|Program Title||Wetlands Reserve Program|
|Department Name||Department of Agriculture|
|Agency/Bureau Name||Department of Agriculture|
Direct Federal Program
|Assessment Section Scores||
|Program Funding Level
|Year Began||Improvement Plan||Status||Comments|
Collecting and analyzing cost and performance data to improve program management.
|Action taken, but not completed||NRCS is developing a web based program management with beta test expected to begin in 2008. Tool will then be piloted in 5 States.|
Improving WRP's ability to prioritize and focus on priority natural resource concerns.
|Action taken, but not completed||NRCS has had an independent review conducted on WRP easement compensation value. The report has identified several recommendations to improve the appraisal process. NRCS is evaluating these recommendations for appropriate actions.|
|Year Began||Improvement Plan||Status||Comments|
Improving WRP's cost effectiveness by achieving technical assistance efficiencies and reducing contract closure and easement restoration timelines.
|Completed||Completed revision of appraisal process to be consistent with FAR, allocation process, and streamlining recommendations made by OIG. Actions taken include: a team met on TA costs in May 2006 but did not complete the baselines for restoration costs. More analysis is needed to conduct a thorough review of restoration costs. Team identified measures to reduce restoration costs which were incorporated into policy.|
Measure: Percentage increase in the number of WRP projects fully restored within three years of closing the easement.
Explanation:This measure assess the percent of eligible WRP restoration projects that are completed within three years from the date of easement closing. Section 514.7(a) of the WRP Manual requires that wetland restoration activities commence within one year of easement clsoing and be completed within three years. The agency is currently performing a quality check on 2005 actual. Final figures are expected at the time the FY 2007 budget is released.
Measure: Reduced ground and surface water contamination through reduced nutriet application (tons).
Explanation:The measure reflects the program's goal of benefitting water qualit yand directly supports Objectives 2.3 and 2.4 of the NRCS Strategic Plan (2003 Update). Measured by the reduction of nutrients applied that will not enter waterways. Based on the acreage of cropland enrolled into the program and taken out of production, and nutrient application rates for the predominant cropland type.
Measure: Acres of wetlands protected by 30-year or permanent easements, cumulative.
Explanation:This measure reflects the program's goal of protecting wetlands and directly supports the Objective 2.4 of the NRCS Strategic Plan (2003 Update). Targets presume that the program will continue with current enrollment levels as provided for the President's 2006 Budget.
Measure: Percentage increase of WRP easements closed within 12 months of initial project application.
Explanation:This measure assess the percent of WRP easements that are closed within twelve moths. An easement is considered acquired as of the date of closing. This measure directly support Goal 4 of the NRCS Strategic Plan (2003 Update). The agency is currently performing a quality check on 2005 actual. Final figures are expected at the time the FY 2007 budget is released.
Measure: Percentage of protected WRP acres enrolled each year that directly benefit federally and state listed Threatened and Endangered Species.
Explanation:This measure relects the program's statutory objective for placing priority on acquiring easements that protect and enhance wildlife habitat and directly supports Objective 2.4 of the NRCS Strategic Plan (2003 Update). Species listed as threatened or endangered under the Endangered Species Act or state-level equivalent represent a particular category of "other widlife" that are national concern and significance.
Measure: Acres of wetlands created, restored, or enhanced.
Explanation:This measure reflects the acres on which conservation practices have been applied, and directly supports the Objective 2.4 of the NRCS Strategic Plan (2003 Update).
|Section 1 - Program Purpose & Design|
Is the program purpose clear?
Explanation: "The Wetlands Reserve Program (WRP) statute (16 U.S.C. 3837) provides in that the Secretary shall establish a program to assist owners of eligible lands in restoring and protecting wetlands. The WRP regulation (7 CFR Part 1467.4 (a)) provides that, ""Under the WRP, the Department will purchase a conservation easement from, or enter into restoration cost-share agreements with, eligible landowners who voluntarily cooperate in the restoration and protection of wetlands and associated lands."" NRCS places priority on enrolling acres into the program that maximize wildlife values, such as improved habitat, for migratory birds and declining species. "
Evidence: "Food Security Act of 1985, as amended ('16U.S.C. 3837); 7 CFR Part 1467 "
Does the program address a specific and existing problem, interest, or need?
Explanation: "The program focuses on restoring, enhancing, creating, and managing wetland ecosystems for migratory birds and other wetland dependent wildlife, including threatened and endangered species. Healthy wetland landscapes are productive and dynamic, providing benefits including nutrient capture and cycling, carbon sequestration, sediment retention, and surface and groundwater storage. Wetlands modulate water extremes, improve water quality, and provide valuable fish and wildlife habitat. Prior to the authorization of the WRP, government policies encouraged the conversion of wetlands to cropland through drainage and price subsidies. The conversion of native habitats to cropland led to the drainage and alteration of almost 54 % of the wetlands in this country with some states losing as much as 90 % from the 1780s to the 1980. The nation is no longer suffering a net loss of wetland acres as a result of agriculture activities; however, the nation has not replaced the historical wetland losses. "
Evidence: "NRCS Conservation Programs Manual Part 514.01 - 7 CFR Part 1467.6 "
Is the program designed so that it is not redundant or duplicative of any other Federal, state, local or private effort?
Explanation: "There are several federal conservation programs that help private landowners restore and protect wetland acres, including the Department of the Interior's Coastal Program, Partners for Fish and Wildlife Program, North American Wetlands Conservation Act Grants Program. USDA also has programs that restore and protect wetlands, including the Conservation Reserve Program and Wildlife Habitat Incentives Program (WHIP). In total, the Council on Environmental Quality's April 2005 update on the President's wetlands initiative identified 24 federal programs that restore, protect, and enhance wetland acres. WRP does differentiate itself, however, by offering permanent wetland protection on privately owned lands beyond that which is offered by any other Federal program. Other programs, such as WHIP, provide assistance to develop upland habitat and for restoring wetland habitat, but do not provide the permanent protection that WRP offers. Similarly, the Conservation Reserve Program offers restoration with annual rental agreements as protection, but only for ten- to 15-year periods. "
Evidence: NRCS Conservation Programs Manual Part 514 - 7 CFR Part 1467.
Is the program design free of major flaws that would limit the program's effectiveness or efficiency?
Explanation: WRP is designed to restore wetland functions and wildlife habitat on acres enrolled in the program. The program is voluntary. Applications are ranked and applications providing the highest environmental benefits are selected. NRCS was provided administrative authority for the program beginning in 1995. Overtime (1999 through 2004) NRCS has utilized the Oversight and Evaluation Staff to improve the delivery of WRP. Most notable efforts took place in between 1999 and 2002. In 1999 NRCS evaluated the restoration aspects of the program. As a result of the evaluation the agency implemented a series of restoration workshops specifically for WRP projects. These workshops were followed by a series on easement management.
Evidence: "NRCS Oversight and Evaluation (O&E) Reports: Easements Management FY 1999; Wetland Restoration FY 1999; WRP Compatible Use, Large Area Sites FY 2000; Farm Bill Implementation Barriers for EQIP, WRP, WHIP, and FPP Conservation Programs FY 2002; WRP Compatible Uses FY 2002; Cost of WRP Easements FY 2004. An O&E Easement Portfolio Review is being conducted in FY 2005. "
Is the program design effectively targeted so that resources will address the program's purpose directly and will reach intended beneficiaries?
Explanation: "NRCS Headquarters allocates WRP funds to state NRCS offices by a methodology that includes wetland ecological considerations (such as whether the state is in a migratory bird corridor and the rate of wetland loss in the state), state-level NRCS performance (such as average cost per acre and average time to complete restoration projects), and landowner interest in the program (such as the number and dollar value of unfunded applications). At the state level, NRCS offices develop project ranking criteria in order to target projects based on national guidelines. The development of state criteria includes input from NRCS State Technical Committees. The highest ranking applications are funded until the NRCS state office's WRP allocation is fully obligated. NRCS State Conservationists have the authority to select special projects outside of the ranking criteria when the value of the project cannot be captured in a qualitative measure, such as giving priority to a project that augments an existing or concurrent acquisition effort or an inholding in a conservation area. "
Evidence: NRCS Conservation Programs Manual, Part 514 (landowner eligibility and ranking policy); WRP allocation methology description; reauthorization of 16 U.S.C 3837 in 2002.
|Section 1 - Program Purpose & Design||Score||80%|
|Section 2 - Strategic Planning|
Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?
Explanation: "NRCS has revised its long-term performance measures to include three separate outcome measures related to its statutory purposes. 1) By 2015, at least 35% of protected WRP acres enrolled each year will directly benefit federal and state listed threatened and endangered species. This measure assesses the percent of enrolled WRP acres that directly benefit Federal and State listed threatened and endangered species. 2) By 2015 reduce ground and surface water contamination through reduced nitrogen applications. The second long-term outcome measure is related to the permanent retirement of cropland base and the environmental benefits to water quality that result from taking marginal cropland out of production and decrease the nutrient loads from productive working cropland. Measured by the number of tons of nitrogen not applied to cropland, and thereby will not enter waterways. 3) By 2015, increase tons per year of carbon sequestered. Measured by the acreage of habitat type and estimated tons of carbon sequestered for that habitat type as identified by leading carbon scientific experts. "
Evidence: "NRCS Wetlands Reserve Program, Status of Program, 2005; NRCS 2005-2006 Annual Performance Measures by Program; NRCS Logic model. "
Does the program have ambitious targets and timeframes for its long-term measures?
Explanation: Targets have been set based on the agency long-term strategic plan. The long-term performance goals that NRCS created are sufficiently ambitious given current and foreseeable contracts, and they directly support NRCS's long-term Strategic Plan.
Evidence: NRCS Wetlands Reserve Program, Status of Program, 2005; FY2006 Budget Explanatory Notes, Statement of Program.
Does the program have a limited number of specific annual performance measures that can demonstrate progress toward achieving the program's long-term goals?
Explanation: Annual performance measures include wetlands the number of acres created, restored or enhanced by WRP, and the number of wetland acres protected by 30-year or permanent easements. NRCS needs to develop an adequate WRP efficiency measure. : In addition to the annual performance measures identified in NRCS original response and OMB's comments, NRCS has identified two additional annual performance measures related to efficiency. These efficiency measures include: 1) increase the percentage of WRP easements closed within 12 months; and 2) increase the percentage of WRP projects fully restored within 3 years.
Evidence: "NRCS annual performance measures by program; PRS; NRCS Easement Management database. "
Does the program have baselines and ambitious targets for its annual measures?
Explanation: "The goals were established based on the program's authorizing language and the President's budgets. The agency initially established a goal of protecting 1.9 million acres by FY2005 and 2.1 million acres by FY2006. However, given the historic acreage enrollment authorities, and acreage reductions as a result of projects falling out after enrollment, these numbers will need to be revised to target 1.78 million acres for FY 2005 and 1.98 million acres for FY 2006. "
Evidence: "'NRCS Wetlands Reserve Program, Status of Program, 2005; NRCS logic model. "
Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) commit to and work toward the annual and/or long-term goals of the program?
Explanation: NRCS partners support and help identify the overall goals of the program, and report on performance in order to demonstrate accomplishment of the long-term and annual goals of the program. Evidence of support of the goals of the program include participation of partners from federal, state and local governmental agencies, as well as non-governmental organizations, in the State Technical Committees in order to provide advice on WRP implementation issues. NRCS has also entered into contractual arrangements (such as cooperative and contribution agreements) and memorandums of understanding regarding projects that are of common interest. Agreements may address restoration, acquisition, or management of the project area. In these circumstances where the private landowner is interested in managing the land, NRCS provides assistance to ensure the easement is being managed to meet the objectives of the easement. State NRCS offices are responsible for managing program delivery provided by WRP partners. Evidence of reporting performance includes the requirement that partners report program activity to the state NRCS office (such as the cost and time taken to perform restoration work). The state office is then responsible for reviewing costs and the quality of work performed by the conservation partners.
Evidence: "NRCS Conservation Programs Manual, Part 514.06; Various press releases; RFP sample (Arkansas). Report ""Conserving America's Wetlands, Implementing the President's Goal"", Council on Environmental Quality, Executive Office of the President, April 2005. Report available at: www.coastalamerica.gov "
Are independent evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?
Explanation: "The NRCS Oversight and Evaluation staff has conducted numerous independent evaluations of WRP, including evaluations in 1999, 2001, 2002, and 2004. The earlier evaluations were more comprehensive and provided an in-depth review of the program's effectiveness and efficiency. The more recent reviews have focused on the increasing cost of the program and are less focused on the WRP's overall effectiveness. In addition, the NRCS State Technical Committees provide consistent, ongoing evaluation of WRP delivery. These committees are organized at the state level and consist of representatives of producer organizations, commodity groups, advocacy groups, private industry, state and local governments, federal agencies and others. State Technical Committees meet quarterly, or more often as needed. They review the implementation of WRP and other programs and make recommendations on State ranking criteria and program administration. "
Evidence: "O&E reports: Easement Management in the Natural Resources Conservation Service, January 1999; Wetland Restoration Evaluation, January 1999, revised June 1999; Wetlands Reserve Program April 2001; WRP Compatible Uses, May 2002; Implementation Barriers for EQIP, WRP, WHIP, and FPP Conservation Programs, October 2002; Cost of Wetlands Reserve Program Easements, February 2004. An O&E Easement Portfolio Review is being conducted in FY 2005. "
Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?
Explanation: WRP's budget request for FY 2006 is explicitly tied to long-term and annual performance measures. The FY 2007 budget request will be directly tied to achieving WRP's long-term performance goal. Further, NRCS utilizes accomplishments and goals data to make allocation decisions to state NRCS offices. State offices that leverage more dollars and have a greater staff capacity and expenditures to manage and monitor easements receive more WRP funding. Additionally, each state office bases its WRP annual performance goals on its WRP allocation in the NRCS State Performance Plan.
Evidence: "NRCS cost of programs model; WRP Statement of Program. "
Has the program taken meaningful steps to correct its strategic planning deficiencies?
Explanation: The agency has developed three new long-term measures, and has developed baselines and targets for all three measures. In addition, the agency has conducted seven independent Oversight and Evaluation studies that have resulted in management actions taken that included training that was provided to agency employees on the development of wetland restoration plans, the development of contracts, and other actions such as WRP Manual revisions to clarify policy for landowner and NRCS responsibilities for the operation, maintenance, and management of easements.
Evidence: Oversight and Evaluation Management Action Plans
|Section 2 - Strategic Planning||Score||100%|
|Section 3 - Program Management|
Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?
Explanation: "WRP managers regularly collect performance information at both the NRCS state and national levels. Collection is generally on a quarterly basis although at the NRCS state office level it may be more frequent. NRCS developed an easement management database from which it receives quarterly updates from states offices on program performance. Information in the database is compared with information in USDA's financial management system (FFIS) to determine whether the progress reports are reasonable considering funds being spent. FFIS is also used to evaluate progress in obligating and disbursing funds. "
Evidence: "PRS; NRCS Easement Management Tool (access database). "
Are Federal managers and program partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) held accountable for cost, schedule and performance results?
Explanation: "NRCS State Conservationists are responsible and accountable for overall program implementation and results, including identifying, monitoring and analyzing performance indicators and financial integrity. The Deputy Chief for Strategic Planning and Accountability provides national oversight. At the state level, NRCS designates key personnel in the state office to coordinate WRP delivery. NRCS states that they have performance indicators in their annual performance plans; typically, these personnel have a base goal of enrolling a certain number of acres each year. State offices conduct quality assurance reviews of completed projects as well as the work performed by NRCS partners organizations that help to deliver the program. The national office bases its allocations of technical and financial assistance resources to NRCS State Offices based, in part, on performance and cost-effectiveness criteria. "
Evidence: "WRP Funding Allocation Description; Conservation Programs Manual, title 440, Part 514; Sample RFP (Arkansas). "
Are funds (Federal and partners') obligated in a timely manner and spent for the intended purpose?
Explanation: "Funds are generally obligated by September 30 each federal fiscal year. A small percentage of the program funds remain ""committed"" to enrolled projects but not ""obligated"" in the financial system for projects that were enrolled late in the year. These ""committed"" funds have historically been replaced in the following fiscal year for obligation. "
Evidence: "FFIS reports. "
Does the program have procedures (e.g. competitive sourcing/cost comparisons, IT improvements, appropriate incentives) to measure and achieve efficiencies and cost effectiveness in program execution?
Explanation: NRCS has established mechanisms to improve competition among those who are interested in implementing WRP restoration activities, including making broader use of Technical Service Providers by advertising restoration activities and limiting opportunities to utilize contribution agreements. In addition, the application ranking process established at the state level includes a cost component. NRCS will be advertising a Request for Proposals to implement the Wetlands Reserve Enhancement Program (WREP). The WREP is a mechanism where USDA delivers some aspect of WRP through a partnership arrangement. NRCS will provide NGO's, state agencies, and federal agencies an opportunity to compete for funding for projects that meet common objectives between NRCS and its partners. To improve efficiencies, NRCS developed an easement database that enables the national office to evaluate the status of each States program delivery.
Evidence: "NRCS Conservation Programs Manual, Part 514. "
Does the program collaborate and coordinate effectively with related programs?
Explanation: "NRCS collaborates with partners on many aspects of the program. Collaboration efforts include partnering with USFWS Partners for Fish and Wildlife Program on restoration activities. WRP also partners with state agencies, such as the State of Florida's Water Management Districts or the Missouri Department of Conservation on joint protection efforts, where NRCS purchases an easement and the state acquires fee title ownership. Other examples of collaboration was the recently announced partnership in Illinois where NRCS is partnering with the Nature Conservancy on a joint acquisition effort, or the recently announced delegation of administrative jurisdiction of easement management to the USFWS for the Glacial Ridge Project in Minnesota. "
Evidence: See multiple Press Releases (www.nrcs.usda.gov/news/thisweek/2003/031003/flwetlands.html; www.nrcs.usda.gov/news/thisweek/2003/031202/mtwrp.html; www.nrcs.usda.gov/news/thisweek/2004/040428/mnknightglacialridgeearthday.html); NRCS has a significant number of Memorandum of Understandings and other agreements with Federal agencies, Tribal and State governments, and non-profit organizations see (www.nrcs.usda.gov/news/archive/2005newsroom.html; www.nrcs.usda.gov/programs/wrp/states/il.html; www.nrcs.usda.gov/news/thisweek/2004/040728/dumousigning.html www.nrcs.usda.gov/technical/ECS/wildlife/03MOUPF.pdf) Conservation Programs Manual, Part 514. Report "Conserving America's Wetlands, Implementing the President's Goal", Council on Environmental Quality, Executive Office of the President, April 2005. Report available at: www.coastalamerica.gov
Does the program use strong financial management practices?
Explanation: NRCS's Financial Management Division reports that it has established internal control mechanisms. The division alerts the program manager regarding audit reports or financial irregularities. Accounting transactions for WRP are recorded in the Foundation Financial Information System (FFIS). FFIS has automated checks and balances which enforce the separation of duties, internal control for obligating and disbursing the funds. Prior to approving a payment in FFIS, the Approving Official validates the accuracy of the payment and documentation to support the transaction."
Evidence: NRCS FFIS Manual "National Finance Center Procedures, Title IX, FFIS Manual, Chapter 6, NRCS" available at: http://dab.nfc.usda.gov/pubs/docs/ffisnrcs/ffisnrcs.pdf
Has the program taken meaningful steps to address its management deficiencies?
Explanation: "NRCS has developed an easement management information system that is used by NRCS state program managers to evaluate and manage all stages of program delivery and easement management. The NRCS national office also uses this system to assess state progress with restoration activities, easement acquisition activities and easement monitoring and enforcement issues. States submit databases on a quarterly basis to the national office. NRCS NHQ has staff working for the Easement Programs Division that is assisting states with data reporting. In addition to the program improvements made as a result of Oversight and Evaluation reports, the Oversight and Evaluation team developed in November 2004 a study plan for the NRCS easement portfolio which includes WRP. The Oversight and Evaluation team is seeking avenues to improve program easement program efficiency by evaluating opportunities to eliminate redundancy, streamline program delivery and improve services to agricultural producers. "
Evidence: "Sample reports from the National NRCS Easement Management Tool; NRCS Oversight and Evaluation Reports: Easement Management in the Natural Resources Conservation Service, January 1999; Wetland Restoration Evaluation, January 1999, revised June 1999; Wetlands Reserve Program April 2001; WRP Compatible Uses, May 2002; Implementation Barriers for EQIP, WRP, WHIP, and FPP Conservation Programs, October 2002; and Cost of Wetlands Reserve Program Easements, February 2004. An O&E Easement Portfolio Review is being conducted in FY 2005. "
|Section 3 - Program Management||Score||100%|
|Section 4 - Program Results/Accountability|
Has the program demonstrated adequate progress in achieving its long-term performance goals?
Explanation: The program has developed three new long-term performance measures, and the program has demonstrated that it has made moderate progress towards achieving its long-term goals. However, because these are new performance measures and the program does not yet have several years worth of performance data to develop a trend, this question warrants a "small extent" rating.
Evidence: FY 2006 Budget Explanatory Notes.
Does the program (including program partners) achieve its annual performance goals?
Explanation: The program did not fully meet its annual performance goal to "create, restore, or enhance wetland acres" in FYs 2003 and 2004. However, the program did exceed its performance target in FY 2002. Furthermore, the program met its recent annual acreage enrollment goal of enrolling 189,144 acres (which is not a performance measure included in this PART assessment).
Evidence: "FY 2006 Budget Explanatory Notes, Statement of Program. "
Does the program demonstrate improved efficiencies or cost effectiveness in achieving program goals each year?
Explanation: NRCS has demonstrated improved efficiency over prior years. This is evidenced by the agency's efficiency measure related to increasing the number of WRP projects fully restored within three years of closing an easement. From FY 2003 to 2004 the agency improved the percentage of projects fully restored within three years by 1.3 percent. In recent years, NRCS has begun to examine ways to improve the cost effectiveness of WRP. In 2004, the agency conducted an Oversight and Evaluation (O&E) Team assessment that reviewed why the costs of WRP easements have increased substantially in recent years. The report provided some options managing the program's growing costs. NRCS has also evaluated the implementation of WRP performance through several other O&E reviews. Agency leadership established a series of workshops on wetland restoration which have since been converted to agency courses offered through the National Employee Development Center. In addition, the agency provided workshops regarding easement management that take place on a recurring basis that are designed to transfer information regarding program efficiencies to improve the overall effectiveness of the program.
Evidence: Various NRCS Oversight and Evaluation Reports: Easement Management in the Natural Resources Conservation Service, January 1999; Wetland Restoration Evaluation, January 1999, revised June 1999; Wetlands Reserve Program April 2001; WRP Compatible Uses, May 2002; Implementation Barriers for EQIP, WRP, WHIP, and FPP Conservation Programs, October 2002; Cost of Wetlands Reserve Program Easements, February 2004.
Does the performance of this program compare favorably to other programs, including government, private, etc., with similar purpose and goals?
Explanation: NRCS provided a limited amount of evidence demonstrating how WRP compares with other wetland conservation programs. In order to increase the score for this question, the agency needs to provide additional evidence that demonstrates how WRP compares with other similar programs.
Evidence: "Wildlife Benefits of the Wetlands Reserve Program, Charles A. Rewa; FY2006 Budget Explanatory Notes; Statement of Program. "
Do independent evaluations of sufficient scope and quality indicate that the program is effective and achieving results?
Explanation: "Independent evaluations conducted by NRCS's Oversight and Evaluation (O&E) Teams indicate that the agency's delivery of WRP is improving. An NRCS O&E report (2001) found that WRP restoration training efforts have been effective in increasing the quality of designs and restorations. Another O&E report (May 2002) concluded that, after training on compatible use activities, NRCS state offices have improved in developing and documenting compatible uses since a study conducted in 2000. A literature review of scientific journal articles found that WRP is contributing to shifts in land use patterns toward functional wetland ecosystems that occurred prior to conversion to agricultural use in the 20th Century. Preliminary results of studies underway indicate that wildlife use of WRP sites is comparable to or exceeds that of non-program restored wetland habitats. "
Evidence: "NRCS Oversight and Evaluation Reports April, 2001, and May 2002; Widlife Benefits of the Wetlands Reserve Program, Charles A. Rewa, USDA/NRCS, Resource Inventory and Assessment Division. "
|Section 4 - Program Results/Accountability||Score||40%|