U.S. Attorneys: Controls Over Grant-Related Activities Should Be
Enhanced (10-JUN-03, GAO-03-733).
Ninety-three U.S. Attorneys serve 94 judicial districts (the same
U.S. Attorney serves the District of Guam and the District of the
Northern Mariana Islands) under the direction of the Attorney
General. Among other things, the Attorney General expects U.S.
Attorneys to lead or be involved with the community in preventing
and controlling crime including efforts to secure Department of
Justice (DOJ) grant funds and work with grantees. This report
provides information about the guidance U.S. Attorneys are given
in carrying out their responsibilities with regard to DOJ grants.
It makes recommendations to assess compliance with guidance and
to reduce the potential for conflicts of interest.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-03-733
ACCNO: A07133
TITLE: U.S. Attorneys: Controls Over Grant-Related Activities
Should Be Enhanced
DATE: 06/10/2003
SUBJECT: Federal grants
Crime prevention
Grant administration
Conflict of interests
Grant monitoring
DOJ Operation Weed and Seed Program
DOJ Project Safe Neighborhoods
******************************************************************
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GAO-03-733
a
GAO United States General Accounting Office
Report to Congressional Requesters
June 2003 U. S. ATTORNEYS Controls Over Grant- Related Activities Should
Be Enhanced
GAO- 03- 733
U. S. Attorneys* grant activities are guided by legal and ethical
considerations. General guidelines established by the Attorney General in
1994 and revised in 2001 outline how U. S. Attorneys and their staff can
be involved in their community*s crime prevention and control efforts,
including DOJ grant activities. Last year, DOJ issued guidance in response
to U. S. Attorneys* questions about their role in relation to two DOJ
grant programs* Project Safe Neighborhoods and Weed and Seed. In addition,
through its Executive Office for U. S. Attorneys (EOUSA), DOJ provided
training on ethical considerations in dealing with grant applicants and
grantees under both grant programs.
Although EOUSA has an evaluation program to assess and oversee the overall
operations of each U. S. Attorney*s Office, the evaluations are not
designed to assess whether U. S. Attorneys and their staffs are following
the recently established guidelines. Without a mechanism to make this
assessment, EOUSA does not have assurance that DOJ guidance is
adequately understood, has reached all those who are covered by it, and
is correctly applied. In addition, federal regulations and procedures
call for systematic financial disclosure reporting to facilitate the
review of possible conflicts of interest and ensure the efficient and
honest operation of the government. However, while GAO did not identify
any incidences of conflicts of interest, certain individuals* staff in U.
S. Attorneys Offices that work with grantees and nonfederal members of
committees that are appointed by each U. S. Attorney to, among other
things, assess the merits of grant proposals* are not required to disclose
whether they are free from actual or apparent conflicts of interest. Based
on the merits of GAO*s work, DOJ officials stated that they would issue a
directive to require members of these committees to sign a self- certified
conflict of interest statement that is to be held on file subject to DOJ
grant monitoring. Ninety- three U. S. Attorneys serve 94 judicial
districts (the same U. S.
Attorney serves the District of Guam and the District of the Northern
Mariana Islands) under the direction of the Attorney General. Among other
things, the
Attorney General expects U. S. Attorneys to lead or be involved with the
community in preventing and controlling crime including
efforts to secure Department of Justice (DOJ) grant funds and work with
grantees. This report provides information
about the guidance U. S. Attorneys are given in carrying out their
responsibilities with regard to DOJ grants. It makes recommendations to
assess compliance with guidance and to reduce the potential for
conflicts of interest. GAO recommends that the Director of the Executive
Office for U. S. Attorneys take steps to further
mitigate the risk associated with U. S. Attorney involvement in grant
activities by (1) assessing and overseeing compliance with the DOJ
guidance and (2) requiring staff that work on grant- related
matters to certify they are free from conflicts of interest. DOJ reviewed
a draft of this report and had no comments. U. S. ATTORNEYS
Controls Over Grant- Related Activities Should Be Enhanced
www. gao. gov/ cgi- bin/ getrpt? GAO- 03- 733. To view the full report,
including the scope and methodology, click on the link above. For more
information, contact Paul L. Jones at (202) 512- 8777 or jonespl@ gao.
gov. Highlights of GAO- 03- 733, a report to
Congressional Requesters
June 2003
Page i GAO- 03- 733 U. S. Attorneys' Grant Activities Letter 1 Results in
Brief 3 Background 4 DOJ Guidelines Covering U. S. Attorneys* Grant
Activities 7 DOJ Has Not Established Oversight Mechanisms to Assess and
Ensure Compliance with Recent Guidelines 10 Conclusions 17 Recommendations
18 Agency Comments and Our Evaluation 18 Appendix I Summary of Guidelines
Issued for U. S. Attorneys Regarding Grants Awarded under the PSN and Weed
and Seed Programs 19
PSN Grants 19 Weed and Seed Grants 20
Abbreviations
BJA Bureau of Justice Assistance DOJ Department of Justice EARS Evaluation
and Review Staff EOUSA Executive Office for U. S. Attorneys EOWS Executive
Office for Weed and Seed LECC Law Enforcement Coordinating Committee
OIG Office of Inspector General OJP Office of Justice Programs PSN Project
Safe Neighborhoods Contents
This is a work of the U. S. Government and is not subject to copyright
protection in the United States. It may be reproduced and distributed in
its entirety without further permission from GAO. It may contain
copyrighted graphics, images or other materials. Permission from the
copyright holder may be necessary should you wish to reproduce copyrighted
materials separately from GAO*s product.
Page 1 GAO- 03- 733 U. S. Attorneys' Grant Activities
June 10, 2003 The Honorable F. James Sensenbrenner, Jr. Chairman The
Honorable John Conyers, Jr. Ranking Minority Member Committee on the
Judiciary House of Representatives
The Honorable Chris Cannon Chairman The Honorable Melvin Watt Ranking
Minority Member Subcommittee on Commercial and Administrative Law
Committee on the Judiciary House of Representatives
U. S. Attorneys are appointed by the President of the United States, with
advice and consent of the U. S. Senate. Under the direction of the
Attorney General, each of the 93 U. S. Attorneys is the chief federal law
enforcement officer of the United States within his or her particular
jurisdiction. During fiscal year 2002, the Department of Justice (DOJ)
spent about $1.5 billion on its 94 U. S. Attorneys Offices to prosecute
individuals charged with violations of federal criminal law, represent the
government in civil cases, and collect money and property owed to the
government. 1 In addition, U. S.
Attorneys Offices were involved in initiatives to prevent and control
crime in their communities, including some supported by DOJ grant funds.
This report responds to your request that we provide information on U. S.
Attorneys involvement in DOJ grant programs. To address your request, we
are reporting on (1) guidance available to U. S. Attorneys and their
offices in carrying out their responsibilities with regard to DOJ grants
and (2) oversight of those responsibilities by DOJ. To meet our
objectives, we interviewed officials with the Executive Office for U. S.
Attorneys (EOUSA) and Office of Justice Programs (OJP) in Washington, D.
C. and obtained and reviewed information about the guidance available to
and
1 A total of 93 U. S. Attorneys serve 94 districts* the same U. S.
Attorney serves the District of Guam and the District of the Northern
Mariana Islands.
United States General Accounting Office Washington, DC 20548
Page 2 GAO- 03- 733 U. S. Attorneys' Grant Activities
the oversight of U. S. Attorneys Offices in regard to DOJ grant programs.
As agreed with your staff, we also visited 10 of the 94 U. S. Attorneys
Offices and interviewed U. S. Attorneys and their staffs in each office. 2
We performed our work from December 2001 to May 2003 in accordance with
generally accepted government auditing standards.
U. S. Attorneys Offices carry out their grant- related responsibilities
related to two DOJ programs* Project Safe Neighborhoods (PSN) and the Weed
and Seed Program (Weed and Seed). PSN is a multiyear commitment, initiated
by the President and the Attorney General in fiscal year 2001, to take a
comprehensive strategic approach to the enforcement of firearms laws. To
implement this strategy, the Attorney General required each of
the 94 U. S. Attorneys Offices to support, promote, and implement a
comprehensive gun violence reduction program within each local district,
working in partnership with communities and state and local law
enforcement agencies. Under PSN, DOJ*s OJP awards grant funds to
organizations that work with PSN task forces, in coordination with the U.
S. Attorneys Office, to provide support for community outreach, crime
analysis, development of promising gun violence reduction programs, and
juvenile- related firearm reduction programs. Grants are awarded based on
input from the U. S. Attorney and a community based grant selection
committee, which is comprised of nonfederal law enforcement and community
leaders that are appointed by the U. S. Attorney. OJP*s Bureau of Justice
Assistance (BJA) administers the grants awarded to support PSN, including
monitoring grants once they have been awarded. In fiscal year 2002, DOJ
awarded about $65 million for grants to support PSN task forces. DOJ also
expects to award about $60 million in fiscal year 2003 and again in fiscal
year 2004 to support PSN task forces. 3 Weed and Seed is a community
based, multiagency program, initiated in
fiscal year 1991, to *weed out* crime from targeted neighborhoods, then
*seed* the site with a variety of programs and resources to prevent crime
from recurring. Weed and Seed sites are provided grants, technical
assistance, and training to implement programs that will help them deal
2 We visited the Districts of Delaware, Nebraska, Nevada, and South
Carolina, and the Southern District of Indiana; the Western District of
Washington; the Central District of California; the Eastern District of
Pennsylvania; the Western District of Texas; and the Eastern District of
Virginia. 3 PSN funds are also used to fund other PSN grant and nongrant
activities that do not
directly involve support of PSN Task Forces, in coordination with U. S.
Attorneys Offices.
Page 3 GAO- 03- 733 U. S. Attorneys' Grant Activities
with serious crime in their communities. Under the guidance of the U. S.
Attorney, federal, state, and local officials work together at each site
to (1) implement activities designed to reduce drug crimes, gangs, and
other violent crimes in high crime neighborhoods and (2) revitalize those
areas by implementing a range of human service programs and economic
development to keep crimes from recurring. OJP*s Executive Office for Weed
and Seed (EOWS) has overall responsibility for the Weed and Seed Program,
including establishing policy and monitoring Weed and Seed grants. In
fiscal year 2003, DOJ expects to award about $53.9 million for
grants under the Weed and Seed Program. Guidelines established by the
Attorney General in January 2001 encourage U. S. Attorneys to participate
in community crime prevention activities* including those supported by DOJ
grants* through the *establishment of coalitions with the community and
law enforcement as well as strong and real working relationships with
other public and private entities.* In so doing, the guidelines call for
U. S. Attorneys and their staff to remain impartial and to avoid even the
appearance of an involvement with parties and activities that could bring
them into conflict with their official duties. Last year, DOJ published
guidelines for U. S. Attorneys Offices that
specifically focus on their role in PSN and Weed and Seed. In May and
December 2002, DOJ issued guidelines for U. S. Attorneys Offices and PSN
task forces that describe the process they were to follow in securing
grant
funds. Among other things, the guidelines provided U. S. Attorneys Offices
with step- by- step instructions for working with communities to solicit,
review, and select proposals for specific PSN grants, including guidance
on related ethics issues. Also, in December 2002, EOUSA issued guidance
that discussed, among other things, what U. S. Attorneys Offices are to do
when working with local community organizations that are seeking and
administering Weed and Seed grant funds. According to EOUSA officials, the
decision to issue guidance was not prompted by any particular incident;
rather, the guidelines resulted from questions U. S. Attorneys and their
staff raised concerning their roles and responsibilities under the
programs. EOUSA has also provided training on ethical considerations in
dealing with grant applicants and grantees under both programs and have
developed a video that discusses various aspects of the PSN grant
application process, including the ethical considerations facing each U.
S. Attorneys Office as they deal with PSN grants.
An effective internal control process is one that provides management with
a reasonable level of assurance that agency operating, financial, and
compliance objectives are being systematically achieved. DOJ components
Results in Brief
Page 4 GAO- 03- 733 U. S. Attorneys' Grant Activities
have not established oversight mechanisms to assess and ensure compliance
with the PSN and Weed and Seed guidelines they issued last year. Although
EOUSA has an evaluation program to assess and oversee the overall
operations of each U. S. Attorneys Office* including operations associated
with the management of the PSN and Weed and Seed
Programs* the evaluations are not designed to assess whether U. S.
Attorneys and their staffs are following the guidance recently
established. Federal regulations and procedures also call for systematic
financial disclosure reporting to, among other things, facilitate the
review of possible conflicts of interest to guarantee the efficient and
honest operation of the government. However, EOUSA and BJA have not
established a reporting mechanism for employees of U. S. Attorneys Offices
that work with grantees and nonfederal appointees to PSN grant selection
committees to provide management assurance that these individuals are free
from actual or apparent conflicts of interest. EOUSA officials
acknowledged that U. S. Attorneys* Offices staff could face possible
conflicts in their dealings with grantees and said they would consider
ways in which staff could periodically report on any personal, financial,
or business relationships they might have involving nonfederal individuals
or organizations. Likewise, based on our work, BJA officials
said that they would issue a directive that requires selection committee
appointees to submit a signed self- certified conflict of interest
statement that will be kept on file for oversight by BJA grant monitors.
We are recommending that the Attorney General instruct the Director of
EOUSA and U. S. Attorneys to take steps to (1) assess and oversee
compliance with PSN and Weed and Seed guidelines and (2) require financial
disclosure reporting for U. S. Attorneys* staff that work with community
organizations on grant- related matters.
We provided a draft of this report to the Attorney General for comment.
DOJ did not have any comments on this report.
U. S. Attorneys serve as the nation*s principal litigators under the
direction of the Attorney General. U. S. Attorneys conduct most of the
trial work in which the United States is a party. Under Title 28 U. S. C.
547, U. S. Attorneys have three statutory responsibilities:
prosecute criminal cases brought by the federal government Background
Page 5 GAO- 03- 733 U. S. Attorneys' Grant Activities
prosecute and defend civil cases in which the United States is a party,
and
collect debts owed the federal government that are administratively
uncollectible. EOUSA was established to provide a liaison between DOJ in
Washington, D. C., and the 93 U. S. Attorneys. EOUSA provides each U. S.
Attorney and the 94 U. S. Attorneys Offices general executive assistance
and direction, policy development, administrative management and
oversight, operational support, and coordination with other components of
DOJ and other federal agencies. In fiscal year 2002, U. S. Attorneys*, and
EOUSA*s budgets were about $1.5 billion and $64.6 million, respectively.
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. 4 Staff of
the bureaus and program offices develop OJP grant programs, accept and
review applications, make grant awards, and manage and monitor grantees
until the award is closed out. In fiscal year 2002, OJP*s budget was about
$4.3 billion. According to OJP and EOUSA officials, U. S. Attorneys and
their staff
currently are involved in two DOJ programs involving OJP grants* PSN and
Weed and Seed. As mentioned earlier, BJA is responsible for national
administration and management of grants awarded under the PSN initiative.
PSN, which was initiated in fiscal year 2001 by the President and the
Attorney General, was designed to commit more than $900 million over
a 3- year period to hire new federal and state prosecutors, support 4
OJP*s bureaus and program offices are Bureau of Justice Assistance, Bureau
of Justice Statistics, National Institute of Justice, Office of Juvenile
Justice and Delinquency Prevention, Office for Victims of Crime, Office of
Police Corps and Law Enforcement Education, and Community Capacity
Development Office (including the Executive Office
for Weed and Seed). OJP
Page 6 GAO- 03- 733 U. S. Attorneys' Grant Activities
investigators, provide training, and develop and promote community
outreach efforts all with the goal of focusing community attention and
energy on reducing gun violence. 5 Under the program, U. S. Attorneys were
to take the lead in mobilizing federal, state, and local officials in
their districts by establishing PSN task forces to develop comprehensive
gun violence reduction strategies or review and enhance existing
strategies.
PSN task forces are to implement these strategies, in part, through the
use of various OJP grants awarded in each U. S. Attorney*s district. These
OJP grants are the (1) Research Partner/ Crime Analyst Grants to support
the strategic planning and accountability portion of PSN, (2) Media
Outreach and Community Engagement Grants to help task forces in their
community outreach initiatives, (3) Project Sentry Grants to help task
forces address local juvenile related gun crimes, and (4) Open
Solicitation Grants to support comprehensive and innovative approaches to
reduce gun violence in local communities.
EOWS is responsible for providing national leadership as well as
management and administration of the Weed and Seed Program, which in
fiscal year 2002 had a budget of about $59 million. Under the program, U.
S. Attorneys are to serve as both the main contact to Weed and Seed sites
for EOWS and as facilitator of the program*s community based coordination
efforts. Accordingly, U. S. Attorneys are to work with local stakeholders
to develop and implement a community based, multiagency strategy that
proposes to *weed out* crime from targeted neighborhoods, then *seed* the
site with a variety of programs and resources to prevent crime from
recurring. 6 In fiscal year 2002, there were about 229 Weed and Seed sites
and the average grant awarded per site was about $200,000. 5 Under P. L.
106- 553 EOUSA allocated 163 new positions, 113 of which were for
attorneys to prosecute firearms violations in 62 of the 94 judicial
districts to support PSN. In addition, in February 2002, the Attorney
General assigned a new prosecutor to 93 of the 94 districts and placed 1
position in EOUSA to further support the program. 6 A central tenant of
the Weed and Seed Program is for local Weed and Seed sites to develop
partnerships among federal, state, and local governments and private
sector agencies to leverage federal Weed and Seed grant funds with
additional resources from these partners to promote weeding and seeding
activities. These additional resources are intended to help the site
achieve the goal of becoming self- sustaining without Weed and Seed grant
funds.
Page 7 GAO- 03- 733 U. S. Attorneys' Grant Activities
Guidelines first established by the Attorney General in 1994 stated that
U. S. Attorneys and their staff may be involved in their community*s crime
prevention and control efforts* including efforts to secure DOJ grant
funds and work with grantees* as long as they subscribe to legal and
ethical considerations. DOJ components have recently issued related
guidelines for U. S. Attorneys and their staff that, among other things,
focuses specifically on their dealings with grant applicants and grantees
under the PSN and Weed and Seed Programs. According to EOUSA officials,
DOJ issued program specific guidelines in response to the numerous
questions by U. S. Attorneys and their staff concerning their role in
relation to PSN and Weed and Seed.
U. S. Attorneys are encouraged to be involved in community based
activities that seek and secure DOJ grant funds as long as they and their
staff subscribe to legal and ethical considerations commensurate with
being a government employee, an attorney, and U. S. Attorney. 7 According
to guidelines established by the Attorney General in 1994 and revised in
January 2001, U. S. Attorneys are encouraged to engage in community based
crime prevention and control activities and form coalitions with
nonfederal, community based organizations, private entities, and law
enforcement because *promoting crime prevention initiatives enhances the
presence of the Department of Justice in communities around the country
and has proven effective in reducing crime.* The guidelines state
7 Federal conflict of interest rules are published at 18 U. S. C. S: 208
and implementing regulations at 5 C. F. R. S: 2635.402. Essentially, these
rules prohibit employees from taking official action in a particular
matter involving any entity in which they, or someone whose interests are
imputed to them, have a financial interest. Imputed interests include (1)
the interests of the employee*s spouse; (2) minor children; (3) a general
partner; (4) an organization in which the employee is serving as an
officer, director, trustee, general
partner, or employee; or (5) any person or organization with whom the
employee is negotiating or has any arrangement concerning prospective
employment. In addition, Federal Standards of Conduct prohibit employees
from acting in a particular matter that
involves a financial interest of a member of their household or if it
involves a person with whom the employee has a *covered relationship* (5
C. F. R. S: 2635.502). Covered relationship is defined to include (1) a
person with whom the employee conducts business other than routine
consumer transactions; (2) a person who is a member of the employees
household, or who is a relative with whom the employee has a close
personal relationship; (3) a person for whom the employee*s spouse,
parent, or dependent child is serving or seeking to serve as an officer,
director, trustee, general partner, agent attorney, consultant,
contractor, or employee; (4) any person for whom the employee has served,
within the last year, as officer, director, trustee, general partner,
agent attorney, consultant, contractor, or employee; and (5) an
organization in which the employee is an active participant. DOJ
Guidelines
Covering U. S. Attorneys* Grant Activities
Attorney General Guidelines Encourage U. S. Attorneys to Be Active in
Community Based Programs Involving DOJ Grants
Page 8 GAO- 03- 733 U. S. Attorneys' Grant Activities
that, when working with nonfederal entities in implementing crime
prevention initiatives, U. S. Attorneys and their staff are to
remain impartial in carrying out their official duties and be careful to
avoid the appearance of partiality;
consider conflicts of interest statutes when crime prevention activities
involve persons or organizations with whom they have a personal,
financial, or business relationship; and
avoid participation in coalitions that include individuals and
nonfederal organizations that may be victims, witnesses, subjects, or
targets in matters pending in their districts.
Thus, under the Attorney General*s guidelines, U. S. Attorneys may convene
meetings with other potential coalition participants to discuss operating
needs, program initiatives, event planning, and other related matters, but
they are to avoid participating in budget decisions of a coalition,
including decisions regarding the expenditure of funds that could create
the appearance that the U. S. Attorney is managing an entity outside of
DOJ. Also, according to the guidelines, U. S. Attorneys may
endorse specific coalition- based program initiatives as long as they
refrain from endorsing specific organizations; give presentations about
coalition initiatives at fund- raising events as long as the presentation
addresses official DOJ issues and does not solicit contributions; and
participate in public service announcements with other coalition members
when the
purpose of the announcement is to further DOJ*s mission and coalition
initiatives.
With regard to grants, the guidelines state that U. S. Attorneys may
provide potential grant applicants with public information regarding
sources of federal funding and respond to inquiries regarding the grant
application process. Furthermore, they may draft a letter of
recommendation to OJP supporting a grant application. According to the
guidelines, this letter can identify the applicant*s accomplishments and
may express the U. S. Attorney*s views on whether government program funds
should or should not be granted to a particular applicant. However, U. S.
Attorneys* names are not to appear on grant applications unless required
by law, and U. S. Attorneys are not to otherwise contact federal agencies
on behalf of an applicant seeking federal grant monies.
Page 9 GAO- 03- 733 U. S. Attorneys' Grant Activities
DOJ components involved in the PSN and Weed and Seed Programs have taken
steps to provide specific guidance to U. S. Attorneys and their offices in
carrying out their grant- related responsibilities. In May 2002, EOUSA
told U. S. Attorneys and their staff that BJA had published Web based
guidelines for U. S. Attorneys Offices and PSN task forces to instruct
them about their role in the process to solicit, review, and select grant
proposals. According to the memorandum issued by EOUSA*s Director, the
guidance was designed to provide step- by- step instructions on the grant
process that included guidance about specific ethics issues. In December
2002, EOUSA told U. S. Attorneys and their staff about new PSN guidelines*
again including guidance about ethics issues* designed to cover grants to
be awarded in fiscal year 2003. During the same month, the EOUSA Director
sent a memorandum to all U. S. Attorneys, their senior
staff, and Law Enforcement Coordinating Committee (LECC) Coordinators
about U. S. Attorneys Offices* responsibilities in implementing the Weed
and Seed Program, including how to deal with ethics concerns related to
Weed and Seed grant activities. 8 Appendix I provides greater detail on
the guidelines DOJ components issued for U. S. Attorneys Offices on PSN
and Weed and Seed during calendar year 2002. According to EOUSA officials,
the decision to issue guidelines for each
program resulted from DOJ*s overall effort to develop the PSN Program.
EOUSA*s Deputy Legal Counsel in EOUSA*s Office of Legal Counsel said that
the PSN guidance was not prompted by any particular incident; rather, it
was developed in response to numerous questions about PSNrelated ethics
issues from U. S. Attorneys and their staff as the program was being
developed. The Deputy Legal Counsel said the exercise, combined with
similar questions by U. S. Attorneys and their staff subsequently prompted
EOUSA to develop the December 2002 guidance for the Weed and Seed Program.
EOUSA*s Deputy Legal Counsel also said that EOUSA has provided ethics
training to U. S. Attorneys and their staff on their roles and
responsibilities
8 According to EOUSA, there are currently 87 LECC Coordinators nationwide.
LECC Coordinator positions are classified under the General Schedule as
GS- 12 and GS- 13 Law Enforcement Coordination Specialists. According to
EOUSA officials, LECC responsibilities for the PSN and Weed and Seed
Program can vary from district to district, as determined by the U. S.
Attorney and for Weed and Seed sites, the LECC is the individual from the
district that works most closely with the sites, acting as EOWS* direct
contact with the site. Regarding PSN, EOUSA officials said that the LECC
Coordinator is able to use contacts with law enforcement, including those
made through Weed and Seed, to act as a liaison between law enforcement
and other PSN participants or partners. DOJ Has Recently Published
Guidelines for
U. S. Attorney Offices Related to PSN and Weed and Seed Activities
Page 10 GAO- 03- 733 U. S. Attorneys' Grant Activities
as it relates to grants offered and awarded under both programs. In
January 2002, EOUSA provided a presentation to U. S. Attorneys at the
first national PSN conference and in April 2002, EOUSA provided the same
presentation for each districts* LECC Coordinators at a similar
conference. The presentation included a discussion of what U. S. Attorneys
and their
staff can and cannot do when participating in the grant process. The
Deputy Legal Counsel said that ethics training pertinent to the Weed and
Seed Program was also provided to LECCs during October 2002. Also, in
December 2002, EOUSA produced and disseminated a video that discussed the
process U. S. Attorneys are to follow when working with PSN task forces
during the grantee selection and application process.
EOUSA*s Legal Counsel and Deputy Legal Counsel also indicated that they
believe that training, available guidance on ethics issues, and staff
awareness about standards of conflicts and actual or apparent conflicts of
interest are sufficient to ensure that ethical lapses will not occur. They
said that they were unaware of any ethical lapses and said that if
questions were raised, DOJ*s Office of Inspector General (OIG) would
investigate them. OIG staff we contacted who were responsible for dealing
with ethical issues at DOJ said they were aware of only one complaint
involving a U. S. Attorney and the Weed and Seed Program and none
regarding PSN.
An effective internal control process is one that provides management with
a reasonable level of assurance that agency operating, financial, and
compliance objectives are being achieved on a systematic basis. EOUSA has
an evaluation program to assess and oversee the overall operations of each
U. S. Attorneys Office* including operations associated with the
management of the PSN and Weed and Seed Programs* but the evaluations are
not designed to assess compliance with the PSN and Weed and Seed
guidelines recently issued. Similarly, federal regulations and procedures
call for systematic financial disclosure reporting to, among other things,
facilitate the review of possible conflicts of interest to guarantee the
efficient and honest operation of the government. However, DOJ has not
established a financial disclosure reporting mechanism for certain
individuals* employees of U. S. Attorneys Offices that work with grantees
and potential grantees and nonfederal appointees to PSN grant selection
committees* to provide management assurance that these individuals are
free from actual or apparent conflicts of interest. DOJ Has Not
Established Oversight Mechanisms to Assess and Ensure Compliance with
Recent Guidelines
Page 11 GAO- 03- 733 U. S. Attorneys' Grant Activities
According to the Comptroller General*s Standards for Internal Control in
the Federal Government, 9 internal control activities are the policies,
procedures, techniques, and mechanisms that enforce management*s
directives. They include, for example, steps to set the specific standards
or criteria to be achieved by staff as well as steps that provide
management the information to determine on a routine basis whether the
standards are being met and to take corrective action when they are not.
EOUSA has an evaluation program to assess and oversee the overall
operations of each U. S. Attorneys Office that includes an assessment of
the office*s involvement in and performance related to the Weed and Seed
and PSN Programs. However, the evaluations are not designed to assess
compliance with the Weed and Seed and PSN guidance related to ethical
concerns that EOUSA recently issued.
Under 28 C. F. R. Part 0.22, EOUSA is to evaluate the performance of the
U. S. Attorneys Offices, make appropriate reports, and take corrective
actions if necessary. EOUSA*s Evaluation and Review Staff (EARS) is
responsible for the evaluation program, which, according to EOUSA, is an
internal review program designed, among other things, to examine
management controls and prevent waste, loss, unauthorized use, or
misappropriation in federal programs, as required under the Federal
Manager*s Financial Integrity Act. EARS evaluations are conducted in each
of the 94 U. S. Attorneys Offices every 3 years by teams of experienced
Assistant U. S. Attorneys, and administrative and financial litigation
personnel from other U. S. Attorneys Offices. 10 According to EOUSA*s
Assistant Director for EARS, these assessments focus on personnel,
management, and workload issues in individual U. S. Attorneys Offices and
include, among other things, an assessment of the management and
operations of the local Weed and Seed and PSN Programs.
9 U. S. General Accounting Office, Standards for Internal Control in the
Federal Government, GAO/ AIMD- 00- 21. 3.1 (Washington, D. C.: November
1999), which was issued under 31 U. S. C. 3512 (formerly known as the
Federal Manager*s Financial Integrity Act), established the framework for
internal (or management) control in the federal government. An effective
internal control process is one that provides management with a reasonable
level of assurance that agency operating, financial, and compliance
objectives are being achieved on a systematic basis.
10 EOUSA officials told us that, in fiscal year 2001, EARS teams conducted
evaluations in 30 U. S. Attorneys Offices. EARS teams also conducted 32
follow- up reviews in other offices to ensure that issues identified in
earlier visits were resolved. EOUSA Does Not Assess
Compliance with Recent PSN and Weed and Seed Guidelines
Page 12 GAO- 03- 733 U. S. Attorneys' Grant Activities
Our review of EARS guidelines show that when evaluating the management of
the PSN and Weed and Seed Programs in U. S. Attorneys Offices, review
teams were to focus on task force or committee management issues rather
than compliance with the guidelines recently published. For example, the
template for the PSN part of the EARS review instructs EARS reviewers to
examine, among other things, whether the PSN strategy had been
implemented. If so, evaluators were instructed to provide information on a
variety of matters, including
the names of the PSN coordinators and the litigation units, sections, or
branch offices where they serve;
the nature of the partnerships that have been developed with federal,
state, and local law enforcement and whether the partnerships are
districtwide or tailored to meet the individual needs or problems facing
branch offices;
the community outreach activities associated with PSN; the number of
specially allocated attorney and support staff positions
allocated to the office and whether they have been filled; and examples
of successes achieved under the program. For the Weed and Seed Program,
the template instructs review teams to
respond to the following five questions: Does the district have a funded
Weed and Seed Program? If so,
describe the site, its organization, committees, management, programs, and
initiatives.
Who in the U. S. Attorneys Offices supervises and works with the Weed
and Seed Program?
What is the U. S. Attorneys* role in the Weed and Seed Program? What
other U. S. Attorneys Offices staff, such as the LECC or Assistant
U. S. Attorneys have a role in the Weed and Seed Program? Do you know of
any problems or concerns with the Weed and Seed
Program? EOUSA*s Assistant Director for EARS said that reviews for both
programs were broad based management reviews and were not designed to be
Page 13 GAO- 03- 733 U. S. Attorneys' Grant Activities
audits of the programs. The Assistant Director also said that there are
plans to revise the PSN part of EARS to include an evaluation of gun-
crime data that is to be reported to the Attorney General twice yearly,
but there are no similar plans to revise the Weed and Seed part of EARS.
Regarding the recently issued PSN and Weed and Seed guidelines, the
Assistant
Director said that there are no plans to revise EARS to assess compliance
with the guidelines and determine whether they are working as intended.
Staff in U. S. Attorneys Offices can be delegated responsibility to lead
or
work with community organizations that receive Weed and Seed grant funds,
but these staff are not required to file disclosure forms. These forms
might reveal relationships that could be actual or potential conflicts of
interest. According to 5 C. F. R. 2634. 904, each officer or employee
whose position is classified at GS- 15 or below or at a rate of pay that
is less than 120 percent of the minimum rate of pay for GS- 15, is
required to file a confidential financial disclosure report if the agency
concludes that the duties and responsibilities of the employee*s position
require the employee to:
participate personally and substantially through decision or exercise of
judgment, in taking a government action regarding contracting or
procurement; administering or monitoring grants, subsidies, licenses, or
other federal conferred financial or operational benefits; regulating or
auditing any nonfederal entity; or other activities in which the final
decision or action will have a direct and substantial economic effect on
the interests or nonfederal entity or
avoid involvement in a real or apparent conflict of interest, and to
carry out the purpose behind any statute, executive order, rule, or
regulation applicable or administered by that employee.
According to 5 C. F. R. 2634.901, these reports are designed to (1) assist
an agency in administering its ethics program and counseling its employees
and (2) facilitate the review of possible conflicts of interest to
guarantee the efficient and honest operation of the government. 11 11
According to this regulation, the purpose of such reporting is to
complement the public
reporting system established by the Ethics in Government Act of 1978, as
amended, which requires that high- level officials in the executive branch
report certain financial interests publicly to ensure that every citizen
can have confidence in the integrity of the federal government. U. S.
Attorney Staff That Work with Grantees Not
Required to File Confidential Financial Disclosure Forms
Page 14 GAO- 03- 733 U. S. Attorneys' Grant Activities
During our review, we examined the most recent summary of EARS reports
dated between June 1997 and April 2000, for the 10 U. S. Attorneys Offices
we visited. In some of these districts, U. S. Attorneys participated on
the Weed and Seed steering committee, while in others, Assistant U. S.
Attorneys or LECC Coordinators were delegated responsibility for working
with Weed and Seed committees, and according to one report, *run* the Weed
and Seed Program. None of the EARS reports addressed any involvement with
the PSN program because when the reviews were completed, PSN had not been
implemented. Our work in the 10 districts also showed that 9 of the
districts had active Weed and Seed sites in place, and in some districts,
new Weed and Seed sites were under consideration.
Among the districts that had active Weed and Seed sites, some of the U. S.
Attorneys told us that they actively worked with Weed and Seed committees,
whereas others delegated responsibility to an Assistant U. S. Attorney or
to LECC Coordinators. For example, in one district the LECC Coordinator
represented the U. S. Attorney on the Weed and Seed committee, while in
another district the LECC Coordinator helped manage the Weed and Seed
sites day- to- day operations.
Given recent EOUSA, BJA, and EOWS efforts to publish PSN and Weed and Seed
guidelines and train U. S. Attorneys and their staff about ethical
concerns, we asked if U. S. Attorneys and their staff that deal with
potential grant applicants and grantees were required to file financial
disclosure statements. They provided information, published on DOJ
internal Web pages, which showed that under current DOJ guidelines:
U. S. Attorneys, Assistant U. S. Attorneys in supervisory positions,
Senior Litigation Counsels, Special Government Employees, and Schedule C
employees are required to file a Public Financial Disclosure Report within
30 days of assuming their covered position and annually thereafter.
Page 15 GAO- 03- 733 U. S. Attorneys' Grant Activities
All line Assistant U. S. Attorneys and special Assistant U. S. Attorneys
are required to file a Confidential Conflict of Interest Certification
Form to certify that they have no conflict of interest in each matter they
undertake. 12 Employees occupying positions in which they exercise
significant
judgment on matters that have an economic effect on the interests of a
nonfederal entity are required to file a confidential financial disclosure
report within 30 days on entering a covered position and every year by
October 31, including positions where duties involve contracting,
procurement, administering grants, regulating, or auditing a nonfederal
entity or other activities in which the final decision or action will have
a direct and substantial economic effect on the interests of any
nonfederal entity.
EOUSA*s Deputy Legal Counsel also told us that LECC Coordinators and
Assistant U. S. Attorneys that work with organizations involving grantees
are not required to file confidential disclosure forms because they are
not responsible for administering or monitoring grants. The Deputy Legal
Counsel pointed out that employees in U. S. Attorneys Offices are not
supposed to monitor grants. The Deputy Legal Counsel said that the Weed
and Seed guidelines instruct employees to not act on behalf of EOWS;
rather, they are to notify EOWS of any issues that may arise during the
course of the grant relationship and EOWS is to handle the matter under
its own procedures. Nonetheless, the Deputy Legal Counsel acknowledged
that U. S. Attorneys Office staff that work with grantees under the Weed
and Seed Program might encounter situations that could be perceived as
real or apparent conflicts of interest. Furthermore, the Deputy Legal
Counsel and EOUSA*s Deputy Director said that, based on our inquiry, it
might be worthwhile considering a change to procedures so that LECC
Coordinators would be required to file confidential disclosure statements.
The Deputy Legal Counsel added that Assistant U. S. Attorneys are already
required to file the confidential certification form for each matter they
are involved with and was not clear whether involvement in a community
12 According to EOUSA officials, in 1994, the Office of Government Ethics
approved DOJ*s use of the Confidential Conflict of Interest Certification
Form in lieu of a confidential financial disclosure report. According to
DOJ*s internal Web site that discusses the form, the form is designed to
continually impress on each Assistant U. S. Attorney the affirmative duty
of complying with all ethics laws and regulations. DOJ requires that
Assistant U. S. Attorneys assigned to each case complete the form and
maintain it in the case file.
Page 16 GAO- 03- 733 U. S. Attorneys' Grant Activities
Weed and Seed activity related to grants would constitute a matter covered
by the certification form. 13 In developing the PSN grant program, BJA
modeled the PSN selection
committee process after its peer review process, where peer review
committees are used to assess the merits of the grant application and make
recommendations about worthy grant applications. However, whereas BJA has
established a process to screen peer reviewers for actual or apparent
conflicts of interest before they are appointed to peer review committees,
it has not established a similar process for members of PSN selection
committees.
According to a BJA project manager, BJA uses a multistep process to screen
potential peer reviewers for conflict of interest in reviewing
applications for grants. BJA hires a peer review contractor who is
responsible for conducting a preliminary screening of potential peer
reviewers for conflicts of interest based on guidelines established by
BJA. Once past the preliminary screening, peer reviewers are asked to
selfidentify any conflicts of interest by signing a certification
statement.
EOUSA*s PSN coordinator told us that BJA has delegated its peer review
authority to U. S. Attorneys and, as discussed earlier, BJA has issued
guidance that includes the steps the U. S. Attorneys are to follow when
appointing members of the selection committee* peer reviewers for PSN
grants. BJA*s guidance states that the selection committee can include any
or all of the other members of the PSN task force, except the U. S.
Attorney, a member of his or her staff, or any federal employee, as long
as their participation does not represent an actual or apparent conflict
of interest. The guidance further reminds the U. S. Attorneys that the
Standards of Conduct and Conflict of Interest Rules that apply to him or
her and their staff also apply to members of the selection committee.
However, unlike the peer review process employed by BJA for other grant
programs, U. S. Attorneys are not required to screen the selection
13 During our review, we also noted that the U. S. Attorney manual
specifically calls for the staff of U. S. Attorneys Offices to file
confidential financial disclosure forms if they review grant applications.
The manual uses Weed and Seed grants as an example. EOUSA*s Deputy Legal
Counsel told us that this provision would not apply to the staff of U. S.
Attorneys Offices because they do not review grant applications.
Subsequent to that conversation, EOUSA*s Deputy Director told us that,
since the language in the U. S. Attorney*s manual was inaccurate, EOUSA
had removed the language from the manual. PSN Selection Committee
Members Are Not Screened for Actual or Apparent Conflicts of Interest
Page 17 GAO- 03- 733 U. S. Attorneys' Grant Activities
committee members they appoint for actual or apparent conflicts of
interests, nor are committee members asked to self- identify any actual or
apparent conflicts of interest.
Our discussions with BJA and EOUSA officials responsible for PSN indicated
that the lack of a mechanism for identifying actual or apparent conflicts
of interest among selection committee members was not a problem because
they believe (1) appointees from these organizations would likely be
covered by their own ethical guidance governing their capacity as a
selection committee member and (2) the geographic area covered by
individual PSN grants is so small that local jurisdictions would
not select someone to serve on the selection committee that has a vested
interest in who the grants are awarded to. BJA*s Director of the Programs
Division told us that, when BJA developed the guidelines for PSN selection
committees, BJA had not thought of including a requirement that selection
committee members submit a signed self- disclosure conflict of interest
statement. The Director of the Programs Division said that, based on our
inquiry it might be useful to include some type of requirement for
conflict of interest reporting to add an additional level of assurance
about the integrity of the PSN Program. Accordingly, in April 2003, the
Director, BJA Programs Division, said that BJA would issue a directive
requiring PSN fiscal agents to collect a signed self- certified conflict
of interest statement from PSN selection committee members. Fiscal agents
would be required to maintain the statements on file subject to BJA review
in their capacity
as grant monitors. DOJ efforts to provide guidance to U. S. Attorneys
Offices regarding their involvement in activities associated with grants
awarded under the PSN and Weed and Seed Programs are notable. However, as
U. S. Attorneys and their staff become more heavily involved in these
grant programs, they could increasingly encounter actual or apparent
conflicts of interest that could undermine the integrity of the programs
both within districts and nationwide. Without a mechanism for monitoring
U. S. Attorneys Offices* compliance with available guidance, DOJ does not
have reasonable assurance that its steps taken to date* such as the
issuance of guidance, ethics training, and video presentations* are
adequately understood and have reached all those who are covered by this
guidance. DOJ components, such as EOUSA and BJA, are also not positioned
to determine (1) if the guidelines are correctly applied and actually and
systematically achieving the end result of preventing actual or apparent
ethical conflicts or (2) whether guidelines related to grant activities
could be clarified, strengthened, or improved. In addition, the absence of
Conclusions
Page 18 GAO- 03- 733 U. S. Attorneys' Grant Activities
confidential financial disclosure reporting for U. S. Attorneys Office
employees that work with grantees hinders the U. S. Attorneys ability to
(1) fully administer these programs in the context of ethics
considerations
and (2) identify possible conflicts of interest to guarantee the efficient
and honest operation of the government. We recommend that the Attorney
General instruct the Director of EOUSA and U. S. Attorneys to take steps
to further mitigate the risk associated with U. S. Attorneys Offices*
involvement in the grant components of the PSN and Weed and Seed Programs.
Specifically, we recommend that EOUSA and U. S. Attorneys (1) establish a
mechanism to assess and oversee compliance with recently issued guidelines
pertaining to the grant activities of U. S. Attorneys Offices and ensure
that the guidelines are working as intended and (2) require that U. S.
Attorneys* staffs who work with community organizations on grant- related
matters be required to file financial disclosure reports certifying that
they are free from conflicts of
interest. On May 13, 2003, we requested comments on a draft of this report
from the Attorney General. On May 19, 2003, Department of Justice
officials informed us that they had no comments on the report.
Copies of this report will be made available to other interested parties.
This report will also be available on the GAO Web site at http:// www.
gao. gov.
If you have any questions, please contact my Assistant Director, John F.
Mortin, or me at (202) 512- 8777. You may also contact Mr. Mortin at
mortinj@ gao. gov, or me at jonespl@ gao. gov. Key contributors to this
report were Daniel R. Garcia, Grace Coleman, and Maria Romero.
Paul L. Jones Director, Homeland Security and Justice Recommendations
Agency Comments and Our Evaluation
Appendix I: Summary of Guidelines Issued for U. S. Attorneys Regarding
Grants Awarded under the PSN and Weed and Seed Programs
Page 19 GAO- 03- 733 U. S. Attorneys' Grant Activities
The following paragraphs summarize the guidelines the Department of
Justice (DOJ) issued for U. S. Attorneys and their staff during calendar
year 2002 regarding their role in working with grants and grantees awarded
under the Project Safe Neighborhoods (PSN) and Weed and Seed Programs.
During 2002, DOJ issued two sets of guidelines for U. S. Attorneys and PSN
task forces in carrying out their responsibilities under PSN. Under the
May 2002 PSN guidelines, each U. S. Attorneys Office was instructed to
work with interested federal, state, and local officials to form a PSN
task force, chaired or co- chaired by the U. S. Attorney, to develop a
comprehensive
strategic plan. As part of this process, the task force was to formulate
its overall mission and goals after which the U. S. Attorney was
instructed to designate a selection committee to (1) review eligible grant
proposals and (2) select a single grantee for Research Partner/ Crime
Analyst and Media Outreach and Community Engagement grants funded in
fiscal year 2002. The guidelines stated that the selection committee was
not to include
members of the U. S. Attorneys* staff, but could include other members of
the task force as long as their participation did not represent an actual
or apparent conflict of interest. In addition, the guidelines instructed
the U. S. Attorney to
certify to the selection committee, based on the recommendations of the
task force, whether potential grantees are suitable candidates for federal
funding 1 and
convey the committee*s choice to the Bureau of Justice Assistance (BJA),
along with a letter from the U. S. Attorney, certifying that (1) the
potential grant recipient is free from allegations of criminal misconduct
and current investigation and (2) the applicant*s proposal supports the
PSN task force activities, missions, and goals.
In December 2002, the Executive Office for U. S. Attorneys (EOUSA)
announced that BJA had issued similar guidelines for reviewing and
selecting applicants for grants funded in fiscal year 2003. As before, U.
S. Attorneys and their staff were instructed to work with the PSN task
force and, among other things, the U. S. Attorney was to designate a
selection
1 The U. S. Attorney was to certify to the selection committee before the
committee reviewed and selected potential grantees. Appendix I: Summary of
Guidelines Issued
for U. S. Attorneys Regarding Grants Awarded under the PSN and Weed and
Seed Programs
PSN Grants
Appendix I: Summary of Guidelines Issued for U. S. Attorneys Regarding
Grants Awarded under the PSN and Weed and Seed Programs
Page 20 GAO- 03- 733 U. S. Attorneys' Grant Activities
committee* not comprised of the U. S. Attorneys* staff or federal
employees* to choose a grantee. Unlike the earlier guidelines, the
selection committee was to (1) choose a single grantee to act as fiscal
agent for the PSN strategy and (2) determine what portions of the PSN
strategy should be funded and to whom after the grant proposal had been
approved by BJA. 2 BJA*s guidelines for both fiscal years also included
hyperlinks to guidance EOUSA had issued for U. S. Attorneys and their
staff earlier in the year. EOUSA*s guidelines were similar to the Attorney
General*s guidelines, but they focused specifically on numerous ethics and
legal issues they need to consider in relation to their involvement with
the PSN Program. For example, similar to the Attorney General*s guidelines
discussed earlier, U. S. Attorneys are expected to express their views if
there is any reason why a particular applicant is an inappropriate
candidate for PSN funds, but they are prohibited from appearing before the
Office of Justice Programs on behalf of an applicant seeking grant monies
associated with PSN.
In December 2002, EOUSA also issued guidance that outlined the roles and
responsibilities of U. S. Attorney*s and their staff regarding the Weed
and Seed Program. 3 Similar to the Attorney General*s and EOUSA*s PSN
ethics guidelines, EOUSA*s Weed and Seed guidance covered topics ranging
from working with nonprofit organizations to prohibitions against
fundraising and listed what activities U. S. Attorneys and their staff can
perform in support of the Weed and Seed Program. In regard to grants, the
guidance stated that U. S. Attorneys and their staff may, among other
things
2 According to BJA guidelines, the selection committee may select any
government agency* such as a state agency or local jurisdiction* or a
legal nonprofit organization to be the fiscal agent. The guidelines stated
that selection committees are free to select any organization or establish
a new nonprofit agency. However, the guidelines encouraged
selection committees to select established organizations that have
experience administering grant funds. According to BJA, the grant funds,
once awarded by BJA, may be used for any number of purposes* such as
targeting new prosecutors to key areas or augmenting task force research
and outreach efforts* consistent with the local PSN
strategy and at the discretion of the selection committee. 3 EOWS had
guidance in place for the process to be followed in securing and
administering Weed and Seed grants, but the guidance was not directed at
U. S. Attorneys Offices. Rather, it was designed to assist communities and
stakeholders in their efforts to secure grant funding under the Weed and
Seed Program and briefly discussed the role of the U. S. Attorney in that
process. Weed and Seed Grants
Appendix I: Summary of Guidelines Issued for U. S. Attorneys Regarding
Grants Awarded under the PSN and Weed and Seed Programs
Page 21 GAO- 03- 733 U. S. Attorneys' Grant Activities
serve as that chair or co- chair of the Weed and Seed Steering
Committee; certify to the Executive Office for Weed and Seed (EOWS) via
a *letter
of intent* that a potential Weed and Seed site can receive *official
recognition;* that is the site has developed a strategy sufficient to make
them eligible to apply for a Weed and Seed grant; review Official
Recognition applications and prepare a cover letter for
submission to EOWS supporting the site and its strategy; review funding
applications to ensure technical accuracy and
consistency with the Weed and Seed strategy; sign a statement of support
for the Weed and Seed strategy; and supervise the site, as chair or co-
chair of the steering committee,
throughout the life of the initiative. The Weed and Seed guidelines also
instructed U. S. Attorneys that, among other things, they may not become
advocates for individual grant applicants; communicate with or appear
before any federal agency on behalf of a nonprofit organization; or draft
grant proposals or applications. Furthermore, U. S. Attorneys were told
that they are authorized to assist EOWS in monitoring the performance of
the project under the grant to ensure federal grant dollars are not
misused, but they are not to act on EOWS* behalf. The guidelines stated
that U. S. Attorneys are to inform EOWS of site implementation problems or
irregularities to enable EOWS to take appropriate action.
(440169)
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