Prison Privatisation Report International
No. 73, July
06
Published by the Public Services International Research Unit (PSIRU)
www.psiru.org/justice
This publication is supported by a grant from the Foundation Open
Society Institute.
IN THIS ISSUE
ISRAEL UNITED STATES UNITED KINGDOM POLAND BELIZE AUSTRALIA ICPA AND THE PRIVATE SECTOR
Supreme court update
The
supreme court hearing into whether
Meanwhile,
it has emerged that Paul Doucette, vice president of the Association of Private
Corrections and Treatment Organisations in the US (APCTO, see below and PPRI #62,56, 54, etc) is managing US
firm Emerald Correctional Management’s involvement in the consortium formed to
finance, design, build and run the
proposed 800 bed prison at Be’er Sheva.
Writing
in TheMarker,
Missing
from Mr Doucette’s description of
Prison
companies on the campaign trail
During
the 2002 and 2004 election cycles, companies involved in private prisons and
those affiliated with them contributed $3.3 million to candidates and state
political parties, a new report has found.
According
to the National Institute of State Money in Politics, while the companies and
their officials were working the halls of state capitols to advocate their
policy positions, “they also were opening their cheque books during campaign
season.”
The
report found that, “all told, the companies, their executives, directors and
lobbyists gave $3.3 million in 44 states between 2000 and 2004 - a figure that includes contributions from
not only private-prison firms, but also the investment and construction
companies, food service providers, health-care management and counselling
services that do business with them.”
A
closer look at their contributions shows a targeted strategy of giving to
candidates most likely to affect the laws and budgets related to corrections,
with large portions of their contributions going to winning candidates and
those already in office and not up for re-election. The companies also focused
much of their giving on legislative candidates, who approve laws and budgets
governing corrections in their states.
Private-prison
interests tended to pick winners, as well as maintain their relationship with
incumbents. Nearly $1.8 million of the $2.2 million that private prison
interests gave to candidates went to winners or to officer holders who were not
running but were raising money for upcoming campaigns.
Winners
alone received 65 percent of the industry’s contributions, compared with the 12
percent losing candidates received. Incumbent office holders who were not
running but were raising money for the next election accounted for another 17
percent of the money private-prison interests gave.
Companies
favoured states with some of the toughest sentencing laws, particularly those
that had enacted legislation to lengthen the sentence given to any offender who
was convicted of a felony for the third time. Private-prison interests gave
almost $2.1 million in 22 states that had a so-called ‘three-strikes
law,’ compared with $1.2 million in 22 states that did not.
The
authors’ analysis of campaign contributions made to state-level candidates and
political parties also reveals that private-prison interests:
●
gave two-thirds of their money to candidates, who received nearly $2.2 million
during the study period. The remainder went to state-level political party
committees;
●
favoured incumbents, both those seeking re-election and those not up for
election but raising money for future campaigns. These incumbents received $1.6
million of the $2.2 million given to candidates, while those challenging a
seated incumbent received about one-tenth of that amount, at $167,250.
Candidates vying for an open seat received $410,830;
●
backed winners, giving 65 percent of the candidate contributions to winning
candidates;
●
concentrated their giving on legislative candidates who, if elected, act on
state budgets and sentencing laws. These candidates received almost half of the
money given to candidates - slightly more than $1 million;
●
gave heavily to gubernatorial candidates, who propose budgets and set policy
directions and also have the authority to veto laws passed by the legislature.
About $873,300 of the candidate money went to gubernatorial candidates, who
have the power to suggest and to support privatization as a way of keeping
their states’ budgets in balance;
●
favoured Republicans, giving 64 percent of the industry’s $3.3 million to
Republican candidates and Republican Party committees.
Companies
themselves and the lobbyists they hired gave the biggest portions of the funds.
The companies gave almost $1.6 million, or 48 percent of the total. Lobbyists
gave nearly $1.1 million, or 33 percent. The remainder came from company
officials, members of the companies’ boards of directors, construction
companies that work on prison projects and firms that subcontract to provide
services to private prisons.
Lobbyists
hired by the private-prison industry were the top contributors in 10 states,
and the only source of private-prison money in another seven states.
As
part of its analysis of private-prison giving, the Institute looked at
corrections legislation and budgets in 10 states where contributions were
highest or where legislators introduced measures of interest, such as changes
to private-prison contracting procedures, private-prison oversight or
sentencing laws.
Some
states have recently begun re-examining their corrections policies as
overcrowding and high costs continue.
Lawmakers
looked at a wide variety of proposals, some of which would have benefited
private prisons and others that would have shifted state funds away from them.
While the success or failure of the measures can’t be definitively linked to
campaign contributions, the companies and their associates typically targeted
their contributions to winners and incumbents, to be as effective as possible
in supporting their agenda. For example:
●
in Florida, when the prospect of re-opening bids for the operation of five
private prisons surfaced, private-prison vendors lobbied successfully for the
elimination of the commission overseeing the bidding process;
●
in
●
●
legislators with that attitude. The industry gave generously to powerful,
well-established legislative leaders and members of committees hearing measures
affecting sentencing;
●
in
ways to turn government services over to the private sector. Within months,
food and nursing services in state prisons were handed over to the private
companies, and the state contracted for the first private prison in the state.
●
After taking office, Mississippi Governor Haley
Barbour emphasised private prisons as a way of saving money.
The companies
involved
Over the years, key leaders in the arena of
prison privatisation have emerged. The Project focused on the seven largest
firms in the private-prison industry. Institute staff added four other
companies whose names appeared in contribution records. Following is a summary
of each of the companies included in this report:
● Corrections
Corporation of America (CCA) - Headquartered in
● GEO
Group, Inc. - Formerly a unit of Wackenhut Corp.
and known as Wackenhut Corrections, GEO Group is
headquartered in
● Community
Corrections Corp. - Headquartered in
● Cornell
Companies Inc. - Headquartered in
● Correctional
Services Corp. (CSC) -
Acquired by GEO Group in July 2005, CSC was originally
headquartered in
● CiviGenics - Headquartered in Marlborough, Massachusettes,
CiviGenics operates 13
facilities that house more than 3,000 prisoners in 14 states. Contributions
from CiviGenics, its executives, directors and
lobbyists totaled $82,259 in four states.
● Management
and Training Corp. (MTC) - Headquartered in
● Avalon
Correctional Services of
Policy Lockdown: Prison
Interests Court Political Players, National Institute On
State Money In Politics, April 2006, www.followthemoney.org
APCTO moves on
The
Association of Private Correctional & Treatment Organisations (APCTO), the
US private corrections industry’s trade association and lobby group, has moved
its headquarters to Washington DC to enhance its role in promoting the
industry’s interests (see PPRI #62, 56, 54, 45, 44, etc).
The
organisation has also appointed former Cornell Companies Inc. vice president
Paul Doucette as its executive director. Under his leadership APCTO will focus
on:
* increasing federal opportunities for
public-private correctional partnerships;
* continuing to provide media, public policy
think-tanks and legislators with APCTO’s key
messages;
* working with the Congressional
Privatisation Caucus;
*co-ordinating joint member efforts on state
legislative issues; and
*increasing APCTO’s
membership.
APCTO
has stepped up its media monitoring and is playing an increasingly pro-active
role. It has completed an updated press kit promoting its key arguments of cost
savings, providing quality services and increased levels of accountability. Its
newsletters report that the organisation “monitors the print and electronic
media, seeking to inject APCTO key messages into the public debate on private
corrections.”
APCTO’s website also currently includes ‘leading research and issues papers’
which draws heavily from material produced by APCTO and the industry or free
market think tanks that promote privatisation. Of the 13 listed items three are
by Geoffrey Segal, the Reason Foundation’s director of government reform; one
is by Adrian Moore of the Reason Public Policy Institute; one is by the free
market Washington Policy Center; two studies were
commissioned by APCTO; one is a paper by a Corrections Corporation of America
executive (which in turn, relies on much of the material contained in the APCTO
list); one was co-authored by a former Cornell Companies executive and
published by the company in 1998; and one was produced by equity analysts at
Morgan Lewis Githens & Ahn.
June 2005:
101,228 in private prisons
Privately
operated prison facilities held 101,228 prisoners or 6.7% of the total prison
population as at
US Department of Justice,
Bureau of Justice Statistics Bulletin, Prison and Jail Inmates at Midyear 2005,
published May 2006,
www. ojp.usdoj.gov/bjs/abstract/pjim05.htm
■ See also Sexual Violence
Reported by Correctional Authorities, 2005. The Bureau of Justice
Statistics report published in July 2006 contains figures for public and
private prisons.
CCA penalised but stock
still hot
Corrections
Corporation of America (CCA) has been penalised $126,000 by the State of
■
CCA runs 63 prison facilities in 19 states and
Youth Services International’s
legal settlement
The US department of justice
and Youth Services International (YSI, see PPRI
# 70, 69, 62, 61, 58, 55, 45-42, etc) have resolved a lawsuit against the
company arising from alleged failures to provide services to a deaf youth in
the company’s care.
In 2004 Youth Services
International (YSI) paid an undisclosed civil
penalty, compensation for damages and equitable relief to the US and co-damages
to the complainant as a result of the
company’s failure to provide specific services to a deaf resident in their care
at the Victor Cullen Center, Maryland, between 1999
and 2000.
Between 29 August and
However, under a new
settlement dated
At the time of the original
complaint and lawsuit YSI was owned by Correctional Services Corporation (CSC).
In November 2005 CSC was acquired by The GEO Group but YSI was immediately sold
on to JFS Development LLC, controlled by James Slattery the former chief
executive officer of CSC.
Both settlement agreements can be found at www.ada.gov/ysi2sa.htm
Carter Goble: The first 31 years
Carter Goble is a company that has played a major role in
US and international prison expansion - both public and private - and it
celebrates “31 years of service” in October 2006 (see PPRI #72/71, 60 & 48).
Now known as Carter Goble Lee, the Columbia, South
Carolina-based group of companies offers what it calls “A World of Solutions”
including: planning; programme management; facility
engineering and maintenance; and architectural design. The CGL companies
include Carter Goble Lee, LLC; Carter Goble Associates Inc; CGL Engineering
Inc; and CGA Facilities Services Inc. In 2002 the American Correctional
Association’s magazine Corrections Today described
the creation of Carter Goble Lee as the merging of “two of the nation’s
foremost organisations in planning and maintaining
criminal justice facilities.”
In the 1990s the then Copenhagen-based Group 4 (as was)
described Carter Goble as its “associated correctional consultancy company” and
had a minority stock holding in Carter Goble. Stephen Carter was, for some
years, a director of Group 4 companies in the
CGL’s website lists
examples of its “representative prison experience” which includes 86 prison
projects for justice agencies in 27 states and the
In October 2002 the company produced a ten-year adult
corrections master plan for the State of Alabama focusing on the “system’s
facility needs from 2003 to 2012.” In
Georgia CGL Engineering provides comprehensive facility management services for
25 department of juvenile justice facilities. In
Hawaii CGL recently updated the State’s 10 -Year Corrections Master Plan that
was originally completed by the company in 1991. The company recommended five
new facilities and four expansions by 2008 and two expansions and three new
facilities as well as three replacement facilities between 2008 and 2013.
The company’s work abroad has included projects in
In 1993 the company developed a strategy for “replacing and
expanding existing prisons to serve the Israeli criminal population.”
Its involvement in private prison projects includes: Junee Correctional Centre in Australia; New Zealand’s
Auckland Remand Centre; a comprehensive prisons system assessment, privatisation feasibility analysis and strategic
development plan for the government of Peru (see PPRI # 72/71); facility
programming site development and concept designs for two maximum security adult
correctional institutions in South Africa ; and The Wolds and Altcourse prisons in
England.
Carter
Goble Lee, www.cartergoblelee.com
Boost for
private sector
The
private sector is expected to “take the lead” as 8,000 new prison places are built
in
Education
inadequate
“The
overall effectiveness of the provision is inadequate,” stated inspectors from
the UK’s Adult Learning Inspectorate in their report on G4S- run Parc prison in Wales (see PPRI # 65-63, 60, 56, 48, 44-42, etc).
“The
prison’s leadership and management are inadequate, as is its approach to
equality of opportunity and quality improvement. Training is satisfactory in
health, public services and care, ICT, leisure, travel and tourism and arts, media
and publishing. Training in engineering and manufacturing technologies and
preparation for life and work is inadequate.”
Although
the inspection team “had some confidence in the reliability of the
self-assessment process” they noted that the first self-assessment report in
December 2005 “does not effectively use data to support judgements” and that
“there is insufficient textual evidence to support the [identified] strengths
and weaknesses.”
The
prison was first inspected by the ALI in September 2002 and re-inspected in
September 2004. Inspectors “judged provision to be inadequate to meet the
reasonable needs of those receiving it at both inspections.” In May 2005 the
prison operator took over responsibility for all education and training from a
local college subcontractor.
However
“the provider has demonstrated that it has sufficient capacity to make
improvements” and following the previous inspection “the prison has made
progress in introducing a range of strategies to improve the quality of
provision.”
The
ALI has a grading system ranging from grade 1 – outstanding to grade 4
–inadequate. Parc’s overall effectiveness was grade
4.
■
Other recent reports on private prisons published by
the Adult Learning Inspectorate (ALI) this year include
The
inspectors found that “some areas of learning have insufficient staff.
Preparation for life and work is operating with two staff vacancies in
significant areas of the provision. Construction has been without a bricklayer
for a considerable length of time, although an appointment has very recently
been made. All areas of learning have insufficient staff to provide cover
arrangements for long- or short-term absence. Contingency arrangements are only
sufficient for short-term cover.”
They
also reported that: “insufficient
vocational, work and education programmes are provided to meet the needs of all
offenders. Literacy and numeracy programmes are not
supported above level 2, and the programmes offered have waiting lists. The
range of arts and ICT programmes available is narrow. Catering learners who
work in the main kitchen do not have the opportunity to work towards an NVQ
that learners in the vocational training kitchen enjoy.”
The
inspectors identified
•
introduce more work with accredited training;
• further develop the range of courses and progression
opportunities for learners;
•
ensure regular reinforcement of health and safety;
• further develop literacy, numeracy,
language and key skills training across the provision;
•
implement actions to deal with insufficient staffing;
•
maintain and further improve the good standard of teaching and learning;
• further improve accommodation and learning environments;
A
report on GSL-run Altcourse (see PPRI
#69, 36, 35, etc) was published in April 2006. Previously inspected in February
2005, the inspectors noted that: “leadership and management, equality of
opportunity and its arrangements for quality assurance were satisfactory.
Training was good in information and communications technology and satisfactory
in engineering, technology and manufacturing, retailing, customer service and
transportation, and visual and performing arts and media. In hospitality,
sport, leisure and travel, and foundation programmes, the quality of training
was unsatisfactory. At the end of the reinspection
process, the quality of training in hospitality, sport, leisure and travel is
satisfactory and in foundation programmes it is good.”
“At
the previous inspection, teaching was unsatisfactory. Teaching has now improved
and
is satisfactory. Since the previous inspection, a thorough review of all
teaching has taken place.”
The
inspectors also noted that, at the previous inspection, “the range of learning
resources was insufficient with learners spending much of their time completing
photocopied worksheets. Although some progress has been made with this issue,
this still remains a weakness. Learners now have a choice of developing their
literacy and numeracy skills by completing a project
on a topic of interest to them. However, there is still repetitive use of
worksheets. Tutors have developed some innovative learning activities that have
included quizzes and game activities and these have helped to develop learners’
literacy and numeracy skills. However, these are not
used on a sufficiently frequent basis. Some learners working towards literacy
at level 1 and 2 have access to information technology and can use colour and
graphics within their learning programme. These facilities are not available to
all learners. In some lessons there is more use of video resources in response
to learners. requests and plans are being implemented
to widen the use of audiovisual
materials.”
The
ALI ‘s report on
Despite
these improvements the inspectors also reported that: “There still remain
insufficient work opportunities and accredited training for learners who wish
to access employment and gain new skills.
Learners have too little appropriately stimulating, purposeful activity
and, as a result, many participate in the compulsory education programme
reluctantly.”
Inspection Report, HMP &
YOI Parc, 13 January 2006, published 30 June 2006,
Adult Learning Inspectorate, www.ali.gov.uk Reports on Doncaster, Altcourse, Wolds, Bronzefield (December 2005) and Dovegate
(April 2005) as well as a number of publicly-run prisons can also be found at www.ali.gov.uk
Private sector pay still inferior
Basic
grade staff in privately run prisons and immigration centres in
The
most recent study carried out for the government-appointed Prison Service Pay
Review Body found that:
●
in the private sector, starting pay for operational support grades (OSG) and
prison custody officers (PCOs) is seven per cent and
eleven per cent less than their public sector counterparts;
●
average basic pay for OSGs
is 11% less but PCOs earn 41% less than prison
officers in the public sector;
●
differentials for OSGs have
halved since 2002 as companies have increased rates;
●
average basic pay for private sector middle managers
is 4% higher than public sector principal officers;
●
average basic pay for private prison directors and
centre managers is 33% higher than public prison governors. This difference has
increased from 29% since 2004;
●
public sector pensions are superior to the private
sector. For example, the salary values of pensions for public sector OSGs, prison officers and senior officers are 13.7%, 16.0%
and 16.1% more than the private sector.
The contributions for prison service staff give them guaranteed benefits
whereas those for most privates sector staff do not. The prison service
retirement age is 60 whereas it is 65 for many private sector staff;
●
prison service staff receive an average of around
seven more days holiday per year than the average for their private sector
counterparts.
●
All the companies have sick pay schemes but with significantly less generous
benefits to those in the prison service;
●
there are regional variations such as the south of
●
private companies “all have freedom to gear their pay
specifically to the local market in which each prison or centre has to operate.
While the prison service does operate a local pay policy in
●
all the companies determine pay and some aspects of
conditions separately for each contract. Most staff, especially up to
supervisor level, are recruited locally.
●
uniformed staff in the prison service are contracted to work an average 39 hour
week on shifts covering 24 hours and
seven days. Average weekly working hours for private sector OSGs
and PCOs vary between 39 and 44, with most between 39
and 42. One private prison operates an annual hours
scheme based on 2132 annual hours (including holidays, equivalent to an average
41 hour week).
According
to the consultants, the public/private sector differences are explained by the
following two principal factors: “Pay
costs are the largest element in the costs of managing a prison or immigration
centre. In order to compete successfully to win or retain contracts while
remaining profitable, the companies are therefore under sharp pressures to keep
pay costs down, while still attracting, retaining and motivating staff.”
They
also noted that “this is not to say that the prison service is not under any
such pressures but there is a wider range of factors that influence pay
settlements: for example relativities with other parts of the public sector.”
The differences in average pay are also “because prison officers have much
greater opportunity for pay progression.” Other findings included:
●
many prison officers have very long experience. By
contrast “55% of private sector staff at levels equivalent to OSG, officer and
senior officer levels have less than two years service and only 20% more than
five years.”
●
formal training arrangements in companies are very
similar to those in the prison service. More staff fail
to complete their training in the private sector than in the prison service.
However, without further research it was not possible to fully answer the
question of whether training ... is of comparable quality;
●
resignations of PCO/DCO staff in the private sector
averaged 27%, a slight increase over last year’s 25%. The rate of resignations
among public sector prison officers was almost unchanged at only 3%.
Resignations of OSGs and equivalent averaged 37% of
staff in post compared with 7% of OSGs in the prison
service. At supervisor level private
sector resignations averaged 16%. The explanation given for the high private
sector resignation levels included: the dislike of shift patterns; new recruits
finding that the reality of the job is something with which they cannot after
all cope; and competition from more highly paid jobs in the prison and
probation services where the skills learned by PCO and OSG equivalents are
directly relevant.
Unlike
in previous years all four prison operators - GSL, Serco,
UK Detention Services Ltd
and Group 4 Securior - supplied information for this study.
Privately Managed Custodial
Services, Prison Service Pay Review Body, MCG Consulting, September 2005.
Money go
round
Bridgend Custodial Services
Ltd, the
operator of Parc prison in
■On
The
Scottish Prison Service has confirmed that Addiewell
Prison Ltd has been appointed to finance, design, build and operate a new 700
bed prison in
Prison plans and PPP
conference
Rotarians manage prison
The
Kolbe Foundation is a not-for-profit organisation that was formed in 2002
specifically to take over the management of the Belize Central Prison in Hattieville under contract from the ministry of home
affairs (see PPRI #46).
According
to its website the Foundation is “made up of a board of directors, primarily
drawn from Belize City Rotary Club [which] brings a myriad of skills to the
task…” The website also lists many of the Foundation’s achievements in bringing
improvements over the last three years, including the development of a ‘supermax’ facility at the prison during 2003-04.
Missing
from the website, however, is any reference to a report released by the US
Department of State on 8 March 2006 which, as well as noting “improvements in
the prison system” reported: “During the year there were reports that prison
authorities brutalised troublesome prisoners, including placing inmates in a
small unlit and unventilated punishment cell called ‘supermax’.
Inmates claimed that prison officials sometimes withheld food and water as
further punishment, conducted strip searches and beatings, and exhorted money
for transfers to better conditions.” However, as the report also notes: “The
Kolbe Foundation investigated reports of abuse or excessive force by prison
officials. On May 9 the Kolbe Foundation, by means of an internal tribunal,
dismissed three senior prison officers, including the chief of security, for
alleged brutality and bribery. Matters of inmate-on-inmate abuse were directly
turned over to the police.”
Kolbe Foundation www.kolbe.bz/kolbe_foundation.php
Belize - Country Reports
on Human Rights Practices-2005, Released by the Bureau of Democracy, Human
Rights and Labor, 8 March 2006,
www.state.gov/g/drl/rls/hrrpt/2005/61716.htm
The
Queensland government is calling for tenders for Borallon
and Arthur Gorrie Correctional centres, Queensland’s
two privately managed prisons (see PPRI
# 67,62, 61, 59, 56, 55, etc ). Borallon opened in
1990 and Arthur Gorrie in 1992 and both contracts
expire in December 2007. The GEO Group runs the Arthur Gorrie
Correctional centre and Management & Training Corporation operate Borallon.
Corrections
minister Judy Spence announced in July 2006 that: “The tender process is about
ensuring value for money in the establishment of new contracts that are aligned
with recent changes within
The
recently re-elected Labor government has issued a ‘no
privatisations decree’ stating that “there will be no privatisation of State
Government assets during the entire term …” The decree was signed by premier
Mike Rann on 20 March 2006.
Focus on
developing countries
The
ICPA’s last conference took place in
Stephen
Carter of Carter Goble Lee also chaired a ‘directed discussion session’ on the
private sector. The published conference minutes note that “a good mix of
public and private sector representatives were in attendance” and that the main
discussions for the session “would be on the management of violent offenders
and the role of the private sector has to play in this, and how to advance
effective interventions in developing countries.” Ironically, “no
representatives from developing countries were present within the group” but
“there were a number of individuals representing organisations that have had significant
dealings with developing country correctional contracts.”
The
minutes noted that, according to a representative from Serco
A
representative from Group 4 mentioned that: “the organisation has operations in
110 countries worldwide. A quantitative investment appraisal is carried out
followed by a qualitative appraisal that considers issues such as the standards
of the judiciary, police services, etc, in any particular country … in most
circumstances this process ensures they are operating in countries that match
their principles and values.” One member of the group said that: “there needs
to be different assessment criteria if a contract relates to community
corrections rather than prison corrections.”
Private sector more
influential?
It
was suggested that: “the experience from the previous [ICPA] conference in
The
group “saw staff training as a major force for change within developing
countries.” One suggestion was “that the
It
was also suggested that healthcare is one issue which unites correctional
services throughout the world. It was “highlighted that in many circumstances
the private sector can do things that the public sector cannot for political
reasons.” Finally, on the issue of how far the private sector should go in
developing effective interventions, “it was felt that once within a contract a
private contractor could not stray from the customer’s mandate, as there is
then a risk of losing the contract in the future. It was generally agreed by
the group that this was a major restriction to private sector involvement.”
The
minutes of the ‘reflection on conference themes’ noted that: “the healthcare
provision within private prisons was often superior to that which the offender
would meet with outside agencies and that this has proved to be a barrier
towards effective interventions in the past.” Another factor influencing
effective healthcare is the actual physical state of prisons and “private
prisons are generally newer builds and consequently have more modern facilities
to utilise than their public sector counterparts who are often restricted by
housing offenders in Victorian era prisons and conditions.”
“A
question was raised in regards to how the private sector can advise developing
countries on how to improve their correctional facilities. A view was shared
that there is both an uneven economic playing field and significant
cultural/political differences in offender rehabilitation in developing
countries. These differences may need to be addressed before conducive
private sector involvement is effective. A representative from the
On
the issue of effective management of prisoner populations “it was generally
agreed that private prisons should have more input into developing
interventions, contributing towards policy and incorporating technological
advances into prison management.”
“Stephen Carter concluded proceedings with one final
question: how could the directed discussion groups, and indeed ICPA conference
as a whole be improved?” One suggestion from “a
representative from a private firm in