitors Bureau; 
Fiscal years: 2001: X; 
Fiscal years: 2002: X; 
Fiscal years: 2003: X; 
Fiscal years: 2004: X. 

Description of matter: Omission of the Guam Rental Corporation; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2002: X; 
Fiscal years: 2003: [Empty]; 
Fiscal years: 2004: [Empty]. 

Description of matter: Lack of audited financial statements for or 
omission of the Guam Housing Corporation; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2002: X; 
Fiscal years: 2003: X; 
Fiscal years: 2004: [Empty]. 

Description of matter: Lack of audited financial statements for the 
Guam Economic Development and Commerce Authority; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2002: [Empty]; 
Fiscal years: 2003: X; 
Fiscal years: 2004: [Empty]. 

Description of matter: Inability to determine propriety of the General 
Fund continuing appropriations balance; 
Fiscal years: 2001: X; 
Fiscal years: 2002: X; 
Fiscal years: 2003: [Empty]; 
Fiscal years: 2004: [Empty]. 

Description of matter: Inability to determine propriety of the 
inventory balance for the State Agency Surplus, an Internal Service 
Fund--Proprietary Fund Type; 
Fiscal years: 2001: X; 
Fiscal years: 2002: [Empty]; 
Fiscal years: 2003: [Empty]; 
Fiscal years: 2004: [Empty]. 

Description of matter: Receivables recorded in the Solid Waste 
Management Fund and in the Federal Grant Assistance Fund were 
unsubstantiated; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2002: X; 
Fiscal years: 2003: [Empty]; 
Fiscal years: 2004: [Empty]. 

Description of matter: Absence of an accrual for the closure and 
postclosure costs of a solid waste landfill; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2002: X; 
Fiscal years: 2003: X; 
Fiscal years: 2004: [Empty]. 

Description of matter: Inability to determine the propriety of capital 
assets and related amounts for accumulated depreciation and 
depreciation expense; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2002: [Empty]; 
Fiscal years: 2003: X; 
Fiscal years: 2004: [Empty]. 

Sources: Guam Single Audit Reports for fiscal years 2001 through 2004. 

[End of table] 

Table 17: USVI--Matters Leading to the Qualified Audit Opinions on the 
Financial Statements for Fiscal Years 2001 through 2004: 

Description of matter: Not recording a provision for landfill closure 
and postclosure costs in governmental activities or general long-term 
debt account group or the effect of the exclusion of a provision on 
beginning net assets; 
Fiscal years: 2001: X; 
Fiscal years: 2001: X; 
Fiscal years: 2002: X; 
Fiscal years: 2003: X. 

Description of matter: Unable to obtain sufficient evidence that land 
held for sale (amounting to about $25 million) was fairly stated; 
Fiscal years: 2001: X; 
Fiscal years: 2001: X; 
Fiscal years: 2002: X; 
Fiscal years: 2003: [Empty]. 

Description of matter: Virgin Islands Lottery had not been audited for 
business-type activities; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2001: X; 
Fiscal years: 2002: [Empty]; 
Fiscal years: 2003: [Empty]. 

Description of matter: Omission of financial data of the Roy L. 
Schneider Hospital in the public benefit corporations column; 
Fiscal years: 2001: X; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2002: [Empty]; 
Fiscal years: 2003: [Empty]. 

Description of matter: Unable to determine the amount of cash on 
deposit with, and due from, the U.S. Virgin Islands Department of 
Finance as of September 30, 2001; 
Fiscal years: 2001: X; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2002: [Empty]; 
Fiscal years: 2003: [Empty]. 

Description of matter: Auditors of the Juan F. Luis Hospital were 
unable to satisfy themselves about management's contention that the 
preautonomy accounts payable not recorded as a liability as of 
September 30, 2001, were the responsibility of the government; 
Fiscal years: 2001: X; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2002: [Empty]; 
Fiscal years: 2003: [Empty]. 

Description of matter: Omission of the general fixed assets account 
group; 
Fiscal years: 2001: X; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2002: [Empty]; 
Fiscal years: 2003: [Empty]. 

Description of matter: Not maintaining accounting records for income 
tax receivables stated at $87 million; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2001: X; 
Fiscal years: 2002: [Empty]; 
Fiscal years: 2003: [Empty]. 

Description of matter: Auditor of the VI Government Hospital and Health 
Facilities Corporation (Roy L. Schneider Hospital) was unable to 
satisfy themselves as to the propriety of certain transactions recorded 
in the statement of net assets; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2001: X; 
Fiscal years: 2002: [Empty]; 
Fiscal years: 2003: [Empty]. 

Description of matter: Auditor of the VI Housing Authority (VIHA) and 
VI Housing Finance Authority (VIHFA) financial statements, a discretely 
presented component unit, was unable to obtain sufficient evidence as 
to the propriety of the revenue and expenses reported by VIHA, or to 
determine whether capital assets were fairly stated; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2001: X; 
Fiscal years: 2002: X; 
Fiscal years: 2003: [Empty]. 

Description of matter: VIHA did not report an equity interest in a 
joint venture because it had not been able to determine its carrying 
value; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2002: X; 
Fiscal years: 2003: [Empty]. 

Description of matter: Unable to determine the extent to which the 
unemployment insurance fund (a major fund) may have been affected by 
the exclusion of a receivable for unemployment insurance contributions 
due to inadequate records; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2001: X; 
Fiscal years: 2002: X; 
Fiscal years: 2003: X. 

Description of matter: Not maintaining accounting records for corporate 
income tax receivables related to tax year 2002 in the general fund and 
governmental activities; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2002: X; 
Fiscal years: 2003: [Empty]. 

Description of matter: Unable to determine the extent to which the 
revenue, change in fund balance/net assets of the general fund and the 
governmental activities may have been affected by the exclusion of a 
receivable for corporate income taxes pertaining to tax year 2002 in 
the beginning net assets due to inadequate records; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2002: [Empty]; 
Fiscal years: 2003: X. 

Description of matter: Government Employees' Retirement System (GERS), 
a fiduciary component unit (pension trust fund), is not recording 
contributions pursuant to the Early Retirement Act of 1994, had asset 
valuation issues, and adjustments that may have been necessary to 
reflect certain balances with the USVI government's Department of 
Finance; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2002: X; 
Fiscal years: 2003: X. 

Description of matter: Unable to determine the effects of adjustments 
that might have been necessary if the other auditors had obtained 
sufficient audit evidence as to whether capital assets and land held 
for sale were fairly stated in the financial statements of VIHA and 
VIHFA, respectively; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2002: [Empty]; 
Fiscal years: 2003: X. 

Description of matter: Omission of a liability for workers' 
compensation claims from the basic financial statements; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2001: [Empty]; 
Fiscal years: 2002: [Empty]; 
Fiscal years: 2003: X. 

Sources: USVI Single Audit Reports for fiscal years 2001 through 2004. 

[End of table] 

[End of section] 

Appendix II: Internal Control Weaknesses and Compliance with 
Requirements Applicable to Major Federal Programs: 

American Samoa: 

The American Samoan government has seen decreases in the number of 
material weaknesses and reportable conditions that auditors reported 
for internal control over financial reporting. The following table 
shows the numbers of material weaknesses and reportable conditions 
reported for internal control over reporting and compliance with 
requirements applicable to each major federal program, for fiscal years 
2001-2004. 

Table 18: American Samoa--Reported Weaknesses Identified in the 
Auditors' Reports for Fiscal Years 2001 through 2004: 

Fiscal year: 2001; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Material 
weaknesses[A]: 8; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Reportable 
conditions: 0; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Total number of 
findings: 8; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal award): Material weaknesses[B]: 11; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal award): Reportable conditions[C]: 6; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal award): Total number of findings: 17. 

Fiscal year: 2002; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Material 
weaknesses[A]: 6; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Reportable 
conditions: 0; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Total number of 
findings: 6; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal award): Material weaknesses[B]: 13; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal award): Reportable conditions[C]: 9; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal award): Total number of findings: 22. 

Fiscal year: 2003; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Material 
weaknesses[A]: 6; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Reportable 
conditions: 0; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Total number of 
findings: 6; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal award): Material weaknesses[B]: 14; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal award): Reportable conditions[C]: 10; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal award): Total number of findings: 24. 

Fiscal year: 2004; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Material 
weaknesses[A]: 6; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Reportable 
conditions: 0; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Total number of 
findings: 6; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal award): Material weaknesses[B]: 9; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal award): Reportable conditions[C]: 13; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal award): Total number of findings: 22. 

Sources: American Samoa Single Audit Reports for Fiscal Years 2001 
through 2004. 

[A] Material weaknesses in internal control over financial reporting 
are reportable conditions in which the design or operation of internal 
controls does not reduce to a relatively low level the risk that 
misstatements caused by error or fraud--material in relation to the 
financial statements being audited--may occur and not be detected in a 
timely period by employees in the normal course of performing their 
duties. 

[B] Material weaknesses in this context are reportable conditions in 
which internal controls do not reduce to a relatively low level the 
risk of noncompliance with applicable requirements of laws, 
regulations, contracts, and grants that would be material to the major 
federal program being audited and undetected in a timely way by 
employees in the normal course of performing their duties. 

[C] Reportable conditions in this context are matters that come to an 
auditor's attention related to significant deficiencies in the design 
or operation of internal controls over compliance that could adversely 
affect the entity's ability to operate a major federal program within 
the applicable requirements of laws, regulations, contracts, and 
grants. 

Note: The numbers of total findings can be equated with the total 
number of reportable conditions. To compute the numbers of reportable 
conditions that were not material weaknesses, we subtracted the number 
of material weaknesses from the total findings. 

[End of table] 

CNMI: 

In examining the internal controls the government of CNMI uses to 
provide reasonable assurance that it is properly recording financial 
transactions and safeguarding public funds, the auditors found 10 or 
more problems significant enough to warrant reporting. Most of these 
problems were material weaknesses in internal control over financial 
reporting. As shown in table 19, the auditors also reported numerous 
problems in compliance with the requirements for major federal 
programs. 

Table 19: CNMI--Reported Weaknesses Identified in the Auditors' Reports 
for Fiscal Years 2001 through 2004: 

Fiscal year: 2001; 
Internal Control over financial reporting in accordance with government 
auditing standards (report on financial statements): Material 
weaknesses: 10; 
Internal Control over financial reporting in accordance with government 
auditing standards (report on financial statements): Reportable 
conditions: 0; 
Internal Control over financial reporting in accordance with government 
auditing standards (report on financial statements): Total: 10; 
Compliance with requirements applicable to each major federal program 
and internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Material weaknesses: 4; 
Compliance with requirements applicable to each major federal program 
and internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Reportable conditions: 13; 
Compliance with requirements applicable to each major federal program 
and internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Total: 17. 

Fiscal year: 2002; 
Internal Control over financial reporting in accordance with government 
auditing standards (report on financial statements): Material 
weaknesses: 9; 
Internal Control over financial reporting in accordance with government 
auditing standards (report on financial statements): Reportable 
conditions: 1; 
Internal Control over financial reporting in accordance with government 
auditing standards (report on financial statements): Total: 10; 
Compliance with requirements applicable to each major federal program 
and internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Material weaknesses: 2; 
Compliance with requirements applicable to each major federal program 
and internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Reportable conditions: 14; 
Compliance with requirements applicable to each major federal program 
and internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Total: 16. 

Fiscal year: 2003; 
Internal Control over financial reporting in accordance with government 
auditing standards (report on financial statements): Material 
weaknesses: 10; 
Internal Control over financial reporting in accordance with government 
auditing standards (report on financial statements): Reportable 
conditions: 2; 
Internal Control over financial reporting in accordance with government 
auditing standards (report on financial statements): Total: 12; 
Compliance with requirements applicable to each major federal program 
and internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Material weaknesses: 1; 
Compliance with requirements applicable to each major federal program 
and internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Reportable conditions: 15; 
Compliance with requirements applicable to each major federal program 
and internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Total: 16. 

Fiscal year: 2004; 
Internal Control over financial reporting in accordance with government 
auditing standards (report on financial statements): Material 
weaknesses: 8; 
Internal Control over financial reporting in accordance with government 
auditing standards (report on financial statements): Reportable 
conditions: 5; 
Internal Control over financial reporting in accordance with government 
auditing standards (report on financial statements): Total: 13; 
Compliance with requirements applicable to each major federal program 
and internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Material weaknesses: 2; 
Compliance with requirements applicable to each major federal program 
and internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Reportable conditions: 31; 
Compliance with requirements applicable to each major federal program 
and internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Total: 33. 

Sources: CNMI Single Audit Reports for Fiscal Years 2001 through 2004. 

Note: The numbers of total findings can be equated with the total 
number of reportable conditions. To compute the numbers of reportable 
conditions that were not material weaknesses, we subtracted the number 
of material weaknesses from the total findings. 

[End of table] 

Guam: 

The numerous material weaknesses reported by Guam's auditors reveal the 
lack of sound internal controls needed to ensure that (1) transactions 
are properly recorded, (2) assets are adequately safeguarded, and (3) 
federal funds are administered in accordance with the applicable 
requirements of laws, regulations, contracts, and grants. Table 20 
shows the total number of findings from the financial statement audit 
as reported by the auditors on compliance with (1) internal controls 
over financial reporting and (2) with requirements applicable to each 
major federal program. 

Table 20: Guam--Reported Weaknesses Identified in the Auditor's Reports 
for Fiscal Years 2001 through 2004: 

Fiscal: year: 2001; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Material 
weaknesses: 21; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Reportable 
conditions: 59; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Total number of 
findings: 80; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Material Weaknesses: 23; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Reportable conditions: 43; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Total number of findings: 66. 

Fiscal: year: 2002; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Material 
weaknesses: 41; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Reportable 
conditions: 56; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Total number of 
findings: 97; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Material Weaknesses: 30; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Reportable conditions: 14; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Total number of findings: 44. 

Fiscal: year: 2003; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Material 
weaknesses: 8; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Reportable 
conditions: 11; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Total number of 
findings: 19; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Material Weaknesses: 7; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Reportable conditions: 16; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Total number of findings: 23. 

Fiscal: year: 2004; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Material 
weaknesses: 4; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Reportable 
conditions: 3; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Total number of 
findings: 7; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Material Weaknesses: 8; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Reportable conditions: 17; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Total number of findings: 25. 

Sources: Guam Single Audit Reports for Fiscal Years 2001 through 2004. 

Note: The number of total findings can be equated with the total number 
of reportable conditions. To compute the numbers of reportable 
conditions that were not material weaknesses, we subtracted the number 
of material weaknesses from the total findings. 

[End of table] 

USVI: 

USVI audit findings (material weaknesses and reportable conditions) for 
both internal controls over financial reporting and compliance with 
requirements for major federal programs ranged from a total of 31 to 61 
for fiscal years 2001 through 2003, as shown in table 21. 

Table 21: USVI--Reported Weaknesses Identified in the Auditors' Reports 
for Fiscal Years 2001 through 2004: 

Fiscal year: 2001; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Material 
weaknesses: 2; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Reportable 
conditions: 0; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Total number of 
findings: 2; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Material weaknesses: 41; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Reportable conditions: 20; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Total number of findings: 61. 

Fiscal year: 2002; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Material 
weaknesses: 2; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Reportable 
conditions: 0; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Total number of 
findings: 2; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Material weaknesses: 38; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Reportable conditions: 9; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Total number of findings: 47. 

Fiscal year: 2003; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Material 
weaknesses: 3; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Reportable 
conditions: 0; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Total number of 
findings: 3; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Material weaknesses: 43; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Reportable conditions: 10; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Total number of findings: 53. 

Fiscal year: 2004; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Material 
weaknesses: 3; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Reportable 
conditions: 0; 
Internal control over financial reporting in accordance with government 
auditing standards (report on financial statements): Total number of 
findings: 3; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Material weaknesses: 28; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Reportable conditions: 3; 
Compliance with requirements applicable to each major federal program 
and on internal control over compliance with OMB Circular No. A-133 
(report on federal awards): Total number of findings: 31. 

Sources: USVI Single Audit Reports for Fiscal Years 2001 through 2004. 

Note: The numbers of total findings can be equated with the total 
number of reportable conditions. To compute the numbers of reportable 
conditions that were not material weaknesses, we subtracted the number 
of material weaknesses from the total findings. 

[End of table] 

[End of section] 

Appendix III :DOI Inspector General Reports on Four Insular Areas for 
Calendar Years 2000--2005: 

American Samoa: 

Audit Report, Assessment and Collection of Taxes, American Samoa 
Government. No. 2002-I-0003. Guam: November 15, 2001. 

Audit Report, U.S. Fish and Wildlife Service Federal Assistance Grants 
Administered by the American Samoa Government, Department of Marine and 
Wildlife Resources, from October 1, 2001, through September 30, 2003. 
No. R-GR-FWS-0013-2004. Reston, Va.: March 31, 2005. 

CNMI: 

Audit Report, Saipan Harbor Improvement Project, Commonwealth Ports 
Authority, Commonwealth of the Northern Mariana Islands. No. 2003-I- 
0073. Washington, D.C.: September 30, 2003. 

Guam: 

Audit Report, U.S. Department of Defense Contract Funds, Department of 
Education, Government of Guam. No. 00-I-172. Washington, D.C.: January 
10, 2000. 

Survey Report, Guam U.S. Passport Office, Government of Guam. No. 00-I- 
332. Washington, D.C.: April 14, 2000. 

Audit Report, Loan Programs, Guam Economic Development Authority, 
Government of Guam. No. 01-I-417. Guam: September 21, 2001. 

Audit Report, Qualifying Certificate Program, Guam Economic Development 
Authority, Government of Guam. No. 01-I-419. Guam: September 30, 2001. 

Audit Report, Bond Services, Lease Operations and Trust Fund 
Activities, Guam Economic Development Authority, Government of Guam. 
No. 2002-I-0016. Guam: March 28, 2002. 

Audit Report, Management of Federal Grants, Department of Mental Health 
and Substance Abuse, Government of Guam. No. 2002-I-0036. Guam: August 
19, 2002. 

Audit Report, Guam Waterworks Authority, Government of Guam. No. 2003- 
I-0072. Washington, D.C.: September 30, 2003. 

Audit Report, U.S. Fish and Wildlife Service Federal Assistance Grants 
Administered by the Government of Guam, Department of Agriculture, 
Division of Aquatic and Wildlife Resources from October 1, 1999, to 
September 30, 2000. No. R-GR-FWS-0029-2004. Reston, Va.: March 4, 2004. 

USVI: 

Audit Report, Internal Controls over Cashier Operations, Government of 
the Virgin Islands. No. 00-I-166. Washington, D.C.: January 3, 2000. 

Audit Report, Administration of Federal Grants, University of the 
Virgin Islands. No. 00-I-216. Washington, D.C.: February 16, 2000. 

Audit Report, Head Start Program Grants, Department of Human Services, 
Government of the Virgin Islands. No. 00-I-499. Washington, D.C.: June 
14, 2000. 

Audit Report, Low Income Housing Program Grants, Virgin Islands Housing 
Authority. No. 00-I-625. Washington, D.C.: August 24, 2000. 

Audit Report, Environmental Protection Agency Grants, Department of 
Public Works, Government of the Virgin Islands. No. 00-I-696. 
Washington, D.C.: September 2000. 

Audit Report, Administrative Functions, Legislature of the Virgin 
Islands. No. 01-I-107. Washington, D.C.: December 29, 2000. 

Audit Report, Administration and Collection of Excise Taxes, Bureau of 
Internal Revenue, Government of the Virgin Islands. No. 01-I-291. 
Washington, D.C.: March 30, 2001. 

Audit Report, Billing and Collection Functions, Virgin Islands Port 
Authority, Government of the Virgin Islands. No. 01-I-303. Washington, 
D.C.: March 30, 2001. 

Audit Report, Virgin Islands Lottery, Government of the Virgin Islands. 
No. 01-I-290. Washington, D.C.: May 11, 2001. 

Audit Report, Payroll Operations, Department of Education, Government 
of the Virgin Islands. No. 01-I-330. Washington, D.C.: May 14, 2001. 

Audit Report, Virgin Islands Fire Service, Government of the Virgin 
Islands. No. 2002-I-0001. (Virgin Islands: October 30, 2001). 

Audit Report, Job Training Partnership Act Programs, Department of 
Labor, Government of the Virgin Islands. No. 2002-I-0002. (Virgin 
Islands: November 7, 2001). 

Audit Report, Virgin Islands Housing Finance Authority, Government of 
the Virgin Islands. No. 2002-I-0009. Virgin Islands: December 31, 2001. 

Audit Report, Administrative Functions, Virgin Islands Police 
Department, Government of the Virgin Islands. No. 2002-I-0010. Virgin 
Islands: February 13, 2002. 

Audit Report, Federal Highway Grants, Department of Public Works, 
Government of the Virgin Islands. No. 2002-I-0042. Virgin Islands: 
August 16, 2002. 

Audit Report, Grants for the Construction of Health Care Facilities, 
Department of Health, Government of the Virgin Islands. No. 2002-I- 
0043. Virgin Islands: September 20, 2002. 

Audit Report, Professional Service Contracts, Government of the Virgin 
Islands. No. 2002-I-0046. Virgin Islands: September 30, 2002. 

Audit Report, Public Finance Authority, Government of the Virgin 
Islands. No. 2003-I-0002. Washington, D.C.: November 22, 2002. 

Audit Report, Compliance with the Memorandum of Understanding Between 
the Governor of the Virgin Islands and the Secretary of the Interior. 
No. 2003-I-0003. Virgin Islands: November 27, 2002. 

Audit Report, Grant for Solid Waste and Wastewater Disposal Projects, 
Department of Public Works, Government of the Virgin Islands. No. 2003- 
I-0012. Herndon, Va.: March 31, 2003. 

Audit Report, Grant for Hazard Mitigation Projects, Virgin Islands 
Police Department, Government of the Virgin Islands. No. 2003-I-0031. 
Herndon, Va.: March 31, 2003. 

Audit Report, Grant for Hurricane Recovery Projects, Government of the 
Virgin Islands. No. 2003-I-0032. Herndon, Va.: March 31, 2003. 

Audit Report, Follow-up of Recommendations Relating to Internal Revenue 
Taxes, Bureau of Internal Revenue, Government of the Virgin Islands. 
No. 2003-I-0059. Herndon, Va.: August 29, 2003. 

Audit Report, Emergency Services Surcharge Collections by Innovative 
Telephone Corporation on Behalf of the Government of the Virgin 
Islands. No. 2003-I-0067. Herndon, Va.: September 26, 2003. 

Audit Report, Use of Official Credit Cards, Government of the Virgin 
Islands. No. V-IN-VIS-0104-2003. Herndon, Va.: August 27, 2004. 

Audit Report, Financial Arrangements Between the Government of the 
Virgin Islands and Financial Institutions. No. V-IN-VIS-0069-2004. 
Herndon, Va.: September 30, 2004. 

Audit Report, Procurement Practices, Virgin Islands Port Authority, 
Government of the Virgin Islands. No. V-IN-VIS-0001-2004. Washington, 
D.C.: March 28, 2005. 

Audit Report, Grants for Waste Disposal Projects, Department of Public 
Works, Government of the Virgin Islands. No. V-IN-VIS-0072-2004. 
Washington, D.C.: May 11, 2005. 

Audit Report, Indirect Cost Fund, Government of the Virgin Islands. No. 
V-IN-VIS-0110-2003. Washington, D.C.: June 22, 2005. 

[End of section] 

Appendix IV: Comments from the Department of the Interior: 

United States Department Of The Interior: 
Office Of The Assistant Secretary Policy, Management And Budget: 
Washington, DC 20240: 

Take Pride In America: 

DEC 05 2006: 

Norma Samuel: 
Assistant Director: 
Financial Management and Assurance: 
United States Government Accountability Office: 
Washington, D.C. 20548: 

Dear Ms. Samuel: 

Thank you for the opportunity to review and comment on the U.S. Office 
of Government Accountability (GAO) Draft Report No. GAO-07-119, dated 
November 2006, entitled "U.S. Insular Areas: Economic, Fiscal, and 
Financial Accountability Challenges" (Draft Report). The Department of 
the Interior (Department) agrees with the four recommendations 
presented in the Report and is pleased that the GAO recommendations 
validate the ongoing activities of the Department's Office of Insular 
Affairs (OIA), which carries out the Secretary of the Interior's 
responsibilities with respect to the U.S. territories and freely 
associated states. 

We find the GAO's review of the U.S. territories of American Samoa, the 
Commonwealth of the Northern Mariana Islands (CNMI), Guam and the U.S. 
Virgin Islands (USVI) to be mostly accurate and well balanced. The 
focus of the Draft Report lines up well with OIA's top two priority 
areas for the insular areas: private sector economic development and 
accountability. As the Draft Report makes clear, progress is not easily 
achieved in either of these two priority areas. 

Private sector economic development is OIA's top priority because of 
the insular areas' economic challenges and urgent public needs in 
health, education, infrastructure, environmental protection, financial 
management, and several other areas. 

Transforming the insular areas from public-sector-dominated economies 
to healthy, diverse, private-sector-led economies is an enormous task. 
Many of the reasons for this are identified in the Draft Report. This 
transformation cannot succeed unless it is adopted as a top priority by 
the insular area governments themselves. OIA can, however, provide a 
crucial leadership role and can provide important technical assistance 
to help the insular areas improve their business climates, identify 
areas of potential for private sector investment, and market insular 
areas to potential investors. This is what OIA has been doing. 

OIA's other major priority for the insular areas has been to improve 
accountability for Federal financial assistance. For many years there 
was no source of comprehensive financial information for each of the 
insular areas, as each was several years delinquent in completing 
required annual single audits. Since Fiscal Year (FY) 2004, OIA has 
implemented processes and provided funding for projects to help the 
insular areas to produce more timely and accurate financial 
information. OIA's comprehensive approach includes: funding for 
training conferences and workshops to increase local capacity; funding 
for financial experts and consultants to work in the islands; assigning 
OIA staff to provide critical technical advice and aggressively monitor 
and evaluate the fiscal management and reporting activities of insular 
area governments; communicating with other Federal agencies regarding 
systemic issues related to the insular areas' administration of Federal 
grant programs; and developing rating processes to allocate OIA grant 
funds based upon the progress of the insular areas in improving 
financial management and accountability for Federal funds. To date, 
this comprehensive approach has contributed to the completion of 17 
audits by the insular areas covered by the Draft Report. All of the 
insular areas have made progress in developing and implementing 
corrective actions to resolve material audit findings and clear audit 
opinion qualifications. Three of the four insular areas covered in the 
Draft Report American Samoa, the CNMI and Guam-are current on their 
single audits and are developing systems to allow them to continue to 
complete audits in a timely manner. The remaining insular area, the 
USVI, is one audit delinquent. However, the Department is not the 
cognizant agency for audits for the USVI and, therefore, OIA's ability 
to assist the USVI to improve the timeliness and accuracy of its single 
audits is limited. 

In addition to the single audits, OIA receives other financial 
information from the insular areas in the form of quarterly financial 
reports, financial reviews (e.g., Performeter Reports), OIA grant 
administrative reports (Financial Cash Status Reports, Narrative Status 
Reports, cost documents) and audit reports completed by the 
Department's Office of the Inspector General, GAO and insular area 
audit offices. Also, OIA staff meets with insular area officials at 
workshops held every May, June and December, and OIA staff performs on- 
site reviews. Since FY 2003, the workshops have centered on compliance 
with Federal audit requirements and the improvement of the insular 
areas' administration of Federal grant programs. 

As noted in the Draft Report, the insular areas face serious challenges 
with limited resources. As the insular areas complete the task of 
catching up on their delinquent single audits, they will be able to 
target more resources to resolving material deficiencies. 

This in turn will help to resolve audit opinion qualifications and put 
the insular areas on the path to "clean" opinions. 

OIA's accountability efforts are of course not limited to the insular 
areas covered in the Draft Report; they also extend to the insular 
areas that are affiliated with, but not part of, the U.S. In this 
regard, we would note that Palau has submitted clean single audits in a 
timely fashion for the past three fiscal years, and that the most 
recent single audit for the State of Pohnpei, FSM, was timely, clean, 
and with no questioned costs. 

The Department will continue its comprehensive approach and will 
implement other innovative ideas, as resources permit, to assist the 
insular areas to continue to improve financial management and 
accountability. 

GAO Recommendations: 

We concur with the recommendations to the Secretary of the Interior for 
actions by the Deputy Assistant Secretary for Insular Affairs and are 
pleased that the GAO recommendations mirror actions already implemented 
by the Department. The recommendations are discussed below: 

1) Increase coordination activities with officials from other federal 
grant-making agencies on issues of common concern relating to the 
insular area governments, such as late single audit reports, high-risk 
designations, and deficiencies in financial management systems and 
practices. 

The Department agrees with this recommendation, but notes that OIA 
already utilizes a number of processes to promote this type of 
coordination with other Federal agencies. The Draft Report mentions the 
Interagency Group on Insular Areas (IGIA), which brings together 
representatives of nearly 30 Federal agencies for the purpose of 
coordinating policy with respect to the insular areas covered by the 
Draft Report. In August 2004, OIA convened a working group of Federal 
grantor agencies that award material amounts of Federal funding to the 
insular areas. Within both of these groups OIA addresses material 
issues affecting the insular areas and Federal grant programs. In 
addition, in FY 2005 OIA began preparations for a conference that will 
bring together Federal grantor agencies and insular area officials to 
address (a) issues related to material findings identified in single 
audit reports and (b) other financial management issues, including 
declarations of high-risk. The conference is scheduled for June 2007 in 
coordination with the semiannual OIA workshop held for insular area 
officials responsible for finance, budget and procurement. 

2) Conduct formal periodic evaluation of OIA's 's conferences and 
business opportunities missions, assessing their impact on creating 
private sector jobs and increasing insular area income. 

The Department agrees with this recommendation because periodic 
evaluation of all Federal activities is a good thing. We would note, 
however, that the conferences and missions are the primary activities 
through which OIA pursues its top priority for the insular areas, yet 
they account for only a fraction of a percent of OIA's budget. The 
participants in the conferences and mission pay their own expenses. 
Given the successes that have already come out of these efforts, and 
those that are currently in process, these activities are among the 
most cost-effective that OIA engages in. We support evaluating these 
activities so that we can make them even more effective. 

We would note that a number of indirect benefits flow from the 
conferences and missions. For example, all of the insular areas have a 
strong incentive to make a good impression at the conferences and 
missions. This motivates the insular areas to polish their self- 
marketing efforts, and to consider business climate reforms that might 
improve their attractiveness to outside investors. When OIA promotes 
the conferences and missions, it engages in extensive outreach to 
private sector companies. This enables a large number of businesses to 
learn about the competitive advantages offered by some or all of the 
insular areas. We are aware of companies that have pursued important 
opportunities in the insular areas solely on the basis of our pre- 
conference or pre-mission marketing efforts. 

The conferences themselves, of course, give the insular areas an 
invaluable opportunity to market themselves before a wide audience of 
potential investors at minimal cost. The missions are also quite cost- 
effective for the insular areas, because they bring to the islands 
groups of businesspeople who have demonstrated significant interest in 
opportunities there. 

We would also note that we agree with GAO's suggestion that more effort 
should be made to promote non-U.S. investment in the insular areas. OIA 
participated in outreach efforts to potential investors in Tokyo in 
2003 and in Auckland, New Zealand this year, and funded American 
Samoa's participation in trade shows in New Zealand and Hong Kong this 
year. We agree that more of these efforts are needed. 

3) Develop a framework for OIA employees to use in conducting site 
visits to help ensure objectives are achieved, to assure that relevant 
information is shared with the responsible officials, and to allow more 
efficient and effective monitoring of issues. 

The Department agrees with this recommendation, and notes that OIA's 
Financial Assistance Manual, as revised in FY 2003, provides a form to 
be used to structure and summarize on-site visits. The form was 
modified during FY 2006, and OIA staff is ensuring that the required 
information is included in the project file after each site-visit that 
pertains to a material issue. 

4) Develop and implement procedures for formal evaluations of progress 
made by the insular areas to resolve accountability findings and set a 
time frame for achieving clean audit opinions. 

The Department agrees with this recommendation. In addition to the 
ongoing activities discussed above, we note that in FY 2004, OIA 
developed a formal process for monitoring and tracking the insular 
areas' resolution of audit findings. The process was developed as part 
of the Corrective Action Plans that were reviewed and accepted by the 
Department's Office of Financial Management. In addition, the 
information is used in OIA's process for allocating grant funding for 
both the Capital Improvement Program and the Technical Assistance grant 
program. 

The insular areas' progress on resolving material issues will also 
contribute to the resolution of audit opinion qualifications. OIA 
intends to consider a timetable for achieving "clean" audit opinions 
after the insular areas have had adequate time to fully implement 
corrective actions to resolve material findings identified in the 
single audits of FY 2004 and 2005. 

Thank you again for the opportunity to comment on the Draft Report. If 
you have any questions concerning the response, please contact David B. 
Cohen, Deputy Assistant Secretary of the Interior-Insular Affairs, or 
Nikolao Pula, Director of the Office of Insular Affairs, at (202) 208- 
4736. 

Sincerely, 

Signed by: 

R. Thomas Weimer: 
Assistant Secretary: 

[End of section] 

Appendix V: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

Jeanette Franzel at (202) 512-9471 or FranzelJ@gao.gov: 

David Gootnick at (202) 512-3149 or GootnickD@gao.gov: 

Staff Acknowledgments: 

The following individuals made important contributions to this report: 
Norma Samuel, Emil Friberg, Jr., James Wozny, Maxine Hattery, Gina 
Ross, Sandra Silzer, Seyda Wentworth, and Elwood White. 

FOOTNOTES 

[1] These four insular areas are the subject of this report. Not 
included in the scope of this report are Puerto Rico and nine smaller 
insular areas of the United States, Navassa Island in the Caribbean 
Sea, and Baker Island, Howland Island, Kingman Reef, Jarvis Island, 
Johnston Atoll, Midway Atoll, Palmyra Atoll, and Wake Island in the 
Pacific Ocean. 

[2] 31 U.S.C. Chp. 75. 

[3] OIA's mission is to promote sound financial management processes, 
boost economic development, and increase the federal government's 
responsiveness to the unique needs of the insular areas. 

[4] The most recent year for which audited financial statements were 
available for all four insular areas was fiscal year 2004. 

[5] Fund balance is the difference between assets and liabilities 
reported in the governmental fund. A fund is a separate self-balancing 
set of accounts used to account for resources that are segregated for 
specific purposes in accordance with special regulations, restrictions, 
or limitations. 

[6] Net assets are the remaining amount after liabilities have been 
subtracted from assets. Revenues are changes in resources that increase 
net assets whereas expenses are changes in resources that reduce net 
assets. Financial statements describe how assets, liabilities, and net 
assets change over the course of a reporting period, such as a fiscal 
year. 

[7] A U.S. national is either a citizen or someone who "owes permanent 
allegiance to the United States." 8 U.S.C. § 1101 (a) (21), (22). 
Citizenship is derived either from the Fourteenth Amendment to the 
Constitution ("All persons born or naturalized in the United States, 
and subject to the jurisdiction thereof, are citizens of the United 
States") or from a specific statute that confers citizenship on the 
inhabitants of an area that, although not a state, is under the 
sovereignty of the United States. No such legislation conferring 
citizenship has been enacted for American Samoa. 

[8] Organic acts are federal laws that serve as the constitution or 
basic charter of the territory, thereby conferring the powers of 
government upon a territory. The organic acts of the insular areas 
usually include a bill of rights and provide for the establishment of 
the insular areas' tripartite government. 

[9] An unincorporated territory is a U.S. territory or insular area to 
which Congress has determined that only selected parts of the U.S. 
Constitution apply. 

[10] For fiscal years ending before December 31, 2003, the threshold 
that triggered the requirement for a single audit was expenditures of 
$300,000 or more in federal awards a year. 

[11] Office of Management and Budget (OMB) Circular No. A-133, Audits 
of States, Local Governments, and Non-Profit Organizations, establishes 
policies for federal agencies to use in implementing the Single Audit 
Act and provides an administrative foundation for consistent and 
uniform audit requirements for nonfederal entities administering 
federal awards. 

[12] The single audit replaces multiple grant audits with one audit of 
an entity as a whole. 

[13] Internal control is an integral component of an organization's 
management that provides reasonable assurance that the following 
objectives are being achieved--effectiveness and efficiency of 
operations, reliability of financial reporting, and compliance with 
applicable laws and regulations. Internal control also serves as the 
first line of defense in safeguarding assets and preventing and 
detecting errors and fraud. 

[14] The Single Audit Act Amendments of 1996 resulted in the 
establishment of an automated database of single audit information at 
the Federal Audit Clearinghouse (FAC), the organization designated by 
the Office of Management and Budget to receive single audit reports 
from federal award recipients. 

[15] Pub. L. No. 97-357, 96 Stat. 1705 (Oct. 19, 1982). 

[16] Reports for these fiscal years were generally available to be 
downloaded from the FAC. 

[17] The insular area governments submit a data collection form (SF- 
SAC) that includes information about the auditee, its federal programs, 
and the results of the audit. 

[18] For example, U.S. Census Bureau data show that in 2000 there were 
over 55,000 people in the United States who reported ancestry from Guam 
and CNMI, as compared to about 81,000 native born residents in Guam and 
25,000 in CNMI. There were also over 85,000 Samoans in the United 
States--from American Samoa, Western Samoa, and elsewhere--compared to 
32,500 born and living in American Samoa. 

[19] According to DOI officials, the tuna industry generated directly 
or indirectly about 85 percent of the territory's private sector 
activity in 2004. A DOL study indicates that the two canneries, owned 
by Starkist and Chicken of the Sea, supply more than 60 percent of the 
canned tuna consumed in the United States. For details, see [Hyperlink, 
http://www.dol.gov/esa/whd/AS]. 

[20] M. Rubin, Final Trip Report on Benchmark Estimates of 2002 Gross 
Domestic Product in American Samoa (Washington, D.C.: U.S. Census 
Bureau, 2005). 

[21] Impact of Rapid Population Growth in American Samoa: A Call for 
Action, May 2000, by the Governor's Task Force on Population Growth, 
Pago Pago, American Samoa. 

[22] Department of Labor, American Samoa Economic Report 2005, Section 
VI, "Economic Factors for Consideration that May Favor Minimum Wage 
Increases," [Hyperlink, http://www.dol.gov/esa/whd/AS/sec6.htm]. 

[23] 19 U.S.C. §§ 3201, 3202(b)(1), 3203(b)(3),(4). 

[24] According to DOL, pouched tuna, an alternative new technology in 
tuna packaging, is becoming popular among consumers. American Samoa 
Economic Report 2005, Section III, "The Tuna Processing Industry." 

[25] American Samoa Economic Report 2005, Section VI, "Economic Factors 
for Consideration That May Favor Minimum Wage Increases." The U.S. 
Census Bureau estimates that the majority of profits generated by the 
tuna canneries are repatriated. Income payments going abroad represent 
almost 25 percent of GDP. 

[26] 26 U.S.C. § 936. The possessions tax credits originated in the 
1920s as a tax incentive for businesses in the U.S. possessions. 

[27] According to an Interior official, the canneries also benefit from 
several local tax exemptions and subsidies related to water and rent 
that, combined with duty-free access to the United States, provide 
other important advantages to the canneries. However, the value of 
these exemptions and subsidies is not publicly available. 

[28] H.R. 4297, 109th Cong. § 111 (2005). 

[29] Pub. L. No. 109-222, 120 Stat. 345 (May 17, 2006). On December 7, 
2006, the House introduced another measure extending possession tax 
credits for American Samoa's canneries for 2 years. H.R. 6408, 109th 
Cong. § 119 (2006). This language of section 119 was subsequently 
rolled into H.R. 6111, which ultimately passed the House and Senate, 
and was sent to the President for signature on December 9, 2006. As of 
the date of this report, no action had been taken by the President. 

[30] American Samoa Economic Report 2005, Section VI, "Economic Factors 
for Consideration That May Favor Minimum Wage Increases." 

[31] Although the minimum wage in American Samoa is below that of the 
contiguous United States ($3.26 per hour versus $5.15), the lower labor 
rates in countries such as the Philippines and Thailand--about $.67 and 
$.66, respectively--makes such locations attractive to corporations 
seeking lower labor costs. 

[32] As in CNMI, a large number of noncitizens live and work in 
American Samoa, representing over 35 percent of the population, 
according to the 2000 U.S. Census. However, unlike the situation in 
CNMI, about half of American Samoa's foreigners have been living on the 
island for a relatively long time, with the other half entering after 
1990. Western Samoans represent the majority of noncitizens. Also, many 
American Samoans emigrate to the United States. 

[33] The 2000 U.S. Census shows that noncitizens, predominantly Chinese 
and Filipinos, make up over half of CNMI's population. Almost all of 
these temporary foreign workers came to CNMI after 1990. 

[34] An Economic Study for the Commonwealth of the Northern Mariana 
Islands, Business Development Center, Northern Marianas College, with 
funding provided by the Office of Insular Affairs, U.S. Department of 
the Interior, October 1999. 

[35] See M. Rubin and S. Sawaya, Final Trip Report on Benchmark 
Estimates of 2002 Gross Domestic Product in the Commonwealth of the 
Northern Mariana Islands (Washington, D.C.: U.S. Census Bureau, 2005). 
Many businesses, including the garment factories, are owned and 
operated by foreigners. As in American Samoa, profits generated by 
foreign-owned businesses are often repatriated. 

[36] According to the U.S. Harmonized Tariff Schedule, certain items of 
which at least 50 percent of the value was added in a U.S. possession 
are eligible for duty-free shipment to the United States. 

[37] GAO, U.S.-China Trade: Textile Safeguard Procedures Should be 
Improved, GAO-05-296 (Washington, D.C.: Apr. 4, 2005.) 

[38] The burden of this job loss on the government may be mitigated to 
some extent by the fact that garment industry workers are almost 
exclusively foreigners on temporary guest visas. Also, data we obtained 
from the U.S. Census Bureau indicate that foreign workers send much of 
their earnings back to their countries of origin in the form of 
remittances; the remainder, which is spent on local goods and services, 
is relatively small, and as a result, has limited effect on local 
economic activity. Remittances were estimated at about $80 million for 
2002, roughly 10 percent of GDP, and at over $100 million in 2005. 

[39] China Southern Airlines' August 2006 decision to suspend its 
flights from Guangzhou City in China to Saipan in September because of 
low load factor, high fuel costs, and low yield in fares is likely to 
slow the growth of Chinese visitors and hinder CNMI's efforts to 
attract more tourists from China. 

[40] Northwest Airlines has flights from Nagoya, Japan to Saipan as 
well, and is planning to add flights between Tokyo and Saipan. 

[41] M. Rubin and S. Sawaya, Final Trip Report on Benchmark Estimates 
of 2002 Gross Domestic Product in Guam (Washington, D.C.: U.S. Census 
Bureau, 2005). 

[42] [Hyperlink, http://www.visitguam.org/members/?pg=research]. 

[43] The number of visitors declined from 1,286,807 in 2000 to 
1,159,071 in 2001; 1,058,704 in 2002; 
and 909,506 in 2003. 

[44] Guam Economic Report 2003, Bank of Hawaii and East-West Center, 
available at [Hyperlink, 
http://www.eastwestcenter.org/stored/pdfs/OsmanGuamEconomicReport2003.pd
f]. The report indicates that total payroll employment decreased from 
around 70,000 to 56,000 between 1992- 2002, with most of the losses 
taking place in the private sector and national defense. 

[45] Rum distillation is another source of income for USVI. The watch 
industry, once relatively important for the USVI economy, has been 
declining over the past 10 years. Watch exports decreased from over 
1,000,000 before 1997 to about 320,000 in 2004, with shipments going 
down further in 2005, according to the USVI Bureau of Economic 
Research. 

[46] The USVI Bureau of Economic Research 2002 data report 8,910 total 
tourism-related jobs in the following four categories: hotels and other 
lodging places; gift shops; eating and drinking places; and 
transportation by air. Nonagricultural wage and salary employment in 
2002 was 43,129. 

[47] The USVI Economic Review and Industry Outlook indicates that 
refined petroleum exports grew to $6.7 billion in 2004. 

[48] This may be due to the fact that to qualify for tax benefits, 
businesses need to employ only 10 USVI residents. Eligible businesses 
in the service category (category IIA or Designated Services Businesses 
(DSBs)) include business investment managers and advisors, research and 
development, business and management consultants, software developers, 
e-commerce, call centers, high technology, international public 
relations firms, international trading and distributions, and other 
businesses serving clients outside of USVI. 

[49] Pub. L. No. 108-357, 118 Stat. 1418 (Oct. 22, 2004). 

[50] The U.S. Congress passed AJCA partly in response to reported 
abuses of the EDC program as a tax shelter or evasion scheme. While the 
aim of the act was to eliminate loopholes that some businesses had 
exploited, USVI authorities are concerned that AJCA is also driving 
away legitimate companies, undermining their effort to attract U.S. 
firms providing international services. 

[51] DOI reports that the combined economic costs to USVI of Hurricanes 
Hugo in 1989 and Marilyn in 1995 ranged from $3 to $4 billion. FEMA and 
the U.S. Small Business Administration are reported to have provided 
grants and loans of more than $200 million. 

[52] DOI organized one trade mission to Guam, Palau, and CNMI in 2005; 
one to American Samoa and one to USVI in 2006. 

[53] The data come from preregistered participants. A third Conference 
on Business Opportunities in the Islands took place on November 13-14, 
2006 in Hawaii. 

[54] Other agencies, such as the Department of Commerce, the Overseas 
Private Investment Corporation, and the Small Business Administration 
provided managerial and organizational support for these missions. 

[55] The amount for net assets as of the end of fiscal year 2004 was 
reported in the fiscal year 2004 single audit report as $47,193,817, 
and the change in net assets figure was $7,796,791. 

[56] The Grants Management Common Rule was established in 1987 under 
presidential direction to adopt governmentwide terms and conditions for 
grants to state and local governments. Federal departments incorporate 
the Grants Management Common Rule in their own agency regulations. 
Among the many provisions in the regulations, the Grants Management 
Common Rule provides authority to designate a grantee as high-risk. 

[57] Under the Single Audit Act, the single audit reporting package is 
generally required to be submitted to the FAC either 30 days after the 
receipt of the auditor's report or 9 months after the end of the period 
under audit. The audited entity, upon hiring the auditor, negotiates a 
due date for the audit within 9 months after the close of the entity's 
fiscal year. The entity must have time to read the report and prepare 
the corrective action plan that is required to be in the reporting 
package. 

[58] DOI granted CNMI an extension until February 28, 2006, for 
submitting its fiscal year 2004 single audit report. 

[59] Generally accepted accounting principles are the conventions, 
rules, and procedures that provide the norm for fair presentation of 
financial statements. 

[60] Accounting information is material when an omission or 
misstatement of accounting information would, in the light of 
surrounding circumstances, make it probable that the judgment of a 
reasonable person, relying on the information, would have changed or 
been influenced by the omission or misstatement. 

[61] The 14 types are (1) activities allowed or unallowed; (2) 
allowable costs/cost principles; (3) cash management; (4) Davis-Bacon 
Act; (5) eligibility; (6) equipment and real property management; (7) 
matching, level of effort, and earmarking; (8) period of availability 
of federal funds; (9) procurement, suspension and debarment; (10) 
program income; (11) real property acquisition and relocation 
assistance; (12) reporting, (13) subrecipient monitoring; and (14) 
special tests and provisions. 

[62] The primary government is the state or local government. Primary 
governments have separately elected governing bodies and are legally 
separate and fiscally independent of other state and local governments. 

[63] All cash not legally required to be in separate accounts is pooled 
to provide greater internal control over cash, and to maximize the 
amount available for investment, thereby increasing investment 
revenues. 

[64] A discretely presented component unit is an organization that is 
not part of the primary government but for which the nature and 
significance of their relationship with a primary government are such 
that excluding the organization would cause the reporting entity's 
statements to be misleading or incomplete. 

[65] The receivable for unemployment insurance contributions as of 
September 30, 2003, is needed because it affects the determination of 
revenue and changes in net assets for the year ended September 30, 
2004. 

[66] OMB Circular No. A-133 requires auditors to report on compliance 
that includes an opinion (or disclaimer of opinion) as to whether the 
entity being audited complied with laws, regulations, and provisions of 
contracts or grant agreements which could have a direct and material 
effect on the federal program. 

[67] Internal control activities help ensure that management's 
directives are carried out and should be effective and efficient in 
accomplishing control objectives. 

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

[69] A detailed inventory of capital assets is needed to conform to the 
financial presentation required by Statement No. 34 of the Governmental 
Accounting Standards Board (GASB). Statement No. 34, Basic Financial 
Statements--and Management's Discussion and Analysis--for State and 
Local Governments, establishes new requirements for the annual 
financial reports of state and local governments. One of the new 
requirements is that state and local governments report infrastructure 
and depreciate their capital assets. 

[70] GAO, American Samoa: Accountability for Key Federal Grants Needs 
Improvement, GAO-05-41 (Washington, D.C.: Dec. 17, 2004). 

[71] In a letter dated November 24, 1999, a SAMHSA grants officer 
stated that American Samoa would remain in the high-risk status until 
its delinquent audit reports had been submitted and accepted. At that 
time, the fiscal year 1995 financial statements had been submitted, but 
not the single audit reports for fiscal years 1995, 1996, 1997, and 
1998. 

[72] Department of Education, Office of Inspector General, The Virgin 
Islands Is at Risk of Not Meeting the Goals of the September 2002 
Compliance Agreement, ED-OIG/A02-D0028 (New York Audit Region: Feb. 15, 
2005). 

[73] The Virgin Islands Housing Authority (VIHA) is a public housing 
corporation established in 1949 with the responsibility for planning, 
financing, constructing, maintaining, and managing public housing 
development within the territorial boundaries of the U.S. Virgin 
Islands (St. Thomas, St. John, and St. Croix). 

[74] Annual contributions contracts, made between HUD and a housing 
authority, specify what the authority must do to receive funding from 
HUD during the contract year. HUD may declare a housing authority in 
substantial default or in breach of its annual contributions contract 
with HUD. 

[75] Although the insular areas receive grants from many federal 
agencies, one of the grant-making agencies is designated as the 
cognizant agency for purposes of the Single Audit Act. The cognizant 
agencies have specific responsibilities under OMB Circular No. A-133. 
The cognizant agency is usually the agency that provides the 
predominant amount of funding. 

[76] Pub. L. No. 97-357, 96 Stat. 1705 (Oct. 19, 1982). The 1982 Act 
transferred the functions, powers, and duties once vested in the 
government comptroller for Guam (for the islands of Guam and CNMI), 
Virgin Islands, and American Samoa to the Inspector General, Department 
of the Interior, for the purpose of establishing an organization which 
will maintain a satisfactory level of independent audit oversight of 
the respective territory government. 

[77] All federal awarding agencies are responsible for ensuring that 
single audit reports are completed, are in accordance with OMB Circular 
No. A-133, and are received in a timely manner. Cognizant agencies, 
among other duties, have the additional responsibilities of 
coordinating management decisions for audit findings that affect the 
audit programs of more than one agency and considering auditee requests 
for extensions to the due dates of the reports. 

[78] The Pacific Islands Training Initiative (PITI) was established in 
1991 through an Interagency Agreement between the Graduate School, 
USDA's International Institute, and OIA. 

[79] OIA and financial management officials from the insular areas 
formed IGFOA in 1999 to promote improved financial management in the 
insular areas. All four insular areas belong to the IGFOA and the 
organization holds two conferences each year--one conference is held in 
one of the insular areas and the other is held right after the 
Government Finance Officers Association's annual meeting in the United 
States. 

[80] Office of Inspector General, U.S. Department of the Interior, 
Management Challenges for Insular Area Governments: An Opportunity for 
Improvement, No. 2002-I-0017 (Washington, D.C.: March 2002). 

[81] The compact states are the Republic of the Marshall Islands, 
Republic of Palau, and the Federated States of Micronesia. 

[82] Office of Inspector General, U.S. Department of the Interior, 
Evaluation Report, Oversight and Follow-up on Audit Findings and 
Recommendations, Pertaining to the Insular Area Governments' Use of 
Federal Funding, No. 2003-I-0011 (Arlington, Va.: Feb. 28, 2003). 

[83] Office of the Inspector General, U.S. Department of the Interior, 
Report on Grants Administered by the Office of Insular Affairs, No. 
2003-I-0071 (Herndon, Va.: Sept. 30, 2003). 

[84] Pub. L. No. 106-531, 114 Stat. 2537 (Nov. 22, 2000). 

[85] These annual summaries of the top challenges facing DOI are 
published in the department's performance and accountability report. 

[86] These numbers exclude the IG's semiannual reports that present the 
results and accomplishments of the Office for the previous 6 months and 
may include information about the four insular areas. Also excluded are 
advisory reports and financial audits of the Department of the 
Interior. 

[87] As of August 10, 2006, the Territorial Auditor position, the head 
of the Office, remained unfilled. 

[88] The founding parties to the 1988 MOU were the Public Auditor of 
the Federated States of Micronesia, the Public Auditor of the Republic 
of Palau, the Public Auditor of the Commonwealth of the Northern 
Mariana Islands, the Territorial Auditor of American Samoa, and the 
Auditor General of the Republic of the Marshall Islands. APIPA has 
expanded to include Public Auditors from Pohnpei, Yap, Chuuk, Kosrae, 
Guam, Western Samoa, and USVI. 

[89] The IGIA, established in 1999 and reestablished in 2003, is 
charged with working with the Secretary of the Interior to identify 
insular area issues and to make recommendations to the President 
concerning federal government policies and programs. Federal agencies 
are to coordinate significant decisions and activities affecting the 
insular areas with the IGIA. 

[90] If the auditee does not agree with the audit findings or believes 
corrective actions are not required, the corrective action plan in the 
single audit should include an explanation and specific reasons of why 
the plan is not required. 

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