The Tax Exempt and Government Entities Division Could
Improve the Efficiency of Its Advance Ruling Follow-Up Process
August 2003
Reference Number:
2003-10-141
This report has cleared the Treasury
Inspector General for Tax Administration disclosure review process and
information determined to be restricted from public release has been redacted
from this document.
August
22, 2003
MEMORANDUM FOR
Commissioner, Tax Exempt and Government
Entities DIVISION
FROM: Gordon C. Milbourn III /s/ Gordon C.
Milbourn III
Assistant Inspector General for Audit (Small Business and
Corporate Programs)
SUBJECT: Final Audit Report - The Tax Exempt and
Government Entities Division Could Improve the Efficiency of Its Advance Ruling
Follow-Up Process (Audit # 200210051)
This
report presents the results of our review of the advance ruling follow-up
process. The overall objective of this
review was to evaluate the Exempt
Organizations (EO) function’s process of following up on advance rulings and
appropriately classifying the exempt organizations.
In
summary, the EO function implemented
several changes in the processing of Foundation Follow-Up cases in 2002. The changes resulted in different personnel
assuming responsibility for processing these cases. We determined that the current method for conducting Foundation
Follow-Up reviews is a labor-intensive, manual process resulting in few changes
to the foundation status of the tax exempt organizations. In addition, the financial information requested
from tax exempt organizations during the Foundation Follow-Up process is
already provided by those organizations that annually file a Return of
Organization Exempt From Income Tax (Form 990). We determined that 78 percent of the exempt organizations in
which a Foundation Follow-Up was necessary in Fiscal Year 2001 were required to
file a Form 990. By making better use
of available information on the Form 990, EO function management could more
efficiently perform Foundation Follow-Up work.
This would reduce the burden on some of the exempt organizations and may
allow more effective use of available EO function resources. We estimate that up to 10.73 Full-Time
Equivalents (FTE) could be reallocated to more productive oversight of exempt
organizations, such as determination or examination work, if available
financial information was used.
We also determined that an
Internal Revenue Service (IRS) computer system does not always contain accurate
information related to exempt organizations that have been reclassified as
private foundations during the Foundation Follow-Up process.
We recommended that the
Director, EO, pursue alternative approaches to more efficiently conduct
Foundation Follow-Up reviews. In
addition, we recommended that the Director, EO, reemphasize the use of an
available management information report and create a new closing code on the
Employee Plans/Exempt Organization Determination System to ensure this system
contains accurate foundation status and filing requirement information.
Management’s Response: The
Commissioner, Tax Exempt and Government Entities Division, agreed to initiate
changes in response to the recommendations made in this report. The Director, EO Rulings and Agreements, has
given the Form 990 redesign group and the Form 990 e-filing initiative office 6
months to develop recommendations for using Form 990 information to determine
foundation status. The Director, EO
Rulings and Agreements, will request recommendations from the Manager, EO
Determinations, regarding ways to ensure the accuracy of the Electronic
Determination System (EDS). The EO
function expects to implement the redesign of the EDS by December 31,
2005. The Tax Exempt Determination
System team will be asked to address the issue of creating a closing code for
presumptive rulings during the redesign phase.
Management’s complete response to the draft report is included as Appendix VIII.
Copies of this
report are also being sent to the IRS managers who are affected by the report
recommendations. Please contact me at
(202) 622-6510 if you have questions or Daniel R. Devlin, Assistant Inspector
General for Audit (Headquarters Operations and Exempt Organizations Programs),
at (202) 622-8500.
The Foundation Follow-Up Process Can Be More Efficiently
Performed
Foundation Follow-Up Case Information Is Not Always Updated on the Computer System
Appendix I – Detailed Objective, Scope, and Methodology
Appendix II – Major Contributors to This Report
Appendix III – Report Distribution List
Appendix IV – Outcome Measures
Appendix V – Results of Detailed Case Analyses
Appendix VII – Schedule A, Part IV-A, of Form 990
Appendix VIII – Management’s Response to the Draft Report
An organization desiring to obtain recognition of its tax exempt status can apply under Internal Revenue Code (I.R.C.) Section (§) 501(c)(3) to the Internal Revenue Service (IRS) for a determination of its exempt status. If the organization’s application and supporting documents establish that it meets the particular requirements of I.R.C. § 501(c)(3), the Exempt Organizations (EO) function of the Tax Exempt and Government Entities (TE/GE) Division will issue a determination letter to the organization. The determination letter will affirm that the organization is exempt under I.R.C. § 501(c)(3). A determination as to whether the organization is publicly supported may also be made by issuing either a “definitive ruling” or an “advance ruling.”
Definitive rulings are given
if organizations meet the requirements of the law and have completed at least 8
months of their first year of operation.
Advance rulings, based on Treasury Regulations, are given when
organizations have not completed a tax year of at least 8 months. In an advance ruling, charitable
organizations are granted a determination that they will be considered a
publicly supported organization during a specified “advance ruling”
period. The advance ruling period is
usually 5 years from the date of formation of the exempt organization and is
tracked on the Employee Plans/Exempt Organizations Determination System
(EDS). At the end of the advance ruling
period, EO function personnel request that the organizations substantiate the
amount of public support they have received for the 5-year period. “Foundation Follow-Up” is the term applied
to this practice. The EO function
closed 14,223 Foundation Follow-Up cases in Fiscal Year (FY) 2002 and
16,458 cases in FY 2001.
I.R.C. § 501(c)(3) defines tax exempt charitable organizations. Once an organization has been granted exemption under I.R.C. § 501(c)(3), it can be classified as either a public charity or a private foundation. A publicly supported organization derives its financial support from governmental units and/or donations, grants, ticket sales, and similar efforts. By contrast, a private foundation is supported by a limited number of sources and may be liable for some taxes. It is more desirable for an organization to be classified as a public charity than as a private foundation. Contributions to public charities are tax deductible to the extent of 50 percent of the donor’s adjusted gross income (AGI). Private foundation contributions are generally limited to 30 percent of the donor’s AGI. Also, certain excise taxes are imposed on private foundations.
If an organization cannot substantiate public support after the 5-year advance ruling period, it is considered a private foundation as of the effective date of exemption under I.R.C. § 501(c)(3). The organization may be required to file a limited Return of Private Foundation (Form 990-PF) for each year covered by the advance ruling period. The adverse determination letter informing the organization of its change to a private foundation will also include instructions about the Form 990-PF filing requirements.
A former Ohio District Office of Research and Analysis study issued in 1999 reviewed the Foundation Follow-Up process. This study recommended that the EO function propose a change in the Treasury Regulations to eliminate the requirement of issuing advance rulings to reduce both the burden on charitable organizations and the cost to the IRS.
This audit was performed in accordance with Government Auditing Standards from September 2002 through April 2003. The audit was performed by interviewing EO function employees at the TE/GE Division Headquarters in Washington, D.C., and the Cincinnati Area Office, and by reviewing samples of closed Foundation Follow-Up cases. Detailed information on our audit objective, scope, and methodology is presented in Appendix I. Major contributors to the report are listed in Appendix II.
The current method for conducting Foundation Follow-Up reviews is a labor-intensive, manual process resulting in few changes to the foundation status of the exempt organizations. By making better use of available information on the Return of Organization Exempt From Income Tax (Form 990), EO function management could more efficiently perform Foundation Follow-Up work. This would reduce the burden on some of the exempt organizations and may allow more effective use of available EO function resources.
The processing of Foundation Follow-Up cases is very labor-intensive
To perform Foundation Follow-Up work, EO function personnel must conduct the following steps:
·
Review EDS reports on a monthly basis and
manually generate letters requesting the necessary financial information for
all exempt organizations whose advance rulings end in that month.
· Send an additional letter (called a presumptive ruling) informing the organization that it is presumed to be a private foundation if the organization does not respond or does not provide sufficient financial information.
·
Review the financial information (if
provided) to determine whether the organization is a public charity or private
foundation. If more information is
needed, additional contacts with the organization will be made. The type of financial information requested
by the EO function from tax exempt organizations is shown in Appendix VI.
·
Issue a closing letter indicating the EO
function’s determination of foundation status to those organizations that
provided sufficient financial information.
·
Update IRS computer systems to reflect
any changes to foundation status and associated filing requirements.
·
Copy to microfiche all case file
information and retain as required.
Our review of sampled cases showed that the EO function performed the required follow-up reviews and properly classified the organizations as public charities or private foundations. Specifically, we determined that EO function personnel took action on all exempt organizations requiring follow-up during our audit period. In addition, we determined that EO function personnel properly determined whether these organizations were public charities or private foundations based upon their review of the financial information provided.
We did identify that the EO function did not always timely request the financial information from organizations, according to established procedures, and did not always make a timely final determination of foundation status after receipt of the financial information. However, in general, the EO function’s untimeliness in sending the letters to request financial information did not affect the organizations’ ability to provide the information to the EO function within the statutorily required time period. In addition, once the financial information was received, approximately 50 percent of the untimely determinations of foundation status were less than 30 days late. The delays in these two processes were primarily due to the large number of advance rulings requiring follow-up at the end of the year, the manual nature of the work, and the EO function’s limited staffing in this program area.
For Foundation Follow-Up cases closed during FY 2001, EO function employees charged 23,912 hours to review financial information and contact the tax exempt organizations for additional information, if needed. In addition, EO function management estimates that another 4,825 hours were charged in FY 2001 to generate and issue follow-up letters, control cases on the EDS, issue any letters informing the organizations that they are presumed to be private foundations, copy case files to microfiche, and store case documentation. This equates to a total of 13.8 Full-Time Equivalents (FTE) for this program.
Foundation Follow-Up cases usually result in no change to the foundation status of the exempt organization
The EO function rarely changes the foundation status of an exempt organization based upon the Foundation Follow-Up process. For example, EO function management conducted EDS research and determined that 560 (3.4 percent) of the 16,458 advance rulings in FY 2001 resulted in an adverse determination (i.e., a change in foundation status from public charity to private foundation). Our review of 173 cases closed during FY 2001 identified only 4 adverse determinations (2.3 percent). In FY 2002, information on the EDS indicated that 459 (3.2 percent) of the 14,223 advance rulings resulted in an adverse determination. This trend continued into FY 2003, where our review of 74 cases closed during the first quarter of that year identified only 2 adverse determinations (2.7 percent).
The financial information requested during the Foundation Follow-Up process is already provided by those organizations that annually file Form 990
Most tax exempt organizations are required to file a Form 990 if their gross receipts are greater than $25,000 per year. Schedule A, Part IV-A, of the Form 990 (shown in Appendix VII) is required for all I.R.C. § 501(c)(3) entities filing a Form 990 and includes financial data for the past 4 years. This is the same financial information organizations are required to provide for their Foundation Follow-Up reviews. The Schedule A of Form 990 also requires the organization to substantiate that it is publicly supported. Each year, when exempt organizations file Form 990, they must complete a public support test using the prior 4 years of financial data on the Schedule A of the Form 990.
Currently, some Schedule A data are transcribed by IRS personnel into a computer system to update the exempt organization’s account on an IRS database. On a weekly basis, any new information is taken from this database and added to the TE/GE Division’s Return Inventory and Classification System (RICS) for use by EO Examination function personnel. The information transcribed includes most of the financial data necessary to determine foundation status, but not the results of the public support test.
Our analysis of all the exempt organizations which had an advance ruling period ending in FY 2001 showed that 78 percent (14,502 of 18,565) were required to file a Form 990, including Schedule A. If the three additional lines showing the results of the public support test from the Schedule A of the Form 990 were transcribed and available on the RICS, EO function personnel could more efficiently perform Foundation Follow-Up work. By researching the RICS for advance ruling cases, EO function personnel may be able to determine if organizations that have filed a Form 990 qualify as a public charity or private foundation without contacting the organization. This alternative process could greatly reduce both the amount of manual processing by EO function personnel and the burden on tax exempt customers.
Using the figure of 13.8 FTEs estimated for time worked on Foundation Follow-Up cases in FY 2001, the EO function could reallocate up to 78 percent of these resources, or 10.73 FTEs, to more productive oversight of exempt organizations, such as determination or examination work.
In addition, the TE/GE Division could eliminate the need for exempt organizations to provide information during the advance ruling process that has already been provided during the annual Form 990 filing. The remaining 22 percent of exempt organizations that do not have filing requirements would still have to submit their financial information for review.
Furthermore, the public support test information on the RICS could be used by EO Examination function personnel to ensure continued compliance by exempt organizations. EO Examination function personnel could research the public support test results for exempt organizations that have been given a definitive ruling and that file Forms 990 to ensure they are still operating with the proper levels of public support.
The IRS is also in the process of developing an electronic filing system for Forms 990 that will capture 100 percent of the information on the Form 990 and any attachments. The system’s initial deployment is scheduled for January 2004. If transcription of the additional information from the Schedule A of the Form 990 is not feasible, the TE/GE Division should consider using this information when the Form 990 electronic filing initiative is implemented.
1. The Director, EO, should pursue alternative approaches to more efficiently conduct Foundation Follow-Up reviews, such as transcribing additional data from the Form 990 onto the RICS or using the data from electronically filed Forms 990 once this system is deployed.
Management’s Response: The Director, EO Rulings and Agreements, has given the Form 990
redesign group and the Form 990 e-filing initiative office 6 months to develop
recommendations to use Form 990 information to classify organizations as
publicly supported at the end of their 5 year advance ruling period.
An IRS computer system does not always contain accurate information related to exempt organizations that have been reclassified as private foundations during the Foundation Follow-Up process. Specifically, we selected 2 limited samples totaling 70 exempt organizations reclassified as private foundations from public charities (20 definitive adverse rulings and 50 presumptive rulings) and determined that 22 organizations did not have their foundation status or tax filing requirements updated on the Exempt Organizations Business Master File (EOBMF). This update is important because when the type of return filed by an exempt organization does not match its filing requirements on the IRS computer system, the processing of the return will be delayed until the IRS can resolve the reason for the inconsistency. If the cause of this inconsistency is that the filing requirements were not updated, it could result in inefficient use of IRS resources because of unnecessary taxpayer contacts and increased burden on the exempt organization.
An adverse determination results in an exempt organization’s foundation status changing from public to private, which affects the filing requirements of the tax exempt entity. Definitive adverse rulings are a result of exempt organizations providing financial information that indicates they are not publicly supported. When a definitive adverse ruling is closed on the EDS using a certain closing code, the exempt organization’s new foundation status and filing requirements are systemically updated to the EOBMF after the case passes two separate validity tests. If the case fails the first validity check (due to EDS inconsistencies), it is listed on an error report and resolved by EO Determination function personnel. If the case fails the second validity check (due to EOBMF inconsistencies), it is resolved by Small Business/Self-Employed (SB/SE) Division personnel at the Cincinnati Campus.
Presumptive rulings are similar to adverse determinations in that the exempt organization’s foundation status changes from public to private. However, the closing code used to close presumptive rulings on the EDS does not systemically update the exempt organization’s foundation status and filing requirements on the EOBMF. Instead, EO function personnel must manually update the EOBMF with the new information.
Definitive adverse determination information is not always updated to the EOBMF
We selected a random sample of 20 definitive adverse
determinations closed in FY 2001 to determine if the EOBMF was properly updated
with the new foundation status and filing requirements of the entities. Four exempt organizations (20 percent) never
had their IRS computer records systemically updated to reflect the change from
a public charity to a private foundation.
One of these four organizations has since been terminated. After we informed EO function personnel of
the remaining three cases, they took the necessary action to ensure accurate
information was input to the EOBMF.
EO function management did not know why the four exception cases were never updated to the EOBMF. One of the cases failed the initial EDS validity checks and should have appeared on the EDS error report for resolution by EO function personnel. Another case passed the initial EDS validity check and was forwarded to the EOBMF for the second validity check. We contacted SB/SE Division personnel at the Cincinnati Campus and determined that reports showing EO function cases that failed the second validity check are received by SB/SE Division personnel for resolution. We are not making a recommendation related to SB/SE Division actions on this case because another Treasury Inspector General for Tax Administration audit has evaluated the effectiveness of the TE/GE Division’s oversight to ensure SB/SE Division personnel are effectively resolving filing errors associated with TE/GE Division returns. In the remaining two cases, there was insufficient information to determine which validity check stopped information from being updated to the EOBMF.
Presumptive ruling determination information is not always updated to the EOBMF
We selected a random sample of 50 presumptive ruling cases closed in FY 2001 to determine if the EOBMF was updated to reflect both the change in the organization’s status to a private foundation and the revised filing requirements. In three cases, we did not have adequate documentation to determine if the information was updated as required. In the remaining 47 cases, we determined that 18 did not have their foundation status or filing requirements manually updated at the time of case closing to reflect their change to a private foundation. In 6 of the 18 cases, the information was never updated on the EOBMF as required; however, EO function management indicated that the exempt organizations subsequently provided information to support their public charity status. As a result, information on the EOBMF is now accurate and does not need to be changed. After we brought the remaining 12 cases to EO function management’s attention, they ensured that the correct foundation code and filing requirements were input to the EOBMF.
To address the conditions
identified above, we recommend that the Director, EO:
2.
Reemphasize that the EDS
error report needs to be effectively resolved to ensure accurate foundation
status and filing requirements are updated on the IRS computer system.
Management’s Response: The Director, EO
Rulings and Agreements, will request recommendations from the Manager, EO
Determinations, regarding ways to ensure accurate EDS information is provided
to the EOBMF.
3. Create a separate closing code on the EDS (and the new Tax Exempt Determination System [TEDS] under development) that systemically updates the EOBMF for presumptive ruling cases, similar to the closing code for definitive adverse rulings.
Management’s Response: The TEDS team will address this issue for the EO function during the TEDS redesign phase, expected to be implemented by December 31, 2005.
Appendix I
Detailed Objective, Scope,
and Methodology
The overall objective of this audit was to evaluate the Exempt Organizations (EO) function’s process of following up on advance rulings and appropriately classifying the exempt organizations. The following tests were performed to accomplish this objective:
III.
Determined if
the EO Determination function updated the filing requirements on the Exempt
Organizations Business Master File for organizations reclassified as private
foundations (definitive and presumptive rulings) on the EDS based on the
financial information provided for the advance ruling period.
A.
Selected 2 judgmental samples totaling 70 Foundation
Follow-Up cases closed during FY 2001 that consisted of 20 organizations (from
a population of 558) reclassified as private foundations based on sufficient
financial information provided for the advance ruling period and 50
organizations (from a population of 370) reclassified as private foundations
based on insufficient financial information provided for the advance ruling
period.
Appendix II
Major Contributors to This Report
Daniel R. Devlin, Assistant Inspector General for Audit
(Headquarters Operations and Exempt Organizations Programs)
Nancy Nakamura, Director
Jeffrey
M. Jones, Audit Manager
Cheryl Medina, Senior Auditor
Michael McGovern, Auditor
Marjorie Stephenson, Auditor
Appendix III
Commissioner N:C
Deputy Commissioner for Services and Enforcement N:SE
Director, Exempt
Organizations, Tax Exempt and Government Entities Division T:EO
Director, Communications and Liaison, Tax
Exempt and Government Entities Division
T:CL
Chief Counsel CC
National Taxpayer Advocate
TA
Director, Office of Legislative Affairs CL:LA
Director, Office of
Program Evaluation and Risk Analysis
N:ADC:R:O
Office of Management Controls N:CFO:AR:M
Appendix IV
This appendix presents detailed information on the measurable impact that our recommended corrective action will have on tax administration. These benefits will be incorporated into our Semiannual Report to the Congress.
Type and Value of Outcome Measure:
· Inefficient Use of Resources – Potential; 10.73 Full-Time Equivalents (FTE) (see page 3).
Methodology Used to Measure the Reported Benefit:
The current method for conducting Foundation Follow-Up reviews is a labor-intensive, manual process resulting in few changes to the foundation status of the exempt organizations. In Fiscal Year (FY) 2001, 23,912 hours were charged to Foundation Follow-Up cases closed on the Employee Plans/Exempt Organizations Determination System (EDS). In addition to this time, an estimated 4,825 hours were spent by administrative staff to issue letters, control case files, copy case files to microfiche, and retain case files of Foundation Follow-Up cases.
By using the same type of financial information reported on the Return of Organization Exempt From Income Tax (Form 990) for the Foundation Follow-Up review, the Exempt Organizations (EO) function may be able to reallocate resources to more productive oversight of exempt organizations, such as determination or examination work. We identified that 78 percent of exempt organizations with advance ruling end dates in FY 2001 had a Form 990 filing requirement. By multiplying the total number of hours (28,737) by 78 percent, we arrived at a total of 22,415 hours that could be reallocated to other EO function processes.
We then divided the 22,415 hours by the total number of hours per FTE to determine the total number of FTEs that could be reallocated.
28,737 hours multiplied by 78 percent = 22,415 hours
22,415 hours divided by 2,088 hours = 10.73 FTEs
Type and Value of Outcome Measure:
· Taxpayer Burden – Potential; 14,502 taxpayers (see page 3).
Methodology Used to Measure the Reported Benefit:
An EDS extract included 18,565 exempt organizations with advance ruling end dates in FY 2001. Of these taxpayers, 14,502 also had a Form 990 filing requirement on the EDS. These organizations provide the same financial information during their Foundation Follow-Up reviews that they have already reported on their Forms 990. By using the information reported by the organizations on their Forms 990, EO function personnel may be able to eliminate the need for organizations to send in their financial information for the advance ruling period as well as any corresponding customer contact.
Type and Value of Outcome Measure:
· Reliability of Information – Actual; 22 taxpayers (see page 8).
Methodology Used to Measure the Reported Benefit:
We reviewed 2 random samples totaling 70 exempt organizations reclassified as private foundations from public charities (20 definitive adverse rulings and 50 presumptive rulings). Our review showed that 22 of the 70 exempt organizations did not have their foundation status or tax filing requirements updated on the Exempt Organizations Business Master File (EOBMF). This update is important because when the type of return filed by an exempt organization does not match its filing requirements on the Internal Revenue Service’s (IRS) computer system, the processing of the return will be delayed until the IRS can resolve the reason for the inconsistency.
Appendix V
Results of Detailed Case
Analyses
The following three tables summarize the detailed case analyses performed to determine if the Exempt Organizations (EO) function: (1) followed up on all advance rulings and whether the follow-up was timely and (2) timely classified Foundation Follow-Up cases and whether they were properly classified as public charities or private foundations.
Table 1: Sample of Cases With Advance Ruling End Dates in Fiscal Year 2001
|
Total Cases
Sampled |
Total Cases
Reviewed* |
Cases Followed
Up on as Required |
Cases Followed
Up on Timely |
Cases Followed
Up on Untimely |
Inadequate
Documentation for Timeliness Determination** |
|---|---|---|---|---|---|
|
298 |
296 |
296 |
16 |
185 |
95 |
* Two cases did not meet our selection criteria.
** Documentation was not available to make a definitive determination on the timeliness of the follow-up actions taken.
We selected a sample of cases from each of two Employee Plans/Exempt Organizations Determination System extracts to determine the timeliness of Foundation Follow-Up case processing. Our results are summarized in Table 2. We then requested the case files for the same two samples to determine if the exempt organizations were properly classified as public charities or private foundations. These results are summarized in Table 3.
Table 2: Sample of Closed Foundation Follow-Up Cases
- Timeliness
|
|
Total Cases Reviewed |
Timely Processed |
Untimely Processed |
|---|---|---|---|
|
Fiscal Year 2001 |
191 |
119 |
72 |
|
First Quarter Fiscal Year 2003 |
75 |
31 |
44 |
Table
3: Sample of Closed Foundation
Follow-Up Cases – Proper Classification
|
|
Total Cases Sampled |
Total Cases Reviewed* |
Properly Classified |
Not Properly Classified |
Inadequate Documentation |
|---|---|---|---|---|---|
|
Fiscal Year 2001 |
191 |
173 |
173 |
0 |
0 |
|
First Quarter Fiscal Year 2003 |
75 |
74 |
72 |
1** |
1*** |
* The EO function could not locate 19 cases (18 from the Fiscal Year 2001 sample and 1 from the Fiscal Year 2003 sample).
** The caseworker did not receive all the necessary information from the exempt organization to make a definitive ruling. Based on established procedures, the exempt organization should have been presumed to be a private foundation instead of maintaining its public charity status. EO function management indicated that the caseworker made a judgment call that it was in the best interest of the Internal Revenue Service to approve the organization’s public charity status after reviewing the incomplete financial information, which reported typical sources of income for that type of organization.
*** The financial information obtained from the organization was not in the case file, so we could not determine if the EO function properly classified the exempt organization.
Appendix VI
Form 8734 was removed due to its size. To see the Form, please go to the Adobe PDF version of the report on the TIGTA Public Web Page.
Appendix VII
Schedule A, Part IV-A, of Form 990 was removed due to its size. To see the Schedule, please go to the Adobe PDF version of the report on the TIGTA Public Web Page.
Appendix VIII
The response was removed due to its size. To see the complete response, please go to the Adobe PDF version of the report on the TIGTA Public Web Page.