Special Report Legislative Joint Auditing Committee February 24, 2012

Transcription

1 Special Report Legislative Joint Auditing Committee February 24, 2012 Arkansas Department of Workforce Services Review of the Unemployment Insurance Benefit Claims Process, Overpayments, and Advanced Federal Funds INTRODUCTION This report is issued to provide the Legislative Joint Auditing Committee with details about the unemployment insurance benefit process used by the Arkansas Department of Workforce Services (DWS), the $161.3 million in estimated DWS benefit overpayments reported by the United States Department of Labor (USDOL) as a performance measure, and the $360 million in federal funds borrowed by DWS for benefit payments that is expected to be repaid with interest by The results of our review are summarized in the Conclusion section on page 7. OBJECTIVES The objectives of the report are as follows: Describe the unemployment insurance claims filing and approval process. Provide an explanation of the benefit overpayment recovery process and the amount of Agency benefit overpayments. Determine the amount of federal funds advanced to DWS for unemployment benefits during the review period as well as the amount that remains outstanding. SCOPE AND METHODOLOGY This review covers the period July 1, 2009 through June 30, DWS staff were interviewed, and relevant DWS policies and procedures were reviewed. Financial information provided by DWS as well as the USDOL was also reviewed. DWS financial statements are provided in Appendix A. The methodology used in conducting this review was developed uniquely to address the stated objectives and, therefore, was more limited in scope than an audit or attestation engagement performed in accordance with Government Auditing Standards issued by the Comptroller General of the United States. BACKGROUND Unemployment insurance benefits provide temporary financial assistance to eligible workers who lose employment. As identified in Exhibit I on page 2, DWS has 31 local offices providing benefit services. Due ARKANSAS DIVISION OF LEGISLATIVE AUDIT 172 State Capitol, Little Rock, AR Phone: Fax: Report ID: IRSA02011 Report Date: February 22, 2012

2 Arkansas Department of Workforce Services - Review of Unemployment Insurance Exhibit I Arkansas Department of Workforce Services Local Offices As of December 31, 2011 Rogers. Harrison.. Mtn. Home Fayetteville. Walnut Ridge. Jonesboro Batesville.. Paragould. Blytheville. Newport Ft. Smith. Russellville. Searcy Conway... W. Memphis. Forest City. Jacksonville Hot Springs Mena... Benton Arkadelphia... Little Rock. Helena/ W. Helena. Malvern Pine Bluff Hope. Texarkana.. Camden. Monticello Magnolia.. El Dorado Source: Arkansas Department of Workforce Services to the recent national economic recession, total claims for benefits have increased significantly over the last five years. Exhibit II illustrates the number of claims filed and the amount of benefits paid during fiscal years 2006 through Unemployment insurance benefits are funded by taxes collected from employers. DWS collects unemployment insurance from two types of taxpayers: reimbursing and contributing. Reimbursing taxpayers are governmental entities (i.e., federal, state, and local), political subdivisions (i.e., K-12 school districts), and Internal Revenue Code 501(c) (3) non-profit organizations. These taxpayers report wages paid to employees but, instead of paying tax on the wages, reimburse DWS for any benefits paid on their behalf. These entities, in effect, self-insure their risk for unemployment claims. All remaining entities are considered contributing taxpayers. These taxpayers report wages paid quarterly and pay the Arkansas unemployment contribution rate on the first $12,000 (increased from $10,000 on January 1, 2010) of wages paid to each Exhibit II Arkansas Department of Workforce Services Unemployment Insurance Claims Fiscal Years 2006 through ,000,000 2,000,000 1,000,000 0 $1,200,000,000 $1,000,000,000 $800,000,000 $600,000,000 $400,000,000 $200,000, $- Number of Weekly Claims Filed Amount of Benefits Paid Source: Arkansas Department of Workforce Services (unaudited by the Division of Legislative Audit) employee in each calendar year. If state payments are made timely, employers pay a lower federal unemployment tax rate. The contribution rate varies by employer and is detailed later in the report. 2

3 Arkansas Division of Legislative Audit RESULTS OF REVIEW The results of this review are discussed below in three sections: claim filing, approval, and appeal process; unemployment insurance overpayments; and funds advanced from the federal government. While instances of inappropriate activity were not identified, we did note procedures DWS might improve to enhance efficiency. Claim Filing, Approval, and Appeal Process Both Arkansas and federal statutes provide general requirements for claims filing, claims approval, and appeals processing. The benefit process is intentionally structured to provide initial benefits to claimants within 14 days of the claimant becoming eligible. The DWS unemployment benefit process is illustrated in Exhibit III. Each major step is discussed below. Initial Claim Filing Unemployed Arkansas workers may file a claim for unemployment insurance benefits with DWS, which is charged with obtaining the information necessary to determine claimant eligibility within USDOL guidelines and state law. A copy of the claim form is provided in Appendix B. Both monetary and non-monetary factors are considered when determining eligibility. Monetary eligibility is based on work history and wage records. Non-monetary eligibility is based on separation issues (i.e., whether the claimant quit or was discharged) and the claimant s ability to perform work, availability for work, and citizenship status. If additional information is needed, DWS mails documents to claimants and employers and holds benefit payments until eligibility matters are resolved. Once the additional information is obtained, DWS adjudicators Exhibit III Arkansas Department of Workforce Services (DWS) Unemployment Insurance Benefit Claim Filing, Approval, and Appeal Process BAM - Benefit Accuracy Measurement BPC - Benefit Payment Control FIRE - Fraud Investigations, Recovery, and Enforcement Source: Arkansas Department of Workforce Services 3

4 Arkansas Department of Workforce Services - Review of Unemployment Insurance issue necessary determinations and adjust the claim to restart the payment process. Weekly Claim Filing After filing an initial claim, claimants must establish weekly eligibility to continue receiving benefit payments. Weekly claims may be filed online or through an automated telephone system. Based on the information filed, payment will continue or be flagged due to issues such as ability to/availability for work, refusal of a job offer or recall to work, separation issues, and earnings issues. If flagged, payments are suspended until issues are resolved. As with initial claims, flagged issues are assigned to a DWS adjudicator for resolution. Appeals Process A DWS determination concerning the eligibility of an unemployment insurance claim may be appealed to the Arkansas Appeal Tribunal comprised of 12 DWS hearing officers. A subsequent hearing either affirms, reverses, or modifies DWS determination. An appeal may be made to the Arkansas Board of Review, which affirms, reverses, or modifies the Appeal Tribunal s findings and conclusions. The Board consists of three Arkansas citizens appointed by the Governor. All Board decisions may be appealed by petition to the Arkansas Court of Appeals within 30 calendar days. Based on our review of the claim filing, approval, and appeal process, we conclude DWS should enhance the efficiency and effectiveness of its controls to limit the need to obtain additional information from claimants and employers. We recommend DWS adopt additional preventive and detective controls by increasing its use of electronic correspondence with employers, rather than postal mail, to reduce the time needed to gather information verifying eligibility. Management Response: DWS agrees that electronic correspondence with employers helps reduce response time and has a positive effect upon the prevention and detection of possible unemployment insurance overpayments. DWS has developed an Internet application that allows employers to receive and respond to the Notice to Last Employer (DWS 501.3), Notice to Base Period Employer (DWS 550), and all of the Adjudication Questionnaires (DWS 525). DWS is working with select employers to perfect the application. DWS also has an Internet application, the Internet Response Module for Employers (IRME), that allows employers to receive notice of and respond to Wage Audit Notices (DWS 901A). DWS will continue to explore means of incorporating electronic media into its processes that will reduce employer response time and improve our prevention and detection efforts. Unemployment Insurance Overpayments The federal regulations that require DWS to provide initial benefit payments within 14 days cause DWS to render benefits to otherwise ineligible claimants, resulting in overpayments. In effect, routine overpayments of benefits are anticipated because of the federal limitation on the time states have between when a benefits claim is filed and when DWS must determine a claimant s eligibility. However, DWS works to minimize overpayments through management controls as discussed below. Management Controls to Reduce and Identify Overpayments The USDOL mandates that states have procedures in place to estimate the overall benefits amounts overpaid and review individual claims to identify overpayments that can be recovered. DWS utilizes a variety of state efforts to identify and prevent erroneous payments and disqualifying determinations. This report focuses on three DWS units used to reduce and identify overpayments: Benefit Accuracy Measurement (BAM); Fraud Investigations, Recovery, and Enforcement (FIRE); and Benefit Payment Control (BPC). BAM Unit The BAM Unit provides quality control for DWS by testing processed claims. The 4

5 Arkansas Division of Legislative Audit USDOL requires all states to review processed claims so that the USDOL can calculate each state s estimated amount of benefits overpayment. The USDOL predetermines the claims to be selected for testing, and states are expected to review a minimum number of cases each week. The USDOL expects Arkansas to review a minimum of 10 paid claims and 9 denied claims each week, totaling 480 paid claims and 450 denied claims per year. The primary purpose of the testing is to identify system-wide errors and prevent future errors. The BAM Unit then tracks the impact of corrective actions by monitoring the results of subsequent testing. BAM testing results are submitted to a USDOL database and reported on the USDOL s website using varying rate measurements. FIRE Unit The FIRE Unit investigates claimants who incorrectly reported earnings, and prosecution is pursued if the benefit overpayment amount is more than $12,000. FIRE collects evidence for Arkansas prosecuting attorneys who then determine if criminal charges will be filed. The FIRE Unit uses specialized software to automate processing of 85% of its investigations. This automation is designed to identify claimants recently hired to new jobs who continue to file weekly benefit claims through two cross matching processes: a quarterly benefit/wage match and a weekly new hire data match. The benefit/ wage data, which identify those claiming unemployment benefits while drawing wages, are derived from federally mandated quarterly employer payroll reports. Each quarterly cross match compares DWS weekly paid claims to the employer quarterly wage file information for the same time period. This matching process generally takes one week to complete. Because FIRE Unit resources are limited to six investigators, the number of investigations opened is based on staffing availability. Recent DWS statistics show 1,000 FIRE Unit investigations, on average, are initiated each week. When completed timely, the quarterly match process effectively identifies overpayments. However, the process cannot be completed for up to five months for two reasons that are beyond DWS control: First, employer quarterly wage files can be received manually or electronically, and second, time must be allowed for interstate wages (i.e., Arkansas wages employers report to another state) to be processed and submitted to a national database. BPC Unit The BPC Unit s function is to record, calculate, manage, collect, and report on all benefit overpayments identified by DWS. Overpayment reimbursements are received from claimants, courts, and DFA state income tax refund intercepts. Federal Calculation of Overpayments BAM Unit testing data are used to ensure the integrity of the systems states use to administer unemployment insurance benefits and to verify those processes comply with federal requirements. Using each state s BAM testing results, the USDOL then calculates and reports the estimated overpayment amount on its website and to the federal Office of Management and Budget. On September 16, 2011, the USDOL released statistics on unemployment benefit overpayments for all states based on BAM Unit testing data. Arkansas was listed as having an overpayment performance measure of $161.3 million in unemployment benefits from July 1, 2008 through June 30, The USDOL cited the primary overpayment cause in 63% of cases as claimants continuing to claim and receive benefits after returning to work. The USDOL also reported that DWS is fully or partially responsible for 15% of the $161.3 million estimated overpayments, with the claimant or employer being fully or partially responsible for the remaining 85%. The USDOL ranked Arkansas as 5

6 Arkansas Department of Workforce Services - Review of Unemployment Insurance having the 23rd highest percentage of unemployment benefit overpayments during the three-year period at 12%. Indiana is ranked highest with a 43% error rate. However, the BAM data are used by the USDOL as a performance measure only, and Arkansas is not expected to try to collect estimated overpayment amounts or to repay the amount to the federal government. The estimated overpayments are only used to measure controls in state unemployment benefit payment processes. DWS Calculation of Overpayments DWS uses the annual BAM rate discussed above as well as the BAM operational rate to measure its performance. While both rates are derived from the same data, the BAM operational overpayment rate includes overpayments that states are reasonably expected to detect and recover. DWS annual BAM rate and BAM operational rate have been below 10% each year for the past 10 years. Overpayments at the end of fiscal years 2009 through 2011 are provided in Exhibit IV and are divided between fraudulent and non-fraudulent benefit overpayments. Exhibit IV Arkansas Department of Workforce Services Recorded Overpayments (in millions) Fiscal Years 2009 through Fraudulent $31 $23 $21 Non-Fraudulent Total $44 $33 $30 Source: Arkansas Department of Workforce Services (unaudited by the Division of Legislative Audit) For fiscal year 2011, we identified overpayments to 51,580 individual claimants. Of these, 376 individuals received benefit overpayments between $10,000 and $50,000. One individual received overpayments in excess of $50,000, totaling $51,046. Based on our review, we conclude DWS does not match new hire and wage data in a timely manner. Though cross matching inherently requires a five-month delay for data accumulation in various databases, we noted in 2011 that DWS was lagging two additional months behind the five-month inherent lag time when cross matching procedures should have been completed. We recommend not only that DWS conduct its cross matches of new hire and wage data in a timely manner but also that the FIRE Unit more proactively conduct its reviews. Software programming enhancements would allow DWS to compare new data entered by Arkansas employers into new hire reports employers complete weekly for each newly hired employee and wage reports employers prepare quarterly on a continual basis rather than waiting five months for the federal wage registry to be updated. The time gained by running the comparison of Arkansas data prior to the update of the federal registry might significantly reduce the number and amount of claim overpayments. Management Response: DWS agrees that running the cross matches on a timely basis has a positive effect upon the detection of unemployment insurance overpayments. DWS now runs the cross matches as soon as is possible, given the current technological capability and given the availability of the data. DWS is evaluating processes and technology to determine if gains can be made in the timing of the matches in relation to the payment of benefits. Funds Advanced from the Federal Government Higher unemployment rates since 2009 have caused significant increases in claims for unemployment benefits. According to the United States Bureau of Labor Statistics, the unemployment rate in Arkansas was 7.7% for calendar year The increase in claims has necessitated $360 million in loan advances from the federal government over the past three years to fund benefits payments. The loan advances bore an 6

7 Arkansas Division of Legislative Audit interest rate of 4.1% in calendar year DWS plans to repay the advances with interest by To date, DWS has made one interest payment of $10.1 million and one principal payment of $29.1 million, leaving a loan balance of $330.9 million at December 31, On April 1, 2011, Arkansas law increased the unemployment tax rate on all contributing employers by 0.2% to fund the interest due on the advances. The entire employer contribution rate formula is discussed in Exhibit V on page 7. Based on our review of the federal funds advanced from the federal government, we conclude the advances were allowed and, as shown in DWS financial statements at Appendix A, were necessary to pay unemployment benefits. Of 27 states and the U.S. Virgin Islands, which owe a total of $37.9 billion to the federal government, Arkansas ranks 19th in terms of monies owed. CONCLUSION As a result of our review, we did not identify any areas of inappropriate activity relating to benefit payments. Also, we conclude the borrowing of $360 million from the federal government to pay unemployment benefits was allowed and necessary. At December 31, 2011, DWS had a remaining loan balance of $330.9 million, which is expected to be repaid with interest by The loan interest payments are funded by a 0.2% increase in the unemployment tax rate paid by all contributing employers. Additionally, we conclude the $161.3 million in overpayments reported by the USDOL is only a performance measure used to evaluate benefit processing procedures and is not an amount expected to be repaid to the federal government. Exhibit V Arkansas Department of Workforce Services Employer Contribution Rate Formula Contributing unemployment insurance taxpayers report wages paid quarterly and pay the Arkansas contribution rate on the first $12,000 (increased from $10,000 on January 1, 2010) of wages paid to each employee in each calendar year. The contribution rate is the sum of the following: The employer rate Either (a) the new employer rate of 2.9% for the first three years of the employer s existence or (b) the experienced employer rate for employers in existence for more than three years. The experienced employer rate varies from 0.1% to 10%, depending upon if and how much unemployment insurance benefits have been paid on behalf of the employer. The stabilization tax An additional 0.8% that is levied on all contributing employers when the balance of the unemployment insurance fund is insufficient to pay for anticipated obligations. The extended benefits tax An additional 0.1% levied on all contributing employers to pay for the State s 50% share of extended benefits when the unemployment insurance fund balance is insufficient to pay those benefits deemed necessary by the federal government. When deemed necessary, the federal government provides funding for 50% of the extended benefits. The advance interest tax An additional 0.2% levied on all contributing employers to pay the interest on the advances made by the U.S. Treasury to fund unemployment insurance benefits in excess of other sources of funding. Source: Arkansas Department of Workforce Services 7

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9 Arkansas Department of Workforce Services Financial Statements Appendix A Arkansas Department of Workforce Services Unemployment Insurance Programs June 30, 2011, 2010, 2009 BALANCE SHEET At the Years Ended June Cash $ 134,112,619 $ 95,842,701 $ 7,767,621 Accounts receivable Unemployment tax and overpayment receivables 121,817, ,555,520 82,705,439 Federal government 91,498-1,268,834 Interfund receivables 2,376,866 1,766,865 3,189,949 Other 5,785,968 6,842,610 10,775,964 TOTAL ASSETS $ 264,184,038 $ 221,007,696 $ 105,707,807 LIABILITIES AND FUND BALANCE Accounts payable $ 61,688,891 $ 83,587,796 $ 102,294,452 Due to other funds 25,000-1,006,575 Due to other governments 1,852,173 2,035, ,729 Advances from federal government 360,129, ,853,383 69,853,670 TOTAL LIABILITIES 423,695, ,476, ,881,426 FUND BALANCE (159,511,565) (195,469,147) (68,173,619) TOTAL LIABILITIES AND FUND BALANCE $ 264,184,038 $ 221,007,696 $ 105,707,807 REVENUES, EXPENDITURES, AND CHANGES IN FUND BALANCE For the Years Ended June REVENUES Unemployment tax revenues $ 407,174,363 $ 344,900,830 $ 298,883,348 Investment revenue 185, ,825 4,180,958 Other State benefit reimbursements 20,403,796 32,733,551 24,568,164 Federal grants and reimbursements 377,261, ,289, ,496,833 TOTAL REVENUES 805,024, ,660, ,129,303 EXPENDITURES Unemployed worker training expenses 5,017,343 8,268,932 8,327,589 Unemployment benefits 764,049,636 1,060,687, ,867,755 TOTAL EXPENDITURES 769,066,979 1,068,956, ,195,344 EXCESS OF REVENUES OVER EXPENDITURES 35,957,582 (127,295,528) (299,066,041) FUND BALANCE - JULY 1 (195,469,147) (68,173,619) 230,892,422 FUND BALANCE - JUNE 30 $ (159,511,565) $ (195,469,147) $ (68,173,619) Unaudited by the Division of Legislative Audit A-1 SOURCE OF INFORMATION: AASIS funds and

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11 Appendix B! " # $ % $ & ' ( ) * + ) #, & -!. ' & # & ( / 9 < >? : : 1 =? 0? A 7 > 8 D E F G H I J K K L G M J N I O P =? ; 0? A 7 > 8 D E F G H I J K K L G M J N I O P > 7 7 0? : ; : 1 =? { ; : < > Q 1? > ; Ä ;? 3 < Q ; > < «1 > Å 7? b T U V W c ` a T [ W [ _ V b T _ W b \ _ V m V b V b c _ R b _ R \ T m Æ V ² m a d Ç m T T c f 4 T c? V ; X U T c [ R _ T U V W R b T c ` a T [ W [ _ V b T _ W b \ _ V m V b 9 «R c U V W b c _ m V b f d z B W Z Z _ Y ] T Ç a b c e z R b Y ] T c c _ a R \ Ç a b c z 0 T ] ^ V b R b U d e Ç [ R U c V b c c È É ~ Ê w x w Ê o v o p r y Ë o p u Ì y Í Î p y Ï p x } o v s w u y Ð } q Ñ Ò Ê q ~ w w y Ì } w v y «T R _ a T b T b c V \ R Z 7 ] T b µ T \ ` U 6 T ^ Y \ µ 6 ^ b Y \ µ A b T R 6 W c ^ T \ c T [ Y ` R Z < T R S T < R ` 1 X «V b Q T R a B a _ Y \ µ 6 W ] ] T b A b T R 6 a R b T [ «V b 6 _ b Y T B Y \ a T [ Ó V ² Ä T \ T b R Z 3 ² c T \ _ Ô 0 R b [ U Q V Z R U C R ` R _ \ Q V Z R U c A W c Y \ T c c : c T [ ; \ c W ² V b [ Y \ R _ \ < V ` V W _ 6 _ Y Z Z «V b Y \ µ R b Y ] T 2 b Y \ Y \ µ Ô 2 b W µ 0 T c _ B R ] T [ Y ` R Z < T R S T Ä T \ T b R Z > T [ W ` T [ X b V ] X W Z Z _ Y ] T Ç a b c Ù Ú! " # $ % $ & ' ( ) * + ) #, & -!. ' & # & ( / ZT Y_ ZT ZR ZT ZT ZT YV Z_ Yµ Yc Y[ YV Y[ ZV YV ZU 9 2 V U V W m R \ V a R S T B T [ T b R Z ; \ ` V ] T 0 R Õ T c m Y_ a a T Z[ 9 2 V U V W a R S T ` a Y Z[ b T \ Ô V _ a T b c _ a R _ b T Û W Y b T ` R b T f Ø Ø 4 T c? V X b V ] U V W b m T T ZU ² T \ T X Y_ ^ R U ] T \ _ f Ø Ø Ø Ø Ø Ø 4 T c? V 9 ; X 4 T c a R S T R b b R \ µ T ] T \ _ X V b _ a T Y b ` R b T 9 Q R S T U V W a R [ m V b V X R \ U Y \ [ c Y \ ` T U V W b ² T T \ ] R [ T YX U V W X Y \ [ m V b f 4 T c? V < < > f Ø Ø Ø Ø Ø 4 T c? V Q R S T U V W b T X W c T [ R \ U Æ V ² c Y \ ` T U V W ² T ` R ] T 9 3 b T U V W T \ _ Y_ ZT [ _ V V b R b T U V W b T ` T YS Y \ µ R \ U V X _ a T X V Z ZV m Y \ µ 8 W \ T ] ^ ZV U T [ f Ø Ø Ø Ø Ø 4 T c? V 9 C R ` R _ YV \ R U f Ø Ø Ø Ø Ø Ø 4 T c? V 3 b T U V W R T \ [ Y \ µ c ` a V V Z f 4 T c? V 9 Q V Z Y[ R U R U f Ø Ø Ø Ø Ø Ø 4 T c? V ; X? V 3 b T U V W ^ ZR \ \ Y \ µ V \ R T \ [ Y \ µ c ` a V V Z f 4 T c? V 9 A V \ W c R U f Ø Ø Ø Ø Ø Ø 4 T c? V ; X 4 T c 2 V U V W a R S T R [ R _ T X V b T \ _ T b Y \ µ 4 T c? V 9 6 Y ` R U f Ø Ø Ø Ø Ø Ø 4 T c? V c ` a V V Z Y \ X W _ W b T f = \ [ T ` Y[ T [ 9 6 T S T b R \ ` T R U f Ø Ø Ø Ø Ø Ø 4 T c? V 9 Q R S T U V W m V b T [ Y \ B T [ T b R Z 7 ] ^ ZV U ] T \ _ Y \ _ a T ^ R c _ 9 b V X Y_ 6 a R b Y \ µ f Ø Ø Ø Ø Ø Ø 4 T c? V d ] V \ _ a c f? V V Y \ ` Z W [ Y Z Y_ R b U 6 T b S Y ` T Ø Ø Ø Ø Ø Ø Ø Ø 4 T c? V 9 R Y[ V X X 0 Y ] T Ø Ø Ø Ø Ø Ø 4 T c? V 9 ; X 4 T c 9 d 2 V U V W a R S T R ` V ^ U V X U V W b 6 B z 9 3 b T U V W b T ` T YS Y \ µ V b a R S T U V W R ^ ^ Z YT [ X V b R ^ T \ c YV \ R \ \ W Y_ U V b b T _ Y b T ] T \ _ V b 6 B z Ç f 7 6 Ü d B V b ] Ø Ø Ø Ø Ø Ø Ø Ø Ø Ø Ø 4 T c? V X b V ] X V b ] T b T ] ^ ZV U T b c f D N F g L N G I Ý Þ L N ß l F G L H I l M G Ý i L g O P 4 T c? V 9 e 2 V U V W a R S T ^ b V V X V X U V W b ZR c _ 9 : R \ U V W ² T µ Y \ m V b Y ] ] T [ YR _ T ZU f Ø Ø Ø Ø Ø Ø 4 T c? V T R b \ Y \ µ c f 7 6 Ü B V b ] Ø Ø Ø Ø 4 T c? V 9 : R \ U V W m V b B W Z Z 0 Y ] T f Ø Ø Ø Ø Ø Ø 4 T c? V 9 Q R S T U V W a R [ R ` _ YS Y Z Y_ R b U 6 T b S Y ` T Y \ _ a T 9 2 V U V W a R S T _ b R \ c ^ V b _ R _ YV \ _ V R Æ V ² V b a R c ^ R c _ d ] V \ _ a c f Ø Ø Ø Ø Ø Ø 4 T c? V _ b R \ c ^ V b _ R _ YV \ _ V R Æ V ² ² T T \ R b b R \ µ T [ f Ø Ø Ø Ø Ø Ø 4 T c? V 9 ; X 4 T c [ V U V W a R S T R ` V ^ U V X U V W b 2 2 z e d f Ø Ø Ø Ø Ø Ø 4 T c? V 9 2 V U V W a R S T R \ U [ Yc R ² Y Z Y_ YT c _ a R _ Z Y ] Y_ U V W b R ² Y Z Y_ U _ V 9 ; X 4 T c B V b ] Ü Ö Ç b T Û W Y b T [ Ø Ø Ø Ø Ø Ø Ø ^ T b X V b ] U V W b \ V b ] R Z Æ V ² [ W _ YT c f 4 T c? V 9 ; X? 3 z b T Û W Y b T [ Ø Ø Ø Ø Ø Ø Ø 9 3 b T U V W c T ZX z T ] ^ ZV U T [ m V b Y \ µ V \ R ` V ] ] Yc c YV \ V b X R b ] Y \ µ m a Y ` a 9 2 V U V W V ² _ R Y \ m V b _ a b V W µ a R = \ YV \ f Ø Ø Ø Ø Ø Ø 4 T c? V ^ b T S T \ _ c U V W X b V ] c T T Y \ µ m V b V b R ` ` T ^ _ Y \ µ R Æ V ² f 4 T c? V 9 ; X 4 T c? R ] T 8 < V ` R Z? W ] ² T b b T 2 W T c R Y[ f Ø Ø Ø Ø Ø Ø Ø Ø Ø Ø Ø Ø Ø Ø Ø Ø Ø Ø Ø Ø Ø Ø Ø Ø 4 T c? V ; a T b T ² U b T µ Yc _ T b X V b m V b R \ [ X Y ZT \ V _ Y ` T V X W \ T ] ^ ZV U ] T \ _ R \ [ b T Û W T c _ R [ T _ T b ] Y \ R _ YV \ V X ] U ² T \ T X Y_ b Yµ a _ c W \ [ T b 3 b R \ c R c 7 ] ^ ZV U ] T \ _ 6 T ` W b Y_ U < R m Ø ; ` T b _ YX U _ a T Y \ X V b ] R _ YV \ µ YS T \ V \ _ a Yc X V b ] Yc ` V b b T ` _ R \ [ W \ [ T b c _ R \ [ _ a R _ ^ T \ R Z_ YT c R b T ^ b V S Y[ T [ X V b ] R Y \ µ X R Zc T c _ R _ T ] T \ _ c V b X R Y Z Y \ µ _ V [ Yc ` ZV c T ] R _ T b YR Z X R ` _ c Y \ V b [ T b _ V V ² _ R Y \ ² T \ T X Y_ c Ø 6 Yµ \ R _ W b T 8 2 R _ T 8 > 7 à = 3 < ; B 4 ;? Ä «3 Ä T c? V > 7 0 = >? : 1? 0 > 1 < ;? 0 7 > C ; 7 «7 > 6 ;? ; 0 ; 3 < z 3 > Å z Ç d R µ T e V X e > T S Ø d d z Ç B-2

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