Anti-Drug Media Campaign: ONDCP Met Most Mandates, but Evaluations of
Impact Are Inconclusive (Chapter Report, 07/31/2000,
GAO/GGD/HEHS-00-153).

Pursuant to a legislative requirement, GAO reviewed the Office of
National Drug Control Policy's (ONDCP) National Youth Anti-Drug Media
Campaign, focusing on: (1) whether ONDCP provided timely financial
reports to Congress; (2) how funds for paid advertising were managed and
disbursed; (3) whether ONDCP complied with certain statutory
requirements regarding the obligation of funds; (4) what ONDCP has done
to develop and implement guidelines for the Campaign in response to
program requirements; (5) whether the evaluation designs for phases I,
II, and III were appropriate and how well the phases I and II
evaluations were implemented; and (6) how effective phases I and II of
the Campaign were in influencing group awareness of different types of
paid anti-drug media messages and drug attitudes.

GAO noted that: (1) in response to statutory financial reporting
requirements and certain statutory spending restrictions, ONDCP
generally provided timely financial reports to the appropriate
Committees and complied with selected statutory spending restrictions
imposed by Congress for fiscal years (FY) 1998 and 1999; (2) ONDCP had
processes in place to monitor and approve all paid advertising
expenditures before paying vendors and reporting to Congress; (3)
ONDCP's success in meeting the congressionally mandated program
requirements was mixed; (4) the match program, which was developed
during phase I of the Campaign to meet the congressional requirement
that ONDCP supplement existing public service announcements (PSA),
resulted in over 265,000 pro bono or match PSAs; (5) due to the need to
meet the Campaign's reach and frequency goals, ONDCP may not be able to
meet the current congressional direction that it obtain a pro bono match
as a part of each buy from every vendor; (6) contractor officials
explained that some vendors were unwilling or financially unable to
provide a match; (7) in some of these cases, it was necessary to make a
purchase without the match so that ONDCP could meet the Campaign's reach
and frequency goals in that market; (8) ONDCP did not develop a plan to
secure private sector contributions; (9) ONDCP officials told GAO that
they do not believe they will ever be able to attain the highest level
of the congressionally mandated levels of contributions, which range
from 40 to 100 percent of the annual Campaign appropriations for FY 1999
through FY 2002; (10) ONDCP developed policy and guidance prohibiting
advertisements that feature political figures or partisan political
purposes and established an advertisement review process; (11) the
results of the phases I and II evaluations regarding the Campaign's
impact on youth, teen, and parent advertisement awareness and drug
attitudes were inconclusive due to site selection problems, unknown
parent response rates, low school response rates, and data analysis
issues; (12) the 4-year phase III evaluation began in 1999, and its
design appears promising; and (13) Ogilvy and Mather, the phase III
advertising contractor, is to examine the impact of each media element,
and the National Clearinghouse for Alcohol and Drug Information is to
continue to collect data through the end of year 2000 on the volume of
public contracts and reports distributed as supplemental measures of
Campaign awareness/exposure.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  GGD/HEHS-00-153
     TITLE:  Anti-Drug Media Campaign: ONDCP Met Most Mandates, but
	     Evaluations of Impact Are Inconclusive
      DATE:  07/31/2000
   SUBJECT:  Government information dissemination
	     Cost sharing (finance)
	     Financial management
	     Reporting requirements
	     Drug abuse
	     Advertising
	     Program evaluation
	     Mass media
IDENTIFIER:  ONDCP National Youth Anti-Drug Media Campaign
	     National Survey of Parents and Youth
	     Community Longitudinal Survey of Parents and Youth

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GAO/GGD/HEHS-00-153

ANTI- DRUG MEDIA CAMPAIGN

ONDCP Met Most Mandates, but Evaluations of Impact Are Inconclusive

United States General Accounting Office

GAO Report to Congressional Committees

July 2000 GAO/ GGD/ HEHS- 00- 153

United States General Accounting Office General Government Division
Washington, D. C. 20548

Page 1 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

B- 281160 July 31, 2000 The Honorable Ben Nighthorse Campbell Chairman The
Honorable Byron L. Dorgan Ranking Minority Member Subcommittee on Treasury

and General Government Committee on Appropriations United States Senate

The Honorable Jim Kolbe Chairman The Honorable Steny Hoyer Ranking Minority
Member Subcommittee on Treasury, Postal Service,

and General Government Committee on Appropriations House of Representatives

The conference report and Senate Appropriations Committee Report for the
Treasury and General Government Appropriations Act for 1999 required us to
review various aspects of the Office of National Drug Control Policy's
(ONDCP) National Youth Anti- Drug Media Campaign. In response to the
legislative mandate and discussions with your Subcommittees, this report
discusses (1) whether ONDCP provided timely financial reports to Congress;
how funds for paid advertising were managed and disbursed; and whether ONDCP
complied with certain statutory requirements regarding the obligation of
funds; (2) what ONDCP has done to develop and implement guidelines for the
Campaign in response to program requirements set out in Public Law 105- 61
and Public Law 105- 277; and (3) whether the evaluation designs for phases
I, II, and III were appropriate; how well the phases I and II evaluations
were implemented; and how effective phases I and II of the Campaign were in
influencing group awareness of different types of paid anti- drug media
messages and drug attitudes. This report contains recommendations to the
Director of ONDCP regarding the development and implementation of certain
Campaign guidelines.

We are sending copies of this report to the Chairmen and Ranking Minority
Members of other appropriate congressional committees; the Honorable Barry
R. McCaffrey, Director of the Office of National Drug Control Policy; the
Honorable Jacob J. Lew, Director of the Office of Management and Budget; and
other interested parties. Copies will also be made available to others upon
request.

B- 281160

Page 2 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

If you have any questions regarding this report, please call me at (202)
512- 8816 or Daniel C. Harris, Assistant Director, at (202) 512- 8720. You
may also reach us by E- mail at stanar. ggd@ gao. gov or harrisd. ggd@ gao.
gov. The major contributors to this report are listed in appendix IV.

Richard M. Stana Associate Director, Administration of

Justice Issues

Page 3 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

Executive Summary

Page 4 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

The Office of National Drug Control Policy's (ONDCP) National Youth Anti-
Drug Media Campaign, which was proposed as a nearly $1 billion federal
effort over 5 years, was developed in response to reported increases in drug
use among youth in the United States. 1 The conference report 2 and the
Senate Appropriations Report 3 for the Treasury and General Government
Appropriations Act of 1999 directed GAO to (1) conduct a financial audit and
review of the ONDCP Media Campaign, (2) review ONDCP's compliance with
certain Campaign program requirements that are listed in the public law, and
(3) review certain aspects of the results of phase I of the Campaign (of 3
phases). On the basis of subsequent discussions with the Subcommittee on
Treasury and General Government, Senate Committee on Appropriations, and the
Subcommittee on Treasury, Postal Service, and General Government, House
Committee on Appropriations, GAO agreed to determine

ï¿½ whether ONDCP provided timely financial reports to Congress as required by
Public Law 105- 61 and Public Law 105- 277; how funds for paid advertising
were managed and disbursed; and whether ONDCP complied with certain
statutory requirements regarding the obligation of funds;

ï¿½ what ONDCP has done to develop and implement guidelines for the Campaign
in response to the program requirements set out in Public Law 105- 61 and
Public Law 105- 277; and

ï¿½ whether the evaluation designs for phases I, II, and III were appropriate;
how well the phases I and II evaluations were implemented; and how effective
phases I and II of the Campaign were in influencing group awareness of
different types of paid anti- drug media messages (ad awareness) 4 and drug
attitudes.

ONDCP has complied with most statutory requirements regarding Media Campaign
funds and program guidelines, although ONDCP may not be able to fully comply
with certain congressional requirements that were enacted after the initial
legislation establishing the Campaign. Evaluations of the first two phases
of the Campaign remain inconclusive, due to various evaluation survey design
and implementation limitations. However, various other indicators, such as
the Department of Health and Human Service's Substance Abuse and Mental
Health Service Administration's

1 Public Law 105- 61, 111 Stat. 1293, 1294 (1997). 2 H. R. Conf. Rep. No.
105- 825, 1493, 1497 (1998). 3 S. Rep. No. 105- 251, 58- 59 (1998). 4 ONDCP,
Testing the Anti- Drug Message in 12 Cities National Youth Drug Media
Campaign: Phase I (Report No. 2), p. 2- 1, March 1999. Purpose

Results in Brief

Executive Summary Page 5 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

National Clearinghouse for Alcohol and Drug Information (NCADI) data and
focus group and community key informant input, support the conclusion that
the Campaign was having some positive effects during phases I and II. The
phase III evaluation design appears promising; implementation of this phase
began in 1999.

In response to statutory financial reporting requirements and certain
statutory spending restrictions, ONDCP generally provided timely financial
reports to the appropriate Committees and complied with selected statutory
spending restrictions imposed by Congress for fiscal years 1998 and 1999. In
addition, GAO noted that although ONDCP used administrative contract support
from other federal agencies to assist with the paid advertising contracts,
it remained responsible for ensuring that only valid Campaign expenses were
paid. In doing so, ONDCP had processes in place to monitor and approve all
paid advertising expenditures before paying vendors and reporting to
Congress.

ONDCP's success in meeting the congressionally mandated program requirements
was mixed. The match program, which was developed during phase I of the
Campaign to meet the congressional requirement that ONDCP supplement
existing public service announcements (PSA), resulted in over 265,000 pro
bono or “match” PSAs. However, due to the need to meet the
Campaign's reach and frequency goals, ONDCP may not be able to meet the
current congressional direction that it obtain a pro bono match as a part of
each buy from every vendor. This requirement was imposed after the
development of the match program. Contractor officials explained that some
vendors were unwilling or financially unable to provide a match. In some of
these cases, it was necessary to make a purchase without the match so that
ONDCP could meet the Campaign's reach and frequency goals in that market.
GAO is making a recommendation in this report to help address this conflict.

According to ONDCP, its work with community anti- drug coalitions was
limited in the first two phases of the Campaign due to ONDCP's need to focus
efforts on planning and executing the paid advertising Campaign. However,
ONDCP and contractors planned and/ or initiated numerous initiatives for
phase III.

As of the date of GAO's review, ONDCP had not developed a plan to secure
private sector contributions. ONDCP had anticipated having a plan in place
by October 2000 but, as of the date of GAO's review, had fallen behind in
meeting the schedule necessary to complete work by that date. ONDCP
officials told GAO that they do not believe they will ever be able to attain

Executive Summary Page 6 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

the highest level of the congressionally mandated levels of contributions,
which range from 40 to 100 percent of the annual Campaign appropriations for
fiscal years 1999 through 2002. GAO is making a recommendation in this
report to help clarify this matter.

ONDCP (1) developed policy and guidance prohibiting advertisements that
feature political figures or partisan political purposes and (2) established
an advertisement review process. However, ONDCP had no internal controls
requiring that the reviews be documented. GAO is making a recommendation in
this report to correct this situation.

The results of the phases I and II evaluations regarding the Campaign's
impact on youth, teen, and parent ad awareness and drug attitudes were
inconclusive due to various design, implementation, and analytical
limitations. Site selection problems, unknown parent response rates, low
school response rates, and data analysis issues contributed to the
inconclusive youth, teen, and parent survey data. However, unweighted
findings from phases I and II, input from community sources, and data from
NCADI provided indications that the initial phases of the Campaign had some
positive effects. The 4- year, phase III evaluation began in 1999, and its
design appears promising, given its more comprehensive scope and
methodological sophistication. In addition, Ogilvy and Mather, the phase III
advertising contractor, is to examine the impact of each media element, and
NCADI is to continue to collect data through the end of calendar year 2000
on the volume of public contacts and reports distributed as supplemental
measures of Campaign awareness/ exposure.

ONDCP officials reviewed a draft of this report and generally agreed with
its findings, conclusions, and recommendations.

In the Treasury and General Government Appropriations Act for 1998, Congress
required that ONDCP submit a campaign strategy for approval to the
Committees on Appropriations and the Senate Judiciary Committee that
included the following requirements:

ï¿½ guidelines to ensure and certify that funds will supplement and not
supplant current anti- drug community- based coalitions and current pro bono
public service time donated by national and local broadcasting networks;

ï¿½ guidelines to ensure and certify that funds are not used for partisan
political purposes and that funded advertisements do not feature any elected
officials, persons seeking elected office, cabinet- level officials, or
Background

Executive Summary Page 7 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

certain other federal officials, absent advance notice to the respective
congressional Committees;

ï¿½ a detailed implementation plan is to be submitted to the Committees for
securing private sector contributions, including but not limited to in- kind
contributions;

ï¿½ a detailed implementation plan is to be submitted to the Committees
stating the qualifications that are necessary for any organization, entity,
or individual to receive funding for or otherwise be provided broadcast
media time; and

ï¿½ a system is to be developed to measure outcomes of success of the Media
Campaign.

The act further required that the Director of ONDCP report to Congress
quarterly on the obligation of funds, as well as specific parameters of the
Campaign, and report to Congress within 2 years on the effectiveness of the
Campaign. In addition, the act placed certain restrictions on the obligation
of Campaign funds.

In fiscal year 1999, Congress placed additional requirements in the
Campaign's appropriations acts regarding financial reporting; obligation of
funds; public service time (requiring ONDCP to obtain a pro bono match as a
part of each buy from every vendor); private sector contributions (requiring
ONDCP to obtain contributions ranging from 40 to 100 percent of the annual
Campaign appropriations for fiscal years 1999 through 2002, respectively);
and other aspects of the Campaign. In fiscal year 2000, Congress required
that ONDCP not obligate 10 percent of available funds until it submitted a
plan for corporate sponsorship to the Appropriations Committees.

In response to the previously mentioned requirements, ONDCP submitted a
Campaign strategy to the appropriate Committees in November 1997 and, as
requested by the Committees, provided additional information in early 1998.
In addition, ONDCP officials provided Congress with oral reports regarding
spending during the early months of the Campaign and, in May 1998, began
providing periodic written reports on Campaign obligations and expenditures.
These officials also provided impact evaluation reports regarding Campaign
effectiveness in August 1998, September 1998, March 1999, and June 1999.

The centerpiece of the Campaign is the paid advertising effort in which
Campaign funds are used to purchase media time and space for advertisements
that deliver anti- drug messages to the Campaign's target audiences. The
initial reach and frequency goal for the paid advertising

Executive Summary Page 8 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

component was to reach 90 percent of the target audiences with at least four
messages a week, across all types of media. 5

The Campaign is being implemented in the following three phases:

ï¿½ Phase I, a 12- city pilot focused on paid advertising with very limited
implementation of the other Campaign components, ran from January 1998
through July 1998.

ï¿½ Phase II,a nationwide extension of the pilot to include all media types
and very limited implementation of the other Campaign components, ran from
July 1998 through December 1998.

ï¿½ Phase III, a continuation of the nationwide advertising Campaign with
expanded implementation of the other Campaign components, is to run from
January 1999 through December 2002.

ONDCP uses advertising contractors to obtain the media planning, purchasing,
and other advertising expertise that is necessary to conduct the paid
advertising component of the Campaign. Paid advertising includes national
and local television, radio, and cable and newspaper, magazine, and Internet
advertisements, among others. During fiscal years 1998 and 1999, paid
advertising accounted for approximately 84 percent of the total Campaign
expenditures that ONDCP reported to Congress.

ONDCP also relied on other federal agencies for administrative contract
support. However, ONDCP remained responsible for ensuring that the
contractors' performance met the advertising objectives of the Campaign.
This responsibility included selecting contractors, ensuring that contracts
and related modifications were in accordance with ONDCP's media plan, and
authorizing payment of the various media advertising costs.

In performing its review, GAO did not

ï¿½ verify the accuracy of the financial reports provided to Congress or other
financial information provided;

ï¿½ test ONDCP's processes to oversee paid advertising spending to ensure that
the procedures were effective and properly implemented;

ï¿½ review the documents supporting every Campaign obligation;

ï¿½ review ONDCP's compliance with other statutory spending requirements, such
as restrictions regarding the type of activities for which Campaign funds
may or may not be used;

5 “Reach and frequency goal” refers to communicating the message
to a certain percentage of the target audiences a certain number of times a
week.

Executive Summary Page 9 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

ï¿½ verify the accuracy of the youth, teen, and parent survey response data
that were collected in phases I and II, or that of the NCADI and community
informant data obtained; and

ï¿½ conduct a detailed assessment of ONDCP's phases I and II qualitative
evaluations (e. g., focus groups and key informant interviews); instead, GAO
focused on the quantitative youth, teen, and parent evaluations since these
were ONDCP's focus.

In response to statutory financial reporting requirements, ONDCP generally
provided timely financial reports to the Committees. ONDCP provided oral
reports during the early months of the Campaign and provided its first
written report, covering the first 8 months of the Campaign, in May 1998.
Since then, ONDCP provided timely written financial status reports on a
monthly basis, except in October, November, and December, 1998, and October
1999 because of delays in closing the accounting records for one fiscal year
and opening records for the new fiscal year. The reports provided cumulative
obligations and expenditures. Although not statutorily required to submit
reports in fiscal year 2000, ONDCP plans to do so. However, neither written
nor oral reports have been issued in fiscal year 2000 to date, due to delays
associated with (1) upgrading the Executive Office of the President's
financial accounting system that maintains the accounting records and (2)
ONDCP's plans to change the financial report's format.

ONDCP had processes in place to monitor and approve all paid advertising
expenditures before paying vendors and reporting to Congress. ONDCP uses
advertising contractors to carry out the paid advertising portion of the
Campaign. These contracts accounted for about 84 percent of the total
Campaign expenditures as of September 30, 1999. ONDCP used contract support
agents to assist them with these contracts but remained responsible for
ensuring that only valid Campaign expenses were paid.

ONDCP complied with selected statutory spending restrictions that were
imposed by Congress for fiscal years 1998 and 1999. In fiscal year 1998,
ONDCP was not to obligate Campaign funds before submitting a Campaign
strategy for approval to the Appropriations Committees and the Senate
Judiciary Committee. Additionally, obligation of $17 million before
September 30, 1999, was restricted. ONDCP submitted a strategy to Congress
in November 1997 and by December 10, 1997, received approval Principal
Findings

ONDCP Generally Provided Timely Financial Reports and Obligated Funds
According to Selected Statutory Restrictions

Executive Summary Page 10 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

to begin obligating funds. On the basis of GAO's review of contracts and
other obligating documents representing 91 percent of the 1998 appropriation
available for obligation, the first obligation of the Campaign was incurred
on December 18, 1997. The Office of Management and Budget did not apportion
$17 million until after the end of fiscal year 1998 to ensure compliance
with that restriction. In fiscal year 1999, ONDCP was prohibited from
obligating (1) funds before ONDCP had submitted a report on the evaluation
and results of phase I of the Campaign to the Appropriations Committees and
(2) more than 75 percent of Campaign funds before submitting a report on
phase II. GAO's review of contracts and other obligating documents,
representing 94 percent of the 1999 appropriation, indicated that ONDCP
complied with these restrictions.

ONDCP is required to hold back 10 percent of the fiscal year 2000
appropriation until ONDCP submits a corporate sponsorship plan to the
Appropriations Committees. ONDCP officials said that they would monitor
compliance with this restriction.

To meet the congressional requirement that ONDCP supplement existing PSAs,
ONDCP developed the match program. Under this program, ONDCP requires its
advertising contractors, when purchasing advertising time or space, to
obtain either an equivalent value of time and space or an equivalent in-
kind contribution, pro bono, for the PSAs of qualifying organizations. This
program resulted in over 265,000 free or match PSAs, valued at approximately
$148 million and benefiting 45 organizations as of the time of GAO's review.
GAO's review of advertising company documentation indicated with 95- percent
statistical confidence that contractors were successful in achieving at
least a 100- percent rate of match- to- paid advertising value. However, due
to the need to meet the advertising Campaign's reach and frequency goals,
ONDCP may not be able to meet the current congressional direction that it
obtain a pro bono match as a part of each buy from every vendor. This
requirement was imposed after the development of the match program.
Contractor officials explained that some vendors were unwilling or
financially unable to provide a match, or free airtime. In some of these
cases, it was necessary to make a purchase without the match so that ONDCP
could meet the Campaign's reach and frequency goals in that market.
According to the contractors, for the time period covering June 29, 1998, to
December 31, 1999, time and space were purchased from 2, 991 media vendors.
Of this Compliance With Statutory

Program Requirements Was Mixed

Executive Summary Page 11 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

total, the contractors made purchases from 12 vendors who did not provide a
match. 6

According to ONDCP, its work with community anti- drug coalitions was
somewhat limited in the first two phases of the Campaign, due to the need to
focus efforts on planning and executing the paid advertising Campaign.
During phases I and II, most of ONDCP's time was directed at getting the
paid advertising out in the 12 pilot cities and then expanding the effort
nationally. According to ONDCP, phase III will provide the opportunity to
fully develop and implement work with community anti- drug coalitions. ONDCP
and nonadvertising contractors planned and/ or instituted numerous
initiatives for phase III.

As of the date of GAO's review, ONDCP had not developed a plan to secure
private sector contributions. According to ONDCP officials, a plan developed
by a contractor in 1998 was not implemented for several reasons, including
(1) legal difficulties with the contract, (2) the ONDCP belief that it might
be possible to develop a better plan, (3) the need to plan and execute the
paid advertising segment of the Campaign, and (4) ONDCP staffing
limitations. ONDCP anticipated having a plan in place by October 2000 but,
as of the date of GAO's review, fell behind in meeting the schedule
necessary to complete work by that date. Even without a plan, as of the date
of GAO's review, ONDCP reported contributions valued at an estimated $71. 7
million. Beginning in fiscal year 1999, Congress directed ONDCP to develop a
plan to secure contributions equaling 40 to 100 percent of the Campaign's
annual appropriations for fiscal years 1999 through 2002. Officials told GAO
that even when a plan is finalized, ONDCP might not be able to attain these
congressionally mandated levels of contributions. ONDCP plans to learn more
about the availability of private sector contributions as it goes through
the process of obtaining a contractor to implement a contributions plan.

ONDCP and the Partnership for a Drug- Free America (PDFA) developed guidance
prohibiting advertisements that feature political figures or partisan
political purposes and established an advertisement review process.
Advertising agencies must submit proposed advertisements to PDFA's Creative
Review Committee (CRC), which is to review the advertisements following a
29- step process. None of these steps address the prohibition on political
figures or partisan purposes. CRC recommendations are to be documented in a
creative status report. This

6 The overall match rate exceeded 100 percent because some media vendors
provided a match in excess of a dollar- for- dollar value.

Executive Summary Page 12 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

report does not require documentation of review for political figures or
partisan content. The final review is to be made in ONDCP's Office of Legal
Counsel. These reviews are not documented. The Comptroller General's
Standards for Internal Control in the Federal Government (GAO/ AIMD- 00-
21.3.1) requires that all transactions and significant events are to be
clearly documented, and that the documentation is to be readily available
for examination.

Phases I and II principally focused on testing the impact of the Media
Campaign on youth, teen, and parent ad awareness at the local and national
levels, respectively. Ad awareness and other outcome results for those
phases of the Campaign were inconclusive for each of the three groups, due
to several design, implementation, and analytical limitations.

These limitations included site selection problems, unknown parent response
rates, low school response rates, ad awareness measurement problems, and
data weighting issues. Four of the 12 comparison sites dropped out of the
phase I study; of these 4 sites, 2 did not have comparable replacements.
School response rates for youth and teens in phase II were less than 30
percent; comparison site school response rates in phase I were less than 50
percent. Ad awareness was not based on viewing all types of Campaign
advertisements- but instead focused exclusively on television
advertisements.

Other data sources provided evidence that the Campaign had some positive
effects during phases I and II. NCADI demonstrated increased public contacts
and publication distribution during the Campaign, as compared with the pre-
Campaign period. Community sources credited the Campaign with fostering
several anti- drug activities and changes in their localities. In addition,
GAO's examination of unweighted survey data for phases I and II showed some
positive gains on most ad awareness items. In addition, the phases I and II
data did not show any significant changes in respondents' drug attitudes.

The 4- year, phase III evaluation design appeared more promising than the
previous phases in being able to effectively assess the impact of the
Campaign. A comprehensive model of the relationship between media exposure
and drug attitudinal and behavioral change was being tested for the first
time in phase III. The respondent sampling design overcame some of the
limitations of phases I and II- including the use of household surveys to
increase response rates, rather than school and telephone interviews. The
phase III measurement of advertisement exposure is much more inclusive than
the measure of ad awareness in phases I and II Phases I and II Evaluations

Were Inconclusive; Phase III Evaluation Design Appeared Promising

Executive Summary Page 13 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

because the measurement includes both lagged 7 and historic trend analyses,
rather than just percentage change scores. In addition, Ogilvy and Mather
are to conduct an ongoing phase III assessment of the impact of each media
element relevant to cost, in order to maximize the effectiveness of the
Campaign. Finally, NCADI is to continue collecting data on public contacts
and publication distribution as supplemental measures of ad awareness and
exposure through the end of calendar year 2000.

To improve ONDCP's compliance with the statutory program requirements, GAO
recommends that the Director of ONDCP ensure that the appropriate ONDCP or
contractor staff take the following actions:

ï¿½ To determine the extent to which matches do not occur because of efforts
to achieve the Campaign's reach and frequency goals, maintain documentation
of all purchases that do not result in a match, including data on why the
vendor did not provide a match and why the purchase was made without a
match. This information should be provided to Congress to assist in its
assessment of the viability of the current congressional direction that
ONDCP obtain a match from each and every seller of advertising time and
space, given the Campaign's reach and frequency goals.

ï¿½ After adequate research and consultation with experts, provide information
to Congress detailing the anticipated dollar value of all private- sector,
nonmatch contributions to assist Congress in its assessment of the viability
of the private- sector contributions goals and the dollar value that ONDCP
can be expected to obtain from the private sector.

ï¿½ Develop internal controls, in accordance with the Comptroller General's
standards, to ensure that the reviews of new advertisements for political
figures or partisan content are fully documented and available for
examination.

GAO provided a draft of this report to the Director of ONDCP for comment.
ONDCP provided written comments, which are discussed at the end of chapters
2, 3, and 4. GAO also provided relevant sections of the draft report to the
Department of Defense's Office of the Inspector General and the Department
of Health and Human Services' Program Support Center, National Institute on
Drug Abuse, and Substance Abuse and Mental Health Services Administration
for a review of the facts pertaining to them. These organizations, as well
as ONDCP, provided technical or clarifying

7 “Lagged” analyses refer to the study of changes taking place
over time, rather than concurrently. Recommendations

Agency Comments and GAO's Evaluation

Executive Summary Page 14 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

changes, which have been incorporated, as needed, in the appropriate
sections of this report.

Overall, ONDCP agreed with GAO's findings, conclusions, and recommendations.
It stated that the report is balanced, with fair assessments and
recommendations. ONDCP also said that the draft report could have given
greater recognition to various factors that were out of ONDCP's control in
implementing the Campaign.

In commenting on GAO's findings and conclusions relating to the financial
aspects of the Campaign, ONDCP inferred that GAO conducted a financial
audit. It added that internal controls allowed ONDCP to monitor the
expenditures and control payments of outside contractors. GAO emphasizes
that it did not conduct a standard financial audit of the Campaign's fiscal
operations or review the related internal controls. Also, GAO did not
conduct a contract management audit or review how the internal controls were
applied during the contract administration process.

ONDCP asked GAO to amend the draft report to reflect that ONDCP has
submitted to the Appropriations Committees a plan to secure corporate
sponsorship. GAO's review of the document, which ONDCP provided with its
written comments, led GAO to conclude that it is a blueprint or strategy for
ONDCP's acquiring a contractor to develop and implement the plan, rather
than the implementation plan itself. 8 Therefore, the requirement to submit
to the Appropriations Committees and the Senate Judiciary Committee an
implementation plan for securing private sector contributions has not yet
been fulfilled.

Concerning the recommendation relating to the match program, ONDCP provided
GAO with a copy of a letter addressed to Ogilvy and Mather instructing the
contractor to maintain records of instances in which it is unable to obtain
a match (see app. III). Assuming this instruction is followed by the
contractor, GAO believes it addresses the first part of the recommendation
that ONDCP maintain documentation of all purchases that do not result in a
match. However, in instructing the contractor that this information should
be made available upon request, ONDCP did not address the intent of the
second part of the recommendation, that is, that ONDCP proactively provide
this information to the Congress. As a result, GAO is retaining its
recommendation.

8 The Fiscal Year 1998 Treasury and General Government Appropriations Act
required ONDCP to submit to the Appropriations Committees and the Senate
Judiciary Committee a detailed implementation plan for securing private
sector contributions, including but not limited to in- kind contributions.

Executive Summary Page 15 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

In response to GAO's recommendation that ONDCP formalize the review of new
advertisements for political figures or partisan content, ONDCP stated that
it would do so by requiring that the required legal reviews be documented.
Since this action has not yet been taken, GAO is retaining this
recommendation.

Page 16 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

Contents 4 Executive Summary 20 Media Campaign Appropriations and Statutory

Requirements 20

Campaign Strategy and Implementation 21 Campaign Structure 23 Objectives,
Scope, and Methodology 28 Chapter 1

Introduction 34 As Mandated, ONDCP Generally Provided Timely,

Written Financial Reports to Congress Since May 1998 34

ONDCP Established Processes to Oversee Paid Advertisement Spending

36 ONDCP Obligated Funds in Compliance With Selected

Statutory Spending Restrictions 39

Conclusions 41 Agency Comments and Our Evaluation 41 Chapter 2

ONDCP Generally Provided Timely Financial Reports and Obligated Funds in
Accordance With Selected Statutory Restrictions

42 Match Program Developed to Meet Requirements

Regarding Existing PSAs and Qualifications of Recipient Organizations

43 Campaign's Efforts With Community Anti- Drug Coalitions

Have Increased Over Time 51

ONDCP Has Not Developed a Private Sector Contributions Plan

57 Guidance and Procedures Regarding Political Figures and

Partisan Political Purposes Lacked Adequate Internal Control

62 Conclusions 63 Recommendations 64 Agency Comments and Our Evaluation 64
Chapter 3

ONDCP's Compliance With Statutory Program Requirements Has Been Mixed

Contents Page 17 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

67 ONDCP Has System for Evaluating the Campaign 67 Phases I and II
Respondent Sampling Designs Were

Generally Appropriate, but Awareness Measure Had Limitations

70 Phases I and II Implementation and Analytic Limitations

Compromised the Results 72

Some Positive Effects Were Associated With Phases I and II

76 The Phase III Evaluation Design Appears More Promising

Than Previous Phases 78

Conclusions 80 Agency Comments and Our Evaluation 81 Chapter 4

ONDCP Phases I and II Campaign Evaluations Were Inconclusive; Phase III
Evaluation Appears Promising

Appendix I: Experts Consulted 82 Appendix II: NCADI Public Contacts and
Publication

Distribution 84

Appendix III: Comments From the Office of National Drug Control Policy

86 Appendix IV: GAO Contacts and Staff Acknowledgments 91 Appendixes

Table 1.1: Campaign Phases 23 Table 1.2: Descriptions and Roles of
Organizations

Involved in the Media Campaign 24

Table 3.1: Number of Matches, Dollar Values, and Dollar Percentages, Hard
and Soft, Through December 1999

44 Table 3.2: Partnership Activities as of March 2000 54 Table 3.3: Private
Sector Cash, In- Kind, and Other

Contributions 60

Table 4.1: Methodology of the Impact Evaluations for Phases I, II, and III
of the National Youth Anti- Drug Media Campaign

69 Table II. 1: NCADI Public Contacts Pre- Campaign and

Phases I and II (Percentage Change From PreCampaign Period)

84 Table II. 2: NCADI Publication Distribution Pre- Campaign

and Phases I and II 85 Tables

Figure 1. 1: Total Media Campaign Expenditures, as of September 30, 1999

26 Figures Figure 2. 1: Media Campaign Costs Associated With Paid

Advertising, as of September 30, 1999 37

Contents Page 18 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign
Abbreviations

AAF American Advertising Federation CADCA Community Anti- Drug Coalitions of
America CiC Cable in the Classroom CLSPY Community Longitudinal Survey of
Parents and Youth COR Contracting Officer's Representatives CRC Creative
Review Committee DOD Department of Defense EOP Executive Office of the
President FFA Future Farmers of America HHS Department of Health and Human
Services JRAP Joint Recruiting and Advertising Program MTF Monitoring the
Future NASADAD National Association of State Alcohol and Drug Abuse
Directors NCADI National Clearinghouse for Alcohol and Drug Information NDPL
National Drug Prevention League NEA National Education Association NHSDA
National Household Survey on Drug Abuse NIDA National Institute on Drug
Abuse NNN Newspaper National Network NPN National Prevention Network NSPY
National Survey of Parents and Youth OMB Office of Management and Budget
ONDCP Office of National Drug Control Policy PAS Print Audit Service PDFA
Partnership for a Drug- Free America PSA public service announcement PSC
Program Support Center (Health and Human Services) PTSA Prevention Through
Service Alliance RFI Request for Information RFP Request for Proposal SAMHSA
Substance Abuse and Mental Health Services Administration SHRM Society for
Human Resource Management YSA Youth Service America

Page 19 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

Chapter 1 Introduction

Page 20 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

The Office of National Drug Control Policy's (ONDCP) National Youth Anti-
Drug Media Campaign, which was proposed as a nearly $1 billion federal
effort over 5 years, was developed in response to reported increases in drug
use among youth in the United States. The Media Campaign's goals are to (1)
educate and enable youth to reject illegal drugs, (2) prevent youth from
initiating the use of drugs, and (3) convince occasional users to stop using
illegal drugs. The Campaign supports the first goal of the 1999 National
Drug Control Strategy, which is to educate and enable America's youth to
reject illegal drugs as well as alcohol and tobacco. 1

In the Treasury and General Government Appropriations Act for 1998, Congress
authorized ONDCP to undertake a national Media Campaign to reduce and
prevent drug use among youth. 2 The initial appropriation for the Campaign
was $195 million. An additional $185 million were appropriated in the fiscal
year 1999 Appropriations Act 3 and in the fiscal year 2000 Appropriations
Act. 4

As part of its fiscal year 1998 appropriation, Congress mandated that ONDCP
submit a Campaign strategy for approval to the Appropriations Committees and
the Senate Judiciary Committee. The Campaign strategy was to include the
following requirements:

ï¿½ guidelines to ensure and certify that funds will supplement and not
supplant current anti- drug community- based coalitions;

ï¿½ guidelines to ensure and certify that funds will supplement and not
supplant current pro bono public service time that is donated by national
and local broadcasting networks;

ï¿½ guidelines to ensure and certify that the funds will not be used for
partisan political purposes;

ï¿½ guidelines to ensure and certify that no media campaigns to be funded
pursuant to this Campaign shall feature any elected officials, persons
seeking elected office, cabinet- level officials, or other federal officials
employed pursuant to Schedule C of title 5, Code of Federal Regulations,
section 213, absent advance notice to the Appropriations Committees and the
Senate Judiciary Committee;

1 The National Drug Control Strategy, 1999, ONDCP. 2 Public Law 105- 61, 111
Stat. 1293, 1294 (1997). 3 Public Law 105- 277, 112 Stat. 2681- 496 (1998).
4 Public Law 106- 58, 113 Stat. 447, 448 (1999). Media Campaign

Appropriations and Statutory Requirements

Chapter 1 Introduction

Page 21 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

ï¿½ a detailed implementation plan to be submitted to the Appropriations
Committees and the Senate Judiciary Committee for securing private sector
contributions, including, but not limited to, in- kind contributions;

ï¿½ a detailed implementation plan to be submitted to the Appropriations
Committees and the Senate Judiciary Committee of qualifications that are
necessary for any organization, entity, or individual to receive funding for
or otherwise be provided with broadcast media time; and

ï¿½ a system to measure outcomes of success of the Campaign. The act further
required that the Director report to Congress quarterly on the obligation of
funds, as well as specific parameters of the Campaign, and report to
Congress within 2 years on the effectiveness of the Campaign on the basis of
measurable outcomes previously provided to Congress. In addition, the act
placed a restriction on the obligation of Campaign funds.

Subsequently, as discussed in chapters 2 and 3, in fiscal year 1999,
Congress placed additional requirements on ONDCP in the Campaign's
appropriations acts regarding financial reporting, obligation of funds,
public service time, private sector contributions, and other aspects of the
Campaign. In fiscal year 2000, Congress required that ONDCP not obligate 10
percent of its available funds until ONDCP had submitted a plan for
corporate sponsorship to the Appropriations Committees.

In response to these requirements, ONDCP submitted a Campaign strategy to
the appropriate Committees in November 1997 and, as requested by the
Committees, provided additional information in early 1998. In addition,
ONDCP officials provided oral reports to Congress regarding spending during
the early months of the Campaign and began providing written reports on
Campaign obligations and expenditures in May 1998. They also provided impact
evaluation reports regarding Campaign effectiveness in August 1998,
September 1998, March 1999, and June 1999.

Initially, ONDCP and a contractor, Porter Novelli, developed a communication
strategy to establish the overall Campaign direction and to guide the
development of specific Campaign messages, materials, and activities.
According to the communication strategy, the focus of the Campaign is to
promote primary prevention- that is, to prevent drug abuse before it starts.
In general, the Campaign is intended to counteract messages and images in
the popular culture that glamorize, legitimize, normalize, or otherwise
condone drug use. Youth aged 9 to18 years, primarily 11 to 13 year olds;
parents and other primary caregivers; and other adults who influence youth
are targeted by the Campaign. Campaign messages are to accurately depict
drug use and its consequences, Campaign Strategy and

Implementation

Chapter 1 Introduction

Page 22 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

encourage parents to discuss drug abuse with children, and foster other
message strategies as outlined in the communications strategy.

The centerpiece of the Campaign is the paid advertising effort in which
Campaign funds are to be used to purchase media time and space for
advertisements that deliver anti- drug messages to the Campaign's target
audiences. The initial reach and frequency goal, which ONDCP established for
the paid advertising component, was to reach 90 percent of the target
audiences with at least four messages a week, across all media types. 5
Advertisements are to be produced in 11 languages to communicate to youth
and adults of major ethnic groups, including Hispanics, Asian Americans, and
Pacific Islanders.

The Campaign has five other key components, as follows, that support the
advertising effort:

ï¿½ interactive media,

ï¿½ entertainment industry collaboration,

ï¿½ public information/ news media,

ï¿½ partnerships/ community participation, and

ï¿½ corporate participation. The Campaign is being implemented in three
phases. Table 1.1 illustrates the scope, time period, and focus for each
phase.

5 “Reach and frequency goal” refers to communicating the message
to a certain percentage of the target audiences a certain number of times a
week.

Chapter 1 Introduction

Page 23 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

Phase Scope Time period Focus

I 12- city pilot January- July, 1998 Paid advertising- local

television and radio. Very limited implementation of the additional five
Campaign components. II Nationwide, 102

media markets July- December, 1998 Expansion of paid advertising to

include all media types. Very limited implementation of the additional five
Campaign components. III Nationwide, 102

media markets January 1999-

December 2002 a Continuation of paid advertising. Expansion of the
additional five Campaign components. a There was a transition period of
several months between phases II and III. As a result, the fully

integrated Campaign did not start until the summer of 1999. Source: ONDCP.

ONDCP has overall responsibility for developing and implementing the Media
Campaign. However, as directed by the congressional conferees, 6 ONDCP
consults with media and drug experts, such as The Advertising Council, Inc.
(Ad Council), and the Partnership for a Drug- Free America (PDFA). In
addition, ONDCP has worked with other federal entities, private businesses,
nonprofit organizations, and trade associations to obtain support for
various aspects of the Campaign- from initial Campaign design to evaluation.

Table 1.2 lists the organizations that support the Campaign and that are
discussed in this report. The table provides the organizations' name, type,
work description, and role in the Campaign.

6 H. R. Conf. Rep. No. 105- 284 at 67 (1997).

Table 1. 1: Campaign Phases

Campaign Structure

Chapter 1 Introduction

Page 24 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

Organization Type Description and role in Media Campaign

The Advertising Council, Inc. Nonprofit organization Provides public service
communications for nonprofit organizations. Serves as the clearinghouse for
the organizations and public service announcements (PSAs) submitted by
nonprofit groups and government organizations for consideration as part of
the Campaign's national- level media match program. Also assists the
Campaign in recruiting volunteers for anti- drug coalitions and reviews
production costs for new Campaign advertisements. The American Advertising
Federation

Trade association Professional advertising association of corporate
advertisers, agencies, media companies, suppliers, and academia. Oversees
all screening and approval of local organizations and PSAs for participation
in the local- level match program. Bates Advertising USA, Inc. Private
business Phases I and II paid advertising contractor. Efforts included (1)

media planning and purchasing of media time and space from various media
vendors and (2) oversight, negotiation, and implementation of the Campaign's
media match program. Community Anti- Drug Coalitions of America

Nonprofit organization National organization of anti- drug coalitions that
supports community- based strategies for substance abuse prevention, to
promote drug- free communities. Assists the Campaign in developing process
evaluation measures to assess the impact of the Campaign on community-
based, anti- drug efforts and in developing partnerships at the community
level to enhance and leverage Campaign messages. Also, inquiries generated
from Campaign advertisements in certain areas are referred to these
coalitions and their network of community resources. Assisted in surveying
its member coalitions to report impacts on community organizations from
phase I advertisements. Cox and Associates, CPAs, P. C. Private business
Accounting agency. Provides financial management support,

such as invoice processing and development of a Campaign financial and
program information tracking system. CSR, Inc. Private business Policy
research, training, and management services

organization. Campaign evaluation contractor for phases I and II. Department
of Defense (DOD), Defense Manpower Data Center Joint Advertising and Market
Research Division

Federal agency Oversees DOD's Joint Recruiting and Advertising Program,
which, along with its contracting office, the Defense Supply Service,
Washington, provided administrative contract support for phase I paid
advertising efforts by issuing a task order under its existing contract with
Bates Advertising USA, Inc. Department of Health and Human Services' Program
Support Center

Federal agency Among other things, provides contracting support to other
federal agencies on a fee- for- service basis. Provides administrative
contract support for phases II and III paid and nonpaid advertising efforts
through advertising and awarding Campaign contracts (e. g., Bates
Advertising USA, Inc.; Ogilvy and Mather; and Fleishman- Hillard, Inc.)
Department of Health and Human Services' Substance Abuse and Mental Health
Services Administration (SAMHSA)

Federal agency Mission is to improve the quality and availability of
prevention and treatment and rehabilitation services for substance abuse and
mental health. Provided a qualitative analysis of the impact of phase I and
identified ways to amplify the impact of phase I as the Campaign expands
nationally.

Table 1. 2: Descriptions and Roles of Organizations Involved in the Media
Campaign

Chapter 1 Introduction

Page 25 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

Organization Type Description and role in Media Campaign

Fleishman- Hillard, Inc. Private business Phase III nonpaid advertising
contractor. Assists with interactive media, entertainment industry
collaboration, public information/ news media, and partnerships. National
Association of State Alcohol and Drug Abuse Directors

Nonprofit organization National association to foster and support the
development of effective alcohol and other drug abuse prevention and
treatment programs throughout every state. Assists The American Advertising
Federation with its local media match activities, and, through a hotline and
clearinghouse, responds to inquiries generated by Campaign advertisements.
National Clearinghouse for Alcohol and Drug Information

Federal agency SAMHSA's information service, which, upon request, provides
current information and materials concerning substance abuse. Collecting
public contact and publication distribution data for the phases I, II, and
III evaluations. National Drug Prevention League

Nonprofit organization An association of 30 national and major regional
private sector organizations for drug abuse prevention. Assisting ONDCP in
identifying the capacities and key points of contact for drug prevention
among civic and community organizations across the country. National
Institute on Drug Abuse Federal agency Funds 85 percent of the world's drug
abuse research.

Conducting the phase III evaluation on behalf of ONDCP, to ensure state- of-
the- science methods and analytic procedures and the integrity and
independence of the results. Ogilvy and Mather Private business Phase III
paid advertising contractor. Efforts include (1) media

planning and purchasing of media time and space from various media vendors
and (2) oversight, negotiation, and implementation of the Campaign's media
match program. The Partnership for a Drug- Free America

Nonprofit organization Coalition of professionals from the communications
industry. Oversees and implements the creation of all paid advertisements
used in the Campaign. Porter Novelli Private business Strategic
communications planning firm. Provided general

advertising and Campaign expertise and assisted ONDCP in developing the
overall communication strategy. Westat Private business Research
organization. Phase III Campaign evaluation

contractor. Zenith Media Services, Inc. Private business Phases I and II
subcontractor under Bates Advertising USA, Inc.

Purchased media time and space from all national and local broadcast
vendors, except purchases directed at specific ethnic markets.

Source: ONDCP.

ONDCP uses advertising contractors to obtain the media planning, purchasing,
and other advertising expertise necessary to carry out its statutory
responsibilities for conducting the paid advertising component of the Media
Campaign. Media purchases include national and local television, radio, and
cable and newspaper, magazine, and Internet advertisements, among others. As
shown in figure 1. 1, payments to the advertising contractors for media
planning and purchasing accounted for approximately 84 percent of the total
Campaign expenditures for the first 2 years of the Campaign that ONDCP
reported to Congress. ONDCP Uses Advertising

Contractors and Contract Support Agents for Paid Advertisements

Chapter 1 Introduction

Page 26 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

a Includes expenditures for activities such as research, consulting, and
clearinghouse services. Source: GAO analysis of ONDCP Obligation and
Expenditure Report to Congress, as of September 30, 1999.

From the Campaign's inception, ONDCP relied on other federal agencies to
provide administrative contract support for the Campaign's paid advertising
contracts. Administrative contract support included, among other things,
managing the contracting process through solicitation and selection;
awarding the contract; and overseeing the execution of the contract,
including reviewing vouchers against the contract's limit. Although ONDCP
used administrative contract support from other agencies, it remained
responsible for ensuring that the contractors' performance met the
advertising objectives of the Campaign. This responsibility included
selecting the contractors, ensuring those contracts and related
modifications were in accordance with ONDCP's media plan, and authorizing
payment of media advertising costs.

ONDCP officials told us that because of the potentially high demands of the
Campaign, ONDCP initially decided that neither ONDCP nor the Executive
Office of the President (EOP) had the capabilities necessary to support the
contracting efforts needed to undertake the Campaign's paid advertising
efforts. In November 1997, ONDCP entered into an interagency agreement with
the Defense Manpower Data Center Joint Advertising and Market Research
Division, which handles the Department of Defense's (DOD) Joint Recruiting
and Advertising Program (JRAP), to provide

Figure 1. 1: Total Media Campaign Expenditures, as of September 30, 1999

Chapter 1 Introduction

Page 27 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

administrative contract support services for the phase I paid advertising
efforts. JRAP's contracting office, the Defense Supply Service, Washington,
had an existing contract with a large advertising agency, Bates Advertising
USA, Inc. (Bates), which could provide services for other federal agencies.
As a result, the Defense Supply Service, Washington, issued a task order for
the phase I paid advertising, with subsequent modifications, totaling $23
million under its existing contract. ONDCP paid for the costs associated
with running the advertisements, but DOD did not charge ONDCP for its
efforts in administering the contract. Upon completion of the phase I
Campaign efforts, according to ONDCP officials, ONDCP did not renew its
agreement with JRAP because ONDCP always intended for DOD's existing
contract to be used only as a temporary vehicle to quickly initiate the
Campaign.

In April 1998, ONDCP entered into an agency reimbursable work agreement with
the Department of Health and Human Services' (HHS) Program Support Center
(PSC) to provide administrative contract support for the phase II paid
advertising efforts, including award of the contract to an advertising
agency. In May 1998, HHS issued a contract to Bates, the same contractor
that was used for phase I, 7 for about $120 million, which was subsequently
modified to about $140 million for additional media purchases.

In December 1998, the HHS agreement was amended to cover phase III paid
advertising efforts through December 1999. HHS issued a contract for about
$129 million in December 1998 to Ogilvy and Mather for phase III of the
Campaign. 8 The phase III contract was issued for 1 year, with four 1- year
options to cover the entire Campaign. In January 2000, HHS and ONDCP entered
into another agreement to cover the first option year under the contract,
and HHS issued a contract modification for about $133 million to Ogilvy and
Mather to extend the contract through January 3, 2001.

PSC provides administrative support services on a fee- for- service basis to
HHS components and other federal agencies. As of February 2000, ONDCP

7 According to ONDCP and HHS officials, a sole- source contract was issued
to Bates, in part, to prevent disruption in the advertising Campaign as it
transitioned from a 12- city pilot program in phase I to a national Campaign
in phase II.

8 According to ONDCP and HHS, a full- and- open competition was conducted to
select the phase III contractor.

Chapter 1 Introduction

Page 28 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

had agreed to pay PSC about $604,000 for services supporting ONDCP Campaign
contracts. 9

Although ONDCP used administrative contract support from other federal
agencies, it remained responsible for monitoring the contractors' costs for
paid advertising. (See ch. 2 for more information regarding ONDCP's
oversight of paid advertisement spending.)

The conference report 10 and the Senate Appropriations Committee Report 11
for the Treasury and General Government Appropriations Act for 1999 directed
us to (1) conduct a financial audit and review of the ONDCP National Youth
Anti- Drug Media Campaign, (2) review ONDCP's compliance with certain
program requirements listed in the public law, and (3) review certain
aspects of the phase I results. On the basis of subsequent discussions with
staff from the Subcommittee on Treasury and General Government, Senate
Committee on Appropriations, and the Subcommittee on Treasury, Postal
Service, and General Government, House Committee on Appropriations, we
agreed to determine the following:

ï¿½ whether ONDCP provided timely financial reports to Congress as required by
Public Law 105- 61 and Public Law 105- 277; how funds for paid advertising
were managed and disbursed; and whether ONDCP complied with certain
statutory requirements regarding the obligation of funds;

ï¿½ what ONDCP has done to develop and implement guidelines for the Campaign
in response to the program requirements set out in Public Law 105- 61 and
Public Law 105- 277; and

ï¿½ whether the evaluation designs for phases I, II, and III were appropriate;
how well the phases I and II evaluations were implemented; and how effective
phases I and II of the Campaign were in influencing group awareness of
different types of paid anti- drug media messages (ad awareness) 12 and drug
attitudes.

9 ONDCP agreed to pay PSC, in addition, about $156, 000 for other contracts
that supported its advertising efforts (e. g., consulting) and about
$412,000 for nonadvertising Campaign contracts. Thus, the total PSC fees
agreed to by ONDCP to support the Campaign, as of February 2000, were about
$1, 172, 000.

10 H. R. Conf. Rep. No. 105- 825 1493, 1497 (1998). 11 S. Rep. No. 105- 251,
58- 59 (1998). 12 ONDCP, Testing the Anti- Drug Message in 12 Cities
National Youth National Drug Media Campaign: Phase I (Report No. 2), p. 2-
1, March 1999. Objectives, Scope, and

Methodology

Chapter 1 Introduction

Page 29 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

We did not conduct a financial audit of the Campaign's fiscal operations or
review the related internal controls. Also, we did not conduct a contract
management audit, that is, we did not review the contract award process or
review how the internal controls were applied during the contract
administration process.

To review the timeliness of ONDCP's financial reporting, we collected and
examined pertinent ONDCP and EOP documents, including the monthly written
reports on obligations and expenditures that were submitted to Congress, and
the fiscal years 1998, 1999, and 2000 Treasury and General Government
Appropriations Acts. We also interviewed ONDCP and EOP officials, as agreed
with the Subcommittee staffs. We did not, however, verify the accuracy of
the financial information reported.

To describe how funds for paid advertising were managed and disbursed, we
(1) gained an understanding of ONDCP's use of contractors and contract
support agents for its paid advertising efforts and (2) examined the paid
advertising invoicing process from invoice preparation by the contractor to
final payment and expenditure reporting to Congress. We collected and
reviewed pertinent EOP, ONDCP, DOD, HHS, and contractor documents, such as
contracts, interagency agreements, invoices, and supporting documentation
(e. g., media vendor billings). In addition, we also interviewed EOP, ONDCP,
DOD, HHS, the contractors, and the subcontractor officials. However, as
agreed, we did not test ONDCP's processes to oversee paid advertisement
spending to ensure that the procedures were effective and properly
implemented.

To review ONDCP's compliance with selected statutory requirements regarding
the obligation of funds, we collected and analyzed certain obligating
documents, including all Campaign contracts and interagency agreements
entered into during fiscal years 1998 and 1999; other pertinent ONDCP
documents; and fiscal years 1998, 1999, and 2000 Treasury and General
Government Appropriations Acts. However, we did not review the obligating
documents supporting every Campaign obligation. For example, we did not
review the supporting documents for travel and printing obligations. The
obligating documents we reviewed represented about 91 and 94 percent of
ONDCP's fiscal years 1998 and 1999 appropriations, respectively. We did not
review ONDCP's compliance with other statutory spending requirements, such
as restrictions regarding the type of activities for which Campaign funds
may and may not be used.

To review ONDCP's development and implementation of guidelines to meet the
program requirements listed in Public Law 105- 61, we

Chapter 1 Introduction

Page 30 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

interviewed officials at the following offices: ONDCP; Bates; Zenith Media
Services, Inc. (Zenith); Ogilvy and Mather; the Ad Council; The American
Advertising Federation; Fleishman- Hillard; and PDFA. We also collected and
analyzed pertinent documents from each of these offices.

In addition, regarding the “match” program, we verified the
electronic data provided by ONDCP's phases I and II advertising contractors
against their actual supporting documentation. Bates was ONDCP's advertising
contractor for phases I and II; Zenith was the subcontractor responsible for
the purchase of national and local television, radio, and cable
advertisements. Bates and Zenith reported achieving rates of at least
100percent match value to paid value, that were based on computerized data
on paid advertisements and the corresponding matches. In verifying the
accuracy of the electronic data provided by the contractors, we focused
primarily on the number and size of the errors in the databases. We compared
a sample of records from the electronic databases to their supporting
documentation, and defined an “error” as any instance when we
found a difference of more than $100 that would have inflated the estimate
of the percentage of dollars matched. Errors in the electronic data would
indicate that the match estimates were questionable; relatively few
discrepancies between database and supporting documentation would indicate
confidence in the match estimates.

Since the match program covered multiple media types and numerous vendors,
we selected all vendors in some media types and samples of vendors in other
media types, to reduce data collection time and cost. We asked Bates and
Zenith to provide lists of matches negotiated from each media vendor, from
the third quarter of 1998 through the first quarter of 1999. We selected all
magazine, in- school, and cinema/ arcade vendors; all national television
and radio vendors (which accounted for 73 percent of the total dollars spent
on television and radio advertising); and random samples of 64 local
television and radio vendors and 61 newspaper vendors.

We developed a data collection instrument to compare data from the
contractors' databases and their supporting documentation. We pretested our
data collection instrument, using information related to several vendors, to
ensure the reliability of our data collection.

For each vendor, we reviewed database information and the supporting
documentation for each paid advertisement and corresponding match. From the
contractors' databases, we recorded the number and value of paid
advertisements and matches for each vendor. At the offices of Bates

Chapter 1 Introduction

Page 31 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

and Zenith, we used several types of supporting documentation, including
invoices, insertion orders, print requisition forms, rate cards, vendor
agreements, post buy reports, Print Audit Service (PAS) and Newspaper
National Network (NNN) 13 reports, and brand/ time schedules.

The results from the newspaper and the local television and radio vendors'
samples were weighted. The weighting enabled us to make estimates about the
total population error rates in the contractors' databases for these
vendors. Additionally, since our sample contained vendors that accounted for
73 percent of the total dollars spent on television and radio advertising,
we also were able to estimate, with adequate precision, the match
advertisement dollars as a percentage of paid advertisements for television
and radio.

The estimate for the error rate in Bates' database was 3 percent, with a 95-
percent confidence interval of 1 to 7 percent; the estimated error rate in
Zenith's database was 2 percent, with a 95- percent confidence interval of
less than 1 to 8 percent. This means, for example, that we are 95- percent
confident that at least 1 percent of Bates' database records were in error,
but that no more than 7 percent of the records were in error. Similarly, we
are 95- percent confident that from less than 1 to 8 percent of Zenith's
database records were in error.

The estimate for the match program for Bates was 102 percent, with a 95-
percent confidence interval of plus or minus 2 percent; the estimate of the
percentage match received by Zenith was 115 percent, plus or minus 10
percent. In other words, we are 95- percent confident that Bates received at
least a dollar- for- dollar of match- to- paid advertisement value. We are
also 95- percent confident that Zenith received a match between 105 and 125
percent.

To determine how appropriate the impact evaluation designs were for
determining the effectiveness of phases I, II, and III of the Campaign, we
interviewed ONDCP officials and study representatives from the principal
evaluation organizations- CSR, Inc., (phases I and II) and the National
Institute on Drug Abuse (NIDA) (phase III). We obtained documentation from
each of these agencies describing the evaluation designs for each of the
three phases, and we submitted oral and/ or written questions when we
identified concerns or limitations. We also obtained outside reviews from

13 PAS and NNN are services that, for advertising agencies, verify that
newspaper advertisements have been printed as agreed. The data they collect
are entered into databases that produce reports sent to the advertising
agencies.

Chapter 1 Introduction

Page 32 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

experts on the methodological and statistical procedures used in the
Campaign (see app. I). The appropriateness of the evaluation designs was
based on principles of scientific research, input from outside experts, and
our own knowledge base built upon years of scientific research. We also
interviewed Ogilvy and Mather officials and obtained documentation related
to their phase III econometric study of media impact, to determine the
strengths and limitations of the design.

To determine how well the phases I and II evaluations were implemented, we
evaluated the phases I and II final reports that ONDCP submitted to
Congress, in addition to agency documents regarding specific aspects of the
evaluation implementation. 14 We relied on our experience in designing and
assessing evaluation methodologies- that is, our experience with generally
accepted social science methodological standards and practices. We discussed
issues and concerns with ONDCP and CSR and recommended changes to phase I
drafts, some of which ONDCP subsequently approved and adopted. We also
received written reviews from several outside experts on various aspects of
the phases I and II methodological and statistical procedures (see app. I).

To determine how effective phases I and II of the Campaign were in
influencing drug ad awareness and drug attitudes, we examined the aggregate
and site- specific baseline and follow- up survey data from the 12 target
and 12 comparison sites of phase I (see table 4. 1). We also examined the
baseline and follow- up survey data that were derived from ONDCP's phase II
national effort. These data were principally derived from the phases I and
II reports to Congress. But, as questions and issues arose, we were able to
obtain additional statistical information and documentation from either
ONDCP or CSR. In addition, we examined data from the National Clearinghouse
for Alcohol and Drug Information (NCADI) to determine the relationship
between Campaign intervention and agency contacts and requests for
information. Beyond examining the individual data sets, we considered
various methodological and statistical issues as they bear on the evaluation
results, including site selection procedures, response rates, ad awareness
measurement, data weighting procedures, and the representativeness and
generalizability of the results.

We performed our work from September 1998 to May 2000 in accordance with
generally accepted government auditing standards. In June 2000, we requested
comments on a draft of this report from the Director of ONDCP.

14 Phase III implementation was only beginning at the time we completed our
work.

Chapter 1 Introduction

Page 33 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

On July 3, 2000, we received written comments from ONDCP, which are
discussed at the end of chapters 2, 3, and 4 and reprinted in appendix III.

We also provided relevant sections of the draft report to DOD's Office of
the Inspector General, HHS' Program Support Center, NIDA, and the Substance
Abuse and Mental Health Services Administration for a review of the facts
pertaining to them. These organizations, as well as ONDCP, provided
technical or clarifying changes, which have been incorporated, as needed, in
the appropriate sections of this report.

Chapter 2 ONDCP Generally Provided Timely Financial Reports and Obligated
Funds in Accordance With Selected Statutory Restrictions

Page 34 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

In response to statutory financial reporting requirements, ONDCP provided
oral reports to Congress regarding spending during the early months of the
Media Campaign. In May 1998, ONDCP provided its first written financial
report to Congress covering the first 8 months of the Campaign. Since then,
ONDCP has generally provided timely cumulative written financial status
reports on a monthly basis. ONDCP reported spending approximately 84 percent
of the total Campaign funds for fiscal years 1998 and 1999 on paid
advertising. ONDCP had processes in place to monitor and approve all paid
advertising expenditures before paying vendors and reporting to Congress. In
addition, our review showed that ONDCP complied with selected spending
restrictions imposed by Congress.

The Treasury and General Government Appropriations Act of 1998 1 required
the Director of ONDCP to report to Congress quarterly on the obligation of
funds of the Campaign. In December 1997, the Subcommittee on Treasury and
General Government, Senate Committee on Appropriations, requested that ONDCP
provide a monthly report of all obligations and expenditures of funds
associated with the Campaign. 2 Subsequently, the Treasury and General
Government Appropriations Act of 1999 3 required ONDCP to report to Congress
not only quarterly, but also to provide monthly itemized reports of all
obligations and expenditures relating to the Campaign. 4

Our review of fiscal year 1998 obligations 5 revealed that ONDCP made its
first significant financial obligation of the Campaign in December 1997 for
paid advertisements. Related disbursements began in March 1998. ONDCP
officials said that they communicated orally with the appropriate Committees
during the first two quarters of fiscal year 1998, including discussions
regarding the Campaign's financial activities.

1 Public Law 105- 61, 111 Stat. 1293, 1295 (1997). 2 A letter dated December
8, 1997, was sent to ONDCP from the Chairman of the Subcommittee on Treasury
and General Government, Senate Committee on Appropriations. 3 Public Law
105- 277, 112 Stat. 2681- 497 (1998).

4 Although the Treasury and General Government Appropriations Act for 2000
(P. L. 106- 58) did not contain a reporting requirement, the Senate report
on the bill directed ONDCP to submit quarterly reports on the obligation of
funds (S. Rep. No. 106- 87 at 54).

5 We reviewed obligating documents representing 91 percent of the fiscal
year 1998 Campaign's funds that were available for obligation. As Mandated,
ONDCP

Generally Provided Timely, Written Financial Reports to Congress Since May
1998

Chapter 2 ONDCP Generally Provided Timely Financial Reports and Obligated
Funds in Accordance With Selected Statutory Restrictions

Page 35 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

ONDCP provided its first written report to Congress in May 1998. The report
included obligations and disbursements for the first 8 months of the
Campaign (i. e., from Oct. 1997 to May 1998). According to ONDCP officials,
ONDCP previously provided oral reports rather than written reports because
(1) there were several administrative tasks to complete in developing the
new Campaign, including designing reporting procedures and formats; (2)
there were relatively few financial transactions during the first several
months of the Campaign; and (3) ONDCP officials believed that their oral
reports satisfied the intent of the act's reporting requirements.

Since May 1998, ONDCP generally provided written reports on a monthly basis.
The reports included cumulative obligations and expenditures from the
inception of the Campaign. 6 According to ONDCP officials, ONDCP did not
provide written reports in October, November, and December, 1998, 7 and
October 1999 8 because of delays in closing the accounting records for one
fiscal year and opening records for the new fiscal year. Although ONDCP is
not statutorily required to provide financial reports to Congress in fiscal
year 2000, officials stated that they intend to continue to provide
financial reports. However, according to ONDCP officials, due to delays
associated with upgrading the EOP's financial accounting system that
maintains the accounting records and ONDCP's plans to change the report
format, no written or oral reports had been issued in fiscal year 2000 at
the time of our review. ONDCP plans to issue a report that includes
cumulative figures reflecting all activity to date as soon as these two
issues are resolved. According to ONDCP officials, the updated report format
will be more consistent with how the Campaign's efforts are organized,
particularly for paid advertisements.

The fiscal years 1998 and 1999 ONDCP reports detailed the Campaign's
operating budget, commitments, obligations, and expenditures by various
spending categories, such as program evaluation and paid advertisements. The
EOP's Office of Administration maintains the official financial system of
record for the Campaign and, therefore, is responsible for preparing the
financial reports for ONDCP. However, ONDCP is responsible for ensuring the
accuracy of the financial reports. In doing so, ONDCP is to approve all

6 Each written monthly report includes total obligations and expenditures
since the program started, as of the date of the report or the end of the
month before the date of the report, as noted. 7 The subsequent report
provided in January 1999 included cumulative figures that reflected activity
for the months in which no reports were provided. 8 In November 1999, ONDCP
provided a report on all obligations and expenditures as of September 30,
1999.

Chapter 2 ONDCP Generally Provided Timely Financial Reports and Obligated
Funds in Accordance With Selected Statutory Restrictions

Page 36 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

Campaign transactions, including all Campaign obligations and expenditures,
before their input into EOP's financial management system. We did not
conduct a financial audit of the Campaign's fiscal operations or review the
related internal controls to determine the accuracy of the Campaign's
obligations and expenditures.

ONDCP uses advertising contractors to carry out its statutory
responsibilities for conducting the paid advertising portion of the
Campaign. These contractors provide the necessary media planning,
purchasing, and other advertising expertise. Paid advertising includes costs
associated with radio, television, newspaper, magazine, and Internet
advertisements, among others. These paid advertisements are considered the
most significant costs of the Campaign. According to ONDCP's financial
reports to Congress, during the first 2 years of the Campaign, these
contracts accounted for approximately 84 percent of total Campaign
expenditures as of September 30, 1999. 9 Although ONDCP used administrative
contract support from other federal agencies to assist them with the
advertising contracts, ONDCP remained responsible for ensuring that only
valid Campaign expenses were paid. ONDCP is to review all invoices from paid
advertisement contractors and recommend payment or nonpayment to HHS. We did
not conduct a contract management audit or review how the internal controls
were applied during the contract administration process.

From its inception, ONDCP relied on other federal agencies to provide
administrative contract support for the Campaign's paid advertising
contracts. Administrative contract support included, among other things,
overseeing the execution of the contract (e. g., reviewing invoices against
the contract's limit). 10 As shown in figure 2.1, the majority of ONDCP's
expenditures under these advertising contracts were for purchasing time and
space for anti- drug advertisements from various media vendors, including
radio and television broadcasters, newspapers, magazines, and Internet
providers, among others. Expenditures under the advertising contracts were
also made for activities such as advertising production and labor.

9 The remaining 16 percent of the Campaign expenditures included Campaign
evaluation expenditures and those for other activities, such as research,
consulting, and clearinghouse services. (See fig. 1. 1 in ch. 1 of this
report.)

10 For more information regarding these contract support agents and
advertising contracts, see chapter 1. ONDCP Established

Processes to Oversee Paid Advertisement Spending

Chapter 2 ONDCP Generally Provided Timely Financial Reports and Obligated
Funds in Accordance With Selected Statutory Restrictions

Page 37 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

a Includes expenditures for activities such as advertising production and
labor. Source: ONDCP Obligation and Expenditure Report to Congress, as of
September 30, 1999.

Although ONDCP used administrative contract support from other federal
agencies, it remained responsible for monitoring the contractors' costs and
spending for the paid advertising efforts. Monitoring included attending
planning meetings with the contractors, obtaining periodic financial status
reports, and reviewing and approving all Campaign expenditures. In August
1998, ONDCP hired a new staff member to oversee certain contracting and
financial activities of the Campaign, particularly the paid advertising
contracts. Among other duties, his responsibilities included (1) working
with the contract support personnel to ensure, for example, that the
contract modifications and audits were appropriate; 11 (2) working with the
contractors to ensure proper billings; and (3) reviewing and approving all
paid advertising expenditures (i. e., contractor invoices) for cost
reasonableness, allowability, and support. Also, in August 1998, ONDCP
entered into a contract with an accounting firm 12 to acquire additional
financial management support. The accounting firm is to review the support
for advertising invoices submitted by the contractors, such as

11 For the phase II contract with Bates and the phase III contract with
Oglivy and Mather, these duties included acting as the Contracting Officer's
Representative (COR) of record. For phase I, DOD maintained COR
responsibilities, but under its interagency agreement, ONDCP still approved
all invoices before payment and made recommendations to the COR regarding
other issues related to the Campaign task order.

12 Cox and Associates, CPAs, P. C.

Figure 2. 1: Media Campaign Costs Associated With Paid Advertising, as of
September 30, 1999

Chapter 2 ONDCP Generally Provided Timely Financial Reports and Obligated
Funds in Accordance With Selected Statutory Restrictions

Page 38 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

media vendor billings, and make recommendations to ONDCP regarding payment
approval. 13

For each phase of the Campaign, ONDCP's advertising contractors used a
private- sector, on- line accounting and account management system to
produce the invoices sent to ONDCP for the Campaign. The on- line system
supports various aspects of the Campaign, including planning, purchasing,
and billing, and is used as the basis for the contractors' invoices that are
sent to ONDCP. According to advertising contractor officials, this
accounting and account management system is generally accepted by the
advertising industry and used by most large advertising firms in the United
States.

In addition to the invoice review support provided by the accounting firm,
in March 1999, HHS' Program Support Center contracted, on behalf of ONDCP,
with the Ad Council to assist ONDCP in reviewing invoices for producing new
advertisements, among other tasks. Subsequently, ONDCP adopted a review
process for new advertisement production in which ONDCP must approve all
invoices on the basis of recommendations for payment by the Ad Council and
its subcontractor, which are to review each new advertisement production
invoice for cost reasonableness, allowability, and support.

ONDCP officials are responsible for recommending the payment or nonpayment
of all invoices to HHS. 14 After obtaining recommendations regarding payment
from the accounting firm and/ or the Ad Council, an ONDCP official is to
review the completed work and, as necessary, independently review the
underlying support. For example, an ONDCP official is to review all of the
support provided for the contractor's labor and out- of- pocket 15 billings.
The ONDCP official also reviews the invoice for cost reasonableness and
allowability before recommending payment or nonpayment. Once HHS approves
payment, the invoices are to be paid, and ultimately, paid advertising
expenditures are to be reported to Congress as part of ONDCP's monthly
cumulative financial reports.

13 As part of its review procedures, the accounting firm also is to verify
the invoice totals, check for duplicate billings on previous invoices, and
verify that the dates of service coincide with the contract effective dates,
among other actions.

14 Per contractual requirements, all invoice payments are provisional until
final payment is made under the contract, since payments are subject to
later audit. Thus, for example, until the contract is closed, each payment
is subject to possible adjustments if additional information indicates that
the initial payment was incorrect.

15 According to an ONDCP official, out- of- pocket costs include media
production, tracking, and evaluation.

Chapter 2 ONDCP Generally Provided Timely Financial Reports and Obligated
Funds in Accordance With Selected Statutory Restrictions

Page 39 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

To further assist ONDCP in tracking and categorizing detailed Campaign
expenditure information, among other data, ONDCP directed the accounting
firm to establish and implement a Campaign tracking system that is based on
requirements created by ONDCP. ONDCP remained involved throughout the
system's development, testing, and implementation, according to ONDCP
officials, to ensure that the system met ONDCP's objectives. According to
ONDCP and accounting firm officials, the financial management application of
the system includes data on all paid advertising expenditures to date, for
all three phases of the Campaign. The system is capable of providing reports
on paid advertisement expenditures by numerous spending categories,
including the type of spending (e. g., media purchases, media production,
and labor); type of media purchased (e. g., radio, television, newspaper,
magazine, and the Internet); and geographic location of advertising
placements, among others. Accounting firm officials are to use the system to
assist them with their review of contractor invoices. As a result, the data
in the system are based on the advertising contractors' Campaign invoices
and supporting documentation (e. g., media vendor billings). At the time of
our review, the system was being used to process paid advertising invoices.

Congress established statutory spending restrictions limiting ONDCP from
obligating Campaign funds until certain conditions were met. Our review of
supporting documentation and discussions with agency officials showed that
these funds were obligated in accordance with selected statutory spending
restrictions for fiscal years 1998 and 1999. 16

The Treasury and General Government Appropriations Act of 1998 prohibited
the obligation of Campaign funds before the ONDCP Director's submitting a
Campaign strategy for approval to the Appropriations Committees and the
Senate Judiciary Committee. The act further prohibited the obligation of $17
million before September 30, 1998. ONDCP financial and contract management
officials stated that they monitored the obligation of Campaign funds to
ensure compliance with these restrictions. In November 1997, ONDCP submitted
a Campaign strategy to the Committees, 17 and by December 10, 1997, ONDCP
had received approval to begin obligating Campaign funds. On the basis of
the Campaign contracts

16 We did not review documentation supporting 100 percent of the
appropriations for fiscal years 1998 and 1999. For fiscal year 1998, we
reviewed documentation that represented 91 percent of the appropriation
available for obligation; for fiscal year 1999, we reviewed documentation
that represented 94 percent of the appropriation. Also, we did not review
all statutory spending restrictions (see Objectives, Scope, and Methodology
section in ch. 1).

17 Subsequently, ONDCP submitted additional information to the Committees
regarding its development of certain guidelines related to this statutory
provision. ONDCP Obligated

Funds in Compliance With Selected Statutory Spending Restrictions

Chapter 2 ONDCP Generally Provided Timely Financial Reports and Obligated
Funds in Accordance With Selected Statutory Restrictions

Page 40 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

and other obligating documents we reviewed, which represented 91 percent of
the 1998 Campaign appropriation available for obligation, 18 the first
obligation for $14 million was incurred on December 18, 1997, following
ONDCP's submission to the required Committees and its subsequent receipt of
approval to begin obligations. Further, OMB did not apportion $17 million of
the Campaign's appropriation to ONDCP for obligation until after the end of
fiscal year 1998 to ensure compliance with the statutory provision. 19

The Treasury and General Government Appropriations Act of 1999 required that
(1) no Campaign funds be obligated before ONDCP's submitting a report on the
evaluation and results of phase I of the Campaign to the Appropriations
Committees and (2) not more than 75 percent of the Campaign funds be
obligated before submission of a report on the evaluation and results of
phase II. ONDCP financial and contract management officials stated that they
monitored the obligation of Campaign funds to ensure compliance with these
restrictions. ONDCP submitted a phase I evaluation report to the
Appropriations Committees on October 1, 1998, 20 and the phase II report on
May 7, 1999. Our review of Campaign contracts and other obligating
documents, representing 94 percent of the 1999 Campaign appropriation,
indicated that ONDCP complied with these restrictions. On the basis of our
analysis, ONDCP incurred its first Campaign obligation on October 22, 1998,
and, as of May 7, 1999, had incurred obligations representing about 74
percent of its fiscal year 1999 appropriation. 21

The Treasury and General Government Appropriations Act of 2000 required that
10 percent of Campaign funds not be available for obligation before ONDCP's
submitting a corporate sponsorship plan to the Appropriations Committees. 22
As with previous statutory spending restrictions, ONDCP contract and
financial officials said that they would monitor compliance with this
restriction to ensure that obligations

18 We reviewed documents representing 91 percent of the $178 million
available for obligation. Although Congress appropriated $195 million for
fiscal year 1998, $17 million was unavailable for obligation until September
30, 1999.

19 Apportionment is the action by which OMB distributes amounts available
for obligation in an appropriation or fund account. The amounts apportioned
limit the amount of obligations that may be incurred.

20 ONDCP submitted a final phase I evaluation report in March 1999. 21
ONDCP's Campaign had a remaining available balance of about $24 million from
its fiscal year 1998 appropriations. Thus, fiscal year 1999 obligations were
initially offset by this amount. 22 Public Law 106- 58, 113 Stat. 447, 449
(1999).

Chapter 2 ONDCP Generally Provided Timely Financial Reports and Obligated
Funds in Accordance With Selected Statutory Restrictions

Page 41 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

occurred in accordance with the statutory requirements. ONDCP's plan to
secure private sector contributions, including corporate sponsorship, is
still under development. (See ch. 3 of this report for details regarding the
status of ONDCP's efforts.)

In response to statutory requirements, since May 1998, ONDCP generally
provided timely written financial status reports to Congress on cumulative
Media Campaign obligations and expenditures during fiscal years 1998 and
1999. ONDCP also established processes to approve and monitor paid
advertisement spending, which represented about 84 percent of the total
expenditures for fiscal years 1998 and 1999 reported by ONDCP. Further,
ONDCP complied with selected statutory spending restrictions limiting the
obligation of fiscal years 1998 and 1999 funds until certain conditions were
met.

In its written comments on a draft of this report, ONDCP indicated its
agreement with our findings and conclusions in this chapter and did not
raise any issues or concerns. ONDCP also stated that we could have placed
greater emphasis on ONDCP's ability to meet statutory requirements given the
scope and complexity of the Campaign; the speed with which it was
implemented; and the multitude of contracting, legal, and other issues
involved.

In commenting on our findings and conclusions, ONDCP inferred that we
conducted a financial audit. ONDCP added that while it retained outside
administrative contract support, internal controls allowed it to monitor
expenditures and control payments. We want to emphasize that we did not
conduct a financial audit of the Campaign's fiscal operations or review the
related internal controls. Also, we did not conduct a contract management
audit or review how the internal controls were applied during the contract
administration process. Rather, the scope of our work was restricted to (1)
reviewing the timeliness of ONDCP's financial reporting, (2) determining how
funds for paid advertising were managed and disbursed, and (3) reviewing
ONDCP's compliance with selected statutory requirements regarding the
obligation of funds. Conclusions

Agency Comments and Our Evaluation

Chapter 3 ONDCP's Compliance With Statutory Program Requirements Has Been
Mixed

Page 42 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

ONDCP's success in meeting the congressionally mandated program requirements
was mixed. The match program, which was developed early on to meet the
congressional requirement that ONDCP supplement existing public service
announcements (PSA), resulted in over 265,000 pro bono or match PSAs, valued
at approximately $148 million and benefiting 45 organizations as of the time
of our review. 1 However, ONDCP may not be able to fully meet the
congressional direction that it obtain a pro bono match as a part of each
buy from every vendor. This requirement was imposed after the development of
the match program. ONDCP and the Ad Council also developed guidelines to
determine the organizations that could receive the matches.

According to ONDCP, its work to supplement community anti- drug coalitions
was somewhat limited during the first two phases of the Campaign due to
ONDCP's need to focus on planning and executing the paid advertising
Campaign. However, ONDCP and its contractors planned and/ or instituted
numerous initiatives to work with coalitions for phase III.

ONDCP does not yet have the congressionally required private sector
contributions plan in place. It had anticipated having a plan in place by
October 2000, as of the date of our review, but had fallen behind in meeting
the schedule necessary to complete work by that date. ONDCP officials said
that, even when a plan is in place, ONDCP may not be able to meet the
congressionally mandated levels of contributions.

Finally, to meet congressional requirements, ONDCP and PDFA have (1)
developed a policy and guidance prohibiting advertisements that feature
political figures or partisan purposes and (2) established an advertisement
review process. However, ONDCP had no internal controls requiring that the
reviews be documented.

1 Phase I data are not included because matches were used solely for the
Campaign during phase I.

Chapter 3 ONDCP's Compliance With Statutory Program Requirements Has Been
Mixed

Page 43 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

Congress directed ONDCP to develop guidelines to ensure that Campaign funds
supplement and not supplant current PSAs that are donated by national and
local broadcasting networks. ONDCP was also required to develop a detailed
plan regarding the qualifications necessary for an organization, entity, or
individual to receive this free broadcast time. To comply with these
requirements, ONDCP; its advertising contractors; the Ad Council; and PDFA
developed a match program during phase I of the Campaign, including criteria
for receipt of the match. In general, ONDCP requires that every time the
advertising contractors purchase time or space, the media vendor must
provide (1) an equivalent amount of free public service time or space or (2)
an equivalent in- kind contribution. The program includes not only broadcast
media- national and local television, radio, and cable- but also newspapers,
magazines, outdoor media (such as billboards), the Internet, in- school
media, and cinema/ video arcades.

The ONDCP guidelines stating that advertising time or space will not be
purchased without the provision of matching (i. e., free) time or space are
reflected in negotiating directions that ONDCP gave its advertising
contractors. 2 The contractors are to request, when negotiations for the
paid time or space occur, that the media vendors match ONDCP's purchase of
time or space, dollar- for- dollar with nonpaid advertisements or in- kind
contributions of the same value. ONDCP's advertising contractors are also
responsible for ensuring that the match time or space has been provided. The
media vendor is to be paid only after the paid advertisement and its match
have been broadcasted or printed.

Though individual media vendors decide how to meet the requirement, ONDCP's
goal is that the majority of the matches must be in the form of equivalent
time or space, known as “hard matches.” For broadcast media, the
match might be 30 seconds of time given for a purchase of 30 seconds of
time, in a comparable time slot or location. For print media, a hard match
could be a free page of advertisement for a paid page.

In addition to hard matches, media vendors may provide “soft
matches,” which include complementary in- kind contributions, such as
programming; locally or nationally sponsored community anti- drug events;
in- school programs; radio interviews; and public affairs programming. A
programming soft match might be an anti- drug or alcohol message written
into a television show, thus adding to the total amount of available
antidrug or alcohol messages.

2 Bates was the contractor for phases I and II, and Zenith was a
subcontractor to Bates. Ogilvy and Mather is the phase III contractor. Match
Program

Developed to Meet Requirements Regarding Existing PSAs and Qualifications of
Recipient Organizations

Contractor Responsibilities and Type, Valuation, and Number of Matches

Chapter 3 ONDCP's Compliance With Statutory Program Requirements Has Been
Mixed

Page 44 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

ONDCP requires its advertising contractors to document the value of the
matches in conjunction with documentation verifying the paid time or space.
Hard matches are given the same value as the purchased time or space. For
example, 30 seconds provided as a match is valued the same as the paid 30
seconds. According to ONDCP and contractor officials, the valuation of soft
matches was new to them and the industry and, as a result, their valuation
estimates were very conservative. For example, programming (e. g., story
lines and interviews) was valued using a formula that is based on the
requirements for a product advertiser to officially sponsor a show. An
advertiser officially sponsors a half- hour show when it purchases three 30-
second advertisements. As a result, if the theme of a half- hour show was
consistent with the Campaign's strategy and dominated the content of the
program, the contractor was to allow credit for three 30- second
advertisements. Using a less conservative approach, the contractor could
have given credit for the full 30 minutes.

Because the valuation of soft matches and other nonmonetary contributions to
the Campaign is new to ONDCP and its contractors, and to ensure use of the
best system possible, ONDCP is in the process of securing a contractor to
assist in the development of a valuation system.

Table 3.1 shows the number of hard and soft matches obtained by ONDCP
contractors through December 1999, their dollar value, and the percentage
dollar distribution of the hard matches compared with the soft matches.

Hard matches Soft matches Percentage Number Value Number Value Total

dollars Hard value Soft value Phase I

Bates and Zenith a NA b $19,000,000 NA b $297,600 $19,297,600 98% 2%

Phase II

Bates c 339,712 45,773,000 717 2,816,000 48,589,000 94 6 Zenith d 154,679
83,190,049 NA b 19,757,756 102,947,805 81 19

Phase III

Ogilvy and Mather c 137,985 34,620,960 NA b 4,721,040 39,342,000 88 12
Ogilvy and Mather d 110,707 65,142,805 NA b 15,127,437 80,270,242 81 19

Total 743,083 $247,726,814 717 $42,719,833 $290,446,647 85% 15%

a All media types, both general and ethnic markets. b Contractor data were
not available. c Newspapers, magazines, outdoor media, cinema/ video
arcades, in- school media, the Internet, and ethnic market. d National and
local general market television, radio, and cable.

Source: Contractor data.

Table 3. 1: Number of Matches, Dollar Values, and Dollar Percentages, Hard
and Soft, Through December 1999

Chapter 3 ONDCP's Compliance With Statutory Program Requirements Has Been
Mixed

Page 45 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

As shown in table 3.1, the total number of hard and soft matches is
understated because these data were not available from the contractor.
However, the values of hard and soft matches, as determined by the
contractor, are known. The number of hard matches acquired during phase I
was not available because, at that time, the contractor and subcontractor
did not count the individual hard matches. The value of hard matches does
include phase I since the contractor and subcontractor kept financial
records to ensure that they received a dollar- for- dollar match rate. The
total number of soft matches acquired during phases I, II, and III was not
available because the contractor and subcontractor did not count the
individual soft matches during phase I, the subcontractor did not count
these matches during phase II, and the contractor did not count them during
phase III. However, the value of soft matches does include all phases since
the contractors and subcontractor kept financial records to ensure that they
received a dollar- for- dollar match rate.

ONDCP and the Ad Council developed criteria to determine which organizations
and PSAs could qualify for receipt of the national television, radio, and
cable match time. The Ad Council serves as a clearinghouse at the national
level. Nonprofit organizations and government agencies are to submit
applications to the Ad Council on an ongoing basis for participation in the
match program. Television, radio, cable, and some Internet banner
advertisement matches are available for the use of qualifying organizations.
To qualify, organizations and their campaigns must meet the following
criteria:

ï¿½ the campaign must be sponsored by a legally recognized, nonprofit
organization or government agency;

ï¿½ nonprofit organizations should be in compliance with guidelines of the
Council of Better Business Bureaus' Philanthropic Advisory Service or those
of the National Charities Information Bureau and must provide ONDCP with
proof of their tax- exempt status;

ï¿½ PSAs created by the media are eligible only if cosponsored by a nonprofit
organization;

ï¿½ messages must directly benefit the cause of a nonprofit or government
agency; and

ï¿½ messages with commercial benefit or commercial advertiser identification
are not eligible. Qualifications Necessary to

Receive Match Time or Space

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Eligible messages include those that accomplish the following:

ï¿½ educate and support the development of good parenting practices;

ï¿½ encourage greater parental and caregiver involvement in a child's
upbringing and promote effective drug prevention parenting strategies;

ï¿½ foster high expectations and self- esteem for youth;

ï¿½ discourage drug abuse, including underage tobacco and alcohol use; and

ï¿½ emphasize the connection between drugs and crime and violence. The
messages must also be nondenominational, noncommercial, and politically
nonpartisan. They cannot be designed to influence specific legislation or
feature elected officials. Finally, the advertisements are to be screened to
ensure acceptable creative and technical quality.

The Ad Council processes the applications and then forwards them to the
Media Match Task Force for final decision. The task force consists of
representatives from ONDCP, the Ad Council, PDFA, HHS, the Department of
Justice, and the Department of Education. The task force reviews
applications on a quarterly basis and has met seven times to make the final
decisions and discuss the match program, including possible modifications to
the ongoing effort.

After the task force approves the organizations and advertisements, ONDCP's
advertising contractor encodes the television and radio PSAs on a master
reel that is reproduced and distributed to the media vendors on a quarterly
basis. National broadcast media vendors then choose from among the
advertisements on the reel to satisfy their agreed- upon hard match
requirement and concentrate their efforts on issues, organizations, and
target audiences that best fit their public affairs priorities.

As of the time of our review, 45 organizations had received the broadcast
time provided through the match program, including America's Promise, Boys
Town USA, the Center for Substance Abuse Treatment, Connect for Kids, the
Harvard Mentoring Project, Mothers Against Drunk Driving, and the National
4- H Council.

The American Advertising Federation (AAF) performs the clearinghouse
function for local- level organizations that could use the local television,
radio, and cable matches. The guidelines are the same as those used by the
Ad Council. AAF reviews submissions through local review panels that usually
meet quarterly; AAF's goal is to establish these panels in each of the 102
media markets. As of the time of our review, panels had been established in
74 markets. The review panels usually consist of three to six

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members that are drawn from the AAF advertising clubs and federations, plus
a representative of the National Association of State Alcohol and Drug Abuse
Directors (NASADAD). Members of NASADAD are included because of their
technical expertise in drug prevention messages. PSAs approved by the review
panels are forwarded to AAF, which then forwards the PSAs to ONDCP's
advertising contractor. The contractor prepares the reel to be provided to
local broadcasters. AAF officials said that, as of the end of 1999, review
panels had approved 117 PSAs from 8 local markets. 3

According to ONDCP and its contractors, the Campaign has exceeded its goal
of a dollar- for- dollar match. As of September 9, 1999, ONDCP's contractors
reported an overall rate of match- to- paid value of 108 percent.

To test the accuracy of these reported data, we examined media vendor
documentation, including invoices; insertion orders; vendor agreements; and
brand/ time schedules, in the offices of Bates and Zenith. (See pp. 30 and
31 of this report for details.) In comparing this documentation with data
reported by the contractors and ONDCP, we found very few errors. Three
percent of Bates' and 2 percent of Zenith's database records were in error
by at least $100. 4 On the basis of our review and analysis, we can estimate
with 95- percent confidence that both contractors received at least a 100-
percent rate of match- to- paid value. Specifically, we estimate that Zenith
procured a match rate in a range of 105 to 125 percent and that Bates
procured a rate in the range of 100 to 104 percent.

By requiring ONDCP to supplement and not supplant current PSA levels,
Congress expressed concern that the Campaign's advertisements should not
result in the loss of PSA opportunities for other organizations. According
to officials at the Ad Council, some available evidence suggests that there
has been a recent increase in overall broadcast PSA levels. However, to the
extent there has been an increase, there is no clear quantitative evidence
to attribute it to the match program.

Neither ONDCP nor the Ad Council had baseline data on levels of all PSA
activity before the Campaign. We were told that no organization tracks all
PSA activity, which would include the campaigns of local, regional, and
national nonprofit organizations and local and national governments. As a

3 Before AAF's participation, PSAs approved for the national level were
provided for use by local television, radio, and cable. National broadcast
PSAs are still used in markets where local PSAs are not available.

4 The 95- percent confidence interval for the estimated error rate in the
Bates database was 1 to 7 percent of records; the 95- percent confidence
interval for the estimated error rate in the Zenith database was from less
than 1 to 8 percent. Contractors Obtained at

Least a Dollar- for- Dollar Match

Effect of the Match Program on PSA Levels Was Not Clear

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result, ONDCP and contractor officials were unable to provide clear
quantitative evidence that PSA levels had increased since the inception of
the Campaign.

ONDCP expressed the intent, through its match program guidelines, that media
vendors should not reduce support of Ad Council or other public service
campaigns to generate the match PSA; these contributions were to be in
addition to existing PSAs. We were told that at the time of negotiations,
the contractors' buyers were to convey this information to each media vendor
from which they made a purchase. The vendors provided assurances to the
buyers that their existing support of PSAs would not change.

Overall, Ad Council officials believed that broadcasts of its PSAs had
increased since the beginning of the Campaign. 5 As of the date of our
review, the Ad Council managed about 30 active national public service
campaigns. Ad Council officials believed these campaigns represented about
20 to 25 percent of all PSA activity. According to a Senior Vice President
of the Ad Council, Ad Council PSAs increased by 21 percent from 1997 to
1998. Of this increase, about 9 percent could be attributed to
advertisements used by organizations that received match time; the remaining
12 percent were Ad Council advertisements that were not a part of the match
program.

Ad Council officials also provided numerous letters from organizations whose
PSAs were aired through the match program. These organizations all reported
increased exposure of their PSAs, and many reported an increase in calls to
their hotline numbers.

Ad Council officials said that they were skeptical at first regarding the
match program component of the Campaign. They were not sure if the program
would work or if it would benefit organizations in need of free broadcast
time. However, from their experiences to date, these officials expressed
satisfaction with the program and the efforts of ONDCP and its contractors
to increase the overall level of PSAs. According to these officials, ONDCP
listened to their concerns and those of other organizations and designed a
fair program that is intended to assist them and others with their PSA
efforts. These officials were also pleased about the placement of the PSAs
in desirable times that its organizations had not seen in years.

5 The figures provided by the Ad Council reflect activity from 1997 to 1998.

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Data compiled in the 1999 annual report produced by the American Association
of Advertising Agencies and the Association of National Advertisers, Inc.,
have been cited by the Ad Council as evidence of an increase in prime- time
broadcast PSAs. 6 We reviewed the annual report and found no clear pattern
of an increase in broadcast PSAs across programming times, networks, or
broadcast media types. In response to our questions, an Ad Council official
stated that although the data provided some evidence that network PSAs
increased in November 1998, the report does not provide a firm quantitative
basis for determining whether an increase had occurred or, if so, whether
and how much the increase was attributable to the Campaign.

In the fiscal year 1999 appropriation bill, Congress required that ONDCP
obtain a match up front as part of the media buy from each seller of
advertisement time and space. This specific language was not included in the
fiscal year 2000 appropriation bill, but support for this requirement was
reiterated in the conference report. 7 In a few instances, however, ONDCP
and its advertising contractors have been unable to secure a match. In most
of these instances, the contractors stopped the negotiations and did not
make a media buy; in others, due to the advertising Campaign's need to meet
its reach and frequency goals, a buy was made without the required match. 8

According to an official at Ogilvy and Mather, ONDCP and its advertising
contractors developed the Campaign's reach and frequency goals. He explained
that, as in any advertising campaign, the goals are based on the belief that
this specific level of reach and frequency is necessary to achieve the
attitude and behavioral changes the Campaign is seeking to bring about. He
also said that if these goals are not met, the Campaign will be unable to
achieve its ultimate aims.

According to the contractors, time and space were purchased from 2,991 media
vendors 9 during the period covering June 29, 1998, to December 31, 1999. In
15 instances, vendors did not provide a match. In 3 of these 15 instances,
after a buy was made for the Campaign, the vendor

6 ‘98 Television Commercial Monitoring Report, American Association of
Advertising Agencies and Association of National Advertisers, Inc. (1999). 7
H. R. Conf. Rep. No. 105- 825 at 74. (1999).

8 The overall match rate still exceeded 100 percent because some media
vendors provided a match in excess of dollar- for- dollar. 9 This number (2,
991) includes overlap between vendors used by the phases I and II contractor
and the phase III contractor. Need to Attain Campaign's

Reach and Frequency Goals Can Conflict With Congressional Direction
Regarding the Match Program

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reconsidered and provided a match. According to the contractors, in an
additional 193 instances, vendors were unwilling or unable to provide a
match; therefore, the contractors did not purchase from these vendors. From
our assessment of the information provided to us, we determined that neither
ONDCP nor its contractors maintained systematic records of these instances.

ONDCP and contractor officials emphasized that their goal, in keeping with
ONDCP guidelines and the congressional direction, is to achieve a dollar-
for- dollar match in every instance. However, they explained that, due to
the need to achieve the Campaign's reach and frequency goals, they would
likely continue to encounter instances in which a buy must be made without
the benefit of a match. For example, the officials explained that to reach a
particular segment of the target audience in a particular market, it might
be necessary to purchase airtime from a small radio station that is
unwilling or financially unable to provide it for free. Other vendors might
be unwilling to provide free time because, due to the strong economy, they
are able to sell all of their inventory. An official at Zenith emphasized
that attaining the match goal is important; however, if the reach and
frequency goals of the Campaign are to be met, ONDCP and its contractors
need flexibility in instances in which the vendor does not provide a match.

According to an official at Bates, they were occasionally unable to get a
full dollar- for- dollar match for certain media types. For example, there
is a very limited inventory of “out- of- home” advertising
space, such as exterior transit (panels on buses). As a result, Bates could
not get a 100- percent match for this form of media. However, because the
medium represented an important part of the media plan, Bates purchased the
space needed to meet the Campaign's reach and frequency goals, even though
the vendors provided only about a 75- percent match.

Advertising contractors raised concerns about the future viability of the
match program and spoke of the following three barriers to the indefinite
continuation of the program, particularly if they are required to obtain a
match from every vendor:

ï¿½ Media vendors have been influenced by the amount of funding available for
the purchase of time and space and, as a result, are more motivated to
provide the match. If ONDCP's funding for the program decreased, and smaller
purchases were made, the vendors might balk at providing free inventory.

ï¿½ If campaigns relating to other issues (e. g., alcohol or tobacco) begin
requesting matches, the vendors might begin to be selective about their

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participation because they might not be able to participate in all
campaigns.

ï¿½ The advertising market is in good shape now and stations are able to sell
most of their inventory. If this continues, or if the stations are able to
sell their entire inventory, the amount available for the match program
could potentially be reduced.

Congress directed ONDCP to develop guidelines to ensure that Campaign funds
supplement and not supplant current anti- drug community- based coalitions.
10 Guidelines were forwarded to Congress in November 1997. However,
according to ONDCP, because the primary focus of the first two phases of the
Campaign was on paid advertising, which is one of the six Campaign
“components,” less time was devoted to the other components,
including work with community anti- drug coalitions. 11 Most of ONDCP's time
was directed at getting the paid advertising out in the 12 pilot cities and
then expanding the advertising effort nationally. According to the Director
of the Campaign, the advertising focus, along with the speed with which the
Campaign was rolled out, precluded a lot of work with community groups in
phases I and II of the Campaign. According to ONDCP, phase III will provide
the opportunity to fully develop and implement the various nonadvertising
aspects of the Campaign, including partnerships with community anti- drug
coalitions.

ONDCP officials said they made several efforts during phase I to work with
anti- drug coalitions or community groups. During phase I, the Community
Anti- Drug Coalitions of America (CADCA) prepared a tool kit for ONDCP. This
hands- on marketing guide for community coalitions introduced the Campaign
and explained how the local coalitions could use the Campaign to further
their own goals. A Campaign video was also prepared for the launch in the 12
pilot cities, and ONDCP met with various statewide groups to explain how the
Campaign could benefit their efforts. The Campaign's director held one- on-
one and conference telephone calls with community groups and coalitions;
ONDCP also held national teleconferences with local elected officials. In
choosing what groups or organizations to contact, ONDCP used the databases
maintained by CADCA and NASADAD.

10 ONDCP describes community anti- drug coalitions as anti- drug groups that
operate in communities and span or include many and diverse institutions,
such as prevention and treatment programs, police, social services,
businesses, and schools.

11 The Campaign components are as follows: paid advertising; interactive
media; entertainment industry outreach; public information; partnerships
(national and community organizations and coalitions); and corporate
involvement, sponsorship, and participation. Campaign's Efforts

With Community AntiDrug Coalitions Have Increased Over Time

Efforts in Phases I and II Were Limited

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In addition, in phases I and II, ONDCP provided assistance to help local
coalitions capitalize on the increased visibility of drug issues within
their communities. According to an ONDCP official, ONDCP provided training
to the coalitions on how to get news coverage; improve public understanding
of the importance of prevention efforts; and generate a range of
collaborative anti- drug activities with businesses and schools and
community, civic, and other local organizations. ONDCP also coordinated a
Campaign launch satellite broadcast through CADCA and the National Guard.

Throughout the Campaign, ONDCP attempted to “tag” local
advertisements, when appropriate, with the names and telephone numbers of
community anti- drug coalitions. However, during the first two phases of the
Campaign, ONDCP was not always able to tag advertisements, because the
Campaign used off- the- shelf PDFA advertisements that would have required
difficult and time- consuming modifications. According to an ONDCP official,
the local organizations whose telephone numbers were featured in print
advertisement tags provided very positive feedback regarding the response
they received from callers who had seen the advertisements.

Formal ONDCP policy regarding the use of tags went into effect in December
1999. To qualify, the organizations whose telephone numbers are used must
have the following:

ï¿½ governmental or nonprofit status;

ï¿½ a live voice or voice mail to answer calls with a capacity to return calls
within 24 hours;

ï¿½ E- mail and Internet access;

ï¿½ the capacity to refer calls to youth and adult treatment providers and
prevention programs specific to middle school youth and parents, as
requested; and

ï¿½ the capacity to mail, fax, or E- mail materials without cost to the
caller. According to an ONDCP official, tags are to be placed on all parent
advertisements. Youth advertisements will feature tags selectively because
young people have been shown to be much less likely to call in response to a
tag. All local newspaper and some local billboard and local broadcast
advertisements during phase III of the Campaign will be tagged.

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ONDCP has increased its involvement with community anti- drug coalitions in
phase III of the Campaign. ONDCP entered into a contract with Fleishman-
Hillard, Inc., to implement four of the five nonadvertising components of
phase III- interactive, public information, entertainment industry outreach,
and partnerships. ONDCP's efforts with community anti- drug coalitions are a
primary focus of Fleishman- Hillard's work with partnerships.

Fleishman- Hillard officials explained that there are three types of
activities that ONDCP undertakes with partners: (1) using the partners'
resources; (2) using the partners' communication networks to spread the
Campaign's message; and (3) tailoring ONDCP programs to the organization's
mission, to the extent that its mission overlaps that of the Campaign.

Fleishman- Hillard officials provided the following examples of these
activities:

ï¿½ using the National Education Association's school- oriented materials to
further the Campaign's goals,

ï¿½ using the YMCA's resources and communication structures,

ï¿½ assisting the YMCA with the curriculum of its after- school programs and
training its directors to work with or teach children the Campaign's
message.

ONDCP and Fleishman- Hillard are now working with numerous organizations,
including national organizations such as the YMCA, to strengthen anti- drug
efforts at the local level. These organizations and other partnerships with
community groups are displayed in table 3. 2. In addition, Fleishman-
Hillard has entered into discussions with many other organizations in the
102 media markets. Greater Emphasis on

Community Partnerships in Phase III

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Organization/ Community group Project Description of actions being taken

AmeriCorps Training program Proposal in development for a “training
the trainers” program to work with project leaders on substance abuse
and the linking of community service projects to drug prevention. Boys and
Girls Clubs of America In development In discussion to explore potential
partnership opportunities. Cable in the Classroom (CiC) Link with the
National

Future Farmers of America (FFA) program

The Campaign is working with CiC to share production expertise and resources
with FFA members as they develop submissions for the Campaign PSA contest.
ONDCP has also partnered with CiC to produce a series of four short videos
for teachers demonstrating how to incorporate subjects like drug use and
violence into existing curricula on other subjects. Community Anti- Drug
Coalitions of America (CADCA)

3- in- 3 soccer program, leadership forum

In partnership with CADCA, the Campaign launched a series of interactive
satellite programs on Campaign themes that were down- linked to about 250
CADCA sites across the country. The Campaign also participated in CADCA's
National Leadership Forum in December 1999. Community groups Campaign Update

Newsletter The Campaign produces a stakeholder newsletter approximately four
times a year that highlights programs and opportunities across the country.
Community groups Media tool kit for

community action The Campaign developed materials for kits for national,
state,

and local levels to help partners carry out training and awareness- building
activities to extend the Campaign's impact. Community groups Campaign
brochure The Campaign produces a brochure that highlights all of the

components of the Campaign and its programs and opportunities. Community
groups Broadcast E- mail The Campaign alerts stakeholders to time- sensitive

opportunities via a broadcast E- mail system. The database currently has
more than 45,000 entries. ESPN and community groups X Games The Campaign
partnered with ESPN, through a pro bono match

opportunity, to be a sponsor at the X Games in San Francisco; 11 local
partner organizations were enrolled to participate. Girl Scouts Various The
Campaign is working with the Girl Scouts on the creation of

badge and patch programs for all levels of girl scouts. Hepatitis Foundation
International and community groups

Let's Kick Hepatitis Challenge! The Campaign hosted an exhibit and provided
Campaign

resource materials at this event in Atlanta in November 1999. Following the
event, the Campaign also provided additional material for follow- up packets
that were sent to all middle- school students in the Atlanta area. National
Association of Partners in Education

Conference presentation The Campaign made a conference presentation,
“Student Success: The Business of Partnerships,” in November
1999. National Association of State Alcohol and Drug Abuse Directors
(NASADAD)

Local match task forces The Campaign has engaged NASADAD and its affiliate,
the National Prevention Network (NPN) by including a NASADAD member on each
of the local match review panels; promoting the Campaign to state and local
NASADAD and NPN constituents; establishing a mechanism for providing
information from ONDCP to NASADAD and NPN membership; and establishing a
mechanism for providing feedback from NASADAD/ NPN members to ONDCP.
National Council of La Raza In development In discussion to explore
potential partnership opportunities.

Table 3. 2: Partnership Activities as of March 2000

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Organization/ Community group Project Description of actions being taken

National Drug Prevention League (NDPL)

Media market mapping The Campaign has identified capacities of community-
level, drug prevention, and civic organizations in each local media market
working through the 25 largest members of NDPL and their community
affiliates. National Education Association (NEA)

Education program The Campaign is collaborating with NEA on such things as
Web resources, media literacy initiatives, and the integration of a drug
component for its parenting skills workshop program. National Future Farmers
of America

Youth- to- youth education The Campaign has partnered with FFA to create a
peer- to- peer PSA contest for FFA's 450,000 members. The contest was
launched in October 1999. The Campaign created a Web resource area for FFA
on Campaign themes. The National Guard, Sun Microsystems, Inc., Open Voice,
Forever Young Foundation, CADCA

Straight Scoop News Bureau

The October 1999 launch events included an on- line chat and live
videoconference. Viewer reach was over 5 million with participation from,
among others, 2,700 schools and 56 school districts. The New York Times
Educator guide The Campaign is working with the paper's Newspaper in

Education Program and released an updated educator's tool, “Anti- Drug
Education With The New York Times,” in November 1999. Prevention
Through Service Alliance (PTSA)

Civic alliance The Campaign is creating and packaging materials for and Web
resources with the civic organizations of PTSA, whose 47 umbrella members
include Big Brothers Big Sisters of America, National 4- H Council, Girl
Scouts, 100 Black Men of America, and dozens of other community
organizations. ONDCP and PDFA are also creating advertisements specifically
tailored for the magazines of 37 civic, fraternal, and service
organizations. A recognition program for these organizations supporting
youth activities is also being developed. Society for Human Resource
Management (SHRM) Outreach program Discussion groups were held with SHRM
members to gather

information about working with the human resource community to provide anti-
drug information to parents through workplace communication channels. USA
Today Family and education

program The Campaign is working with the USA Today Family and Education
program, the National Association of Student Assistance Professionals, and
the National Middle School Association on the production of a print insert
on Campaign themes. Various Freevibe The Campaign developed this Web site
for middle- school

children. The Web site has extensive drug information and links. An on- line
guide for teachers is also available. YMCA of the USA Resources, training,
and

after- school program The Campaign is collaborating with the YMCA on the
launch of its “City Agenda,” which includes an after- school
program for middle- school students. Contributions include assisting with
curriculum development, training of YMCA center directors, and creating
Internet and Intranet resources for members and teen staff on Campaign
themes. Youth Service America (YSA) Community fairs, Web

resource development The Campaign is working with YSA to create 35 National
Youth

Service Day programs around the country highlighting volunteerism as a drug
prevention intervention. Web resources are in development to take advantage
of YSA's youth volunteerism opportunities across the country.

Source: Fleishman- Hillard, Inc., and ONDCP.

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Fleishman- Hillard has also developed a Media Tool Kit for Community Action.
The kit will be given to community anti- drug coalitions and others and will
provide information about what the Campaign is and how these groups can use
it in their own programs.

According to ONDCP, the Ad Council is also playing an important role with
community groups during phase III. As a part of its contract with ONDCP, the
Ad Council is developing and assisting in the implementation of an anti-
drug coalition/ drug prevention organization recruitment campaign. Through
this effort, ONDCP hopes to recruit adults to join anti- drug organizations,
including community coalitions. In partial fulfillment of this task, the Ad
Council established an Anti- Drug Coalition Task Force, which held meetings
with a broad range of coalitions to assist the Ad Council in understanding
the work of the coalitions, how they recruit, and the barriers to
participation in the work of these coalitions. In addition, six focus groups
met to discuss why some individuals decline to become involved in anti- drug
coalitions. Through these meetings, the Ad Council learned that many adults
(1) do not feel qualified to join an anti- drug group, (2) are afraid of the
stigma associated with being part of an antidrug group, and/ or (3) have a
negative opinion of anti- drug groups.

The Ad Council concluded that an educational awareness campaign would be
needed before a serious recruitment effort could be successful. In response,
the Ad Council developed a two- stage approach. The first stage, to be
carried out over 1 to 2 years, is to (1) focus on education and awareness to
change misconceptions about anti- drug coalitions and present a positive
face on anti- drug coalition activities and (2) involve a series of print
and possibly, outdoor, advertisements directed toward adults. This campaign
is to be launched in August 2000. The second stage of this campaign will
focus on recruitment, using various advertising media.

Through the AAF and the local- level match program, ONDCP also assists
community anti- drug coalitions by providing free media time to those that
qualify for the match time (see pp. 46 and 47 of this report, for additional
details).

ONDCP staff also attended all regional meetings in 1999 of the Centers for
the Application of Prevention Technology, which is an organization that
brings together coalitions at the local level. ONDCP used these meetings to
bring members up to date on the Campaign and how it can be used as a tool to
their benefit. ONDCP staff also made presentations at the bimonthly meetings
of the National Drug Prevention League (NDPL) and

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obtained information about local- level chapters. NDPL is made up of
representatives from 30 groups that are involved in prevention. Through
NDPL, ONDCP is to identify in each market the capacities and points of
contact for prevention, civic and community organizations, and experts. This
information is to be used to create a media market map that will establish a
communications framework for Campaign initiatives and for responding to
time- sensitive media opportunities.

Congress directed ONDCP to develop a detailed implementation plan for
securing private sector contributions including, but not limited to, in-
kind contributions. In its November 1997 submission to Congress, ONDCP
stated its intention to finalize a detailed plan in January 1998. However,
as of the date of our review, ONDCP had not yet developed a detailed
implementation plan for securing private sector contributions and was
slipping on its current schedule to produce a plan by October 2000.
Nevertheless, even without a plan, as of March 2000, ONDCP reported
contributions valued at an estimated $71.7 million. According to ONDCP, even
when a plan is finalized, ONDCP may not be able to raise the required
amounts in private sector contributions.

A proposed corporate sponsorship/ participation plan was developed in 1998
by Porter Novelli, which is a strategic communications planning firm under
contract with ONDCP for phases I and II of the Campaign. ONDCP officials
explained that this plan was not implemented for the following reasons:

ï¿½ Implementation of the plan was included in the contract with Porter
Novelli as an unpriced option. ONDCP wanted to exercise this option for
implementation in the fall of 1998. However, it realized that when
exercising an unpriced option, the contractor must be justified as a sole
source. It was not possible to justify Porter Novelli as a sole source for
this activity.

ï¿½ The plan focused heavily on corporate sponsorship. 12 ONDCP believed that
other approaches, such as direct monetary contributions, might be more

12 Congress, in the initial Campaign legislation, required ONDCP to submit a
plan to secure private sector contributions. The Porter Novelli plan defined
the following three types of contributions: (1) corporate sponsorship, or
rights fees paid by corporate brands in exchange for specific benefits and
promotional rights around the campaign and its target audiences; (2)
corporate charitable contributions, or donations of cash and/ or in- kind
services to the campaign; and (3) media or promotional matches, or free or
discounted time or space given as part of the match program (see pp. 43 to
51, of this report, for additional detail), or the requirement that
corporate sponsors dedicate a percentage of their own media and promotional
vehicles to publicizing their participation in the campaign. In subsequent
legislation, Congress referred to corporate sponsorship. In this discussion
of private sector contributions, we refer to all types of contributions.
ONDCP Has Not

Developed a Private Sector Contributions Plan

ONDCP Was Unable to Implement a 1998 Plan

Chapter 3 ONDCP's Compliance With Statutory Program Requirements Has Been
Mixed

Page 58 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

advantageous to the Campaign than a heavy focus on corporate sponsorship,
and ONDCP wanted time to “test the market.”

ï¿½ The Campaign lacked a “brand,” which ONDCP officials explained
is a unifying idea that permeates every aspect of a media campaign and that
heightens recall of campaign messages. Both ONDCP and PDFA came to believe
it would be necessary to develop this unifying idea before developing a
contribution plan. 13

ï¿½ ONDCP decided that to make the most effective use of a contributions plan,
it would first need to have the full phase III Campaign in place because
resources generated from the private- sector contributions plan could
support the nonadvertising components of the Campaign, such as partnerships.

ï¿½ Other demands of the Campaign made it difficult to focus on the
contributions plan. The development and implementation of a media campaign
was new to ONDCP. The first two phases of the Campaign were devoted
primarily to planning and executing the paid advertising segment of the
Campaign. ONDCP also began the nonadvertising communication activities in
areas of public information, the Internet, entertainment industry
collaboration, and partnerships with nongovernmental organizations.

ï¿½ ONDCP staffing limitations also played a part. The few staff devoted to
the Campaign had many other responsibilities important to the Campaign in
the first two phases, such as working with the contractors on the paid
advertising campaign.

ONDCP hoped to have a detailed implementation plan for securing private
sector contributions in place in October 2000. Officials explained that as a
first step, ONDCP would issue a request for information (RFI), using this
mechanism because ONDCP has no in- house expertise regarding private sector
contributions. Private industry would be asked to identify specific
requirements that are necessary for formulating and executing a program to
develop and apply private resources to the Campaign. The information
acquired through the RFI process would be included in the statement of work
section of a request for proposal (RFP) that ONDCP would issue to obtain a
contractor's assistance with the development and implementation of a
contributions plan. ONDCP estimated that it would take about 1 year to
implement a private- sector contributions plan once a contractor is chosen.

ONDCP had planned to obtain a contractor according to the following
timetable:

13 The campaign launched its brand, “The Anti- Drug,” in
September 1999. Steps and Timetable for

Development of a Contributions Plan Were Behind Schedule

Chapter 3 ONDCP's Compliance With Statutory Program Requirements Has Been
Mixed

Page 59 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

ï¿½ Issue the RFI in November 1999, with the closing date for responses in
January 2000.

ï¿½ Issue the RFP in March 2000, after review of the RFI and meetings with
industry representatives for additional input into the RFP.

ï¿½ Award a contract around October 2000. However, as of the time of our
review, the process had not begun; neither the RFI nor the RFP had been
issued.

ONDCP was also looking for a firm with expertise in both valuation and
advertising to advise ONDCP on how to value noncash contributions, such as
entertainment story lines and special events tailored to the needs of the
Campaign. ONDCP planned to either issue an RFP or use a firm from the
General Services Administration schedule. ONDCP did not meet its goal for
completing the selection process for this contract by the end of calendar
year 1999.

Even without a plan to secure private sector contributions, as of the time
of our review, ONDCP reported the contributions listed in table 3. 3. 14
ONDCP and its contractors valued these contributions at a combined estimate
of over $71.7 million.

14 ONDCP has received both cash and various in- kind contributions but has
not received corporate sponsorship to date. ONDCP Received

Contributions in the Absence of a Plan

Chapter 3 ONDCP's Compliance With Statutory Program Requirements Has Been
Mixed

Page 60 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

Contribution Type/ Source Description Value Cash

United Parcel Service N/ A $30,000 The Waitt Family Foundation N/ A 100,000

Subtotal $130,000 In- Kind

ABC The creative development and production costs of six PSAs. $1,500,000 a,
b ABC/ Disney Free development and management of the “Freevibe”
Web

site. 100,000 a America Online, Inc. Free development and management of a
Web site for

parents, the development of Web sites for teens and middle school children,
and sponsorship of several Web chat sessions on drugs.

1,000,000 a CBS The creative development and production costs of four PSAs.
1,200,000 a, b ESPN The creative development and production costs of seven

PSAs. 500,000 a, b

Fox The creative development and production costs of five PSAs. 1,400,000 a,
b NBC The creative development and production costs of seven

PSAs. 1,700,000 a, b PDFA Advertisements for use in the Campaign. c
61,800,000 a Univision The creative development and production costs of two
PSAs. 500,000 a, b WB Network The creative development and production costs
of four PSAs. 1,200,000 a, b

Subtotal $70,900,000 Other

CADCA Showed six national satellite downlink broadcasts to its members on
media Campaign message themes.

d Current Miss America Contributed her time for personal appearances, PSAs,
and

Internet chat sessions. d

Major League Soccer Sponsored a “coachaton” anti- drug event,
placed anti- drug information on its programs, requested that its teams do
anti- drug events, and designated one of its players as a national spokesman
on the drug issue.

d Miss Teen USA Pageant Designated youth anti- drug media Campaign as the

pageant's official cause. d

Reader's Digest, the Ad Council, and the DC Boys and Girls Club

Sponsored a youth PSA contest. d Seventeen Major League Baseball teams and 5
NFL teams Ran PSAs during games. d Several local school districts Sponsored
a youth PSA construction media summit. d

Subtotal over $700,000 Total over $71,730,000

a Valuation was determined by contractors using industry standards. b Does
not include the value of the time donated by celebrities. c Does not include
contributions from advertising firms for creative development, the full
value of the waiver of celebrity actors' fees, and the full value of the
waiver of music rights fees from owners of copyrights. d ONDCP did not
separately value these contributions; it estimated a combined value that
exceeds

$700,000.

Table 3. 3: Private Sector Cash, In- Kind, and Other Contributions

Chapter 3 ONDCP's Compliance With Statutory Program Requirements Has Been
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Page 61 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

Source: ONDCP.

For fiscal year 1999, Congress added the requirement that ONDCP develop a
plan to secure contributions equaling 40 percent of the Campaign's
appropriation for that fiscal year- 60 percent in fiscal year 2000; 80
percent in fiscal year 2001; and 100 percent in fiscal year 2002. The
Campaign was appropriated $195 million in its fiscal year 1998 appropriation
and $185 million in both its fiscal years 1999 and 2000 appropriations. For
fiscal year 2000, Congress directed ONDCP to hold back 10 percent of its
appropriated funds until ONDCP submitted a corporate sponsorship plan to the
Appropriations Committees (see pp. 40 and 41 of this report). In addition,
the Senate Appropriations Committee specified that ONDCP should secure
contributions equaling 80 percent of the Campaign's fiscal year 2000
appropriation, which was an increase of the requirement established for
fiscal year 1999.

ONDCP officials told us that even when a private- sector contributions plan
is developed and implemented, they do not believe they will be able to
attain the highest levels of the congressionally mandated levels of
contributions. ONDCP officials said they did not know at what level of
congressionally mandated contributions they would run into trouble. An ONDCP
official indicated that, on the basis of Porter Novelli's 1998 proposed plan
and its knowledge of corporate sponsorship and what the market will
generally “bear” in this area, ONDCP might be able to obtain
from $20 million to $30 million a year in financial or in- kind
contributions, including the value of corporate sponsorship, for a few
years. ONDCP plans to learn more about market limitations through the
process of developing the statement of work and awarding a contract for the
implementation of a contributions plan. ONDCP then plans to brief Congress
on what ONDCP might be able to accomplish in terms of total annual
contributions. ONDCP May Be Unable to

Achieve Contributions Goals

Chapter 3 ONDCP's Compliance With Statutory Program Requirements Has Been
Mixed

Page 62 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

Congress directed ONDCP to develop guidelines to ensure that Campaign funds
would not be used for partisan political purposes, and that no Campaign
efforts would feature elected officials; persons seeking elected office;
cabinet- level officials; or other federal officials employed pursuant to
Schedule C of title 5, Code of Federal Regulations, section 213, 15 absent
advance notice to the Appropriations Committees and the Senate Judiciary
Committee. ONDCP and PDFA developed (1) policy and guidance addressing this
requirement and (2) a review process intended, in part, to ensure that
advertisements do not feature political figures or partisan content.
However, neither ONDCP nor PDFA has an internal control requirement that
these reviews be documented. As a result, ONDCP cannot ensure that
advertisements have been reviewed for the presence of political figures and
partisan content.

In its November 1997 submission to Congress, ONDCP stated that all
advertisements to be used in the Campaign would be carefully reviewed to
ensure that they did not feature political figures or partisan purposes. A
PDFA official explained that ONDCP and PDFA subsequently inserted the
following into PDFA's production guidelines:

“Please note that under no circumstances whatsoever should anyone
running for public office, members of the Cabinet, elected officials, or any
other political appointees to federal office be featured in a PDFA PSA.
Additionally, PDFA PSA's cannot be used by anyone in public office in his or
her own political advertising campaign.” 16

According to ONDCP and PDFA, advertising agencies must present their
concepts to PDFA's Creative Review Committee (CRC). The CRC, which consists
of creative directors from major advertising agencies, can approve, decline,
or request revisions to creative work. In reviewing agencies' presentations,
CRC is to follow a 29- step creative development process. The 29 steps
include activities such as soliciting agencies to do the work on a pro bono
basis, reviewing agency work, and notifying the agency regarding any
necessary changes that must be made. None of the steps address the
prohibition on political figures and partisan purposes.

Recommendations made by the CRC are to be recorded by PDFA staff and kept on
a creative status report. According to PDFA, if political figures/ partisan
purposes were found, this would be captured in the creative status report,
but the report itself does not require that these

15 These are noncareer employees of the Senior Executive Service and, in
some agencies, noncareer GS- 15s. 16 The production guidelines are
instructions that detail advertisement production from start to finish and
are provided to each advertising agency that develops messages for the
Campaign. Guidance and

Procedures Regarding Political Figures and Partisan Political Purposes
Lacked Adequate Internal Control

Chapter 3 ONDCP's Compliance With Statutory Program Requirements Has Been
Mixed

Page 63 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

reviews be documented. However, PDFA believes that the appearance of
political figures/ partisan purposes would be curtailed by PDFA staff. PDFA
staff work closely with the advertising agency and PDFA management believe
its staff would inform the agency about content that violates the production
guidelines.

The final review is to be made at ONDCP. New advertisements would be
presented to the Office of Legal Counsel for review. Part of that review is
to ensure that the advertisements do not feature political figures or
partisan purposes. However, these reviews also are not documented.

The Comptroller General's guidance on internal controls in the federal
government, Standards for Internal Control in the Federal Government (GAO/
AIMD- 00- 21.3.1), requires that all transactions and other significant
events are to be clearly documented, and that the documentation is to be
readily available for examination. The documentation should appear in
management directives, administrative policies, or operating manuals and may
be in paper or electronic form. All documentation and records should be
properly managed and maintained. The documentation of transactions or other
significant events should be complete and accurate and should facilitate
tracing the transaction or event and related information.

For various reasons, ONDCP's progress and results in implementing the
various program requirements related to the Campaign have been mixed. ONDCP
fully complied with some requirements, is still in the process of
implementing others, and may not be able to fully comply with some unless
certain issues are resolved.

Although ONDCP's contractors were successful in obtaining at least a dollar-
for- dollar match, they were not able to obtain a match from every vendor.
To reach the Campaign's reach and frequency goals, it was sometimes
necessary for contractors to purchase time or space from a vendor unwilling
or financially unable to provide equivalent free time or space. Until the
conflict between the congressional direction and the program goals is
resolved, ONDCP may not be able to fully comply with the congressional
direction or achieve its reach and frequency goals.

Although ONDCP obtained some private sector contributions, it still did not
develop a detailed implementation plan to secure private sector
contributions. Moreover, ONDCP indicated that, even when a plan is developed
and implemented, it does not believe that it can raise annually an amount
close to its annual appropriation. Instead, it believes that it might be
possible to raise $20 to $30 million a year in financial or in- kind
Conclusions

Chapter 3 ONDCP's Compliance With Statutory Program Requirements Has Been
Mixed

Page 64 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

contributions, including the value of corporate sponsorship. Therefore,
until this issue of a feasible amount of private sector contributions is
resolved, it appears that ONDCP may not be able to meet the congressional
mandate.

ONDCP and PDFA have developed a policy and guidance to help ensure that
advertisements developed for the Campaign do not feature political figures
or partisan content. However, although they have established a requirement
and process to review advertisements for political content, there is no
internal control requirement that such reviews be documented and readily
available for examination. This is important because without documentation,
ONDCP cannot be certain that its policy and guidance are being followed and,
thus, whether it is in full compliance with Congress' intent.

To improve ONDCP's compliance with the statutory program requirements, we
recommend that the Director of ONDCP direct the appropriate ONDCP or
contractor staff to take the following actions:

ï¿½ To determine the extent to which matches do not occur because of efforts
to achieve the Campaign's reach and frequency goals, maintain documentation
of all purchases that do not result in a match, including why the vendor did
not provide a match and why the purchase was made without a match. This
information should be provided to Congress to assist in its assessment of
the viability of the current congressional direction that ONDCP obtain a
match from each seller of advertisement time and space given the Campaign's
reach and frequency goals.

ï¿½ After adequate research and consultation with experts, provide information
to Congress detailing the anticipated dollar value of all private- sector,
nonmatch contributions to assist Congress in its assessment of the viability
of the private- sector contributions goals and the dollar value ONDCP can be
expected to obtain from the private sector.

ï¿½ Develop internal controls in accordance with the Comptroller General's
standards to ensure that the reviews of new advertisements for political
figures or partisan content are fully documented and available for
examination.

In its written comments on a draft of this report, ONDCP generally agreed
with the findings, conclusions, and recommendations contained in this
chapter. However, ONDCP stated the belief that we had given “short
shrift” to its accomplishments regarding the match program. It was not
our intent to do so. In fact, we recognized that ONDCP and its contractors
were able to achieve a match- to- paid rate in excess of 100 percent. Our
focus was on Recommendations

Agency Comments and Our Evaluation

Chapter 3 ONDCP's Compliance With Statutory Program Requirements Has Been
Mixed

Page 65 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

the difficulty in obtaining a match in every instance and in developing a
recommendation to address this issue. ONDCP agreed with our recommendation
regarding the match program and provided, as attachment A to its written
comments (see app. III), a copy of a letter addressed to Ogilvy and Mather
instructing the contractor to maintain records of instances in which it is
unable to obtain a match. Assuming this instruction is followed by the
contractor, we believe it addresses the first part of the recommendation,
that ONDCP maintain documentation of all purchases that do not result in a
match. However, in instructing the contractor that this information should
be made available upon request, ONDCP did not address the intent of the
second part of the recommendation, that is, that ONDCP proactively provide
this information to the Congress. As a result, we are retaining our
recommendation.

ONDCP asked that we note that ONDCP's involvement with anti- drug coalitions
was based on an incremental approach. We believe that the report's treatment
of the issue of ONDCP's involvement with anti- drug coalitions already
reflects such an approach to meeting the requirement to work with the
coalitions. Specifically, we noted that because ONDCP's primary focus in the
first two phases of the Campaign was on paid advertising, less time was
devoted to the other Campaign components, including work with community
anti- drug coalitions, and that ONDCP has increased its involvement with
community anti- drug coalitions in phase III of the Campaign.

ONDCP asked us to amend the draft report to reflect that it has submitted a
plan to secure corporate sponsorship to the Appropriations Committees. 17
ONDCP attached a copy of this plan to its comments. Our review of the
document led us to conclude that it is a blueprint or strategy for ONDCP's
acquiring a contractor to develop and implement a plan, rather than the
implementation plan itself. In fact, as discussed on page 59, neither the
RFI nor the RFP have been issued. Therefore, the requirement to submit a
detailed implementation plan for securing private sector contributions has
not been fulfilled.

ONDCP also notes that, in addition to nearly $72 million in unsolicited
contributions, it has received another $334 million 18 in value through the

17 The Fiscal Year 1998 Treasury and General Government Appropriations Act
required ONDCP to submit to the Appropriations Committees and the Senate
Judiciary Committee a detailed implementation plan for private sector
contributions, including but not limited to in- kind contributions.

18 This figure differs from that in table 3. 1 because it includes data
developed by Ogilvy and Mather subsequent to completion of our review.

Chapter 3 ONDCP's Compliance With Statutory Program Requirements Has Been
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Page 66 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

match program. However, as ONDCP also correctly mentions, Congress has
directed that the value of such match contributions not be counted as
private sector contributions.

Finally, in response to our recommendation, ONDCP stated that it would
formalize its existing process for reviewing advertisements for political
figures or partisan content to include documenting the required legal
review. Since this action has not yet been taken, we are retaining the
recommendation on this matter.

Chapter 4 ONDCP Phases I and II Campaign Evaluations Were Inconclusive;
Phase III Evaluation Appears Promising

Page 67 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

As required by law, ONDCP established a system for evaluating the impact of
the National Youth Anti- Drug Media Campaign. The first two evaluation
phases have been completed; the third has recently begun. The results of the
phase I and II evaluations regarding the Campaign's impact on youth, teen,
and parent ad awareness and drug attitudes were inconclusive because of
various design, implementation, and analysis limitations. There were,
however, other indications that the initial phases of the Campaign had some
positive effects. These derived from unweighted awareness data, Campaign
community informants, and information obtained from the Substance Abuse and
Mental Health Services Administration's (SAMHSA) NCADI. Although it is too
early to gauge the success of phase III in affecting drug attitudes,
beliefs, and behaviors, the evaluation design appears promising, given its
comprehensive scope, methodological sophistication, and use of lessons
learned from previous phases.

In response to the legislative mandate discussed in chapter 1, ONDCP
established a three- phase impact evaluation system for measuring the
success of the Campaign. Other entities also developed research projects to
help inform Campaign managers. To date, ONDCP has issued final evaluation
reports to Congress on the success of phases I and II. Outcome results on
phase III are scheduled to be issued every 6 months, beginning approximately
in late summer 2000.

After a decade of decreasing drug use by teenagers, the Monitoring the
Future (MTF) survey of 8, 10, and 12 graders showed a rising rate of drug
use from 1992 to 1996 as well as a corresponding decrease in drug risk
perception. 1 A major goal of The National Drug Control Strategy of 1997 was
to “[ e] ducate and enable America's youth to reject illegal drugs as
well as alcohol and tobacco.” In pursuit of that goal, one objective
was to “[ p] ursue a vigorous advertising and public communications
program dealing with the dangers of drug, alcohol, and tobacco use by
youth.”

ONDCP has discussed the evaluation of the 5- year Campaign in two parts: (1)
as an “impact” evaluation (subdivided into three phases) and (2)
as other research projects, which have helped inform Campaign managers
throughout the process.

In phase I of the impact evaluation (Jan. to June, 1998), a 6- month pilot
study, ONDCP principally tested whether the infusion of a paid anti- drug
Campaign made a significant difference in youth, teen, and parent ad

1 The MTF survey is one of the nation's principal sources of drug prevalence
data on school age youth. The University of Michigan has conducted the
survey annually since 1975, with funding from NIDA. ONDCP Has System

for Evaluating the Campaign

Chapter 4 ONDCP Phases I and II Campaign Evaluations Were Inconclusive;
Phase III Evaluation Appears Promising

Page 68 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

awareness. 2 Twelve target sites received the paid advertisements over the
6- month period. These sites were compared with 12 comparison sites that
relied on available PSAs and other community sources for their anti- drug
information.

In the phase II impact evaluation (July 1998 to early 1999), which was
approximately 6 months in duration, ONDCP expanded the Campaign evaluation
from the 24 target and comparison sites to a national scale. Ad awareness
remained the principal focus of concern in the evaluation but, as in phase
I, other drug- related data also were collected.

Phase III comprises the full- scale national Campaign impact evaluation, to
be conducted over a 4- year period, starting in 1999. Awareness of and
exposure to media advertisements will continue to be explored, but the
principal focus will shift toward evaluating the degree to which changes in
drug attitudes, behaviors, and beliefs can be causally related or associated
with the Campaign. These other variables were not principally considered in
phases I and II since ONDCP believed that it would take another 1 to 2 years
before changes in perceptions and attitudes could be detected and 2 to 3
years for drug use changes to be evident.

In addition to the impact evaluation, other research studies were developed
to help inform Campaign managers. These studies included (1) the collection
of local qualitative data from focus groups and key informants, under
contract with SAMHSA's Center for Substance Abuse Prevention; (2) public
contact and publication distribution information from NCADI; and (3) an
assessment of the utility of the Campaign elements, relative to cost,
developed by Ogilvy and Mather.

The principal focus of our report was to review the ONDCP impact evaluation,
since it focused on the primary dependent variables- drug ad awareness,
attitudes, beliefs, perceptions, and drug use change- upon which ONDCP drew
its phases I and II conclusions and will draw its phase III conclusions.

An overview of ONDCP's impact evaluation design for each phase of the
Campaign is presented in table 4.1.

2 In phase I, quantitative survey data were also collected on drug
attitudes, past use of drugs, perceptions of drug risk, drug information
sources, and parent- child communication about drugs. Also, qualitative data
were collected from focus groups and key informants (i. e., members of the
community who are knowledgeable or informed about the community's drug-
related problems and may play a role in policy or program decisionmaking).

Chapter 4 ONDCP Phases I and II Campaign Evaluations Were Inconclusive;
Phase III Evaluation Appears Promising

Page 69 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

Methodological issue Phase I Phase II Phase III

Geographic site selection 24 metropolitan areas: 12 target sites 12
comparison sites

National cross- sectional sample

National cross- sectional sample, four- site longitudinal sample, and
special analytic studies

Respondent selection Youth & teens: school survey Parents: telephone survey

Focus groups, key informants, and community organizations

Youth & teens: school survey Parents: telephone survey

Focus groups, key informants and community organizations

Youth & teens: household survey Parents: household survey

Actual sample size Baseline: School survey: 18,300 Telephone survey: 4,314

Follow- up: School survey: 17,015 Telephone survey: 4,211

Baseline: School survey: 22,534 Telephone survey: 4,209

Follow- up: School survey: 23,414 Telephone survey: 4,256

Data are not yet collected Principal analytic focus Ad awareness Ad
awareness Ad exposure, drug use, attitudes,

and beliefs Campaign evaluation period January 1998 to June 1998

(total of 6 months) July 1998 to early 1999

(total of about 6 months) Starting in 1999

(total of 4 years) National sponsorship agency

ONDCP ONDCP ONDCP/ NIDA Primary evaluation contractor CSR CSR Westat

Source: Documentation provided by ONDCP and NIDA.

As requested, we addressed the following methodological and analytic
questions related to the various phases of the Campaign:

ï¿½ How appropriate were the evaluation designs for assessing the
effectiveness of phases I, II, and III?

ï¿½ How successfully were these evaluation designs implemented?

ï¿½ How effective were the first two phases of the Campaign in influencing
both drug ad awareness and attitude change? 3

3 We limited our assessment of phase III to the design stage since data
collection was just beginning at the time our work was completed.

Table 4. 1: Methodology of the Impact Evaluations for Phases I, II, and III
of the National Youth Anti- Drug Media Campaign

Chapter 4 ONDCP Phases I and II Campaign Evaluations Were Inconclusive;
Phase III Evaluation Appears Promising

Page 70 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

The phases I and II impact evaluation sampling designs for selecting youth,
teen, and parent participants in the respective local and national surveys
were generally appropriate on the basis of common scientific practice.
However, the ad awareness measure- the principal outcome variable of both
phases I and II- did not adequately measure the overall awareness generated
by the Campaign.

In the phases I and II impact evaluations, ONDCP sought to obtain youth
(grades 4 to 6), teen (grades 7 to 12), and parent participation in the
local and national surveys to study the impact of the Campaign on drug ad
awareness, attitudes, and other outcome variables. The sampling designs used
to select respondents from each of these three groups were generally
appropriate. 4

A multistage sampling approach was used to conduct baseline and followup
surveys of teens and youth in each phase. The phase I design involved the
selection of 12 target and 12 comparison sites, 5 followed by the random
selection of schools and classrooms at the sites. The goal was to obtain
completed questionnaires from 24, 000 students at baseline and 24,000 at
follow- up, equally divided by target and comparison sites. The phase II
design called for the random selection of counties nationwide, followed by
the random selection of schools and classrooms in these counties. The goal
was to obtain completed questionnaires from 21,000 students at baseline and
follow- up, equally divided between youth and teens. The questionnaires were
to be anonymously completed by students present on the day of the survey in
each phase.

The parent samples in the phases I and II telephone surveys were to be
selected independently from the student samples. The parent samples were
obtained by random digit dialing, a standard sampling technique used in
telephone surveys of the general population. Each household contacted

4 The term “generally appropriate” is used here to indicate that
although the respondent sampling design was largely positive, our outside
reviewers did cite some limitations in the sampling design (e. g., student
exclusion from private schools in phase I and a reduced precision of
estimates attributable to highly clustered student samples). This latter
limitation can occur in surveys in which students are sampled from clusters
of schools.

5 The site selection criteria included the following characteristics: (1)
geographic dispersion; (2) population size and other demographic
characteristics; (3) presentation, at least in some areas, of emerging drug
problems; (4) availability of community drug data; and (5) low drug PSA
activity, to minimize outside drug media influences. Phases I and II

Respondent Sampling Designs Were Generally Appropriate, but Awareness
Measure Had Limitations

Respondent Sampling Designs Were Generally Appropriate

Chapter 4 ONDCP Phases I and II Campaign Evaluations Were Inconclusive;
Phase III Evaluation Appears Promising

Page 71 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

was to be screened to determine if it contained a parent of a child 18 years
old or younger. Parents satisfying these criteria were requested to
participate in the survey.

Ad awareness was the major outcome variable in the phases I and II
evaluations. But the ad awareness measures established in the design stage
did not capture the full extent of either local or national awareness of the
Campaign. Nor did the Campaign appropriately measure teen and parent
awareness.

We identified several limitations that may have had an effect on ad
awareness measurement, including the following:

ï¿½ Youth, teens, and parents were asked only about television advertisements
in the phases I and II survey forms; radio, newspaper, magazine, and
billboard media ad awareness items were not included in the survey
instruments. 6

ï¿½ Teen and parent awareness responses were to be measured in a conservative
manner; that is, positive teen and parent awareness responses were to be
based on seeing an advertisement “often” in the past few months
rather than “ever” seeing the advertisement. Had the working
definition of awareness been broadened, Campaign awareness results would
have increased.

ï¿½ “Aided recall” 7 procedures were used to assess individuals'
awareness of Campaign advertisements. Although aided recall procedures have
been used in other surveys, there is a risk that respondents could have
indicated awareness of a specific advertisement when, in fact, they were
unfamiliar with that advertisement. 8 To counter this overreporting
potential, follow6

In phase I of the Campaign, advertisements for youth and teens were
presented on television and radio; advertisements for parents were presented
on television, radio, and newspapers. In phase II, the use of magazines and
the Internet were introduced. ONDCP recognized the need to ask about other
media in addition to television, yet indicated that at the time that the
phases I and II surveys were approved by the Office of Management and
Budget, only television advertisements were available.

7 Aided recall procedures are used in surveys in an attempt to stimulate
respondents' memories. These procedures provide the respondent with
information or other memory cues to help the individual complete the task,
rather than leaving the individual to his/ her own devices. In the Campaign,
ONDCP provided respondents with one- to four- sentence descriptions of the
surveyed advertisements.

8 Seymour Sudman and Norman M. Bradburn, Response Effects in Surveys: A
Review and Synthesis. Aldine Publishing Company, Chicago, 1974, pp. 80- 81.
Seymour Sudman and Norman M. Bradburn, Asking Questions: A Practical Guide
to Questionnaire Design. Jossey- Bass Publishers, San Francisco, 1982, pp.
36- 39. Limitations Existed in the

Ad Awareness Measures

Chapter 4 ONDCP Phases I and II Campaign Evaluations Were Inconclusive;
Phase III Evaluation Appears Promising

Page 72 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

up questions could have been asked (on at least a few items) to elicit a
more in- depth description of the advertisement or action sequence. 9

ï¿½ One or more false advertisements could have been provided in the survey
instrument as a measure of respondent veracity. 10

We identified several limitations in ONDCP's efforts to implement and
analyze the phases I and II youth, teen, and parent evaluations. These
limitations related to geographic site selection, unknown parent response
rates, high school nonresponse rates, and problems relating to data
analysis- with implications for the quantitative accuracy,
representativeness, and generalizability of the youth, teen, and parent
survey results.

The phase I survey design strategy called for obtaining a geographic sample
of comparable target and comparison sites to determine whether the paid
Campaign intervention made a difference in local ad awareness and other
outcome variables. However, several target and comparison sites were not
comparable at the implementation stage. As a result, ONDCP could not
determine how much of the ad awareness differences found between these sites
should be attributed to the campaign intervention versus other outside
factors.

To test the effects of the paid Campaign in phase I, ONDCP sought to create
comparable (or matched) target and comparison sites in an effort to minimize
the effects of outside factors. If the target sites exposed to the paid
media advertisements demonstrated more positive effects than matched the
comparison sites on ad awareness and other outcome variables, ONDCP would
have had greater assurance that at least some of these positive effects may
have been due to the Campaign. ONDCP presented its matching strategy in the
phase I final report. “Each site was [to be] paired with a comparison
site that had similar population characteristics, to the extent possible,
and was located in a relatively

9 The underreporting of ad awareness could have also taken place, given that
respondents were only provided with an one- to four- sentence description of
the specific advertisements in the ONDCP survey instruments. One of ONDCP's
consultants believed that the false positives generated by aided recall were
“probably more than offset by underreporting,” but we had no way
to verify the underreporting or overreporting. In addition, one of our
outside expert reviewers judged the lack of unaided recall procedures as
“the biggest objection” to the survey instruments.

10 Because false advertisements were not provided in the survey instruments,
ONDCP sought after- thefact to develop a surrogate measure of this
phenomenon in response to our concern. In both phases I and II, ONDCP noted
that a limited number of teen advertisements had been included in the survey
instruments but ultimately not used either as PSAs or in the paid Campaign.
Respondents demonstrated low awareness of these advertisements both at
baseline and follow- up, thereby providing some degree of reporting
veracity. Phases I and II

Implementation and Analytic Limitations Compromised the Results

Geographic Site Selection Proved Problematic

Chapter 4 ONDCP Phases I and II Campaign Evaluations Were Inconclusive;
Phase III Evaluation Appears Promising

Page 73 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

similar geographic area.” However, the initial pairing of target and
comparison sites did not always yield sites well matched on population
characteristics and geographic area, as intended by ONDCP. For example, our
outside reviewers and we noted that 9 of the 12 target sites had larger
populations than their matched comparison sites. In 1 illustration, the
median target site (Baltimore) had a population that was 275 percent the
size of its respective comparison site (Richmond)- that is, 2, 383,172
versus 865,640. The crime rate per 100,000 per year in Baltimore was more
than double that of Richmond (1,335 v. 603), and the percentage of children
under 18 living below the poverty level in Baltimore was more than twice
that of Richmond (34 v. 14). In another illustration, Washington, D. C. 's,
population was more than 4 times larger than that of Birmingham, AL, which
was its comparison site (3, 923,574 v. 907,810). Birmingham had a crime rate
that was150 percent higher than that of Washington (1, 071 v. 716), an
unemployment rate that was 165 percent higher than that of Washington (6.1
v. 3.7), and a child poverty level that was 258 percent higher than that of
Washington (20.4 v. 7.9). In addition, Washington is located in the South
Atlantic census region, whereas Birmingham is located in the East South
Central region. 11 In all, 6 target- comparison site matches demonstrated
crime- rate variations that were greater than 350 per 100,000 per year. Four
matches were not in the same geographic census region. 12

Further, as previously indicated, target and comparison sites were to be
matched on other design variables (i. e., areas of low drug public service
activity, areas of emerging drug problems, and areas of available community
drug data). However, ONDCP has not presented the data indicating the success
of the matches for these variables.

ONDCP also experienced problems gaining school survey data in 4 of the 12
comparison sites chosen. Since ONDCP did not have any other comparison sites
in reserve, when these four sites were dropped from the study, four
comparison sites already participating in the study had to be

11 In addition, ONDCP noted that “[ i] t was very difficult to find an
MSA [Metropolitan Statistical Area] with characteristics similar to those of
Atlanta.” Memphis was chosen as the Atlanta match. However, there were
several differences between these two sites: Memphis had about one- third
the population of Atlanta (981, 747 v. 2,833, 511), a different racial
configuration (41 percent v. 25 percent African American), a crime rate 155
percent higher than that of Atlanta (1,253 v. 807), and about twice the
percentage of children under 18 living below the poverty level (26. 6 v.
13.9).

12 The following matches were not in the same geographic census region:
Milwaukee (West North Central census region) with Nashville (East South
Central census region); Memphis (East South Central) with Atlanta (South
Atlantic); Tucson (Mountain) with Austin (West South Central); and
Washington with Birmingham.

Chapter 4 ONDCP Phases I and II Campaign Evaluations Were Inconclusive;
Phase III Evaluation Appears Promising

Page 74 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

used as replacements. 13 Two of these four sites were not comparable to the
target sites.

Moreover, key informants participating in the Campaign pointed out that
other recent events in at least four target sites and one comparison site
might have influenced drug awareness results in these sites irrespective of
the Campaign. 14

ONDCP reported adjusted response rates 15 for the parent surveys in the
phases I and II final reports submitted to Congress. The phase I adjusted
response rates were reported to be 47 percent for the baseline survey and 46
percent for the follow- up survey. The phase II adjusted response rates were
reported to be 53 percent for the baseline survey and 52 percent for the
follow- up survey. We questioned the accuracy of these adjusted parent
response rates, given the high levels of reported initial refusals 16 and
the methodology used to compute the adjusted rates. 17 We also had concerns
about the generalizability of the parent data. 18 ONDCP subsequently

13 ONDCP cited four reasons for its inability to recruit alternate sites:
(1) a tight time schedule- the design and implementation of the study had to
be conducted in 3 months, (2) budget limitations, (3) difficulty recruiting
in additional cities and schools, and (4) insufficient notice that the four
sites would refuse participation- clarification was obtained in December;
baseline data collection was to be completed in January.

14 For example, key informants in the Baltimore area indicated that the
Campaign may have only “slightly” raised awareness of the drug
problem in the community because “numerous” federal, state,
local, and private efforts have been ongoing to address drug use and
trafficking; a “concurrent” media campaign conducted by Assets
for Colorado Youth “may have affected survey responses” in
Denver, in addition to the recent formation of institutionalized prevention
programs within government; a key informant in Atlanta attributed increased
awareness of anti- drug television messages to a “major antidrug media
campaign conducted in the Atlanta area in 1997” (just before the
inception of the Campaign); and site visits to San Diego and Memphis
demonstrated that each of these sites had ongoing anti- drug media campaigns
in place before and during the Campaign.

15 Since there were large numbers of households that refused to participate
in the parent survey screening process, ONDCP could not determine exactly
how many households contacted actually had a member qualified for
participation (i. e., had at least one parent with a child 18 years of age
or younger). ONDCP therefore adjusted the overall survey response rates in
an attempt to take parent qualification into consideration.

16 According to ONDCP, the term “initial refusals” refers to the
actual number of households refusing to participate in the parent survey
screening processes of phases I and II. In phase I, ONDCP reported 14, 812
initial refusals at baseline and 15, 249 at follow- up; in phase II, ONDCP
reported 10,966 initial refusals at baseline and 11, 116 at follow- up.

17 Because of the apparent high number of households that refused to provide
information about parent status, ONDCP's estimates could have been biased.
18 Surveys with a high level of nonresponse could be affected by nonresponse
bias and other statistical problems, particularly at response rates lower
than 50 percent. Office of Information and Regulatory Affairs, Office of
Management and Budget (OMB), The Paperwork Reduction Act of 1995:
Implementing Guidance for OMB Review of Agency Information Collection, June
2, 1999, pp. 73, 127129. Unknown Parent Response

Rates; Low School Response Rates

Chapter 4 ONDCP Phases I and II Campaign Evaluations Were Inconclusive;
Phase III Evaluation Appears Promising

Page 75 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

provided revised response rate data, but we found inconsistencies in these
calculations as well. Consequently, the actual parent response rates for
phases I and II of the Campaign are unknown.

School response rates were low for both phases I and II. This was
particularly so in phase II, in which less than one- third of the originally
invited schools agreed to participate in ONDCP's youth and teen surveys. In
phase II, 27 percent of the schools for youth agreed to participate at
baseline and follow- up; 29 percent of the schools for teens agreed to
participate at these two time periods. 19 In phase I, the aggregate school
response rates in the comparison sites were 41 percent at baseline and 42
percent at follow- up. 20

To obtain the planned quotas of completed questionnaires, ONDCP selected
additional schools to replace the originally selected schools that did not
participate. A total of 97 replacement schools participated in phase I; 248
replacement schools participated in phase II. ONDCP's contractor was not
able to provide a response rate for the replacement schools due to the
nonrandom method they used to select the replacements (i. e., due to time
pressures, they enlisted the participation of several schools at the same
time and selected the first one willing to participate). Because of the
quota procedure used, the low original school response rates and the
nonrandom method of selecting replacement schools, it is likely that
participating youth and teens were not representative of their respective
study populations. 21 Thus, as with results of the parent surveys, the
results from the school surveys should not have been generalized beyond the
respondent samples.

ONDCP weighted the parent, youth, and teen results from the phases I and II
surveys using population parameters. However, since there was reason

19 In ONDCP's request for revised survey instrument clearance from OMB, it
was anticipated that at least 80 percent of the schools contacted would
participate in the phase II baseline study; 90 percent of those were
expected to cooperate at follow- up.

20 ONDCP provided the following two reasons to explain their
“handicap” in the school recruitment process: (1) “We were
new to the field and had no record of cooperation with the schools, unlike
the MTF which has been in existence for more than 25 years, and (2) there
are too many surveys competing for scarce time in the classroom, including
the MTF, the Youth Risk Behavior Survey, state and local surveys, and
several non- drug related surveys by Federal, State, and local
governments.”

21 As noted by OMB, “The statistical laws that permit inference from a
sample to a population assume complete coverage, complete response, and
random selection ‘quota samples' cannot produce results that can be
generalized to the universe of study. Likewise, samples drawn from a
substantially incomplete frame, or which suffer from significant nonresponse
cannot support valid statistical inferences.” Office of Information
and Regulatory Affairs, OMB, The Paperwork Reduction Act of 1995:
Implementing Guidance for OMB Review of Agency Information Collection, June
2, 1999, p. 73. Analysis Problems

Chapter 4 ONDCP Phases I and II Campaign Evaluations Were Inconclusive;
Phase III Evaluation Appears Promising

Page 76 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

to believe that the samples of these respective groups may not have been
representative of their respective populations (due to unknown parent
response rates, high school nonresponse rate, and loss of the randomized
sample) unweighted data- that is, actual data that were obtained from the
respondents participating in the survey samples- should have been used.

In addition, tests were used to determine the statistical significance of
these survey results. However, statistical significance testing generally
requires that data be obtained from random samples. Youth and teen data
collection from replacement schools was implemented in a nonrandom fashion.
Therefore, use of statistical significance testing with these results is
questionable. At a minimum, ONDCP should have indicated that statistical
tests had been used even though the final samples were not completely
random. ONDCP should also have provided reasons, on the basis of such
factors as subject matter knowledge, experience, and judgment, why it
believed such tests were nevertheless justified.

The previously mentioned limitations notwithstanding, there were indications
from the unweighted survey results, community informants, and information
obtained from NCADI, that led us to believe the initial phases of the
Campaign had some positive effects.

First, unweighted data from the impact studies of phases I and II seemed to
indicate increased awareness of Campaign advertisements. Youth, teens, and
parents in target sites 22 demonstrated positive gains on 25 of 26
unweighted ad awareness items during these phases of the Campaign.
Unweighted drug attitudinal data for the three groups showed both small
gains and losses.

Second, focus groups and Campaign community informants have reported
anecdotal information that describe positive community anti- drug
activities/ changes taking place as a result of the Campaign. 23 These
changes included the following:

22 We considered only target sites in the phase I analysis to obviate
comparison site match concerns. We also measured ad awareness in the same
way that ONDCP measured this variable for youth, teens, and parents.

23 Some of these findings were derived from the ONDCP phase I final report
section on site- specific results; other findings were derived from the
Pacific Institute for Research and Evaluation, ONDCP Media Campaign
Surrogate Measures Project, report prepared under contract from the Center
for Substance Abuse Prevention, Substance Abuse and Mental Health Services
Administration, June 25, 1998. We did not verify each observation made by
community informants against source documents. Some Positive Effects

Were Associated With Phases I and II

Chapter 4 ONDCP Phases I and II Campaign Evaluations Were Inconclusive;
Phase III Evaluation Appears Promising

Page 77 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

ï¿½ In Washington, D. C., prevention program providers cited a 30- percent
increase in hotline telephone calls from individuals searching for
information on substance abuse prevention and treatment.

ï¿½ In Sioux City, several local television and radio stations aired the
campaign advertisements as PSAs rather than as paid slots. The stations
donated the money saved from the paid advertisements to community prevention
programs.

ï¿½ In Colorado, a $50, 000 grant was allocated for conducting marijuana
education.

ï¿½ In Houston, advertisements were aired on Channel 1 in the Houston
Independent School District.

ï¿½ In San Diego, the Partnership for a Drug Free San Diego was asked to
provide the police force with substance abuse prevention materials for its
neighborhood policing effort.

Third, our comparison of the volume of NCADI's public contacts 24 and
publications distribution over three, 6- month periods 25 showed that
clearinghouse activity increased substantially during the Campaign period.
For example, there was a 192- percent increase in telephone contacts and a
64- percent increase in faxes, E- mails, and mail contacts between the
preCampaign and phase II periods. The number of hits per day on NCADI's
PREVLINE Web site increased from 44,433 in the pre- Campaign period to
74,905 during phase I and 103,303 hits in phase II (an increase of 132.5
percent within a 1- year period.) In phase II, there were also distribution
increases on five of seven anti- drug publications, ranging between 122
percent and 249 percent compared with the pre- Campaign period (see app.
II). Although at least some of this increased activity could be due to
factors other than the Campaign, NCADI data lend support to the contention
that there is a positive relationship between increased Campaign awareness
and heightened clearinghouse activity. 26

24 Public contacts comprise telephone calls, faxes, regular mail, E- mails,
and Internet Web site hits. 25 Phases I and II were compared with a pre-
Campaign period: the pre- Campaign period (July 1997 to Dec. 1997), phase I
(Jan. 1998 to June 1998), and phase II (July 1998 to Dec. 1998). 26 To
illustrate, a Campaign advertisement for a marijuana publication appeared in
Parade Magazine. NCADI reported receiving 2, 776 contacts the following day,
resulting in the shipment of 5, 299 copies, approximately 3 times the number
of publications shipped either the week before or after the advertisement
appeared. In addition, SAMHSA found that daily increases in the distribution
of seven publications were associated with Campaign activities announcing
the ONDCP toll- free telephone number. We did not seek to verify these data.

Chapter 4 ONDCP Phases I and II Campaign Evaluations Were Inconclusive;
Phase III Evaluation Appears Promising

Page 78 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

The phase III evaluation design appears to be more promising than previous
phases in being able to provide a more comprehensive overall assessment of
the Campaign's impact and effectiveness. This is because the phase III
design (1) seeks to examine a more extensive set of evaluation objectives
and variables, including drug use behaviors, attitudes, knowledge, and
belief patterns; (2) incorporates a theoretical model of the relationship
between these variables, to better understand the process through which
media exposure occurs and drug use and attitudinal change take place; (3)
employs a sampling design that builds upon lessons learned from phases I and
II, and allows for the collection of both cross- sectional and longitudinal
data; and (4) uses a more comprehensive analytical strategy for
demonstrating whether there is a preponderance of evidence in support of the
Campaign. Also, the continued collection of NCADI data as a supplemental
measure will help to demonstrate whether public awareness of and exposure to
anti- drug messages are increasing or diminishing over time. In addition, an
Ogilvy and Mather study will seek to determine the impact of particular
media elements, with the aim of revising the Campaign while in progress to
maximize its effectiveness.

According to NIDA, the phase III evaluation will comprise the following five
major objectives, containing a greater number of intermediate and outcome
variables than was covered in the phases I and II evaluations:

ï¿½ measure changes in drug- related knowledge, attitudes, beliefs, and
behavior in youth and their parents;

ï¿½ assess the relationship between changes in drug- related knowledge,
attitudes, beliefs, and behavior and their association with self- reported
measures of media exposure, including the salience of message;

ï¿½ assess the association between parents' drug- related knowledge,
attitudes, beliefs, and behavior and those of their children;

ï¿½ assess changes in the association between the parents' drug- related
knowledge, attitudes, beliefs, and behavior and those of their children that
may be related to the Campaign; and

ï¿½ assess the extent to which community- based drug prevention activities
change in response to the Campaign.

During phase III, the relationship between the Campaign and drug use
behavioral change- the key outcome variable- will be initially explored.
ONDCP officials had not examined this relationship in earlier phases of the
study because they said that it would take approximately 2 to 3 years for
the Campaign to have an impact on drug use change. Both phases I and II were
each only about 6 months in duration. The Phase III

Evaluation Design Appears More Promising Than Previous Phases

Phase III Objectives Are More Extensive Than Those for Phases I and II

Chapter 4 ONDCP Phases I and II Campaign Evaluations Were Inconclusive;
Phase III Evaluation Appears Promising

Page 79 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

The ONDCP phase III evaluation of the Campaign is based primarily on two
studies, the National Survey of Parents and Youth (NSPY) and the Community
Longitudinal Survey of Parents and Youth (CLSPY). Both studies use household
surveys- rather than school and telephone surveys- to maximize response
rates. Both studies sample parents and youth from the same households to
study interaction effects that may be taking place among family members. If
these phase III design elements are properly implemented, ONDCP should be
able to provide Congress and the public with more conclusive results
regarding the impact of the Campaign than were provided in phases I and II.

The NSPY was designed as a nationally representative, cross- sectional
survey of noninstitutionalized youth and parent (or caregiver) respondents,
living in all 50 states and Washington, D. C. As in phases I and II, a
multistage sampling approach is to be used in selecting respondents. The
NSPY household survey is to be administered once every 6 months, over a
period of 4 years. This time frame provides NIDA and its contractors with
the opportunity to continually measure changes in the outcome variables over
time. This was not feasible in phases I and II, in which there was only a
single follow- up to the baseline measure.

The CLSPY was designed as a longitudinal survey to better understand the
progressive and interactive dynamics taking place among youth, parents, and
communities in four sites, as a result of the Campaign. The CLSPY has three
principal aims: (1) to determine how knowledge, attitudes, and beliefs among
younger age groups relate to subsequent drug use behaviors as teens; (2) to
evaluate the impact of parent- child interactions on subsequent outcome
changes; and (3) to assess the impact of the Campaign on communities and
local organizations.

Participating CLSPY youth and parent respondents will be interviewed for the
first time at phase III baseline, and then subsequently interviewed once a
year for the next 3 years, to obtain the necessary follow- up data.

NIDA and its contractor/ subcontractors realized that other outside factors
might be impinging on individuals simultaneously during phase III of the
Campaign. The phase III evaluators succeeded in designing a comprehensive
theoretical model and analytic strategy for determining the impact of the
Campaign on several drug intermediate and outcome variables.

A few highlights of the types of analyses planned are illustrated below: The
Phase III Sample

Designs Build on Lessons Learned From Phases I and II

Comprehensive Analytical Strategy Planned for Determining the Impact of
Phase III

Chapter 4 ONDCP Phases I and II Campaign Evaluations Were Inconclusive;
Phase III Evaluation Appears Promising

Page 80 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

ï¿½ To assess whether the Campaign may be having a positive impact on national
drug use rates, historic trend data (from the MTF and the National Household
Survey On Drug Abuse surveys) will be evaluated to determine whether drug
use rates during the Campaign period have declined relative to those in the
pre- Campaign period.

ï¿½ To assess whether changes in parents' drug attitudes are having an
influence on their children, “lagged” analyses 27 are to be
conducted over the 4- year, phase III time frame to determine when, and if,
child attitudinal scores change in accordance with their parents.

ï¿½ To determine whether there is a concurrent or lagged relationship between
attitudinal modification and drug use change, current and longer- term
attitudinal data will be compared against drug use change scores.

ï¿½ Special analytic studies are also to be designed to focus on the
“indirect, message- specific, outcome- specific, and risk- group-
specific effects of the Campaign.” More complex analyses, including
logistic, multivariate, structural equations, will be used to design and
test various hypotheses.

Further, NCADI will continue to collect information on the volume and types
of public contacts received and publications distributed through the end of
calendar year 2000. As previously mentioned, the volume of public contacts
are to be measured in terms of telephone calls, faxes, regular mail, E- mail
contacts, and Web site hits, while publication distribution data are to
cover publications of general community interest. NCADI is also continuing
to collect user satisfaction data as part of its overall performance
monitoring and quality assurance tasks.

In addition, as part of the phase III evaluation, Ogilvy and Mather has
designed an econometric study to provide continuous, short- term feedback to
Campaign officials regarding the contribution of each media element to the
Campaign, relative to costs. If appropriately used, the study has the
potential to help ONDCP make media adjustments on an as needed basis,
thereby enhancing the potential media impact of the Campaign.

As required by law, ONDCP has established a system to evaluate the three
phases of the Campaign. However, due to various design, implementation, and
analytical concerns, the phases I and II youth, teen, and parent survey
evaluation data remain inconclusive. Potential limitations regarding
geographic site selection, nonresponse rates, and data representativeness
and generalizability may have compromised the results. But unweighted
findings from the phases I and II impact studies; input from focus groups,
key informants, and community organizations; and data derived from

27 “Lagged” analyses refers to the study of changes taking place
over time, rather than concurrently. Conclusions

Chapter 4 ONDCP Phases I and II Campaign Evaluations Were Inconclusive;
Phase III Evaluation Appears Promising

Page 81 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

NCADI lead us to believe that the initial phases of the Campaign had some
positive effects.

The 4- year, phase III evaluation design appears to be more promising than
previous phases for several reasons. A theoretically based, better- designed
model has been developed. More comprehensive analytical strategies have been
enumerated for demonstrating the impact of the Campaign. Various statistical
procedures have been designed for analyzing both current and long- term
effects. Moreover, limitations of phases I and II may be overcome in the
phase III design strategy, thereby maximizing response rates and permitting
the study of family drug interaction patterns. Also, NCADI plans to continue
to collect data on the volume of public contacts and reports distribution, a
supplemental measure of campaign awareness and exposure. In addition, Ogilvy
and Mather plans to determine the importance of each media element relevant
to cost- on a rapid turnaround basis- to maximize the impact of the
Campaign.

In its written comments on a draft of this report, ONDCP generally agreed
with our findings and conclusions relating to the evaluation of the
Campaign's three phases, and did not raise any issues or concerns.

However, we need to clarify ONDCP's paraphrasing of two of our findings and
conclusions. First, ONDCP stated that indications from NCADI and focus
groups “support that the Campaign has positive effects on changing
youth attitudes toward drug use.” As discussed in this chapter, we
found that information from NCADI and focus groups provided indications that
the Campaign may have had some positive effects on anti- drug awareness. We
did not find, however, that these sources provided indications of the
Campaign having positive effects specifically on youth attitudes toward drug
use.

Second, ONDCP stated that our report concludes that the phase III evaluation
“should yield superior data.” Although we concluded that phase
III appears to be more promising than previous phases because of its design
and analytical strategy, we did not specifically characterize the quality of
data it might yield. Agency Comments and

Our Evaluation

Appendix I Experts Consulted

Page 82 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

We consulted with the following experts in reviewing the (1) appropriateness
of the methodological, statistical, and design aspects of ONDCP's
evaluations of phases I and II of the National Youth Anti- Drug Media
Campaign and (2) results of these evaluations.

Elaine Cardenas, MBA Director of Marketing The Gallup Organization

Dr. James Derzon Research Scientist Hamilton Fish National Institute on
School and Community Violence The George Washington University Rosslyn,
Virginia

Dr. John Finnegan, Jr. Associate Dean for Educational Affairs School of
Public Health University of Minnesota Minneapolis, Minnesota

Peter Hannan, Senior Research Fellow Division of Epidemiology School of
Public Health University of Minnesota Minneapolis, Minnesota

Dr. Leslie Kish, Professor Emeritus Department of Sociology Survey Research
Center Institute for Social Research University of Michigan Ann Arbor,
Michigan

Dr. Philip Palmgreen Department of Communication University of Kentucky
Lexington, Kentucky

Appendix I Experts Consulted

Page 83 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

Dr. John Pierce Sam M. Walton Professor for Cancer Research Associate
Director for Cancer Prevention and Control University of California, San
Diego La Jolla, California

Dr. Michael Slater Departments of Journalism & Technical Communication/
Psychology Colorado State University Fort Collins, Colorado

Dr. Roger Tourangeau Senior Advisor The Gallup Organization

Dr. Stephen Weber Senior Vice President Market Facts McLean, Virginia

Appendix II NCADI Public Contacts and Publication Distribution

Page 84 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

We compared changes in the volume of NCADI's public contacts and
publications distribution over three, 6- month periods to determine whether
clearinghouse activity increased during the local and national phases of the
Campaign. These periods and their time frames were as follows: (1) the pre-
Campaign period (July 1997 to Dec. 1997), (2) phase I (Jan. 1998 to June
1998), and (3) phase II (July 1998 to Dec. 1998).

NCADI's public contacts included telephone calls, faxes, E- mails, regular
mail, and Web site hits (see table II. 1). Publication distribution was
based on a review of seven anti- drug publications that were directed toward
youth, teens, and their parents (see table II. 2).

Campaign evaluation period Total telephone contacts Total FAX/ E- mail/

mail contacts Average PREVLINE Web site hits/ day

Pre- Campaign (July 1997 - Dec. 1997) 63,765 17,625 44,433 Phase I (Jan.
1998 – June 1998)

70,337 (+ 10.3%)

21,482 (+ 21.9%)

74,905 (+ 68.6%) Phase II (July 1998 - Dec. 1998

186,251 (+ 192.1%)

28,929 (+ 64.1%)

103,303 (+ 132.5%)

Source: SAMHSA's National Clearinghouse for Alcohol and Drug Information.
Weekly Reports on Impact of Office of National Drug Control Policy Youth
Anti- Drug Media Campaign on NCADI Operations, 1999; and unpublished Web
site documentation.

Table II. 1 indicates that the volume of public contacts with the
clearinghouse increased during both phases I and II of the Campaign. The
greater increases took place during phase II, as would be expected, given
that the scope of the Campaign had been enhanced from a local to a national
effort.

Regarding telephone contacts, there was a 10.3- percent increase at phase I
and a 192.1- percent increase at phase II, compared with the 6- month
preCampaign period. Regarding total fax/ E- mail/ mail contacts, there was a
21.9- percent increase at phase I and a 64.1- percent increase at phase II,
compared with the same pre- Campaign period. On the PREVLINE Web site (a
service of SAMHSA's Center for Substance Abuse Prevention, which is operated
through NCADI), there was a 68.6- percent increase at phase I and a 132.5-
percent increase at phase II.

Table II. 1: NCADI Public Contacts Pre- Campaign and Phases I and II
(Percentage Change From Pre- Campaign Period)

Appendix II NCADI Public Contacts and Publication Distribution

Page 85 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

Campaign period and distribution (percentage change from pre- Campaign
period)

Publication Pre- Campaign

(July 1997 to Dec. 1997)

Phase I (Jan. 1998 to

June 1998) Phase II

(July 1998 to Dec. 1998)

Keeping Youth Drug Free: A Guide for Parents, Grandparents, Elders, Mentors
and Other Caregivers 258,739 269,140

(+ 4.0%) 574,035 (+ 121.9%) Tips for Teens About Inhalants 170,507 335,895

(+ 97.0%) 482,445

(+ 182.9%) Marijuana, Facts Parents Need to Know 52,028 120,978

(+ 132.5%) 161,424

(+ 210.3%) Marijuana, Facts for Teens Not available 112,058 99,383

Inhalant Abuse: Its Dangers Are Nothing to Sniff At (NIDA Research Report
Series) 20,397 15,905

(- 22.0%) 17,616 (- 13.6%) Marijuana, Facts for Teens (Spanish version)
11,177 18,217

(+ 63.0%) 26,443

(+ 136.6%) Marijuana, Facts Parents Need to Know (Spanish version) 7,231
18,039

(+ 149.5%) 25,212

(+ 248.7%) Source: Unpublished documentation submitted by SAMHSA to GAO.

Table II. 2 demonstrates publication distribution gains during the Campaign
period as well. Five of the seven publications showed increased
distributions at phase I relative to the pre- Campaign period and even
greater gains at the phase II stage of the Campaign.

In one instance- that is, regarding a publication entitled Marijuana, Facts
for Teens- percentage change distribution results could not be calculated
because the publication was not available in the pre- Campaign period.

In the single instance in which a distribution decrease was noted during the
Campaign period, relative to the pre- Campaign time frame, SAMHSA indicated
that this was due to a decreased inventory of the publication entitled
Inhalant Abuse: Its Dangers Are Nothing to Sniff At.

During phase I, the median publication distribution increase, compared with
the pre- Campaign period, was 80 percent. During phase II, the median
publication distribution increase was 159.8 percent. For the 6 publications,
for which there are data for all 3 time periods, 520,079 were distributed in
the pre- Campaign period; 778,174 in phase I; and 1,287,175 in phase II.

Table II. 2: NCADI Publication Distribution Pre- Campaign and Phases I and
II

Appendix III Comments From the Office of National Drug Control Policy

Page 86 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

Now on pp. 43- 51. Now on p. 34.

Now on p. 36. Now on p. 39.

Appendix III Comments From the Office of National Drug Control Policy

Page 87 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

Now on pp. 57- 61. Now on p. 51.

Appendix III Comments From the Office of National Drug Control Policy

Page 88 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

Now on pp. 62- 63. Now on pp. 67- 78. Now on p. 76.

Appendix III Comments From the Office of National Drug Control Policy

Page 89 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

We did not reproduce attachment B.

Appendix III Comments From the Office of National Drug Control Policy

Page 90 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

Appendix IV GAO Contacts and Staff Acknowledgments

Page 91 GAO/ GGD/ HEHS- 00- 153 Anti- Drug Media Campaign

Richard L. Stana (202) 512- 8816 Daniel Harris (202) 512- 8720

In addition to the persons named above, the following persons made key
contributions to this report: Doris Page, Jared Hermalin, Amy Lyon, Wendy
Ahmed, David Alexander, Louise DiBenedetto, Nancy Finley, Michael Little,
Sidney H. Schwartz, Rebecca Shea, and Keith Wandtke. GAO Contacts

Acknowledgments

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