Office of Justice Programs: Problems with Grant Monitoring and	 
Concerns about Evaluation Studies (07-MAR-02, GAO-02-507T).	 
								 
The Office of Justice Programs (OJP) provides grants to state and
local governments, universities, and private foundations, to help
prevent and control crime, administer justice, and assist crime  
victims. OJP bureaus and program offices award both formula and  
discretionary grants. The monitoring of grant activities is a key
management tool to ensure that funds awarded to grantees are	 
being properly spent. Over the last few years, GAO 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 to address these problems, but its too early 
to tell whether its efforts will be enough to resolve many of the
issues identified.						 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-02-507T					        
    ACCNO:   A02868						        
  TITLE:     Office of Justice Programs: Problems with Grant	      
Monitoring and Concerns about Evaluation Studies		 
     DATE:   03/07/2002 
  SUBJECT:   Grant monitoring					 
	     Formula grants					 
	     Discretionary grants				 
	     Federal aid for criminal justice			 
	     Byrne Children at Risk Program			 
	     DOJ Edward Byrne Memorial State and		 
	     Local Law Enforcement Assistance Formula		 
	     Grant Program					 
								 

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GAO-02-507T
     
United States General Accounting Office

GAO Testimony

Before  the Subcommittee  on  Crime, Committee  on the  Judiciary,  House of
Representatives

For Release on Delivery Expected at 10:00 a.m.,

Thursday, March 7, 2002

OFFICE OF JUSTICE

PROGRAMS

Problems with Grant Monitoring and Concerns about Evaluation Studies

Statement of Laurie E. Ekstrand, Director, Justice Issues

GAO-02-507T

Mr. Chairman and Members of the Subcommittee:

I am pleased to be here today to discuss our work on the Office of Justice
Programs (OJP). During the last 5 years, we have reported on a number of
programs run by OJP bureaus and offices. An overarching theme of these
reviews is a need for improvements in monitoring and evaluating the myriad
grant programs that OJP oversees. Our work has shown longstanding problems
with OJP grant monitoring and has begun to raise questions about the
methodological rigor of some of OJP's impact evaluation studies. Monitoring
and evaluation are the activities that identify whether programs are
operating as intended, whether they are reaching those that should be
served, and ultimately whether they are making a difference in the fight
against crime and delinquency. In other words, these are major elements of
assessing results. Our recent work has focused mostly on discretionary grant
programs administered by the Bureau of Justice Assistance (BJA), the
Violence Against Women Office (VAWO), the Office of Juvenile Justice and
Delinquency Prevention (OJJDP), the Executive Office for Weed and Seed
(EOWS), and the Drug Courts Program Office (DCPO). We have also examined
National Institute of Justice (NIJ) impact evaluations of some of these
programs.

OJP, the grant making arm of the Department of Justice (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 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 OJP's five bureaus-including BJA, NIJ, and OJJDP-as well
as its seven program offices, including VAWO, the Executive Office for Weed
and Seed (EOWS), and the Drug Courts Program Office. 1

1 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 and Alaska Native Affairs Desk, Violence Against
Women Office, Executive Office for Weed and Seed, Corrections Program
Office, Drug Courts Program Office, Office for Domestic Preparedness, and
Office of Police Corps and Law Enforcement Education. Appendix I shows OJP's
current organizational structure.

Background

OJP bureaus and program offices award two types of grants: formula and
discretionary. Formula grants are awarded to state governments, which then
make subawards to state and local units of government. Discretionary grants
can be awarded on a competitive and non-competitive basis directly to
states, local units of government, Indian tribes and tribal organizations,
individuals, educational institutions, private nonprofit organizations, and
private commercial organizations. Bureaus and program offices, like BJA,
VAWO, and OJJDP are, together with OJP's Office of the Comptroller,
responsible for monitoring OJP's discretionary grants to ensure that they
are being implemented as intended, responsive to grant goals and objectives,
and compliant with statutory regulations and other policy guidelines. NIJ is
OJP's principal research and development agency and awards grants for the
research and evaluation of many of OJP's grant programs. OJJDP also funds
research and evaluation efforts associated with the juvenile justice system.

Between fiscal years 1990 and 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

The monitoring of grant activities is a key management tool to help ensure
that funds awarded to grantees are being properly spent. 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 to address these problems, but it is too early
to tell whether its efforts will be enough to resolve many of the issues
identified.

OJP's Efforts to Resolve Continuing Grant Monitoring Problems

                           Problems with OJP Grant
                           Monitoring Are Not New

Since 1996, we have testified and issued reports that document grant
monitoring problems among some of OJP's bureaus and offices. In November
2001, in response to a request by Senators Sessions and Grassley, we
reported that grant files for discretionary grants awarded by VAWO and under
BJA's Byrne Program often lacked the documentation necessary to ensure that
required monitoring activities occurred.3 In

2 Appendix II shows the growth of OJP's budget between fiscal years 1990 and
2000, and Appendix III shows OJP's fiscal year 2000 budget broken out by
Bureaus and Program Offices.

3U.S. General Accounting Office, Justice Discretionary Grants: Byrne Program
and Violence Against Women Office Grant Monitoring Should Be Better
Documented, GAO-02-025 (Washington, D.C.: Nov. 28, 2001).

October 2001, at the request of Congressman Schaffer, we cited similar
problems with the monitoring of OJJDP discretionary grants-problems
consistent with the lack of OJJDP monitoring documentation we reported in
May 1996.4 For example, our review of grant files for a representative
sample of OJJDP, BJA Byrne, and VAWO discretionary grants active in all of
fiscal years 1999 and/or 2000 showed the following:

* BJA and VAWO grant files did not always contain requisite grant monitoring
plans, whereas OJJDP grant files generally did. When monitoring plans were
in the files, grant managers from the three organizations did not
consistently document their monitoring activities, such as site visits,
according to the monitoring plans they developed.

* A substantial number of OJJDP, BJA Byrne, and VAWO grant files did not
contain progress and financial reports sufficient to cover the entire grant
period, contrary to OJP guidelines. Furthermore, Byrne and VAWO grantee
progress and financial reports were often submitted late by grantees. These
reports are an important management tool to help managers and grant monitors
determine if grantees are meeting program objectives and financial
commitments.

* BJA Byrne, VAWO, and OJJDP grant files did not always contain the required
closeout documents-key documents by which OJP ensures that, among other
things, the final accounting of federal funds have been received.

We concluded that neither OJP, OJJDP, BJA, VAWO, nor GAO can determine the
level of monitoring performed by grant managers as required by OJP and the
comptroller general's internal control standards, which call for
documentation of all transactions and other significant events to ensure
that management directives are being carried out.5 We recommended that
OJJDP, BJA, and VAWO review why documentation problems occurred and take
steps to improve their documentation of grant monitoring. We also
recommended that OJP (1) study and recommend ways to establish an approach
to systematically test or review grant files to ensure consistent
documentation across OJP and (2) explore ways to electronically compile and
maintain documentation of monitoring

4U.S. General Accounting Office, Juvenile Justice: Better Documentation of
Discretionary Grant Monitoring is Needed, GAO-02-65 (Washington, D.C.: Oct.
10, 2001) and Juvenile Justice: Selected Issues Relating to OJJDP's
Reauthorization, GAO/T-GGD-96-103 (Washington, D.C.: May 8, 1996).

5U.S. General Accounting Office, Internal Control: Standards for Internal
Control in the Federal Government, GAO/AIMD-00-21.3.1 (Washington, D.C.:
Nov. 1999).

activities to facilitate more consistent documentation, more accessible
management oversight, and sound performance measurement.

Also, in 1999, our report on the management of the Weed and Seed Program
showed similar results.6 Among other things, EOWS did not always ensure that
local Weed and Seed sites met critical requirements- almost one half of 177
sites funded in fiscal year 1998 had not submitted all of the required
progress reports. Furthermore, while EOWS was to conduct site visits at all
Weed and Seed sites, EOWS monitors did not always document the results of
these visits. We concluded that EOWS lacked adequate management controls
over its grant monitoring process and recommended that EOWS improve program
monitoring to ensure that sites meet grant requirements for submitting
progress reports and EOWS document site visits.

Our work has also shown that others, including OJP itself and the DOJ Office
of the Inspector General, have identified problems with grant monitoring.
Our November 2001 report discussed that, in 1996, an OJP-wide working group
reported on various aspects of the grant process, including grant
administration and monitoring. Among other things, the working group found
that grant monitoring was not standardized in OJP; given available
resources, monitoring plans were overly ambitious, resulting in failure to
achieve the level of monitoring articulated; and an OJP-wide tracking system
was needed to 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 grant monitoring.

Almost 4 years later, in February 2000, an independent contractor delivered
a report to OJP containing similar findings.7 The report stated that OJP
lacked consistent procedures and practices for performing grant management
functions, including grant monitoring, across the agency. For example, the
contractor found that (1) no formal guidance had been provided grant
managers about how stringent or flexible they should be with grantees in
enforcing deadlines, due dates, and other grant requirements and (2) grant
files were often not complete or reliable. The

6U.S. General Accounting Office, Federal Grants: More Can Be Done to Improve
Weed and Seed Program Management, GAO/GGD-99-110 (Washington, D.C.: July 16,
1999).

7Dougherty and Associates, Final Report of Finding & Recommendations for
Improvement of the Grant Management Process (Alexandria, VA, 2000).

contractor recommended that, among other things, OJP develop an agencywide,
coordinated and integrated monitoring strategy; standardize procedures for
conducting site visits and other monitoring activities; and mandate the
timeliness and filing of monitoring reports.

Finally, the DOJ Office of the Inspector General has identified and reported
on OJP-wide monitoring problems and has identified grant management as one
of the 10 major management challenges facing DOJ. In December 2000, the
inspector general 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
reviews did not consistently address all grant conditions.

Too Early to Gauge Effectiveness of OJP's Efforts to Resolve Grant
Monitoring Problems

We reported in November 2001 that OJP had begun to work with bureaus and
offices to resolve some of the problems it and others have identified, but
it was 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 the Government Performance and Results
Act of 1993, 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, the grant management system will
assist OJP in setting priorities for program monitoring and facilitate
timely program and financial reports from grantees.

At the time of our review, the new system covered grants for some
organizations up to the award stage. Since then, OJP has created a chief
information officer position charged with planning and implementing an
agency-side grant management system. According to the assistant attorney
general, the new system is envisioned to produce reports in response to
informational requests, provide information pertaining to grantees and all
resources provided by OJP, and maintain information from the opening to the
closing of a grant award. Although the assistant attorney general said that
OJP will consider the comptroller general's internal control standards in
taking these steps, it is unclear whether the new system will include the
full range and scope of monitoring activities.

We also reported that OJP had been working on two other key efforts. 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 revising
closeout guidelines and elevating the importance of the closeout function as
a required procedure in the administration of grants. By November 2000, OJP
reported that this operation closed out 4,136 outstanding grants over a
6-month period, resulting in over $30 million in deobligated funds. As of
September 2001, OJP had plans to initiate another closeout operation based
on the success of the pilot.

Another OJP initiative involved the issuance of new OJP-wide guidance for
grant administration, including grant monitoring. In January 2001, OJP
released its Grant Management Policies and Procedures Manual to update and
codify OJP's policies and procedures regarding its business practices. 8
According to OJP officials, the new guidance was developed to reengineer the
grant management process based on the best practices of bureaus and offices
throughout OJP. At the time of our review, OJP had trained over 300 grant
managers and had plans to train supervisors about the new guidance. OJP also
had planned to send a similar questionnaire to recently trained grant
managers and supervisors, respectively, to identify any issues or problems
with using the new manual and to identify potential training interest and
topics. However, there were no plans to test or systematically monitor
compliance with the new guidelines to ensure that grant managers were
fulfilling their responsibilities.

OJP's bureaus and program offices have told us that they recognize that they
need to take some steps to respond to our recent recommendations, but it is
too early to tell if these actions will be effective. For example, in
response to our November 2001 report on the monitoring of Byrne and VAWO
discretionary grants, BJA said that it had, among other things, (1) modified
its internal grant tracking system to include tracking of events such as
site visits, phone contacts involving staff and grantees, and grant
closeouts and (2) developed more specific guidance for grantees on
completing progress reports to ensure more specific performance data are
obtained. VAWO said it had begun to develop both an internal monitoring
manual that would include procedures for development of monitoring plans
using a risk-based assessment tool and a management information

8 This  document superseded  OJP Handbook:  Policies and Procedures  for the
Administration of OJP Grants (Washington, D.C., 1992).

system that will eventually track the submission of progress and financial
reports.

Likewise, in response to our October 2001 report on OJJDP grant monitoring,
OJJDP officials said they conducted an internal assessment of grant
monitoring activities and established an OJJDP standard for grant
administration and monitoring; a protocol for adhering to the standard; and
a set of tools for grant administration and monitoring. OJJDP said that it
anticipates OJJDP-wide implementation during fiscal year 2002. Finally, with
respect to our 1999 Weed and Seed report, EOWS said it recognizes the need
to improve program monitoring-citing that it has a chronic problem of
grantees not submitting programmatic progress reports in a timely manner-and
acknowledged the need to document all monitoring visits. In a July 2000
letter, EOWS officials said that EOWS had taken steps to improve program
monitoring, including documentation of site monitoring visits.

Concerns about Impact Evaluation Studies

We have also issued reports questioning the methodological rigor of impact
evaluation studies of various OJP grant programs. Impact evaluations are
intended to assess the net effect of a program by comparing program outcomes
with an estimate of what would have happened in the absence of the program.

Today, we are issuing a report on work undertaken at the request of Senators
Sessions and Grassley concerning the methodological rigor of impact
evaluations of a Byrne grant program and three VAWO discretionary grant
programs.9 During fiscal years 1995 through 2001, NIJ awarded about $6
million for 5 Byrne and 5 VAWO discretionary grant program evaluations. Of
the 10 program evaluations, all 5 VAWO evaluations were intended to measure
the impact of the VAWO programs. One of the 5 Byrne evaluations was designed
as an impact evaluation. Our in-depth review of the 4 impact evaluations
that have progressed beyond the formative stage showed that only 1 of these,
the evaluation of the Byrne Children at Risk (CAR) Program, was
methodologically sound.

9U.S. General Accounting Office, Justice Impact Evaluations: One Byrne
Evaluation Was Rigorous; All Reviewed Violence Against Women Office
Evaluations Were Problematic, GAO-02-309 (Washington, D.C.: Mar. 7, 2002).

The other 3 evaluations, all of which examined VAWO programs, had
methodological problems that raise concerns about whether the evaluations
will produce definitive results. Although program evaluation is an
inherently difficult task, in all 3 VAWO evaluations, the effort is
particularly arduous because of variations across grantee sites in how the
programs are implemented. In addition, VAWO sites participating in the
impact evaluations have not been shown to be representative of their
programs, thereby limiting the evaluators' ability to generalize results.
Further, the lack of nonprogram participant comparison groups hinders their
ability to minimize the effects of factors that are external to the program
and isolate the impact of the program alone. In some situations, other means
(other than comparison groups) can be effective in isolating the impact of a
program from other factors. However, in these evaluations, effective
alternative methods were not used. In addition, data collection and
analytical problems (e.g. related to statistical tests, assessment of
change) compromise the evaluators' ability to draw appropriate conclusions
from the results.

We have made a recommendation in relation to the two VAWO impact evaluations
in the formative stage of development, and for all future impact
evaluations, to ensure that potential methodological design and
implementation problems are mitigated. The assistant attorney general
commented that she agreed with the substance of our recommendations and has
begun or plans to take steps to address them. It is still too early to tell
whether these actions will be effective in preventing or resolving the
problems we identified, but they appear to be steps in the right direction.

Our in-depth review of 10 of OJJDP's impact evaluations of its own programs
undertaken since 1995 also raised some concerns about whether many of the
evaluations would produce definitive results. We reported these concerns in
an October 2001 report, requested by Congressman Schaffer, on OJJDP grantee
reporting requirements and evaluation studies.10 At the time of our review,
all of the 10 evaluations were ongoing, with 5 in their formative stages and
5 well into implementation. As in the report cited above, we noted that some
of the evaluations we reviewed were particularly difficult to design because
sites varied in how they implemented the same program. While these
variations were intended to

10U.S. General Accounting Office, Juvenile Justice: OJJDP Reporting
Requirements for Discretionary and Formula Grantees and Concerns About
Evaluation Studies, GAO-02-23 (Washington, D.C.: Oct. 30, 2001).

allow communities to tailor programs to meet their unique needs, they will
make it difficult to interpret evaluation results when the studies are
completed. Two of the evaluations that were in their later stages and 3 of
those that were in their formative stages at the time of our review lacked
specific plans for comparison groups, which would aid in isolating the
impacts of the program from the effects of other factors that may have
influenced change. Furthermore, 3 of the 5 evaluations that were well into
implementation at the time of our review had developed data collection
problems.

We recommended in our report that OJJDP assess the 5 impact evaluations that
were in their formative stages to address potential comparison group and
data collection problems and initiate any needed interventions to help
ensure the evaluations produce definitive results. In commenting on a draft
of our report, the assistant attorney general said the report is an
important tool that OJP would use to improve the quality of its evaluations
and to design programs to achieve greater impact. Furthermore, OJP will
assess the five impact evaluations in their formative stages, as we
recommended. Two months after our report's issuance, OJP reported to us on
the status of these evaluations. OJP informed us that OJJDP had decided to
discontinue 1 evaluation that had planned to use a comparison group because
of delays and difficulties in identifying a comparison site. In addition,
OJJDP is considering scaling back and refocusing the scope of another
evaluation because the program being studied did not lend itself to an
impact evaluation with comparison groups.

We have also reported on problems with evaluation studies of federally
funded drug court programs.11 In our 1997 report to the House and Senate
Judiciary Committees,12 we found, among other things, that differences and
methodological limitations in existing drug court evaluation studies did not
permit firm conclusions to be made on the overall impact or

11The main purpose of a drug court program is to use the authority of the
court to reduce crime by changing defendants' substance abuse or risk
behavior. Under this concept, in exchange for the possibility of dismissed
charges or reduced sentences, defendants are diverted to drug court programs
in various ways and at various stages in the judicial process. Judges
preside over drug court proceedings; monitor the progress of defendants; and
prescribe sanctions and rewards as appropriate in collaboration with
prosecutors, defense attorneys, treatment providers, and others.

12U.S. General Accounting Office, Drug Courts: Overview of Growth,
Characteristics, and Results, GAO/GGD-97-106 (Washington, D.C.: July 31,
1997).

effectiveness of drug court programs. We recommended that future drug court
program impact evaluations, funded by DOJ and others, be required to include
post-program data and comparison groups within their scope. The preliminary
results of our ongoing follow-up work on drug court programs for Senators
Grassley and Sessions indicate that various administrative and research
factors have hampered NIJ's efforts to complete a national impact evaluation
study, and that alternative plans for addressing the impact of federally
funded drug court programs, if implemented, are not expected until year
2007. As a result, DOJ will continue to lack near term information that the
Congress, the public, and other program stakeholders may need to determine
the overall impact of federally funded drug court programs and to assess
whether these programs are an effective use of federal funds. We expect to
issue a report on this issue in April 2002.

In summary, OJP's grant programs have grown rapidly during the last decade,
increasing the importance of ensuring that they are achieving intended
results. Yet, repeated GAO reviews of grant monitoring and impact
evaluations across a variety of OJP entities have shown a need for
improvement. OJP itself and the DOJ Office of the Inspector General have
identified a need for improvements in grant management as well.

Despite past commitments to shore up grant monitoring and better assess
program results, we have still found problems in very recent reports. The
recent reorganization plans and the anticipated management information
system have been cited as the foundation for positive changes in grants
management, including monitoring and evaluation. But, reorganization and
management information systems are only tools and are only as good as the
management that wields them. Commitment to improvement and oversight are
needed to ensure progress. Chairman Smith has recently requested an
assessment of NIJ's impact evaluation studies. This work may lead to
additional recommendations related to OJP grant evaluations.

Mr. Chairman, this concludes my prepared statement. I would be pleased to
answer any questions that you or other members of the subcommittee may have.

For further information regarding this testimony, please contact Laurie E.
Ekstrand or John F. Mortin at (202) 512-8777. Individuals making key
contributions to this testimony included James Blume, Dan Harris, Charles
Johnson, Weldon McPhail, Wendy Simkalo, Lori Weiss, Jared Hermalin, Rochelle
Burns, Jenna Battcher, and Kimberly Hutchens.

                     Appendix I: OJP Organization Chart

 Note: The organization chart is current as of March 2002. Source: Prepared
                     by GAO based on OJP documentation.

Appendix II: OJP's Budget

Note: Annual totals include Crime Victims Fund collections and Public
Safety Officers' Benefits Program and exclude Management and Administration.

Source: OJP Office of Budget and Management Services.

Appendix III: OJP's FY 2000 Budget by Program Office and Bureau

           Source: OJP Office of Budget and Management Services.

Related GAO Products

Justice Impact Evaluations: One Byrne Evaluation Was Rigorous; All Reviewed
Violence Against Women Office Evaluations Were Problematic, GAO-02-309
(Washington, D.C.: March 7, 2002).

Justice Discretionary Grants: Byrne Program and Violence Against Women
Office Grant Monitoring Should Be Better Documented, GAO-02-25 (Washington,
D.C.: November 28, 2001).

Juvenile Justice: OJJDP Reporting Requirements for Discretionary and Formula
Grantees and Concerns About Evaluation Studies, GAO-02-23 (Washington, D.C.:
October 30, 2001).

Juvenile Justice: Better Documentation of Discretionary Grant Monitoring Is
Needed, GAO-02-65 (Washington, D.C.: October 10, 2001).

Internal Control: Standards for Internal Control in the Federal Government,
GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999).

Federal Grants: More Can Be Done to Improve Weed and Seed Program
Management, GAO/GGD-99-110 (Washington, D.C.: July 16, 1999).

Drug Courts: Overview of Growth, Characteristics, and Results,
GAO/GGD-97-106 (Washington, D.C.: July 31, 1997).

Juvenile Justice: Status of Delinquency Prevention Program and Description
of Local Projects, GAO/GGD-96-147 (Washington, D.C.: August 13, 1996).

Juvenile Justice: Selected Issues Relating to OJJDP's Reauthorization,
Tï¿½GAO/GGD-96-103 (Washington, D.C.: May 8, 1996).

OJJDP Discretionary Grant Programs, GAO/GGD-96-111R (Washington, D.C.: May
7, 1996).

Drug Courts: Information on a New Approach to Address Drug-Related Crime,
GAO/GGD-95-159BR (Washington, D.C.: May 22, 1995).

Office of Justice Programs: Discretionary Grants Reauthorization,
GAO/GGD-93-23 (Washington, D.C.: November 20, 1992).
*** End of document. ***