Justice Discretionary Grants: Byrne Program and Violence Against 
Women Office Grant Monitoring Should Be Better Documented	 
(28-NOV-01, GAO-02-25). 					 
								 
GAO reviewed selected aspects of the U.S. Department of Justice  
(DOJ) Office of Justice Program's (OJP) grant monitoring and	 
evaluation efforts. Specifically, this report discusses the	 
monitoring of discretionary grants awarded by the Bureau of	 
Justice Assistance's (BJA) Byrne Program and the Violence Against
Women Office (VAWO) within OJP. Byrne and VAWO discretionary	 
grants grew, in constant 2000 dollars, about 85 percent--from	 
$105 million to $194 million between fiscal years 1997 and 2000. 
These funds were awarded to state and local governments, either  
on a competitive basis or pursuant to legislation allocating	 
funds through congressional earmarks. BJA and VAWO, together with
OJP's Office of the Comptroller, are responsible for monitoring  
these grants to ensure they are implemented as intended, are	 
responsive to grant goals and objectives, and compliant with	 
statutory regulations and policy guidelines. OJP's monitoring	 
requirements include the development of monitoring plans that	 
articulate who will conduct monitoring, the manner in which it	 
will be done, and when and what type of monitoring activities are
planned. Grant managers are to maintain documentation in grant	 
files using such techniques as written reports of on-site reviews
and telephone interview write-ups. GAO's review of 46 Byrne and  
84 VAWO discretionary grants indicated that only 29 percent of	 
Byrne and 11 percent of VAWO award files contained monitoring	 
plans. In addition, for awards covering the most recent 12-month 
period, grant managers were not consistently documenting their	 
monitoring activities.	BJA and VAWO cannot systematically	 
oversee grant managers' compliance with monitoring requirements  
because documentation is not readily available. Both BJA and VAWO
rely on staff meetings and discussions to identify grant problems
or monitoring issues, and neither have management information	 
systems to compile and analyze data about monitoring activities. 
OJP has begun to work with its bureaus and offices to address	 
grant management problems, but it is too early to tell whether	 
OJP's efforts will effectively resolve many of the issues GAO and
others, including OJP itself, have identified.			 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-02-25						        
    ACCNO:   A02374						        
  TITLE:     Justice Discretionary Grants: Byrne Program and Violence 
Against Women Office Grant Monitoring Should Be Better Documented
     DATE:   11/28/2001 
  SUBJECT:   Discretionary grants				 
	     Grant monitoring					 
	     Edward Byrne Memorial State and Local		 
	     Law Enforcement Assistance Program 		 
								 

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GAO-02-25
     
Report to Congressional Requesters

United States General Accounting Office

GAO

November 2001 JUSTICE DISCRETIONARY GRANTS

Byrne Program and Violence Against Women Office Grant Monitoring Should Be
Better Documented

GAO- 02- 25

Page i GAO- 02- 25 Justice Discretionary Grants Letter 1

Results in Brief 2 Background 5 Scope and Methodology 7 Discretionary Grant
Monitoring and Requirements 9 BJA and VAWO Grant Files Did Not Always
Contain Adequate

Documentation That Monitoring Occurred 11 BJA and VAWO Are Not Positioned to
Systematically Determine

Staff Compliance With Monitoring Requirements and Assess Overall Performance
21 OJP?s Efforts to Resolve Continuing Grant Monitoring Problems 23
Conclusions 27 Recommendations for Executive Action 28 Agency Comments and
Our Evaluation 28

Appendix I Size and Growth of OJP, BJA, and VAWO Budgets and BJA and VAWO
Discretionary Grant Programs 31

Budget Increases at OJP, BJA, and VAWO in the 1990s 31 Discretionary Grant
Award Increases at BJA and VAWO in the

1990s 32

Appendix II Stages of the Discretionary Grant Process 36

Appendix III Comments From the Department of Justice 39 GAO Comments 49

Appendix IV GAO Contacts and Staff Acknowledgments 51 GAO Contacts 51 Staff
Acknowledgments 51

Tables

Table 1: Estimated Timeliness of Progress Report Submissions 16 Table 2.
Estimated Timeliness of Financial Report Submissions 17 Contents

Page ii GAO- 02- 25 Justice Discretionary Grants Figures

Figure 1: Overall OJP, BJA, and VAWO Yearly Budget Resources 6 Figure 2:
Overall OJP and BJA and VAWO Yearly Budget Resources 32 Figure 3: Overall
Yearly BJA Discretionary Awards 33 Figure 4: Dollar Amount of Overall BJA
Discretionary Awards 34 Figure 5: Number of Yearly VAWO Discretionary Awards
35 Figure 6: Dollar Amount of VAWO Discretionary Awards 35 Figure 7: Life of
a Discretionary Grant 36 Figure 8: Supplemental Award Process and Time Frame
38

Abbreviations

BJA Bureau of Justice Assistance DOJ Department of Justice GMS Grant
Management System GPRA Government Performance and Results Act of 1993 OJP
Office of Justice Programs VAWO Violence Against Women Office

Page 1 GAO- 02- 25 Justice Discretionary Grants

November 28, 2001 The Honorable Charles E. Grassley Ranking Minority Member
The Honorable Jeff Sessions, Member Subcommittee on Youth Violence Committee
on the Judiciary United States Senate

This report responds to your request that we review selected aspects of the
U. S. Department of Justice?s (DOJ) Office of Justice Program?s (OJP) grant
monitoring and evaluation efforts. Specifically, this report discusses the
program monitoring of discretionary grants awarded by the Bureau of Justice
Assistance?s (BJA) Byrne Program 1 and the Violence Against Women Office
(VAWO) within OJP. Between fiscal years 1997 and 2000, Byrne and VAWO
discretionary grant awards grew, in constant 2000 dollars, about 85 percent-
from about $105 million to approximately $194 million. These funds were
awarded directly to various organizations, such as state and local
governments, either on a competitive basis or pursuant to legislation
allocating funds through congressional earmarks. BJA and VAWO, together with
OJP?s Office of the Comptroller, were responsible for monitoring these
grants to ensure that they were being implemented as intended, responsive to
grant goals and objectives, and compliant with statutory regulations and
other policy guidelines.

To address your request, we reviewed and are reporting on (1) OJP?s
discretionary grant monitoring process and requirements, (2) the extent to
which BJA and VAWO documented their monitoring activities for discretionary
grants, (3) what BJA and VAWO do to determine compliance with OJP?s grant
monitoring guidelines, and (4) OJP?s efforts to identify and address grant
monitoring problems. 2 To meet our objectives, we interviewed agency
officials and grant managers and supervisors in Washington, D. C.; reviewed
OJP, BJA, and VAWO policies, procedures,

1 The Edward Byrne Memorial State and Local Law Enforcement Assistance
Program Discretionary Grants Program is the largest single discretionary
grant program within BJA. 2 In October 2001, we issued a similar report on
the documentation of discretionary grant monitoring by OJP?s Office of
Juvenile Justice and Delinquency Prevention, entitled

Juvenile Justice: Better Documentation of Discretionary Grant Monitoring Is
Needed

(GAO- 02- 65, Oct. 10, 2001).

United States General Accounting Office Washington, DC 20548

Page 2 GAO- 02- 25 Justice Discretionary Grants

and practices for and OJP reports on administering and monitoring grants;
analyzed data from a representative sample of 46 of 110 Byrne and 84 of 635
VAWO grant files active during 1999 and/ or 2000; and analyzed OJP, BJA, and
VAWO budget data on OJP grant programs from fiscal years 1990 through 2000.
As agreed with your staff, we focused on monitoring activities associated
with the Byrne and VAWO discretionary grant programs that supported a
program or theme, rather than those that supported training and technical
assistance.

Our analysis did not address how well BJA and VAWO monitored their grantees.
For example, we reviewed documentation to determine whether BJA and VAWO
made the site visits they said they would conduct, but it was not feasible
to review how well they conducted the site visits. Further, we did not
examine OJP?s efforts to conduct financial monitoring of Byrne and VAWO
discretionary grants through the Office of Comptroller. For purposes of this
report, a grant consists of an initial award and any subsequent supplemental
awards. Thus, when we reviewed a grant file, we reviewed all award files
within each grant.

OJP has monitoring and documentation requirements for its discretionary
grants. The monitoring requirements include the development of monitoring
plans that articulate who will conduct monitoring, the manner in which it
will be done, and when and what type of monitoring activities are planned.
Grant managers are to maintain documentation in grant files on their
monitoring activities, using such techniques as written reports of on- site
reviews and telephone interview write- ups. Grant files are also to include
program and financial progress reports submitted by grantees to OJP at
defined intervals, and grant managers are to notify grantees when reports
are delinquent. In addition, when grants are closed, grant files are
supposed to contain key documents, including all financial and progress
reports and the final accounting of federal funds.

Our review of a representative sample of 46 Byrne and 84 VAWO discretionary
grants showed that they did not always contain the required monitoring
plans: an estimated 29 percent of Byrne and 11 percent of VAWO award files
did not contain monitoring plans. In addition, for awards covering the most
recent 12- month period of grant activity, grant managers were not
consistently documenting their monitoring activities according to the
monitoring plans they developed. For example, 25 of 46 Byrne and 53 of 84
VAWO files had plans with specific criteria for site visits. Of these 25
Byrne files, 21 did not contain documentation to show whether all the
planned site visits occurred. For the VAWO files, we Results in Brief

Page 3 GAO- 02- 25 Justice Discretionary Grants

estimate that 90 percent of all files did not contain documentation that all
the planned site visits occurred. Our review of grant files also showed the
following:

 A substantial number of Byrne and VAWO files did not contain progress and
financial reports sufficient to cover the entire grant period. For example,
an estimated 70 percent of Byrne and 66 percent of VAWO files did not have
progress reports to cover the complete grant period, and an estimated 41
percent of Byrne and 36 percent of VAWO grant files did not contain
financial reports covering the full grant period. In addition, seven of the
files we reviewed- three Byrne and four VAWO- did not contain any of the
required grantee progress reports.

 Progress and financial reports were often submitted late by grantees. An
estimated 68 percent of Byrne and 85 percent of VAWO progress reports were
late, and 53 percent of Byrne and 54 percent of VAWO financial reports were
late.

 The Byrne and VAWO files we reviewed did not always contain the required
closeout documents. There were not enough closed Byrne or VAWO grants to
ensure that our assessment was representative of all grant closeouts.
However, our limited review showed that of the 19 closed Byrne grants we
reviewed, 15 did not contain documentation of the required precloseout
contact with the grantee, 10 did not contain the final progress report, and
7 did not contain the final financial report. Of the 3 closed VAWO grants we
reviewed, 3 did not contain documentation of the required precloseout
contact with the grantee, 2 did not contain the final progress report, and 1
did not contain the final financial report.

BJA and VAWO are not positioned to systematically oversee grant managers?
compliance with monitoring requirements because documentation is not readily
available on monitoring activities. Both BJA and VAWO rely on staff meetings
and discussions with staff to identify grant problems or monitoring issues,
and neither have management information systems that enable them to compile
and analyze data about most monitoring activities. The lack of systematic
data for monitoring grant manager compliance, combined with a failure to
document monitoring activities, could impede BJA and VAWO?s ability to
measure their performance consistent with the Government Performance and
Results Act of 1993 (GPRA). 3 For example, DOJ?s Fiscal Year 2000
Performance Report and 2002 Performance Plan list three VAWO program

3 P. L. 103- 62.

Page 4 GAO- 02- 25 Justice Discretionary Grants

targets and performance measures for which needed performance data are to be
derived from grantee progress reports, on- site monitoring, and VAWO program
office files- all validated and verified through a review of monitoring
information. Although the performance report and plan state that the goals
and measures have no known limitations, questions arise as to whether
inconsistent documentation and the lack of systematic data could hinder
VAWO?s ability to measure whether it is achieving its goals.

Problems with OJP grant monitoring are not new. Over the last few years, we
and others, including OJP, have identified various grant monitoring problems
among OJP?s bureaus and offices. For example, since 1996, we have testified
and issued reports that discuss inconsistent documentation of discretionary
grant monitoring activities in OJP?s Office of Juvenile Justice and
Delinquency Prevention and Executive Office for Weed and Seed. In addition,
reports by or for OJP have found similar problems among OJP?s bureaus and
offices. The DOJ Office of Inspector General has declared OJP grant
management a major management challenge. OJP has begun to work with its
bureaus and offices, like BJA and VAWO, to address these problems, but it is
too early to tell whether OJP?s efforts will effectively resolve many of the
issues we and others, including OJP itself, have identified. For example,
although OJP has issued new guidance on grant monitoring and is soliciting
the opinions of grant managers regarding the usefulness of its new guidance,
OJP has not considered what it plans to do to test compliance and ensure
that grant managers are documenting their activities.

We are making recommendations regarding (1) BJA and VAWO?s need to improve
their documentation of discretionary grant monitoring and (2) OJP?s need to
establish an approach to compile, maintain, and systematically review
documentation of monitoring activities.

In commenting on a draft of this report, OJP?s Assistant Attorney General
said that overall, the report provides useful information by highlighting
monitoring activities that need improvement (see appendix III). She noted
that BJA and VAWO had already taken steps to address our recommendations
regarding their monitoring activities, but she was silent about what OJP
planned to do to address our recommendations regarding OJP?s need to
establish an approach to compile, maintain, and systematically review
documentation of monitoring activities. We acknowledge that BJA and VAWO
appear to be taking steps in the right direction. However, until their
actions become operational, BJA and VAWO will not be able to determine why
the problems we identified occurred so that they can take corrective action.
In addition, although

Page 5 GAO- 02- 25 Justice Discretionary Grants

these steps might help BJA and VAWO better understand and act upon the
problems we identified, they appear to be specific to those organizations.
Thus, it is unclear whether and to what extent these actions can be applied
OJP- wide so that OJP can begin to address the long- standing monitoring
problems we and others, including OJP, have identified.

OJP, the grant- making arm of DOJ, provides grants to various organizations,
including state and local governments, universities, and private
foundations, that are intended to develop the nation?s capacity to prevent
and control crime, administer justice, and assist crime victims. OJP?s
Assistant Attorney General is responsible for overall management and
oversight of OJP through setting policy and for ensuring that OJP policies
and programs reflect the priorities of the President, the Attorney General,
and the Congress. The Assistant Attorney General promotes coordination among
the various bureaus and offices within OJP, including BJA, one of the five
bureaus within OJP, and VAWO, one of OJP?s seven program offices. 4 In
fulfilling its mission, BJA provides grants for sitebased programs and for
training and technical assistance to combat violent and drug- related crime
and help improve the criminal justice system. VAWO administers grants to
help prevent, detect, and stop violence against women, including domestic
violence, sexual assault, and stalking.

Since 1996, OJP?s budget has increased substantially, following the passage
of the Violent Crime Control and Law Enforcement Act of 1994. 5 Figure 1
shows changes to OJP?s budget from fiscal year 1990 through fiscal year 2000
and compares those changes in relation to BJA?s budget over the same period
and VAWO?s budget since its inception in 1995.

4 OJP?s five bureaus are Bureau of Justice Assistance, Bureau of Justice
Statistics, National Institute of Justice, Office of Juvenile Justice and
Delinquency Prevention, and Office for Victims of Crime. OJP?s seven program
offices are American Indian & Alaska Native Affairs Desk, Violence Against
Women Office, Executive Office for Weed and Seed, Corrections Program
Office, Drug Courts Program Office, Office for State and Local Domestic
Preparedness Support, and Office of the Police Corps and Law Enforcement
Education.

5 P. L. 103- 322. Background

Page 6 GAO- 02- 25 Justice Discretionary Grants

Figure 1: Overall OJP, BJA, and VAWO Yearly Budget Resources

Note 1: According to OJP budget officials, yearly figures include all funds
appropriated to OJP, transfers from other agencies, and receipts from the
Crime Victim Fund, which is derived not from tax dollars, but from fines and
penalties paid by federal criminal offenders. However, the yearly figures do
not include grants awarded and administered by OJP bureaus and offices for
other federal agencies (including other DOJ agencies) under reimbursable
agreements. Also, the yearly amounts do not include direct appropriations
for OJP management and administration. The large funding increase for fiscal
year 1996 resulted from the Omnibus Consolidated Recissions and
Appropriations Act of 1996, which appropriated funds authorized by the
Violent Crime Control and Law Enforcement Act of 1994.

Note 2: The budget amounts for each fiscal year are adjusted to constant
fiscal year 2000 dollars. Source: OJP Office of Budget and Management
Services.

One of BJA?s major grant programs is the Edward Byrne Memorial State and
Local Law Enforcement Assistance Program. 6 Under the Byrne Discretionary
Grants Program, BJA provides federal financial assistance to grantees for
educational and training programs for criminal justice personnel; technical
assistance to state and local units of government; and projects that are
replicable in more than one jurisdiction nationwide. In fiscal year 2000,
BJA awarded 99 Byrne discretionary grants worth about $69 million.

6 Local law enforcement programs established by the Anti- Drug Abuse Act of
1986 (P. L. 99570) were amended and renamed the Edward Byrne Memorial State
and Local Law Enforcement Assistance Program by the Anti- Drug Abuse Act of
1988 (P. L. 100- 690). The Byrne grant program is codified at 42 U. S. C.
3750- 3766b. The Byrne program is one of approximately 20 programs
administered by BJA.

Page 7 GAO- 02- 25 Justice Discretionary Grants

VAWO was created in 1995 to carry out certain programs created under the
Violence Against Women Act of 1994. 7 The Victims of Trafficking and
Violence Prevention Act of 2000 8 reauthorized most of the exisiting VAWO
programs and added new programs as well. VAWO?s mission is to lead the
national effort to end violence against women, including domestic violence,
sexual assault, and stalking. VAWO programs seek to improve criminal justice
system responses to these crimes by providing support for law enforcement,
prosecution, courts, and victim advocacy programs across the country. In
addition, programs are to enhance direct services for victims, including
victim advocacy, emergency shelter, and legal services. VAWO also addresses
violence against women issues internationally, including working to prevent
trafficking in persons. In fiscal year 2000, VAWO awarded 425 discretionary
grants worth about $125 million.

Appendix I discusses the growth in OJP, BJA, and VAWO budgets and provides
information on the number and amount of BJA and VAWO discretionary grants
awarded from fiscal year 1990 to fiscal year 2000.

To meet our objectives, we conducted our work at OJP, BJA, and VAWO
headquarters in Washington, D. C. We reviewed applicable laws and
regulations and OJP, BJA, and VAWO policies and procedures for awarding and
managing grants, and we interviewed responsible OJP, BJA, and VAWO
officials, including grant managers. As agreed with your offices, we focused
on monitoring activities associated with the Byrne and VAWO discretionary
grant programs. In particular, we focused on grant monitoring for grants
that were active during fiscal years 1999 and 2000 and supported a program
or theme, rather than technical assistance or training efforts.

To address our first objective, concerning OJP?s process and requirements
for discretionary grant monitoring, we reviewed applicable laws and
regulations and OJP policies and procedures for grant administration and
grant monitoring. We also interviewed OJP, Comptroller, BJA, and VAWO staff.
We obtained information about the Comptroller?s Control Desk, which
maintains the official grant files and is responsible for receiving,

7 Title IV of the Crime Act (P. L. 103- 322). 8 P. L. 106- 386. Scope and

Methodology

Page 8 GAO- 02- 25 Justice Discretionary Grants

distributing, and tracking grant documents, including financial and progress
reports.

To address our second objective regarding the extent to which BJA and VAWO
documented their monitoring activities for discretionary grants, we reviewed
representative samples of official grant files and grant manager files using
a data collection instrument to record whether evidence of the required
monitoring activity- progress reports, financial reports, and other required
documents- were included in the files. For each grant, we also reviewed the
most recent award covering 12 months to examine the documentation of
specific monitoring requirements and activities, such as telephone calls and
site visits. 9 Specifically, we reviewed a random sample of 46 of 110 Byrne
and 84 of 635 VAWO discretionary grants that had a program theme and were
active throughout fiscal year 1999 or 2000. The results of the samples are
representative of the populations from which they were drawn. We express our
confidence in the precision of our sample results as a 95- percent
confidence interval. Unless otherwise noted, all confidence intervals are
less than or equal to plus or minus 10 percentage points.

In regard to grantee financial and progress reports, we reviewed all
available reports for the BJA and VAWO discretionary grants included in our
sample from the initiation of the grant through December 31, 2000. We
determined timeliness using dates recorded on reports compared with the
specified intervals when they were supposed to be received. Also, to
determine whether BJA and VAWO closeout procedures were implemented in
accordance with OJP policy, we reviewed those grant files in our sample when
the grant end date was between September 30, 1999, and August 31, 2000. For
our review, we focused on required closeout documentation, such as
precloseout contacts, closeout checklists, and final financial and progress
reports.

To address our third objective, regarding how BJA and VAWO determine
compliance with OJP monitoring requirements, we requested information on any
existing oversight and review processes relating to grant

9 A grant consists of an initial award, any subsequent supplemental awards
and grant adjustment notices. Grant adjustment notices are completed for
changes to the grant (e. g., project period extensions or budget
modifications). Once reviewed and certified, the grant adjustment notice
communicates approval of such changes by the appropriate OJP office.
Therefore, when we reviewed a grant file, we reviewed all award files within
each grant, as well as all relevant grant adjustment notices.

Page 9 GAO- 02- 25 Justice Discretionary Grants

monitoring at BJA and VAWO and gathered and reviewed documentation that BJA
and VAWO officials provided concerning their oversight processes. We also
met with BJA and VAWO officials to obtain information on any new initiatives
they had to address the oversight and management of their grants.

To meet our fourth objective, on OJP?s efforts to identify and address grant
management problems, we met with OJP officials to discuss their efforts, and
we reviewed reports and documents they had prepared about the new Grant
Management System (GMS), revisions to the OJP Handbook and associated
decision documents, and other initiatives. In addition, we reviewed the DOJ
Fiscal Year 2000 Performance Report and Fiscal Year 2002 Performance Plan
and information on grant management developed by the DOJ?s Office of the
Inspector General.

Finally, to obtain information on the size and growth of BJA and VAWO grant
programs within the context of OJP, we obtained and analyzed budget and
resource data from OJP on grant funds and programs from fiscal years 1990
through 2000.

We conducted our work between October 2000 and October 2001 in accordance
with generally accepted government auditing standards.

We requested comments on a draft of this report from DOJ on October 24,
2001. Its comments are discussed near the end of this letter and are
reprinted as appendix III. DOJ also provided technical comments that were
incorporated in the report.

After BJA and VAWO award discretionary grants, OJP policies require them, in
coordination with Office of the Comptroller, to monitor grants and related
activities and document the monitoring results. Monitoring is done to ensure

 compliance with relevant statutes, regulations, policies, and guidelines;

 responsible oversight of awarded funds;

 implementation of approved programs, goals, objectives, tasks, products,
time lines, and schedules;

 identification of issues and problems that may impede grant
implementation; and

 implementation of adjustments by the grantee as approved by BJA or VAWO.
Discretionary Grant

Monitoring and Requirements

Page 10 GAO- 02- 25 Justice Discretionary Grants

The OJP Handbook is the basic reference for OJP policies and procedures for
the administration of OJP grants, including discretionary grant monitoring.
10 According to the Handbook, each grant manager is to prepare a monitoring
plan as part of a grant manager?s memorandum recommending initial or
continuation funding. The level of monitoring is to be based on the stated
monitoring plan in the grant manager?s memorandum. The plan is to contain
information on who will conduct the monitoring, how it will be done, and
when and what type of monitoring activities are planned. Monitoring
information is to be collected using such techniques as on- site visits,
telephone calls, and desk reviews, which are reviews to ensure that the
grant files are complete and the grantee is in compliance with the program
guidelines.

In addition, grant managers are to review grantee program and financial
progress reports. According to OJP?s Handbook, grantees are required to
submit periodic progress reports that summarize project activities to aid
program and grant managers in carrying out their responsibilities for grant-
supported activities. 11 Likewise, grantees are required to submit periodic
financial status reports to update OJP on how grant funds are being spent.
In addition, OJP requires that grant managers close out the grant when the
project period ends to ensure that the agency has received all required
financial, programmatic, and audit reports and that all federal funds have
been accounted for.

OJP bureaus and program offices, such as BJA and VAWO, are to carry out the
program (nonfiscal) monitoring aspects of the grants they award. During
fiscal year 2000, BJA had approximately 20 program managers responsible for
the monitoring activities for most nonformula BJA grants. Generally, each
BJA program manager had responsibility for monitoring 25 to 40 discretionary
grants, including those under the Byrne program. VAWO had 13 program
managers, each of whom had responsibility for the program monitoring aspects
for about 60 VAWO grants, including VAWO discretionary grants.

10 OJP, OJP Handbook: Policies and Procedures for the Administration of OJP
Grants

(Washington, D. C.: Feb. 1992). In January 2001, OJP released Grant
Management Policies and Procedures Manual to update OJP?s policies and
procedures for grant management activities. This manual supersedes and
cancels the 1992 Handbook. The revised policies and procedures were not
applicable to the grant periods covered by our review.

11 In 1996, OJP changed its procedures to require grantees to submit
progress reports semiannually. Before then, grantees had to submit progress
reports quarterly.

Page 11 GAO- 02- 25 Justice Discretionary Grants

The Office of the Comptroller has primary responsibility for monitoring the
fiscal aspects of all OJP- awarded grants, including those awarded by BJA
and VAWO. To assess grantee financial records, the Comptroller?s Monitoring
Division is to perform risk- based, on- site financial reviews for a sample
of grantee organizations to monitor administrative and financial capability.
12 The Monitoring Division is to review various program and financial
documents contained in the official grant files to ensure that they are
complete and the documents are properly executed. For discretionary grants,
the Monitoring Division conducted 36 desk reviews for Byrne and 38 for VAWO
discretionary grants in fiscal year 1999 and 6 desk reviews for Byrne and 16
for VAWO discretionary grants in fiscal year 2000. In addition, the Control
Desk is to maintain the official grant files and is responsible for tracking
the receipt of all grantee documents. The Control Desk is to receive grantee
progress and financial reports, log the date of receipt into a tracking
system, file the original in the official grant file, and forward a copy to
the cognizant program office. The Control Desk also is to generate a monthly
report on delinquent progress and financial reports, which is distributed to
responsible officials within bureaus and program offices. BJA and VAWO grant
managers are responsible for ensuring that grantees submit timely progress
and financial reports and are to contact the grantee if reports are
delinquent.

Appendix II discusses grant monitoring within the context of the grant award
process throughout the life of a grant.

OJP requires that grant managers document their monitoring of the grants.
This documentation is to include both the grant manager?s written plan for
monitoring the project and grantee progress and financial reports. In
addition, OJP requires certain documentation at the time of grant closeouts
from both the grantee and the grant manager. Byrne and VAWO grant files did
not always contain monitoring plans, and grant managers were not
consistently documenting their monitoring activities, according to the
monitoring plans that we reviewed. In fact, for those award files
representing the most recent 12- month period of activity for each grant,
few contained records to show that such activities as telephone contacts and
site visits occurred. Furthermore, the progress and financial reports did
not always cover the entire period covered by the award, a few grants

12 The Comptroller?s Monitoring Division applies risk- based criteria to a
universe of grants to develop a sample for each fiscal year?s monitoring
plan based on the dollar amount of the grant, new grantees, new grant
programs, and programs with known problems. BJA and VAWO Grant

Files Did Not Always Contain Adequate Documentation That Monitoring Occurred

Page 12 GAO- 02- 25 Justice Discretionary Grants

were missing all progress reports, and progress and financial reports were
often late. For those closed grants that we reviewed, key documents, which
are to ensure a final accounting of federal funds and show whether the
grantee met the programmatic goals of the grant, were sometimes missing.

Our review of grant files showed that monitoring plans were not always in
the files. Each grant may contain one or more individual grant awards, 13
and for each award, OJP requires that grant managers prepare a monitoring
plan containing information on, among other things, who will conduct the
monitoring, how it will be done, and when and what type of monitoring
activities and reports are planned. Our review of documentation on the
awards in 46 Byrne grant files and 84 VAWO grant files showed that an
estimated 29 percent of the Byrne awards and about 11 percent of the VAWO
awards did not contain a grant manager?s monitoring plan. 14

We also compared the planned monitoring activities in the monitoring plans
for the most recent 12- month period of grant activity for each of the 46
Byrne and 84 VAWO grant files to actual monitoring documentation. Of those
files that contained a monitoring plan, some had specific plans for
monitoring, while others did not. When the file contained a plan that
outlined the type of monitoring and its frequency, our review showed that
the documentation in the files was inadequate to demonstrate whether or not
BJA and VAWO grant managers were consistently following the monitoring
plans. For Byrne files, there were not enough monitoring plans with specific
planned activities to ensure that our assessment was representative of all
the awards. However, our limited comparisons of planned to actual
documentation regarding phone contacts, site visits, and desk reviews
revealed the following:

 Phone Contacts. 13 of 46 Byrne files contained monitoring plans that
specified the planned number and frequency (e. g., monthly or quarterly) of
telephone contacts to be made. Of those 13 files, none contained
documentation to show that all of the planned number of telephone contacts
occurred. Furthermore, 4 of the 13 files had documentation that showed that
some, but not all, of the planned telephone contacts had been

13 For further discussion of the life of a grant and subsequent awards, see
appendix II. 14 The 46 Byrne grants contained 76 awards, and the 84 VAWO
grants contained 152 awards. Missing Monitoring Plans

and Inadequately Documented Monitoring Activities

Page 13 GAO- 02- 25 Justice Discretionary Grants

made, while the remaining 9 files contained no documentation that any
telephone contacts occurred.

 Site Visits. 25 of 46 Byrne files contained monitoring plans that
specified the number of grantee site visits to be conducted, but only 4 of
25 files contained documentation that showed that the planned number of site
visits occurred. Only 1 of the 25 files had documentation that some, but not
all, of the site visits had been made, and the remaining 20 of the 25 files
contained no documentation that any site visits occurred.

 Desk Reviews. 15 of 46 Byrne files contained monitoring plans that
specified the frequency of desk reviews to be conducted. However, none of
the files showed evidence that any desk reviews were conducted.

Our assessment of the VAWO files provided enough cases to develop a
representative sample of all available VAWO monitoring plans. Specifically,
our review of planned to actual monitoring activities- phone contacts, site
visits, and desk reviews- showed the following:

 Phone Contacts. 59 of 84 VAWO files contained monitoring plans that
specified the planned number and frequency (e. g., monthly or quarterly) of
telephone contacts to be made. However, none contained documentation to show
that the planned number of telephone contacts occurred. Furthermore, we
estimate that 56 percent of VAWO files had documentation that some, but not
all, of the planned telephone contacts had been made, and 44 percent of VAWO
files 15 with monitoring plans containing criteria for a specific number of
telephone contacts had no documentation that any telephone contacts
occurred.

15 The estimated range is between 31 and 58 percent.

Page 14 GAO- 02- 25 Justice Discretionary Grants

 Site Visits. 53 of 84 VAWO files contained monitoring plans that specified
the number of grantee site visits to be conducted. 16 We estimate that 10
percent of VAWO files 17 contained documentation that the planned number of
site visits occurred. Furthermore, only 2 percent of VAWO files had
documentation that even some, but not all, of the planned site visits had
been made, while the remaining 88 percent of VAWO files 18 contained no
documentation that any site visits occurred.

 Desk Reviews. 47 of 84 VAWO files contained monitoring plans that
established specific criteria for the frequency of desk reviews. However,
none of the VAWO files showed evidence that any desk reviews were conducted.

OJP requires that grantees file semiannual progress reports and quarterly
financial reports throughout the life of a grant. Progress reports are to
supply information on the activities and accomplishments of the grantee
during the previous reporting period. Financial reports are to show the
actual expenditures and unliquidated obligations for the reporting period
(calendar quarter) and cumulative for the award. We found Byrne and VAWO
grant files in which progress reports and financial reports did not cover
the entire period of the grant and a few files with no evidence of progress
reports. We also found that progress and financial reports were often late.
Combined, these factors resulted in unaccounted periods of time, where OJP
had either no information or no up- to- date information about grantee
progress or financial activities.

For example, we compared the time periods progress and financial reports
were supposed to cover with the time periods they actually covered for each
of the Byrne and VAWO grant files we reviewed. Based on our analysis of the
grant files, we estimate that 70 percent of the Byrne grants 19 had periods
of time during the grant period not covered by progress reports, and 41
percent of the Byrne grants 20 had periods of time not covered by financial
reports. Likewise, we estimate that 66 percent of the

16 For VAWO site visits, our estimates are based on 51 files, not 53,
because we did not collect the necessary documentation on 2 of the files. 17
The estimated range is between 3 and 22 percent.

18 The estimated range is between 76 and 96 percent. 19 The estimated range
is between 57 and 80 percent. 20 The estimated range is between 30 and 54
percent. Progress and Financial

Reports Did Not Cover the Entire Grant Period and Were Often Late

Page 15 GAO- 02- 25 Justice Discretionary Grants

VAWO grants had periods of time during the grant period not covered by
progress reports and 36 percent of the VAWO grants had periods of time not
covered by financial reports. These gaps, cumulative over the life of the
grant, ranged from as little as 2 weeks to over 3 years for progress reports
and from 1 month to 1ï¿½ years for financial reports. With regard to progress
reports, we estimate that 30 percent of Byrne grants 21 and 18 percent of
VAWO grants had more than 12 months that were not covered. With regard to
financial reports, we estimate that only 4 percent of grants at both BJA and
VAWO had more than 12 months that were not covered.

Our analysis also showed that a few grant files did not contain any progress
reports. For the files we reviewed, seven- three Byrne and four VAWO-
contained no progress reports. We noted that OJP awarded one VAWO grantee
two supplemental awards over the course of a 3- year period, even though
there were no progress reports in the file. In total, these seven grant
files without progress reports represent over $2 million in grantee funds
awarded over a 5- year period. Finally, we noted examples of progress
reports covering more than the required 6- month period and noted that one
VAWO progress report that was submitted to cover a 2ï¿½ year period was a
half- page long. Given OJP?s requirement that progress reports are to be
submitted for each 6- month period of the grant, the fact that reports
covered periods well beyond the required 6 months raises questions about
whether a grant manager has sufficient information to monitor progress and
identify any potential grantee problems.

We asked BJA and VAWO officials why these seven grant files did not contain
any progress reports. BJA?s Acting Director at the time of our review said
that reorganizations in BJA over the last 2 years have contributed to
difficulty in ensuring complete and accurate grant files. VAWO officials
explained that one of the four grant files involved a grantee that had some
grant implementation problems that have since been corrected and said that
problems aside, the grantee had been unaware that progress reports were
required for periods of grant inactivity. They said that another of the four
grantees had been accustomed to the reporting requirements for formula
grants, but unaware of different reporting requirements for discretionary
grants. According to VAWO officials, this situation has since been corrected
and the files have been made current. VAWO officials were unclear about why
another grantee had not submitted progress reports. However, they said that
the

21 The estimated range is between 20 and 43 percent.

Page 16 GAO- 02- 25 Justice Discretionary Grants

one grantee that had been awarded two supplemental grants is now scheduled
for closeout because of the extended period of time the grantee has been
delinquent in submitting progress reports. In addition, VAWO officials said
that it was unacceptable for a grantee to submit a half- page progress
report covering 2ï¿½ years.

Our review of grant files also showed that late reports were common. 22 OJP
has specific guidance that spells out when progress and financial reports
are to be filed by grantees. Progress reports are due 30 days after the
close of each previous 6- month period, 23 and financial reports are to be
turned in 45 days after the end of the calendar quarter. We compared the
dates progress and financial reports were supposed to be filed by grantees
with the dates they were actually received by OJP?s Office of the
Comptroller. We estimate that 68 percent of Byrne and 85 percent of VAWO
progress reports were late. However, for both Byrne and VAWO, we estimate
that about 40 percent of all reports were late by only about a month. Table
1 shows our estimates of the timeliness of Byrne and VAWO progress reports.

Table 1: Estimated Timeliness of Progress Report Submissions Percent late
Percent on time 30 days

or less 31- 90 days 91- 180

days 181 days or more

Byrne 32 42 15 6 5 VAWO 15 43 21 9 12

Note 1: The percentages in this table are estimates based on a random sample
of 46 Byrne and 84 VAWO discretionary grant files, representing,
respectively, 209 and 361 progress reports from the initiation of the grant
through December 31, 2000. Of these reports, we excluded 7 at BJA and 13 at
VAWO because of data- related problems, such as missing submission dates.
The estimates are subject to sampling error. The 95- percent confidence
intervals for the estimates are within plus or minus 10 percent.

Note 2: Lateness is measured by the number of days beyond the deadline (30
days after the close of each previous 6- month period) the progress report
is submitted to OJP.

Source: GAO analysis.

22 We reviewed 209 BJA and 361 VAWO progress reports and 458 BJA and 811
VAWO financial reports in the files from the initiation of the grant through
December 31, 2000. Of these reports, we excluded 7 BJA progress, 4 BJA
financial, 13 VAWO progress, and 8 VAWO financial reports because of data-
related problems, such as missing submission dates.

23 In 1996, OJP changed its procedures to require grantees to submit
progress reports semiannually. Before then, grantees had to submit progress
reports quarterly.

Page 17 GAO- 02- 25 Justice Discretionary Grants

Similarly, in the case of financial reports, our review showed an estimated
53 percent of Byrne and 54 percent of VAWO financial reports were submitted
late. Similar to progress reports, about one- third of all reports were late
by 30 days or less. Table 2 shows our estimates of timeliness of Byrne and
VAWO financial reports.

Table 2: Estimated Timeliness of Financial Report Submissions Percent late
Percent on time 30 days

or less 31- 90 days 91- 180

days 181 days or more

Byrne 47 29 11 8 5 VAWO 46 29 15 6 4

Note 1: The percentages in this table are estimates based on a random sample
of 46 Byrne and 84 VAWO discretionary grants, representing, respectively,
458 and 811 financial reports from the initiation of the grant through
December 31, 2000. Of these reports, we excluded 4 at BJA and 8 at VAWO
because of data- related problems, such as missing submission dates. The
estimates are subject to sampling error. The 95- percent confidence
intervals for the estimates are within plus or minus 10 percent.

Note 2: Lateness is measured by the number of days beyond the deadline (45
days after the close of each previous quarter) the financial report is
submitted to OJP.

Source: GAO analysis.

OJP?s Office of the Comptroller also found problems similar to those we
identified regarding financial reports. As mentioned earlier, the Office of
the Comptroller does periodic financial reviews of the official grant file.
We examined Comptroller records for 22 grants also covered in our review and
found they identified 8 Byrne and 9 VAWO files that were missing some
financial reports and 5 Byrne and 8 VAWO files in which financial reports
were late. We did not determine what was done to follow up on the late or
missing financial reports found during these financial reviews. However,
Comptroller procedures call for contacting the grant manager or grantee to
request copies of documents that may be missing from the file and to ensure
that all documentation related to the financial review is included in the
official grant file before the review is closed.

Our review also showed that BJA and VAWO grant managers did not always
document key closeout activities for those files we examined. OJP requires
that grants be closed in a timely manner and considers the process to be one
of the most important aspects of grant administration. Closing out grants is
the final step in a process by which OJP ensures that all required financial
and progress reports and final accounting of federal funds have been
received. The timeframe for completion of closeout is no more than 180 days
after the end of the grant project. According to OJP Byrne and VAWO Closeout

Documents Missing

Page 18 GAO- 02- 25 Justice Discretionary Grants

guidance, as part of the closeout process, the grant manager is to review
the grant file and contact the grantee about the upcoming grant end date and
final report submissions. The grant manager is to use the closeout checklist
as a means of ensuring that all closeout requirements- the grantee?s
submission of final progress and financial reports- are met.

We identified 19 closed Byrne grants and 3 closed VAWO grants that ended
between September 30, 1999, and August 31, 2000. 24 There were not enough
closed cases in our sample to ensure that our assessment was representative
of all grant closeouts. However, our limited review showed that some grant
files did not contain required closeout materials. For example, for the
Byrne grants:

 15 files did not contain documentation of the precloseout contact with the
grantee; 25

 9 files did not contain closeout checklists;

 10 files did not contain the final narrative progress report; and

 7 files did not contain the final financial report. For the VAWO grants:

 3 files did not contain documentation of the precloseout contact with the
grantee;

 3 files did not contain closeout checklists;

 2 files did not contain the final narrative progress report; and

 1 file did not contain the final financial report. 24 In order to take
into account the minimum 180 days OJP allows bureaus and offices to complete
closeout activities, we used August 31, 2000, as the cutoff date for our
analysis of BJA closeout activities. Using this cutoff date, we identified
an additional 2 grants at VAWO that appeared to be closed. However,
according to VAWO, the 2 grants were not actually closed, but rather, had
been given extensions. VAWO officials acknowledged that the required
documents extending the grant period were not in the files. These grants
were excluded from our closed grant analysis.

25 We did not collect information for one of the files on precloseout
contacts; therefore, this part of the review covered 18, not 19, cases.

Page 19 GAO- 02- 25 Justice Discretionary Grants

BJA and VAWO officials acknowledged that their file maintenance and
documentation may not have always been in compliance with OJP monitoring
requirements. Officials at both agencies stated that, in some instances,
lack of documentation was because of an increased workload among grant
managers. In addition, VAWO officials said that since VAWO?s inception, VAWO
grant managers have had the responsibility to not only monitor an increasing
volume of grants, but also to develop and implement several new grant
programs. 26 In commenting on a draft of this report, the Assistant Attorney
General stated BJA grant managers have had similar responsibilities. The
Assistant Attorney General also commented that one reason for VAWO?s lack of
documentation regarding site visits might be a past practice by which all
VAWO grant managers memorandums included a standard monitoring plan that was
developed in fiscal year 1995, when VAWO was responsible for monitoring one
formula and one small discretionary grant program.

Regardless, officials from both BJA and VAWO stated that the monitoring
activities may still be taking place, even though they are not documented
consistently. When asked how one would know whether a desk review had been
done, one BJA official told us that desk reviews were not a specific
process, rather they were the type of activities that grant managers did on
a day- to- day basis. He added that since BJA had no formalized process for
conducting desk reviews, no documentation was required of the grant managers
upon completion. Nonetheless, OJP?s guidance for the period covered by our
review stated that a desk review form is to be prepared periodically to
note, among other things, all contacts, reports, and product reviews. The
form is also to include issues, accomplishments, and problems, noting
recommended solutions.

BJA?s Acting Director at the time of our review told us that oversight of
grants can and has suffered through changes at BJA, including
reorganizations within BJA and the increased number of grants and greater
workload for BJA grant managers. He said that there is no question that, as
mentioned earlier, reorganizations contributed to the difficulty in ensuring
complete and accurate grant files and cited transfers of grant files among
grant managers as one reason why files were inaccurate or incomplete. He
pointed out that BJA has made some changes, including the drafting of new
policies and procedures, that are designed to assist

26 For example, the Higher Education Amendments of 1998 established the
Grants to Combat Violence Crime Against Women on Campuses Program (20 U. S.
C. 1152). BJA and VAWO Officials

Acknowledge Lack of Consistent Compliance With OJP Requirements

Page 20 GAO- 02- 25 Justice Discretionary Grants

grant managers in their grant responsibilities. For example, BJA?s draft
procedures called for desk reviews to be performed by grant managers every 6
months or when files were transferred among grant managers. These reviews
were to require that each grant manager fill out a checklist- covering such
things as the completeness of grant paperwork and the timeliness of progress
and financial reports- that upon completion, was to be reviewed by a branch
chief. According to the Acting Director at the time of our review, BJA?s
guidance, which was undated, had been drafted sometime before July 2000, but
had since been subsumed into OJP?s January 2001 update to its grant
monitoring procedures. At the time of our review, it was unclear whether BJA
had put any of these procedures into practice. In commenting on a draft of
this report, the Assistant Attorney General noted that BJA has indicated
that it expects to put these procedures into practice in fiscal year 2002.

In those same comments, the Assistant Attorney General also stated that like
BJA, VAWO has been working on developing policies and procedures for
monitoring grantees more effectively. For example, she stated that a VAWO
Monitoring Working Group was formed in spring 2001. The group is working to
develop a risk- based assessment tool to develop more realistic monitoring
plans; pre-, post-, and on- site protocols for site visits; a standard site
visit report form; and a comprehensive training program on monitoring for
new employees. Also, according to the Assistant Attorney General, VAWO has
developed a desk review checklist that will begin to be used in fiscal year
2002.

OJP requires documentation of grant monitoring activities to provide
assurance to OJP grant managers and supervisors that appropriate oversight
of grant activities is taking place. It is possible that grant managers are
conducting grant monitoring activities even if no documentation exists.
However, without documentation, neither OJP, BJA, VAWO, nor we are
positioned to tell with any certainty whether such monitoring occurred. The
Comptroller General?s internal control standards 27 require that all
transactions and other significant events be clearly documented and that the
documentation be readily available for examination. Appropriate
documentation is an internal control activity to help ensure that
management?s directives are carried out. Without such documentation, OJP,
BJA, and VAWO have no assurance that grants are

27 Standards for Internal Control in the Federal Government (GAO/ AIMD- 00-
21. 3. 1, Nov. 1999).

Page 21 GAO- 02- 25 Justice Discretionary Grants

meeting their goals and funds are being used properly. In addition, such
documentation is essential to systematically address grant performance
problems.

BJA and VAWO are not positioned to systematically determine grant managers?
compliance with monitoring requirements because documentation about
monitoring activities is not readily available. BJA officials told us that
they do not have a management information system to collect and analyze data
that would help them oversee the monitoring process. Instead, they rely on
staff meetings and informal discussions with staff to oversee grant
monitoring activities and identify potential grantee problems. As discussed
earlier, BJA?s Acting Director at the time of our review acknowledged that
BJA had experienced some documentation problems and told us that, in
addition to drafting the aforementioned BJA guidelines, BJA had begun to
modify an officewide management information system to capture data on
monitoring activities. According to BJA officials, the enhanced system is to
enable grant managers to enter data on such activities as site visits and
phone contacts so that they can be tracked. However, at the time of our
field work, the system was still in developmental stages. In commenting on a
draft of this report, the Assistant Attorney General stated that the
monitoring portion of this system was deployed in October 2001.

Like BJA, VAWO does not have an overall management information system to
track monitoring activities. VAWO officials said that they hold weekly staff
meetings during which they rely on their grant managers to proactively
identify and discuss any grant problems or monitoring issues. 28 They added
that VAWO has developed a computerized site visit tracking sheet that
provides information about the details of grant managers? onsite visits. A
VAWO official said that information reported in site visit reports is shared
at staff meetings and is accessible to all staff on VAWO?s internal computer
system. 29 VAWO officials also indicated that they are in

28 In commenting on a draft of this report, the Assistant Attorney General
noted that VAWO staff receive feedback from grantees and those receiving
services from grantees, as well as attend training events in which grantees
participate, all of which assist VAWO staff in monitoring grants.

29 OJP uses site visit data to compile an OJP- wide report for the Attorney
General. However, according to an official, OJP does not uniformly compile
these data for all types of grants awarded by OJP. For example, whereas OJP
reports on VAWO site visits, it does not report on site visits for BJA
discretionary grants. BJA and VAWO Are

Not Positioned to Systematically Determine Staff Compliance With Monitoring
Requirements and Assess Overall Performance

Page 22 GAO- 02- 25 Justice Discretionary Grants

the process of developing a management information system that will track,
in addition to site visits, other monitoring activities such as the
submission of progress and financial reports. However, like BJA, VAWO?s
system was still in the developmental stages at the time of our review.

BJA and VAWO also do not appear to be routinely using available OJPwide data
on late progress and financial reports that could help them identify
potential grantee documentation problems. As mentioned earlier, the Office
of the Comptroller has primary responsibility for carrying out the
monitoring of the fiscal aspects of grants awarded by OJP bureaus and
program offices, and the Control Desk issues monthly reports on whether
grantee progress and financial reports are late. These reports are to be
forwarded to the administrative officers in the bureaus and program offices.
According to OJP?s Chief of Staff at the time of our review, once the
monthly report is distributed, bureaus and program offices are responsible
for determining what action to take regarding delinquent reports. BJA and
VAWO program officials told us that they were aware of the monthly report,
but the Acting Director of VAWO?s Program Management Division told us that
VAWO probably uses the report every other month. A BJA supervisor indicated
that he did not receive the reports, but he could get it, as needed, from
the Office of the Comptroller.

The lack of systematic data associated with program monitoring activities
and the documentation problems we observed raise questions about whether BJA
and VAWO are positioned to measure their performance consistent with the
Government Performance and Results Act of 1993. For example, in its Fiscal
Year 2000 Performance Report and Fiscal Year 2002 Performance Plan, DOJ
articulated a strategic goal to ?prevent and reduce crime and violence by
assisting state, tribal, local and community- based programs.? DOJ?s
performance report and plan list various annual goals and performance
measures along with performance data needed to gauge performance, including
three program targets and performance measures for VAWO formula and
discretionary grant programs. To gauge annual performance for the three VAWO
targets, the plan and report state that needed performance data

 will be obtained from grantee progress reports, on- site monitoring, and
VAWO program office files;

 will be verified and validated through a review of grantee progress
reports, telephone contacts with grantees, and on- site monitoring of
grantee performance by grant program managers; and

 contain no known limitations.

Page 23 GAO- 02- 25 Justice Discretionary Grants

Although the DOJ performance report and plan state that there are no known
data limitations, inconsistent documentation and the lack of systematic data
could be a serious limitation that hinders VAWO?s ability to measure whether
it is achieving its goals. VAWO officials told us that they are not
satisfied with the current performance measures because they do not believe
they are meaningful for measuring program outcomes. They said that they have
begun to work with OJP?s Office of Budget and Management Services and an
outside contractor to develop new measures. They added that their goal is to
have these new measures available for the fiscal year 2003 GPRA performance
plan.

Over the last few years, we and others, including OJP, have identified
various grant monitoring problems among OJP?s bureaus and offices. OJP has
begun to work with its bureaus and offices, such as BJA and VAWO, to address
these problems, but it is too early to tell whether its efforts will be
enough to resolve many of the issues that we and others, including OJP, have
identified.

Since 1996, we have testified and issued reports that document grant
monitoring problems among some of OJP bureaus and offices. In 1996, we
testified on the operations of the Office of Juvenile Justice and
Delinquency Prevention. 30 We found that almost all of the official
discretionary grant files we reviewed contained monitoring plans, but there
was little evidence that monitoring had occurred. More recently, in an
October 2001 report, we observed many of the same issues concerning OJJDP?s
lack of documentation of its monitoring activities. 31 Also, in 1999, we
issued a report that, among other things, addressed how OJP?s Executive
Office for Weed and Seed monitors local Weed and Seed sites to ensure that
grant requirements are met. 32 We found that, during fiscal year 1998,
grantees had not submitted all of the required progress reports and grant
managers had not always documented the results of their on- site monitoring
visits.

30 Juvenile Justice: Selected Issues Relating to OJJDP?s Reauthorization
(GAO/ T- GGD- 96- 103, May 8, 1996). 31 GAO- 02- 65.

32 Federal Grants: More Can Be Done to Improve Weed and Seed Program
Management

(GAO/ GGD- 99- 110, July 16, 1999). OJP?s Efforts to

Resolve Continuing Grant Monitoring Problems

Problems With OJP Grant Monitoring Are Not New

Page 24 GAO- 02- 25 Justice Discretionary Grants

OJP has also identified problems with grant monitoring. In 1996, an OJPwide
working group, established at the request of the Assistant Attorney General,
issued a report on various aspects of the grant process, including grant
administration and monitoring. Among other things, the working group found
that

 the administration of grants, including monitoring, was not standardized
within OJP;

 given the monitoring resources available, monitoring plans were overly
ambitious, the usual result being failure to attain the level of monitoring
indicated in the plans; and

 an OJP- wide monitoring tracking system was needed to document all
monitoring activities on an individual grant and facilitate control of the
monitoring process.

The working group recommended that OJP establish another working group to
develop detailed operating procedures, giving special attention to the issue
of grant monitoring.

Almost 4 years later, in February 2000, Dougherty and Associates, under
contract, delivered a report to OJP containing similar findings. 33 The
report stated that that OJP lacks consistent procedures and practices for
performing grant management functions, including grant monitoring, across
the agency. For example, according to the report, no formal guidance had
been provided to grant managers on how stringent or flexible they should be
with grantees in enforcing deadlines, due dates, and other grant
requirements. Also, the report stated that the official grant files were
often not complete or reliable. To improve grant monitoring, the contractor
recommended, among other things, that OJP develop an agencywide, coordinated
and integrated monitoring strategy; standardize guidelines and procedures
for conducting site- visits, product reviews, and other monitoring
activities; and mandate the timeliness and filing of monitoring reports.

The DOJ?s Office of Inspector General has also identified and reported on
OJP- wide grant management and monitoring problems. For example, in December
2000, the Inspector General identified grant management as one of the 10
major management challenges facing DOJ. The Inspector General

33 Final Report of Findings & Recommendations for Improvement of the Grant
Management Process (Alexandria, VA: Dougherty and Associates, Feb. 2000).

Page 25 GAO- 02- 25 Justice Discretionary Grants

stated that DOJ?s multibillion- dollar grant programs are a high risk for
fraud, given the amount of money involved and the tens of thousands of
grantees. Among other things, the Inspector General said that past reviews
determined that many grantees did not submit the required progress and
financial reports and that program officials? on- site monitoring reviews
did not consistently address all grant conditions.

OJP has begun to work with bureaus and offices to resolve some of the
problems it and others have identified, but it is much too early to tell how
effective these efforts will be in resolving these issues. In its Fiscal
Year 2000 Performance Report and Fiscal Year 2002 Performance Plan developed
under GPRA, OJP established a goal to achieve the effective management of
grants. Among other things, DOJ plans to achieve this goal by continued
progress toward full implementation of a new Grant Management System as a
way of standardizing and streamlining the grant process. According to the
performance report and performance plan, GMS will assist OJP in setting
priorities for program monitoring and facilitate timely program and
financial reports from grantees.

OJP?s Chief of Staff at the time of our review told us that, in his view,
the only way to ensure that staff consistently document their monitoring
activities is to require grant managers to enter information about their
monitoring activities, when they occur, into an automated system, like GMS.
He said that currently, OJP runs the risk of losing or misplacing key
documentation, especially since documents are kept in two files physically
maintained by two organizations in different locations- one, the official
file maintained by the Office of the Comptroller, and the other, the grant
manager?s file maintained by the program office. He said that the new system
currently covers grants for some OJP organizations up to the award stage,
but that OJP?s goal is to include tracking information about all stages of
the grant process from preaward through closeout. 34

Although GMS may ultimately help OJP better manage the grant administration
process, DOJ?s Fiscal Year 2000 Performance Report and Fiscal Year 2002
Performance Plan does not state when GMS will be expanded- either to all of
the OJP components or to include the full range and scope of monitoring
activities. Regarding the latter, OJP?s Director of Office of Budget and
Management Services indicated that it is unlikely that

34 Appendix II illustrates the stages of the grant process. Too Early to
Gauge

Effectiveness of OJP?s Efforts to Resolve Grant Monitoring Problems

Page 26 GAO- 02- 25 Justice Discretionary Grants

GMS will cover the full range of monitoring activities; instead, OJP would
be more likely to develop a monitoring management information system to
capture monitoring data that would link to GMS. 35 The Director said that
OJP has formed an OJP- wide working group to further study data issues
related to monitoring activities, but the group is in its preliminary stages
and has yet to develop a charter to define its activities.

OJP has also been working on two key efforts to enhance its ability to
better control grant administration. One of these initiatives, ?Operation

Closeout,? was a pilot project announced in February 2000 by OJP?s Working
Group on Grant Administration that was to, among other things, accelerate
the grant closeout process through revised closeout guidelines and elevate
the importance of the closeout function as a required procedure in the
administration of grants. 36 In November 2000, the working group announced
that it had realized several of the Operation?s objectives and, working with
the Office of the Comptroller, was able to reduce the backlog of grants,
including some managed by BJA and VAWO, that were eligible to be closed but
had not been closed. According to the Chairman of the working group, this
operation closed out 4,136 outstanding grants over a 6- month period,
resulting in over $30 million in deobligated funds. In September 2001, the
Chairman said that OJP was going to initiate another closeout operation
based on the success of the pilot.

Another OJP initiative involved the development and issuance of new OJPwide
guidance for grant administration, including grant monitoring. As mentioned
earlier, in January 2001, OJP released Grant Management Policies and
Procedures Manual to update and codify OJP?s current policies and procedures
regarding its business practices. 37 According to OJP officials, the new
guidance was developed at the direction of the former Assistant Attorney
General to address overall concerns about weaknesses in the 1992 version.
The guidance was developed over a period of about two years, with the goal
of reengineering the grant management process based on the best practices of
bureaus and offices throughout OJP. For example, the changes include some
provisions pertaining to some of the aforementioned closeout activities--
grantees are

35 In commenting on a draft of this report, the Assistant Attorney General
noted that the Office of the Comptroller already utilizes a financial
monitoring tracking system to manage financial monitoring activities and
capture financial monitoring information.

36 The working group was comprised of staff members from OJP?s bureaus and
offices. 37 This document superseded the 1992 Handbook.

Page 27 GAO- 02- 25 Justice Discretionary Grants

now given 120 days to submit final financial reports (instead of 90 days).
Also, grant managers are given greater latitude to close out a grant if they
have been unsuccessful in obtaining the final financial report from the
grantee.

OJP trained over 300 grant managers during summer 2001 and, according to the
Chairman of the working group, intends to train supervisors about the new
guidance in fall 2001. OJP also has drafted and plans to send a
questionnaire to recently trained grant managers to identify any issues or
problems with using the online manual and to identify potential training
interest and topics. OJP plans to develop and send a similar questionnaire
to supervisors once they are trained. However, the Chairman indicated that
there are no plans to test or systematically monitor compliance with the new
guidelines to ensure that grant managers are fulfilling their
responsibilities. He said that OJP had not contemplated testing or
systematic monitoring because of other initiatives currently under way.

Because BJA and VAWO discretionary grant files were insufficiently
documented neither OJP, BJA, VAWO, or we can determine the level of
monitoring being performed by grant managers as required by OJP and the
Comptroller General?s internal control standards. BJA and VAWO supervisors
rely on staff meetings and discussions with staff to alert them to grantee
problems or grant monitoring issues, but these activities are not sufficient
to ensure that required monitoring is taking place or that the proper
documentation is occurring. Furthermore, BJA and VAWO do not have readily
available data on most monitoring activities that would help them determine
grant managers? compliance with OJP guidelines, and even when data are
available, it is not clear that supervisors use the data to ensure that
monitoring activities occurred. The lack of systematic data, combined with
poor documentation, limits BJA and VAWO?s ability to manage the grant
monitoring process so that they can determine whether grant managers are
monitoring grantees, and if not, why not, or if so, why are they not
documenting their activities. It also hinders BJA and VAWO?s ability to
measure their performance consistent with GPRA, especially given that DOJ is
relying on data collected through grant monitoring to measure the
Department?s performance for many of its grant programs. Furthermore, it
places BJA and VAWO at risk in ensuring that the millions of dollars in
discretionary grant funds that they distribute are effectively and
responsibly managed.

Grant monitoring problems have been long- standing at DOJ, and although OJP
has taken steps intended to resolve some of them, it is too early to tell
whether these steps will effectively solve the types of documentation
Conclusions

Page 28 GAO- 02- 25 Justice Discretionary Grants

problems that we and others have identified. Automation of the grant
management process, particularly in regard to grant monitoring, holds some
promise if OJP takes steps to ensure that all monitoring activities are
consistently recorded and maintained in a timely manner. However, current
and future efforts will be futile unless OJP and its bureaus and offices,
such as BJA and VAWO, periodically test grant manager compliance with OJP
requirements and take corrective actions to enforce those requirements.

To facilitate and improve the management of program monitoring, we recommend
that the Attorney General direct BJA and VAWO to review whether the
documentation problems we identified were an indication of grant monitoring
requirements not being met or of a failure to document activities that did,
in fact, take place. If monitoring requirements are not being met, we
recommend that the Attorney General direct BJA and VAWO to determine why
this is so and to take into account those reasons as they consider solutions
for improving compliance with the requirements. If it is determined that
required monitoring is taking place but is not being documented, we
recommend that the Attorney General take steps to direct BJA and VAWO to
periodically articulate and enforce clear expectations regarding
documentation of monitoring activities.

We also recommend that the Attorney General direct OJP to study and
recommend ways to establish an OJP- wide approach for systematically testing
or reviewing official and program files to ensure that the grant managers in
its various bureaus and offices are consistently documenting their
monitoring activities in accordance with OJP requirements and the
Comptroller General?s internal control standards. Furthermore, we recommend
that the Attorney General direct OJP to explore ways to electronically
compile and maintain documentation of monitoring activities to facilitate
(1) more consistent documentation among grant managers; (2) more accessible
oversight by bureau and program office managers; and (3) sound performance
measurement, consistent with GPRA.

We provided a copy of a draft of this report to the Attorney General for
review and comment. In a November 9, 2001, letter, the Assistant Attorney
General commented on the draft. Her comments are summarized below and
presented in their entirety in appendix III.

The Assistant Attorney General said that overall, the report provides useful
information in highlighting management and monitoring activities in
Recommendations for

Executive Action Agency Comments and Our Evaluation

Page 29 GAO- 02- 25 Justice Discretionary Grants

need of improvement. She noted that BJA and VAWO have already taken steps to
address the recommendations for follow- up action included in the draft
report. For example, the Assistant Attorney General said that BJA has taken
steps to, among other things, expand its grants tracking system to include
tracking of staff and grantee contacts and instituted a policy that a desk
review be conducted twice per year for all grants. With regard to VAWO, the
Assistant Attorney General said that, among other things, VAWO had
established a monitoring working group tasked with developing monitoring
policies and procedures for monitoring grantees more effectively, including
more realistic monitoring plans and a standardized site visit reporting
format.

We acknowledge that BJA and VAWO appear to be taking steps in the right
direction toward resolving some of the issues we identified. However, until
these actions become operational, BJA and VAWO will not be able to determine
whether the problems we identified constitute either a failure to carry out
required monitoring activities or a failure to document monitoring
activities. Once BJA and VAWO make this determination, they will be better
positioned to consider what additional steps need to be taken, such as
articulating and enforcing clear expectations regarding the documentation of
monitoring activities.

In her letter, the Assistant Attorney General did not address our
recommendations that OJP (1) study and recommend ways to establish an OJP-
wide approach for systematically testing or reviewing official and program
grant files or (2) explore ways to electronically compile and maintain
documentation of monitoring activities. Although the steps BJA and VAWO are
taking may help them better understand and act upon problems associated with
the documentation of monitoring activities, the steps discussed in the
Assistant Attorney General?s letter appear to be actions specific to those
organizations. Thus, it is unclear whether and to what extent those actions
can be applied throughout OJP. Without a more focused and concerted effort
to implement an OJP- wide approach for systematically testing or reviewing
program grant files and an automated approach to compile and document
monitoring data, OJP could continue to face the grant monitoring problems we
and others, including OJP, have identified.

In addition to the above comments, the Assistant Attorney General made a
number of suggestions related to topics in this report. We have included the
Assistant Attorney General's suggestions in the report, where appropriate.
Also, the Assistant Attorney General provided other

Page 30 GAO- 02- 25 Justice Discretionary Grants

comments for which we did not make changes. See appendix III for a more
detailed discussion of the Assistant Attorney General's comments.

We are sending copies of this report to the Chairmen of the Senate Judiciary
Committee and its Subcommittee on Youth Violence; Chairmen and Ranking
Minority Members of the House Committee on Education and the Workforce;
Attorney General; OJP Assistant Attorney General; BJA Administrator; VAWO
Administrator; and Director, Office of Management and Budget. We will also
make copies available to others on request.

If you or your staff have any questions about this report, please contact
John F. Mortin or me at (202) 512- 8777. Key contributors to this report are
acknowledged in appendix IV.

Laurie E. Ekstrand Director, Justice Issues

Appendix I: Size and Growth of OJP, BJA, and VAWO Budgets and BJA and VAWO
Discretionary Grant Programs

Page 31 GAO- 02- 25 Justice Discretionary Grants

The Office of Justice Programs (OJP) and its bureaus and offices, including
the Bureau of Justice Assistance (BJA) and the Violence Against Women Office
(VAWO), experienced budget growth in the latter half of the 1990s, following
the passage of the 1994 Crime Act. 1 According to data we obtained from OJP,
in the 1990s, the yearly number of BJA discretionary awards and total dollar
amount of those awards fluctuated somewhat, but generally increased. The
number of Byrne discretionary grant awards have decreased since a high point
in fiscal year 1994; however, the total yearly dollar amount has increased
overall. Furthermore, while the yearly number of Byrne awards and the dollar
amount of those awards generally increased, there were some yearly
decreases. Following the creation of VAWO in 1995, the yearly number of
discretionary awards and total dollar amount of those awards increased
overall.

According to OJP data, from 1990 through 2000, OJP?s budget grew, in
constant fiscal year 2000 dollars, by 323 percent, from about $916 million
in fiscal year 1990 to nearly $3.9 billion in fiscal year 2000. 2 Our
analysis of the OJP data also showed that BJA?s budget grew during the
1990s, but to a lesser extent than OJP?s. BJA?s budget increased by 173
percent, from about $618 million in fiscal year 1990 to nearly $1.7 billion
in fiscal year 2000. In fiscal year 1996, OJP and BJA?s budget increased
sharply after enactment of the 1994 Crime Act. BJA?s budget as a percentage
of OJP?s budget decreased from about 67 percent in fiscal year 1990 to 57
percent in fiscal year 1996. Following its creation in 1995, VAWO?s budget
increased by 42 percent, from $176 million in fiscal year 1996, its first
full year of funding, to about $250 million in fiscal year 2000. 3 Figure 2
shows the growth in overall OJP, BJA, and VAWO budgets, illustrating how BJA
and VAWO fit into the overall OJP budget from fiscal years 1990 through
2000.

1 Violent Crime Control and Law Enforcement Act of 1994 (P. L. 103- 322). 2
All budget figures in this appendix, unless otherwise noted, are adjusted to
constant fiscal year 2000 dollars. 3 VAWO was first funded under the
Violence Against Women Act of 1994, Title IV of the Crime Act (P. L. 103-
322). Appendix I: Size and Growth of OJP, BJA, and

VAWO Budgets and BJA and VAWO Discretionary Grant Programs

Budget Increases at OJP, BJA, and VAWO in the 1990s

Appendix I: Size and Growth of OJP, BJA, and VAWO Budgets and BJA and VAWO
Discretionary Grant Programs

Page 32 GAO- 02- 25 Justice Discretionary Grants

Figure 2: Overall OJP and BJA and VAWO Yearly Budget Resources

Note1: According to OJP budget officials, yearly figures include all funds
appropriated to OJP, transfers from other agencies, and receipts from the
Crime Victim Fund, which is derived not from tax dollars, but from fines and
penalties paid by federal criminal offenders. However, the yearly figures do
not include grants awarded and administered by OJP bureaus and offices for
other federal agencies (including other DOJ agencies) under reimbursable
agreements. Also, the yearly amounts do not include direct appropriations
for OJP management and administration. The large funding increase for fiscal
year 1996 resulted from the Omnibus Consolidated Recissions and
Appropriations Act of 1996, which appropriated funds authorized by the
Violent Crime Control and Law Enforcement Act of 1994.

Note 2: The budget amounts for each fiscal year are adjusted to constant
fiscal year 2000 dollars. Source: OJP Office of Budget and Management
Services.

For this report, we analyzed the growth in the number and dollar amount of
discretionary awards each year by BJA and VAWO from 1990 through 2000, based
on data provided by OJP. From 1990 to 2000, the number of BJA Byrne
discretionary awards increased by about 83 percent- from 54 in fiscal year
1990 to 99 in fiscal year 2000. Overall, the total number of BJA
discretionary awards, including Byrne discretionary awards, increased by
about 320 percent- from 65 in fiscal year 1990 to 273 in fiscal year 2000.
As shown in figure 3, the overall increase in BJA discretionary awards for
the 11- year period we analyzed was moderate, with some yearly decreases.
Discretionary Grant

Award Increases at BJA and VAWO in the 1990s

Appendix I: Size and Growth of OJP, BJA, and VAWO Budgets and BJA and VAWO
Discretionary Grant Programs

Page 33 GAO- 02- 25 Justice Discretionary Grants

Figure 3: Overall Yearly BJA Discretionary Awards

Source: OJP Office of the Comptroller.

Along with the increased number of discretionary awards by BJA, the yearly
total dollar amount of those awards also increased. As illustrated in figure
4 below, the total dollar amount of Byrne discretionary awards increased, in
constant fiscal year 2000 dollars, by 256 percent- from about $19 million in
fiscal year 1990 to almost $69 million in fiscal year 2000. The total dollar
amount of all BJA discretionary awards, including Byrne discretionary
awards, increased even more- by about 422 percent- from just over $36
million in fiscal year 1990 to nearly $189 million in fiscal year 2000. The
increase in the yearly total dollar amount of Byrne discretionary awards was
moderate, with some yearly decreases. For all BJA discretionary awards,
particularly non- Byrne discretionary awards, the total dollar amount
increases were substantial in fiscal years 1998 through 2000. Figure 4 shows
the dollar amount of BJA discretionary awards (Byrne and non- Byrne) from
fiscal year 1990 to 2000.

Appendix I: Size and Growth of OJP, BJA, and VAWO Budgets and BJA and VAWO
Discretionary Grant Programs

Page 34 GAO- 02- 25 Justice Discretionary Grants

Figure 4: Dollar Amount of Overall BJA Discretionary Awards

Note: The award amounts for each fiscal year are adjusted to constant fiscal
year 2000 dollars. Source: OJP Office of the Comptroller.

Data provided by OJP showed that at VAWO, since its inception in 1995, the
yearly total number and dollar amount of its discretionary awards also
increased. As shown in the figures below, the yearly number of VAWO
discretionary awards increased by about 362 percent- from 92 in fiscal year
1996, the first full year of funding to 425 in fiscal year 2000. In
addition, the yearly dollar amount of VAWO discretionary awards increased by
about 940 percent- from just over $12 million in fiscal year 1996, the first
full year of funding, to about $125 million in fiscal year 2000.

Figure 5 shows the number of VAWO discretionary awards for each fiscal year
from 1995 to 2000. Figure 6 shows the dollar amount of VAWO discretionary
awards for the same period.

Appendix I: Size and Growth of OJP, BJA, and VAWO Budgets and BJA and VAWO
Discretionary Grant Programs

Page 35 GAO- 02- 25 Justice Discretionary Grants

Figure 5: Number of Yearly VAWO Discretionary Awards

Source: OJP Office of the Comptroller.

Figure 6: Dollar Amount of VAWO Discretionary Awards

Note: The award amounts for each fiscal year are adjusted to constant fiscal
year 2000 dollars. Source: OJP Office of the Comptroller.

Appendix II: Stages of the Discretionary Grant Process

Page 36 GAO- 02- 25 Justice Discretionary Grants

OJP awards two types of grants: formula and discretionary. OJP formula
grants are awarded directly to state governments, which then make subawards
to state and local unites of government. Discretionary grants can be awarded
to states, local units of government, Indian tribes and tribal
organizations, individuals, educational institutions, private nonprofit
organizations, and private commercial organizations. With some discretionary
grant programs, OJP has some flexibility in selecting topics as well as
grantees. Some discretionary awards are competitive, while others are non-
competitive, owing to limited amount of funds available to a limited number
of potential recipients. Figure 7 summarizes the life of a discretionary
grant from application to closeout.

Figure 7: Life of a Discretionary Grant

Once the application for the discretionary grant is accepted, OJP guidance
requires the grant manager to prepare a grant manager?s memorandum, which
OJP reviews before the award is made. The memorandum is to consist of the
following, among other things:

 an overview of the project;

 a detailed description of what type of activities the grantee plans to
implement;

 a discussion of the financial justification of the grant funds and of the
costeffectiveness evaluation of the application; and

 a discussion of past assessments, where applicable. Appendix II: Stages of
the Discretionary

Grant Process

Grantee activity

is comprised of an implementation plan, milestones, and deliverables.

Grant manager's memorandum

is received, prepared, and approved.

Application Assessment Monitoring/ Progress Requirements include

 Monitoring activities for both initial and supplemental grants, including

 site visits,  desk reviews, and  telephone contacts and  Progress
reports

and financial reports (from the grantee).

Supplemental Award( s) Closeout Supplemental awards

occur at this phase only if requested.

Initial Award Monitoring plan

is a part of the grant manager's memorandum, and it lays out

 the type of monitoring and

 the frequency.

Closeout requirements include

 final financial report; and

 final progress report.

Live Grant

Appendix II: Stages of the Discretionary Grant Process

Page 37 GAO- 02- 25 Justice Discretionary Grants

As part of a grant manager?s memorandum, each grant manager is to prepare a
monitoring plan. The plan is to contain information on who will conduct the
monitoring, how it will be done, and when and what type of monitoring
activities are planned. Monitoring information is to be collected using such
techniques as on- site visits, telephone calls, and desk reviews, which are
reviews to ensure that the grant files are complete and that the grantee is
in compliance with the program guidelines. Also, OJP guidance requires the
grantee to file specific reports with the Office of the Comptroller:
semiannual progress reports that summarize project activities and quarterly
financial reports that provide an accounting of grant expenditures. The
Office of the Comptroller is to forward the reports to grant managers.

OJP is to apply the same process to supplemental awards as it does to the
original award of a grant. When the grantee requests an extension, thus
requiring supplemental funding, the grantee must repeat the award
application process, and more time and money is expended.

At the end of the grant period, the grant manager is required to close out
the grant according to OJP guidance. Closing out grants is the final step in
a process by which OJP ensures that all required financial and progress
reports and a final accounting of federal funds have been received. Figure 8
illustrates the grant process, including supplemental or extended funding.

Appendix II: Stages of the Discretionary Grant Process

Page 38 GAO- 02- 25 Justice Discretionary Grants

Figure 8: Supplemental Award Process and Time Frame 1st Year 2nd Year 3rd
Year 4th Year 5th Year 6th Year 7th Year 8th Year Original

award First

supplemental award Second

supplemental award Third

supplemental award

Time frame Process

Process repeated

Process repeated

Application Assessment

Award Live grant

Supplemental Close out

Application Assessment

Award Live grant

Supplemental Application

Assessment Award

Live grant Supplemental Process

repeated Application

Assessment Award

Live grant Supplemental

Life of a Grant

Appendix III: Comments From the Department of Justice

Page 39 GAO- 02- 25 Justice Discretionary Grants

Appendix III: Comments From the Department of Justice

Note: GAO comments supplementing those in the report text appear at the end
of this appendix.

Appendix III: Comments From the Department of Justice

Page 40 GAO- 02- 25 Justice Discretionary Grants

Appendix III: Comments From the Department of Justice

Page 41 GAO- 02- 25 Justice Discretionary Grants

See comment 5. See comment 4.

See p. 19. See comment 3.

See comment 2. See comment 1.

Appendix III: Comments From the Department of Justice

Page 42 GAO- 02- 25 Justice Discretionary Grants

See comment 7. See comment 2. See footnote 28.

See comment 6.

Appendix III: Comments From the Department of Justice

Page 43 GAO- 02- 25 Justice Discretionary Grants

See p. 20. See comment 8. Now footnote 9.

Appendix III: Comments From the Department of Justice

Page 44 GAO- 02- 25 Justice Discretionary Grants

Now on p. 21. Now on p. 21. See comment 10.

Now on p. 19. Now on p. 19.

See comment 9.

Appendix III: Comments From the Department of Justice

Page 45 GAO- 02- 25 Justice Discretionary Grants

See comment 13. See comment 1.

See comment 12. See comment 11.

See footnote 34. Now on pp. 21- 22. Now on p. 21.

Appendix III: Comments From the Department of Justice

Page 46 GAO- 02- 25 Justice Discretionary Grants

See comment 14. Now on pp. 37- 38.

Now on p. 36.

Appendix III: Comments From the Department of Justice

Page 47 GAO- 02- 25 Justice Discretionary Grants

Appendix III: Comments From the Department of Justice

Page 48 GAO- 02- 25 Justice Discretionary Grants

Appendix III: Comments From the Department of Justice

Page 49 GAO- 02- 25 Justice Discretionary Grants

The following are GAO?s comments on the Department of Justice?s November 9,
2001, letter.

1. We report on the growth in the number and dollar amount of VAWO
discretionary grants since fiscal year 1996 in appendix I (see pp. 34- 35).

2. We have amended the Background section of the report to add this
information (see p. 6).

3. We disagree. As we stated in the report (see p. 2), financial monitoring
was not within the scope of our work. It is important to note that the scope
of our work was based on agreements with our requesters and was not
influenced by whether or not financial monitoring information is included in
OJP?s annual financial statement audit.

4. According to the OJP Handbook: Policies and Procedures for the
Administration of OJP Grants (Feb. 1992), official grant files kept by the
Office of Comptroller Control Desk are to contain documents relating to each
grantee, including progress and financial reports and site visit reports. In
addition, for documentation to be readily available for examination, as
required by the Comptroller General?s internal control standards, keeping
them in the official grant files seems appropriate.

5. As we reported, in our review of closeout procedures, we waited more than
the required 180 days before reviewing grant files to allow sufficient time
for BJA and VAWO to complete the grant closeout process (see footnote 24, p.
18). However, the files we reviewed did not contain the required closeout
documents.

6. As we reported, BJA and VAWO officials told us that supervisors discuss
monitoring activities with staff through informal discussions or meetings,
which could include one- on- one meetings with staff. As we stated, it is
possible that grant managers are conducting grant monitoring activities even
if no documentation exists. However, without documentation, neither OJP,
BJA, VAWO, nor we are positioned to tell with any certainty whether such
monitoring occurred (see pp. 20- 21).

7. We have amended the report to add some of this information (see p. 7). As
discussed in comment 1, we report on the growth in the number GAO Comments

Appendix III: Comments From the Department of Justice

Page 50 GAO- 02- 25 Justice Discretionary Grants

and dollar amount of VAWO discretionary grants in appendix I (see pp. 34-
35).

8. We disagree. Financial monitoring was not part of our review as clearly
stated in our introduction. Therefore, we do not believe that the title of
this section, as stated, implies that financial monitoring was part of our
review.

9. We agree that the grant files did not always contain documentation and
acknowledge that the lack of documentation does not necessarily indicate
whether monitoring did or did not occur. As we stated in comment 6, without
required progress reports and other documentation, neither OJP, BJA, VAWO,
nor we are positioned to tell with any certainty whether such monitoring
occurred.

10. We have amended the report to add most of this information (see p. 20).
A discussion of the development of VAWO?s management information system can
be found on page 21 of the report.

11. As discussed in comment 6 and as we reported, it is possible that grant
managers are conducting grant monitoring activities even if no documentation
exists. However, without documentation, neither OJP, BJA, VAWO, nor we are
positioned to tell with any certainty whether such monitoring occurred.

12. We disagree. As we reported, the Comptroller General?s internal control
standards require that all transactions and other significant events be
clearly documented and that the documentation be readily available for
examination. Appropriate documentation is an internal control activity to
help ensure that management?s directives are carried out. Without such
documentation, OJP, BJA, and VAWO have no assurance that grants are meeting
their goals and funds are being used properly.

13. We have amended the report to incorporate the first of these two changes
(see p. 31). However, as illustrated in figures 3 and 4, the annual number
of Byrne awards and the dollar amount of those awards have generally
increased, although there were some yearly decreases (see pp. 33- 34).

14. We reported that, according to VAWO officials, VAWO grant managers have
sometimes been responsible for additional duties beyond grant monitoring
over the last few years (see p. 19).

Appendix IV: GAO Contacts and Staff Acknowledgments

Page 51 GAO- 02- 25 Justice Discretionary Grants

Laurie E. Ekstrand, (202) 512- 8777 John F. Mortin, (202) 512- 8777

In addition to the above, Kristeen G. McLain, Samuel A. Caldrone, Dennise R.
Stickley, Keith R. Wandtke, Jerome T. Sandau, Michele C. Fejfar, and Ann H.
Finley made key contributions to this report. Appendix IV: GAO Contacts and
Staff

Acknowledgments GAO Contacts Staff Acknowledgments

(182106)

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