Grants Management: EPA Needs to Strengthen Efforts to Provide the
Public with Complete and Accurate Information on Grant		 
Opportunities (03-FEB-05, GAO-05-149R). 			 
                                                                 
The Environmental Protection Agency (EPA) has faced persistent	 
challenges for many years in managing its grants, which 	 
constitute over one-half of the agency's budget, or about $4	 
billion annually. Among other things, EPA has been criticized for
not always promoting competition in awarding grants, including	 
not completely and accurately announcing grant opportunities to  
the public and potential applicants. One avenue EPA uses to	 
inform the public about grant opportunities is the Catalog of	 
Federal Domestic Assistance (CFDA), the federal government's	 
listing of available grants and other federal funding		 
opportunities. EPA's Office of Grants and Debarment (OGD), among 
other things, develops grants policy and guidance and compiles	 
grant information for the CFDA. OGD has taken several steps to	 
address criticism regarding the lack of complete and accurate	 
information in the CFDA. In this context the Chairman, Senate	 
Committee on Environment and Public Works, asked us to determine 
whether EPA is providing complete and accurate information on	 
grant opportunities to the public in the CFDA.			 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-05-149R					        
    ACCNO:   A16816						        
  TITLE:     Grants Management: EPA Needs to Strengthen Efforts to    
Provide the Public with Complete and Accurate Information on	 
Grant Opportunities						 
     DATE:   02/03/2005 
  SUBJECT:   Grants						 
	     Grant administration				 
	     Data integrity					 
	     Research programs					 
	     Government information dissemination		 
	     Management information systems			 
	     Prioritizing					 
	     Appropriated funds 				 
	     Environmental monitoring				 
	     GSA Catalog of Federal Domestic			 
	     Assistance 					 
                                                                 

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GAO-05-149R

United States Government Accountability Office Washington, DC 20548

February 3, 2005

The Honorable James M. Inhofe Chairman, Committee on Environment

and Public Works United States Senate

Subject: Grants Management: EPA Needs to Strengthen Efforts to Provide the
Public with Complete and Accurate Information on Grant Opportunities

Dear Mr. Chairman:

The Environmental Protection Agency (EPA) has faced persistent challenges
for many years in managing its grants, which constitute over one-half of
the agency's budget, or about $4 billion annually. Among other things, EPA
has been criticized for not always promoting competition in awarding
grants, including not completely and accurately announcing grant
opportunities to the public and potential applicants. Informing the public
about grant opportunities provides greater assurance that EPA will receive
proposals from a large and varied pool of eligible and highly qualified
applicants who otherwise might not have known about grant opportunities.
One avenue EPA uses to inform the public about grant opportunities is the
Catalog of Federal Domestic Assistance (CFDA), the federal government's
listing of available grants and other federal funding opportunities
(available at www.CFDA.gov).1

The CFDA provides the public and potential applicants with specific
information about grant opportunities. The CFDA identifies grant programs
by title and an identifying number, known as a CFDA program code.
Furthermore, EPA uses the CFDA to describe funding priorities-that is, the
specific major activities, projects, and/or programs that EPA will fund
for certain grant programs; these priorities can

2

change from year to year. EPA's segment of the CFDA provides information
on both discretionary and nondiscretionary grant programs. Discretionary
grants are those for which EPA has the legislative authority to
independently determine the recipients

1The General Services Administration and Office of Management and Budget's
CFDA is a governmentwide compendium of federal programs, projects, and
activities that provide assistance or benefits to the American public.
Assistance includes, but is not limited to, financial assistance such as
grants and cooperative agreements. For simplicity, we are referring to
grants and cooperative agreements as grants. EPA uses other tools for
announcing some grant programs, such as the Federal Register, and all
competitive funding opportunities are announced on www.Grants.gov.

2EPA uses the CFDA to comply with an Office of Management and Budget
requirement that federal agencies announce funding priorities for
discretionary grants.

and funding levels. Nondiscretionary grants are those that Congress
directs to prospective recipients who meet specific eligibility criteria;
these grants are often awarded to states on the basis of formulas
prescribed by law or agency regulation. Information on nondiscretionary
grants is valuable to the public and potential applicants because, in some
cases, states receive these grants and local officials can apply to their
states for funding from them.

EPA's Office of Grants and Debarment (OGD), among other things, develops
grants policy and guidance and compiles grant information for the CFDA.
OGD has taken several steps to address criticism regarding the lack of
complete and accurate information in the CFDA. Most notably, OGD has
revised its annual CFDA guidance to grant officials, emphasizing the need
to provide complete and accurate information on grant opportunities.

In this context, you asked us to determine whether EPA is providing
complete and accurate information on grant opportunities to the public in
the CFDA. To respond to your request, we interviewed and obtained policy,
guidance, and other documents from OGD officials. We reviewed EPA's
descriptions of the 78 grant programs listed in the August 2004 CFDA to
determine if the program descriptions identified funding priorities and
funding level estimates. Of these 78 programs, EPA identified 68 as

                                       3

discretionary and 10 as nondiscretionary. To verify the accuracy of the
information in the CFDA, we obtained data from EPA's Integrated Grants
Management System (IGMS), a computer database that OGD uses to manage and
report on information about grants; we also conducted a limited data
reliability assessment of that system. We reviewed Office of Management
and Budget (OMB) Circulars A-102 and A-110, which, among other things, lay
out requirements for announcing funding priorities for

4

discretionary grant programs. We also reviewed GAO and EPA Office of
Inspector General reports, the Senate Environment and Public Works
majority staff report,5 and

                                       6

EPA's response to the Senate report. We focused our review on EPA program
funding priorities, funding levels, and CFDA program codes in the August
2004 CFDA-the most current version at the time of our review-because these
elements had been identified as incomplete and inaccurate in the past. We
performed our work from September 2004 through January 2005 in accordance
with generally accepted government auditing standards.

3The CFDA refers to discretionary grants as "project grants" and
nondiscretionary grants as "formula grants." In addition to these 78 grant
programs, one EPA program provided technical assistance but no funding.

4OMB Circular No. A-102, Grants and Cooperative Agreements with State and
Local Governments (10/7/94, as further amended 8/29/97); OMB Circular No.
A-110, Uniform Administrative Requirements for Grants and Agreements with
Institutions of Higher Education, Hospitals, and Other Non-Profit
Organizations (11/19/93, as further amended 9/30/99).

5Senate Environment and Public Works Committee Majority Staff,
Transparency in EPA Grants: Website Access to Available Grants and
Disclosure of Recipients (Washington, D.C.: May 13, 2004).

6U.S. Environmental Protection Agency, Associate Administrator, Office of
Congressional and Intergovernmental Relations, correspondence to the
Chairman, Senate Committee on Environment and Public Works (Washington,
D.C.: June 4, 2004).

Results in Brief

EPA still does not consistently provide complete and accurate information
on grant opportunities in the CFDA, according to our analysis of the 78
grant programs listed in the August 2004 CFDA. Without complete and
accurate information, potential applicants will not be fully informed
about grant opportunities, and EPA may not have the broadest applicant
pool from which to select grantees. Specifically, we found problems in the
following areas:

o  	Funding priorities. Sixty-two of the 68 discretionary grant programs
and all 10 nondiscretionary grant programs did not have clearly identified
fiscal year 2004 funding priorities in the August 2004 CFDA. Without these
priorities, potential applicants did not benefit from knowing the specific
activities, projects, and/or programs for which funding was available in
2004, which could have influenced their decision to apply. OGD did not
clearly identify the funding priorities primarily because, beginning in
April of fiscal year 2004, it systematically replaced priorities for
2004-which the public would expect to find in the CFDA-with those for
2005. Adding to the inaccuracy of the information presented, OGD did not
always label the fiscal year to which the priorities applied. OGD
officials explained that the replacement was inadvertent and noted that
the 2004 funding priorities were accurate from the start of the fiscal
year until OGD replaced them beginning in April 2004. We believe the
problem occurred in part because OGD's guidance does not require OGD to
include and clearly identify both the current and upcoming fiscal years'
funding priorities in the CFDA. In addition, funding priorities were not
always clearly identified because EPA program offices did not provide the
funding priority information to OGD. In these cases, OGD did not follow
its own guidance to ensure that program offices provided complete CFDA
program descriptions.

o  	Funding level estimates. For fiscal year 2004, most CFDA program
descriptions included funding level estimates, but seven discretionary
grants did not. OGD guidance states that financial information must be
provided and that it should include funding level estimates. The lack of
complete funding information makes it difficult for potential applicants
to determine the level of funding available, which could affect their
decision to apply. In some of these seven cases, this information was
missing because program offices did not provide it to OGD, and OGD took
only limited action to obtain it. In other cases, OGD did not designate a
single program official to coordinate and develop a funding estimate for
grant programs involving multiple program offices; as a result, no
consolidated estimate was provided.

o  	Miscellaneous CFDA program codes. EPA has created 31 more
programspecific codes, but it continues to list grant opportunities in
broad, miscellaneous codes. EPA has been criticized for this practice. The
use of these broad codes could make it difficult for potential applicants
to find information about specific grants, thereby making the CFDA less
useful.

Placing these opportunities in more program-specific codes would better
inform the public and potential applicants.

OGD was not aware of the continuing problems with funding priorities and
funding levels in the CFDA that we had identified until we brought them to
its attention during our review. OGD has begun taking steps to correct the
problems we identified. Although OGD had issued CFDA guidance in 2002 on
providing complete and accurate information, it had not evaluated the
effectiveness of this guidance and its procedures. Periodic evaluation of
the effectiveness of guidance and procedures is necessary to ensure that
information is complete and accurate.

During the course of our review, we also identified inaccuracies in EPA's
IGMS, which OGD uses to generate reports about its grants to the public
and the Congress. These inaccuracies could impair EPA's ability to
completely and accurately inform the public and the Congress about its $4
billion annual investment in grants. For example, we found instances in
which the IGMS incorrectly identified funding as being awarded under one
grant program when the funding should have been identified as being
awarded under another grant program. Consequently, the information on
funding levels was inaccurate for multiple programs-overstating the amount
available in one program and understating it in another. OGD might have
detected these problems if it had conducted a comprehensive review of the
IGMS's data quality.

We are making recommendations to address EPA's continuing problems on
providing complete and accurate information to the public in the CFDA. We
are further recommending that EPA conduct a comprehensive, systemwide data
quality review of the IGMS.

Background

The CFDA provides the public and potential applicants with specific
information about grant opportunities. EPA's segment of the CFDA Web site
had about 57,600 "hits" between July 2003 and October 2004. This segment
contains 78 grant programs, and for each of these grant programs, EPA
specifies its statutory authority, objectives, funding, and contacts for
further information, among other things. EPA also requires information on
funding priorities for discretionary grants in the CFDA in order to comply
with OMB Circulars A-102 and A-110. These circulars require federal
agencies to publicly announce funding priorities for discretionary grants.

In 2001, EPA's Inspector General found that competition for discretionary
grants was lacking in part because information in the CFDA was not
complete and accurate.7 For example, EPA had not always (1) identified
each program's funding priorities and (2) provided the funding levels
available for each program. Furthermore, the Inspector General found that
EPA bundled a number of programs under one CFDA program code, 66.606,
"Surveys, Studies, Investigations, and Special Purpose Grants," thus
making it difficult to find information about specific grant programs. In
a 2003

7EPA Office of Inspector General, EPA's Competitive Practices for
Assistance Awards, Report No. 2001-P-00008 (Philadelphia, PA: May 21,
2001).

report, we highlighted the Inspector General's finding that EPA had not
provided

8

complete and accurate information on its grants programs to the public in
the CFDA.

EPA has taken the following steps to address the Inspector General's
findings:

o  	In 2002, EPA issued an order to promote competition by requiring that
certain discretionary grants be competed.9 The order promoted the
widespread announcement of grants and established requirements for
publishing funding opportunities in the CFDA.

o  	Also in 2002, OGD revised its CFDA guidance to program offices,
stating that 10

they must include annual funding priorities in the CFDA. OGD's April 2004
version of this guidance emphasized the need to provide complete and
accurate information on grant opportunities in the CFDA.11 OGD guidance
also stated that financial information must be included and that it should
include funding level estimates for the 2004 fiscal year.

o  	EPA incorporated into its 2003 grants management plan-which addresses
long-standing grants management challenges-the goal of promoting
competition by (1) providing guidance to EPA's program offices on how to
describe their programs and funding priorities in the CFDA, and (2)
expanding public awareness of EPA funding opportunities through accurate
and specific CFDA program descriptions to encourage a large and diverse
group of grant

12

applicants.

o  	EPA added 31 CFDA program codes to better identify grants with more
program-specific codes in the CFDA.

Most recently, in response to a 2004 report prepared by the Senate
Committee on Environment and Public Works' majority staff, EPA stated in
June 2004 that the agency had taken steps to resolve these problems.

To obtain information for the CFDA, OGD contacts EPA's program offices in
the spring and fall to obtain data on new and updated grant programs. It
collects most of this information in the first cycle, which occurs between
February and April. By

8GAO, Grants Management: EPA Needs to Strengthen Efforts to Address
Persistent Challenges, GAO-03-846 (Washington, D.C.: Aug. 29, 2003).

9The order applied to most discretionary grant programs or individual
grants of more than $75,000.

10EPA Office of Grants and Debarment, Memorandum: Preparation and
Submission of Catalog of Federal Domestic Assistance Program Information
for Update Cycle 2002, Mar. 3, 2002.

11EPA Office of Grants and Debarment, Memorandum: Preparation and
Submission of Catalog of Federal Domestic Assistance Program Information
for Basic Cycle 2004, Apr. 8, 2004.

12U.S. Environmental Protection Agency, Grants Management Plan: 2003-2008,
EPA-216-R-03-001 (Washington, D.C.: Apr. 2003).

collecting the upcoming year's funding priorities about mid-way through
the current fiscal year, EPA announces priorities in advance so that
potential applicants can plan accordingly. During the second cycle, which
occurs between October and November, EPA asks program offices to identify
funding priorities only for new grant programs. OGD guidance requires each
program office's senior resource official to approve the upcoming year's
funding priorities and states that the official should submit this

                                       13

approval by memorandum to the OGD Director. This memorandum serves as the
official agency record of each program office's annual funding priorities.
EPA's Office of the Chief Financial Officer reviews funding level data.

According to OGD officials, they review each grant program description to
ensure that it is complete and accurate. OGD provides guidance that OGD
officials return information on funding priorities that is not complete
and accurate to the program office so that complete information can be
entered into the CFDA.

After these reviews, OGD submits the data to the General Services
Administration (GSA) for review. According to OGD officials, CFDA analysts
at GSA review the information and provide any comments to EPA. GSA then
submits each program description to OMB, whose budget examiners review
program funding levels and approve the information for the CFDA. GSA then
posts the information to the CFDA Web site.

EPA Still Does Not Consistently Provide Complete and Accurate Information
to the Public on Grant Opportunities

According to our analysis of the August 2004 CFDA, EPA continues to
provide incomplete and inaccurate information on funding priorities and on
estimates of funding levels, and continues to obscure information by
placing certain grant programs in miscellaneous CFDA program codes.
Without complete and accurate information, potential applicants will not
be fully informed about grant opportunities, and EPA may not have the
broadest applicant pool from which to select grantees. OGD was not aware
of the continuing problems until we brought them to its attention during
our review because it has not evaluated the effectiveness of its CFDA
guidance and its implementation to ensure the accuracy and completeness of
the information in the CFDA.

EPA Does Not Consistently Provide Complete and Accurate Information on
Funding Priorities

EPA listed 78 grant programs-68 discretionary and 10 nondiscretionary-in
the August 2004 CFDA. (See the enclosure for a complete list of these
programs.) EPA did not provide complete and accurate information on
funding priorities for 62 of the 68 discretionary grants and for the 10
nondiscretionary grants for fiscal year 2004 that it listed in the August
2004 CFDA, as table 1 shows. Without complete and accurate

13Senior resource officials are typically deputy assistant administrators
in headquarters offices and assistant regional administrators in regional
offices, and are in charge of strengthening agencywide fiscal resource
management while also ensuring compliance with laws and regulations.

funding priorities, potential grant applicants do not have information on
which program areas EPA's offices are considering for grant funding and
how applicable and useful their grant proposals would be. Publicly
announced priorities also help ensure that EPA will have a broader, more
diverse pool of qualified grant applicants from which to choose.

Table 1: EPA Grant Programs Lacking Clearly Identified Funding Priority
Information in the August 2004 CFDA for Fiscal Year 2004

                                            Number of grant programs
                                           Lacking clearly       With clearly 
                    Number of grant     identified funding identified funding 
      Grant type           programs             priorities         priorities 
    Discretionary                68                     62                  6 
Nondiscretionary              10                     10                  0 
        Total                    78                     72                  6 

Source: GAO analysis of CFDA data.

Three factors contributed to the lack of complete and accurate funding
priority information for fiscal year 2004 discretionary grants in the
August 2004 CFDA. First, for 47 of the 62 discretionary grant programs
lacking clearly identified funding priorities, OGD systematically replaced
the current year's funding priorities-which the public would expect to
find in the CFDA-with the upcoming fiscal year's priorities, and did not
identify the fiscal year to which these priorities applied. Without this
information, potential applicants did not know the major project,
activities and/or programs for which funding was available in 2004, which
could have affected their decision to apply for a specific grant. OGD
began these replacements in April 2004, as the program offices submitted
their CFDA information for fiscal year 2005. OGD officials told us this
replacement was inadvertent. Although OGD officials agreed that funding
priorities were replaced beginning in April 2004, they noted that funding
priorities were complete and accurate from October 2003 until they were
replaced. This replacement and labeling problem occurred in part because
OGD's guidance does not state that OGD must include and clearly identify
the current and upcoming fiscal years' priorities in the CFDA. We believe
this problem could be avoided in the future, and potential applicants
could benefit, if the guidance required OGD to provide and label such
information for both current and upcoming fiscal years.

Second, for 14 of the 62 discretionary grant programs, program offices did
not provide information on funding priorities, and OGD did not return CFDA
program descriptions that lacked funding priorities to program offices, as
specified in OGD's guidance. In some cases, according to an EPA official,
OGD sent follow-up e-mails and made telephone inquiries to the program
offices. But these efforts did not result in complete information.
Consequently, OGD submitted incomplete information for these grant
programs in the CFDA.

Third, for 1 of the 62 discretionary grant programs, the program office
provided the funding priority, but OGD mistakenly omitted the words
"funding priority" from the CFDA program description. As a result, the
public and potential applicants would

find it difficult to identify funding priority information in the CFDA for
this grant program.

Funding priorities for all 10 nondiscretionary grants in fiscal year 2004
were also incomplete and inaccurate. As it had done with the discretionary
grants, OGD replaced the fiscal year 2004 funding priorities with those
for fiscal year 2005 beginning in April 2004 and did not identify the
fiscal year. OGD officials reiterated that funding priority data were
complete and accurate until they were replaced.

In addition, we found that, for five discretionary grant programs, two
program offices did not submit the memorandum, as the guidance states they
should, from the program offices' senior resource official approving the
fiscal year 2005 funding priorities. Consequently, OGD listed these
funding priorities in the CFDA without assurance that the information was
accurate. For example, EPA's Office of Air and Radiation did not provide a
memorandum for the funding priorities it submitted to OGD for four grant
programs. Although OGD's guidance states that senior resource officials
"must" approve funding priorities, the guidance only states that the
senior resource officials "should" provide the memorandum to the OGD
Director. However, OGD officials confirmed to us that the memorandum was
required and they believed that OGD guidance may not be clear.

Finally, OGD's guidance only states that funding priorities must be
provided for discretionary grant programs, but according to OGD officials,
funding priorities are required for both discretionary and
nondiscretionary grant programs. While the guidance does not state this
requirement for nondiscretionary grants, these officials told us that the
program offices understood that they had to submit funding priorities for
nondiscretionary grants and did so.

EPA Does Not Consistently Provide Information on Funding Level Estimates

For fiscal year 2004, most CFDA program descriptions had funding
estimates, but EPA did not include estimated funding levels for 7 of the
68 discretionary grants programs, as table 2 shows. OGD guidance states
that financial information must be provided and that it should include
funding level estimates. Without complete funding information, potential
applicants cannot determine the level of funding available, which could
affect their decision to apply.

Table 2: EPA Grant Programs with and without Fiscal Year 2004 Funding
Level Estimates in the August 2004 CFDA

                                            Number of grant programs
                                        Without FY 2004 funding  With FY 2004 
                    Number of grant             level estimates funding level 
      Grant type           programs                                 estimates 
    Discretionary                68                           7            61 
Nondiscretionary              10                           0            10 
        Total                    78                           7            71 

Source: GAO analysis of CFDA data.

Three of the seven program descriptions in the CFDA lacked complete
funding information because one program office failed to provide OGD with
the estimated funding levels, and OGD did not take the follow-up action
its guidance called for to obtain this information from the program. The
other four programs lacking funding estimates involved multiple program
offices. However, OGD did not designate a single program official to serve
as a focal point for reporting a consolidated funding estimate to OGD, and
therefore no such funding estimate was presented in the CFDA.

EPA Has Created More Program-Specific Codes But Continues to Use
Miscellaneous Program Codes in the CFDA

In 2001, EPA's Inspector General reported that EPA had inappropriately
placed program-specific grants under the miscellaneous CFDA program code
66.606, entitled "Surveys, Studies, Investigations, and Special Purpose
Grants."14 By combining multiple grant programs under one miscellaneous,
nonspecific program code, EPA makes it difficult for potential applicants
to find information about specific grants, thereby making the CFDA's
information less useful.

In 2002, OGD issued guidance, which it updates annually, requesting
program offices to reduce their use of the 66.606 program code and place
grants in more programspecific CFDA program codes. To support this effort,
EPA created six new CFDA codes for "Surveys, Studies, Investigations, and
Special Purpose Grants": one each for Clean Air (66.034), Safe Drinking
Water (66.424), Clean Water (66.436), Office of Research and Development
(66.510), Office of Administrator (66.610), and Educational Outreach
(66.716). In addition, OGD officials told us that they created another 25
CFDA program codes to better identify grants with specific programs.

At the same time, OGD allowed existing 66.606 grants to continue under
this code until this grant funding ended. It also instructed program
offices to use the 66.606, program code-"Surveys, Studies, Investigations,
and Special Purpose Grants"-for both congressional earmarks and for
multi-media grants (i.e., those with more than one statutory authority).

We are concerned by this action for two reasons. First, OGD officials
could provide no rationale for why congressional earmarks and multi-media
grants should be combined into one program code. The 66.606 CFDA program
code therefore continues to be a miscellaneous code. Second, it is
inaccurate to describe congressional earmarks only as "Surveys, Studies,
Investigations, and Special Purpose Grants"-a term that EPA has
traditionally applied to research or similar grants. According to OGD
officials, congressionally earmarked EPA grants are not limited to
research.

14EPA Office of Inspector General, EPA's Competitive Practices for
Assistance Awards, Report No. 2001-P-00008 (Philadelphia, PA: May 21,
2001).

Moreover, in March 2004,15 we reported that between fiscal years 1993 and
2003, EPA added grants to another broad miscellaneous code-CFDA program
code 66.500, "Consolidated Research Grants.'' By combining research grants
supporting multiple programs into one miscellaneous nonspecific code, EPA
obscures information about specific programs, as it does with the use of
the code 66.606.

OGD recognizes that it has a continuing problem with the use of
miscellaneous CFDA codes. Its 2004 CFDA guidance reiterated to program
offices that agency policy is to break up "overly-broad" CFDA program
descriptions, including the six codes it has used since 2002 to better
specify grants in the 66.606 program code. It has issued similar guidance
for the 66.500 program code in 2004.

EPA Has Not Evaluated the Accuracy and Completeness of the CFDA
Information

OGD was not aware of continuing errors with funding priorities and funding
level estimates in the CFDA until we identified them during our review,
but it has begun taking steps to address them. Although OGD issued new
guidance in 2002 to address criticisms of the CFDA information, OGD never
evaluated the effectiveness of the guidance and its implementation.
Periodic evaluation of the effectiveness of guidance and procedures is
necessary to ensure that information is complete and accurate. Such an
evaluation could have alerted OGD officials to the problems we identified
on funding priorities and funding levels in the CFDA and allowed them to
take corrective actions.

EPA Has Not Conducted a Comprehensive Data Quality Review of the IGMS

During the course of our review, we also identified inaccuracies in EPA's
Integrated Grants Management System (IGMS), which OGD uses to generate
reports on its grant programs to the public and the Congress. The IGMS's
inaccuracies could impair EPA's ability to accurately and comprehensively
inform the public and the Congress about its $4 billion annual investment
in grants.

According to OGD officials, since the IGMS and CFDA report on similar
information, the two sources should be consistent. We found, however, that
the CFDA and IGMS were not always consistent and that the information
extracted from the IGMS could be inaccurate. For example, the IGMS
information OGD officials provided to us listed the grant program, State
Grants to Reimburse Operators of Small Water Systems for Training and
Certification Costs (66.471), as having $5.3 million in discretionary
grant funds; the CFDA correctly listed this program as nondiscretionary.
When we brought this inconsistency to OGD's attention, officials explained
that they had incorrectly drawn information from the IGMS,16 thereby
incorrectly classifying the program as discretionary.

15GAO, Grants Management: EPA Needs to Better Document Its Decisions for
Choosing between Grants and Contracts, GAO-04-459 (Washington, D.C.: Mar.
31, 2004).

16The IGMS does not label grant programs as discretionary or
nondiscretionary; instead OGD had to create definitions of discretionary
and nondiscretionary in order to sort the information in the IGMS and
extract it.

We also found instances in which the IGMS incorrectly placed funding in
one grant program when the funding belonged in a different program. As a
result, the IGMS information on funding levels was inaccurate for a number
of programs. For example, according to the IGMS, the Air Pollution Control
Program Support grant program had about $471,000 in discretionary grant
funds and about $76 million in nondiscretionary grant funds for fiscal
year 2004. However, when we questioned this allocation because of
information in the CFDA to the contrary, OGD found that the $471,000 in
discretionary funding belonged in another program. Thus, the IGMS
incorrectly overstated funding for the air pollution control support
program by $471,000 and understated the funding for another program by the
same amount.

OGD officials acknowledged the problems with inaccurate funding data in
the IGMS. They said that in June 2004, after learning that project
officers were finding it difficult to link their grants to the appropriate
CFDA program codes in the IGMS, they instituted new IGMS controls. OGD
added a "dropdown" menu in the IGMS to help staff accurately connect
grants to CFDA codes. However, OGD did not correct the data that had been
inaccurately entered before June 2004.

OGD has never conducted a comprehensive, systemwide data quality review of
the IGMS, despite the importance of the database for reporting on EPA's $4
billion annual investment in grants to the public and the Congress.
Furthermore, in 2002, EPA issued guidelines for ensuring the quality of
information.17 These guidelines state, among other things, that the
agency's offices assess existing data to verify that they are of
sufficient quantity and quality for their intended use. OGD officials have
not yet taken the steps identified in these guidelines to ensure IGMS data
quality.

Conclusions

OGD has not resolved its long-standing problem of consistently providing
complete and accurate information to the public and potential applicants
on grant opportunities in the CFDA. While OGD has issued guidance on
gathering and presenting correct and accurate information in the CFDA, we
found weaknesses in the guidance and OGD's implementation of it that
contributed to the lack of accurate and complete information in the CFDA.
Without reviewing the effectiveness of its guidance and implementation,
OGD was unable to detect these problems. Until OGD corrects these
problems, it will not fully realize its goal of promoting competition in
awarding grants by providing complete and accurate information to
potential grant applicants.

Furthermore, OGD's IGMS contains inaccuracies that could impair EPA's
ability to inform the public and the Congress about its $4 billion annual
investment in grants. A comprehensive, systemwide data quality review is
necessary to ensure the accuracy of information reported to the public and
the Congress.

17U.S. Environmental Protection Agency Office of Environmental
Information, Guidelines for Ensuring and Maximizing the Quality,
Objectivity, Utility, and Integrity of Information Disseminated by the
Environmental Protection Agency, EPA/260R-02-008 (Oct. 2002).

Recommendations for Executive Action

To address EPA's continuing problems in consistently providing complete
and accurate information on grant opportunities to the public in the CFDA,
we recommend that the Administrator, EPA require the Director of the
Office of Grants and Debarment to

o  revise the agency's CFDA guidance to state that

o 	both current and upcoming fiscal years' funding priorities be provided
and clearly identified for inclusion in the CFDA;

o 	information on funding priorities for both discretionary and
nondiscretionary grant programs be provided in the CFDA; and

o 	senior resource officials provide a memorandum documenting approval of
program funding priorities;

o  work closely with

o 	program offices so that they always provide complete program
descriptions, including funding priorities and funding estimates; and

o 	senior resource officials to ensure that they provide a memorandum
documenting approval of the program's funding priorities;

o  	continue to work on placing grant opportunities under program-specific
codes instead of under miscellaneous codes; and

o  	periodically evaluate the effectiveness of CFDA guidance and its
implementation to ensure that the CFDA contains complete and accurate
information.

We further recommend that OGD conduct a comprehensive, systemwide data
quality review of the IGMS in order to ensure the accuracy of the
information reported from the database to the public and the Congress.

Agency Comments and Our Evaluation

We provided a draft of this report to EPA for its review and comment. The
Director of EPA's Office of Grants and Debarment provided oral comments.
EPA generally agrees with the recommendations in our draft report. EPA has
formed a work group, which will consider the full range of issues we
identified regarding both the CFDA and the IGMS. However, EPA did not want
to revise its guidance to provide both current and upcoming fiscal years'
funding priorities in the CFDA. The Director believes that OGD can best
address GAO's concerns by keeping the current year's funding priorities in
the CFDA and announcing the upcoming year's funding priorities-possibly
later in the CFDA cycle-when EPA can ensure their accuracy.

Although we believe that potential applicants would benefit from having
funding priorities announced in advance, we believe that announcing the
upcoming year's funding priorities when EPA can ensure their accuracy
would meet the intent of our recommendation. The Director is also asking
the work group to review various options for managing the entire CFDA
process, including when to list the upcoming fiscal year's funding
priorities in the CFDA. OGD also provided a number of technical comments,
which we incorporated as appropriate.

We will send copies of this report to the congressional committees with
jurisdiction over EPA and its activities; the Acting Administrator, EPA;
and the Director, Office of Management and Budget. In addition, this
report will be available at no charge on the GAO Web site at
http://www.gao.gov.

If you or your staff have any questions about this report or need
additional information, please contact me at (202) 512-3841. Key
contributors to this report were David Bobruff, Andrea Wamstad Brown,
Rebecca Shea, Carol Herrnstadt Shulman, Bruce Skud, and Amy Webbink.

Sincerely yours,

John B. Stephenson Director, Natural Resources

and Environment

Enclosure

Enclosure

                     EPA Grant Programs Listed in the CFDA

Tables 3 and 4 present the Environmental Protection Agency's (EPA) grant
programs in the Catalog of Federal Domestic Assistance (CFDA) of
discretionary grants (which the CFDA refers to as project grants) and
nondiscretionary grants (which the CFDA refers to as formula grants),
respectively.

Table 3: EPA Discretionary Grant Programs in August 2004 CFDA

CFDA program code                    CFDA program title                    
        66.001                Air Pollution Control Program Support           
        66.032                      State Indoor Radon Grants                 
        66.033                           Ozone Transport                      
        66.034       Surveys Studies, Investigations Demonstrations and       
                     Special Purpose Activities relating to the Clean Air Act 
        66.305       Compliance Assistance-Support for Services to the        
                     Regulated Community and Other Assistance Providers       
        66.306         Environmental Justice Collaborative Problem-Solving    
                                          Grants Program                      
        66.418          Construction Grants for Wastewater Treatment Works    
        66.424       Surveys, Studies, Demonstrations and Special Purpose     
                     Grants - Section 1442 of the Safe Drinking Water Act     
                     Surveys, Studies, Investigations, Demonstrations, and    
        66.436       Training Grants and Cooperative Agreements - Section     
                     104(B)(3) of the Clean Water Act                         
        66.437                      Long Island Sound Program                 
        66.439                      Targeted Watershed Grants                 
        66.456                       National Estuary Program                 
        66.461                        Wetland Program Grants                  
        66.463                 Water Quality Cooperative Agreements           
        66.466                        Chesapeake Bay Program                  
        66.467        Wastewater Operator Training Grant Program (Technical   
                                           Assistance)                        
        66.469                         Great Lakes Program                    
        66.472       Beach Monitoring and Notification Program Implementation 
                                              Grants                          
        66.473         Direct Implementation Tribal Cooperative Agreements    
        66.475                        Gulf of Mexico Program                  
        66.476          Security Planning Grants For Large Drinking Water     
                                            Utilities                         
                     Vulnerability Assessments and Related Security           
        66.477       Improvements at Large Privately-Owned Community Drinking 
                     Water Utilities                                          
        66.478           Water Security Training and Technical Assistance     
        66.500           Environmental Protection - Consolidated Research     
        66.508               Senior Environmental Employment Program          
        66.509              Science to Achieve Results (STAR) Program         
        66.510       Surveys, Studies, Investigations and Special Purpose     
                     Grants within the Office of Research and Development     
        66.511       Office of Research and Development Consolidated Research 
        66.513          Greater Research Opportunities Fellowship Program     
        66.514         Science to Achieve Results (STAR) Fellowship Program   
        66.515                Greater Opportunities Research Program          
        66.516          P3 Award: National Student Design Competition for     
                                          Sustainability                      

Enclosure

CFDA program code                    CFDA program title                    
        66.600         Environmental Protection Consolidated Grants-Program   
                                             Support                          
        66.604       Environmental Justice Hazardous Substances Research      
                     Small Grants to Community Groups                         
        66.605                    Performance Partnership Grants              
        66.606        Surveys, Studies, Investigations, and Special Purpose   
                                              Grants                          
        66.607            Training and Fellowships for the Environmental      
                                        Protection Agency                     
        66.608       Environmental Information Exchange Network Grant Program 
        66.609        Protection of Children and Older Adults (Elderly) from  
                                    Environmental Health Risks                
        66.610       Surveys, Studies, Investigations and Special Purpose     
                     Grants within the Office of the Administrator            
        66.611              Environmental Policy and Innovation Grants        
        66.700            Consolidated Pesticide Enforcement Cooperative      
                                            Agreements                        
        66.701          Toxic Substances Compliance Monitoring Cooperative    
                                            Agreements                        
        66.707           TSCA Title IV State Lead Grants Certification of     
                                  Lead-Based Paint Professionals              
        66.708                 Pollution Prevention Grants Program            
        66.709       Capacity Building Grants and Cooperative Agreements for  
                                        States and Tribes                     
        66.714        Pesticide Environmental Stewardship - Regional Grants   
        66.715       Childhood Blood-Lead Screening and Lead Awareness        
                     (Educational) Outreach for Indian Tribes                 
        66.716       Surveys, Studies, Investigations, Training               
                     Demonstrations, and Educational Outreach                 
        66.717                     Source Reduction Assistance                
        66.802       Superfund State, Political Subdivision, and Indian Tribe 
                     Site-Specific Cooperative Agreements                     
        66.804          State and Tribal Underground Storage Tanks Program    
        66.805         Leaking Underground Storage Tank Trust Fund Program    
        66.806       Superfund Technical Assistance Grants (TAG) for          
                     Community Groups at National Priority List (NPL) Sites   
        66.808                  Solid Waste Management Assistance             
        66.809            Superfund State and Indian Tribe Core Program       
                                      Cooperative Agreements                  
        66.810       Chemical Emergency Preparedness and Prevention (CEPP)    
                     Technical Assistance Grants Program                      
        66.812                    Tribal Hazardous Waste Grants               
                     Alternative or Innovative Treatment Technology Research, 
        66.813       Demonstration, Training, and Hazardous Substance         
                     Research Grants                                          
        66.814       Brownfields Training, Research, and Technical Assistance 
                     Grants and Cooperative Agreements                        
        66.815            Brownfield Job Training Cooperative Agreements      
        66.816          Headquarter and Regional Underground Storage Tanks    
                                             Program                          
        66.817               State and Tribal Response Program Grants         
        66.818            Brownfields Assessment and Cleanup Cooperative      
                                            Agreements                        
        66.926        Indian Environmental General Assistance Program (GAP)   
        66.931       International Financial Assistance Projects Sponsored by 
                     the Office of International Affairs                      
        66.950             Environmental Education and Training Program       
        66.951                    Environmental Education Grants              

                       Source: GAO analysis of CFDA data.

Enclosure

Table 4: EPA Nondiscretionary Grant Programs in August 2004 CFDA

CFDA program code                    CFDA program title                    
        66.419         Water Pollution Control State and Interstate Program   
                                             Support                          
        66.432                State Public Water System Supervision           
        66.433              State Underground Water Source Protection         
        66.454                  Water Quality Management Planning             
        66.458        Capitalization Grants for Clean Water State Revolving   
                                               Fund                           
        66.460                Nonpoint Source Implementation Grants           
        66.468       Capitalization Grants for Drinking Water State Revolving 
                                               Fund                           
        66.471          State Grants to Reimburse Operators of Small Water    
                           Systems for Training and Certification Costs       
        66.474                Water Protection Grants to the States           
        66.801           Hazardous Waste Management State Program Support     

                       Source: GAO analysis of CFDA data.

(360507)

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