The following summarizes the major findings resulting from the Audit of Overtime Expenditures at the Solid Waste Division of the Department of Public Works (AC-03-60-99).
Background (pages 1 to 2)
– The Virgin Islands Government paid, excluding fringe benefits, $15.9 million and $17.8 million in overtime costs during 1997 and 1998.
Finding 1 – Overtime Approval (pages 5 to 6)
– The Solid Waste Division of the Department of Public Works incurred $593,000 and $477,000 in overtime costs in 1997 and 1998, most without documented approval.
– Overtime work was not planned in advance, and was verbally approved on a daily basis without regard to budgetary constraints.
– As a result, services were duplicated, and significant, unsupervised and sometimes questionable overtime work was being claimed.
Finding 2 – Excessive Overtime Claims (pages 7 to 8)
– Three employees were paid $328,000, or 30% of the Solid Waste overtime costs in 1997 and 1998.
– The employees claimed as much as 100 hours of work per week, or 14 hours per day, 7 days a week for the two-year period.
– One employee assigned to help reduce overtime, instead contributed to it.
– Another employee, living on Public Works property and working as a "mechanic on call", also claimed to have worked an average of 14 hours per day, 7 days a week.
Finding 3 – Employee Absenteeism and Shortages (pages 12 to 13)
– Employee absenteeism was not being adequately controlled in order to reduce the need for overtime.
– Over the two-year period about 9,670 hours was lost due to paid and unpaid leave.
– Three employees were chronically absent for work, being absent from 48% to 62% of the time.
– The absenteeism and staff shortages contributed to the need for overtime work.
Finding 4 – Union Contracts (pages 14 to 15 )
– Government negotiations agreed to beneficial overtime provisions that resulted in a 28% increase in Solid Waste overtime costs.
– These provisions are costing the Government an estimated $2.7 million to $5.0 million in additional overtime costs.
August 2, 1999
Honorable Charles W. Turnbull
Governor of the Virgin Islands
Government House
Kongens Gade
St. Thomas, Virgin Islands 00802
Honorable Vargrave A. Richards
President
23rd Legislature
Capitol Building
St. Thomas, Virgin Islands 00802
Dear Governor Turnbull and Senator Richards:
Attached is the final report of our audit of overtime expenditures at the Solid Waste Division of the Department of Public Works.
The objectives of the audit were to determine if overtime payments were: (i) authorized and adequately accounted for; and, (ii) monitored to ensure that they were necessary, reasonable and performed.
Our review showed that Public Works did not have control of overtime costs. Specifically, we found that: (i) Solid Waste employees were claiming significant amounts of overtime without documented approval; (ii) there was no monitoring to ensure that overtime was actually needed and worked; (iii) chronic employee absenteeism contributed to the need for some Solid Waste employees to work overtime; and, (iv) government negotiators agreed to overtime provisions that were overly beneficial to union employees.
A draft report was issued on July 7, 1999, with a response due by July 28, 1999. The Commissioner of Public Works and the Chief Labor Negotiator, in their responses to the draft report, agreed with the recommendations made. Based on the responses, we consider each recommendation resolved; however, at a later date we will review the status of implementation. Appendix I beginning on page 16 and Appendix II beginning on page 26 details the responses received.
If you or your staff require additional information, please call me at 774-6426.
Sincerely,
Steven van Beverhoudt, CFE, CGFM
Inspector General
BACKGROUND
During the process of identifying expenditures and potential cost savings for the Virgin Islands Government, reviews of overtime expenditures incurred by the Executive Branch were initiated. In calendar years 1997 and 1998, records at the Department of Finance (Finance) showed overtime payments, excluding related fringe benefits, of $15.9 million and $17.8 million respectively. The following summarizes the overtime costs for the two years.
Department/Agency —– 1997 —————— 1998
Police ———————– $5,146,000———— $5,770,000
Justice (Corrections)— 2,092,000———— 1,942,000
Public Works—————– 1,526,000————– 1,629,000
Juan Luis Hospital———– 1,452,000————– 1,859,000
Roy Schneider Hospital—– 1,406,000————– 1,506,000
Health ——————— 1,043,000————- 1,190,000
Fire Service———— 685,000——————1,380,000
All Others————- 2,538,000———– 2,488,000
——————- $15,888,000———— $17,764,000
The Department of Public Works (Public Works), selected for review of overtime costs, paid $1.5 million in 1997 and $1.6 million in 1998 for overtime work claimed by its employees. The Solid Waste Division (Solid Waste) of Public Works accounted for $593,000 or 40% in 1997 and $477,000 or 30% in 1998 of the total Public Works overtime costs.
The responsibility of solid waste management for the Virgin Islands Government is vested in Public Works. Title 19 Section 1553 of the Virgin Islands Code (Code) requires Public Works to among other things: (i) develop and implement a solid waste management plan for the territory; (ii) oversee the collection and disposition of waste; (iii) issue permits and oversee the private collection, storage, salvage, and recovery of waste; and, (iv) issue citations for violations of waste disposal rules and regulations.
Solid Waste was given the responsibility to manage the collection and disposal of solid waste as required by the Code. As part of its collection responsibilities, Solid Waste operated two garbage collection shifts. The first shift was from 5 a.m. to 1 p.m., and the second shift was from 2 p.m. to 10 p.m.. Solid Waste had six garbage trucks available for this purpose; however, on average only four trucks were operating on a daily basis. In accordance with provisions of employee union contracts, each truck was required to be staffed with one driver and two collectors. During fiscal years 1997 and 1998, Solid Waste employed 7 drivers and 14 collectors.
Employees at Solid Waste were represented by two unions, the Seafarers International Union (SIU) and the Maritime Engineers Beneficial Association (MEBA). The SIU collective bargaining agreement stipulated that workers were to be compensated for overtime work at one and a half times their regular rate for the first eight hours worked over 40 hours and double time after 48 hours in a work week. The MEBA contract stipulates that employees were to be compensated at one and a half times their regular rate for any overtime work performed over an 8-hour day, 5-day work week. Work done on the second day of two days off in a week and holidays was to be compensated at double time.
For other government employees not covered by a collective bargaining agreement, Title 3 Section 560 of the Code states that employees would be paid at one and a half times their regular rate for any overtime worked, and double time for work done on a holiday.
OBJECTIVES AND SCOPE
The objectives of the audit were to determine if overtime payments were: (i) authorized and adequately accounted for; and, (ii) monitored to ensure that they were necessary, reasonable and performed.
Our audit was performed at Public Works and Finance, and covered overtime charges for calendar years 1997 and 1998.
As part of our review, we evaluated the internal controls over the approval and payment of overtime cos
ts to the extent necessary to accomplish the audit objectives. Weaknesses identified during the review are discussed in the Audit Results section of this report.
Except for limitations to our independence as detailed in the succeeding two paragraphs, the audit was performed in accordance with "Government Auditing Standards" issued by the Comptroller General of the United States. We included tests and procedures that were considered necessary under the circumstances.
The second General Standard states; "In all matters relating to the audit work, the audit organization and the individual auditors, whether government or public, should be free from personal and external impairments to independence, should be organizationally independent and should maintain an independent attitude and appearance."
Under the current organizational structure, the Virgin Islands Bureau of Audit and Control (Audit Bureau) is not organizationally independent. Budget and personnel limitations have adversely affected the Audit Bureau's ability to fully carry out its responsibilities.
PRIOR AUDIT COVERAGE
We are unaware of any audits of overtime costs conducted during the last five years.
CONCLUSIONS
Our review showed that Public Works did not have control of overtime costs. Specifically, we found that: (i) Solid Waste employees were claiming significant amounts of overtime without documented approval; (ii) there was no monitoring to ensure that overtime was actually needed and worked; (iii) chronic employee absenteeism contributed to the need for some Solid Waste employees to work overtime; and, (iv) government negotiators agreed to overtime provisions that were overly beneficial to union employees.
As a result of these conditions: (i) Solid Waste spent about $1.1 million in overtime costs during the two-year period of 1997 to 1998; (ii) required authorization and overtime request forms were not prepared to justify and substantiate the overtime payments; (iii) three employees were paid $328,000, representing 30% of the total Solid Waste overtime costs for the two-year period; (iv) the three employees were averaging over 14 hours of work per day, 7 days a week during the same period; (v) an employee transferred to assist a supervisor to reduce the need for overtime, instead contributed to the problem by both employees claiming significant overtime hours; (vi) an employee, who was allowed to live on Public Works property rent-free, was also being compensated for claimed work averaging 14 hours per day, 7 days a week; (vii) three employees were continuously absent from work, one as much as 62% of the time, resulting in other employees being required to work overtime; and, (viii) union contracts with generous overtime provisions resulted in $302,000, or 28%, in additional overtime costs.
FINDING 1: OVERTIME APPROVAL
Solid Waste incurred $593,000 and $477,000 in overtime costs in 1997 and 1998 without documented approval. In addition, overtime work was not planned in advance, and approval was made verbally on a daily basis without regard to budgetary constraints. This resulted in duplicate services being provided at the supervisory level; significant, unsupervised and sometimes questionable overtime work being claimed by some employees; and excessive payments being made by Public Works.
Prior Approval
Public Works officials indicated to us that, although there were no written procedures available, it was standard policy to require approval of overtime work in advance. A form was devised to identify the individuals required to perform the overtime work, the period of coverage, and the work to be performed. Final approval was required of the Commissioner. It was stated, however, that because of the continuous problems with solid waste collections, advance overtime was not requested. Rather, overtime was approved on a daily basis by the Assistant Commissioner. These verbal approvals were granted without ensuring that there were sufficient funds to cover the costs. As a result, Public Works has recently been forced to impose strict limitations on spending in order to avoid over obligating their budget.
There were no records to show that the overtime work was performed. The only evidence of overtime claims was the weekly time cards of the various employees. Questions related to the accuracy of the time cards will be discussed in the finding related to excessive overtime claims.
The lack of documented approval and monitoring of requests for overtime resulted in instances where individuals were claiming significant amounts of overtime work with no evidence to show the work was performed. For example:
– One employee claimed to have worked an average of 6 hours per day in overtime over a two-year period, without the supervisor's advance approval. This employee, on most occasions, was given assignments from three supervisors from different divisions within Public Works. The claimed hours assigned by these supervisors were not documented; as a result, no supervisor was able to account for the time allegedly worked by the employee. In addition, this individual was allowed to reside at Public Works following Hurricane Marilyn in 1995. He has only recently been asked to vacate the premises. A more detailed discussion on the impact of this employee's overtime can be found in the finding on excessive overtime claims.
– Another employee was assigned to assist a supervisor in the performance of various responsibilities at Solid Waste. The assignment was to alleviate the high rate of overtime work being claimed by the supervisor. The reassignment, however, did not alleviate the problem, but rather contributed to it, because both individuals were claiming overtime for almost two years. They averaged between 10 and 14 hours of work a day for each individual. This situation is discussed in more detail in the finding on excessive overtime claims.
Recommendations
We recommend that the Commissioner of Public Works:
1. Enforces procedures requiring documented approval of requests for overtime.
2. Ensures that the purpose for overtime work is properly documented.
3. Ensures that sufficient funds are available before overtime is approved.
Public Works' Response
The Commissioner of Public Works indicated agreement with the recommendations made in this section of the report. Draft procedures were submitted to the Office of Collective Bargaining for review and agreement by the respective unions.
Inspector General's Comments
We consider the response to the recommendations in this section to be sufficient for us to consider them resolved. At a later date, we will review the progress of implementation. FINDING 2: EXCESSIVE OVERTIME CLAIMS
During 1997 and 1998, three Solid Waste employees were paid $328,000, or 30% of the total Solid Waste overtime costs for the two-year period. The employees were averaging as much as 100 hours of work per week, or 14 hours per day, 7 days a week. One of the employees was assigned to help reduce the need for overtime, instead significantly contributed to it. Another employee, who was allowed to live on Public Works property rent-free, was also claiming to have worked an average of 14 hours per day, 7 days a week.
Background
In 1996, Solid Waste management consisted of four individuals, a director, a superintendent, and two supervisors. These individuals performed the management and supervisory responsibilities of Solid Waste. During the year, however, three of the four positions became vacant, resulting in only one supervisor being responsible for the management duties.
In 1997, the Assistant Commissioner of Public Works assigned a litter enforcement officer to assist the one remaining supervisor in managing the operations of Solid Waste. The individual was to be trained in order to alleviate the need for the supervisor to work long overtime hours. Since there were two 8-hour shifts per day, each supervisor would have been responsible for supervisory work for one shift.
In addition to these two employees, Sol
id Waste employed a mechanic who also claimed a substantial amount of overtime work. This individual was allowed to live on Public Works property rent-free after Hurricane Marilyn, and was allegedly "a mechanic on call". It was claimed that the individual also performed various services for other divisions within Public Works.
Overtime Analysis
We conducted an in-depth review of each of these employees' overtime payments, since, as previously indicated, they represented 30% of the entire Solid Waste overtime costs. As indicated in the first finding on overtime approval, there are no records to show prior approval of overtime work claimed nor evidence to show the work allegedly done. Our review, therefore, was limited to an analysis of the time and attendance records, time clock records, and interviews. The following is a summary of our analysis.
Supervisor. In an effort to assist in the management of Solid Waste, the Assistant Commissioner of Public Works assigned a litter enforcement officer to assist with supervisory duties. However, this assistance did not materialize in alleviating the overtime claimed by the supervisor. The assistance only served to compound the overtime costs to Solid Waste. This occurred because the work time was not shared between the two employees, rather, both employees claimed to have worked simultaneously on both shifts claiming almost identical hours of work.
For each year under review, 1997 and 1998, the supervisor claimed to have worked an average of 14 hours per day, 7 days a week and 10 hours per day, 7 days a week respectively. No vacation, sick, or any type of leave was taken, and hours worked were claimed for every holiday except for one day. The supervisor's regular salary was $23,495, and with overtime payments of $78,576 and $53,344 in 1997 and 1998, this individual's gross salary was $102,071 and $76,839 respectively.
During 1997, the supervisor was paid for a total of 5,085 hours. The total consisted of 2,080 hours at the regular rate of pay, 376 hours at time and a half, and 2,629 hours at double time. These hours also included 144 holiday hours claimed to have been worked. As previously stated, no vacation, sick or any type of leave was taken in 1997. For the 365 days in the year, the supervisor averaged 98 hours of claimed work per week, or 14 hours per day, 7 days a week.
For 1998, the supervisor was paid for a total of 3,608 hours. The claimed time consisted of 2,080 hours at the regular rate of pay, 384 hours at time and a half, and 1,144 hours at double time. There was a total of 176 hours of holiday time available, all of which were allegedly worked. No vacation, sick, or any type of leave was taken in 1998. For the 365 days under review, the supervisor was paid for an average of 69 hours per week, or 10 hours per day, 7 days a week.
During our audit work in 1998, Public Works curtailed overtime payments allegedly, because of budgetary limitations. The supervisor indicated to us, however, that although overtime was not being paid, a record was being kept for possible payment in the future.
We also reviewed the time clock records of this employee, and the results of this review will be discussed in the section of this report dealing with time clock records.
Litter Enforcement Officer. During 1997, a litter enforcement officer was assigned to assist the Solid Waste supervisor in managing the operations. However, after a period of training, instead of sharing the duties in order to alleviate the need for the excessive overtime, the individual maintained a schedule almost identical to the supervisor. This schedule continued throughout 1998 with both employees allegedly beginning and ending work at the same time of the day.
For the two-year period under review, the litter enforcement officer claimed to have worked an average of 13 hours per day, 7 days a week in 1997, and 10 hours per day, 7 days a week in 1998. The only leave taken was 3 ½ consecutive weeks of sick leave in 1997. The individual claimed to have worked on all but 3 holidays. The litter enforcement officer's regular salary in 1997 and 1998 was $20,574 and $22,792 respectively. However, with overtime payments of $62,042 and $30,254 in 1997 and 1998, the gross salary for the two years was $82,616 and $53,046.
During 1997, the litter enforcement officer was paid for a total of 4,758 hours. The total consisted of 2,080 hours at the regular rate of pay, 384 hours at time and a half and 2,294 hours at double time. These hours also included 128 holiday hours claimed to have been worked. No vacation leave was claimed; however, 144 hours of sick leave was used. For the 365-day period in 1997, the individual claimed to have averaged 92 hours worked per week or 13 hours per day, 7 days a week.
For 1998, the litter enforcement officer was paid for a total of 3,474 hours. This consisted of 2,080 hours at the regular hourly rate, 416 at time and a half and 978 hours at double time. Included in the double time hours were 176 hours for holidays. The employee took no vacation, sick or other leave in 1998. For the 365-day period, the employee averaged 67 hours per week, or 10 hours per day, 7 days a week.
As previously indicated, when the audit was started in 1998, overtime was curtailed by Public Works due to budgetary constraints.
Mechanic. An individual employed as a mechanic was allowed to claim and be paid for significant amounts of overtime in 1997 and 1998. In addition to being employed as a mechanic, this individual also performed other duties for various divisions within Public Works. As with the other employees, there were no records to show the work performed that warranted the amount of overtime claimed. In addition, this employee was allowed to live on Public Works property rent-free after Hurricane Marilyn in 1995.
For the two-years period, the mechanic claimed to have worked an average of 14 hours per day, 7 days a week. Except for the first pay period in 1997, no vacation, sick or other leave was claimed. In addition, it was claimed that work was performed on all holidays during the period. The employee's base salary was $17,520; however, with $55,940 and $59,062 in claimed overtime, the gross salary was increased to $73,460 and $76,582 in 1997 and 1998 respectively.
During 1997, the mechanic was paid for 5,176 hours, consisting of 2,080 regular hours, 352 hours at time and a half and 2,744 hours at double time. Included in the double time hours were 128 holiday hours. For the 365-day period in 1997, the individual claimed to have averaged 99.5 hours worked per week, or 14 hours per day, 7 days a week.
For 1998, the employee was paid for 5,224 hours. This time consisted of 2,080 regular hours, 416 hours at time and a half and 2,728 hours at double time. There were 176 hours of holiday time for which work was allegedly done. No type of leave was taken in 1998. For the 365-day period in 1998, the mechanic claimed to have worked an average of 100.5 hours per week, or 14 hours per day, 7 days a week.
Time-Card Records. We also reviewed the time-card records for several employees at Solid Waste. This review also raised concerns as to the accuracy of the information it contained. Individuals were punching in and out within a few minutes of each other, for both the morning and the afternoon shifts. As an example, the three employees previously discussed, all punched in and out for the morning and afternoon shifts at the same time for the week of February 23 to March 1, 1997. This situation occurred on numerous occasions during the 2-year period reviewed. It was claimed that the employees all come to work at the same time; however, we question the likelihood of the employees coming in at the same time for the first shift at 5 a.m. each morning and punching out at 1 p.m., with the second shift punching in together at 2 p.m. and out at 10 p.m. consistently week after week. The supervisor also alleged that on several occasions employees completed their assignments and were allowed to leave early; however, the supervisor punched out for them at the en
d of the regular shift. This resulted in some employees being compensated for overtime not worked.
Recommendations
We recommend that the Commissioner of Public Works:
1. Refers the overtime situation to the V.I. Attorney General for possible investigation.
2. Strictly enforces the monitoring of claimed overtime by employees. Hold supervisors responsible for the approval of claimed overtime work.
3. Ensures that all overtime is adequately documented and approved in advance.
Public Works' Response
The response indicated agreement with the three recommendations made. The Commissioner indicated that any potential disciplinary action would be guided by the Department of Justice. In addition, supervisors have been instructed on the appropriate procedures and record keeping required to document overtime costs.
Inspector General's Comments
We consider all three recommendations resolved, and will review the status of implementation procedures at a later date.
Regarding the referral of the overtime costs to the Department of Justice, we have already been in contact with that agency.
FINDING 3: EMPLOYEE ABSENTEEISM AND SHORTAGES
Solid Waste did not adequately control employee absenteeism in order to reduce the need for overtime. Total work hours lost due to leave with or without pay totaled 9,670 hours over the two-year period. Disciplinary action was not taken against three employees in particular, who were excessively absent from work. Absenteeism by these three employees ranged from 48% to 62%. Staff shortages also contributed to the need for Solid Waste employees to work overtime.
Background
Solid Waste in carrying out its garbage collection responsibilities, operated two shifts. The first shift from 5 a.m. to 1 p.m. used four garbage trucks. On the second shift, from 2 p.m. to 10 p.m., two trucks were used. There were six garbage trucks in the fleet, however only four were operational at a given time. In accordance with the existing union contract, each truck was required to have one driver and two collectors. For the period reviewed, there were 7 drivers and 14 collectors employed at Solid Waste.
Absenteeism
Our analysis of time and attendance records showed a significant amount of absenteeism. Within Solid Waste, the total manpower hours lost due to leave totaled 9,670 hours over the two-year period. This resulted in Public Works having to pay overtime for each hour not worked by an employee. There were three collectors with chronic absenteeism ranging from 48% to 62%. Public Works officials were aware of the problem, however, disciplinary actions were not taken to correct the abuse. For example:
– Out of a possible 2080 hours of available regular time in a given year, a collector was actually on the job for 775 hours in 1997 and 874 hours in 1998. This represents an attendance record of 38% and 42% respectively.
– Another collector reported to work for 1,090 hours in 1997 and 781 in 1998, representing an attendance record of 53% and 38% respectively.
– The final collector reported to work for 1,073 hours in 1998, an attendance record of 52%.
Public Works officials, when questioned, were aware of the absentee problem; however, actions were not taken to discipline abusers. Due to an already understaffed unit, high levels of absenteeism required employees to work overtime, this situation further contributed to the already high amount of overtime costs.
Staff Shortages. Solid Waste does not have enough employees (7 drivers and 14 collectors) to maintain the current level of garbage collection without incurring substantial overtime costs. As previously stated, Solid Waste had four trucks on any given day available for garbage collection, making a total of six pick up trips per day. Also, as per the union contracts, each truck is required to have one driver and two collectors. Given this scenario, Solid Waste would need a minimum of 8 drivers and 16 collectors assigned exclusively to garbage collection. These 8 drivers and 16 collectors, along with the elimination of absenteeism, would significantly reduce the amount of overtime required.
Recommendations
We recommend that the Commissioner of Public Works:
1. Takes disciplinary action against employees who abuse leave benefits, and are chronically absent from work.
2. Develops and strictly enforces in conjunction with the respective unions, policies and procedures dealing with leave and excessive instances of absenteeism.
3. Requests authorization to employ additional drivers and collectors to eliminate the need for overtime work.
Public Works' Response
Public Works agreed with the three recommendations made. In conjunction with the unions, steps to address the absentee records of the three employees identified in the report have been initiated. In addition, written policies have been developed, and are pending review by the Office of Collective Bargaining and unions. Finally, requests to fill vacant positions to reduce overtime costs have been submitted.
Inspector General's Comments
Based on the responses made, we consider the recommendations resolved. We will review this area at a later date.
FINDING 4: UNION CONTRACTS
Government negotiators agreed to generous overtime policies that have resulted in a 28% increase in overtime costs to Solid Waste. Government wide, it is estimated that between $2.7 million and $5.0 million can be attributed to this provision of union contracts.
Criteria
Some union contract provisions require that employees be paid at one and a half times the regular rate for the first 8 hours of overtime worked in a 40-hour work week. Any time worked over 48 hours in a week will result in the employee being paid at twice the hourly rate.
Title 3, Section 560 of the Code, governs the overtime compensation for employee not covered by collective bargaining agreements. It states that employees would be paid at one and a half times the regular rate for any overtime worked, and double time for work done on holidays.
Time and a Half versus Double Time
Our analysis of overtime costs for Solid Waste showed that during 1997 and 1998 over $164,000 and $138,000 in additional overtime costs were incurred because of the generous overtime provisions in the union contracts. These costs represented 28% and 29% of the overtime costs paid by Solid Waste in 1997 and 1998.
Based on these percentages we estimate that the government paid as much as $5.0 million in additional overtime costs because of the double time provision in existing union contracts. This amount does not include the related fringe benefits. In light of the fiscal crisis currently encountered by the government, we feel that negotiations should be initiated with the various unions in an effort to seek concessions in overtime cost. Even if we use a more conservative rate of 15%, the change from double time to time and a half will result in savings of $2.7 million, again excluding related fringe benefits.
Recommendation
We recommend that the Chief Labor Negotiator:
– Initiates discussions with the various unions in an effort to seek concessions in the double time provisions of the various union contracts.
Office of Collective Bargaining's Response
The Chief Labor Negotiator agreed with the recommendation made in this section of the report. It was indicated that steps to get union concessions to the double time provisions will be initiated.
Inspector General's Comments
We consider this recommendation to be resolved. At a later date we will review the status of the negotiations with the unions.
Additional Issue
During the course of other overtime reviews, additional issues dealing with the time and a half/double time provision of the union contracts surfaced. These issues could have an effect on overtime payments at Public Works. They will be investigated further and reported on in a subsequent report.