Anti-Drug Media Campaign: An Array of Services Was Provided, but 
Most Funds Were Committed to Buying Media Time and Space	 
(31-MAR-05, GAO-05-175).					 
                                                                 
The Office of National Drug Control Policy (ONDCP) was required  
by the Drug Free Media Campaign Act of 1998 (21 U.S.C. 1801 et	 
seq.) to conduct a national media campaign to reduce and prevent 
drug use among America's youth. Since 1998, Congress has	 
appropriated over $1 billion for the media campaign. However, a  
2003 report by the Senate Committee on Appropriations expressed  
some concerns about the media campaign, including concern that a 
large portion of the campaign's budget had been used for	 
consulting services rather than the direct purchase of media time
and space. The report, therefore, directed GAO to review the use 
of consultants to support the media campaign. This report	 
describes the services provided by consultants (defined by GAO as
the prime contractors and their subcontractors) in support of the
media campaign, along with the estimated award amounts for these 
services.							 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-05-175 					        
    ACCNO:   A20499						        
  TITLE:     Anti-Drug Media Campaign: An Array of Services Was       
Provided, but Most Funds Were Committed to Buying Media Time and 
Space								 
     DATE:   03/31/2005 
  SUBJECT:   Advertising					 
	     Advertising costs					 
	     Consultants					 
	     Drugs						 
	     Funds management					 
	     Government contracts				 
	     National policies					 
	     Prime contractors					 
	     Program evaluation 				 
	     Public relations					 
	     Research and development				 
	     Subcontractors					 
	     Subcontracts					 
	     Television advertising				 
	     Youth						 
	     ONDCP National Youth Anti-Drug Media		 
	     Campaign						 
                                                                 

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GAO-05-175

United States Government Accountability Office

GAO	Report to the Subcommittee on Transportation, Treasury, the Judiciary,
       Housing and Urban Development, and Related Agencies, Committee on
                          Appropriations, U.S. Senate

March 2005

ANTI-DRUG MEDIA CAMPAIGN

An Array of Services Was Provided, but Most Funds Were Committed to Buying Media
                                 Time and Space

GAO-05-175

[IMG]

March 2005

ANTI-DRUG MEDIA CAMPAIGN

An Array of Services Was Provided, but Most Funds Were Committed to Buying Media
Time and Space

                                 What GAO Found

Our analysis of contracts covering ONDCP's National Youth Anti-Drug Media
Campaign from fiscal years 2002 through 2004 revealed that four
contractors provided many of the services required to execute the
campaign. These four prime contractors provided an array of services that
fell within three broad categories: (1) advertising, (2) public
communications and outreach, and (3) evaluation services to gauge the
campaign's effectiveness. The prime contractors also acquired additional
specialized expertise from 102 subcontractors. Some of the specific tasks
performed by the contractors and their subcontractors included conducting
qualitative and quantitative research for advertising creation, working
with the entertainment industry to portray the negative consequences of
drug use in television and movies, and conducting an evaluation intended
to measure the effectiveness of the media campaign. Based on our analysis
of contracts covering fiscal years 2002 through 2004, we estimated that
$520 million was awarded to the four prime contractors, of which an
estimated $373 million-72 percent-was committed to purchasing media time
and space for campaign advertisements. The remaining $147 million-28
percent-was for the services provided by the prime contractors.
Contractors, in turn, awarded $14 million of that amount to their
subcontractors.

Estimated Award Amounts for Contractor Services and Purchase of Media Time
and Space (fiscal years 2002-2004)

Source: GAO.

Note: Percentages may not add up to 100 percent due to rounding.

United States Government Accountability Office

Contents

     Letter                                                                 1 
                                    Results in Brief                        2 
                                       Background                           3 
                 Prime Contractors and Their Subcontractors Provided Three 
                                                                     Broad 
                   Categories of Services, but Most of the Estimated Award 
                                                                   Dollars 
                    Were Committed to Purchasing Media Time and Space       6 
                           ONDCP's Comments and Our Evaluation             13 
Appendix I                     Scope and Methodology                    
Appendix II           Three Phases of Advertising Development           

Appendix III
Ogilvy & Mather's Subcontractor Services and Associated Estimated Award
Amounts

Appendix IV
Fleishman-Hillard Subcontractor Services and Associated Estimated Award
Amounts

Appendix V
Comments from the Office of National Drug Control Policy

Appendix VI GAO Contacts and Staff Acknowledgments 35

GAO Contacts 35 Staff Acknowledgments 35

Tables

Table 1: Estimated Award Amounts to Subcontractors during Fiscal Years
2002-2004 9 Table 2: Services Provided by the 102 Subcontractors in
Support of the Media Campaign during Fiscal Years 2002 through 2004 12

Table 3: Estimated Contract Award Amounts to Groups of Fleishman-Hillard
Subcontractors by Fiscal Year (20022004)

Figures

Figure 1: Media Campaign's Advertising Development/Research Process 5

Figure 2: Estimated Award Amounts for Contractor Services and Purchase of
Media Time and Space during Fiscal Years 2002-2004 7

Figure 3: Example of Award-Based Data Calculation 18 Figure 4: Example of
Rate-Based Data Calculation 20

Abbreviations

BCEP Behavioral Change Expert Panel
DCI data collection instrument
FCEP Formative Creative Evaluation Panel
MAM Madison Advertising Management, LTD.
NIDA National Institute on Drug Abuse
ONDCP Office of National Drug Control Policy
PDFA The Partnership for a Drug-Free America
SADD Students Against Destructive Decisions, Inc.
VNR video news release

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. However, because this
work may contain copyrighted images or other material, permission from the
copyright holder may be necessary if you wish to reproduce this material
separately.

United States Government Accountability Office Washington, DC 20548

March 31, 2005

The Honorable Christopher Bond

Chairman

The Honorable Patty Murray

Ranking Member

Subcommittee on Transportation, Treasury, the Judiciary, Housing and Urban
Development, and Related Agencies Committee on Appropriations United
States Senate

The Office of National Drug Control Policy (ONDCP) is charged with
reducing illicit drug use, manufacturing and trafficking, drug-related
crime and violence, and drug-related health consequences. To achieve these
goals, the office formulates a National Drug Control Strategy that
includes multipronged approaches to combating national drug use. Among
these approaches is an effort to reduce and prevent drug use among
America's youth by conducting educational and community action programs,
including a National Youth Anti-Drug Media Campaign. The campaign combines
paid and donated advertising with public communications outreach in an
effort to change teen and parental beliefs and behaviors regarding drug
use.

Congress first authorized funding for the media campaign in fiscal year
1998, with the expectation that demonstrable changes in youth drug
behaviors would be apparent within 3 years. Since then, over $1 billion
has been appropriated for the media campaign. In a committee report for
the fiscal year 2004 appropriations cycle, the Senate Appropriations
Committee asserted that drug use was increasing in spite of the campaign
and that some observers had concluded that the campaign was having no
noticeable impact.1 In addition, the report asserted that a large portion
of the campaign's budget pays for outside media and advertising
consultants. As such, the report expressed concern about the amount of
resources consumed by consultants and the extent to which funds were spent
for

1Senate Report No. 108-146, at 143 (2003) accompanied the media campaign's
proposed 2004 appropriation in the Transportation, Treasury & General
Government Appropriations Bill, 2004, S. 1589, 108th Cong. The media
campaign's 2004 appropriation was ultimately enacted as part of the
Consolidated Appropriations Act, 2004, P.L. 108-199, 118 Stat. 325 (2004).

                     consulting services rather than media time and space for 
                                                              advertisements. 
                    Given these issues, the committee report directed us to   
                    review how                                                
                    consultants were used in support of the media campaign.2  
                    This report                                               
                         focuses on the following question: What services did 
                                                        contractors and their 
                           subcontractors provide in support of ONDCP's media 
                                                            campaign and what 
                      were the estimated award amounts for these services for 
                                                            fiscal years 2002 
                         through 2004? We are currently conducting a separate 
                                                             review examining 
                        the design and execution of ONDCP's primary effort to 
                                                           evaluate the media 
                                    campaign's effectiveness.                 
                    To respond to the question for this report, we met with   
                    and obtained                                              
                       documentation from officials at ONDCP headquarters and 
                                                               contractor and 
                    subcontractor officials in Washington, D.C., and New York 
                    City that                                                 
                    supported the media campaign. We analyzed the contracts   
                    of the prime                                              
                    contractors and their subcontractors to determine the     
                    services they                                             
                      provided and the associated estimated award amounts. We 
                                                               used estimated 
                    award data because at the time of our review actual       
                    expenditure                                               
                     information was not complete. We conducted our work from 
                                                                   March 2004 
                           through February 2005 in accordance with generally 
                                                          accepted government 
                        auditing standards. Appendix I provides more detailed 
                                                            information about 
                             the scope and methodology of our work.           
                        During fiscal years 2002 through 2004, the four prime 
Results in Brief      contractors we reviewed and their 102 subcontractors 
                                          provided a variety of services that 
                    fell within three broad categories: (1) advertising, (2)  
                                             public                           
                    communications and outreach, and (3) evaluation services. 
                    Some of the                                               
                    specific tasks they performed included conducting         
                    qualitative and                                           
                    quantitative research for advertising creation, working   
                    with the                                                  
                               entertainment industry to portray the negative 
                                                     consequences of drug use 

2The senate committee report that mandated our review did not define the
term "consultants." But given the concern expressed by the committee, we
focused our review on the prime contractors and their subcontractors used
by ONDCP to implement the media campaign. During the period of our review,
ONDCP obtained acquisition services to award the contracts in support of
its media campaign from the U.S. Navy Fleet Industrial Supply Center
(FISC) and GovWorks (a service-for-fee federal acquisition center,
operating under the U.S. Department of the Interior's Franchise Fund).
Acquisition services included planning, soliciting, awarding,
administering, terminating, and closing out all contracts for ONDCP's
media campaign. ONDCP's contract management responsibilities included,
among other things, developing statements of work and tracking and
reporting on contractors' performance. Although the contracts were awarded
and managed by FISC and GovWorks on behalf of ONDCP, because ONDCP
provided the funding for these contracts, we refer to ONDCP as having used
these contractors to implement the media campaign.

in television and movies, and evaluating the campaign's effectiveness.
Based on our analysis of contracts awarded for fiscal years 2002 through
2004, we estimated that $520 million was awarded to the four prime
contractors. However, of this $520 million, an estimated $373 million-72
percent-was committed to purchasing media time and space for
advertisements. The remaining $147 million-28 percent-was for the services
provided by the prime contractors. Of that amount, $14 million was awarded
to the subcontractors by the prime contractors.

In commenting on a draft of this report, the Director of the Office of
National Drug Control Policy generally agreed with our findings. ONDCP
provided technical comments that have been incorporated into this report
where appropriate.

                                   Background

    Congressional Authorization and Funding of the Media Campaign

The Drug-Free Media Campaign Act of 1998, 21 U.S.C. 1801 et seq., required
the Office of National Drug Control Policy to conduct a national media
campaign to reduce and prevent drug abuse among America's youth. The act
specified certain uses of funds provided for the media campaign to include
(1) the purchase of media time and space; (2) out-ofpocket advertising
production costs; (3) testing and evaluation of advertising; (4)
evaluation of effectiveness; (5) partnerships with community, civic, and
professional groups and with government organizations; (6) collaboration
with the entertainment industry to incorporate anti-drug messages in
movies, television, Internet media projects, and public information; (7)
news media outreach; and (8) corporate sponsorship and participation,
among other uses. The act also mandated a matching requirement. To
implement this requirement, ONDCP developed a pro bono match program
requiring media vendors who sell advertising time or space to the media
campaign to provide (1) an equivalent amount of free public service time
or space or (2) an equivalent in-kind contribution.

Congress has appropriated over $1 billion for ONDCP's media campaign since
it was initiated in 1998. However, the media campaign's annual
appropriations have declined since Congress initially funded the program.
ONDCP's 2005 appropriation provides $120 million for the media campaign,
which represents a $25 million decline from the 2004 appropriation and a
$75 million decline from the first-year funding in 1998.

    Media Campaign's Advertising Development and Research Process

The media campaign employs an iterative three-phase advertising
development and research process. The first phase, the exploratory
research phase, occurs before advertisements are created. For example,
before developing the "Monitoring/Love" advertisement series-a message
targeting parents, promoting awareness of their children's whereabouts-
extensive research was conducted to help ad creators understand methods of
communicating effectively with parents of teens.3 The second phase
consists of creating advertisements and subjecting them to research and
expert review. For example, in the "Monitoring/Love" series, focus groups
were used to assess parents' reactions to a set of advertising concepts.
The concepts were subsequently revised in response to the feedback. Once
the concepts were approved by ONDCP, the actual advertisements were
produced and tested for effectiveness. The third and final phase begins
after the advertisements have been determined to meet ONDCP's
effectiveness standards and involves the strategic placement of the
advertisements in television, radio, and print media. For example, the
"Monitoring/Love" series advertisements were aired during television shows
and radio programs most popular with the target audience, the parents of
teens. This phase also involves measuring the effectiveness of specific
advertisements over time within target audiences. See figure 1 for a
depiction of the three-stage process. Appendix II provides a more detailed
description of the campaign's advertising development and research
process.

3An advertising series is a set of three or four advertisements with a
common theme.

      Figure 1: Media Campaign's Advertising Development/Research Process

                            Source: Ogilvy & Mather.

    Contractor Services in Support of the Media Campaign

ONDCP uses advertising contractors to supplement its in-house capabilities
regarding the development, production, and placement of paid
advertisements on television, radio, print, and the Internet. The media
campaign also used a contractor to provide assistance with public
communications and outreach for the campaign, for example, encouraging the
entertainment industry to portray the negative consequences of drug use in
movies and television. In addition to developing advertisements and
conducting public outreach, ONDCP is required to assess whether the media
campaign's efforts have been effective in changing American youths'
behavior regarding drug use. During fiscal years 2002 through 2004, ONDCP
used four prime contractors with varying responsibilities to carry out the
campaign's requisite tasks: Ogilvy & Mather, The Advertising Council, Inc.
(The Ad Council), Fleishman-Hillard, Inc. (Fleishman-

  Prime Contractors and Their Subcontractors Provided Three Broad Categories of
  Services, but Most of the Estimated Award Dollars Were Committed to Purchasing
  Media Time and Space

Hillard), and Westat, Inc. (Westat).4 These contractors used funds from
their contracts to secure additional specialized expertise from
subcontractors.5

During fiscal years 2002 through 2004, the four major prime contractors
were responsible for a variety of services that generally fall into three
broad categories-advertising, public communications and outreach, and
evaluation. According to our analysis, an estimated $520 million was
awarded to the prime contractors, of which an estimated $373 million-72
percent-was committed to purchasing media time and space for
advertisements. The remaining $147 million-28 percent-was for the services
provided by the prime contractors.

4In its comments on our report, ONDCP disagreed that Westat is a prime
contractor of the media campaign because Westat's contract is with the
National Institute on Drug Abuse (NIDA), not with ONDCP. Although we are
aware that NIDA awarded the evaluation contract to Westat, we considered
Westat as a prime contractor of the media campaign for purposes of this
report. We did so because ONDCP has statutory responsibility for
evaluating the media campaign's effectiveness, see P.L. 105-61, 111 Stat.
1295 (1997), and it entered into an interagency agreement with NIDA for
NIDA to award a contract to evaluate ONDCP's media campaign. The
interagency agreement provided that ONDCP would fund the evaluation
contract through media campaign appropriations and would work with NIDA to
ensure that the evaluation met ONDCP program and policy objectives of
measuring the campaign's impact.

5Two additional prime contractors, the National Clearinghouse of Alcohol
and Drug Use Information and the National Institute of Justice, provided
clearinghouse services in support of the media campaign. We did not
include these contractors in our review because the focus of our review
was to examine the services provided by advertising, public communications
and outreach, and evaluation contractors.

Figure 2: Estimated Award Amounts for Contractor Services and Purchase of
Media Time and Space during Fiscal Years 2002-2004

Source: GAO.

Note: Percentages may not add up to 100 percent due to rounding.

Tasks associated with advertising and advertisement development were
performed by prime contractors Ogilvy & Mather and the Ad Council. Ogilvy
& Mather was responsible for managing the creative development and
production of advertising that is targeted toward changing drug beliefs
and behaviors among America's youth and parents. More specifically, Ogilvy
& Mather's tasks included (1) media planning, placement, and purchase; (2)
qualitative and quantitative research for advertising creation; and (3)
advertising assessment and review. The total estimated amount awarded to
Ogilvy & Mather for these services was about $97 million.6

The Ad Council was responsible for implementing several specific aspects
of the advertising component of the media campaign, including (1)
overseeing the use of media match space and time for public service

6This estimated award amount does not include the approximate $373 million
included in Ogilvy & Mather's contract that was committed to purchasing
media time and space for advertisements. The approximate sum of $373
million was to cover the cost of the media time and space only and does
not include the cost of Ogilvy & Mather's labor associated with
negotiating and executing media purchases.

announcements that are not part of the media campaign, (2) creating and
managing a community-based anti-drug strategy advertising campaign, and
(3) administering reviews of media campaign advertisement production
costs. The total estimated amount awarded to the Ad Council for these
services was about $5 million.

The purpose of public communications and outreach, which was implemented
by Fleishman-Hillard, was to extend the reach and influence of the
campaign through nonadvertising forms of marketing communications. To
achieve this end, Fleishman-Hillard's tasks included (1) conducting media
outreach-for example, submitting articles relating to key campaign
messages such as effective parenting or the effects of marijuana on teen
health to newspapers and magazines; (2) building partnerships and
alliances-for example, coordinating positive activities for teens with
local school and community groups; (3) creating Web sites and exploring
other alternative media approaches-for example, designing and hosting
message-oriented Web sites such as theantidrug.com; and (4) entertainment
industry outreach-for example, encouraging the entertainment industry to
portray the negative consequences of drug use in movies and television.
The total estimated amount awarded to Fleishman-Hillard for these services
was about $27 million.

To evaluate the effects of the campaign, ONDCP entered into an interagency
agreement with the National Institute on Drug Abuse (NIDA). NIDA, in turn,
contracted with Westat to design, develop, and implement an evaluation of
the outcome and impact of the media campaign in reducing illegal drug use
among youth.7 To accomplish this, Westat designed a multiphase study to
measure the attitudes and behavior of critical target audiences-preteens,
teenagers, and parents. The total estimated amount awarded to Westat for
these services was about $18 million.

To fulfill their responsibilities, the prime contractors retained the
expertise and services of 102 subcontractors for approximately $14
million. Table 1 shows the estimated award amounts for subcontractors
during fiscal years 2002 through 2004.

7Because Westat's contract with NIDA implements ONDCP's statutory
requirement of evaluating the media campaign's effectiveness, and because
ONDCP funded the Westat contract through media campaign appropriations, we
treated Westat as a prime contractor of the media campaign throughout the
course of this review.

Table 1: Estimated Award Amounts to Subcontractors during Fiscal Years
2002-2004

                              Dollars in thousands

                                   Number of                         
            Prime contractor subcontractors   2002    2003    2004      Total 
             Ogilvy & Mather              20 $1,059  $1,926  $1,880    $4,865 
                  Ad Council               1     280     210     146      636 
           Fleishman-Hillard              80  4,165   2,910      834    7,909 
                      Westat               1     218     224     343      785 
                       Total             102 $5,722  $5,270  $3,203   $14,195 

Source: GAO analysis of media campaign contracts.

Ogilvy & Mather retained 20 subcontractors for nearly $5 million to
provide two types of services: (1) multicultural media planning and buying
agencies and (2) substance use behavioral change experts, who constituted
the Behavioral Change Expert Panel (BCEP). The multicultural
subcontractors received more than $4 million (about 90 percent of the
nearly $5 million awarded by Ogilvy & Mather to subcontractors) for
providing marketing services and strategies with regard to specific
minority audiences. For example, one subcontractor, Bromley
Communications, was responsible for strategically purchasing media time
and space for advertisements targeting Hispanic parents and youth. Bromley
Communications also provided advice on how to develop effective
advertising for Hispanic audiences.

The BCEP received less than $500,000 (about 10 percent of the $5 million
awarded by Ogilvy & Mather to subcontractors) for applying behavioral
science expertise to several aspects of the campaign. For example, one
behavioral change expert provided consulting services related to
developing drug use prevention messages targeted to parents by reviewing
advertising concepts and recommending revisions to enhance effectiveness.
See appendix III for a more comprehensive description of these services.

The Ad Council retained one subcontractor, Madison Advertising Management,
LTD., (MAM), to provide advertising production cost review services for
about $636,000. MAM was responsible for tracking, analyzing, and managing
estimates and invoices detailing the production costs for media campaign
advertisements to ensure that production costs were reasonable and adhered
to ONDCP guidelines. MAM's goals were to work with the pro bono
advertising agencies, their production companies,

ONDCP, The Partnership for a Drug-Free America (PDFA), and the Ad Council
to minimize production costs without infringing on the creative process
and to maximize the cost efficiency of the media campaign.8

Fleishman-Hillard awarded about $8 million of its total contract award to
80 subcontractors for public communications and outreach services. These
subcontractors provided a wide range of services, including photography
and video services, research services, Internet technology services, and
an assortment of speaker and panelist services. See appendix IV for a
complete description of all services provided by Fleishman-Hillard
subcontractors and the associated award amounts for these services.

Of the estimated $8 million awarded by Fleishman-Hillard to
subcontractors, the vast majority-89 percent-went to 14 subcontractors
that provided campaign message promotion services. These services were
designed to extend the reach and influence of the media campaign beyond
the paid advertisements by using a variety of marketing techniques to
publicize the media campaign's anti-drug messages. For example, Rogers &
Associates was responsible for promoting the campaign's message by
encouraging the entertainment industry to incorporate specific media
campaign messages-such as the negative consequences of drug use-into
television show and movie plots. Another campaign message promotion
subcontractor, Campbell & Company, was responsible for using its social
marketing and public health experience to conduct public outreach to the
African American community-for example, developing partnerships with
school and community organizations to lend credibility to and extend the
reach of the media campaign.

Westat retained one subcontractor-the Annenberg School of Communication at
the University of Pennsylvania (Annenberg)-for an estimated $785,000.
Although Annenberg was responsible for providing

8In partnership with ONDCP and the advertising contractors, The
Partnership for a Drug-Free America engaged pro bono advertising agencies
to create and develop the advertising concepts of the media campaign.
Production companies selected by the pro bono agencies produced the actual
advertisements. These production companies developed production estimates
(i.e., estimates of the cost of producing the advertisement) and submitted
them to MAM for review. Production of the advertisements occurred only
after MAM recommended the production estimates to ONDCP for approval (and
ONDCP granted approval). After producing the advertisements, the
production companies submitted their invoices and cost reimbursement
totals to MAM. After MAM approved the reimbursement request, Ogilvy &
Mather reimbursed the production companies for the cost of producing the
advertisements.

overall support to Westat with respect to the entire scope of work
detailed in the prime contract, it was specifically directed to provide
particular support for the following six tasks: (1) project management,
(2) development of the campaign evaluation plan, (3) instrument
development, (4) data analysis and report generation, (5) preparation of
contract reports, and (6) modification of the campaign evaluation plan.

To determine the full range of subcontractor services, we reviewed the
agreements between the prime contractors and their 102 subcontractors.
From our analysis, we identified 16 distinct categories of services. Table
2 contains definitions and examples for each category.

Table 2: Services Provided by the 102 Subcontractors in Support of the
Media Campaign during Fiscal Years 2002 through 2004

Service category Subcontract tasks Examples

Administrative reporting 1. Project status reporting Providing monthly
summaries of spending

2. Meeting and coordinating with other campaign on television, radio, and
print time and

partners, contributors, and prime contractors space to air the media
campaign advertisements

3. Budget management and reporting Application of behavioral science
expertise Participation in the Behavioral Change Expert Panel.
Specifically, the application of specialized expertise to:

1. development of a Behavioral Briefa

2. 	review and revision of ad concepts during the preliminary phase of the
message creation process

3. 	evaluation of ad effectiveness in the post production and the post
distribution phases of the campaign Summarizing the major findings of
behavioral science research that are relevant to drug use behavior change
in youth and presenting this information to the pro bono advertising
agencies responsible for developing and producing the media campaign
advertisements

    Developing   Initiating relationships and         Identifying and         
partnerships  coordinating ONDCP's                 building coalitions     
                                                      with                    
                 anti-drug activities with               school and community 
                 professional, civic, and                    groups and using 
                 community associations; businesses;  their support to extend 
                 community                            the reach and           
                 anti-drug coalitions; and government strengthen the          
                                        organizations influence of the media  
                                                             campaign         

Entertainment industry outreach	Influencing popular culture by promoting
campaign Encouraging television shows popular messages about drug abuse
and addiction issues among youth to incorporate specific media through the
entertainment industry, including campaign messages-such as the negative
television, movies, music, and other forms of popular consequences of drug
use-into their plots entertainment

Meeting and event planning	Retaining experts as panelists or speakers to
the public in support of ONDCP's campaign, planning special events to
highlight the campaign messages, or generating event attendance through
promotional work

Internet marketing 	Web site development and maintenance or design and
production of banner ads Participating in media campaign roundtables-such
as the Marijuana & Kids Media Briefings, which included discussions about
the latest science on marijuana's neurological, health, and developmental
effects, particularly on young people

Answering "Ask the Expert" questions that are submitted through and posted
on theantidrug.com Web site Management of pro bono match Participation in
"Pro Bono Match," which refers to the Ensuring that media vendors (such as

activity	media campaign program addressing Congress' television stations,
radio stations, or requirement that for every dollar of advertising that
newspapers) donate free time and space to ONDCP spends, an equal dollar of
match activity in air media campaign ads in amounts equal to time, space,
or other in-kind contributions must be the time and space purchased from
them obtained. Management of pro bono match activity with media campaign
money. includes the negotiation, documentation, and tracking of all
required match activity

Materials development and Development and dissemination of materials such
as Distributing instructional brochures for

distribution 	brochures, fact sheets, and posters to support parents on
"Keeping Your Kids Drug Free" ONDCP's campaign messages

Service category        Subcontract tasks                Examples          
    Media outreach      Promoting campaign messages   Researching and writing 
                                  through broadcast       feature articles on 
                         media (radio, television); themes such as the        
                            print media (magazines, influence of popular      
                     newspapers); and display media culture on youth drug use 
                                  (posters, signs),       or substance        
                     with the goal of educating the abuse and related public  
                               media and the public health issues for         
                    about youth drug use. This does   submission to magazines 
                                 not include buying            and newspapers 
                           advertising time         

Media planning and buying	Development and execution of a strategy to buy
and Purchasing advertising media time and monitor media advertising time
and space designed space strategically to target specific media to deliver
maximum reach, frequency, and campaign audiences, such as American
effectiveness of the campaign at the lowest cost Indian parents and youth

Multicultural community outreach	Anti-drug activities designed to ensure
that ONDCP's campaign reaches targeted multicultural populations

Qualitative research 	Small-group methods such as focus groups, case
studies, and the development of background information on a defined issue
or problem

Quantitative research 	Surveys, content analysis, and other statistical
analysis of data

Stakeholder communications 	Communications designed to keep stakeholders
(i.e., ONDCP, PDFA, the prime contractors, and other campaign partners)
abreast of developments in the campaign and to generate further
involvement and support Establishing connections within target
multicultural communities for the purpose of ensuring that media campaign
messages reach their intended audiences.

Researching and reporting on the potential for using humor to address drug
prevention goals

Conducting a study on the prevalence and context of substance use and
abuse in 150 music videos most popular among youth for the purposes of
determining both the negative and positive substance-related messages to
youth audiences

Producing a bimonthly "Campaign Update" newsletter to be distributed to
all campaign partners

Strategic input General consultation and services given in support of
Providing advice on how to market to target the media campaign on an
as-needed basis audiences, such as how to create culturally sensitive
advertising that appeals to Hispanic parents

Trafficking of advertising Physical formatting of advertising and
distribution to Ensuring that the correct advertisements media vendors
(i.e., the actual film) are distributed to the television stations that
are airing them

  ONDCP's Comments and Our Evaluation

Source: GAO analysis of subcontracts.

aThe Behavioral Brief is a background document that describes the major
insights of research and literature that should be taken into account when
developing advertising intended to reach youth audiences.

We provided a draft of this report to the Director of the Office of
National Drug Control Policy for comment. In a March 14, 2005, letter, the
Director commented on the draft. His written response is presented in its
entirety in appendix V. In its comments, ONDCP generally agreed with our
report's findings, and we incorporated its technical comments where
appropriate. At the same time, ONDCP expressed some concerns about our
definition of consulting services as it had done throughout our review.
Specifically,

ONDCP argued that the "common use of the term" defines consultants as
providing advice only, not services. As discussed with ONDCP officials
throughout this review, we defined "consultants" as the prime contractors
and their subcontractors that provided services, including expert advice,
to implement the media campaign. Although the senate committee report that
mandated our review did not define the term "consultants," through our
consultations and its previous hearings, the committee expressed concerns
about the use of contractors and their subcontractors for the media
campaign. We used our definition of consultants to comprehensively account
for how campaign funds were being used to supplement ONDCP's in-house
capabilities regarding the advertising, public communications and
outreach, and evaluation aspects of the media campaign.

ONDCP also commented on a footnote in appendix IV of this report, which
cites a GAO appropriations law decision holding that ONDCP violated
publicity or propaganda prohibitions and the Anti-Deficiency Act when it
is used appropriated funds to produce several prepackaged news stories
which failed to disclose that ONDCP produced them for video news releases
(VNRs) used in the media campaign. ONDCP commented that it has not
produced a VNR since well before May 19, 2004, when GAO issued its first
decision, B-302710, on VNRs and prepackaged news stories. ONDCP also said
that it has no further plans to produce any VNRs, stating that GAO's
guidance on prepackaged news stories provided in our Circular Letter,
B-304272, February 17, 2005, is "inherently incompatible with contemporary
news gathering methods, thus rendering VNRs impracticable." However, the
guidance in the Circular Letter addresses the lack of attribution in
prepackaged news stories, which are only one part of VNRs. The Circular
Letter advises agencies that prepackaged news stories can be utilized
without violating the law, so long as there is clear disclosure to the
television viewing audience that this material was prepared by or in
cooperation with the government department or agency.

We are sending copies of this report to the Director, Office of National
Drug Control Policy, appropriate congressional committees, and other
interested parties. In addition, the report will be available at no charge
on GAO's Web site at http://www.gao.gov. If you or your staff have any
questions on this report, please call Glenn Davis on (202) 512-4301 or me
on (202) 512-8777.

Laurie E. Ekstrand, Director Homeland Security and Justice

                       Appendix I: Scope and Methodology

Our review of contractor services and contract award amounts associated
with the Office of National Drug Control Policy's (ONDCP) National Youth
Anti-Drug Media Campaign covered fiscal years 2002 through 2004. To
develop background critical to describing and evaluating key aspects of
the campaign, we conducted our work at the headquarters of ONDCP, The
Partnership for a Drug Free America (PDFA), and media campaign prime
contractors in Washington, D.C., and New York City. We reviewed the
legislation authorizing the campaign-The Drug-Free Media Campaign Act of
1998-and subsequently enacted campaign legislation, as well as reports,
testimony, interagency agreements, contracts, subcontracts, invoices, and
vouchers. In addition, to obtain information on the media campaign
process, we interviewed officials from ONDCP and PDFA. We also interviewed
officials from the four prime contractors: Ogilvy & Mather,
Fleishman-Hillard, the Ad Council, and Westat. To supplement our
understanding of some of the kinds of services provided by subcontractors,
we also interviewed officials from three of the subcontractors. In
addition, we reviewed guidelines, reports, and other background documents
relevant to the media campaign process provided by the officials we
interviewed. Finally, we reviewed the contracts between the prime
contractors and ONDCP, which laid out the objectives, strategies, and
processes of the campaign, as well as the subcontracts issued under those
prime contracts. While we reviewed the contract and subcontract documents,
we did not review any of the products resulting from those contracts or
subcontracts to determine whether they complied with any applicable laws.

To describe the services provided by contractors and their subcontractors
in support of the media campaign, we analyzed the contracts of the four
prime contractors and the subcontracts of the 102 subcontractors. We
obtained information about the roles and responsibilities of each of the
four prime contractors from the background, scope of work, and task
description sections of their respective contracts. Additionally, to
describe services provided by the 102 subcontractors, we developed a data
collection instrument (DCI) to allow us to analyze these services
uniformly by capturing the following information: (1) the subcontract
agreement date(s), (2) the prime contractor issuing the subcontract(s),
and (3) what task categories captured the tasks listed in the subcontract
agreement(s).1

1Two coders independently reviewed the subcontracts. If the coders
disagreed with the coding of a particular task, they reconciled their
responses before finalizing the DCI for the subcontract.

Appendix I: Scope and Methodology

We supplemented our analysis of the prime contracts and subcontracts with
information from interviews with officials from ONDCP and PDFA and
representatives from several prime contractors and subcontractors.

We estimated the amounts awarded to each of the four prime contractors
based on the award data contained in their contracts and any subsequent
modifications to these contracts related to awards. Each of the four prime
contracts was a "cost plus fixed fee" contract, meaning that with the
exception of a fixed fee, payments were disbursed in the form of
reimbursements for invoiced costs. Therefore, the award amounts listed in
the contract agreements were estimates of the amounts the contractors
would actually receive in reimbursements. Because these estimates were
constantly revised based on the status of campaign projects or other
information, contract modifications were used to update the contract award
data. For the purposes of this review, we used the latest contract
modifications to estimate the prime contractors' awards as they contained
the most recent information. Each of these contracts covered multiple
years. Awards for each year of the contract were estimated at the
beginning of the contract, and those yearly estimates were modified
throughout the life of the contract. The year time frames established by
the contracts (with the exception of the Westat contract) did not
correspond to government fiscal years and differed with each contractor.
For example, Ogilvy & Mather's contract year was from January to January
and Fleishman-Hillard's contract year was from December to December. In
order to estimate the prime contractors' award amounts by fiscal year, it
was necessary to prorate the award data listed in the contracts and
modifications. By prorating the award data, we obtained estimated award
data for each month and were then able to calculate estimated award
amounts by fiscal year. An example of this type of calculation appears
below.

                       Appendix I: Scope and Methodology

               Figure 3: Example of Award-Based Data Calculation

Source: GAO. Note: Numbers may not add due to rounding.

The major limitation of this method of analysis is that it assumes an
equal distribution of the total estimated award over the term of the
contract, which may not reflect the actual schedule of reimbursements to
the contractor. Another limitation of our analysis is that it relies on
estimates of the actual costs (i.e., estimated award amounts). We decided
to use estimated award data instead of the expenditure data provided by
ONDCP because the expenditure data were not complete.

We estimated the amounts awarded to each of the 102 subcontractors based
on the award data contained in their subcontracts and modifications to
these subcontracts. In 18 cases where subcontract award data were
insufficient, we used invoices and vouchers provided by the prime
contractors to estimate expenditure data. Subcontract award data were
determined to be insufficient if (1) the subcontract did not contain any
estimated award data or (2) the subcontract listed a rate of compensation
for services but did not specify a maximum term or compensation.

We classified the award data contained in the subcontracts of the 102
subcontractors into five types: (1) cost-reimbursable, (2) cost plus fixed
fee, (3) indefinite quantity/indefinite delivery, (4) firm fixed price,
and (5) rate-based. We analyzed each type of award data differently to
produce

Appendix I: Scope and Methodology

estimated award data for the 102 subcontractors for fiscal years 2002
through 2004. We analyzed the subcontracts containing cost-reimbursable,
cost plus fixed fee, and indefinite quantity/indefinite delivery award
data using the same method used to analyze the prime contractor award
data.

We analyzed the subcontracts containing firm fixed price award data using
the prorating method described above only if the term of the subcontract
covered multiple fiscal years. Many of these subcontracts had terms that
fell completely within a single fiscal year, in which case we assigned the
total award amount listed in the subcontract to the appropriate fiscal
year. Firm fixed price subcontracts are agreements in which the
subcontractor receives a fixed amount for the services it provides.
Regardless of the time the subcontractor requires to complete its assigned
tasks or whether the subcontractor incurs additional unexpected costs in
the completion of its assigned tasks, it will not receive any additional
funds without a subsequent modification to the subcontract. Consequently,
the award data contained in the firm fixed price subcontracts represents
the actual amount the subcontractor should have received.2

We analyzed subcontracts containing rate-based awards in a two-step
process to produce estimated awards by fiscal year. Subcontracts
containing rate-based data contain (1) a rate of compensation for the
subcontractor (for example, $200 per hour), (2) a maximum term (such as 10
hours) or maximum compensation (such as $2,000), and (3) a term or period
of performance (i.e. the period of time during which the subcontractor
will provide its service, such as between June 1, 2002, and June 30,
2002). We calculated the maximum possible award by multiplying the rate of
compensation by the maximum term (unless the subcontract specified a
maximum compensation). We considered this calculation of maximum possible
awards as the total estimated award amounts for all rate-based
subcontracts. If the term (period of performance) of the subcontract fell
within a single fiscal year, then the total estimated award of the
contract was assigned to the appropriate fiscal year. If the term (period
of performance) of the subcontract covered multiple fiscal years, then the
total estimated award was prorated as previously described, and total
estimated awards for each fiscal year were calculated. An example of this
type of analysis appears below.

2Because this review is not a contract audit, and we focused on the
estimated awards amounts for contractors and subcontractors, we did not
verify that contractors received the exact amounts listed in their firm
fixed price contracts.

                       Appendix I: Scope and Methodology

                Figure 4: Example of Rate-Based Data Calculation

Source: GAO.

In the 18 cases where we used invoices and vouchers to estimate
expenditure data because subcontract award data were insufficient, we
grouped the invoices and vouchers of each subcontractor by fiscal year and
totaled the invoice/voucher amounts for each fiscal year.

The methods of analysis used to produce estimated award data for
subcontractors for fiscal years 2002 through 2004 have many of the same
limitations as the method used to analyze the prime contract award data
(i.e., much of the subcontract award data had to be prorated and some of
the subcontract award data represented estimated reimbursements). In
addition, we had to substitute expenditure data in the case of 18
subcontracts that did not contain sufficient award data. Consequently, we
based some of our calculations related to total subcontractor estimates on
different types of data (expenditure or award). We decided to use
estimated award data whenever possible to ensure data consistency (i.e.,

Appendix I: Scope and Methodology

to avoid comparing contractor awards based on estimated award data with
subcontractor awards that were based on expenditure data).

We conducted our work from March 2004 through February 2005 in accordance
with generally accepted government auditing standards.

Appendix II: Three Phases of Advertising Development

To develop anti-drug television, print, Internet, and radio ads, the media
campaign employs a three-phase advertising development and research
process. The three phases of the advertising development and research
process are (1) the exploratory research phase (pre-ad creation); (2) the
qualitative and quantitative research and expert review phase (during ad
creation); and (3) the media planning, placement, and tracking phase
(post-ad creation).

The initial exploratory phase consists of extensive research to understand
the subject matter and covers many sources of information, including (1)
consumer insights, (2) national studies, (3) behavioral change experts,
and (4) subject matter experts. PDFA is a major source for this background
research. In addition, the Behavioral Change Expert Panel (BCEP),
assembled by Ogilvy & Mather, is composed of a number of individuals
possessing specialized expertise relevant to specific aspects of the media
campaign, such as the sociology of behavior change in youth or
communicating with minority audiences. The BCEP is responsible for
developing a Behavioral Brief, which is a background document that
describes the major insights of research and literature to consider when
developing advertising intended to reach youth audiences. The final goal
of the exploratory research phase is for Ogilvy & Mather and PDFA to
produce a Creative Brief for each advertising series.1 The Creative Brief
is a compilation of information provided by subject matter experts,
including (1) information relevant to the specific messages of the
campaign and (2) relevant portions of the qualitative research provided by
PDFA regarding consumer insights and national studies. The pro bono
agencies responsible for the creative development of a given advertising
series use the Creative Brief and the Behavioral Brief to inform their
efforts.

The second phase involves ad creation and qualitative and quantitative
research. PDFA is responsible for soliciting pro bono advertising agencies
that create the advertising concepts using the Creative and Behavioral
Briefs. The media campaign uses multiple pro bono advertising agencies to
develop advertisements. One example of a media campaign advertising series
is the "Monitoring/Love" series of advertisements-a message targeting
parents, promoting awareness of their children's activities. A single pro
bono ad agency developed all of the advertisements within this series.
After initial advertising concepts are developed, the Formative Creative
Evaluation Panel (FCEP) and the BCEP review these initial

1An advertising series consists of three or four similarly themed
advertisements.

Appendix II: Three Phases of Advertising Development

concepts.2 Next, feedback from FCEP and BCEP is used to revise the
advertising concepts. Any recommendations or observations that may be
relevant to future campaign efforts are to be kept for possible
applications to new Creative Briefs during the initial exploratory
research phase (i.e., the feedback loop in this iterative process).

Once the advertising concepts have been reviewed and revised, production
estimates are calculated and reviewed for maximum cost efficiency. Once
this process is completed, ONDCP is responsible for reviewing the ad
concepts and approving funding for production of the advertisements. After
advertisements are produced, they are submitted for copytesting, a process
used to determine whether advertisements meet effectiveness standards for
distribution. In the copytesting process, large sample audiences (usually
consisting of 300 youths and 150 parents per copytest session) view the
ads and are surveyed regarding their responses to the advertisement, drug
attitudes, beliefs, and behaviors. Copytesting relies on a comparison of
exposed audiences and nonexposed control audiences to determine
effectiveness of advertisements. According to Ogilvy & Mather (the
contractor responsible for implementing copytesting), the audience is
split evenly across ethnic, gender, and age categories. One-half of the
audience is exposed to the advertisement and the other half is not.
Copytesting researchers then survey and compare the drug beliefs and
intentions of each group to determine the effectiveness of the
advertisement. If an advertisement does not meet effectiveness standards
set by ONDCP, the advertisement is not aired. To successfully pass the
copytesting process, an advertisement must significantly strengthen
anti-drug beliefs or weaken intentions to use marijuana without creating
any adverse effects. Copytesting questions are designed so that the
information provided by the responses can be used to revise advertisements
that fail to meet effectiveness standards.

Media planning (determining where, when, and for how long to air or print
the advertisements) occurs concurrently with the advertising development
and assessment process. The media plan is finalized and executed (the
advertisements are distributed to media vendors) once the advertisements
have successfully completed the copytesting phase and the advertisements
have undergone a final review by ONDCP. After the advertisements air,

2FCEPs are evaluative discussion panels (i.e., focus groups), consisting
of target audience individuals (teens or parents) who are carefully
recruited and convened to review advertising concepts.

Appendix II: Three Phases of Advertising Development

audience reactions are to be tracked through an evaluative process that
measures the effectiveness of specific ads over time within specific
audience populations.3

3This evaluative process for the individual advertisements is separate
from the evaluation of the effectiveness of the media campaign as a whole
(the Westat study).

Appendix III: Ogilvy & Mather's Subcontractor Services and Associated Estimated
Award Amounts

During fiscal years 2002 through 2004, Ogilvy & Mather retained the
services of two groups of subcontractors: (1) multicultural media planning
and buying agencies and (2) substance use behavioral change experts- the
Behavioral Change Expert Panel. Ogilvy & Mather awarded nearly $5 million
to its 20 subcontractors.

  Multicultural Subcontractors Services and Estimated Awards

Six multicultural subcontractors provided services in support of Ogilvy &
Mather's media planning, placement, and purchase responsibilities. Each
multicultural subcontractor provided marketing services and strategies
with regard to a specific minority audience. Each multicultural
subcontractor was responsible for planning and buying media advertising
time and space targeting its minority audience, managing the pro bono
match activity that accompanied its media purchases, and trafficking
advertising to media vendors. The multicultural subcontractors also
assisted Ogilvy & Mather with its advertising creation and assessment
responsibilities by providing strategic input with regard to marketing to
minority audiences, particularly at the preliminary qualitative research
and initial ad concept review phases.

Ogilvy & Mather awarded more than $4 million to the multicultural
subcontractors, constituting about 90 percent of the nearly $5 million
amount awarded by Ogilvy & Mather to subcontractors during fiscal years
2002 through 2004. The awards received by multicultural subcontractors
covered only the cost of labor, overheard, and fees and did not include
any funding specifically designated for the purchase of media advertising
time and space.

Behavior Change Expert BCEP subcontractors mainly applied their
specialized expertise to three Panel Subcontractors aspects of the
advertising development and research process: (1) the Services and
Associated development of the Behavioral Brief,1 (2) the review and
revision of initial Estimated Award Amounts advertising concepts, and (3)
the evaluation of ad effectiveness in the

postproduction and postdistribution phases of the campaign. During the

initial exploratory research phase, the BCEP developed the Behavioral

1The Behavioral Brief is a background document that describes the major
insights of research and literature that pro bono ad agencies should be
aware of when developing advertisements intended to reach youth audiences.

Appendix III: Ogilvy & Mather's Subcontractor Services and Associated
Estimated Award Amounts

Brief and contributed to the development of the Creative Brief.2 The pro
bono advertising agencies engaged by PDFA used the Behavioral and Creative
Briefs to develop initial advertising concepts and preliminary ads. During
the qualitative research and expert review portion of the ad creation
phase, the BCEP reviewed the initial advertising concepts and preliminary
ads and contributed to the qualitative research process by recommending
improvements and revisions to the ads to foster behavior changes in the
target audiences. After the final production of the ads, the BCEP worked
with PDFA and Ogilvy & Mather to develop the questions used during the
copytesting and postdistribution evaluation processes to determine the
nature and extent of the effect of the ads on audience beliefs and
intentions. At any point during the advertising development and research
process, BCEP subcontractors were to provide strategic input and advice to
any media campaign partner on an as-needed basis.

Ogilvy & Mather awarded less than $500,000 to the BCEP subcontractors,
constituting about 10 percent of the nearly $5 million awarded by Ogilvy &
Mather to all of its subcontractors during fiscal years 2002 through 2004.

2Creative Briefs are constructed by Ogilvy & Mather and PDFA for specific
campaign messages. BCEP subcontractors are responsible for ensuring that
the points listed in Creative Briefs are accurate and consistent with
Behavioral Briefs.

Appendix IV: Fleishman-Hillard Subcontractor Services and Associated Estimated
Award Amounts

To support its public communications and outreach efforts,
Fleishman-Hillard retained the services of 80 subcontractors, which we
categorized in the following 10 groups: (1) campaign message promotion,
(2) photography and video production, (3) campaign message development,
(4) contracting management, (5) research, (6) internet technology, (7)
Marijuana & Kids Briefings panelists and speakers, (8) Library Working
Group experts, (9) Asian American and Pacific Islander Marijuana Media
Roundtable panelists and speakers, and (10) Teen Advisor Program experts.
Fleishman-Hillard awarded about $8 million to its 80 subcontractors.

Approximately 89 percent of the estimated $8 million dollars that
Fleishman-Hillard awarded was provided to a single category of
subcontractor-those responsible for campaign message promotion. Table 3
depicts award amounts within the remaining 11 percent (about $900,000),
which was awarded to nine categories of subcontractors.

Table 3: Estimated Contract Award Amounts to Groups of Fleishman-Hillard
Subcontractors by Fiscal Year (2002-2004)

                                Number of                          Aggregated 
            Group          subcontractors  2002       2003  2004       totals 
    Photography and video              11 $28,875 $281,199 $34,665   $344,739 
         production                                                
      Campaign message                 14 $82,777 $108,466 $22,313   $213,556 
         development                                               
     Contract management                1 $61,376 $98,972  $13,931   $174,279 
          Research                      5 $35,840 $45,198  $1,563     $82,601 
     Internet technology                4 $2,680  $25,800  $6,400     $34,880 
      Marijuana & Kids                 12 $2,300  $12,700        0    $15,000 
          briefings                                                
    Library Working Group               5 $5,000         0       0     $5,000 
           meeting                                                 
     Asian-American and                                            
      Pacific Islander                                             
          Marijuana                                                
      Media Roundtable                 10       0  $5,000        0     $5,000 
    Teen advisor program                4       0        0  $800         $800 
      Aggregated total                                               $875,855 

         Source: GAO analysis of estimated subcontractor award amounts.

Photography and Video Eleven photography and video production
subcontractors provided a wide

Production 	array of services, including photographing media campaign
promotional events and creating audiovisual materials promoting media
campaign

Appendix IV: Fleishman-Hillard Subcontractor Services and Associated
Estimated Award Amounts

messages.1 For example, one photography subcontractor was responsible for
photographing the media campaign's Boston Parent Wake-Up Rally and
processing the photographs for Web display and digital reproductions.
Gourvitz Communications, Inc. was responsible for producing a number of
videos for the media campaign, including the Marijuana Initiative Video
News Release and the Marijuana Community Coalition Video.

Fleishman-Hillard awarded an estimated total of nearly $345,000 to
photography and video production subcontractors during fiscal years 2002
through 2004. Within this group, the two largest awards went to video
production subcontractor Gourvitz Communications, Inc. (an estimated
$262,000) and to Court TV (an estimated $77,000). The remaining nine
awards were each for an estimated $1,500 or less.

  Campaign Message Development

Fourteen campaign message development subcontractors provided a wide array
of services, including planning and implementing promotional events and
researching and drafting feature articles for submission to print and
online media venues. For example, one campaign message development
subcontractor, Students Against Destructive Decisions, Inc. (SADD), was
responsible for raising public awareness of the risks of marijuana use by
planning and executing five guerrilla "Wake-Up" student rallies in which
students, dressed in distinctive clothing designed by ONDCP and SADD,
distributed media campaign materials in highly public urban sites during
rush hour. Another campaign message development subcontractor answered
"Ask the Expert" questions submitted through the media campaign's
"theantidrug.com" Web site and researched and wrote feature articles on
media campaign key messages that were placed on the Web site and submitted
to print media venues.

1A July 2004 congressional request asked us to examine several video news
releases (VNRs) produced for the media campaign. Those releases included,
among other things, several prepackaged news stories. Because those news
stories did not disclose to the targeted television viewing audiences that
they had been prepared at the government's behest, we determined in
B-303495, Jan. 4, 2005, Office of National Drug Control Policy- Video News
Release, and in B-303495.2, Feb. 15, 2005, Reconsideration of B-303495-
Office of National Drug Control Policy Prepackaged News Stories, that
ONDCP violated the publicity or propaganda prohibitions and the
Anti-Deficiency Act when it used appropriated funds to produce those
stories. GAO subsequently issued a Circular Letter, B304272, Feb. 17,
2005, advising agencies that prepackaged news stories can be utilized
without violating the law, so long as there is clear disclosure to the
television viewing audience that this material was prepared by or in
cooperation with the government department or agency. ONDCP commented that
it ceased producing VNRs well before May 2004, and has no plans to produce
any further VNRs.

Appendix IV: Fleishman-Hillard Subcontractor Services and Associated
Estimated Award Amounts

Fleishman-Hillard awarded an estimated $214,000 to campaign
messagedevelopment subcontractors during fiscal years 2002 through 2004.
Within this group, the four largest awards went to SADD (an estimated
$44,000), to Pride Youth Programs (an estimated $30,000), and to two
individual experts (estimated amounts of $54,000 and $25,500). The
remaining 10 awards were each for an estimated $14,000 or less.

Contract Management 	The sole subcontractor providing contract management
services was a temporary placement agency. This subcontractor provided
temporary personnel staff to Fleishman-Hillard to assist with the
preparation of invoices to be submitted to ONDCP regarding
Fleishman-Hillard projects. Fleishman-Hillard awarded an estimated
$174,000 to this subcontractor during fiscal years 2002 through 2004.

  Research

Five research subcontractors provided a wide array of services, including
analyzing media campaign marketing strategies and reporting on the kinds
of drug-related messages currently influencing America's youth. For
example, one research contractor, MarketBridge was responsible for
demonstrating and quantifying the value of corporate partnerships to the
media campaign. Another research subcontractor, Mediascope, was
responsible for conducting a study on the prevalence and context of
substance use and abuse in the 150 most popular music videos for the
purposes of identifying the negative and positive substance-related
messages targeting youth audiences.

Fleishman-Hillard awarded an estimated $83,000 to research subcontractors
during fiscal years 2002 through 2004. Within this group, the largest
award, an estimated $56,000, went to MarketBridge. The remaining four
awards were each for an estimated $10,000 or less.

                              Internet Technology

Four Internet technology subcontractors provided a wide range of services
including e-mail distribution and Web site development. For example, an
Internet technology subcontractor, Experian eMarketing Services, was
responsible for creating and sending e-mail messages to recipient lists
created by Fleishman-Hillard, using content provided by Fleishman-Hillard.
Another Internet technology subcontractor, TestPros, assessed the
usability of two media campaign Web sites.

Fleishman-Hillard awarded an estimated $35,000 to Internet technology
subcontractors during fiscal years 2002 through 2004. Within this group,

Appendix IV: Fleishman-Hillard Subcontractor Services and Associated
Estimated Award Amounts

the largest award, an estimated $17,500, went to Experian eMarketing
Services. The remaining three awards were each for an estimated $11,000 or
less.

                           Marijuana & Kids Briefings

Twelve Marijuana & Kids Briefings subcontractors served as panelists and
speakers in roundtable discussions addressing the latest science on
marijuana's neurological, health, and developmental effects on youth.

Fleishman-Hillard awarded an estimated $15,000 to these subcontractors
during fiscal years 2002 through 2004 to panelists and speakers for its
Marijuana and Kids Briefings. All of the Marijuana & Kids Briefings'
subcontractors were individual experts, rather than firms. Most of these
subcontractors were paid at a daily rate of $500, with a maximum term of
service of 1 day. Within this group, the largest award went to an
individual expert for an estimated $9,000. The remaining 11 awards were
each for an estimated $1,000 or less.

                             Library Working Group

The purpose of the Library Working Group was to explore how librarians and
other adults can help kids find accurate, high-quality information about
drugs on the Internet. Five Library Working Group subcontractors provided
a range of services including advising on common library and Internet
issues; assisting in the development of instructional products about
cyberliteracy and illicit drugs; and recommending strategies, vehicles,
and partnerships to accomplish program goals.

Fleishman-Hillard awarded an estimated $5,000 to Library Working Group
subcontractors during fiscal years 2002 through 2004. All of the Library
Working Group subcontractors were individual expert, rather than firms.
Each of the five subcontractors received a total estimated award of
$1,000.

  Asian American and Pacific Islander Marijuana Media Roundtables

Ten Asian American and Pacific Islander Marijuana Media Roundtable
subcontractors served as panelists and speakers in roundtable discussions
to address the latest scientific findings on marijuana's neurological,
health, and developmental effects on youth.

Fleishman-Hillard awarded an estimated $5,000 to Asian American and
Pacific Islander Marijuana Media Roundtable subcontractors during fiscal
years 2002 through 2004. All of the Asian American and Pacific Islander
Marijuana Media Roundtable subcontractors were individual experts,

 Appendix IV: Fleishman-Hillard Subcontractor Services and Associated Estimated
                                 Award Amounts

rather than firms. Each of these subcontractors received a total estimated
award of $500.

                              Teen Advisor Program

Four Teen Advisor Program subcontractors were responsible for providing
insight and feedback on the campaign's youth-oriented strategies in order
to guide the development of teen programs, events, and Web site content.

Fleishman-Hillard awarded an estimated $800 to Teen Advisor Program
subcontractors during fiscal years 2002 through 2004. All of the Teen
Advisor Program subcontractors were individual experts, rather than firms.
Each of the four subcontractors received a total estimated award of $200.

Appendix V: Comments from the Office of National Drug Control Policy

Appendix V: Comments from the Office of National Drug Control Policy

Appendix VI: GAO Contacts and Staff Acknowledgments

GAO Contacts

  Staff Acknowledgments

(440293)

Laurie E. Ekstrand (202) 512-8777
Glenn G. Davis (202) 512-4301

In addition to those named above, the following individuals contributed to
this report: David Alexander, Leo Barbour, R. Rochelle Burns,
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