Attorney General William P. Barr Honors Department of Justice Employees and Others for the 68th Annual Attorney General’s Awards

Today, Attorney General William P. Barr announced the recipients for the 68th Annual Attorney General’s Awards, recognizing Department of Justice employees and partners for extraordinary contributions to the enforcement of our nation’s laws. This year, 240 DOJ employees received awards, while 27 non-department individuals are also being honored for their work. This year, due to coronavirus restrictions, Attorney General Barr is honoring recipients virtually here.

“I am honored to recognize the recipients of this year’s Attorney General’s Awards, whose tireless work and steadfast dedication have proven critical to enforcing the rule of law and protecting all Americans,” said Attorney General William P. Barr. “Those honored today have demonstrated exceptional efforts and made tremendous personal sacrifices throughout their time working at the Department of Justice, and for that, I am truly thankful.”

The 68th Annual Attorney General’s Awards and recipients are as follows.

The Attorney General’s David Margolis Award for Exceptional Service is the department’s highest award for employee performance. Attorney General Barr recognizes Justice Management Division, Office of the Assistant Attorney General, Assistant Attorney General for Administration, Lee J. Lofthus.

The Attorney General’s Award for Distinguished Service is the department’s second highest award for employee performance; there are thirteen Distinguished Service Awards being awarded today.

The first Distinguished Award is presented to Special Agents Brad S. Brasher, Ryan C. Caudill, Russel R. King, Louisville Field Division, Bureau of Alcohol, Tobacco, Firearms and Explosives, and; Majors Richmond (Kentucky) Police Department William J. O’Donnell and Rodney O. Tudor.

The second Distinguished Award is presented to Section Chief Lynda K. Marshall, Assistant Section Chief Caldwell Harrop, Trial Attorney Timothy S. Longman, and Paralegal Specialist Jessica A. Rodriguez of the Antitrust Division, International Section.

The third Distinguished Award is presented to September 11th Victim Compensation Fund Special Master Rupa Bhattacharyya and Deputy Special Master Stefanie G. Langsam, of the Civil Division.

The fourth Distinguished Award is presented to Deputy Chief, Special Operations Leonard H. LeVine, Jr., Acting Assistant Deputy Chief Adrienne L. Rose, and Trial Attorney Kaitlin J. Sahni Narcotic and Dangerous Drug Section; Trial Attorney Margaret N. O’Malley of the Office of International Affairs, Criminal Division; Assistant U.S. Attorney Christopher C. Myers, Supervisory Paralegal Specialist Debora J. Wilson, Victim/Witness Specialist Dimple A. Smith, Legal Assistant Lori E. Daly of the U.S. Attorney’s Office for the District of North Dakota; Assistant U.S. Attorney Scott M. Kerin of the U.S. Attorney’s Office for the District of Oregon; Special Agent Michael A. Buemi, Miami Division, Drug Enforcement Administration; Special Agent Steven J. Gilpin, North Dakota Bureau of Criminal Investigations, and; Special Agents Guy Gino, Alexis J. Gregory, and Jeremy L. Grube, Homeland Security Investigations, U.S. Immigration and Customs Enforcement, U.S. Department of Homeland Security.

The fifth Distinguished Award is presented to Deputy Chief Keith A. Becker and Trial Attorneys Ralph A. Paradiso and Lisa Marie Freitas, Child Exploitation and Obscenity Section, Criminal Division; Senior Trial Attorneys Judith H. Friedman and Lynn C. Holliday, Office of International Affairs, Criminal Division; Deputy Chief Michael J. Stawasz, Senior Counsels Jared S. Hosid and Nathan P. Judish, Computer Crime and Intellectual Property Section, Criminal Division; Assistant U.S. Attorneys Kristi N. O’Malley and Thomas M. Sullivan of the U.S. Attorney’s Office for the District of Maryland; Supervisory Special Agents J. Brooke Donahue and P. Michael Gordon, Criminal Investigative Division, FBI; Supervisory Agent Steven A. Smith, Jr., Cyber Division, FBI, and; Supervisory Special Agent Daniel E. O’Donnell, Critical Incident Response Group, FBI.  

The sixth Distinguished Award is presented to Special Litigation Counsel Julia K. Gegenheimer, Trial Attorney Patricia A. Sumner, Supervisory Paralegal Specialist Kimberly N. Lawrence, Criminal Section, Civil Rights Division; Assistant U.S. Attorney Mack E. Jenkins and Paralegal Specialist Adriana Abalos of the U.S. Attorney’s Office for the Central District of California; Supervisory Special Agent Randy R. Gonzalez, Criminal Investigative Division, FBI; Supervisory Special Agent Ramon C. Johnson, New York Field Office, FBI; and Special Agents Caroline A. Walling and Michael Richard Ramsey, Los Angeles Field Office, FBI.

The seventh Distinguished Award is presented to Section Chief Lisa Lynne Russell, Principal Deputy Chief James D. Gette, Assistant Section Chief Guillermo A. Montero, Senior Litigation Counsel Frank J. Singer, Senior Attorney Marissa A. Piropato, Trial Attorneys Sean C. Duffy, Clare M. Boronow, and Erika D. Norman, Natural Resources Section, Environment and Natural Resources Division, and; Principal Deputy Chief Andrew C. Mergen, and Trial Attorneys Robert J. Lundman and Sommer H. Engels, Appellate Section, Environment and Natural Resources Division.

The eighth Distinguished Award is presented to Assistant U.S. Attorneys Celia V. Cohen, Scott A. Hartman, Jaqueline C. Kelly, Alexandra N. Rothman, and Hagan Scotten, Special Agent John J. Carillo, and Paralegal Specialist Shannon N. Becker of the U.S. Attorney’s Office for the Southern District of New York; Special Agents Christopher J. MungerElizabeth Nygaard, Theodore J. Otto III, and Cindy A. Peil, New York Field Office, FBI; Supervisory Special Agent Luigi Mondini, Chicago Division, FBI; Detective Darrell J. Julien and Task Force Officer William E. Dionne, New York City Police Department.

The ninth Distinguished Award is presented to Assistant U.S. Attorneys David G. Lazarus, Susan M. Poswistilo, Mark T. Quinlivan, Amanda P.M. Strachan, Fred M. Wyshak, Jr., K. Nathaniel Yeager, Victim Assistance Specialist Jessica M. Pooler, and Litigation Technology Specialist Helen R. Bower of the U.S. Attorney’s Office for District of Massachusetts; Special Agents Vivian M. Barrios, Paul S. Baumrind, Staff Operations Specialist Stacey Schlender, and Forensic Accountant Bridget Horan, Boston Field Office, FBI; Special Agent Sharon L. Moorefield, Office of Criminal Investigations, U.S. Food and Drug AdministrationSpecial Agent Scott T. Wisnaskas, Office of Inspector General, U.S. Department of Health and Human Services, and; Senior Investigator Christine M. Tang, Employee Benefits Security Administration, U.S. Department of Labor.

The tenth Distinguished Award is presented to Supervisory Attorney-Advisors Alan M. Fisher and Sean S. Park, Office of Intelligence, National Security Division; Trial Attorney Adam L. Small, Counterintelligence and Export Control Section, National Security Division; Assistant U.S. Attorney William N. Hammerstrom, Jr. of the U.S. Attorney’s Office for the Eastern District of Virginia; Supervisory Special Agent Ryan C. Gaynor and Special Agents Christine A. Botz and Christina M. Sun, Washington Field Office, FBI.

The eleventh Distinguished Award is presented to Special Counsel Paul P. Colborn and Attorney-Advisors Kevin J. Barber, Christine M. Buzzard, Nathan A. Forrester, Jared M. Kelson, David K. Suska, Ryan N. Watzel, Office of Legal Counsel.

The twelfth Distinguished Award is presented to Pro Bono Program Manager Laura F. Klein, Professional Responsibility Advisory Office.

The thirteenth Distinguished Award is presented to Chief Senior Litigation Counsel Dennis M. Donohue and Senior Litigation Counsel Kari Madrene Larson, Office of Civil Litigation, Tax Division; Senior Litigation Counsel Judith A. Hagley, Appellate Section, Tax Division; Trial Attorneys Matthew S. Johnshoy, Gregory L. Jones and Harris J. Phillips, Civil Trial Section, Tax Division, and; Assistant U.S. Attorney William E. Farrior of the U.S. Attorney’s Office for the Western District of Oklahoma.

The Attorney General’s Award for Excellence in Law Enforcement recognizes outstanding professional achievements by law enforcement officers of the Department of Justice. This year, one Excellence in Law Enforcement Award is presented to Supervisory Special Agent Clifford R. Swindell, Special Agent Kevin W. McDonald, Baltimore Field Office, FBI; Task Force Officers Joseph Landsman, Jeffrey Lilly, Mark Neptune, Baltimore Police Department, and; Task Force Officer Daniel DeLorenzo, Anne Arundel County (Maryland) Police Department.

The Attorney General’s Award for Exceptional Service in Indian Country recognizes extraordinary efforts by those who demonstrated the department’s commitment to fighting crime in Indian Country. This year, two Exceptional Service in Indian Country Awards are being presented.

The first Exceptional Service in Indian Country is presented to Assistant U.S. Attorneys Jeffrey K. Starnes, Lori Harper Suek, Paralegal Tammy M. Farris, and Victim/Witness Specialist Keri B. Leggett of the U.S. Attorney’s Office for the District of Montana; Assistant U.S. Attorneys Sarah B. Collins and Eric Kelderman and Paralegal Lori E. Climis of the U.S. Attorney’s Office for the District of South Dakota; Special Agent Fred Bennett, Office of Justice Services, Bureau of Indian AffairsSpecial Agent in Charge Curt L. Muller, Assistant Special Agent in Charge Anissa D. Andrews, Special Agents Justin C. Christman and Justin W. Reedy, Office of Inspector General, U.S. Department of Health and Human Services, and; Police Officers Frank Goings, Charlie Wolftail, and Sarah Wolftail, Blackfeet Law Enforcement Agency.

The second Exceptional Service in Indian Country is presented to Special Agent Elizabeth A. Green, San Francisco Field Office, FBI; Special Agents Aaron D. Christensen, Larry J. McGrail II, Victim Specialist Michele L. Stewart, and Evidence Technician Susan L. Stephenson, Salt Lake City Division, FBI; Assistant U.S. Attorney Lori HarperSuek of the U.S. Attorney’s Office for the District of Montana, and; Special Agent John J. Grinsell, Bureau of Indian Affairs, U.S. Department of the Interior.

The Attorney General’s Award for Excellence in Management recognizes outstanding administrative or managerial achievements, which have significantly improved operations, productivity, or reduced costs. This year, two Excellence in Management Awards are being presented.

The first Award for Excellence in Management is presented to Assistant U.S. Attorney Mary E. Toscano of the U.S. Attorney’s Office for District of New Jersey.

The second Award for Excellence in Management is presented to Deputy Assistant Inspector General Allison E. Russo, Evaluation and Inspections Division, Office of the Inspector General, and; Assistant Regional Audit Manager Elizabeth M. Smith, Auditors Gerardo Cartagena and Jessica M. Rivera, and Program Manager Jessica R. Brower, Audit Division, Office of the Inspector General.

The Attorney General’s Award for Excellence in Information Technology recognizes outstanding achievements in applying information technology to improve operations and productivity, reduce or avoid costs, and solve problems. One Excellence in Information Technology Award is presented to Supervisory Information Technology Specialists George A. Cramer, Omar S. Khan, Anmy D. Torres Lawrence P. Packard, Information Technology Specialists Dee A. Alkire, Natasha Gibson, Christopher M. Greer, Connie LaSalle, Darrell L. Lyons, Matthew K. Phillips, Eliot E. Schmidt, James W. Schreiner, Benjamin L. Schwarten, Jun B. Yun, Office of the Chief Information Officer, and; Supervisory Security Specialist Robert L. Mack II, Security and Emergency Planning Staff, Justice Management Division.

The Attorney General’s Award for Excellence in Furthering the Interests of U.S. National Security recognizes outstanding achievements and contributions towards protecting U.S. National Security. One Excellence in Furthering the Interests of U.S. National Security Award is presented to Supervisory Attorney-Advisors Tyrone A. Brown and Loyaan A. Egal, Foreign Investment Review Section, National Security Division.

The Attorney General’s Award for Equal Employment Opportunity is the department’s highest award for performance in support of the Equal Employment Opportunity Program. One Equal Employment Opportunity Award is presented to Senior Trial Attorney Liza Zamd and Trial Attorney Stacey I. Young, Immigrant and Employee Rights Section, Civil Rights Division; Trial Attorney Eliza P. B. Dermody, Disability Rights Section, Civil Rights Division; Trial Attorney Colleen M. Phillips, Educational Opportunities Section, Civil Rights Section; Senior Trial Attorney Patricia L. Stasco, Employment Litigation Section, Civil Rights Division; Trial Attorney Melanie Krebs-Pilotti, International Section, Antitrust Division; Trial Attorney Patricia L. Sindel, Technology and Financial Services Section, Antitrust Division; Trial Attorney Danielle Wolfson Young, Federal Programs, Civil Division; Trial Attorneys Lindsay C. Dunn, Allison Frayer, Stefanie Notarino Hennes, Office of Immigration Litigation, Appellate Section, Civil Division; Assistant Director Marc R. Salans, Office of Attorney Recruitment and Management, Justice Management Division, and; Supervisory Attorney-Advisor Shana N. Eaton, Office of Intelligence, National Security Division.

The Attorney General’s Award for Excellence in Legal Support recognizes outstanding achievements in the field of legal support to attorneys by paralegal specialists and other legal assistants.  Three Excellence in Legal Support Awards are presented this year.

The first Excellence in Legal Support Award in the paralegal category is presented to Paralegal Specialist Minnie V. Becton, Environmental Enforcement Section, Environment and Natural Resources Division.

The second Excellence in Legal Support Award in the paralegal category is presented to Supervisory Paralegal Specialist Christina J. Griffiths of the U.S. Attorney’s Office for the Middle District of Florida.

The third Excellence in Legal Support Award in the legal support category is presented to Legal Assistant Jennifer L. Goldbetter, Environmental Enforcement Section, Environment and Natural Resources Division.

The Attorney General’s Award for Excellence in Administrative Support recognizes outstanding performance in administrative or managerial support by administrative employees or secretaries. Two Excellence in Administrative Support Awards are being presented.

The first Excellence in Administrative Support Award in the Administrative category is presented to Administrative Officer Elaine A. Thompson, Atlanta Regional Office, U.S. Trustee Program.

The second Excellence in Administrative Support Award in the Secretarial category is presented to Warden’s Secretary Rodell T. Fletcher, Federal Correctional Institution – Edgefield, SC Federal Bureau of Prisons.

The John Marshall Awards are the department’s highest awards offered to attorneys, which recognizes attorneys for their contributions and excellence in specialized areas of legal performance. Thirteen awards in nine categories are being presented this year.

The first John Marshall Award in the Trial of Litigation category is presented to Assistant U.S. Attorneys David D. Leshner, Todd W. Robinson, U.S. Attorney’s Office for the Southern District of California.

The second John Marshall Award also in the Trial of Litigation category is presented to Trial Attorney Richard M. Rolwing, Northern Criminal Enforcement Section, Tax Division, and; Senior Litigation Counsel John E. Sullivan and Trial Attorneys Leslie A. Goemaat and Arthur J. Ewenczyk, Western Criminal Enforcement Section, Tax Division.

The third John Marshall Award in the Participation in Litigation category is presented to Assistant Section Chiefs Lisa A. Scanlon and Yvette F. Tarlov and Trial Attorneys Meagan K. Bellshaw, Lee F. Berger, Mona S.K. Haar, Sarah H. Licht, Craig D. Minerva, Media, Entertainment, and Professional Services Section, Antitrust Division.

The fourth John Marshall Award also in the Participation in Litigation category is presented to Associate Director Christopher J. Smith and Trial Attorney Rebecca A. Haciski, Office of International Affairs, Criminal Division, and; Assistant U.S. Attorney Robert J. Emery, U.S. Attorney’s Office for the Southern District of Florida.

The fifth John Marshall Award in the Support of Litigation category is presented to Senior Counsel Wendy R. Waldron, Computer Crime and Intellectual Property Section, Criminal Division; Criminal Division Deputy Chief Sarah M. Kauke and Trial Attorney Molly S. Braese, Office of Enforcement Operations, Criminal Division; Assistant U.S. Attorney Amy E. Larson of the U.S. Attorney’s Office for the District of Columbia; Assistant General Counsel Christopher G. Bubb, Office of the General Counsel, FBI, and; Trial Attorney Jennifer Kennedy Gellie, Counterintelligence and Export Control Section, National Security Division.

The sixth John Marshall Award also in the Support of Litigation category is presented to Assistant U.S. Attorney Hollie W. Reed of the U.S. Attorney’s Office for the Middle District of Alabama.

The seventh John Marshall Award in the Handling of Appeals category is presented to Trial Attorney John M. Pellettieri, Appellate Section, Criminal Division.

The eighth John Marshall Award in the Providing Legal Advice category is presented to Appellate Litigation Counsel Mark B. Stern and Trial Attorneys Daniel Aguilar and Joshua M. Salzman, Appellate Staff, Civil Division.

The ninth John Marshall Award also in the Providing Legal Advice category is presented to Assistant U.S. Attorney Herbert L. Bunton III of the U.S. Attorney’s Office for the Western District of Texas.

The tenth John Marshall Award in the Preparation or Handling of Legislation category is presented to General Counsel Rafael A. Madan, Office of the General Counsel, Office of Justice Programs.

The eleventh John Marshall Award in the Preparation of Asset Forfeiture category is presented to Assistant U.S. Attorneys Jonathan S. Galatzan, Michael R. Sew Hoy, John J. Kucera, Poonam G. Kumar, and Steven R. Welk, U.S. Attorney’s Office for the Central District of California; Assistant U.S. Attorney Andrea Duvall, U.S. Attorney’s Office for the District of ColumbiaAssistant U.S. Attorney Christopher Cardani, U.S. Attorney’s Office for the District of Oregon; Associate Director Jeffrey M. Olson, Senior Trial Attorney Colette L. Ford, Trial Attorney Erin E. Mikita, Office of International Affairs, Criminal Division, and; Deputy Chief, International Unit Mary K. Butler, Deputy Chief Woo S. Lee, Senior Trial Attorney Jonathan T. Baum, Trial Attorneys Barbara Yu. Levy and Joshua L. Sohn, Money Laundering and Asset Recovery Section, Criminal Division.

The twelfth John Marshall Award in the Preparation of Alternative Dispute Resolution category is presented to Acting Chief John R. Read, Trial Attorneys Thomas P. DeMatteoJames K. Foster, Catherine S. Montezuma, Samer M. MusallamBlake W. Rushforth, Lowell R. Stern, Angela Y. Ting, and Bashiri B. Wilson, Defense, Industrials, and Aerospace Section, Antitrust Division, and; Trial Attorneys William H. Jones II and Ethan D. Stevenson, Media, Entertainment, and Professional Services Section, Antitrust Division.

The thirteenth John Marshall Award in the Interagency Cooperation category is presented to Senior Assistant Regional Counsel D. Henry Elsen, Region 8 – Montana Operations Office, U.S. Environmental Protection Agency.

The Claudia J. Flynn Award for Professional Responsibility recognizes department attorneys who have made significant contributions in the area of professional responsibility by successfully handling a sensitive and challenging professional responsibility issue in an exemplary fashion and/or leading efforts to ensure that department attorneys carry out their duties in accordance with the rules of professional conduct. This year’s Claudia J. Flynn Award is presented to Senior Legal Advisor Patrice M. Mulkern, Professional Responsibility Advisory Office; Assistant U.S. Attorney Francis M. Hamilton III, U.S. Attorney’s Office for the Eastern District of Tennessee; Assistant U.S. Attorney Cecil VanDevender, U.S. Attorney’s Office for the Middle District of Tennessee, and; Assistant U.S. Attorney Tony R. Arvin, U.S. Attorney’s Office for the Western District of Tennessee.

The Attorney General’s Award for Fraud Prevention recognizes exceptional dedication and effort to prevent, investigate, and prosecute fraud, white-collar crimes, and official corruption. This year’s Fraud Prevention Award is presented to Trial Attorneys Joshua D. Rothman and Philip M. Toomajian, Investigator Luke M. Shoemaker, Consumer Protection Branch, Civil Division; Senior Trial Attorney John A. Beasley, Jr., Office of International Affairs, Criminal Division; Assistant U.S. Attorneys Luis M. Perez, Kimberly A. Selmore, Paralegal Specialist Maureen Booker, U.S. Attorney’s Office for the Southern District of Florida, and; Postal Inspectors Bryan Masmela and Luis F. Soler, Miami Division, U.S. Postal Inspection Service.

The Attorney General’s Award for Outstanding Contributions to Community Partnerships for Public Safety recognizes outstanding achievement in the development and support of community partnerships designed to address public safety within a community. Two Outstanding Contributions to Community Partnerships for Public Safety Awards are being presented this year.

The first Outstanding Contributions to Community Partnerships for Public Safety is presented to Special Agent Michael C. Coad, Tampa Field Division, Bureau of Alcohol, Tobacco, Firearms and Explosives.

The second Outstanding Contributions to Community Partnerships for Public Safety is presented to Counsel Amy M. Markopoulos, Health Care Fraud Unit, Fraud Section, Criminal Division.

The Cubby Dorsey Award for Outstanding Service by a Wage Grade System Employee recognizes extraordinary performance and contributions by wage grade system employees, including laborers, mechanics, and skilled craft workers. One Cubby Dorsey Award for Outstanding Service by a Federal Wage Grade System Employee is presented to, Utility System Repairer – Operator Leader Allen B. Hudson, Finance and Facilities Division, FBI.

The Attorney General’s Award for Outstanding Contributions by a New Employee recognizes exceptional performance and notable accomplishments towards the department’s mission by an employee with fewer than five years of federal career service. The Attorney General’s Award for Outstanding Contributions by a New Employee is presented to Trial Attorney Julie A. Finocchiaro, Organized Crime and Gang Section, Criminal Division.

The Edward H. Levi Award for Outstanding Professionalism and Exemplary Integrity pays tribute to the memory and achievements of former Attorney General Edward H. Levi. This award is presented to an individual whose career as an attorney, law professor and dean, and public servant exemplified these qualities in the best traditions of the Department. This year’s Edward H. Levi Award is presented to Deputy Assistant Attorney General Kevin R. Jones, Office of Legal Policy.

The Attorney General’s Award for Meritorious Public Service, the top public service award granted by the department, recognizes the most significant contributions of citizens and organizations that have assisted the department in the accomplishment of its mission and objectives. Two Meritorious Public Service Awards are being presented this year.

The first Award for Meritorious Public Service is presented to, Phoenix 11, a group of 11 survivors whose child sexual abuse was recorded, and in the majority of cases, distributed online. This group has banded together to challenge the inadequate responses to the prevalence of child sexual abuse images on the internet.

The second Award for Meritorious Public Service is presented to the Middle East Media Research Institute and its President and Founder, Yigal Carmon.

The last award presented this year is the Mary C. Lawton Lifetime Service Award, which recognizes employees who have served at least 20 years in the department and who have demonstrated high standards of excellence and dedication throughout their careers. This award is presented only in exceptional circumstances to those individuals of special merit and is not awarded to express general appreciation for tenure alone. This year’s the Mary C. Lawton Award is presented to Supervisory Criminal Investigator Daniel P. Wertheimer, Investigative Operations Division, U.S. Marshals Service.

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    In U.S GAO News
    GAO identified 59 for-profit college conversions that occurred from January 2011 through August 2020, almost all of which involved the college's sale to a tax-exempt organization. In about one-third of the conversions, GAO found that former owners or other officials were insiders to the conversion—for example, by creating the tax-exempt organization that purchased the college or retaining the presidency of the college after its sale (see figure). While leadership continuity can benefit a college, insider involvement in a conversion poses a risk that insiders may improperly benefit—for example, by influencing the tax-exempt purchaser to pay more for the college than it is worth. Once a conversion has ended a college's for-profit ownership and transferred ownership to an organization the Internal Revenue Service (IRS) recognizes as tax-exempt, the college must seek Department of Education (Education) approval to participate in federal student aid programs as a nonprofit college. Since January 2011, Education has approved 35 colleges as nonprofit colleges and denied two; nine are under review and 13 closed prior to Education reaching a decision. Figure: Example of a For-Profit College Conversion with Officials in Insider Roles IRS guidance directs staff to closely scrutinize whether significant transactions with insiders reported by an applicant for tax-exempt status will exceed fair-market value and improperly benefit insiders. If an application contains insufficient information to make that assessment, guidance says that staff may need to request additional information. In two of 11 planned or final conversions involving insiders that were disclosed in an application, GAO found that IRS approved the application without certain information, such as the college's planned purchase price or an appraisal report estimating the college's value. Without such information, IRS staff could not assess whether the price was inflated to improperly benefit insiders, which would be grounds to deny the application. If IRS staff do not consistently apply guidance, they may miss indications of improper benefit. Education has strengthened its reviews of for-profit college applications for nonprofit status, but it does not monitor newly converted colleges to assess ongoing risk of improper benefit. In two of three cases GAO reviewed in depth, college financial statements disclosed transactions with insiders that could indicate the risk of improper benefit. Education officials agreed that they could assess this risk through its audited financial statement review process and could develop procedures to do so. Until Education develops and implements such procedures for new conversions, potential improper benefit may go undetected. A for-profit college may convert to nonprofit status for a variety of reasons, such as wanting to align its status and mission. However, in some cases, former owners or other insiders could improperly benefit from the conversion, which is impermissible under the Internal Revenue Code and Higher Education Act of 1965, as amended. GAO was asked to examine for-profit college conversions. This report reviews what is known about insider involvement in conversions and to what extent IRS and Education identify and respond to the risk of improper benefit. GAO identified converted for-profit colleges and reviewed their public IRS filings. GAO also examined IRS and Education processes for overseeing conversions, interviewed agency officials, and reviewed federal laws, regulations and agency guidance. GAO selected five case study colleges based on certain risk factors, obtained information from college officials, and reviewed their audited financial statements. In three cases, GAO also reviewed Education case files. Because of the focus on IRS and Education oversight, GAO did not audit any college in this review to determine whether its conversion improperly benefitted insiders. GAO is making three recommendations, including that IRS assess and improve conversion application reviews and that Education develop and implement procedures to monitor newly converted colleges. IRS said it will assess its review process and will evaluate GAO's other recommendation, as discussed in the report. Education agreed with GAO's recommendation. For more information, contact Melissa Emrey-Arras at (617) 788-0534 or emreyarrasm@gao.gov.
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