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Benefits and Challenges of Smartphone Applications to Augment Contact Tracing (GAO-21-104622)

Summary

A GAO technology assessment report to congressional addressees, GAO-21-104622, dated September 2021, on exposure notification. It examines smartphone applications developed with the spread of COVID-19 to supplement manual contact tracing, a public health measure. GAO explains that exposure notification apps determine the proximity of users and notify people who have been in close contact with another user who was likely infectious. It states that the apps are expected to enhance the speed and reach of contact tracing, and the report examines their benefits and challenges.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

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                 United States Government Accountability Office

                 Report to Congressional Addressees



September 2021   TECHNOLOGY ASSESSMENT

                 Exposure Notification
                 Benefits and Challenges of Smartphone
                 Applications to Augment Contact Tracing




GAO-21-104622
The cover image displays a stylized depiction of the use of an exposure notification app by various individuals and an
example of an exposure notification message.

Cover source: GAO. | GAO-21-104622
                                               TECHNOLOGY ASSESSMENT

Highlights of GAO-21-104622, a report to
congressional addressees                      Exposure Notification
September 2021                                Benefits and Challenges of Smartphone
                                              Applications to Augment Contact Tracing
 Why GAO did this study                       What GAO found
 With the emergence and rapid global          Exposure notification applications (apps)—which determine the proximity of users
 spread of COVID-19, smartphone               and notify people who have been in close contact with another user who was likely
 apps have been developed to
 supplement manual contact tracing,           infectious—are expected to enhance the speed and reach of contact tracing and
 which is a public health measure used        help slow the spread of infectious diseases such as COVID-19. As of June 2021,
 to slow the spread of infectious             almost half (26/56) of U.S. states, territories, and the District of Columbia had
 disease.                                     deployed an app for COVID-19, all using a system developed jointly by Google and
 GAO was asked to conduct a                   Apple (see figure). In the absence of a national app, states independently launched
 technology assessment of exposure            apps, resulting in a staggered rollout over 10 months beginning in August 2020.
 notification apps. This report
                                              Map of deployment of exposure notification apps by U.S. states and territories, as of
 discusses (1) the benefits of exposure
 notification apps; (2) the current level     June 2021
 of deployment in the U.S.; (3)
 challenges affecting their use; and (4)
 policy options that may help address
 these challenges for future use.
 To address these objectives, GAO
 reviewed agency documentation, met
 with officials from several federal
 agencies, and conducted a review of
 technical and policy literature. GAO
 also interviewed representatives
 from companies involved in the
 development of exposure notification
 apps, public health organizations,
 federally funded research and
 development centers, and academic            Reported app development costs for selected states varied, ranging from no cost
 researchers. In addition, GAO                (provided by a nonprofit organization) to $700,000. Marketing costs for selected
 analyzed information from a selection        states ranged from $380,000 to $3.2 million. Reported app download levels in the
 of states. GAO is identifying policy         selected states ranged from 200,000 to more than 2 million, as of June 2021.
 options in this report.
                                              GAO identified several challenges limiting app use and the ability of states and
 GAO received technical comments on           others to determine whether the apps were effective:
 a draft of this report from five federal
 agencies and five organizations               Accuracy of               Technical limitations to measuring distance and exposure can result in
 included in the review, which it              measurements              inaccurate exposure notifications.
 incorporated as appropriate.                  Privacy and               The public may lack confidence that its privacy is being protected, in
                                               security concerns         part, due to a lack of independent privacy and security assessments and
                                                                         a lack of federal legal protections.
                                               Adoption                  States have faced challenges attracting public interest in downloading
                                                                         and using an exposure notification app.
                                               Verification code         States faced challenges in promptly providing people who tested
                                               delays                    positive for COVID-19 with a verification code necessary to notify other
                                                                         close contacts of potential exposure using the app.
                                               Evidence of               Limited data are available to evaluate the effectiveness of the apps.
                                               effectiveness
View GAO-21-104622. For more information,     Source: GAO. | GAO-21-104622
contact Karen L. Howard at (202) 512-6888
or, howardk@gao.gov or Vijay A. D’Souza, at
(202) 512-6240, dsouzav@gao.gov.
                                                                                                       United States Government Accountability Office
GAO developed the following four policy options that could help address challenges related to exposure notification apps. The policy
options identify possible actions by policymakers, which may include Congress, other elected officials, federal agencies, state and
local governments, and industry. See below for details of the policy options and relevant opportunities and considerations.

Policy Options to Help Address Challenges of Exposure Notification Apps for Future Use
                                                    Opportunities                                            Considerations
Research and Development       •   Research on technological limitations could help         •   The research needed may be costly.
(report page 41)                   increase accuracy, encouraging users to download         •   Improvements may not be cost-effective,
Policymakers could promote         and use the apps.                                            since existing apps may already be
research and development to    •   Research on technologies and architectures other             sufficiently accurate.
address technological              than those used by U.S. states could lead to             •   Research may result in apps that are not
limitations.                       improvements.                                                functional for the next pandemic, since the
                               •   Partnerships with technology companies could spur            current apps were developed for COVID-19.
                                   innovation and help with integrating improvements.
Privacy and Security           •   Uniform standards and best practices could help          •   Policymakers would need to balance the
Standards and Practices            address real and perceived risks to the public’s data,       need for privacy and security with the costs
(report page 42)                   potentially increasing adoption.                             of implementing standards and practices.
Policymakers could promote     •   Standards developed by a broad coalition of              •   Implementation of privacy requirements
uniform privacy and security       stakeholders could increase the likelihood of                may need to be flexible, since jurisdictions
standards and practices for        stakeholder agreement and buy-in.                            could use different approaches.
exposure notification apps.                                                                 •   Standards and practices could be
                                                                                                challenging to oversee and enforce.
Best Practices (report page    •   Best practices could help authorities better promote     •   Best practices could require consensus from
43)                                app adoption.                                                many public- and private-sector
Policymakers could promote     •   Best practices could help state public health                stakeholders, which can be time- and
best practices for                 authorities by providing information on procedures           resource-intensive.
approaches to increasing           and potential approaches for distributing                •   Current best practices may have limited
adoption and to measure            verification codes in a timely manner.                       relevance to a future pandemic.
the effectiveness of           •   Best practices could help public health authorities      •   In some cases, stakeholders may lack
exposure notification apps.        establish a more rigorous way to measure the                 sufficient information or the experience to
                                   extent of app use and any resulting improvements             develop best practices.
                                   in notifying exposed people.
National Strategy (report      •   Enhanced national coordination that builds on            •   A coordinated national approach would
page 44)                           the underlying infrastructure and lessons                    likely have associated costs and require
Policymakers could                 learned from COVID-19 could prompt faster                    sustained funding during the pandemic.
collaborate to enhance             deployment of apps in the future.                        •   Coordination of groups with divergent
the pandemic national          •   A future national marketing campaign with                    perspectives and interests may pose
strategy and promote a             cohesive and coherent messaging could result                 challenges to defining outcomes, measuring
coordinated approach               in wider adoption.                                           performance, and establishing a leadership
to the development             •   Policymakers could recommend a national app that             approach.
and deployment of                  public health authorities could decide to use based      •   It is unclear whether potential users
exposure notification              on their individual needs. A national app could add          would be more or less likely to trust a
apps.                              more functions by integrating exposure notification          national exposure notification app than
                                   capabilities with test scheduling and vaccine                one developed by a state government.
                                   delivery coordination.
Source: GAO. | GAO-21-104622
This is a work of the U.S. government and is not subject to copyright protection in the United States. The published
product may be reproduced and distributed in its entirety without further permission from GAO. However, because this
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Table of Contents
Introduction ........................................................................................................................ 1
1 Background ...................................................................................................................... 4
       1.1 COVID-19 ........................................................................................................................... 4
       1.2 Manual contact tracing for COVID-19 ............................................................................... 4
       1.3 Roles of states, federal agencies, and other stakeholders ................................................ 6
2 Benefits and Design of Exposure Notification Apps ........................................................ 9
       2.1 Exposure notification apps are expected to provide enhanced speed and reach ............ 9
       2.2 How exposure notification apps work ............................................................................. 10
       2.3 Apps can use either a centralized, decentralized, or hybrid system to manage data.....12
       2.4 States are widely using the Google and Apple Exposure Notifications system ..............14
3 Deployment and Adoption of Exposure Notification Apps ........................................... 18
       3.1 About half of the states have deployed an exposure notification app ........................... 18
       3.2 About half of the states use a customized app ............................................................... 21
       3.3 States reported that app development time and cost varied based on
             several factors .............................................................................................................. 25
       3.4 Officials reported varying download levels and use........................................................ 26
4 Challenges Associated with Exposure Notification Apps ............................................... 27
       4.1 Accuracy of measurements ............................................................................................. 27
       4.2 Privacy and security concerns ......................................................................................... 28
       4.3 Adoption and use of apps ................................................................................................ 31
       4.4 Verification code delays .................................................................................................. 32
       4.5 Limited evidence of effectiveness ................................................................................... 33
5 Policy Options That Could Help Address Challenges for Future Use ............................. 41
       5.1 Policy option: Research and development ...................................................................... 41
       5.2 Policy option: Privacy and security standards and best practices ................................... 42
       5.3 Policy option: Best practices to measure effectiveness .................................................. 43
       5.4 Policy option: Enhance the national strategy .................................................................. 44




                                                                                              Exposure Notification GAO-21-104622 i
6 Agency and Expert Comments ....................................................................................... 46
Appendix I: Objectives, Scope, and Methodology ............................................................ 47
Appendix II: Exposure Notification App Adoption Rates for Selected U.S. States ........... 51
Appendix III: GAO Contacts and Staff Acknowledgments ................................................ 54




                                                                             Exposure Notification GAO-21-104622 ii
Abbreviations
APHL       Association of Public Health Laboratories
BLE        Bluetooth Low Energy
CDC        Centers for Disease Control and Prevention
COVID-19   Coronavirus Disease 2019
DHS        Department of Homeland Security
FCC        Federal Communications Commission
FTC        Federal Trade Commission
GPS        Global Positioning System
HHS        Health and Human Services
NIH        National Institutes of Health
NIST       National Institute of Standards and Technology
QR         quick response
WHO        World Health Organization




                                                            Exposure Notification GAO-21-104622 iii
441 G St. N.W.
Washington, DC 20548

Introduction
September 9, 2021

Congressional Addressees

For more than a century, public health authorities have used contact tracing to track and limit
the spread of infectious diseases. Manual contact tracing involves interviewing infected people
to identify others they have been in contact with, notifying those contacts that may have been
exposed, and advising the infected individual and contacts to take appropriate measures.

Manual contact tracing can be effective, but it has limitations. Specifically, it is a resource-
intensive process, and it is most effective during the early stage of an outbreak, when case
numbers tend to be lower, or during phases with fewer cases. 1 In addition, its effectiveness
relies, in part, on prompt and complete identification of individuals and notification of contacts,
which could be difficult with a rapidly spreading disease. Other limitations of manual contact
tracing include the reliance on human recall of contacts and movements (which can be prone to
error), and the inability to identify strangers. Further, people may not be forthcoming in sharing
information about their contacts.

With the emergence and rapid spread of the highly infectious Coronavirus Disease 2019 (COVID-
19), digital contact tracing technologies have been developed to supplement manual contact
tracing and help address its limitations. One such technology is a type of application (app)
developed for use on a smartphone. 2 Referred to as an exposure notification app, 3 it is intended
to be used to notify a smartphone user who has been in close contact with another user who
later tested positive for COVID-19. 4 This type of app is intended to reduce transmission by
notifying potentially exposed people faster than manual contact tracing, including contacts the
infected person may not have known.




1
 Center for Infectious Disease Research and Policy, COVID-19: the CIDRAP Viewpoint, (Minneapolis, Minn.: University of Minnesota,
June 2, 2020).
2
 An estimated 85 percent of adults in the U.S. own a smartphone, according to a survey conducted by the Pew Research Center.
However, this decreases to an estimated 61 percent for people 65 and older. In addition, the rate varies based on other factors,
including income level and whether a person lives in an urban or rural area. This estimate was based on a survey of U.S. adults,
conducted between Jan. 25 and Feb. 8, 2021. See Pew Research Center, Mobile Fact Sheet, (Washington, D.C.: Apr. 7, 2021),
accessed July 1, 2021, https://www.pewresearch.org/internet/fact-sheet/mobile.
3
 An exposure notification app can include both software that a user downloads to use on a smartphone, or a function built into the
phone’s operating system that can be activated by users.
4
 While contact tracers have previously used smartphone apps, including for data entry, we are unaware of any exposure notification
apps in public use prior to the COVID-19 pandemic.




                                                                                      Exposure Notification GAO-21-104622 1
In July 2020, we issued a Science & Tech Spotlight overview of exposure notification app
technology. 5 Since then, there has been an increase in the development and use of these apps.
You asked us to conduct an assessment of these technologies. This report discusses (1) the
benefits and design of exposure notification apps, (2) the current level of deployment in the
U.S., (3) challenges affecting their use, and (4) policy options that could help address key
challenges for future use.

To address all of these objectives, we reviewed documentation and met with officials from
selected federal agencies involved in providing guidance, funding research, and directing other
efforts related to exposure notification apps. In addition, we interviewed representatives from
entities involved in the development of exposure notification apps; public health organizations;
federally funded research and development centers; academic researchers; and
nongovernmental organizations. We also conducted a review of literature discussing exposure
notification apps, including their benefits, design, and challenges, as well as relevant policy
options.

To identify the current level of deployment, we developed an inventory of exposure notification
apps that had been deployed by U.S. states, territories, and the District of Columbia (hereafter
referred to as states) as of June 2021. States that had an app in a pilot phase at the time of our
review were included the category of “states that had not deployed an app as of June 2021.”

To obtain additional information associated with the development and use of these apps, we
interviewed state public health officials from a non-generalizable sample of nine states that had
deployed an exposure notification app as of January 1, 2021: Alabama, Colorado, Connecticut,
Minnesota, Nevada, North Carolina, Pennsylvania, Virginia, and Washington. We also reached
out to two other states (Louisiana and Utah) that deployed apps in the later stages of our
evidence collection and received written feedback to structured questions about the status of
their efforts to deploy an app, their rates of adoption, and other topics. We selected the sample
of nine states to obtain a range of views, based on factors such as deployment date,
geographical distribution, number of COVID-19 cases, and app developer. Because the selection
was based on a non-generalizable sample, the results were not used to make inferences about
all states that had deployed an app. In addition to our interviews with officials from the selected
states, we conducted a review of each of the selected states apps, including the key functions,
features, and privacy use policies for those apps.

To obtain perspectives from states that had not deployed an app, we collected information from
a non-generalizable selection of seven states that had not deployed an app at the time of our
review (Montana, Nebraska, Oregon, Rhode Island, South Carolina, Texas, and West Virginia).




5
 GAO, Science & Tech Spotlight: Contact Tracing Apps, GAO-20-666SP (Washington, D.C.: July 28, 2020). While the terms exposure
notification apps and contact tracing apps have been used to describe these technologies, we will use the term exposure notification
apps in this review.




                                                                                      Exposure Notification GAO-21-104622 2
For these states, we conducted an interview with officials from one state and obtained written
responses to a semi-structured set of questions for the other six.

We identified policy options that may address the identified challenges based on our literature
review and interviews. We assessed each policy option by identifying potential benefits and
considerations of implementing them, as identified over the course of our review. See appendix
I for a detailed description of our objectives, scope, and methodology.

We conducted our work from November 2020 to September 2021 in accordance with all
sections of GAO’s Quality Assurance Framework that are relevant to technology assessments.
The framework requires that we plan and perform the engagement to obtain sufficient and
appropriate evidence to meet our stated objectives and to discuss any limitations to our work.
We believe that the information and data obtained, and the analysis conducted, provide a
reasonable basis for any findings and conclusions in this product.




                                                              Exposure Notification GAO-21-104622 3
1 Background

1.1 COVID-19                                                    nation. 7 In the U.S., there have been more
                                                                than 596,000 reported deaths 8 and 32
The outbreak of COVID-19 was first                              million reported confirmed and probable
reported on December 31, 2019, in Wuhan,                        cases as of July 2021. 9 In addition, despite
China. 6 In the weeks that followed, the virus                  strides made in getting people vaccinated,
quickly spread around the globe. On                             the threat of variants is growing, including
January 31, 2020, the Secretary of Health                       evidence of increased transmissibility. As a
and Human Services declared a public                            result, uncertainty about the future of the
health emergency for the U.S., retroactive                      COVID-19 pandemic remains.
to January 27, which followed a World
Health Organization (WHO) declaration on                        1.2 Manual contact tracing for
January 30 that the outbreak constituted a
public health emergency of international
                                                                COVID-19
concern. On March 11, 2020, WHO
characterized the COVID-19 outbreak as a                        Contact tracing is a key component in
global pandemic due to its levels of spread                     controlling the transmission and spread of
and its severity. COVID-19 is highly                            infectious diseases, according to the
contagious and may be spread by people                          Centers for Disease Control and Prevention
who are not showing symptoms (i.e.,                             (CDC). 10 Contact tracing is intended to
“asymptomatic”) or before symptoms                              separate the people who have (or may
appear (“pre-symptomatic”).                                     have) an infectious disease from those who
                                                                do not and provide information on other
More than a year later, as we have                              measures the potentially exposed contacts
                                                                should take, such as being tested for the
previously reported, the pandemic has
                                                                disease or self-isolating. Together, the test,
resulted in catastrophic loss of life and
                                                                trace, and isolate strategy is part of the
substantial damage to the global economy,
and to the stability and security of our


6                                                               9
 This disease is caused by SARS-CoV-2 (Severe Acute               Data on COVID-19 cases in the U.S. are based on aggregate
Respiratory Syndrome, Coronavirus 2).                           case reporting to the Centers for Disease Control and
7                                                               Prevention, COVID Data Tracker, (Atlanta, Ga.), accessed July
 GAO, COVID-19: Key Insights from the GAO’s Oversight of        7, 2021,
the Federal Public Health Response, GAO-21-396T                 https://covid.cdc.gov/covid-data-tracker/#datatracker-home
(Washington, D.C.: Feb. 24, 2021).                              , and include probable and confirmed cases as reported by
8                                                               states and jurisdictions. Centers for Disease Control and
 CDC’s National Center for Health Statistics COVID-19 death
counts in the U.S. are based on provisional counts from         Prevention (CDC) COVID-19 counts are subject to change
death certificate data, which do not distinguish between        due to delays or updates in reported data from states and
laboratory-confirmed and probable COVID-19 deaths.              territories. According to CDC, the actual number of COVID-
Provisional death counts are incomplete due to an average       19 cases is unknown for a variety of reasons, including that
delay of 2 weeks (a range of 1–8 weeks or longer) for death     people who have been infected may not have been tested or
certificate processing. Data include deaths occurring from      may not have sought medical care.
January 2020 through the week ending on July 3, 2021.           10
                                                                  Centers for Disease Control and Prevention, Operational
Centers for Disease Control and Prevention, National Center     Consideration for Adapting a Contact Tracing Program to
for Health Statistics, (Atlanta, Ga.), accessed July 7, 2021,   Respond to the COVID-19 Pandemic in non-US Settings,
https://www.cdc.gov/nchs/nvss/vsrr/covid19/index.htm.           (Atlanta, Ga.: June 23, 2021).




                                                                              Exposure Notification GAO-21-104622 4
broader effort to limit the transmission of                 agencies typically maintain an existing
infectious diseases such as COVID-19.                       capacity to conduct contact tracing for
                                                            infectious diseases, this capacity is generally
Contact tracers are the people who                          sufficient only to respond to relatively small
manually trace the contacts of each person                  or isolated outbreaks.
who has tested positive for COVID-19.
Contact tracers begin the process by                        Contact tracing is resource intensive,
interviewing the person with the positive                   because, as cases increase, the contact
test result in order to identify others whom                tracer will need more time to contact all
that person might have contacted. Next,                     potentially exposed persons. Hence, more
the tracer advises the person and the                       and more tracers will be needed to ensure
contacts to take containment measures                       comprehensive contact tracing of all
(e.g., a 14-day quarantine for COVID-19),                   diagnosed cases and potentially exposed
and coordinates or provides information on                  persons. The particular features of the
any needed care, testing recommendations,                   COVID-19 pandemic—asymptomatic
and resources. 11                                           persons and the ability to spread rapidly—
                                                            require a significantly large workforce of
For COVID-19, CDC defines a close contact                   contact tracers. According to the National
as anyone who has been within 6 feet of an                  Association of County and City Health
infected person for a total of 15 minutes or                Officials, the benchmark rate is 30 contact
more over a 24-hour period (for example,                    tracers per 100,000 people. This equates to
three individual 5-minute exposures for a                   about 98,460 contact tracers needed to
total of 15 minutes). 12 According to CDC,                  cover the entire U.S. population. 13
infected persons can spread COVID-19                        According to CDC, state health departments
starting from 48 hours (or 2 days) before                   reported a total of 51,855 employed
they have symptoms or test positive for                     contact tracers for the month of December
COVID-19.                                                   2020, which was about one month before
                                                            the peak of reported new cases in the U.S. 14
In a public health emergency such as the
COVID-19 pandemic, it is critical that each                 To supplement the capabilities of manual
state has a sufficient workforce of contact                 contact tracing, several states have used
tracers in order to contain the disease.                    smartphone apps. These apps include those
Although state and local public health                      that help people monitor their COVID-19


11                                                          13
   Consistent with CDC guidance, except in certain            National Association of County and City Health Officials,
circumstances, people who have been in close contact with   Position Statement: Building COVID-19 Contact Tracing
someone who has COVID-19 should quarantine. However,        Capacity in Health Departments to Support Reopening
people who have been fully vaccinated and people who        American Society Safely (Washington, D.C.: Apr. 16, 2020).
were previously diagnosed with COVID-19 within the last 3   14
months may not need to quarantine.                            This number represents a best estimate for a 1-month
                                                            snapshot and may not include contact tracers employed at
12
  See Centers for Disease Control and Prevention,           the local health department or community level, according
“Appendices,” COVID-19, (Atlanta, Ga.: Updated July 2,      to CDC documentation. Data are reported monthly, and
2021), accessed July 2, 2021,                               estimates will continue, and be updated regularly, according
https://www.cdc.gov/coronavirus/2019-ncov/php/contact-t     to CDC. We used the reported estimates from December
racing/contact-tracing-plan/appendix.html#contact.          2020 to illustrate capacity just before the peak cases
                                                            observed in January 2021.




                                                                          Exposure Notification GAO-21-104622 5
symptoms, assist people in recalling the                     Federal agencies
places they had visited when providing that
information to a contact tracer, and                         Federal agencies—including CDC, the
exposure notification apps. 15                               Department of Homeland Security (DHS),
                                                             the National Institutes of Health (NIH), and
1.3 Roles of states, federal agencies,                       the National Institute of Standards and
and other stakeholders                                       Technology (NIST)—have taken various
                                                             steps to assist states in the development
Various entities have a role in the                          and use of exposure notification apps,
deployment and use of exposure                               including issuing guidance, distributing
notification apps within the U.S. These                      funds to states, and funding research.
entities include states, federal agencies, and
other stakeholders, such as national public                  Specifically, in May 2020 and December
health organizations and organizations                       2020, CDC issued two guidance documents
involved in research and development of                      on digital contact tracing tools, which
the apps.                                                    included discussion of exposure notification
                                                             apps. 16 The guidance is intended to provide
States                                                       health departments with minimum and
                                                             preferred characteristics of the apps,
                                                             including those for contact notification and
In the U.S., public health authorities at the
                                                             data security. 17 In addition, CDC distributes
state, territorial, and local levels plan and
                                                             funds to states—through established
coordinate pandemic response actions
                                                             mechanisms such as its Epidemiology and
within their jurisdictions. In addition, these
                                                             Laboratory Capacity for Prevention and
authorities generally lead contact tracing
                                                             Control of Emerging Infectious Diseases
efforts, including the implementation of
                                                             cooperative agreement, which currently
related technologies, such as exposure
                                                             provides funds to 64 jurisdictions to detect,
notification apps.
                                                             prevent, and respond to the growing
                                                             threats posed by infectious diseases,
                                                             including for the development and use of
                                                             exposure notification apps, according to




15                                                           16
   For example, in April 2020, Utah deployed an app which      Centers for Disease Control and Prevention, Preliminary
allowed residents to check their symptoms, and privately     Criteria for the Evaluation of Digital Contact Tracing Tools
share a subset of their location information with public     for COVID-19, version 1.2 (Atlanta, Ga.: May 17, 2020); and
health officials to aid in the contact tracing process. In   Guidelines for the Implementation and Use of Digital Tools to
summer 2020, Utah disabled the location–based services in    Augment Traditional Contact Tracing, version 1.0 (Atlanta,
this app.                                                    Ga: Dec. 15, 2020).
                                                             17
                                                               These characteristics included that the apps should enable
                                                             health departments to define different exposure risk levels
                                                             used to identify contacts based on how close and how long
                                                             their exposure was and to require user consent before their
                                                             data are shared with a health department.




                                                                           Exposure Notification GAO-21-104622 6
CDC documentation. 18 (See ch. 3 for                                years. NIH has also funded various projects
additional information on uses of this                              related to contact tracing tools. 20
funding.)
                                                                    In early 2020, NIST began work on a project,
CDC has also funded research on exposure                            which is currently ongoing, to study and
notification apps, including research                               develop exposure notification systems with
performed by the Massachusetts Institute                            strong privacy and cybersecurity
of Technology’s Lincoln Laboratory, to                              protocols. 21 As a part of this project, NIST
examine barriers to adoption and the                                held an event in June 2020 to help facilitate
efficacy of the underlying technologies used                        research aimed at improving the
by various apps. Further, CDC officials                             performance of these kinds of apps.
stated that the agency has provided                                 Further, in January 2021, NIST held a
ongoing support and consultation to states                          workshop on challenges associated with
interested in implementing exposure                                 exposure notification apps.
notification apps. For example, since early
August 2020, CDC has coordinated with                               Other stakeholders
Lincoln Laboratory to host meetings with
state public health authorities where they                          National public health organizations have
can discuss issues related to app                                   issued guidance and provided other support
development and deployment.                                         to state public health authorities to assist in
                                                                    the development and deployment of
In addition, DHS’s Science and Technology                           exposure notification apps. These
Directorate provided funding to two                                 organizations include the Association of
projects through its Silicon Valley                                 Public Health Laboratories (APHL),
Innovation Program. 19 These projects are                           Association of State and Territorial Health
intended to develop criteria the apps can be                        Officials, Council of State and Territorial
tested against and to enable the capability                         Epidemiologists, National Association of
to test the apps using the criteria. According                      County and City Health Officials, Linux
to DHS officials, they expect that these                            Foundation Public Health, the Public Health
projects will be completed in the next 2                            Informatics Institute, and others. Other key
                                                                    stakeholders include entities involved in the
                                                                    research and development of exposure


18                                                                  19
  The 64 jurisdictions receiving awards under the                     DHS intends for this program to find new technologies
Epidemiology and Laboratory Capacity for Prevention and             that strengthen national security.
Control of Emerging Infectious Diseases cooperative                 20
agreements include all 50 states, several large metro areas,          These projects included tools to identify businesses and
and U.S. territories and affiliates. A full list of recipients is   hot spots visited by people with COVID-19 and development
provided on the Centers for Disease Control and                     of a digital health pass to enable businesses to verify health
Prevention’s website. See Centers for Disease Control and           credentials.
Prevention, National Center for Emerging and Zoonotic               21
                                                                       A system (or protocol) provides a framework that
Infectious Diseases, Division of Preparedness and Emerging          determines the function of a particular software application,
Infections, Recipients, Project Officers, and Jurisdictional        like an app on a smartphone.
Assignment Listing, (Atlanta, Ga.: last reviewed June 16,
2021), accessed June 30, 2021,
https://www.cdc.gov/ncezid/dpei/elc/advisor-list.html.




                                                                                   Exposure Notification GAO-21-104622 7
notification apps or analysis of their                 they developed this system to help
performance. Specifically, researchers,                governments and the global community
organizations, and technology companies                slow the spread of the COVID-19 pandemic.
have played a key role in the design of the            In addition, Google and Apple collaborated
systems used by exposure notification                  with Microsoft and APHL to establish and
apps. 22                                               host servers to facilitate the system.
                                                       Further, Google and Apple collaborated
In May 2020, Google and Apple—the two                  with the MITRE Corporation to deploy the
primary developers of operating systems                Exposure Notification Private Analytics
for smartphones—collaborated on the                    portal, which provides public health
development of an exposure notification                authorities with data on the performance of
system used by the states discussed later in           the states’ apps. This effort involves several
the report. According to Google and Apple,             other partners, including the Internet
                                                       Security Research Group and NIH.




22
  These include, for example, the TCN Coalition and
Massachusetts Institute of Technology Pact developed
systems—referred to as the Temporary Contact Numbers
Protocol, or TCN Protocol; and the Private Automated
Contact Tracing (PACT) protocol, respectively.




                                                                  Exposure Notification GAO-21-104622 8
2 Benefits and Design of Exposure Notification Apps

Exposure notification apps are intended to                      documentation, and publications that we
automate and augment the manual contact                         reviewed.
tracing process, with enhanced speed and
reach being among the expected benefits,                        Speed. Apps are expected to allow for
according to scientific literature, state                       faster identification and notification of
officials, federal agency documents, and                        contacts. After a positive test result is
representatives of stakeholder                                  received, apps automate the process of
organizations we interviewed. They work by                      identifying and notifying contacts. This
using proximity detection to determine                          automation can lead to faster notification,
when two smartphone users are in close                          which in turn can lead to faster changes in
contact, then notifying all contacts of a user                  individual behavior aimed at helping slow
who later reports a positive test result for                    disease transmission, namely testing and
                                                                quarantine, according to selected studies. 23
COVID-19. The apps can use a centralized,
decentralized, or hybrid system to collect,
store, and manage data. Many states within                      Reach. Apps are also expected to provide
the U.S. are using apps based on a                              more complete and faster identification of
decentralized system that was developed                         contacts because, unlike manual contact
jointly by Google and Apple.                                    tracing, they do not rely on a person’s
                                                                memory to identify the people they came
                                                                into contact with, according to CDC
2.1 Exposure notification apps are
                                                                documents. In addition, according to a Pew
expected to provide enhanced                                    Research Center report, 41 percent of
speed and reach                                                 Americans asked about their views on
                                                                speaking with a public health official
Exposure notification apps are expected to                      reported that they are unlikely to talk with
provide two key benefits—speed and reach.                       contact tracers. The report also noted that
Specifically, they are expected to allow for                    younger adults, those with lower incomes,
more timely identification and notification                     and those with less formal education are
of contacts and greater (more complete)                         especially unlikely to engage with manual
coverage of contacts, according to the                          contact tracers. 24 Apps may provide a way
majority of the selected states, CDC
                                                                to increase coverage of these populations.
                                                                In addition, apps can reach people even



23                                                              Institute of Technology, Oct. 29, 2020), and J.A. Moreno
   John Hopkins University and Association of State and
Territorial Health Officials, A National Plan to Enable         Lopez et al., “Anatomy of Digital Contact Tracing: Role of
Comprehensive COVID-19 Case Finding and Contact Tracing         Age, Transmission, Setting, Adoption, And Case Detection,”
in the US (Baltimore, Md.: Johns Hopkins University, Apr. 10,   Science Advances, vol. 7, no. 15 (2020): eabd8750.
2020), Massachusetts Institute of Technology Lincoln            24
                                                                  Pew Research Center, The Challenges of Contact Tracing
Laboratory, Realizing the Promise of Automated Contact          as U.S. Battles COVID-19, (last updated Oct. 30, 2020),
Tracing Technology to Control the Spread of COVID-19:           accessed July 2, 2021,
Recommendations for Smartphone App Deployment, Use,             https://www.pewresearch.org/fact-tank/2020/10/30/key-fi
and Iterative Assessment (Cambridge, Mass.: Massachusetts       ndings-about-americans-views-on-covid-19-contact-tracing/.




                                                                              Exposure Notification GAO-21-104622 9
when manual contact tracing resources are                          signal can receive and store these
limited or overwhelmed.                                            encounter messages. The distance
                                                                   between two phones can be estimated
2.2 How exposure notification apps                                 by comparing the strength of the BLE
                                                                   signal when it was sent with its strength
work                                                               when it is received. 27
                                                              •    If one or more of the messages later
Exposure notification apps use proximity
                                                                   turns out to have been from a contact
detection to determine whether two app
                                                                   who tested positive for COVID-19, a
users are in close contact. The app then
                                                                   central server or a user’s smartphone
notifies a person if they had been in close
                                                                   analyzes the encounter message to
contact with another user who was likely
                                                                   determine whether the user’s risk of
infectious at the time, and who voluntarily
                                                                   exposure exceeds a predetermined
confirmed their diagnosis in the app.
                                                                   threshold. The risk analysis includes
Proximity detection involves a series of
                                                                   factors such as the time spent at
automated actions that determine the
                                                                   various distances and when the contact
proximity of two persons, notify them of
                                                                   occurred in relation to when the
potential exposure, and provide guidance in                        contact was most infectious. 28
the case of exposure.
                                                              The formula used to calculate the level of
The proximity detection steps are described
                                                              risk, including the specific risk factors, can
more fully here.
                                                              be set by the public health agency. The
                                                              assessment generally involves determining
•    An exposure notification app                             whether the encounter meets the CDC’s
     periodically broadcasts messages
                                                              definition of a close contact (i.e., at least 15
     (referred to as encounter messages)
                                                              minutes within 6 feet within 24 hours). The
     using a wireless radio transmission
                                                              apps do not consider other factors that
     technology—Bluetooth Low Energy
                                                              affect the risk of infection. For example,
     (BLE) 25—that contain, among other
                                                              they do not consider whether the users
     things, a random identifier and the
                                                              were wearing masks, or whether the
     strength of the signal sent (i.e.,
     transmitted power). 26 Any other phone                   encounter occurred in a well ventilated
                                                              location (e.g., indoors or outdoors).
     that has the same or similar app
     installed and is in range of the user’s



25                                                            27
  BLE is a wireless radio transmission technology with a        The BLE signal will weaken as the distance between two
range of around 30 feet. BLE started to be included in        smartphones increases. The strength of the signal when it is
smartphones in 2011, and is now included on most              received is referred to as a received signal strength
smartphones to enable communication between devices,          indication measurement.
such as smart watches and wireless headphones.                28
                                                                This can be determined based on when the person first
26
  To help preserve user privacy and to limit the ability to   had symptoms or was tested.
track the movements of other users, the random identifiers
are changed on a periodic basis (e.g., every 10 minutes).
Further, the identifiers do not reveal any personal
information about other users.




                                                                           Exposure Notification GAO-21-104622 10
If a user’s risk of exposure exceeds the risk                  of measurements and other potential
threshold, the user receives an exposure                       technologies.
notification from the app. 29 The exposure
notification can also include other                            Location data can also be used instead of,
information, such as when the exposure                         or in addition to, the data gathered using
occurred and the next steps the person                         the BLE messages. Location data are not
should take, such as getting tested,                           currently used by U.S. states. However,
monitoring symptoms, and self-                                 other nations (e.g., Israel) have apps that
quarantining. See figure 1 for an example of                   use Global Positioning System (GPS) data to
an exposure notification message.                              track and record a person’s location,
                                                               including the date and time. 30 Further, apps
The distance measured between two                              can track user locations by having the user
phones using BLE is only an estimate, and                      scan a quick response (QR) code at a
its accuracy can be affected by various                        specific location (e.g., venue, restaurant). 31
factors. See section 4.1 for additional                        The app then records the location, date,
discussion of factors affecting the accuracy




29                                                             31
  In certain systems, a public health provider could provide     A QR code is a barcode with the ability to encode different
the notification in lieu of an app notification.               types of information. Each location needs to have a unique
30                                                             QR code and it must be accessible (e.g., posted at the
  Other methods to determine a smartphone’s location           entrance to a building).
include assisted-GPS, the triangulation of cell towers, and
Wi-Fi access point identification.




                                                                            Exposure Notification GAO-21-104622 11
and time. 32 See figure 2 for an example of a                    2.3 Apps can use either a
QR code.                                                         centralized, decentralized, or hybrid
                                                                 system to manage data

                                                                 Exposure notification apps can use a
                                                                 centralized, decentralized, or hybrid
                                                                 architecture for collecting, storing, and
                                                                 analyzing data. 35 The main difference
                                                                 between these types of architecture is the
                                                                 extent to which the information used to
                                                                 determine exposure is stored and analyzed
                                                                 on a central server or on an individual
                                                                 smartphone. These differences affect the
                                                                 privacy protections built into the system. A
                                                                 decentralized architecture may help
                                                                 preserve a user’s privacy more than a
                                                                 centralized architecture. These types of
                                                                 architecture are described more fully here.

                                                                 •    In a centralized architecture, most of
A user’s recent locations can be compared                             the data are stored on a central server,
with a list of locations of people who have                           which also analyzes the data to
tested positive for COVID-19 to determine                             determine which users may have been
the risk of exposure. 33 However, GPS                                 exposed. For example, the central
location estimates are only accurate within                           server collects personal information as
about a 16-foot radius outdoors. In                                   a part of users’ registration and
addition, the accuracy decreases near                                 generates the random identifiers used
buildings, bridges, and trees, and indoors or                         for the encounter messages. A public
underground. 34 Thus, the location estimates                          health authority can access this
may not always be reliable in determining                             information (including information on
whether two people were in close contact.                             which users were in contact) and
                                                                      aggregate it to perform further analyses
                                                                      of the data to identify additional
                                                                      potential exposures and to identify
                                                                      potential surges in cases to help inform


32                                                               35
  The app uses the phone’s camera to scan the QR code.             Data architecture is a framework that comprises of
33                                                               models, policies, rules, and standards that govern the
  The list of locations from infected persons can also include   collection, storage, arrangement, integration, and use of
locations obtained through manual contact tracing.               data in organizations.
34
  National Coordination Office for Space-Based Positioning,
Navigation, and Timing, GPS Accuracy, (Washington, D.C.:
last update Apr. 22, 2020), accessed May 17, 2020,
https://www.gps.gov/systems/gps/performance/accuracy.




                                                                              Exposure Notification GAO-21-104622 12
    broader mitigation and response                 contact tracing efforts, and identifying
    efforts. The central server can also            where infections may be occurring. For
    incorporate data from other sources,            example, this architecture does not
    such as manual contact tracing (e.g.,           allow authorities to know who received
    locations an infected person visited).          an exposure notification.
    However, storing data on a centralized
                                                •   A hybrid architecture incorporates
    server can also reveal potentially
                                                    aspects of both architectures.
    sensitive information to governmental
                                                    Specifically, the random identifier
    organizations, or others who gain
                                                    generation for encounter messages
    access to the server. An example of a
                                                    remains decentralized (i.e., handled by
    centralized app is one used by the
                                                    user smartphones) to help preserve
    nation of Singapore, which it deployed
                                                    privacy, while the risk analysis and
    in March 2020.
                                                    notifications are handled by the central
•   In a decentralized architecture, most of        server. Hybrid systems have been
    the data are located on users’                  developed by researchers, but we are
    smartphones, with only limited data on          not aware of their use at a national or
    a central server. Each user’s device            state level.
    analyzes the data to determine whether
    an exposure has occurred. This              Table 1 provides a comparison of the
    approach may help preserve personal         different architectures, including how data
    privacy; however, it also limits the data   are managed and the key advantages and
    that are available to public health         disadvantages to each approach.
    authorities for determining the
    effectiveness of the apps, informing




                                                         Exposure Notification GAO-21-104622 13
Table 1: Advantages and disadvantages of centralized, decentralized, and hybrid data architectures
used in exposure notification apps

                                         Centralized                        Decentralized                   Hybrid
 Where most information is               central server                     smartphone device               smartphone device
 stored
 Where random identifiers                central server                     smartphone device               smartphone device
 are generated
 Where exposure data are                 central server                     smartphone device               central server
 analyzed
 Level of data access by                 higher                             lower                           moderate
 public health authorities
 Key advantages                          Public health authorities          Seeks to preserve               Seeks to preserve
                                         can access data to                 individual privacy by           individual privacy and
                                         perform analysis,                  limiting data accessible to     provides health
                                         identify additional                entities (e.g., public health   authorities with useful
                                         exposure and potential             authorities).                   data.
                                         surges, and inform
                                         response efforts.a
 Key disadvantages                       Data could reveal                  Limits the data that are        Data could reveal
                                         potentially sensitive              available to public health      potentially sensitive
                                         information to public              authorities for determining     information to public
                                         health authorities or              how well the app works          health authorities or
                                         other entities that gain           and to inform response          other entities that gain
                                         access to the server.              efforts.                        access to the server.
Source: Based on GAO review of technical and industry documentation. I GAO-21-104622
aThe central server can also incorporate data from other sources, such as manual contact tracing (which can provide

the location of an infected person among other things).

2.4 States are widely using the Google                                       customizing their own exposure notification
and Apple Exposure Notifications                                             apps.
system
                                                                             In September 2020, Google and Apple
                                                                             provided public health authorities with an
U.S. states with apps are using the Google and
                                                                             additional option (referred to as the Express
Apple Exposure Notifications system. 36 (See
                                                                             option), which was intended to make it easier
ch. 3 for additional information on                                          for authorities to use the Google Apple
deployment of apps by state public health                                    system by removing the need for the
authorities.) The Google Apple system was                                    authorities to build their own custom apps. In
released in May 2020 as an application-                                      this option, Google developed an app for
programming interface to be used by public                                   Android-based phones, and Apple deployed
health authorities in developing and                                         app-less functionality, such that a person can




36
  For the purposes of this report we refer to the Google and
Apple Exposure Notifications system as the Google Apple
system.




                                                                                            Exposure Notification GAO-21-104622 14
enable the system for their area (if available)                   encounter messages. If there is a match, the
through the settings on an iPhone. 37                             app analyzes the risk of exposure based on
                                                                  the method and parameters established by
The Google Apple system uses BLE and a                            the public health authority. If the risk exceeds
decentralized architecture. In this system,                       a predetermined threshold, the app displays
each user’s app creates a temporary key                           an exposure notification to the app user. The
(changes every 24 hours) that the app uses to                     notification can include guidance and
generate random identifiers, and to encrypt                       instructions. Figure 3 provides an overview of
information provided in the encounter                             this process.
messages. The app then exchanges a random
identifier with other users’ apps, and                            In August 2020, Microsoft partnered with
maintains a list of the encounter messages                        APHL to establish a key server that could be
that the user has received. To help preserve                      used by all U.S. states—the National Key
the privacy of the users, the encounter                           Server. With its launch, apps from different
messages do not include personal information                      U.S. states could be interoperable, so that app
or location data.                                                 users can find out if they have been exposed
                                                                  without needing to download and use apps
If the user tests positive for COVID-19, a                        from multiple states. 38 This feature is
public health authority uses a verification                       particularly important in regions where
server to generate a verification code, and                       commuters regularly cross jurisdictional
then sends the user the code to verify the                        boundaries (e.g., in neighboring areas of
positive test result. A user can then                             Washington D.C., Maryland, and Virginia).
voluntarily input this code in the app to                         Further, according to APHL, the server also
submit their recent temporary keys (e.g.,                         reduces the burden of each state’s public
prior 14 days) to a key server. If a user                         health agency needing to build and host its
chooses not to input the code in the app, the                     own key server.
user will not enable the notification of other
recent close contacts who were also using the
                                                                  In addition to the National Key Server, APHL
app of potential exposure.
                                                                  manages a central verification server,
                                                                  referred to as the Multi-tenant Verification
Each exposure notification app periodically                       Server, which was launched in September
downloads the temporary keys from people                          2020. APHL made the verification server
who had recently tested positive from the key                     available to reduce the effort needed by
server and then compares it with its list of                      public health agencies to bring an exposure


37                                                                38
  The Express option works differently on iPhones and Android       App interoperability means that a person using an app from
phones. For iPhones, the Express option is built into the         one state could receive an exposure notification based on an
operating system and can be activated by users in the iPhone      encounter with any other person who had an app that also
settings. To receive exposure notifications, no app is required   used this server, such as a person from another state.
and therefore it is said to have “app-less” functionality. For
Android smartphones, states develop the configuration
settings (e.g., risk parameters), and Google then develops the
app, which states can then use. For Apple devices, the Google
Apple system works on iPhones running at least iOS 12.5. For
Android, the system works for any smartphone capable of
running Android version 6.




                                                                                 Exposure Notification GAO-21-104622 15
notification app to their jurisdiction. As a part
of the Google Apple system, APHL noted that
a verification server is necessary to ensure a
user has received a positive test result before
uploading their temporary keys to the
National Key Server. APHL also noted that
rather than each public health agency
standing up its own verification server and
deciding on a verification approach, providing
one verification server reduces the time and
cost to deploy the Google Apple system. For
the states and territories with apps, nearly all
were using the National Key Server, while
over two-thirds were using the Multi-tenant
Verification Server as of August 2021,
according to APHL. 39




39
  Although a verification server is necessary, it does not have
to be the Multi-tenant Verification Server, so some states
elected to use their own verification servers.




                                                                  Exposure Notification GAO-21-104622 16
Exposure Notification GAO-21-104622 17
3 Deployment and Adoption of Exposure Notification Apps

Almost half of U.S. states have deployed an      3.1 About half of the states have
exposure notification app. In the absence of a   deployed an exposure notification
national exposure notification app, states       app
have independently launched their own apps
at different times, resulting in a staggered
                                                 As of June 2021, 26 of 56 U.S. states
rollout. States have developed and deployed      (including territories and the District of
apps using the Google Apple system and           Columbia) have deployed an app (see fig. 4).
about half have customized their apps, which     Unlike other countries, the U.S. does not have
provides the apps with more flexibility and      a national exposure notification app; instead,
functionality. According to officials from       states have independently deployed
selected states, development time, costs, and    individual apps.
levels of adoption have varied.




                                                            Exposure Notification GAO-21-104622 18
The patchwork of app deployment shown in           The 26 states deployed apps over a span of 10
figure 4 arises from the fact that public health   months, in a staggered rollout beginning in
authorities at the state and territorial levels    August 2020. Figure 5 provides a timeline of
decide whether and when to deploy an app.          app deployment and related events. Virginia
Furthermore, there was no existing option for      was the first state to deploy an exposure
a national app that states could use,              notification app, in August 2020, and
according to CDC documentation. As of June         Massachusetts was the most recent, in June
2021, 26 out of 56 states had deployed apps.       2021. Seventeen of the states deployed an
Officials from seven selected states that had      app between October 2020 and June 2021,
not deployed an app cited several reasons for      which was after the Express option was made
that decision, including limited cell phone        available (see fig. 5).
coverage in rural areas or other challenges
related to the deployment and use of an app
(see ch. 4 for additional detail). They also
cited competing priorities, such as natural
disaster response or vaccine distribution
efforts, and were concerned that exposure
notification app development would divert
limited resources away from other priorities.




                                                              Exposure Notification GAO-21-104622 19
Note: The timeline indicates the Google Apple exposure notification option that was initially deployed by the state
(i.e., custom or Express). Seven states deployed the Express option after initially deploying a custom app (Minnesota,
Nevada, Hawaii, New York, Virginia, Louisiana, and New Jersey) between January and April 2021. In addition to
exposure notification apps based on the Google Apple system, a few states developed smartphone apps to help
people monitor their COVID-19 symptoms or assist in recalling the places they had visited when providing that
information to a contact tracer. For example, in April 2020, Utah deployed an app which allowed residents to check
their symptoms, and privately share a subset of their location information with public health officials to aid in the
contact tracing process. In summer 2020, Utah disabled the location-based services in this app.




                                                                            Exposure Notification GAO-21-104622 20
3.2 About half of the states use a
customized app

Of the 26 U.S. states that had deployed
apps as of June 2021, all are using a version
of the Google Apple system. 40 With this
system, public health authorities can
choose to develop customized apps, use the
Express option, or use both in tandem (see
table 2). States could use, for example, a
customized app for Android and the Express
option for iOS smartphones. 41




40                                                              41
  In addition to the U.S., most countries with an app use BLE     One of the selected states uses a customized app for both
(primarily using the Google Apple system); approximately        Android and iOS and also enabled the Express option for iOS.
one-third use GPS. Some countries use both BLE and QR
codes; for example, the United Kingdom’s National Health
Service’s app uses both the Google Apple system and QR
codes to check-in to locations.




                                                                             Exposure Notification GAO-21-104622 21
Table 2: U.S. states deployment of apps using the Google Apple Exposure Notifications system
   States                                                 Customized app                                 Express option
   Alabama                                                ●                                              ○
   Arizona                                                ●                                              ○
   California                                             ○                                              ●
   Colorado                                               ○                                              ●
   Connecticut                                            ○                                              ●
   Delaware                                               ●                                              ○
   District of Columbia                                   ○                                              ●
   Guam                                                   ●                                              ○
   Hawaii                                                 ●                                              ●
   Louisiana                                              ●                                              ●
   Maryland                                               ○                                              ●
   Massachusetts                                          ○                                              ●
   Michigan                                               ●                                              ○
   Minnesota                                              ●                                              ●
   Nevada                                                 ●                                              ●
   New Jersey                                             ●                                              ●
   New Mexico                                             ○                                              ●
   New York                                               ●                                              ●
   North Carolina                                         ●                                              ○
   North Dakota                                           ●                                              ○
   Pennsylvania                                           ●                                              ○
   Utah                                                   ○                                              ●
   Virginia                                               ●                                              ●
   Washington                                             ○                                              ●
   Wisconsin                                              ○                                              ●
   Wyoming                                                ●                                              ○
   Total                                                  16                                             17
Legend: ● = State or territory that is using a version of the Google and Apple Exposure Notifications system; ○ =
State or territory that is not using the identified version of the Google Apple system.
Source: GAO compilation of data from selected states, related documents, interviews, and other sources. I GAO-21-104622

Note: State public health authorities can deploy customized exposure notification apps, which may offer unique
functions and features. State public health authorities can also elect to use the Express option of the Google Apple
system. The Express option provides convenience and efficiency but potentially less flexibility to tailor exposure
notification functionality. The total in the table (33) does not equal the number of states with apps (26) because some
states use both a customized app and the Express option.


To build a customized exposure notification                                university partners). For the Express option,
app, public health authorities can seek                                    public health authorities can provide Google
external technical support (e.g., third-party                              and Apple an electronic configuration file that
developers, nonprofit organizations, or                                    includes instructions and content, including




                                                                                             Exposure Notification GAO-21-104622 22
the risk parameters for enabling an exposure        For example, a customized app may help
notification and messaging for app users.           users identify testing facilities and access
While states can use their own internal             state-level statistics about COVID-19
technical team or seek outside help to              infections and death rates. State officials
develop their app, officials from all nine of the   noted that they included these features to
selected states we interviewed said they had        provide information to the public outside of
limited technical expertise and resources and       their agencies’ websites, which they hoped
received varying levels of external support to      would encourage people to download and
deploy their apps, regardless of whether they       use their app. Based on our observations of
used customized apps or the Express option.         exposure notification apps for the selected
                                                    states, a common customized function was
According to Google and Apple                       the ability to share the app with others.
representatives, the Express option was             Figure 6 shows screenshots for two
developed to help states quickly and easily         customized apps. These images illustrate how
deploy their app. However, the Express              an app can be tailored to offer unique
option does not offer states the same               functions in the user interface. For example,
flexibility to tailor the functions and features    one screenshot illustrates a unique function,
of their app as do customized exposure              “Healthcheck,” which allows app users to
notification apps.                                  report any COVID-19 related symptoms,
                                                    exposure history, and testing history to their
                                                    public health authority.




                                                               Exposure Notification GAO-21-104622 23
Note: The number in the image on the left (490238) is an illustration of a verification code that would be provided by
a public health authority to an app user to verify the positive results of a COVID-19 test. A user can then voluntarily
input this code in the app to submit their recent temporary keys.




                                                                             Exposure Notification GAO-21-104622 24
Based on our review of the apps for the nine                      preparing marketing campaigns, and choosing
selected states, among other qualitative                          to pilot the app prior to the full release. States
differences between state apps, we noted                          that chose the Express option generally noted
variation in the depth and scope of guidance                      shorter development times.
information provided to app users.
Specifically, some states provided more                           The cost of app development also varied
detailed information on symptoms, testing,                        according to the information reported to us
and quarantine. We also found that the apps’                      by officials from the 11 states. 44 One state
privacy use agreements provided varying                           reported zero development costs because a
details on how the apps protect privacy,                          nonprofit organization developed the state’s
including how users can delete their data. 42                     app, while another state reported
                                                                  development costs of $700,000. 45 State
                                                                  officials noted that their marketing costs also
3.3 States reported that app
                                                                  varied; costs ranged from $380,000 to $3.2
development time and cost varied                                  million, as of June 2021.
based on several factors
                                                                  States used federal funding for development
Officials from each of the nine selected states                   and marketing costs; some used state funding
we interviewed and the two additional states                      as well. Six of the nine states reported that
that provided written information varied in                       they used CARES Act funding to support the
their reported app development time frames                        development of their apps or marketing costs.
and costs. 43 Some public health authorities                      However, according to the CDC, which
from these states attributed these variations                     distributes certain CARES Act and
to several factors, including legal review and                    supplemental COVID-19 relief funds through
marketing efforts. Officials from nine of the
                                                                  its Epidemiology and Laboratory Capacity for
11 states reported that the time to develop
                                                                  Prevention and Control of Emerging Infectious
their apps ranged from less than 2 months to
                                                                  Diseases cooperative agreement, 46 exposure
over 5 months. This time included the
                                                                  notification apps are allowable expenses
development of the apps, as well as
conducting legal reviews of contracts,                            through these awards, but the agency does


42                                                                45
  Some of the exposure notification apps had embedded links         We did not independently verify the states’ reported costs.
to the public health authorities’ websites, which provided        46
access to the state’s privacy use agreement or other                As part of the Coronavirus Aid, Relief, and Economic Security
information.                                                      Act (CARES), Coronavirus Preparedness and Response
                                                                  Supplemental Act, and Paycheck Protection Program and
43
   We interviewed state public health officials from a non-       Health Care Enhancement Act supplements, the cooperative
generalizable sample of nine states that had deployed an          agreement awarded approximately $11 billion to support the
exposure notification app as of January 1, 2020: Alabama,         domestic response to COVID-19. See CARES Act, Pub. L. No.
Colorado, Connecticut, Minnesota, Nevada, North Carolina,         116-136, 134 Stat. 281 (2020); Coronavirus Preparedness and
Pennsylvania, Virginia, and Washington. We also reached out       Response Supplemental Appropriations Act, 2020, Pub. L. No.
to two other states, Louisiana and Utah, which deployed apps      116-123, 134 Stat. 146 (2020); Paycheck Protection Program
in the later stages of our evidence collection about the status   and Health Care Enhancement Act, Pub. L. No. 116-139, 134
of their efforts to deploy an app and received written feedback   Stat. 620 (2020). An additional award of $19.11 billion from the
to our structured questions.                                      Coronavirus Response and Relief Supplemental Appropriations
44                                                                Act of 2021, Pub. L. No. 116-260, Div. M was awarded to
  This includes the nine selected states we interviewed and the   continue to shore up domestic response efforts to COVID-19.
other two states that provided written responses to our           See Consolidated Appropriations Act, 2021, Div. M, Pub. L. No.
questions.                                                        116-260, 134 Stat. 1182 (2020).




                                                                                  Exposure Notification GAO-21-104622 25
not require recipients to report on use of                     In addition, different levels of app use were
funds to support exposure notification apps.                   reported by officials from the nine selected
                                                               states we interviewed and the two additional
3.4 Officials reported varying                                 states that provided written information.
                                                               Specifically, for two states the number of
download levels and use                                        times their app users received exposure
                                                               notifications as of June 2021 were above
Different app download levels (or activations                  30,000 (31,000 for one state and 42,000 for
for states using the Express option) were                      the other), while four states reported
reported by officials from the nine selected                   notifications that ranged from about 900 to
states we interviewed and the two additional                   3,800; the remaining five states did not track
states that provided written information. 47                   these data. However, the number of
Specifically, four states reported less than 1                 notifications depends on a variety of factors,
million, four states reported 1 to 2 million,                  including the extent of the app users’
and two states reported more than 2 million                    contacts.
downloads (or activations), as of June 2021. 48
The other state does not track these data.                     Further, limited data are available on the
According to Google and Apple                                  extent to which exposure notifications
representatives, states that initially deployed
                                                               affected people’s behavior, according to
a custom app and then later added the
                                                               public health officials and studies we
Express option, experienced a significant
                                                               reviewed. For example, public health
increase in activations. Specifically,
                                                               authorities do not know whether app users
representatives stated that the adoption rate
                                                               are actually using the app and following
quadrupled for four states that added the
Express option (Nevada, New Jersey, New                        instructions for next steps contained in the
York, and Virginia). However, there may be                     alerts. Seven of the nine selected states that
other factors that affect adoption rates.                      we interviewed said that they did not track
Further, the number of downloads and                           whether app users actually sought testing or
activations is not an accurate reflection of the               medical care based on the receipt of an
number of people using the app. For example,                   exposure notification from an app; one state
a person could download or activate the app                    said it was done inconsistently and the other
and not use it, or could download the app                      remaining state did not respond to our
multiple times. See section 4.5 for additional                 request for these data.
information on this issue and appendix II for
additional information on state app adoption
rates.




47                                                             48
  Download data includes Android and iOS phones in states        States with customized apps can calculate download levels
with customized apps; downloads for Android phones in states   for Android and iOS smartphones from data obtained from
using the Express option; or “activations” for iOS phones in   Google and Apple apps stores. However, for states using the
states using the Express (“app-less”) option.                  Express option, they can determine downloads for Android
                                                               devices but must estimate the number of users that activated
                                                               the app on iOS smartphone.




                                                                              Exposure Notification GAO-21-104622 26
4 Challenges Associated with Exposure Notification Apps
We identified the following five categories                   the phone is being held or is in a pocket or
of challenges associated with these apps:                     otherwise obstructed location, and the
                                                              position of one phone with respect to the
•    Accuracy of measurements
                                                              other phone (e.g., if it has a 90 degree
•    Privacy and security concerns                            rotation or is facing down).
•    Adoption and use of apps
                                                              As a result, a person could receive a
•    Verification code delays                                 notification even if that person was far
•    Evidence of effectiveness                                away or separated by a physical barrier
                                                              from an infected person. Such a result,
                                                              known as a false positive, can lead a person
4.1 Accuracy of measurements                                  who has been notified to take unnecessary
                                                              steps, such as getting tested, or self-
The techniques that exposure notification                     quarantining. Further, false positives could
apps use to measure distance have                             reduce that person’s confidence in the app,
technical limitations that can result in users                which could lead to them not using the app
receiving false exposure notifications. For                   or using it less often. In addition, without
example, BLE wireless radio technology,                       accurate measurements, an app could fail
used to measure the distance between two                      to detect that two people are in close
smartphones, cannot always reliably                           proximity for a certain amount of time,
measure whether two smartphones are                           leaving the potentially exposed person with
within 6 feet of each other. In addition,                     a false sense of security—a false negative.
research has demonstrated that the BLE
signal strength does not always decrease                      To help address these limitations, various
with distance, and can even increase with
                                                              industry experts have highlighted the
distance under certain conditions. 49 For
                                                              potential of using other technologies to
example, objects in the environment
                                                              perform measurements instead of or in
between a sender and a receiver (e.g.,
                                                              addition to BLE, including ultra-wideband
furniture, walls, people) can impact the
                                                              signals and ultrasound. 50 Several studies
signal, causing the received signal strength
to vary substantially. Other factors include                  have found that these other technologies
the type of phone and antenna, whether                        may be more accurate than BLE. 51 In


49                                                            51
  See Douglas Leith & Stephen Farrell, “Coronavirus Contact     See, for example, N. Ahmed et al., “A Survey of COVID-19
Tracing: Evaluating the Potential of Using Bluetooth          Contact Tracing Apps,” IEEE Access, vol. 8 (July 2020):
Received Signal Strength for Proximity Detection,” ACM        134577-134601, accessed December 1, 2020,
SIGCOMM Computer Communication Review, vol. 50, no.4          https://doi.org/10.1109/ACCESS.2020.3010226; and J.
(2020); 1-11.                                                 Meklenburg et al., “SonicPACT: An Ultrasonic Ranging
50                                                            Method for the Private Automated Contact Tracing (PACT)
  Like BLE, ultra-wideband is a wireless radio transmission   Protocol,” arXiv.org (Dec. 2020): 1-14, accessed November
technology, but it could provide measurements that are        24, 2020, https://arxiv.org/abs/2012.04770.
more accurate. However, ultra-wideband is only available on
certain newer smartphones. Ultrasound refers to the
transmission of inaudible acoustic pulses in the ultrasonic
frequency range between phones.




                                                                          Exposure Notification GAO-21-104622 27
addition, researchers have suggested that                       Despite the privacy protections built into
exposure notification apps could use sensor                     the apps by Google and Apple, the public
technologies to improve distance                                may lack confidence that their privacy is
estimation based on BLE measurements,                           protected, in part, due to a lack of
such as by using a gyroscope, an                                independent assessments and federal legal
accelerometer, or a magnetometer. 52 For                        protections for the privacy of app data. In
example, these technologies could help to                       particular, CDC’s guidance on the
detect the position of the phone. However,                      implementation and use of exposure
                                                                notification apps recommends that the
thus far, there has been only limited use of
                                                                apps go through independent security and
these technologies. Specifically, while some
                                                                privacy assessments, 53 and that the results
entities with an exposure notification app
                                                                be made publicly available. 54 However, we
use ultrasound technology for distance
                                                                found that none of the nine selected states
estimation, including several U.S.
                                                                had fully implemented this guidance.
universities, as of June 2021, we did not
                                                                Specifically, officials from five of the nine
find any exposure notification apps that use
                                                                selected states reported that security and
ultra-wideband signals, a gyroscope,
                                                                privacy assessments were performed;
accelerometer, or a magnetometer.                               however, the results were not made
                                                                publicly available. The remaining four states
4.2 Privacy and security concerns                               reported that these assessments were not
                                                                performed.
Privacy
                                                                Currently there is no federal law that
Officials from all nine of the selected states                  provides the public with clearly applicable
identified privacy as an important factor in                    privacy protections for the information that
determining whether to implement an                             exposure notification apps gather.
exposure notification app and in selecting                      Specifically, in January 2019, we reported
the system used by the app (i.e., Google                        that the U.S. did not have a comprehensive
Apple system). In particular, officials stated                  internet privacy law governing the
that users would likely not adopt an app                        collection, use, and sale or other disclosure
that collected their personal information,                      of consumers’ personal information.
including location data.                                        Accordingly, we recommended that
                                                                Congress consider developing legislation on



52                                                              document detailing the process and the outcome of the
  A gyroscope is a device used for measuring or maintaining
orientation and angular velocity. An accelerometer is a         analysis. See Office of Management and Budget, Managing
device used to measure acceleration forces. A                   Information as a Strategic Resource, Circular A-130
magnetometer is a device that measures the strength and         (Washington, D.C.: July 2016).
sometimes the direction of magnetic fields.                     54
                                                                  Centers for Disease Control and Prevention, Guidelines for
53                                                              the Implementation and Use of Digital Tools to Augment
   An example of such an assessment is a privacy impact
assessment that is used by federal agencies in response to      Traditional Contact Tracing, version 1.0 (Atlanta, Ga.: Dec.
requirements in the E-Government Act of 2002. Among             15, 2020) and Preliminary Criteria for the Evaluation of
other things, the assessment is an analysis of how personally   Digital Contact Tracing Tools for COVID-19, version 1.2
identifiable information is handled to ensure compliance        (Atlanta, Ga.: May 17, 2020).
with applicable privacy requirements and manage privacy
risks. Also, a privacy impact assessment includes a formal




                                                                             Exposure Notification GAO-21-104622 28
internet privacy that, among other things,                       Security
would enhance consumer protections. 55
Legislation governing the collection and use                     To ensure that exposure notification apps
of consumers’ personal information—in                            function as intended and that user privacy
particular for exposure notification apps—                       is protected, it is important that developers
could help to safeguard their privacy, and                       build in security protections. However,
provide the public with greater assurance                        security assessments of these apps are
that its privacy is protected. However, such                     limited.
legislation has not been enacted. 56
                                                                 Security considerations should include the
In the absence of such legislation, individual                   supporting infrastructure—such as central
companies have set their own privacy                             servers—and address how the data are
requirements for exposure notification                           stored and maintained, including
apps, including requirements on the
                                                                 appropriate authentication and access
collection and use of the data. For example,
                                                                 controls. Security incidents could lead to
Google and Apple have each established
                                                                 privacy violations (e.g., identifying or
requirements for their exposure notification
                                                                 tracking users) or disrupt the functioning of
system and their respective app stores
regarding data collection and privacy. These                     the app (e.g., inserting false data). This
requirements specify that only the                               would likely result in the public’s loss of
minimum amount of user data that is                              confidence in the apps, potentially leading
necessary for response efforts should be                         to decreased use. Researchers have
collected, and that the data may only be                         identified a variety of potential threats for
used for such efforts. 57 In addition, the
requirements state that the apps cannot
collect any information to identify or track
the precise location of users.




55                                                               specifically address exposure notification apps or the
  GAO, Internet Privacy: Additional Federal Authority Could
Enhance Consumer Protection and Provide Flexibility,             associated privacy issues. In addition, at least one state
GAO-19-52 (Washington, D.C.: Jan. 15, 2019). Other federal       passed a law regarding the use of location data for contact
laws governing health information, including the Health          tracing. Specifically, in June 2020 Kansas passed a law stating
Insurance Portability and Accountability Act, may not            that contact tracing shall not be conducted through the use
provide consistent, clearly-applicable privacy protections for   of any service or means that uses cell phone location data to
the information that likely would be gathered and used in        identify or track, directly or indirectly, the movement of
digital contact tracing activities. See Congressional Research   persons. See K.S.A. § 48-961 (2021).
Service, COVID-19: Digital Contact Tracing and Privacy Law,      57
                                                                   See, for example, Google, Google COVID-19 Exposure
LSB10511 (Washington, D.C.: July 9, 2020).                       Notifications Service Additional Terms, (last modified May 4,
56                                                               2020), accessed May 16, 2021,
  Congress has introduced several bills over its last two
sessions that address aspects of exposure notification apps      https://blog.google/documents/72/Exposure_Notifications_
or digital contact tracing tools. Of the bills that have been    Service_Additional_Terms.pdf; and Apple, Exposure
introduced, one that was enacted into law related to             Notification APIs Addendum, (last revised May 4, 2020),
implementing a national strategy for contact tracing and         accessed May 16, 2021,
enhancing information technology and data modernization          https://developer.apple.com/contact/request/download/Ex
capabilities (American Rescue Plan Act of 2021, Pub. L. No.      posure_Notification_Addendum.pdf.
117-2, § 2401, 135 Stat. 4, 40 (2021)). However, it does not




                                                                              Exposure Notification GAO-21-104622 29
exposure notification apps. 58 Table 3
identifies several examples of these threats
and their potential effects.

Table 3: Examples of threats and their effects for exposure notification apps
  Threat             Description                                   Potential Effect
  Re-                Comparing exposure notifications with         The identity of an infected app user is revealed.
  identification     personal logs of a phone owner’s recent
                     contacts.
  Denial of          Broadcasting fake encounter messages to       Loss of availability of a smartphone due to the
  service            consume resources of other smartphones.       additional battery power, storage, and processing
                                                                   time required to store and process the fake
                                                                   messages.
  Phone              Tracking a user’s location by analyzing the   A user’s location and movements is revealed.
  tracking           information sent in encounter messages,
                     such as the random identifiers.
  Relay (or          Re-transmitting captured encounter            Smartphone receives exposure notification despite
  replay)            messages at the same or a different           not coming in close contact with an infected person
                     location.                                     (i.e., false positive).

Source: GAO review of selected literature. | GAO-21-104622


The Google Apple system includes features                          apps are a relatively new technology, these
intended to mitigate these threats. In                             assessments have, as of now, limited data
addition, according to representatives from                        and results. Further, as previously stated,
these companies, they had a third party                            the selected states have not provided the
perform a security assessment of the                               results of independent security assessments
system. There are also ongoing assessments                         in a public format, as recommended by CDC
on the security of exposure notification                           guidance. 60
apps, including on the Google Apple
system. 59 However, as exposure notification



58                                                                 testing and validation services. In April 2021, the company
   See, for example, N. Ahmed et al., “A Survey of COVID-19
Contact Tracing Apps”; Massachusetts Institute of                  reported that it had identified a vulnerability with apps using
Technology Lincoln Laboratory, “Exposure Notification              the Google Apple system. Specifically, the company reported
Security Assessment Considerations,” Lexington,                    that preinstalled apps could gain access to system logs made
Massachusetts. Unpublished Article; and M. Chowdhury et            by exposure notification apps on Android devices. According
al., “COVID-19 Contact Tracing: Challenges and Future              to the company, these logs could include information, such
Directions,” IEEE Access, vol. 8 (Nov. 2020): 225703-225729,       as whether a person had received an exposure notification
accessed February 16, 2021,                                        and the random identifiers that a smartphone device had
https://ieeexplore.ieee.org/document/9252092.                      sent and received. Google representatives stated that a fix
                                                                   for this vulnerability was available as of May 5, 2021, and
59
  For example, the Massachusetts Institute of Technology’s         that there is no evidence that it was exploited.
Lincoln Laboratory has developed security assessment               60
                                                                     Centers for Disease Control and Prevention, Guidelines for
considerations for the Google Apple system and conducted a
security assessment of one of the apps used in the states. In      the Implementation and Use of Digital Tools to Augment
addition, in February 2021, DHS’s Science and Technology           Traditional Contact Tracing, version 1.0 (Atlanta, Ga.: Dec.
Directorate’s Silicon Valley Innovation Program awarded            15, 2020).
funding to a company (AppCensus) for a project to develop




                                                                                Exposure Notification GAO-21-104622 30
4.3 Adoption and use of apps                                 users, which followed other incidents of
                                                             misuse of personal information. 62 Also,
States have also faced challenges attracting                 multiple officials noted that the public was
public interest in downloading (or                           skeptical of the Google Apple system, since
activating) and using an exposure app. State                 it is a joint initiative between U.S.
public health officials told us that, in spite               technology companies and the government
of their marketing and outreach efforts,                     that involves personal health information.
getting people to download (or activate)                     In particular, officials from three states
and use their app is difficult for the                       indicated that the public expressed
following reasons.                                           concerns about the perceived “big brother”
                                                             nature of exposure notification.
Lack of trust. Mistrust of governmental
health authorities and technology                            Lack of understanding of how apps
companies can lead people to forgo using                     function. Multiple officials said they
apps, according to literature and state                      frequently had to counter misinformation
officials. For example, officials from six of                about how the apps work and the data they
the 11 states cited public concerns about                    collect. For instance, officials from one state
the use of apps for government surveillance                  reported that they emphasized the app's
(e.g., using the apps to track users’ location)              use as a public health communication tool
as a leading obstacle to app adoption, 61                    because of misinformation describing the
even though these apps do not collect                        exposure notification app as a data
location data. In addition, the public may                   collection tool used to surveil and track the
not trust big technology companies with                      public.
their data. These concerns may be
exacerbated by reported vulnerabilities                      Also, multiple officials said the public had a
with apps using the Google Apple system.                     limited understanding about the apps’
Specifically, as previously stated, a company                privacy-preserving features. Officials from
reported that other apps on a phone could                    three states said that they believed the
potentially gain access to sensitive                         public did not understand the technical
information, including whether a person                      aspects of the apps, which may include how
had received an exposure notification. In                    the random identifiers do not reveal
addition, the lack of trust regarding the use                personal information. 63 Such
of apps may be intensified by other                          misunderstandings may contribute to public
incidents where technology companies                         unwillingness to download or use the apps.
potentially misused consumers’ personal                      Further, such misunderstandings may also
information. For instance, in April 2018,                    contribute to hesitance to enter verification
Facebook disclosed that a Cambridge                          codes for people who had downloaded an
University researcher may have improperly                    app on their device. Specifically, sometimes
shared the personal data of 87 million of its                people receive positive COVID-19 test



61                                                           63
  The 11 states include nine from our selected sample plus     According to Google and Apple documentation, the
two additional states.                                       random identifiers exchanged with other smartphones are
62                                                           not linked to the app user’s identity or phone number and
  GAO-19-52.                                                 change on a periodic basis (e.g., every 10 minutes).




                                                                         Exposure Notification GAO-21-104622 31
results long after the app has been             reason they chose not to deploy an app was
downloaded. Because people may not have         the lack of necessary supporting
initially understood (or have forgotten) how    infrastructure or internet service in rural
the app works, including the apps’ built-in     areas. To be effective, exposure notification
privacy preserving features, some app users     apps need to be downloaded and used by a
many not want to input their verification       critical mass of the general public. While
codes to prompt exposure notifications to       the levels of adoption needed to achieve
other people, according to officials from       certain measures of effectiveness are not
selected states.                                well established (see section 4.5), increasing
                                                the number of people using the app should
Lack of awareness of the availability of the    result in a greater likelihood that users who
apps. Officials from several states noted       come in close contact with an infectious
that it was difficult to make people aware of
                                                person will be notified of potential
the apps. For example, officials from
                                                exposure, according to CDC and the
multiple states noted that they thought
                                                Massachusetts Institute of Technology’s
building awareness in closely connected
                                                Lincoln Laboratory.
communities with influential leaders would
encourage people to download and use an
app. However, one state tried, but was          4.4 Verification code delays
unsuccessful, in recruiting support from
some of these groups, including churches        States were challenged in distributing
and a college football program. One official    verification codes quickly to the public. As
said the lack of support was a lost             previously stated, these codes are used to
opportunity to build awareness and              confirm that a person had a positive test or
increase that state’s app adoption rate.        diagnosis before they are able to upload
Further, some states reported having            their recent temporary keys to the National
minimal resources for marketing, which one      Key Server. For people to be notified of
official said resulted in low awareness of      potential exposure quickly, these
the state’s app. Three states reported that a   verification codes need to be distributed in
federally led national marketing campaign       a timely manner and users need to
would have helped promote their app and         voluntarily decide to use them to notify
drive higher rates of adoption. Similarly,      recent contacts.
officials from a national health organization
reported that a national public awareness       Officials from several of the selected states
campaign led by the CDC would help              reported that their initial process for
encourage adoption and be more cost-            distributing the codes required a public
effective than individual state campaigns.      health official, such as a contact tracer, to
                                                provide a person with the verification code
Limited access. Another reason it can be        via phone after the person had received a
difficult to get people to download and use     positive test result or a confirmed diagnosis.
an exposure notifications app is lack of        However, states reported that, due to
access to a smartphone, reliable cellular       staffing shortages, in particular as cases
coverage, and broadband internet service,       surged, it sometimes took several days to
according to selected states and literature.    provide the code. As a result, some app
Indeed, officials in a few states told us one   users who had tested positive for COVID-19




                                                          Exposure Notification GAO-21-104622 32
were delayed in submitting their                                website with instructions for how to obtain
verification codes to notify others of                          the code. State officials reported that this
possible exposure, according to officials                       automated distribution resulted in an
from selected states. 64 In addition, there                     increase in the number of verification codes
can be delays in test results being available                   disseminated to app users. For example,
and provided to health care providers who                       following implementation of the new
report the results to local or state health                     process, one state's average distribution of
officials. In particular, earlier in the                        verification codes increased from 15 to 85 a
pandemic, testing availability and                              day, according to public health officials. In
turnaround time for results could take a                        addition, officials from a different state
week or more. Following the receipt of test                     reported that they had seen an increase in
results, the health care provider or
                                                                the number of codes redeemed, and
laboratory then reports the results to local
                                                                improved the timeliness of code
or state health officials. Any delays in this
                                                                redemption following implementation of
process could also contribute to delays in
                                                                the new system. However, another state
public health authorities’ distribution of
verification codes to individuals after the                     noted that, even after automating the
individual has received the confirmed                           process, it still took 4 days, on average, for
diagnosis.                                                      a person to receive a verification code
                                                                following a positive test result.
In addition, a few states noted that contact
tracers did not always follow the state’s                       4.5 Limited evidence of
processes for providing app users with a                        effectiveness
verification code to enter COVID-19 test
results in the app. For example, when a                         We found limited evidence that exposure
contact tracer was conducting an interview                      notification apps are effective at enhancing
with a person, they were supposed to ask if                     the speed or reach of manual contact
the person had downloaded the state’s app,                      tracing or at reducing the spread of disease.
and if so, to provide them with a
                                                                One reason for the dearth of evidence is
verification code. However, officials from
                                                                that states collect limited data from
one state stated that this was not always
                                                                exposure notification apps due to the
performed.
                                                                emphasis on data privacy. In addition, little
                                                                to no guidance exists on what data to
To help address this challenge, five of the
                                                                collect and how to collect the data. As for
nine selected states implemented an
                                                                slowing the spread of COVID-19, studies
automated process to distribute the codes.
                                                                have not yet sufficiently demonstrated that
Instead of providing the codes entirely
                                                                exposure notification apps are having an
through phone calls, some states also send
                                                                effect. CDC and others have, therefore,
text messages with the code or a link to a


64
  If the user tests positive for COVID-19, a public health
authority generates a verification code and then sends the
user the code to verify the positive test results. A user can
then voluntarily input this code in the app to submit recent
temporary keys.




                                                                          Exposure Notification GAO-21-104622 33
highlighted the need for additional research                   diseases like COVID-19, the speed of
into the effectiveness of exposure                             contact tracing plays a critical role in
notification apps in preventing the spread                     reducing disease spread, allowing those
of disease.                                                    who may have been exposed to take action
                                                               more quickly. States could use the speed of
4.5.1 States collect limited data from                         notification as one indicator or metric of
exposure notification apps                                     app effectiveness. According to Google and
                                                               Apple representatives, the time between
The privacy protections that are                               when a user submits their temporary keys
incorporated into the functionality of the                     to the key server and when a person would
existing apps limit the data available to                      be notified is estimated to be between 4
public health authorities, which reduces the                   and 10 hours. However, a few factors can
ability to measure and improve the                             delay the submission, including the amount
effectiveness of the apps. For example,                        of time it takes to receive a test result (e.g.,
officials from all nine selected states said to                time for test processing and reporting to
preserve personal privacy, they do not                         the health care provider and to the local
collect data on who has installed an app,                      health officials) and when that person
including who has received an exposure                         receives and uses the verification code.
notification. In addition, states have limited
data on how well the apps are working,                         4.5.2 States lack guidance on measuring
including how changes to the formula used
                                                               effectiveness
to calculate the level of risk affects the
number of people provided with exposure
notifications. 65 In addition, states do not                   States lack guidance for measuring the
                                                               effectiveness of exposure notification apps.
collect location data, so they are unable to
                                                               Officials from nearly all the selected states
identify where disease spread is occurring.
                                                               told us they wanted to gauge the impact of
                                                               their apps and assess effectiveness, such as
Furthermore, states do not collect data on                     the enhanced reach through electronic
the speed of exposure notification,                            notification. Officials from several of the
according to our review of information                         selected states said that they had reached
provided by selected states. Metrics on the                    out to CDC for guidance regarding
speed of notification are not provided as                      recommended approaches and indicators
part of the Google Apple system, though                        for measuring app effectiveness, which was
these data could be collected by the states                    confirmed by CDC officials. However, the
individually, should they choose to,                           requested information was not available.
according to Google and Apple                                  CDC officials indicated that they considered
representatives. With fast-spreading                           developing additional guidance to evaluate


65
  MITRE is planning to enhance the Exposure Notification
Private Analytics portal with additional features, including
the ability to analyze how changes in risk parameters affect
the number of exposure notifications. The portal and the
exposure notification analytics data it provides are only
available to states using the Express option.




                                                                         Exposure Notification GAO-21-104622 34
app effectiveness. However, they                                or reach compared to manual contact
acknowledged there are limited app                              tracing. 67
evaluation strategies available due to the
lack of data from exposure notification apps                    The lack of standardized metrics was
and, as a result, they are not planning to                      identified as a challenge in President
develop additional guidance. Because of the                     Biden’s National Strategy for the COVID-19
lack of federal guidance, officials from                        Response and Pandemic Preparedness in
states said they were “on their own” and                        January 2021. The strategy noted that
began reaching out to other states and                          states use and report different metrics for
countries that had deployed apps for advice                     tracking COVID-19 response activities,
and best practices, such as metrics for                         including contact tracing, and called for
measuring effectiveness. Officials from the                     common federal metrics to evaluate
majority of the selected states said they                       progress and the identification of areas
wished there had been additional guidance                       where additional federal resources should
available, including how to measure app                         be directed. 68
effectiveness; officials from three states
used the analogy of “building the plane                         In part due to the lack of federal guidance,
while flying it,” to describe their experience                  selected states varied in the types of data
deploying their apps with limited direction.                    that they are collecting to measure the
                                                                overall effectiveness of their own apps and
CDC has developed general guidance on                           have developed their own metrics and
exposure notification apps, such as                             indicators for determining how well the
minimum and preferred characteristics. 66                       apps are working. States are using one or
CDC also developed guidance to measure                          more of these metrics:
the success of manual contact tracing
efforts, including both process and outcome                     •    App downloads or activations 69
metrics, but has not developed specific                         •    Verification codes issued 70
guidance on criteria to use in measuring
app effectiveness, such as increased speed                      •    Verification codes claimed 71



66                                                              68
  Centers for Disease Control and Prevention, Preliminary         The White House, National Strategy for the COVID-19
Criteria for the Evaluation of Digital Contact Tracing Tools    Response and Pandemic Preparedness, (Washington, D.C.,
for COVID-19, version 1.2 (Atlanta, Ga.: May 17, 2020); and     Jan. 21, 2021).
Guidelines for the Implementation and Use of Digital Tools to   69
Augment Traditional Contact Tracing, version 1.0 (Atlanta,        As previously mentioned, download data includes Android
Ga.: Dec. 15, 2020). CDC’s May 2020 and December 2020           and iOS phones in states with customized apps; downloads
guidance and website information on digital contact tracing     for Android phones in states using the Express option; or
tools did not include a definition for effectiveness or any     “activations” for iOS phones in states using the Express
standardized metrics for states or indicators for measuring     (“app-less”) option.
app effectiveness.                                              70
                                                                  Verification codes issued refers to the codes that are
67                                                              disseminated to app users with a positive COVID-19 test
  Centers for Disease Control and Prevention, Evaluating
Case Investigation and Contact Tracing Success, (Atlanta,       result. The codes may be provided on the phone by contact
Ga.: May 26, 2020), accessed June 9, 2021,                      tracers or through other methods, such as text message.
https://www.cdc.gov/coronavirus/2019-ncov/php/contact-t         71
                                                                  Verification codes claimed refers to the codes entered by
racing/contact-tracing-plan/evaluating-success.html.            app users with a positive COVID-19 test result that enables
                                                                them to send the recent temporary keys to the National Key
                                                                Server to notify others that they may be at risk.




                                                                            Exposure Notification GAO-21-104622 35
•    Exposure notifications generated 72                       regard to reach, the number of downloads
                                                               gives an approximate, but not actual sense
Yet, officials from eight of the nine selected                 of the number of app users.
states noted that some of these metrics
provide a limited understanding of app                         The number of downloads is not an
effectiveness. Data on downloads,                              accurate reflection of app usage. Officials
verification codes, and exposure                               from one state speculated that some
notifications provide public health                            people were downloading the apps out of
authorities some information to gauge how                      curiosity but never enabling them on their
effective they are. However, these metrics                     smartphone. Further, after a person
do not indicate how quickly people were                        downloads the app, they need to perform a
notified of exposure or timeliness relative                    series of actions for it to be used as
to manual contact tracing alone. With                          intended (see fig. 7). Therefore, a user


72
  Exposure notifications are alerts provided to close
contacts of the app users who confirm a positive test or
diagnosis using a verification code they enter into the app.
However, they are only an estimate, as app users voluntarily
provide this information.




                                                                        Exposure Notification GAO-21-104622 36
could download but not use the app or                            according to officials from one state.
download it more than once, according to                         Further, because states do not track who
public health officials from several selected                    receives an exposure notification, states
states. Also, people could choose to not                         have a limited understanding of what
enable receiving exposure notifications;                         impact, if any, these notifications have on
ignore notifications; and if they do test                        disease spread and the overall effectiveness
positive, not voluntarily provide that                           of their apps.
information. While download totals may
represent the possible population of app                         Nonetheless, public health officials from
users that could receive benefits (i.e.,                         seven of the nine selected states said they
notification) from these apps, these                             believe the exposure notification apps have
limitations hinder states from                                   been effective and that their apps had been
understanding the effectiveness of using                         worthwhile. Officials from two states said
exposure notification apps.                                      they think adoption even at relatively low
                                                                 levels would help slow disease spread.
Verification codes claimed by the people                         Furthermore, exposure notification apps
who have tested positive for COVID-19 and                        provided a new tool for states to use—at a
who entered the information in the app                           time of urgent need—to limit the spread of
(which prompts exposure notifications to be                      COVID-19.
sent to others) may also provide an
indication of app use. Similarly, the number                     4.5.3 Evidence of reduced disease
of exposure notifications gives a sense of                       spread has been limited but additional
how many people are notified of potential                        studies are underway
exposure to COVID-19, but it may provide
limited insight into the effectiveness of the                    We reviewed seven selected modeling
public health intervention because users                         studies that have sought to measure the
need to voluntarily provide this information                     effects of the use of apps on the spread of
in their apps. Finally, none of the data                         COVID-19. However, there are important
indicate whether people changed behavior                         limitations to these studies—such as limited
as a result of the notification.                                 evidence to support assumptions about
                                                                 behavioral changes—which hinder the
While people seeking testing or medical                          ability to draw high-confidence conclusions
care could be asked whether they sought                          about the apps effectiveness. 73 The studies
testing or care due to an exposure                               we reviewed generally suggested that the
notification from an app, such information                       use of exposure notification apps can
may violate a user's expectations of privacy,                    reduce disease transmission. 74 In general,


73                                                               74
  Infectious disease models are simplified versions of reality     The selected studies we reviewed covered a range of
that help to characterize disease spread (see GAO-20-372         geographic areas, including Washington State, the United
for an overview of infectious disease modeling). Other types     Kingdom, Spain, and Switzerland, and were published
of epidemiological studies of contact tracing apps that could    between April 2020 and May 2021. Five of the seven papers
be conducted in real world settings, rather than via             are peer-reviewed publications. We identified the papers
modeling, face methodological, logistical, and ethical           from our interviews with subject matter experts and a
challenges, including the lack of empirical data, confounding    search of the literature. Studies we reviewed include:
factors that affect disease spread, and other issues.




                                                                             Exposure Notification GAO-21-104622 37
the studies suggested that app usage can                          isolated. In some cases, particularly with
decrease COVID-19 infections and deaths,                          studies earlier in the pandemic, these
with the size of the estimated effects                            assumptions were not grounded in research
depending on the level of app adoption,                           and were not otherwise well supported. For
among other things. For example, one peer-                        example:
reviewed study estimated that, when 15
percent of the population used an exposure                        •    Assumptions in one study were that
notification app, infections could be                                  everyone notified of a potential
reduced by approximately 8 percent and                                 exposure would self-isolate, with a 2
deaths by about 6 percent. Another peer-                               percent drop-out rate each day, and
reviewed study in the United Kingdom                                   that 18 percent of infected people
estimated that a 30 percent app uptake                                 remained asymptomatic, with no
averted approximately one infection for
                                                                       variation in this rate across age
every four infections that arose over a 4½-
                                                                       groups. 75 These assumptions were not
month period.
                                                                       grounded in evidence because little to
                                                                       none was available at the time.
However, there are significant limitations to
these modeling studies. For example, the                          •    A study of three counties in Washington
models estimated outcomes by relying on                                State assumed in its simulations that it
assumptions about app usage and                                        would take 2 days from symptom onset
behavioral changes associated with                                     to receive a COVID-19 test result, which
notifications. These assumptions covered                               the authors characterized as a key
factors such as how many people used an                                assumption underlying the findings.
app, how many app users had a positive                                 However, in the earlier months of the
test result, and how many app users self-



R. Hinch, et al., Effective Configurations of a Digital Contact   D. Menges, et al., “A Data-Driven Simulation of the Exposure
Tracing App: A Report to NHSX, (April 16, 2020), accessed         Notification Cascade for Digital Contact Tracing of SARS-CoV-
December 9, 2021,                                                 2 in Zurich, Switzerland,” JAMA Network Open, (4
https://cdn.theconversation.com/static_files/files/1009/Rep       (4):e218184), (April 30, 2021), accessed July 13, 2021,
ort_-_Effective_App_Configurations.pdf?1587531217.                https://jamanetwork.com/journals/jamanetworkopen/fullar
M. Abueg, et al., “Modeling the Effect of Exposure                ticle/2779376.
Notification and Non-pharmaceutical Interventions on              Massachusetts Institute of Technology Lincoln Laboratory,
COVID-19 Transmission in Washington State,” npj Digital           “Simulated Automatic Exposure Notification (SimAEN):
Medicine, (4, 49), (March 12, 2021) accessed March 12,            Exploring the Effects of Interventions on the Spread of
2021, https://www.nature.com/articles/s41746-021-00422-           COVID,” Private Automated Contact Tracing (PACT)
7.                                                                Technical Report #3, (December 8, 2020), accessed March 1,
C. Wymant, et al., “The Epidemiological Impact of the NHS         2021, https://pact.mit.edu/simulated-automatic-exposure-
COVID-19 App,” Nature, Vol. 594, no. 7863 (2021).pp. 408-         notification-simaen-exploring-the-effects-of-interventions-
412, accessed February 25, 2021.                                  on-the-spread-of-covid-wlogos/.
                                                                  75
P. Rodríguez, et al., “A Population-Based Controlled                Estimates of the COVID-19 asymptomatic rates vary
Experiment Assessing the Epidemiological Impact of Digital        widely by age group, according to information from CDC.
Contact Tracing,” Nature Communications, (January 26,             Centers for Disease Control and Prevention, “Estimated
2021), accessed February 22, 2021,                                Disease Burden of COVID-19,” COVID-19, (Atlanta, Ga.:
https://www.nature.com/articles/s41467-020-20817-6.               updated May 19, 2021), accessed July 13, 2021,
S. Marcel, et al., “Early Evidence of Effectiveness of Digital    https://www.cdc.gov/coronavirus/2019-ncov/cases-updates
Contact Tracing for SARS-CoV-2 in Switzerland,” Swiss             /burden.html.
Medical Weekly, (December 16, 2020), accessed March 9,
2021, https://smw.ch/article/doi/smw.2020.20457.




                                                                               Exposure Notification GAO-21-104622 38
     pandemic, wait times for test results in                     underway that suggest the use of apps can
     U.S. could be a week or more. 76                             help mitigate the spread of COVID-19. 77 In
                                                                  addition, some states are conducting their
•    Oxford University researchers
                                                                  own evaluations of the effectiveness of
     associated with the United Kingdom
                                                                  exposure notification apps in reducing
     studies told us that the recent rise in
                                                                  disease spread.
     variant strains and vaccinations has
     increased uncertainty in assumptions
     about disease transmission.                                  4.5.4 CDC and others have highlighted
                                                                  the need for additional research and
In addition to the studies on disease spread,                     data
some studies have estimated shorter-term
outcomes, such as the number of close                             Exposure notification apps are a relatively
contacts detected by exposure notification                        recent public health intervention. As a
apps. In one simulation study, the findings                       result, additional primary research on the
implied that the app prompted quarantine                          benefits and effectiveness of exposure
                                                                  notification apps is needed, according to
recommendations for, at most, an
                                                                  CDC and other public health researchers. 78
estimated 5 percent more exposed contacts
                                                                  This includes a need for primary research
than manual contact tracing. However, as
                                                                  into the use of digital tools in conjunction
with the modeling studies we reviewed on
                                                                  with manual systems, since public health
disease spread, these studies of shorter-
                                                                  authorities are unlikely to use digital tools
term outcomes are also subject to
                                                                  in isolation, according to all selected states
important limitations, such as model inputs                       and most literature we reviewed.
derived from studies with limited sample                          Specifically:
sizes or national estimates applied to states
or local regions.
                                                                  •    CDC has noted that more data are
                                                                       needed from preliminary
Since we originally identified papers for our                          implementation efforts to quantify the
review, additional studies are now                                     public health value of these apps. 79


76                                                                78
  D. Lazer, et al., “Report #8: Failing the Test: Waiting Times      A. Anglemyer, et al., “Digital contact tracing technologies
for COVID Diagnostic Tests Across the U.S.” in The State of       in epidemics: a rapid review.” Cochrane Database of
the Nation: A 50-State COVID-19 Survey, (OSF Preprints,           Systematic Reviews. (2020).
August 2020), accessed July 13, 2021,                             79
https://doi.org/10.31219/osf.io/gj9x8.                              Centers for Disease Control and Prevention, Guidelines for
                                                                  the Implementation and Use of Digital Tools to Augment
77
  See, for example, C. Segal, et al., Early Epidemiological       Traditional Contact Tracing, version 1.0 (Atlanta, Ga.: Dec.
Evidence of Public Health Value of WA Notify, a Smartphone-       15, 2020).
based Exposure Notification Tool: Modeling COVID-19 Cases
Averted in Washington State (June 2021), accessed July 1,
2021,
https://www.medrxiv.org/content/10.1101/2021.06.04.212
57951v4; and J. Masel, et al., Quantifying meaningful
adoption of a SARS-CoV-2 exposure notification app at the
campus of the University of Arizona (June 2021), accessed
June 1, 2021,
https://www.medrxiv.org/content/10.1101/2021.02.02.212
51022v6.




                                                                               Exposure Notification GAO-21-104622 39
     Also, the agency has highlighted the                          effectiveness of exposure notification
     need for more studies on the                                  apps is needed, since there is currently
     effectiveness of digital tools, including                     a limited understanding of the extent to
     exposure notification apps, to support                        which apps may have changed the
     contact tracing and reduce the spread                         course of the pandemic in the U.S. 81
     of infectious disease. In addition, CDC                       The organization called for a data
     has identified a specific research need                       driven approach and research on app
     to comprehensively compare the                                efficacy to help app developers and
     effectiveness of manual contact tracing                       others, including the federal
     with exposure notification apps and has                       government, decide whether to
     initiated work to study these issues with                     improve apps for potential future use or
     the Massachusetts Institute of                                abandon the approach if research
     Technology’s Lincoln Laboratory,                              showed that desired outcomes had not
     according to CDC officials.                                   been achieved.
•    WHO has called for additional research
     on the minimum adoption levels                           Moreover, the need for additional research
     required for these apps to be effective                  on the effectiveness was identified as a
     in light of the limited evidence to                      challenge in President Biden’s National
     date. 80 In addition, since some                         Strategy, issued in January 2021. The
     populations have limited access to                       strategy notes that the federal government
     digital technology, WHO identified the                   should work with public health authorities
     potential for the systematic exclusion of                and the private sector to collect COVID-19
     individuals who cannot access such                       data on a range of issues, including the
                                                              effectiveness of contact tracing. 82
     technologies. It called for additional
     research and sufficient regulatory
     oversight of these issues.
•    Linux Foundation Public Health noted
     that additional research on the




                                                              82
                                                                The White House, National Strategy for the COVID-19
80
  World Health Organization, Contact Tracing in the Context   Response and Pandemic Preparedness, (Washington, D.C.,
of COVID-19, Interim Guidance, February 1, 2021.              Jan. 21, 2021).
81
  Linux Foundation Public Health was founded in summer
2020 with an initial focus on helping public health
authorities deploy apps based on the Google Apple system.




                                                                          Exposure Notification GAO-21-104622 40
5 Policy Options That Could Help Address Challenges for Future Use

We identified four policy options that, when                     result in users receiving false exposure
implemented, could help address the                              notifications, such as by improving the
challenges we have identified for both                           accuracy of the distance measurements
current and future use of exposure                               performed by exposure notification apps.
notification apps. 83 Policymakers could also                    For example, apps could use additional
choose to maintain the status quo—that is,                       sensors (e.g., the gyroscope and
allow current efforts to proceed without                         magnetometer that certain smartphones
intervention. The relevant policymakers                          already have) or other technologies, such as
                                                                 ultra-wideband and ultrasound. In addition,
could include Congress, other elected
                                                                 research could examine methods for
officials, federal agencies, state and local
                                                                 evaluating other factors that affect the risk
governments, academic research
                                                                 of disease transmission, such as whether
institutions, and industry. While some
                                                                 the encounter occurred indoors or
challenges described in this report may be
                                                                 outdoors.
addressed through current efforts, other
challenges may not be resolved, may be
                                                                 Policymakers could promote research in
exacerbated, or may take longer to resolve                       multiple ways, including by providing grants
without intervention. The four policy                            to academic and research institutions or by
options are in the following areas: research                     setting up a public-private partnership.
and development, privacy and security,                           Further, the research could build off of prior
data collection and measurement, and                             and ongoing research by various entities.
national strategy.
                                                                 Opportunities
5.1 Policy option: Research and
                                                                 •    Research on technological limitations,
development                                                           such as inaccurate distance
                                                                      measurements, could help increase the
Policymakers could promote research and                               accuracy and speed of exposure
development to address technological                                  notification apps, incentivizing users to
limitations.                                                          download and use them.
                                                                 •    Research on technologies and
Description
                                                                      architectures other than those used by
                                                                      U.S. states could also improve the apps,
Research could seek to address the
technical limitations we identified that can                          for example by increasing the speed


83                                                               that would be needed to fully implement a specific policy
   We present policy options that were within the scope of
this technology assessment. This is not an exhaustive list of    option or combination of options—for instance, on potential
all potential policy options, nor are policy options intended    design and legal issues—nor did we assess how effective the
to be recommendations to federal agencies or matters for         options may be. We express no view regarding the extent to
congressional consideration. They are not listed in a specific   which legal changes would be necessary to implement them.
rank or order, and we are not suggesting that they be
completed individually or combined in any particular
fashion. We did not conduct the detailed additional analysis




                                                                             Exposure Notification GAO-21-104622 41
    and reach of notifications. Such                 smartphone technology would require
    alternatives include GPS and centralized         ongoing research.
    or hybrid data architecture.
•   Partnerships with technology                 5.2 Policy option: Privacy and
    companies could help with integrating        security standards and best
    improvements into smartphone                 practices
    operating systems. These collaborations
    could spur further technological             Policymakers could promote uniform
    innovation.                                  privacy and security standards and best
Considerations                                   practices for exposure notification apps.

•   Research into new technologies could
                                                 Description
    be costly and is generally considered a
    long-term investment with uncertain
                                                 Policymakers could support the
    benefits.                                    development of privacy and security
•   The roles for government, the private        standards and best practices for exposure
    sector, and academia in researching          notification apps to ensure that these apps
    new technologies for exposure                function as intended and that user privacy
    notification apps would need to be           is protected. One way to do this would be
    defined, planned, and coordinated to         to specify standards for public health
    ensure that research and costs are not       authorities to ensure that personal data are
    duplicative.                                 encrypted when stored, and to specify
                                                 limits on the types of data that can be
•   Research may not produce cost-               collected and how the data may be used
    effective improvements, because              and disclosed. In addition, the standards
    existing apps may still be sufficiently      could specify that the data can only be used
    accurate for notifying a person of           for disease response efforts and that
    potential exposure. Moreover, other          personal data cannot be shared with other
    alternative technologies also have           agencies, law enforcement, or immigration
    accuracy limitations, and other data         authorities without a user’s consent.
    architectures may increase the risk of
    revealing sensitive user information.        Another action policymakers could take is
                                                 to require that standards be developed and
•   Research into new technologies based
                                                 agreed on by a broad coalition of
    on the COVID-19 pandemic may also
                                                 stakeholders. Best practices could also be
    result in apps that are not functional for   developed by government agencies (e.g.,
    future outbreaks or pandemics.               NIST) or the private sector.
    Diseases that are not transmitted
    through the air, such as sexually            Opportunities
    transmitted diseases, would require
    apps that use different methods to           •   Developing and adopting uniform
    determine potential exposure. In                 privacy and security standards and
    addition, the continuous changes in              related best practices could help
                                                     address real and perceived risks that




                                                          Exposure Notification GAO-21-104622 42
     the public’s data might be misused or               Description
     otherwise not appropriately protected.
                                                         Policymakers could assess the approaches
•    Standards developed and agreed on by
                                                         that states have used to increase adoption
     a broad coalition of stakeholders could
                                                         and then develop best practices based on
     increase the likelihood of still broader
                                                         those results. Best practices could also
     stakeholder agreement and buy-in.
                                                         include standardization of the metrics
•    Independent security and privacy                    collected and reported to measure
     assessments could evaluate apps based               effectiveness as well as the procedures for
     on these standards and best practices,              verification code distribution. The
     and these assessments could be made                 development of best practices could be led
     publicly available.                                 by a broad coalition of stakeholders and
                                                         result in guidance to states. These efforts
Considerations                                           could help address the challenges we
•    Policymakers would need to balance                  identified related to app adoption,
     the need for privacy and security with              verification code delays, and efficacy
     the direct and indirect costs of                    determination.
     developing and implementing these
     standards and practices.                            Opportunities
•    Implementing these privacy
                                                         •   Best practices could help state public
     requirements may require flexibility
                                                             health authorities share strategies to
     because different jurisdictions could
                                                             improve app adoption. For example, if a
     use different technologies (e.g., BLE or
                                                             state found that translating the app into
     GPS) and data architectures to collect
                                                             multiple languages improved adoption
     and use the data.
                                                             among non-English speaking people,
•    It could be challenging to determine                    this information could be shared with
     how to oversee and enforce the privacy                  other states. Also, understanding and
     and security standards and practices.                   appealing to user motivations could
                                                             promote app adoption. Further,
5.3 Policy option: Best practices to                         partnering with trusted sponsors could
measure effectiveness                                        encourage cooperation in COVID-19
                                                             contact tracing, as published by the
Policymakers could promote best practices                    National Academies of Sciences,
to increase adoption and measure the                         Engineering, and Medicine. 84
effectiveness of exposure notification apps.             •   Such practices could help state public
                                                             health authorities by providing
                                                             information on potential methods and


84The National Academies of Sciences, Engineering, and

Medicine, Encouraging Participation and Cooperation in
Contact Tracing: Lessons from Survey Research,
(Washington, D.C.: Aug. 2020).




                                                                  Exposure Notification GAO-21-104622 43
     processes for distributing verification             deployment, and use of exposure
     codes in a timely manner.                           notification apps.
•    In addition, best practices can help
     states to measure the effectiveness and             Description
     impact of these apps. Best practices
     could also leverage outside knowledge               Policymakers could evaluate whether to
     to promote app adoption. More                       enhance the current national strategy or a
                                                         future pandemic response strategy to
     accurate measurement of app
                                                         enable a coordinated nationwide approach
     effectiveness would help public health
                                                         to the development and deployment of
     authorities identify opportunities for
                                                         exposure notification apps. 85 This could
     improvement, both to the technology’s
                                                         help address the challenges we identified
     function and to its widespread use.
                                                         related to the adoption of these apps and
                                                         evidence of their effectiveness. An
Considerations                                           enhanced strategy could include specifying
                                                         federal, state, and local roles and
•    The creation of best practices could                coordination efforts. Further, an enhanced
     require consensus from many public                  strategy could identify what other
     and private sector stakeholders, which              infectious diseases (e.g., tuberculosis,
     can be time- and resource-intensive.                measles) may be applicable to exposure
                                                         notification apps in the future.
•    If the best practices are not updated,
     they may not be relevant or useful in a
                                                         As part of this strategy, the federal
     future pandemic.
                                                         government could decide to repurpose
•    In some cases, stakeholders may lack                apps that were developed for state use
     sufficient or complete information or               during the COVID-19 pandemic, or use
     the experience to develop best                      comparable technology to develop new
     practices. If best practices are put in             contact tracing solutions. Policymakers
     place without sufficient basis, it could            could recommend a national exposure
     limit further innovation.                           notification app that public health
                                                         authorities could decide to use based on
5.4 Policy option: Enhance the                           their individual needs, resulting in a generic
                                                         exposure notification app tailored to state
national strategy                                        needs or a federally managed exposure
                                                         notification app that is made available for
Policymakers could collaborate to enhance                states to use.
the national strategy and promote a
coordinated approach to the development,




85
  The White House, National Strategy for the COVID-19
Response and Pandemic Preparedness, (Washington, D.C.,
Jan. 21, 2021).




                                                                   Exposure Notification GAO-21-104622 44
Opportunities                                 Considerations

•   Enhanced national coordination could      •   Implementing a coordinated national
    prompt faster deployment of apps in           strategy would likely have associated
    the future if that coordination builds        costs and require a source of sustained
    upon the underlying infrastructure and        funding during and after the pandemic.
    leverages the lessons learned from
                                              •   Without clear roles and responsibilities,
    COVID-19.
                                                  coordination culd be challenging. For
•   A federally led national marketing            example, coordination of groups with
    campaign with cohesive and coherent           divergent perspectives and interests
    messaging could result in wider               may pose challenges to defining
    adoption of exposure notification apps.       outcomes and measuring performance
    Increased federal promotion and               and effectiveness of apps.
    support of the exposure notification
                                              •   It is unclear whether the public would
    apps could potentially help with
                                                  be more or les likely to trust and use a
    increasing public trust in the apps.
                                                  national exposre notification app than
•   A national app could allow integration        one developed by their state
    of exposure notification capabilities         government. Some states, including
    with other disease prevention and             Virginia, Colorado, and California, have
    response activities, such as test             passed state-wide privacy laws. Due to
    scheduling or vaccine delivery                the absence of a federal privacy law in
    coordination.                                 the U.S., the public may be less likely to
                                                  trust the federal government’s privacy
                                                  protections.




                                                       Exposure Notification GAO-21-104622 45
6 Agency and Expert Comments

We provided a draft of this report to the Departments of Health and Human Services (including
CDC and NIH), Homeland Security, and Commerce, Federal Communications Commission, and
Federal Trade Commission for their review. The agencies provided technical comments, which
we incorporated as appropriate. Representatives from Apple, the Association of Public Health
Laboratories, Google, Massachusetts Institute of Technology’s Lincoln Laboratory, and MITRE
Corporation also reviewed a draft of this product; we incorporated their technical comments as
appropriate.




We are sending copies of this report to the appropriate congressional committees and other
interested parties. In addition, the report is available at no charge on the GAO website at
https://www.gao.gov.

If you or your staff have any questions about this report, please contact Karen L. Howard at
(202) 512-6888 or howardk@gao.gov or Vijay A. D’Souza at (202) 512-6240 or
dsouzav@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs
may be found on the last page of this report. GAO staff who made key contributions to this
report are listed in appendix III.




Karen L. Howard, PhD
Director,
Science, Technology Assessment, and Analytics




Vijay A. D’Souza
Director,
Information Technology and Cybersecurity




                                                             Exposure Notification GAO-21-104622 46
List of Congressional Addressees

The Honorable Patrick Leahy              The Honorable Bennie G. Thompson
Chairman                                 Chairman
The Honorable Richard Shelby             The Honorable John Katko
Vice Chairman                            Ranking Member
Committee on Appropriations              Committee on Homeland Security
United States Senate                     House of Representatives

The Honorable Ron Wyden                  The Honorable Carolyn B. Maloney
Chairman                                 Chairwoman
The Honorable Mike Crapo                 The Honorable James Comer
Ranking Member                           Ranking Member
Committee on Finance                     Committee on Oversight and Reform
United States Senate                     House of Representatives
The Honorable Patty Murray               The Honorable Richard Neal
Chair                                    Chairman
The Honorable Richard Burr               The Honorable Kevin Brady
Ranking Member                           Republican Leader
Committee on Health, Education, Labor,   Committee on Ways and Means
and Pensions                             House of Representatives
United States Senate
                                         The Honorable Morgan Griffith
The Honorable Gary C. Peters             Republican Leader
Chairman                                 Subcommittee on Oversight and
The Honorable Rob Portman                Investigations
Ranking Member                           Committee on Energy and Commerce
Committee on Homeland Security and       House of Representatives
Governmental Affairs
United States Senate                     The Honorable Brett Guthrie
                                         Republican Leader
The Honorable Rosa L. DeLauro            Subcommittee on Health
Chairwoman                               Committee on Energy and Commerce
The Honorable Kay Granger                House of Representatives
Ranking Member
                                         The Honorable Michael C. Burgess
Committee on Appropriations
                                         House of Representatives
House of Representatives

The Honorable Frank Pallone, Jr.
Chairman
The Honorable Cathy McMorris Rodgers
Republican Leader
Committee on Energy and Commerce
House of Representatives



                                                 Exposure Notification GAO-21-104622 47
Appendix I: Objectives, Scope, and Methodology
Objectives                                       •   Federal Communications Commission
                                                     (FCC).
We were asked to assess smartphone
applications (apps)—commonly referred to as      In addition, we interviewed representatives
exposure notification apps—that are intended     from companies involved in the development
to notify persons of potential exposure to       of exposure notification apps (Google, Apple,
infectious diseases. This report discusses:      and PathCheck Foundation); public health
                                                 organizations (Association of Public Health
•   the benefits and design of exposure          Laboratories, Public Health Informatics
    notification apps;                           Institute, Council of State and Territorial
                                                 Epidemiologists, Association of State and
•   the current level of deployment in the
                                                 Territorial Health Officials); federally funded
    U.S.;
                                                 research and development centers
•   challenges affecting their use; and          (Massachusetts Institute of Technology’s
•   policy options that could help address key   Lincoln Laboratory and MITRE Corporation);
    challenges for future use.                   and academic researchers from Oxford
                                                 University’s Big Data Institute, Nuffield
Scope and methodology                            Department of Medicine. We identified these
                                                 entities through our interviews and document
                                                 reviews. During our interviews with officials
To address these objectives, we reviewed
                                                 and representatives, we discussed topics such
documentation and met with officials from
                                                 as exposure notification app functionality;
selected federal agencies and entities
                                                 benefits of its use; levels of deployment in the
involved in providing guidance, funding
                                                 U.S.; technological limitations; and challenges
research, and other efforts related to
                                                 to its development, deployment, and use. We
exposure notification apps. These agencies
                                                 also obtained written responses from two
were:
                                                 organizations: the National Association of
                                                 County and City Health Officials and Linux
•   Centers for Disease Control and
                                                 Foundation Public Health.
    Prevention (CDC) and National Institutes
    of Health (NIH) within the Department of
    Health and Human Services (HHS),             Further, we conducted a literature search for
•   Cybersecurity and Infrastructure Security    articles regarding exposure notification apps,
    Agency, Science and Technology               including their benefits, capabilities, and
    Directorate, within the Department of        challenges, as well as policy options
    Homeland Security (DHS),                     associated with the apps. A research librarian
•   National Institute of Standards and          conducted searches of various databases
    Technology (NIST), Federal Trade             including Inspec, Scopus, Policy File,
    Commission (FTC), within the Department      ProQuest’s COVID-19 Research Database, and
    of Commerce, and                             the Harvard Kennedy School’s Custom Google
                                                 Think Tank Search. We used synonyms of the




                                                             Exposure Notification GAO-21-104622 48
following search terms to identify relevant                          We also contacted several individual states to
articles: contact tracing, exposure                                  verify their status in deploying an app. We
notification, Google Apple exposure,                                 analyzed the inventory to identify the extent
application, app, system, platform, digital,                         to which states and territories had deployed
mobile, smartphone. We paired these search                           apps, the underlying technologies used (e.g.,
terms with additional synonyms for privacy,                          Bluetooth Low Energy), and the use of
security, policy, legislation, opportunities, and                    national servers. 87 States that had an app in a
challenges. We considered articles that met                          pilot phase at the time of our review were
the following criteria: published from 2016                          included in the category of “states that had
through January 2021 in academic journals,                           not deployed an app as of June 2021.”
working papers, trade journals, legislative
materials, and reports by government                                 To obtain additional information associated
agencies and nonprofit organizations. From                           with the development and use of the apps,
the results produced by this search, we                              we interviewed state public health officials
reviewed a selection of articles to provide an                       from a non-generalizable sample of nine
overview and additional context for our                              states that had an exposure notification app
research objectives. We also used the results                        as of January 1, 2021: Alabama, Colorado,
to help inform our development of an                                 Connecticut, Minnesota, Nevada, North
inventory of states by app deployment status,                        Carolina, Pennsylvania, Virginia, and
among other sources noted below.                                     Washington. 88 We selected this sample based
                                                                     on deployment date, geographical
To identify the current level of deployment in                       distribution, the number of COVID-19 cases
the U.S., we developed an inventory of                               and deaths, and app developer. We aimed for
exposure notification apps that had been                             a selection of states that would allow for the
deployed by U.S. states and territories as of                        selected states to provide a broad overview
June 2021. We developed the inventory by:                            and context for assessing our engagement’s
                                                                     research objectives. Because the selection
•    reviewing inventories that had been                             was based on a non-generalizable sample, the
     developed by other organizations; 86                            results cannot be used to make inferences
•    reviewing state health department                               about all states that had deployed an app. We
     websites related to COVID-19 to identify                        also received written feedback to structured
     whether they identified an available app,                       questions from two additional states
     or plans to deploy one;                                         (Louisiana and Utah) that deployed apps in
•    conducting Google searches; and                                 the later stages of our evidence collection.
•    reviewing Android and iPhone app stores.                        We also conducted a review of each of the
                                                                     selected states apps on both a phone using


86The inventories included those developed by MIT Technology         88We considered a state as having an app if it had an official

Review, the Association of State and Territorial Health Officials,   application available for download or the state officially
and the Ada Lovelace Institute.                                      supported an exposure notification system that exists in a
87Specifically, whether states used the Association of Public        smartphone operating system. As of January 1, 2021, we had
                                                                     identified 20 states with an exposure notification app. After we
Health Laboratories’ National Key Server and Multi-tenant            selected our sample, we learned that one additional state—
Verification Server.                                                 Wisconsin—had deployed an app in late December 2020.




                                                                                     Exposure Notification GAO-21-104622 49
the iOS (iPhone 6) and Android (Samsung                            intended to be inclusive of all potential policy
Galaxy S9) operating systems. As a part of this                    options and are neither recommendations to
review, we reviewed the general functions,                         federal agencies nor matters for
features, and usability of the apps. To help                       congressional consideration. They are also not
understand how privacy considerations                              listed in any specific rank or order. We are not
applied to the apps, we examined and                               suggesting that they be done individually or
compared each state’s privacy policies with                        combined in any particular fashion.
recommended practices identified in federal                        Additionally, we did not conduct work to
guidance, such as CDC’s guidelines for digital                     assess how well they may lead to a particular
tools. 89                                                          outcome.

In addition, to obtain perspectives from states                    We conducted our work from November 2020
that had not deployed an app, we collected                         to September 2021 in accordance with all
information from a non-generalizable                               sections of GAO’s Quality Assurance
selection of seven states that had not                             Framework that are relevant to technology
deployed an app at the time of our review                          assessments. The framework requires that we
(Montana, Nebraska, Oregon, Rhode Island,                          plan and perform the engagement to obtain
South Carolina, Texas, and West Virginia),                         sufficient and appropriate evidence to meet
which included an interview with one state                         our stated objectives and to discuss any
and written responses to a semi-structured                         limitations to our work. We believe that the
set of questions for the other six. We selected                    information and data obtained, and the
these states based on geographical                                 analysis conducted, provide a reasonable
distribution, suggestions from stakeholders                        basis for any findings and conclusions in this
we interviewed, and information we gathered                        product.
during our review regarding challenges
certain states may have faced.

We identified policy options based on our
literature review and interviews with federal
agencies, the selected states, and other
stakeholders, including national health
organizations and researchers. We assessed
each policy option by identifying potential
benefits and considerations of implementing
them, as identified over the course of our
review. Based on the evidence collected, we
identified four policy options. The list is not


89
  Centers for Disease Control and Prevention, Preliminary
Criteria for the Evaluation of Digital Contact Tracing Tools for
COVID-19, version 1.2 (Atlanta, Ga.: May 17, 2020); and
Guidelines for the Implementation and Use of Digital Tools to
Augment Traditional Contact Tracing, version 1.0 (Atlanta, Ga.:
Dec. 15, 2020).




                                                                               Exposure Notification GAO-21-104622 50
Appendix II: Exposure Notification App Adoption Rates for Selected
U.S. States

As previously discussed, states may use the rate of adoption to measure the success of their
efforts to promote exposure notification apps. However, officials from the 11 states in our
review reported that they used differing methods to calculate adoption rates. App adoption
rates can be determined by dividing the total number of smartphone downloads, or
activations, (numerator) by the size of a given population (denominator). However, states use
different methods for determining the denominator, which affects the adoption rates.
Specifically, two states used the total state population, three used populations aged 18 or
older, and three used the percent of the population with a smartphone (either age 18 or older
or 18 to 65), according to state officials. These inconsistent methods impede comparative
assessments across states. The following table provides information on the apps deployed by
the nine U.S. states selected for our review, plus Louisiana and Utah.

Table 4: Reported exposure notification app adoption rates for 11 U.S. states, as of June 2021
 State         Type          App name        Launch   Reported              Reported            Reported
               (custom or                    date     downloads and/or      population          adoption
               Express)                               estimated             (denominator)       rateb
                                                      activationsa
                                                      (numerator)
 Alabama       Custom        GuideSafe™      Aug.     280,000               Not provided        20%
                                             2020
 Colorado      Express       COVID           Oct.     2,511,070             Not provided        42%
                             Exposure        2020     The combined
                             Notifications            number of iOS and
                                                      Android
                                                      activations taken
                                                      from several
                                                      sources.
 Connecticut   Express       COVID Alert     Nov.     N/A                   N/A                 N/A
                             CT              2020
 Louisiana     Custom and    COVID           Jan.     663,379               3,560,976           19%
               Express       Defense         2021     This includes the     (18 and older)
                                                      combined number       Based on U.S.
                                                      of iOS and Android    Census Bureau
                                                      app downloads for     estimate for the
                                                      the custom app, as    adult population.
                                                      well as the
                                                      Android app
                                                      downloads and
                                                      the estimated
                                                      number of
                                                      activations for iOS
                                                      for the Express
                                                      option.




                                                                  Exposure Notification GAO-21-104622 51
Minnesota      Custom and   COVIDAware      Nov.    1,419,232             5,600,000            25%
               Express                      2020    This includes the     (Total population)
                                                    combined number       Based on U.S.
                                                    of iOS and Android    Census Bureau
                                                    app downloads for     estimates.
                                                    the custom app, as
                                                    well as the
                                                    Android app
                                                    downloads and
                                                    the estimated
                                                    number of
                                                    activations for iOS
                                                    for the Express
                                                    option.
Nevada         Custom and   COVID Trace     Aug.    1,202,874             3,100,000            49%
               Express                      2020    This includes the     (80% of state
                                                    combined number       population, a
                                                    of iOS and Android    proxy for the
                                                    app downloads for     number of people
                                                    the custom app, as    with
                                                    well as the           smartphones)
                                                    Android app           Based on U.S.
                                                    downloads and         Census Bureau
                                                    the estimated         estimates.
                                                    number of
                                                    activations for iOS
                                                    for the Express
                                                    option.
North          Custom       SlowCOVIDNC     Sept.   854,802               9,472,502            9%
Carolina                                    2020    The combined          (18 and older)
                                                    number of iOS and     Based on North
                                                    Android app           Carolina’s Office
                                                    downloads.            of State Budget
                                                                          and Management
                                                                          estimates for the
                                                                          adult population.
Pennsylvania   Custom       COVID Alert     Sept.   912,863               10,880,000           8%
                            PA              2020    The combined          (18-65 years old)
                                                    number of iOS and     Based on U.S.
                                                    Android app           Census Bureau
                                                    downloads.            estimates for the
                                                                          adult population
                                                                          and Pew Research
                                                                          Center estimates
                                                                          that 85% of the
                                                                          adult population
                                                                          has a smartphone.
Utah           Express      UT Exposure     Feb.    N/A                   N/A                  N/A
                            Notifications   2021




                                                                Exposure Notification GAO-21-104622 52
                                                                           Data are not
                                                                           tracked. However,
                                                                           officials estimated
                                                                           there were
                                                                           600,000
                                                                           activations in the
                                                                           initial phase of app
                                                                           deployment.
 Virginia            Custom and          COVIDWISE            Aug.         1,100,338                  4,253,335             26%
                     Express                                  2020         This includes the          (18-65 years old)
                                                                           combined number            Based on U.S.
                                                                           of iOS and Android         Census Bureau
                                                                           app downloads for          estimates for the
                                                                           the custom app, as         adult population
                                                                           well as the                and Google and
                                                                           Android app                Apple statements
                                                                           downloads and              that 80% of the
                                                                           the estimated              adult population
                                                                           number of                  has a smartphone.
                                                                           activations for iOS
                                                                           for the Express
                                                                           option.
 Washington          Express             WA Notify            Nov.         2,068,916                  6,115,500             34%
                                                              2020         The number of              (18 and older)
                                                                           Android app                Based on
                                                                           downloads and              Washington’s
                                                                           the estimated              Office of Financial
                                                                           number of                  Management
                                                                           activations for iOS.       estimates for the
                                                                                                      adult population
                                                                                                      and Pew Research
                                                                                                      Center estimates
                                                                                                      that 85% of the
                                                                                                      adult population
                                                                                                      has a smartphone.
Legend: N/A = A state that does not track the number of app downloads or its adoption rate.
Source: GAO compilation of data from selected states, related documents, interviews and other sources. I GAO-21-104622

Notes: The “as of “date for the data provided by the states ranged from May 31, 2021 to June 11, 2021.
aFor states using the Express option, daily activations for Android are from the Google Play app store, while the

Apple activations numbers are an estimate based on counting the number of times people accessed the app’s logo
image and using a multiplier provided by Google and Apple to estimate the number of people who go on to install
the Express option.
bThe adoption rates were provided to us by the states; we rounded the rates up to the nearest whole number. We

did not calculate the adoption rates; however, the rates can be calculated with the provided numerators and
denominators for the states that provided this information.




                                                                                          Exposure Notification GAO-21-104622 53
Appendix III: GAO Contacts and Staff Acknowledgments

GAO contacts

Karen L. Howard, PhD, (202) 512-6888 or howardk@gao.gov

Vijay A. D’Souza, (202) 512-6240 or dsouzav@gao.gov

Staff acknowledgments

In addition to the contacts named above, Sushil Sharma (Assistant Director), Neela Lakhmani
(Assistant Director), Eric Bachhuber (Analyst in Charge), Scott Borre (Analyst in Charge), Nora
Adkins, Daniel Emirkhanian, Donna Epler, Nancy Glover, Anika McMillon, Melissa Melvin,
Monica Perez-Nelson, Ben Shouse, Amber Sinclair, and Umesh Thakkar made key
contributions to this report. Rebecca Gertler, Tim Kinoshita, Eleni Orphanides, and Ethiene
Salgado-Rodriguez also contributed to this report.




(104622)




                                                             Exposure Notification GAO-21-104622 54
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