United States of America 

BEFORE THE FEDERAL SERVICE IMPASSES PANEL

 

In the Matter of  DEPARTMENT OF THE TREASURY OFFICE OF CHIEF COUNSEL WASHINGTON, D.C.
and NATIONAL TREASURY EMPLOYEES UNION	Case No. 04 FSIP 5

 DECISION AND ORDER

        The National Treasury Employees Union (Union or NTEU) filed a request for assistance with the Federal Service Impasses Panel (Panel) to consider a negotiation impasse under the Federal Service Labor-Management Relations Statute (Statute), 5 U.S.C. § 7119, between it and the Department of the Treasury, Office of Chief Counsel (OCC), Washington, D.C. (Employer or Counsel).

         After investigation of the request for assistance, concerning issues which arose during negotiations over a successor master collective-bargaining agreement (MCBA), the Panel determined that the parties should meet with Panel Member Mark A. Carter to assist them in resolving any outstanding issues.  Thereafter, if any issues remained unresolved, the parties were informed that the Panel would take whatever action it deems appropriate to resolve the matter, which could include the issuance of a binding decision.

            Pursuant to this procedural determination, Member Carter convened an informal conference with the parties on March 8 and April 19, 2004, at the Panel’s offices in Washington, D.C.  During the course of those meetings, however, the parties remained deadlocked.   The Panel has considered the entire record, including the parties’ final offers and post-conference statements of position.

 BACKGROUND 

       The Employer’s mission is to serve America’s taxpayers fairly and with integrity by providing correct and impartial interpretation of the internal revenue laws and the highest quality legal advice and representation for the Internal Revenue Service (IRS).  The Union represents a bargaining unit of approximately 1,600 professional and non-professional employees.  Of those, about 1,000 are attorneys assigned to the Employer’s headquarters office in Washington, D.C. and field offices nationwide; the remainder of the bargaining unit consists of paralegals and administrative support personnel.  The parties’ current MCBA, which was implemented in 1992 for an initial term of 3 years, has been extended until a successor agreement is in place.[1]/

ISSUES 

      The parties disagree over contract provisions concerning hours of work, awards, details and the payment of bar dues.

POSITIONS OF THE PARTIES

1.     Article 5, Work Schedules

            a.     The Union’s Position

       In essence, the Union proposes that the parties conduct a 1-year pilot of a 4/10 & compressed work schedule (CWS) in two Associate Areas within the Headquarters office and four field offices; support personnel participation would be limited to only one participant in offices where there are three to five support personnel, two in offices where there are six to eight support personnel, and three in offices where there are nine or more support personnel; support personnel in the same Associate Area or field office would not be permitted to have the same regular day off (RDO).  The flexible band for workhours would be from 6:30 a.m. to 10 p.m.; employees who work a 4/10 CWS and those on their 8-hour day under a 5-4/9 CWS, would be permitted to begin work at 6 a.m.[2]/  Core hours for all employees, regardless of the type of work schedule, would be from 10 a.m. to 3 p.m.  With respect to employee travel, in the event that “changes in Federal law authorize compensation to Federal employees for travel outside of duty hours, employees will be compensated in accordance with such statutory authority.”  The standard for disapproving individual work schedule requests should be the adverse agency impact standard as defined in 5 U.S.C. § 6131(b)[3]/ of the Federal Employees Flexible and Compressed Work Schedules Act (Act).[4]/  Whenever possible, an employee involuntarily reassigned to a different work unit would be permitted to retain the work schedule the employee had prior to the reassignment.  Finally, the Union also proposes that current practices among offices concerning the use of sign in/out sheets be retained.

      A 1-year pilot 4/10 CWS should be implemented to test its effect on employee working conditions and agency operations.  The Employer has raised no allegations of adverse agency impact and, since a 4/10 CWS has never been tried before, there is no evidence that it would cause such an impact in terms of productivity, costs, or the level of services provided to customers.  Although the number of employees who would be eligible to participate in a 4/10 CWS would be relatively small, a 1-year test period would provide the parties with data enabling them to determine whether the schedule should be continued and/or expanded to include a broader group of employees.  Congress has expressly noted the benefits of alternative work schedules, and passed a law authorizing their implementation.  To address the Employer’s concern regarding potential coverage problems, its proposal places special limitations upon support staff participation in a 4/10 CWS.  Furthermore, if at any time during the pilot period the Employer believes that the 4/10 CWS is causing an adverse agency impact, it can come to the Panel to seek its termination.  A 4/10 CWS would provide greater workhour flexibility for commuters, many of whom must travel to offices in Washington, D.C., where traffic congestion is nationally known.  Moreover, a 4/10 CWS is a more “family-friendly” work schedule which would allow employees time on their RDOs to attend to family matters without having to use leave; if employees do not have to use leave, they would be available to perform the work of the Agency.  In other cases involving flexible and/or compressed schedules, the Panel has favored the implementation of a test period so that parties may develop the evidence needed to determine their long-term feasibility.  Without such evidence, an employer’s objections to a 4/10 CWS are largely speculative.  Finally, employees within the IRS with whom Counsel attorneys interact have had the right to work a 4/10 CWS for several years. 

       With respect to the flexible band, one that ranges from 6:30 a.m. to 10 p.m. should be adopted for employees who work a flexitour schedule or flexitour with credit hours.  The current morning flexible band, which begins at 7 a.m., is unnecessarily restrictive and does not permit commuters to avoid morning traffic congestion, which has worsened since the MCBA was last negotiated in 1992.  Rush hour, in most major metropolitan areas, starts long before 7 a.m., and permitting an earlier start time for employees would help reduce employee commuting times.  Other Federal agencies in Washington, D.C. allow their employees to begin work even earlier, at 6 a.m., including some within the Department of the Treasury.  The Employer already has agreed to allow employees who work a 5-4/9 CWS to start as early as 6 a.m., thereby acknowledging that there is work available for employees to perform between 6 and 7 a.m.  Moreover, in the Employer’s recent announcement of new library hours to begin at 6:30 a.m., it noted that 6:30 a.m. is the start of “the normal workday.”  Lengthening the flexible band to 10 p.m. is warranted inasmuch as the Employer has agreed, for the first time, to permit employees to work 3 credit hours, non-contiguous to their regularly-scheduled workday.  A longer flexible band would give employees the opportunity to work their regular schedule, commute home, attend to family needs, and then work additional hours (pre-approved by a supervisor) up to 10 p.m. 

      Core hours should be changed to 10 a.m. to 3 p.m. from 10 a.m. to 3:30 p.m.  This would permit employees who would start work at 6:30 a.m. under the Union’s flexible band proposal to work an 8-hour day and leave at 3 p.m.  They could fulfill the core hour requirement and leave their offices just prior to rush hour, thereby avoiding traffic congestion.  IRS employees, with whom Counsel employees interact, may leave as early as 2:30 p.m.

      Although the parties agree, essentially, that employees who perform work while traveling may be eligible to earn credit hours, the Union’s proposal would guarantee that any changes in Federal law concerning compensation while in a travel status supersede the contract’s provisions.  In this regard, the Senate recently has passed legislation authorizing agencies to compensate Federal employees for time spent in travel status; the measure currently is before the House of Representatives for consideration.  If passed, employees could be compensated for the time spent traveling outside normal duty hours.  The proposal would ensure that if the legislation is enacted, employees would receive greater benefits than those which the parties have agreed to.

      Its proposal concerning the approval/disapproval of individual work schedule requests should be adopted because it gives an employee the opportunity to revise a work schedule request if an initial request is rejected by the supervisor.  The Union and management would be permitted to informally resolve problems, which should circumvent the need to initiate grievance actions.  Moreover, requiring the Employer to base a rejection of all schedules upon the adverse agency impact criteria in 5 U.S.C. § 6131, would help to ensure that schedules are not denied for reasons that fall short of the statutory standards.  Permitting employees who have been involuntarily reassigned to a new work unit to retain their old work schedule “whenever possible” would help maintain consistency in employee work schedules.  Ultimately, however, the Employer would have the right to determine whether a change in the employee’s schedule is necessary.  With respect to employees’ signing in and out at work, the practice currently in effect should be retained because there is no demonstrated need to change it; thus, offices would be able to continue the use of sign in/out sheets.  Maintaining the status quo would avoid the need for repetitive office-by-office local bargaining on this subject; furthermore, other methods of keeping track of workhours are available to the Employer besides using sign in/out sheets.

                b.     The Employer’s Position

      Basically, the Employer opposes the implementation of a 4/10 CWS pilot.  It would retain the current flexible band, from 7 a.m. to 6:30 p.m.,[5]/ and core hours from 10 a.m. to 3:30 p.m.  The standard for disapproving work schedules would vary slightly from the adverse agency impact standard defined in 5 U.S.C. § 6131(b) of the Act.  If there are changes to a work unit that have not already been addressed in this section, employees would be able to retain their work schedules, whenever possible, absent a showing of adverse agency impact.  A “time accounting method” negotiated locally by the various offices should be implemented to help the Employer verify that employees who work under a flexible or CWS are maintaining the proper number of hours in a biweekly pay period.

         If a 4/10 CWS pilot is implemented it may be difficult for the Employer to continue to provide the high level of services its customers expect.  In this regard, since the IRS’s reorganization in 2000, it has requested significantly more assistance from Counsel in “up-front services and advice,” such as the examination of tax returns, collecting appropriate amounts of taxes, performing public outreach, and other related tax matters.  Under a 4/10 CWS, employees would be available only 4 days a week, and fewer days during business hours to field calls from opposing counsel and the public.  In addition, permitting support personnel to participate may result in coverage problems.  Over the past 5 years, the number of support staff has been reduced by 50 percent; thus, a 4/10 CWS would exacerbate an already low support-staff-to-attorney ratio.  The 4/10 CWS proposed by the Union also would allow support personnel to start work as early as 6 a.m.  They typically are not needed that early to answer telephone calls.  Furthermore, the proposed pilot would allow the 4/10 CWS to remain in place even after a year, while the parties negotiate over whether it should be retained, modified or terminated.  Since the Panel has previously stated that termination of a CWS, absent mutual agreement, can only occur under the requirements of the Act, employers face significant hurdles to eliminate such schedules after they have been implemented.  Therefore, it is likely that the pilot would remain in effect for a much longer period of time than the proposed 1-year period.

        The current flexible band of 7 a.m. to 6:30 p.m., and core hours from 10 a.m. to 3:30 p.m., should continue because there is no demonstrated need to change the status quo which has been in effect since 1992.  These hours best meet the needs of the Employer, who is expected to be responsive to customers during normal business hours.  Very little work comes into offices before 7 a.m., nor do telephones require answering, so the current starting time would ensure that employees are available when they are needed.  This is the same starting time as many of the IRS employees that Counsel assists.  Core hours should continue to end at 3:30 p.m., and not at 3 p.m., because a longer workday permits employees to interact with private practice attorneys who tend to work later hours.  If core hours were to end 30 minutes earlier, the Employer’s ability to perform its mission may be impeded.  Although management has agreed to allow employees who work a 5-4/9 CWS the option of starting work as early as 6 a.m. on their 8 9-hour days, they should not be permitted to start work earlier than 7 a.m. on their 8-hour day for the reasons stated above.  Finally, with respect to the work schedules of employees who have changed work units, whenever possible they would be permitted to retain their work schedules absent a showing of adverse agency impact by the Employer.  This would establish a reasonable standard for determining whether an individual work schedule should continue, or be terminated or modified. 

CONCLUSIONS

      After careful consideration of the evidence and arguments presented by the parties on these issues, we conclude that the dispute over this article should be resolved on the basis of the Union’s final offer.  With respect to the implementation of a 1-year 4/10 CWS pilot program, the Employer’s mission-related arguments appear speculative.  In addition, contrary to its view that a 4/10 CWS would not provide any potential benefits to management, a 4/10 CWS is available to many of the IRS employees with whom Counsel employees interact.  For this reason, its availability to a test group of attorneys within the OCC could result in greater assistance to customers.  The Employer’s claim that the 4/10 CWS could remain in effect long after the 1-year test period ends also is unpersuasive.  Under § 6131(c)(3) of the Act, employers have the right to file a request for Panel assistance seeking the termination of a CWS at any point they believe they can substantiate that an adverse agency impact is occurring.  The Panel is required, statutorily, to take action within 60 days of receiving a perfected request.  In our view, there are adequate safeguards in effect to protect the Employer should the 4/10 CWS adversely affect its operations.  Without a test period, however, the impact of a 4/10 CWS would be unknown.

      As to the flexible band, the Employer’s position is inconsistent with its agreement to permit employees working 5-4/9 CWSs or pre-approved credit hours to start as early as 6 a.m.  In our view, employees would benefit from the opportunity to start work before 7 a.m., given the increases in traffic congestion in metropolitan areas since the MCBA was last negotiated.  Moreover, some IRS employees, with whom Counsel employees interact, have the ability to start work before 7 a.m.  Thus, it may make sense for Counsel employees to have that same option in order to maintain Counsel’s high level of service to its customers.  On the issue of core hours, it is unclear that reducing them by 30 minutes would have the significant impact on its mission that the Employer alleges, and its concern in this regard is counter-balanced by the reduction in evening commuting times employees are likely to experience if they are permitted to leave the workplace by 3 p.m. 

      Turning to the parties’ dispute over the approval and disapproval of individual work schedule requests, the Employer’s proposed standard for disapproving work schedules, which refers to “work units,” does not mirror the statutory definition of adverse agency impact found in 5 U.S.C. § 6131(b) of the Act, nor does the Employer provide a rationale for the deviation.  The Union’s wording, on the other hand, adheres more closely to the statutory definition of “adverse agency impact.”  As to the Union’s proposal concerning changes in the law regarding compensation while in a travel status, we see no basis for denying employees the benefits of future legislation simply because of the timing of the resolution of this dispute.  Finally, in regard to the issue of the use of sign in/out sheets and other time accounting methods, there is no evidence in the record that the Employer has been unable to verify that employees on existing flexible schedules or CWSs are not working the proper number of hours in a biweekly pay period.  Accordingly, for the reasons provided above, we shall order the adoption of the Union’s final offer on the issues in dispute.

2.    Article 14, Awards

      a.     The Union’s Position

       The Union proposes, essentially, to implement a 1-year pilot of an awards system that would permit the Employer to determine whether to fund a performance awards program; awards, step increases, etc., would be based on objective assessments of performance without discrimination in connection with the President’s “Pay-for-Performance Goals” for Federal employees.  Employees rated “outstanding” would receive 3-percent of salary as an award, those rated “exceeds fully successful” would receive 2 percent, and those rated “fully successful” would receive no more than 1½ percent.  Management could pay different amounts than the percentages noted above, however, if it chooses to use the same estimated percentage of salaries and expenses allocated by the IRS under its negotiated agreement for bargaining-unit awards, or the same estimated percentage of salaries and expenses allocated for non-bargaining unit awards.  The Employer would be required to notify the Union annually of the estimated funding levels for the bargaining unit awards pool for the fiscal year.  For bargaining-unit employees, the Union would be provided with the name, type and amount of award and the basis for which it was granted.  At the end of 1 year, the parties would analyze awards distribution data and assess the fairness and impact of the distribution, and either party would be permitted to reopen the awards article, as well as the issues of quality step increases, special act or service awards, and manager awards.

     Its proposal would bring needed change to the current awards system, which is “arbitrary, unfair and bears no relation to performance,” and has resulted in employees feeling underappreciated and cheated.  Awards figures show that for Fiscal Year (FY) 2003, similarly-situated bargaining-unit employees within the same grade, but in different divisions, received awards that varied by as much as $1,170.  There are also unexplained “vast discrepancies” between awards issued to headquarters and field bargaining-unit employees, and among similarly-situated headquarters and field employees, field employees receive substantially more “large-sized” awards ($2,000 or greater).  Non-bargaining unit employees typically receive a far greater portion of awards money, including the executive members of the Employer’s bargaining team, who have awarded themselves $20,000 to $25,000.  If the Employer continues its current methods of distributing awards, it is likely to run afoul of Equal Employment Opportunity (EEO) regulations.  If EEO violations are found, it would have to make reparations, including attorney fees, directly from appropriated funds that otherwise should be used to administer the tax system. 

     The Union’s proposal should also be adopted because it is modeled after Department of the Treasury Regulations applicable to the OCC, and follows the wording in those regulations with few exceptions.  Under its proposed first option, the Employer basically would be following regulations in existence since 1986; awards would be required only for those rated “outstanding” or “exceeds fully successful;” for employees who receive ratings below those levels, the Employer would have the discretion to issue awards.  In addition, the proposal is consistent with the Administration’s goal of paying more to people who do more.  Finally, a pilot program would give the parties an opportunity to study its effect after a 1-year period and permit either party to reopen the awards program if changes need to be made.

      b.     The Employer’s Position

      For the most part, the Employer proposes that the wording in the current contract article on awards be retained.  In this regard, the program would reward employee achievement, and focus on “Sustained Superior Performance Awards,” which are to be based on employees’ overall performance appraisal ratings.  Each January, the Union would be provided with information concerning the names, award amounts, and the organizational component of employees who were granted awards for the previous fiscal year.  Also, the Union would be notified concerning employees who achieved “excellent” or “exceeds fully successful” ratings or above, but who were not provided an award.  Failure to provide an award to an employee who achieves a specific performance rating would not, in and of itself, be the basis for an employee grievance.

      The proposal is consistent with the Panel’s view that management should retain discretion to distribute performance and incentive awards.  The Employer’s history of issuing awards demonstrates that it has a “robust awards program” in effect.  In FY 2003, 64 percent of bargaining-unit employees received awards averaging $1,330; in FY 2002, 58 percent received awards averaging $1,225; and in FY 2001, 63 percent received awards averaging $1,437.  The proposal would continue to grant the Employer the discretion to authorize higher awards for managers.  Although this is something the Union decries, it is justified because bargaining-unit employees and managers are not similarly situated.  Managers are responsible for carrying out key program objectives, and are held accountable when they are not met.  Moreover, the Employer has both bargaining-unit attorneys and managers at the same GS-15 grade level.  Without the flexibility to issue larger awards to managers there would be little incentive for these employees to remain in the ranks of management.

CONCLUSIONS

      Having fully considered the parties’ evidence and arguments concerning the Awards Article, we are persuaded that the Employer’s final offer provides the better approach for resolving their dispute.  The first option proposed by the Union appears to be based on the Government-wide Performance Management Personnel System (PMRS), which required that percentages of salary be awarded to managers depending upon their performance ratings.  The PMRS was abolished by Congress in 1993, however, primarily because agencies wanted more flexibility to develop their own performance management systems.  The other options available to the Employer under the Union’s proposal also would result in what amounts to a mandatory awards system.  As we have stated elsewhere,[6]/ the Panel believes that limitations upon the discretion to distribute performance and incentive awards should not be unilaterally imposed upon management.  In our view, the Union’s proposal would limit the Employer’s discretion to use an effective management tool – the ability to reward excellent performance and enhance the likelihood that those employees most deserving of merit increases will continue to serve the Government.  Accordingly, we shall order the adoption of the Employer’s final offer on this article.

3.    Article 24, Details

      a.     The Union’s Position

      The Union proposes that “(a)n employee who is detailed to a position of a higher grade for at least 1 pay period will be temporarily promoted, if eligible, and receive the rate of pay for the position to which temporarily promoted.”  This same wording has been in the current contract since 1992, and the Employer has failed to demonstrate a need to change the provision.  It allows employees who are assigned to higher graded duties to be compensated for that work, assuming that certain criteria are met, i.e., the duties must be associated with those of an established higher graded position, and the employee assigned to those higher graded duties must meet time-in-grade requirements, as well as all other mandatory qualification requirements for the position.  It is only fair that employees who are assigned to higher graded duties be appropriately compensated after performing them for a minimum of 2 weeks.  A long-standing ruling of the Comptroller General indicates that employees may be compensated for higher graded work performed on either a formal or an informal detail.[7]/  Essentially, the proposal would help to ensure that employees receive the pay they are entitled to for performing more complex work.  If employees are compensated fairly for performing higher graded work, they are not likely to file grievances.    

      b.     The Employer’s Position

        The Employer’s proposal is identical to the Union’s except that it would require employees to be temporarily promoted and compensated accordingly only when they are on “formal” details.  Adding the requirement for a “formal” detail reflects the true intent of the parties when the article was originally negotiated.  In this regard, it was intended that an SF-52 form be executed before the employee could be temporarily promoted and receive the pay of a higher graded position.  Since a detail involves an employee changing positions for a specified period of time, including the word “formal” would make it clear that unless the detail is accompanied with the necessary paperwork, the work assignment is not a detail for which the employee may be temporarily promoted and receive additional compensation.  Its position is consistent with the Supreme Court’s decision in United States v. Testan, 424 U.S. 392 (1976), which stated that employees who perform duties similar to those performed by higher graded employees are not entitled to receive higher graded pay; rather, an employee is entitled only to the pay of the position to which the employee is appointed.  The adoption of its proposal would prevent employees from filing grievances over whether the work they are performing at their current grade level constitutes higher graded duties for which they should be promoted and compensated.

  CONCLUSIONS

      Upon full consideration of the parties’ positions on this issue, we find that their impasse over the details article should be resolved on the basis of the Employer’s proposal.  In our view, its wording is clearer regarding the conditions that must be met for an employee to receive a temporary promotion and higher rate of pay for performing the work of a higher graded position.  By requiring details to be “formal,” it would limit the potential for grievances by employees who have not been temporarily assigned to a higher graded position but, nevertheless, believe they are performing work deserving higher compensation.  For such employees, the more appropriate avenue is to request an audit of their position to determine whether a reclassification may be in order.  For these reasons, the Employer’s final offer shall be adopted.

4.   Bar Dues

     a.     The Union’s Position

      The Union proposes that the Employer reimburse attorneys in the bargaining unit for bar dues as follows:  the first year of the MCBA, $100; second and third years, $155 or the amount of dues required of attorneys for admission to the District of Columbia bar, whichever is greater.  Attorneys who pay bar dues on a biennial basis would receive the entire amount of the fees, subject to the cap limitations above; if an employee’s bar dues are less than the cap, the employee would be reimbursed only for the actual amount of the dues.  Employees admitted to more than one bar would receive reimbursement only for the least expensive one.

      The proposal is reasonable because it limits payments to the “actual” costs of the “least expensive” bar to which the employee belongs, and is consistent with recent legislation permitting the Federal government to make such payments.  While the amount of the reimbursement is modest, a bar dues subsidy nevertheless would go a long way to improving employee morale.  Increasingly, the standard practice in the legal community is for employers to pay the bar dues for attorneys.  Bar dues for the District of Columbia are referenced in the proposal because that is where most bargaining-unit attorneys are members.  Finally, the payment of bar dues is not unprecedented in the Federal sector.  Another Federal agency, the Federal Deposit Insurance Corporation (FDIC), also pays dues for bargaining-unit attorneys represented by NTEU.

         b.     The Employer’s Position

      The Employer opposes subsidizing bar dues for bargaining-unit attorneys primarily on the basis of cost.  Although it offered to pay an annual subsidy of $100 towards bar dues, beginning in FY 2005, during the informal conference, that was part of a package deal to resolve all the issues in dispute which was ultimately rejected by the Union.  Paying bar dues would be extremely costly for the Employer given the large number of attorneys in the bargaining unit.  Moreover, the Employer is reluctant to incur such a financial obligation given the “current lean budget situation.”  Paying bar dues would require a significant expenditure of funds from a small agency which already has agreed to other financial benefits for employees, such as transportation subsidies, child care subsidies for its lower income employees, and a “Human Resources Investment Fund” which pays the tuition of employees who take outside educational courses designed to enhance and develop employee skills.  There simply are not enough funds available to pay for every benefit. 

CONCLUSIONS

      After carefully considering the evidence and arguments presented by the parties on this issue, we are persuaded that the Employer’s position should be adopted.  Based on the evidence in the record, it does not appear that the subsidization of bar dues by employers is a common practice within the Federal sector.  In fact, only one other Federal agency was cited by the Union and, unlike the Employer, FDIC does not operate on appropriated funds.  Given the cost of its proposal for a bargaining unit that includes  approximately 1,000 attorneys, and the lack of tangible benefits to the Agency, we shall order the Union to withdraw its proposal.

ORDER

      Pursuant to the authority vested in it by the Federal Service Labor-Management Relations Statute, 5 U.S.C. § 7119, and because of the failure of the parties to resolve their dispute during the course of proceedings instituted under the Panel’s regulations, 5 C.F.R. § 2471.6(a)(2), the Federal Service Impasses Panel under § 2471.11(a) of its regulations hereby orders the following:

1.    Article 5, Work Schedules

         The parties shall adopt the Union’s proposals.

2.    Article 14, Awards

         The parties shall adopt the Employer’s proposal.

3.    Article 24, Details

         The parties shall adopt the Employer’s proposal.

4.    Bar Dues

      The Union shall withdraw its proposal.

By direction of the Panel.

Ellen J. Kolansky 
Acting Executive Director

June 30, 2004
Washington, D.C.