Selected Agencies Adapted to COVID-19 Challenges but Actions Needed to Reduce Backlogs (GAO-22-105845)

Summary

GAO testimony, GAO-22-105845, before the Senate Committee on the Judiciary on March 29, 2022, the statement of James R. McTigue, Jr., Director, Strategic Issues, on the Freedom of Information Act (FOIA). It summarizes GAO's January 2022 report finding that the COVID-19 pandemic affected selected government-wide measures of FOIA administration, while other indicators reflected ongoing longer-term trends. It notes that FOIA seeks to improve the public's access to government information and promote openness and accountability. Its title states that selected agencies adapted to COVID-19 challenges but that actions are needed to reduce backlogs.

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Full text

United States Government Accountability Office
Testimony
Before the Committee on the Judiciary,
United States Senate

FREEDOM OF
For Release on Delivery
Expected at 10:00 a.m. ET
Tuesday, March 29, 2022

INFORMATION ACT
Selected Agencies
Adapted to COVID-19
Challenges but Actions
Needed to Reduce
Backlogs
Statement of James R. McTigue, Jr., Director,
Strategic Issues

GAO-22-105845
March 29, 2022

FREEDOM OF INFORMATION ACT
Selected Agencies Adapted to COVID-19 Challenges
but Actions Needed to Reduce Backlogs
Highlights of GAO-22-105845, a testimony
before the Committee on the Judiciary, United
States Senate

Why GAO Did This Study What GAO Found
FOIA seeks to improve the public’s In January 2022, GAO reported that the COVID-19 pandemic affected selected
access to government information and government-wide measures of Freedom of Information Act (FOIA) administration,
promote openness and accountability while other indicators reflected ongoing longer-term trends. FOIA requests
in government. However, the COVID- received declined by 8 percent and requests processed declined by 12 percent in
19 pandemic presented challenges for fiscal year 2020, the first year of the pandemic, compared to the previous year.
FOIA administration by significantly
affecting how federal employees FOIA Requests Received and Processed Government-wide, Fiscal Years 2012 through 2020
performed their work as agencies
adopted a maximum telework posture
and limited on-site work.

GAO was asked to testify on FOIA
government-wide performance and the
associated impact of the pandemic.
Specifically, this statement
summarizes the results from GAO’s
previously issued reports on (1)
government-wide FOIA performance
for fiscal year 2020 compared to fiscal
year 2019 and long-term trends from
fiscal years 2012 through 2020; (2)
selected agencies’ initial pandemic-
related challenges and their use of
leading practices to maintain FOIA
operations; (3) selected agencies’
continuing challenges with FOIA
request backlogs; and (4) selected
agencies’ use of proactive information This report also found that four of five selected agencies--the Departments of
disclosures—making records publicly Agriculture, Homeland Security, and Labor, and the Environmental Protection
available without waiting for specific Agency—initially encountered temporary challenges preparing employees to
requests. work in the maximum telework environment. These challenges including working
in a virtual environment and ensuring access to equipment at home. The
To address these objectives, GAO agencies subsequently used various practices, such as providing interim
summarized the results of pertinent releases of requested information, to help maintain operations.
FOIA reports it issued from 2018 to
2022. It also followed up with selected GAO has reported that selected agencies faced continuing challenges with FOIA
agencies on the extent to which they request backlogs. From fiscal years 2012 to 2020, the government-wide backlog
had implemented GAO’s prior increased by 97 percent. GAO has made several recommendations to address
recommendations related to FOIA these challenges, including that agencies develop specific plans to reduce
operations. backlogs. However, three of these recommendations from its January 2022
report and two from its 2018 review have not yet been implemented.
Further, in 2021, GAO found that selected agencies had not (1) updated their
policies and processes to reflect current proactive disclosure requirements, and
(2) accurately and completely reported disclosures. Accordingly, it made six
recommendations to these agencies to improve their management of proactive
View GAO-22-105845. For more information, disclosures, which have not yet been implemented.
contact James R. McTigue, Jr. at (202) 512-
6806 or McTigueJ@gao.gov. Taking actions to address backlogs and make proactive disclosures could help
enhance government transparency and the efficient use of agency resources.
United States Government Accountability Office
Letter Letter

Chairman Durbin, Ranking Member Grassley, and Members of the
Committee:

I am pleased to be here today to discuss the Freedom of Information Act
(FOIA) request processing during the COVID-19 pandemic. My statement
is based on our previously issued reports on agencies’ implementation
and compliance with FOIA, including the use of proactive disclosures. 1

Signed into law more than 50 years ago, FOIA is one of several laws that
seeks to improve the public’s access to government information and
promote the principles of openness and accountability in government. 2
FOIA requires federal agencies to provide the public with access to
certain government records. 3 Each year, individuals and entities file
hundreds of thousands of FOIA requests for information on numerous
topics that contribute to the understanding of government actions.

We recently reported that the COVID-19 pandemic significantly affected
how federal employees performed their work as agencies adopted a
maximum telework posture and only allowed on-site work for limited
agency operations. In May 2020, the Office of Information Policy (OIP) in
the Department of Justice (DOJ), which is responsible for encouraging

1GAO, Freedom of Information Act: Selected Agencies Adapted to the COVID-19
Pandemic but Face Ongoing Challenges and Backlogs, GAO-22-105040 (Washington,
D.C.: Jan. 26, 2022); Freedom of Information Act: Actions Needed to Improve Agency
Compliance with Proactive Disclosure Requirements, GAO-21-254 (Washington, D.C.:
Mar. 10, 2021); Freedom of Information Act: Update on Federal Agencies’ Use of
Exemption Statutes, GAO-21-148 (Washington, D.C.: Jan. 12, 2021); Freedom of
Information Act: Federal Agencies’ Recent Implementation Efforts, GAO-20-406R
(Washington, D.C.: Mar. 11, 2020); and Freedom of Information Act: Agencies Are
Implementing Requirements, but Additional Actions Are Needed, GAO-18-365
(Washington, D.C.: June 25, 2018).
2We recently reported on several of these federal efforts to increase government
transparency. See GAO, Federal Spending Transparency: Opportunities Exist to Further
Improve the Information Available on USAspending.gov, GAO-22-104702 (Washington,
D.C.: Nov. 8, 2021); and Open Data: Agencies Need Guidance to Establish
Comprehensive Data Inventories; Information on Their Progress is Limited, GAO-21-29
(Washington, D.C.: Oct. 8, 2020). The Open, Public, Electronic and Necessary
Government Data Act, which is Title II of the Foundations for Evidence-Based
Policymaking Act of 2018, Pub. L. No. 115-435, 132 Stat. 5534 (2019), the FOIA
Improvement Act of 2016, Pub. L. No. 114-185, 130 Stat. 538 (2016), and the Digital
Accountability and Transparency Act, Pub. L. No. 113-101, 128 Stat. 1146 (2014), among
other efforts, have sought to improve the availability, transparency, and quality of federal
data.
35 U.S.C. § 552(a).

Page 1 GAO-22-105845
and overseeing agency compliance with FOIA, published guidance for
agencies to focus on finding workable solutions to maximize the efficiency
and effectiveness of FOIA administration during the pandemic. 4 In the
guidance, DOJ acknowledged that many agencies faced challenges due
to the pandemic, such as staffing and technology limitations, but affirmed
that FOIA’s statutory response times continued to apply.

My testimony today discusses (1) government-wide FOIA performance for
fiscal year 2020 compared to fiscal year 2019, as well as long-term FOIA
trends from fiscal years 2012 through 2020; (2) selected agencies’ initial
pandemic-related challenges and their use of leading practices to
maintain FOIA operations; (3) selected agencies’ continuing challenges
with FOIA backlogs; and (4) selected agencies’ use of proactive
disclosures—making records publicly available without waiting for specific
requests.

The products cited throughout this statement include detailed
explanations of the methods used to conduct our work. In addition, for this
testimony, we followed up with agencies on their implementation of our
prior relevant recommendations. We conducted the work on which this
statement is based in accordance with generally accepted government
auditing standards. Those standards require that we plan and perform the
audit to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on audit objectives. We
believe the evidence obtained provides a reasonable basis for our
findings and conclusions based on our audit objectives.

We previously reported that the COVID-19 pandemic affected selected
Key FOIA Measures measures of FOIA administration government-wide. For example, FOIA
Continued Longer- requests received and processed declined in fiscal year 2020, the first
year of the pandemic, compared to fiscal year 2019. Other key measures
Term Trends with continued longer-term trends, such as increases in FOIA request
Some Shorter-Term backlogs.
Effects from the FOIA requests received and processed. As we previously reported,
Pandemic FOIA requests received declined government-wide by 8 percent in fiscal

4Department of Justice, Office of Information Policy, Guidance for Agency FOIA
Administration in Light of COVID-19 Impacts, May 28, 2020.

Page 2 GAO-22-105845
year 2020 (790,688) compared to fiscal year 2019 (858,952). 5 Agencies
processed 12 percent fewer requests in fiscal year 2020 (772,868) than in
fiscal year 2019, when requests processed reached a record high
(877,964). 6 Prior to the pandemic, FOIA requests received and processed
government-wide rose nearly every year, increasing by 32 percent from
fiscal years 2012 through 2019. 7 (See fig. 1.)

Figure 1: FOIA Requests Received and Processed Government-wide, Fiscal Years 2012 through 2020

5In GAO-22-104050, we discuss challenges related to receiving requests by mail, so the
number of requests received may not account for unlogged requests.
6DOJ officials stated that FOIA statistics may have also been affected by a partial
government shutdown in fiscal year 2019.
7We used fiscal year 2012 as the starting point for those analyses to be consistent with
analyses presented in our prior work. GAO-21-148; GAO-20-406R; and GAO-18-365.

Page 3 GAO-22-105845
FOIA-related employees and costs. Our prior report showed that the
government-wide numbers of FOIA-related employees and costs had
generally risen since fiscal year 2012. Both of these also increased from
fiscal years 2019 to 2020.

• From fiscal year 2012 through fiscal year 2020, the total number of
FOIA full-time equivalents increased by 1,494 (37 percent). Although
FOIA-related employment across the federal government has grown,
our selected agencies cited staffing-related issues as a limitation to
addressing their backlogs.
• From fiscal year 2012 through fiscal year 2020, total FOIA-related
costs increased 39 percent on a nominal basis (22 percent adjusted
for inflation). Selected agency officials attributed increased costs to
factors such as obtaining contractor support, investing in technology
and software licenses, or addressing litigation.
FOIA request disposition. While FOIA request disposition government-
wide remained about the same from fiscal year 2019 compared to fiscal
year 2020, we previously reported that the percentage of partially granted
and partially denied requests has increased since fiscal year 2012. 8
Agencies government-wide reported 30 percent of their total requests as
partially granted and partially denied in fiscal year 2012 and nearly 42
percent in fiscal year 2020. (See fig. 2.)

8FOIA specifies nine exemptions agencies may cite to withhold information when
responding to requests, which can be applied to portions of records or the entire record.
DOJ uses the disposition category of “partial grant/partial denial” when an agency
provides the requester with some, but not all, of the information requested. This typically,
but not always, means that an agency used exemptions in its response. The number of full
denials reflects withholding all of the requested information based on a FOIA exemption
list at 5 U.S.C. § 552(b). In GAO-21-148, we analyzed agencies’ increasing use of
exemption 3, also referred to as the (b)(3) exemption, which specifically authorizes
withholding information under FOIA on the basis of another federal statute that prohibits
disclosure of that information.

Page 4 GAO-22-105845
Figure 2: Comparison of Request Disposition Government-wide, Fiscal Years 2012
and 2020

Selected Agencies
Addressed
Pandemic-Related
Challenges and Used
Leading Practices to
Maintain FOIA
Operations
The COVID-19 Pandemic In our recent report, we discussed how selected agencies addressed
Presented Initial pandemic-related challenges. Specifically, we reviewed a
nongeneralizable sample of five agencies based on a variety of factors,
Challenges for Agencies
including the number of FOIA requests received, processed, and
backlogged, and the size of FOIA offices, among other criteria. In
addition, we selected one component at each of the two largest agencies
based on FOIA volume. We selected the

• Department of Agriculture,
• Department of Homeland Security (DHS) and Customs and Border
Protection (CBP),
• DOJ and the Federal Bureau of Investigations (FBI),

Page 5 GAO-22-105845
• Department of Labor, and
• Environmental Protection Agency.
We found that four of the five selected agencies encountered temporary
challenges preparing employees to work in the maximum telework
environment in the early months of the pandemic, such as ensuring
access to equipment at home or adjusting to a virtual environment. 9 The
pandemic also affected agencies’ ability to receive FOIA requests by mail
and access paper records.

The FBI’s challenges differed from the other four agencies, given its dual
law enforcement and intelligence mission, which requires FBI’s staff to
handle a large volume of sensitive and classified records within an on-site
classified information technology system. As such, compared to other
agencies, FBI had to ensure workforce safety in a physical office setting
rather than being able to rely on telework. However, FBI officials stated
they had resumed limited on-site operations by the end of April 2020.

Although the five selected agencies said they effectively managed
challenges related to the pandemic to maintain their FOIA operations,
their experience was not necessarily representative of all federal
agencies. Office of Government Information Services (OGIS) officials told
us that some federal agencies had more difficulty managing these
challenges or encountered additional challenges.

Selected Agencies Used OIP’s COVID-19 guidance stated that agencies significantly affected by
Leading Practices to processing limitations due to the pandemic could consider strategies and
leading practices to implement FOIA. In our recent report, we found that
Maintain Operations
selected agencies used strategies and leading practices to maintain
during the Pandemic operations during the pandemic that included the following:

Increased communication with requesters. All selected agencies
posted notices on their websites describing the effects of the pandemic
on FOIA operations. These notices generally alerted requesters to
potential delays in receiving requests by mail or other limitations related
to processing.

Interim releases. OIP encouraged agencies to provide interim releases
as another opportunity to communicate with requesters, such as asking
whether the requester would like to reformulate or narrow the scope of
9We considered the declaration of the national emergency related to COVID-19 on March
13, 2020 as the beginning of the pandemic.

Page 6 GAO-22-105845
the request based on the initial information received. All five selected
agencies noted the helpfulness of such interim releases because they (1)
sometimes fully satisfied a requester’s information needs, causing them
to close their requests, or (2) potentially reduced litigation when they
could not fulfill requests within statutory timeframes.

Proactive disclosures. OIP reiterated the practice of proactive
disclosures—making records publicly available without waiting for specific
requests. 10

As we previously reported, the government-wide FOIA request backlog
Selected Agencies increased by 18 percent (from 120,436 to 141,762 requests) from fiscal
Faced Persistent years 2019 to 2020. Backlogged requests have been trending generally
upwards since fiscal year 2016. (See fig. 3.) 11 From fiscal years 2012 to
FOIA Backlogs 2020, backlogs increased by a total of 97 percent. During this same time
period, the appeals backlog also increased by 63 percent. 12

105 U.S.C. § 552(a)(2).

11DOJ reported a 3-week government shutdown during which some agencies could not
process requests in fiscal year 2014. The government-wide FOIA backlog rose 67 percent
from fiscal year 2013.
12FOIA allows a requester to challenge an agency’s final decision on a request through an
administrative appeal or a lawsuit. Agencies generally have 20 working days to respond to
an administrative appeal.

Page 7 GAO-22-105845
Figure 3: Request Backlogs Government-wide, Fiscal Years 2012 through 2020

In fiscal year 2020, most federal agencies had fewer than 100 backlogged
requests, but these 87 agencies represented only 1 percent of the total
backlogged requests government-wide. The 16 agencies with backlogs of
more than 1,000 requests (an increase of three agencies from the
previous fiscal year) represented 94 percent of the total backlogged
requests government-wide. (See fig. 4.) 13

13The top three agencies with request backlogs are DHS, DOJ, and the Department of
Defense. For more information about the other agencies, see figure 11 in
GAO-22-105040.

Page 8 GAO-22-105845
Figure 4: Percentage of Total Backlogged Requests Government-wide by Number
of Backlogged Requests for Fiscal Year 2020

In our recent report, we discussed that the selected agencies identified
several new or ongoing challenges that affected their backlog, such as
the complexity of requests, increasing litigation, staffing limitations, and
technology-related issues.

Increasing complexity of requests. Between fiscal years 2012 and
2020, the number of complex requests processed rose for four of the five
selected agencies—Department of Agriculture (USDA), DHS, DOJ, and
Department of Labor (DOL)—while the percentage of complex requests
processed rose at three of the five agencies—USDA, DOJ, and DOL.
(See table 1 below.) Complex requests typically seek a high volume of
material or require additional steps to process, such as the need to
search for records in multiple locations. Agencies also may consider

Page 9 GAO-22-105845
some FOIA requests as presenting “unusual circumstances” and seek to
extend the statutory time limit. 14

Table 1: Selected Agencies’ Complex FOIA Requests Processed in Fiscal Years 2012 and 2020

Fiscal Year 2012 Fiscal Year 2020
Complex Complex Complex Complex Percent
Requests Requests as Requests Requests as change from
Selected Agency Processed Percent of Total Processed Percent of Total 2012 to 2020
Department of 1,696 7.8% 2,190 9.5% 29
Agriculture
Department of 111,811 58.8% 184,957 50.8% 65
Homeland Security
Department of Justice 9,738 16.0% 13,837 19.2% 42
Department of Labor 9,872 51.3% 10,639 68.0% 8
Environmental 4,135 49.2% 1,528 21.3% -63
Protection Agency
Source: GAO analysis of agency-reported Freedom of Information Act (FOIA) data on FOIA.gov. | GAO-22-105845

Litigation. The selected agencies stated that litigation affects the
resources available for processing FOIA requests and administrative
appeals. Further, they said litigation can negatively impact a FOIA
program office’s ability to process nonlitigation FOIA requests in a timely
manner by requiring them to prioritize work on responses in litigation. This
can result in an increase in backlogged requests if an office has
insufficient staff to process both litigation and nonlitigation requests.

All five selected agencies we reviewed in our recent report cited a general
increase in litigation as a current or emerging challenge prior to the
pandemic. Overall, DOJ’s annual reporting showed a more than 100
percent increase in the number of the FOIA litigation cases received and
decided in federal district courts from 2012 to 2020. (See fig. 5.)

14“Unusual circumstances” is defined in statute as (1) the need to search for and collect
records from field facilities or other establishments that are separate from the office
processing the request; (2) the need to search, collect, and examine a voluminous amount
of separate and distinct records which are demanded in a single request; and (3) the need
for consultation with another agency having a substantial interest in the determination of
the request, or among two or more components of an agency having substantial subject-
matter interest. 5 U.S.C. § 552(a)(6)(B)(iii). The 20-working-day time limit may be
extended by up to 10 days for a total of 30 working days by notifying the requester in
writing, setting forth the unusual circumstances for an extension and the date the agency
expects to send its determination. 5 U.S.C. § 552(a)(6)(B)(i).

Page 10 GAO-22-105845
Figure 5: FOIA Litigation Cases Received and Decided in Federal District Courts, 2012 through 2020

In our report, we recommended that OIP reassess the reporting
requirements, including collecting more information on current and
emerging challenges, such as the use of the “unusual circumstances”
designation and effects of FOIA litigation. By reassessing the reporting
process, OIP could help align the workload required for agencies to meet
the reporting requirements and ensure they have the information they
need to meet their responsibilities under FOIA. In December 2021, OIP
agreed with the recommendation and stated it will continue looking for
ways to both reduce reporting burden and collect metrics that provide
value. We will monitor OIP’s progress and follow up as necessary.

Resource Constraints. Selected agencies cited the loss of staff or
increasing workload as a limitation to their ability to address backlogs.
Several agencies made organizational changes to improve long-term
FOIA implementation, such as speeding up request processing through
centralization. Selected agencies also cited technology-related challenges
such as the need for system upgrades. Several agencies continued long-
term efforts for improving their FOIA operations by implementing a new
case management system or planning for procurement.

Our recent report compared selected agencies’ backlog reduction plans
to leading practices for performance management. (See fig. 6.) DOJ

Page 11 GAO-22-105845
guidance instructs agencies to have a backlog reduction plan if they have
more than 1,000 backlogged requests in the previous year. 15

Figure 6: Summary of GAO’s Assessment of Selected Agencies’ FOIA Backlog
Reduction Plans

Note: For the purposes of our analysis, we are excluding the Department of Justice (DOJ). DOJ’s
FOIA program is decentralized, with 31 separate FOIA offices handling requests under Office of
Information Policy oversight. Many DOJ components develop their own backlog reduction plans, such
as the Federal Bureau of Investigation.

In 2018 and in our recent report, we made recommendations for agencies
to improve their backlog reduction plans. In 2018, we reviewed selected
agencies’ documentation for methods to reduce backlogged requests,
and then compared their procedures to best practices for reducing
backlogs, as identified by the Office of Information Policy. 16 We made

15DOJ’s guidance for agency Chief FOIA Officer Reports states that, as part of their
reports, agencies with a backlog of more than 1,000 requests in the previous fiscal year
should explain their plans to reduce backlogs in the next fiscal year. Agencies are also
asked to detail how the agency developed and plans to execute their plan. Department of
Justice, Office of Information Policy, Guidelines for 2021 Chief FOIA Officer Reports
(Sept. 24, 2020); and OIP Guidance for Further Improvement Based on 2019 Chief FOIA
Officer Reports (January 22, 2020).
16Department of Justice, Office of Information Policy: Guidance on Reducing Backlogs
and Improving Timeliness, (August 15, 2014) and Best Practices Workshop, (May 20,
2014).

Page 12 GAO-22-105845
eight backlog-related recommendations for agencies to address the need
to develop and document a plan—six have been implemented and two
are not yet implemented. 17

In January 2022, we made three recommendations—one each to the
Departments of Agriculture, Homeland Security, and Labor—to address
varying aspects of their backlog reduction efforts. 18 All three agencies
agreed with our recommendations and planned to take additional steps
toward improving their backlog reduction efforts.

When agencies make proactive disclosures, they enhance transparency
Improving Agency by ensuring that agencies readily and efficiently make certain information
Compliance with about the operations and activities of the government available to all.
Additionally, publicly releasing records on a popular topic could reduce
Proactive Disclosure the number of FOIA requests for the same records an agency receives.
Requirements Could For example, in our most recent report, one of our selected agencies told
us they closed over 1,000 FOIA requests by directing the requester to
Make More information already posted online in fiscal years 2019 and 2020.
Information Publicly
In our 2021 report, we found that some selected agencies had not fully
Available updated their policies and processes to reflect the current proactive
disclosure requirements. 19 All three selected agencies had not fully
complied with the statutory reporting requirements and DOJ guidance on
their proactive disclosures. While the agencies have made progress, our
six recommendations related to proactive disclosures have not yet been
implemented. We also identified additional steps OIP could take to
support agency compliance. OIP implemented two recommendations we
made by requiring agencies that report zero proactive disclosures to

17The Department of Interior and Equal Employment Opportunity Commission had not yet
implemented their respective recommendations to take steps to develop and document a
plan that fully addresses best practices with regards to reduction of backlogged FOIA
requests.
18Specifically, we recommended that the Department of Agriculture better document their
backlog reduction efforts; the Department of Labor resolve data quality issues; and the
Department of Homeland Security develop component-level backlog reduction plans.
19In our 2021 report, we reviewed three agencies—Federal Aviation Administration (FAA),
Department of Housing and Urban Development (HUD), and Veterans Health
Administration (VHA). We found that FAA should document proactive disclosure
requirements and procedures and HUD should update its policies for compliance.
GAO-21-254.

Page 13 GAO-22-105845
provide an explanation and providing new guidance for agencies on
counting disclosures. 20

In summary, making proactive disclosures helps enhance government
transparency and the efficient use of agency resources. In addition,
accurately and completely reporting disclosures could provide useful
information for agencies to manage their FOIA programs as well as for
the public to assess agencies’ transparency.

The selected agencies we reviewed adapted to maintain operations
during the COVID-19 pandemic. However, increasing FOIA request
backlogs remain a persistent challenge. Current and emerging
challenges, such as litigation, further threaten agencies’ ability to reduce
backlogs. Addressing these challenges by incorporating leading practices
into backlog reduction plans and tracking emerging challenges could
improve agencies’ ability to respond to the needs of requesters and the
public.

Chairman Durbin, Ranking Member Grassley, and Members of the
Committee, this concludes my prepared statement. I would be pleased to
respond to any questions that you may have at this time.

If you or your staff have any questions about this testimony, please
GAO Contact contact me at (202) 512-6806 or mctiguej@gao.gov. Contact points for
and Staff our Offices of Congressional Relations and Public Affairs may be found
on the last page of this statement.
Acknowledgments
Key contributors to this testimony include Shea Bader (Assistant
Director), Giny Cheong (Analyst-in-Charge), Jacqueline Chapin,
Samantha Lalisan, Andrew Lobel, and Robert Robinson. Other staff who
made key contributions to the reports cited in the testimony are identified
in the source products.

20Department of Justice, Office of the Attorney General, Memorandum for Heads of
Executive Departments and Agencies: Freedom of Information Act Guidelines (March 15,
2022).

(105845)
Page 14 GAO-22-105845
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