Management of Mail Operations Audit
Final Report
Corporate Audit and Evaluation Branch
April 2010
Executive Summary
Background: The timely and accurate delivery of mail, both internally and externally, is necessary to support the Agency in meeting its commitments to contributing to the efficiency of government by delivering world-class tax and benefit administration that is responsive, effective and trusted. In fiscal year 2008-2009, the Canada Revenue Agency (CRA) Mail Program handled approximately 31 million pieces of incoming
Canada Post mail, and 17 million pieces of inbound intra-Agency mail. In terms of outgoing mail, the Mail Program handled approximately 11 million pieces of the 114 million pieces of total outgoing CRA mail (the vast majority of outgoing CRA mail is managed by Public Affairs Branch under the Print-to-Mail Program) and 24 million pieces of outbound intra-Agency Mail. The salary and operations and maintenance expenses of mail operations, as reported by Finance and Administration Branch (F&A), were $38 million. During the same period, the Agency spent $79 million on postage.
The Corporate Services Division (CSD) of the Administration Directorate (AD) of F&A has full accountability and authority for the policies and activities of CRA's mail operations. In 2004, the Mail Transformation Initiative (MTI) was launched, and as a result,
the Hub and Spoke delivery model was introduced with the objective of bringing operational efficiencies, greater standardization and cost savings to mail operations.
Objective: The objective of the audit was to determine whether management controls exist and are functioning as intended to support the Mail Program, and to monitor progress towards the achievement of the desired results of the MTI.
The audit was conducted in accordance with the International Standards for the Professional Practice of Internal Auditing.
Conclusion and Recommendations: The MTI has now been fully implemented and management controls are in place to support the Mail Program. Recommendations have been made to strengthen management controls, including: improved communication of roles and responsibilities for mail employees, and around processes for budgeting, problem resolution, and change management with affected program areas; formalized training for mail employees; improved compliance to mail procedures; and, enhanced monitoring and performance reporting. Given the limitations of performance measurement processes, the Mail Program will continue to face challenges in reporting its overall success as well as on progress in achieving the operational efficiencies and other desired benefits associated with the MTI.
Action Plans: The Administration Directorate of F&A agrees with the recommendations put forward by Internal Audit and have provided action plans to address the audit findings and to further strengthen the Mail Program in the Agency. Among several action plans, of key importance will be to develop and implement a training program for all mail employees, strengthen communications with Programs and Regions, and undertake various initiatives to improve monitoring and reporting capacity.
Introduction
In fiscal year 2008-2009, the Canada Revenue Agency (CRA) Mail Program handled approximately 31 million pieces of incoming Canada Post mail, and 17 million pieces of inbound intra-Agency (or internal) mail[Footnote 1]. In terms of outgoing mail, the
Mail Program handled approximately 11 million pieces of the 114 million pieces of total outgoing CRA mail (the vast majority of outgoing CRA mail is managed by the
Public Affairs Branch (PAB) under the Print-to-Mail Program) and 24 million pieces of outbound intra-Agency mail.
The timely and accurate delivery of mail, both internally and externally, is needed to support the Agency in meeting its commitments to contributing to the efficiency of government by delivering world-class tax and benefit administration that is responsive, effective, and trusted. Taxpayer confidence in the integrity of the tax system is of utmost importance to the Agency, and mail operations play a key role in that regard by preserving the confidentiality of taxpayer information while ensuring the timely movement of correspondence.
The Administration Directorate (AD) of the Finance and Administration Branch (F&A) is the responsible authority for national mail operations within the CRA. Given this, the AD has full accountability and authority for policies and activities relating to national mail. It is also responsible for establishing the policy direction and framework, and exploring innovative solutions for mail services that can meet client expectations and better support CRA operations and service standards. Within the AD, the Corporate Services Division (CSD) is responsible for national advisory services and program direction regarding mail and its transportation, program monitoring, compliance reviews and performance reporting. CSD is also responsible for the development and strategic positioning of CRA's relationship with the Canada Post Corporation (CPC).
Background – The Mail Transformation Initiative
The Mail Transformation Initiative (MTI) was designed to achieve efficiencies through better utilization of resources, to reduce misdirected and misaddressed mail[Footnote 2], and to improve mail processing and distribution activities. Reductions against the Mail Program functional budgets were subsequently made by the CRA as contributions to the Government's reallocation exercises in the amount of $2.7 million annually (beginning in fiscal year 2007-2008) and an additional $1.36 million annually (beginning in fiscal year 2009-2010). These reductions were achieved through salary cost reductions, decreased transportation costs through mailroom consolidation, and the implementation of the Hub and Spoke[Footnote 3] delivery model.
Implementing the new delivery model resulted in a different configuration of mail services for CRA. With the new configuration, the previous 52 mailrooms were converted to 12 hubs, 29 spokes, and 11 stand-alone mailrooms. The mail hubs, predominantly located in the Tax Centres (TCs), provide services to their regional Tax Services Offices (TSO) (spoke). The 11 stand-alone mailrooms are located in mainly remote areas. Refer to Appendix B: Current Mail Services Configuration for further details.
When the initiative was first launched, the expectation was that there would be a decrease in mail volume over time, due to the increasing popularity of e-filing. Such a decrease did not occur, and in fact, mail volumes have increased over the past 5 years, due in part, to the addition of new federal and provincial programs.
Focus of the Audit
The objective of the audit was to determine whether management controls exist and are functioning as intended to support the Mail Program and to monitor progress towards the achievement of the desired results from the MTI.
The scope included a review of the Mail Program's operations, supporting information systems, reports, and other relevant sources of information. The audit also involved key internal stakeholders (corporate and program areas) in terms of the mail services and CSD's responsibilities related to those areas of CRA, such as Security, Business Returns, Individual Returns, Print-to-Mail, Payments Processing, and Appeals. The audit was conducted at Headquarters and at selected offices in the Ontario, Prairie and Atlantic regions between February and August 2009.
The audit was conducted in accordance with the International Standards for the Professional Practice of Internal Auditing.
Findings, Recommendations and Action Plans
1.0 Management ControlsKey management controls of the Mail Program were assessed, including the clarity of goals and objectives, the roles and responsibilities associated with work that related to mail services (provided by CRA mail employees as well as third party contractors), controls for the budgeting process, the policy framework including the policies and procedures for the management of mail, as well as controls for monitoring and reporting.
The CRA's mail services policy clearly outlines the following objective of the
Mail Program: “To ensure the constant, secure, effective, and efficient movement and transportation of CRA mail.” The policy also states that mail services will be provided in support of CRA's programs and operational requirements. In keeping with this policy objective, the CSD launched the development and implementation of the MTI in 2004.[Footnote 4] It redefined CRA's mail service to improve upon all elements contained in the program objective statement.
Roles and Responsibilities
Roles and responsibilities for mail operations employees were clearly defined on the F&A website and also communicated verbally and in print form by management. Job descriptions and performance expectations were in place and discussed with employees on a regular basis. However, inconsistencies exist in the application of work activities between mailrooms, such as mail inserting and the sealing of mail envelopes. A formal training program is not in place for mail employees, however, on-the-job training and mentoring activities were commonly practiced in the mailrooms. Standardized training would support consistency, efficiency and cost-effective service delivery across the country.
In addition to the work that is performed by CRA's mailroom employees, CSD relies on third party contractors (such as CPC and private couriers) to conduct specific types of work in the movement of CRA mail. Roles and responsibilities of contractors were well defined in the form of contracts. However, deficiencies were noted regarding CSD's contract monitoring responsibilities, in particular, regarding the consistent recording and tracking of complaints concerning third parties. As a result, CSD does not always have the necessary information to take appropriate steps to formally resolve these complaints.
Recommendation 1:
Corporate Services Division (CSD) s hould put in place a standardized training program for mail employees in order to ensure consistent adherence to the defined roles and responsibilities for mail operations.
Action Plan 1:
A training program will be developed by the end of 2010-2011 and implemented in
2011-2012 The program will include orientation for new staff, as well as updating/strengthening skill sets for existing staff.
Recommendation 2:
CSD should ensure that instances of work being conducted by mail program staff that are outside of the scope of defined mail operation roles and responsibilities are raised with applicable program areas and/or local offices to determine appropriate corrective action.
Action Plan 2:
CSD will address these situations on a site-by-site basis with the regional management and functional authorities to ensure accurate attribution of activity costs and duties to the appropriate functions.
Recommendation 3:
CSD should ensure that a formal monitoring mechanism is in place to ensure adherence to all agreed contract terms and conditions, in particular, the formal recording, tracking and resolution of complaints concerning third party contractors.
Action Plan 3:
While no formal monitoring mechanism is yet in place, CSD has two resources in place at all times to address these regional mail issues as they occur. CSD has also recently implemented a formal review of delivery timelines for intra-Agency mail to identify when deliveries are outside of the CPC contracted standards. Also, given that a Request for Proposal will be posted in 2010-2011 for third party services, CSD will use this opportunity to establish more rigorous contract performance monitoring clauses.
Budgeting Process
A main objective associated with the implementation of MTI was increased operational efficiencies and effectiveness, to be attained largely through the standardization of mail processes. A key component of the MTI was the adoption of a new
Activity-Based Costing (ABC) model that included the use of a funding algorithm. The algorithm uses the total volume of mail transiting through a particular mailroom to determine the required resource levels and the corresponding funding allocation.
The new funding model has been operational since 2007. However, improvements to the existing budget controls are needed. Comments from interviews revealed that mail operations employees continue to perform duties that are not funded under the funding model. Generally, these are duties that were performed prior to the implementation of the new model. Disparities were found in the data reported by the field offices that feeds into the algorithm calculations, such as averaging the count, counting each document, or failing to report. These disparities are important as they have budget implications.
Generally, there is considerable misunderstanding within regional mail operations regarding the funding model and the purpose of consistent tracking and reporting activities against the established budget. Overall, the full cost of mail operations is still not entirely known and most program areas do not track what they perceive as increased program costs due to the implementation of MTI.
Recommendation 4:
CSD should ensure that the detailed time-activity reporting system accurately records the various aspects of mail employee work. Training should be provided to ensure employees' understanding of the system and for consistency in time reporting. Where work performed is outside of Mail's responsibility (as per the new funding model), CSD should develop a mechanism that identifies these discrepancies and consult with program areas to determine where the related costs should be allocated.
Action Plan 4:
CSD will ensure that the training program discussed in Recommendation 1 includes a module on volume tracking and recording by Regions. Regional Mail Program coordinators have developed a proposal to adjust the method of capturing mail volumes in conjunction with current mail ‘Activity Types' already used in CAS. This proposal will be reviewed by CSD in 2010-2011 and any changes reflected in the Administration Directorate Activity Type Interpretation document currently posted on Infozone.
Local managers of offices with mail staff performing work outside of Mail's responsibility will be asked to resolve at a local level. Issues that cannot be resolved locally will be referred to CSD for discussion with appropriate program areas.
Policies and Procedures
CRA's Finance and Administration Manual (FAM) provides the main guidance on policies and procedures for mail operations. Within FAM, the procedures define the key processes that need to be executed by mailroom employees.
The audit found that policies and procedures for the management of mail processes were available and accessible electronically. However, there was conflicting information within the mail directives regarding the addressing protocols for internal mail. Two audit tests were performed: one on the requirements for addressing mail, and a second on the accuracy of CRA employees' internal addressing information, which is contained in Outlook properties.
In the first test regarding addressing requirements, the audit drew upon a statistically valid random sample of 198 pieces of internal mail and found 11 percent compliance to addressing requirements. While this is a very low compliance rate for internal mail, audit's full review of mail addressing for one day of mail received at 11 different mailrooms (4731 pieces of internal and external mail) found 44 percent compliance for internal mail and 72 percent compliance for external or drop box mail. In the second test on the accuracy of CRA's Outlook properties, based on a statistically valid sample of 144, the audit revealed 76 percent compliance. Overall, tests results revealed significant problems with mail being properly addressed, and to a lesser degree, the accuracy of CRA's Outlook properties. CRA staff is neither properly following the guidelines for addressing internal mail nor consistently updating their Outlook properties. These factors are impediments to the efficient movement of mail within the CRA.
In addition to addressing protocols, the Mandatory Address Elements procedure requires that mail employees are to reject improperly addressed internal mail. Audit test results indicate that this procedure was not always applied. The Mail Reject Slip (TF634) was created to respond to these errors, however, it is not always used by mail employees at pick-up points. Improperly addressed mail and items that were not packaged according to both mail and security requirements for protected information continued to be accepted by the mailrooms. In these incidences, mail employees conducted the necessary research to identify the recipient and the proper destination of the item in question. This has a compounding effect on the time and expense to process internal mail. For example, it was calculated in one mailroom that this work was taking the equivalent of one full time employee (FTE), and in another, one-third of a FTE.
Other tests were performed regarding mailroom employees' compliance to policy and other applicable procedures to determine if all mail procedures were followed and in a consistent manner. The audit found that dual control[Footnote 5] procedures as outlined in FAM were not consistently practiced. This financial control requires at least two employees to be present when opening mail, handling or processing mail, or delivering items of value. Interviews revealed a common perception of mail staff that this control is unpractical and too expensive to implement.
It was also noted that the use of the Routing Advice and Controlled Shipment Tracking Form (T973) was not being fully utilized in HQ and the regions examined. T973 forms must be used, tracked and reconciled in order to ensure that protected mail reaches the intended recipient. More education on the use of the T973 would ensure its systematic use and a higher level of compliance by CRA employees for mail that is categorized as “Protected B” or higher.
Overall, the policy framework is in place to support the management of mail operations. However some weaknesses were detected, including non-compliance and inconsistent application of certain procedures. Interviews indicated that these issues may be attributed to a lack of clearly defined and communicated procedures and thus limited understanding among mail staff, as well as insufficient monitoring by management.
Recommendation 5:
Periodically, CSD should review the FAM as it pertains to mail operations, as well as the procedures that define the key processes that need to be executed by mailroom employees to determine their continued relevance and utility and amend these as required. Policy and procedural changes need to be communicated with mail staff as well as with affected programs areas.
CSD should ensure that mail addressing protocols are current, communicated, and understood by CRA employees. If addressing protocols are not complied with, CSD should ensure that Mail Reject Slip (TF634) is consistently applied.
Action Plan 5:
The policy framework is in place and mail processes are reviewed on a continuous basis for revision of the FAM. CSD will develop and execute a communication strategy in conjunction with PAB in fiscal year 2010-2011 to enhance communication of mail protocols to all CRA employees. In addition, the conflicting information within the mail directives regarding the addressing protocols for internal mail that was noted in the audit will be corrected immediately.
Recommendation 6:
CSD should review and revise, if required, the use of Dual Control procedures as well as the T973 Routing Advice and Controlled Shipment Tracking Form, in order to ensure consistent application and compliance.
Action Plan 6:
Recent funding by Administration Directorate for 2010-2011 now provides small office mail operations with the opportunity to perform dual control. CSD has added 12 General Services FTEs to facilitate dual control as well as improve the local processing of payments in the Regions. CSD will undertake a risk/policy assessment over the next 24 months to determine whether a different approach to dual control may be warranted.
With regards to the T973, the Security Directorate has agreed to include the requirement for the use of the T973 in the FAM for shipments of Protected B material and higher. CSD is also working with ITB on automating the chain of custody of the T973 to improve the controls of the current manual process. We expect to be able to perform end to end tracking of T973s in the Shipment Management System in
2011-2012.
Monitoring and Reporting
Overall, the monitoring requirements for mail activities are clearly defined and mailroom employees regularly monitor and report on the processing of mail products within their local offices. However, inconsistencies exist with regards to how data was collected and reported nationally. For example, offices were found to have different methods for determining the average count of contents in a mail bin. Mail employees did not always understand the purpose of data collection and the reporting process. A principal role of the regional mail advisors is to monitor and report on the progress of each region, but in practice, their role centres on liaison and problem solving between the field and headquarters, and to a lesser degree on the data collection and analysis activities associated with monitoring. The Radio Frequency Identification tracking tool that was fully implemented in 2009 will assist in the tracking and monitoring of intra-Agency mail.
Some program areas have started to monitor their mail intake in response to claims of a decline in the quality of mail service, particularly in the area of redirected mail[Footnote 6]. One area reported that up to 25 percent of the mail received was incorrectly routed. To address the issue of returned mail, CSD initiated a pilot project in April 2009. Pilot results revealed that 85 percent was attributed to incorrect taxpayer address information on file as opposed to incorrect routing of mail. These results are being reviewed to look at ways to decrease the amount of returned mail.
In CRA, there are many stakeholders involved in the preparation and movement of mail. During mailroom visits, the audit team looked at controls used by mailroom employees to mitigate the risk of security incidences, such as sending the wrong information to a taxpayer. The audit team reviewed the procedures in place to ensure that the right taxpayer information is folded and inserted in the envelope to be mailed out, and determined that mailroom controls were adequate. In the event of a security incident, the CRA's Security, Risk Management and Internal Affairs Directorate (SRMIAD) is notified and conducts an investigation of the incident. Misdirected mail[Footnote 7] is monitored, and when deemed necessary, a Security Incident Report[Footnote 8] is prepared.
In 2008, there were 1851 misdirected mail incidents reported. All misdirected mail Security Incident Reports for the year 2008-2009 (43 reports) were reviewed and the results of the analysis were shared with SRMIAD. The analysis revealed, in part, that 42 percent of the reports (or files) reviewed did not have a risk assessment on file as required, and 47 percent of the reports did not provide evidence that corrective measures had been implemented. Instructions regarding whether relevant parties should be informed that their personal information had been potentially exposed to a third party were found to be unclear. SRMIAD acknowledged these concerns and has commented that efforts are underway to improve this process and ensure that all key internal stakeholders (such as Legal Services and local management) are consulted in order to resolve security incidents in the most effective manner possible. Overall, the ratio of Security Incident Reports compared to the volume of mail sent remains extremely low. In addition, each misdirected incident is reviewed by the proper authority in order to mitigate its risk.
2.0 Mail Transformation Implementation
A second line of enquiry was to assess the achievement of the desired results of the MTI. This included assessing how changes to mail operations were communicated and implemented, as well as the extent of progress made in achieving the various operational efficiencies that were expected with the mail transformation.
Communication and Change Management
During the initial implementation of the MTI, CSD prepared and delivered several presentations to senior management describing the Hub and Spoke model and its relation to organizational structures in the regions. These presentations also included: historic mail volumes; costing data and cost savings projections; an implementation strategy and schedule; new mail processes; and highlights of various program concerns. Although regional clients felt they were informed of the changes to come, they did not view these information sessions as opportunities to provide feedback.
Interviewees stated that communication at the local level between mail operations employees and their clients was very good within areas where mailroom hubs were located. However, difficulties in communication were noted where the extent of change was significant, for example, between the mail hubs and their clients located in spokes. Generally, program and key internal stakeholders do not have a clear understanding of the new mail processes. Major changes, such as revised mail-related policies and procedures, have not been well communicated to program areas. Of the selected program areas visited during the audit, two reported that they have been required to alter their program service standards in response to the changed mail procedures.
Comments from interviews also revealed that complaints received (typically from program areas) were dealt with as they occurred at the local and regional level. However, there was no evidence that complaints were formally tracked or that the nature of the problem and the resulting solution were documented. As this information was not shared with other mail areas and regions, such problems were frequently not assessed and communicated to parties outside the local area. Actions should be taken to raise awareness of potential and actual problems and to prevent the reoccurrence of such problems.
Recommendation 7:
CSD should develop and implement a communications strategy to support the Mail Program's change management process, including the sharing of information and revised policies and procedures within mail operations and with key program areas. In addition, CSD should develop a formalized approach to problem resolution, including the tracking of complaints, documenting of resolutions, and communicating to parties outside the local area in which the problem occurred.
Action Plan 7:
Over the last year, one of our priorities has been to focus on increased communication with Regions through Mail Committees and conference calls on changes and issues. This approach has gone a long way into resolving residual issues with MTI. CSD has worked to develop a community of practice on mail to look at issues and resolve them with Programs and Regions from a national perspective. This work will continue and will evolve in a more formal process in 2010-2011, including establishing more formalized forums for the community as well as developing tools to assist in the tracking and sharing of issues and resolutions.
Progress on Achieving MTI Results
The implementation of the MTI was expected to achieve various operational efficiencies, including: improved utilization of resources; reduction of misdirected and misaddressed mail; and improvements to mail processing and distribution activities. Prior to implementing the MTI, the CSD had conducted limited baseline measurements for various aspects of the Mail Program operations (including those that are tied to the desired benefits of MTI). Although performance indicators to track desired results were developed in the planning phase of MTI, they were not clearly defined, measurable, or communicated to the mailroom community.
Without an established comprehensive baseline and benchmarks prior to MTI implementation, attempts to measure the achievement of desired benefits of MTI and other aspects of program performance will continue to be problematic. Furthermore, in the absence of clearly defined and communicated performance indicators, the data used for key performance indicators that relates to the achievement of the expected benefits of MTI is not being collected or analyzed. While monitoring and reporting mechanisms are in place, improvements are needed to improve upon the quality of monitoring and reporting of performance for the Mail Program.
Recommendation 8:
CSD should enhance its performance measurement and monitoring process in order to permit accurate reporting against program objectives, including the realization of the desired benefits associated with the implementation of MTI.
Action Plan 8:
A review of our mail performance measurement and monitoring process is being conducted in 2010-2011. Along with our commitment to improve time-based and activity-based cost reporting in order to fully assess mail program costs, we will work with Regions to establish a common Performance Measurement and Monitoring Framework that evaluates mail operations time spent processing inbound and outbound mail against standard processing rates. These processing rates, along with our current measurement of timeliness of mail service delivery, will permit for accurate performance and effectiveness reporting of CRA Mail Operations.
Conclusion
The management of mail in the Agency is a complex business. The introduction of the Hub and Spoke delivery model brought a standardized approach to managing mail and prompted significant changes both within the Mail Program and involving other programs areas using mail services. There were significant challenges in communicating these changes. Generally, program areas do not have a clear understanding of the new mail processes. Major changes, such as revised mail-related policies and procedures, have not been well communicated, which has impacted the acceptance and understanding of the new distribution model.
The MTI has now been fully implemented and management controls are in place to support the Mail Program. Recommendations have been made to strengthen management controls, including: improved communication of roles and responsibilities for mail employees, and around processes for budgeting, problem resolution, and change management with affected program areas; formalized training for mail employees; improved compliance to mail procedures; and, enhanced monitoring and performance reporting. Given the limitations of performance measurement processes, the
Mail Program will continue to face challenges in reporting its overall success as well as on progress in achieving the operational efficiencies and other desired benefits associated with the MTI.
Appendix A – Glossary of Terms
Dual control: As per FAM, dual control is a security measure for the protection of staff handling items of value, and consists of two employees working together within visual contact to identify, count, record and deliver any valuables discovered during the handling of Agency mail.
Hub: In reference to the Hub and Spoke model, a hub is the mail processing centre that services the regional satellite offices. Mail processing hubs perform various activities, including the sorting of correspondence to be distributed to the satellite locations.
Hub and Spoke Model: The hub-and-spoke distribution paradigm (or model or network) is a system of connections arranged like a chariot wheel, in which all traffic moves along ‘spokes' connected to the ‘hub' at the center. The model is commonly used in industry, in particular in transport, telecommunication and freight, as well as in distributed computing.
Intra-Agency or internal mail: Mail that is sent and received within the Agency. This refers to mail items routed between CRA offices, e.g., regional offices, TSOs, TCs, Ottawa Technology Centre, and Headquarters.
Misaddressed mail: Misaddressed mail,also referred to as under-addressed mail or incorrectly addressed mail, refers to mail that lacks all mailing address requirements, such as name of intended recipient, program name, address, city, province and postal code.
Misdirected mail: Misdirected mail refers to a piece of mail that is received by one party (or individual), but the content of which was intended for another party (or individual). This may be due to various reasons, such as human error, improper information, new address, etc.
Redirected (rerouted) mail: Redirected or rerouted mail refers to mail that has arrived at an initial destination, to be sent ultimately to its intended destination. Not all misdirected mail is redirected mail.
Security incident: As per FAM, a security incident refers to the compromise of an asset, or any act or omission that could result in a compromise, threat or act of violence toward employees.
Security Incident Report: A security incident report is deemed necessary to be prepared, based on a risk assessment done by the local Director, where the misdirected mail was reported.
Spoke: In reference to the Hub and Spoke model, a spoke is a satellite location serviced by a local mail processing hub. Activities performed in spoke mailrooms are limited to the extraction of vertical mail, scanning of drop box mail for payments, local distribution of mail received from hubs and exceptional processing of outgoing mail.
Footnotes
- [Footnote 1]
- Refer to Appendix A: Glossary of Terms.
- [Footnote 2]
- Ibid
- [Footnote 3]
- Ibid
- [Footnote 4]
- Following an internal review conducted on National Mail Services Redesign (CGI, 2003).
- [Footnote 5]
- Refer to Appendix A: Glossary of Terms.
- [Footnote 6]
- Refer to Appendix A: Glossary of Terms.
- [Footnote 7]
- Ibid.
- [Footnote 8]
- Ibid.
Page details
- Date modified: