oversight

OIG's Independent Report on the Department's Performance Summary Report for Fiscal Year 2009

Published by the Department of Education, Office of Inspector General on 2010-02-25.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                           UNITED STATES DEPARDIE:-IT OF EDUCATION
                                          OFt-l eE OF SAFE A.':D DRl'G·FREE SCHOOLS




                                                           "....


Honorable R. Gil Kerlikowske
Director
Office of National Drug Control Policy
Executive Office of the Presidem
Washington. D.C. 20500

Dear Director Kerlikowske:

In accordance with the Office of National Drug Control Policy (ONDCP) Circular Drug Control
Accounting, enclosed please fmd detailed infonnation about perfonnance·rel3ted measures for
key drug control programs administered by the U.S. Department of Education contained in the
U.S. Department ofEducation's Performance Summary Report/o r Fiscal Year 2009, along with
the Department of Education Assistant Inspector General's authentication of the management
assertions included in that report.

Please do not hesitate to contact me if you have any questions about th is information.

                                                 Sincerely,




                                                 Kevin Jcrmings
                                                 Assistant Deputy Secretary


Enclosure #1: Department of Education Perfonnance Summary Report for Fiscal Year 2009,
dated February 19.2010

Enclosure #2: Authentication letter from Keith West, Assistant Inspector General for Audit
Services, dated February 25, 2010

cc: Keith West




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       Department of Education 





         Performance Summary Report 


                 Fiscal Year 2009 





                   In Support of the 


            National Drug Control Strategy 


As required by ONDCP Circular: Drug Control Accounting 




                   February 19, 2010
                                                Department of Education

                          Perfonnance Summary Report for Fiscal Year 2009 


                                                  TABLE OF CONTENTS 


Transmittal Leiter ...................................... ... ... ....... ..... ........... ... ............... ........................ 1 


Perfonnance Summary Infonnation .... .... ..................................................... __ .................. 2 


          Safe Schools/Hea~hy Students ............................................................... .............. 2 


          Student Drug Testing ... ......................................................................................... 7 


          Safe and Drug-Free Schools and Communijies State Grants Program ... ........... 16 


          Grants to Reduce Alcohol Abuse ........................................................................23 


Assertions .. ........ .. .......... ................................................................................................ 32 


          Performance Reporting System .................... ...... .. .. ........ ...... .............................. 26 


          Methodology for Establishing Performance Targets ................................ .... 33 


          Performance Measures for Significant Drug Control Aclivities ............................ 33 


Criteria for Assertions ...... ................................. .... .... ................ .... ..,.. .. ....... .... .............. 33 

                          UNITED SfATES DEPARTMENT OF EDUCATION
                                     OffiCE OF SAFE AND DRUG-FREE SCHOOLS

                                                                                              ASSiSTANT DEPUTY SECRETARY




Ms. Mary Mnchelson
Inspector General (Acting)
U.S. Department of Education
400 Maryland Avenue, S.w.
Washington, DC 20202-1510

Dear Ms.    M~chel son :

As required by Office of National Drug Control Policy (ONDCP) Circular Drug Control
Accounting, enclosed please find detailed information about pelformance-related
measures for key drug control programs administered by the U.S. Department of
Education, in acccrdance with the guidelines in the circular dated May 1, 2007. This
infonnation covers the Safe and Drug-Free Schools and Communities program, which is
the Department's only Drug Control Budget Decision Unit displayed in the National Drug
Control Budget Summary.

Consistent with the instructions in the ONDCP Circular, please provide your
authentication to me in writing and I will transm~ H to ONDCP along with the enclosed
Pelformance Summary Report. As you know, ONDCP requests these documents by
March 1,2010 if possible. Please do not hes ~ate to contact me if you have any
questions about the enclosed information.

                                                 Sincerely,




                                                 Kevin Jennings




                                400 MARYLANDAVE.,S.W.. WASIDNGTON, DC 20202
                                                        www.ed.gov
   011, Ininio.   u Ie IIIJIlN ffllMIl MCISS to ,duell/um 4JUl to prrntuJU rducalion4l ucdhlKe r#uougJaolll the nDtioll.
Performance Summary Information

                         Safe Schools/Healthy Students

Measure 1: The percentage of grantees demonstrating a decrease in substance
abuse over the three-year grant period. (Safe SchoolslHea~hy Students - FY
2005, and 2006 cohorts)

Table 1

Cohort FY 2005 FY2006 FY2007 FY 2008 FY 2009 FY 2009 FY2010
        Actual  Actual  Actual  Actual  Target  Actual  Target
2005   nla     nla     43.75   34.2    86.25   pending nla
2008   nla     nla             66.67   76.67   pendinQ 80.0

The measure. This performance measure is for the Safe SchoolslHea ~ hy
Students in ~iative , a joint project of the Departments of Education, Health and
Human Services, and Justice. The initiative provides grants to local educational
agencies (LEAs) to support the development and implementation of a
comprehensive plan deSigned to prevent student drug use and vio lence and
support healthy youth development.

This measure, one of four for this in~iative for th e 2004, 2005, and 2006 cohorts,
focuses on one of the primary purposes of the initiative - reduced student drug
use. The initiaijve and this measure, are directly related to the National Drug
Control Strategy's goal of preventing drug use before ~ begins. Grantees select
and report on one or more measures of prevalence of drug use for students. For
the FY 2004 - 2006 cohorts, the ~ems selected by grantees to respond to this
measure are not common across grant sites but, rather, reflect priority drug use
problems identified by sites.

FY 2009 Performance Results. S~es were not required to provide or collect
baseline data at the time of application or before program interventions were
implemented, so grantees provide baseline data for their selected measures
related to drug use after year one (for example in FY 2005 for the FY 2004
cohort). Grantees from the FY 2005 cohort generally completed no-cost
extensions and are providing GPRA data in final grantee reports that were due at
the end of December 2009. Those data will be aggregated late r in FY 2010 to
          n
determine the FY 2009 target for the cohort has been met. The FY 2006 cohort
of grantees received no-cost extensions during FY 2009. Final GPRA data for
this cohort will be submitted at the end of December 201 O. FY 2009 data for the
FY 2006 cohort have been received and are being aggregated, but are not yet
available for inclusion in this summary report.

FY 201 0 Performance Targets. Targets for the two earliest cohorts were intlially
established before any performance data for this measure were received, and

                                        2

represented our best judgment at the time, given the significant size of SS/HS
grants and the emphasis on research-based programs that is central to the
initiative. We elected in 2008 to revise the target for the FY 2005 cohort for this
measure based on the actual perfonnance to date (implementation year two) of
the FY 2004 cohort. Based on our professional judgment. it seemed that the
revised target of 86.25 percent was appropriately aggressive and that attaining
that target would be a meaningful outcome for the program, wh ile acknowledging
that our original target of 90 percent for the in~ia l (FY 2004) cohort may have
been unrealistic. In 2008 we also developed revised targets for the FY 2006
cohort, again, based on the limited data available for this measure. We have
made no additional revisions to targets for these cohorts at this time.

Our ability to establish appropriate targets for this program has also been
impacted by challenges associated with the quality of data supplied by grant
sites. Initially, a significant number of sites failed to provide valid data for this
and some other SS/HS measures. Through technical assistance activities we
have achieved some improvements in data quality for some sites, including
significantly improved response rates for the 2005 and 2006 grant cohorts, but
have not completed a full grant cycle with cohorts that have received early and
more intensive technical assistance.

Subsequently, we have adopted revised GPRA measures for this initiative
beginning with the FY 2007 cohort in order to address implementation challenges
with the measure described above. Those revised GPRA measures for the
program that are relevant to the National Drug Control are included as Measures
2 and 3 in this summary report.

Methodology. Data are collected by grantees, generally using student surveys.
Data are furnished in the second of two semi-annual perfonnance reports
provided by grantees each project year. If grantees identified more than one
measure of drug abuse or provided data for individual school-building types (for
example, separate data for middle and high schools), grantees were considered
to have experienced a decrease in substance abuse if data for a majority of
measures provided reflected a decrease. If a grant site provided data for an
even number of measures and hatf of those measures reflected a decrease and
haK reflected no change or an increase, that grant s~e was judged not to have
demonstrated a decrease in substance abuse. While most sites were able to
provide some data related to this measure, we considered as valid data only data
from sites that used the same elements/items in each of two years. We
considered a grant site to have experienced a decrease if data supplied reflected
a decrease over baseline data provided.

The contractor for the SS/HS national evaluation is also using data for this
measure as part of the program evaluation. The evaluation contractor reviews
data submitted, and works with grantees to seek clarifying infonnation and
provide technical assistance if grantees are having ditficulty in collecting or


                                           3

reporting data for this measure. The contractor supplies data for the measure
after it has completed data cleaning processes. If data for this measure are not
available at the time that performance reports are submitted, staff follow up with
sites to attempt to obtain data for the measure.

Grantees that fail to provide data are not included in the tabulation of data for the
measures. Also, grantees that did not provide data for two consecutive project
years (so that we could determine ~ a decrease in substance abuse had
occurred) are not included in data reported for the measure. Authorized
representatives for the grant sHe sign the annual perfonnance report and, in
doing so, certify that to the best of the signer's knowledge and belief, all data in
the performance report are true and correct and that the report fully discloses all
known weaknesses concerning the accuracy, reliability, and completeness of the
data included. Generally, the Department relies on the certification concerning
data supplied by grantees and does not conduct further reviews.

Targets were established for this measure after the baseline data for the FY 2004
cohort were provided. Based on more recent available data for this first cohort
and subsequent cohorts, we adjusted targets. For example, the targets for the
FY 2005 and 2006 cohorts were adjusted in 2008. We made no additional
adjustments to these targets in FY 2009.

Measure 2: The percentage of SS/HS grantees that report a decrease in
students who report current (30-day) marijuana use (SSfHS - FY 2007 and
2008 cohorts)

Table 2

Cohort    FY         FY         FY        FY2008 FY 2009         FY2009 FY 2010
          2005       2006       2007      Actual Target          Actual Target
          Actual     Actual     Actual
2007      nla        nl a       nla      I pending    pending    pending I pending
2008      nla        nl a       nla        nla        pending    pending I pending

The measure. Th is performance measure is for the Safe SchoolsiHeanhy
Students initiative, a joint project of the Departments of Education, Hea~h and
Human Services, and Justice. The initiative provides grants to local educational
agencies (LEAs) to support the development and implementation of a
comprehensive plan designed to prevent student drug use and violence and
support hea~hy youth development. Beginning with the FY 2007 cohort, the
project period for SS/HS grants is 48 months.

This measure, one of six for this initiative for cohorts from FY 2007 and forward,
focuses on one of the primary purposes of the initiative - reduced student drug
use. The initiative and this measure are directly related to the National Drug
Centrol Strategy's goal of preventing drug use before it begins.

                                         4

FY 2009 Performance ResuHs. SHes were asked to provide baseline data at the
time of application or collect baseline data before program interventions were
implemented. Generally, grantees from the FY 2007 cohort provided baseline
and performance data in 2008, though some sites experienced significant delays
in beginning implementation of Interventions while they finalized partnership
agreements, completed a project logic model, and developed an evaluation plan.
Final data for 2008 (both baseline and year one data), as well as data for 2009,
have been received and are being aggregated. ResuHs for 2008 and 2009 will
be reported in the 2010 report.

The FY 2008 cohort recently reported baseline and year one performance data.
Those data are being reviewed as part of the aggregation process. Results will
be reported in the 2010 report.

FY 2010 Performance Targets. We have not established targets for this
measure for any cohort, pending aggregation of final 2008 and 2009 data for the
FY 2007 cohort. We plan to establish targets for the 2007 and 2008 cohorts in
2010. At that time we'll review data received to date from these cohorts, as well
as the results from similar measures in other OSDFS programs and infonnation
from the research IHerature about program effect size, in order to establish
targets.

Methodology. Data are collected by grantees, generally using student surveys.
Data are furnished in the second of two semi·annual penormance reports
provided by grantees each project year.

The contractor for the SS/H S national evaluation is also using data for this
measure as part of the national program evaluation. The evaluation contractor
reviews data submitted by grantees, and works with grantees to seek clarifying
information and provide technical assistance if grantees are having difficulty in
collecting or reporting data for this measure. The contractor supplies data for the
measure after it has completed data cleaning processes. If data for this measure
are not available at the time that performance reports are submitted, staff follow
up with Sites to attempt to obtain data for the measure.

Grantees that fail to provide data or that provide data that does not respond to
the established measure are not included in the tabulation of data for the
measures. Authorized representatives for the grant site sign the annual
performance report and, in doing so, certify that to the best of the signe~s
knowiedge and belief, all data in the performance report are true and correct and
that the report fully discloses all known weaknesses concern ing the accuracy,
reliability, and completeness of the data included. Generally, the Department
relies on the certification concerning data supplied by grantees and does not
conduct further reviews.



                                        5

We will establish targets for this measure when we have final baseline and
performance data from at least one cohort.

Measure 3: The percentage of SS/HS grantees that report a decrease in
students who report current (30-day) alcohol use (SSlHS - FY 2007 and
2008 cohorts)

Table 3

Cohort    FY         FY        FY        FY 2008 FY 2009       FY 2009 FY2010
          2005       2006      2007      Actual  Target        Actual  Target
          Actual     Actual    Actual
2007      nla        nla       nl a      pendin    I pendina   pending   I pending
2008      nla        nla       nla       nla         pending   pending   I pending
The measure. This performance measure is for the Safe SchoolslHealthy
Students inHiative, a joint project of the Departments of Education, Health and
Human Services, and Justice. The initiative provides grants to local educational
agencies (LEAs) to support the development and implementation of a
comprehensive plan designed to prevent student drug use and violence and
support h ea~hy youth development. Beginning wHh the FY 2007 cohort, the
project pertod for SSIHS grants is 48 months.

This measure, one of six for this initiative for cohorts from FY 2007 and forward,
focuses on prevalence of alcohol use. While the National Drug Control Strategy
is focused most intensively on preventing the use of controlled substances, the
strategy does address the role of alcohol as a drug of choice for teenagers. Data
do suggest that ear1y use of alcohol is more likely to result in heavy later use of
alcohol. The initiative and this measure, are directly related to the National Drug
Control Strategy's goal of preventing drug use before H begins.

FY 2009 Performance Resu ~s . SHes were asked to provide baseline data at the
time of application or collect baseline data before program interventions were
implemented. Generally, grantees from the FY 2007 cohort provided baseline
and performance data in 2008, though some sites expelienced significant delays
in beginning implementation of interventions while they finalized partnership
agreements, completed a project logic model, and developed an evaluation plan .
Final data for 2008 (both baseline and year one data), as well as data for 2009
have been received and are being aggregated. Resutts for 2008 and 2009 will
be reported in the 2010 report.

The FY 2008 cohort recently reported baseline and year one performance data.
That data is being reviewed as part of the aggregation process. Results will be
reported in the 2010 report.




                                        6

FY 201 0 Performance Targets. We have not established targets for this
measure for any cohort, pending aggregation of fi nal 2008 and 2009 data for the
FY 2007 cohort. We plan to establish targets for the 2007 and 2008 cohorts in
2010. At that time we'll review data received to date from these cohorts, as well
as the resuHs from similar measures in other OSDFS programs and information
from the research literature about program effect size" in order to establish
targets.

Methodology. Data are collected by grantees, generally using student surveys.
Data are furnished in the second of two semi-annual performance reports
provided by grantees each project year.

The contractor for the SS/HS national evaluation is also using data for this
measure as part of the national program evaluation. The evaluation contractor
reviews data submitted by grantees, and works with grantees to seek clarifying
information and provide technical assistance if grantees are having difficulty in
collecting or reporting data for this measure. The contractor supplies data for the
measure after it has completed data cleaning processes. If data for this measure
are not available at the time that performance reports are submitted, staff follow
up with sites to attem pt to obtain data for the measure.

Grantees that fail to provide data or that provide data that does not respond to
the established measure are not included in the tabulation of data for the
measures.    Authorized representatives for the grant site sign the annual
performance report and, in doing so, certify that to the best of the signer's
knowledge and belief, all data in the performance report are true and co rrect and
that the report fully discloses all known weaknesses concerning the accuracy,
reliability, and completeness of the data included. Generally, the Department
relies on the certification concerning data supplied by grantees and does not
conduct further reviews.

We have delayed in establishing targets for this measure until we have final
baseline and performance data from at least one cohort.

                              Student Drug Testing

Measure 4: The percentage of student drug testing grantees that experience a 5
percent reduction in current (30-day) illegal drug use by students in the target
population. (Student Drug Testing - FY 2005,2006,2007, and 2008 cohorts)

Table 4

Cohort       FY       FY      FY2007       FY 2008        FY        FY         FY
           2005     2006      Actual        Actual      2009       2009       2010
          Actual   Actual                              Target     Actual     TarQet
2005      nla      nla        no valid   no valid      nla       nla         nla

                                         7

                              data        data
                              available   available
2006      nla       nla       nfa         66 ,67        70        12,5      70
2007      nla       nfa       nfa         established   50        41.7      60
                                          baseline
2006      nla       nfa       nfa         nfa           33       48.8       50

The measure. This measure is one of two measures for the Student Drug­
Testing Programs grant competrtion. The competrtion provides discretionary
grants to LEAs, community-based organizations, or other public and private
entrties to support implementation of drug testing of students, consistent with the
parameters established by the U.S. Supreme Court or for students and their
families that voluntarily agree to participate in the student drug testing program.

This measure Is directly related to the National Drug Control Strategy's goal
related to preventing drug use before rt starts. Student drug testing was been
prominently featured in the 2009 version of the strategy as a recommended drug
prevention intervention.

FY 2009 Performance Resurts. FY 2009 performance data for the FY 2006,
2007, and 2008 cohorts are included in the chart for this measure above.

During FY 2008 we comp leted a review of data submitted to date by the FY 2005
cohort for this measure and identified significant concems about the quality and
comparability of the data. Grant srtes have reported on prevalence rates for a
variety of illegal drugs and did not always provide data from the same
items/elements across project years one and two. Also, some sites surveyed
their entire student population and others surveyed only students in the testing
pool.

Based on these concerns, we obtained assistance from the U.S. Department of
Education's Data Quality Inrtiative contractor. With the contractor's help, we
created and disseminated detailed data collection and reporting guidance for the
program, as well as data standards that we will use to determine what constITutes
valid data for this measure. We disseminated this guidance to FY 2007
grantees during project implementation, but were able to provide the guidance to
the new cohort of 2008 grantees at the start of their projects. Based on that
gUidance, as well as data quality and aggregation checks, in FY 2009 we
aggregated available data from the FY 2007 and 2008 cohorts and recorded
those data In the Department's soflware that houses GPRA measures and data.

Data for the FY 2006 cohort come from the evaluation being conducted for the
Department of Education by a contractor. Data for this cohort were collected by
the contractor annually; the data reported in the chart above reflects the progress
of cohort grant srtes based on aggregate information at the grantee level about
changes in prevalence of drug use among each grantee's students surveyed by

                                          8

the contractor. Based on the performance data for this measure for the FY 2006
cohort collected and reported in FY 2008, we revised the established 2009 target
(60 percent) to 70 percent of grant sttes

Because of the concerns about data quality discussed previously. including
receiving valid data from only a small percentage of grantees in the cohort, no
aggregate data for the FY 2005 can be provided.

It is difficuij to assess why performance results for the 2006 and 2007 cohorts fell
short of the established targets for this measure. We have carefully considered
performance reports submitted by grantees, as well as our experience in
mondoring and providing technical assistance to grantees, and have identified
some challenges that may have impeded grant performance. Some common
problems include turnover in leadership (at the school board, authorized
representative or project director level) and challenges with collecting and
reporting valid data about the measure. Another variable that might affect
perfonnance in sites is related to project design. For example, we're not certain
how to assess the likely impact of a random student drug testing intervention on
students that vol unteer to be included in the testing pool, versus students who
are forced to be tested as a condition of participation in extracurricular activities.
Finally, cohort size and composition varies from cohort to cohort. In some years
funding for a large amount of new awards is available and in others only a
handful of sites will receive grants. To the extent that our peer review results that
are used to rank order applications and select grantees accurately predict project
qualrty, the range of scores funded (and perinaps the range of project quality)
varies from fiscal year to fiscal year.

We believe that an equally important dimension in assessing performance
against established targets for this measure is our abilrty to correctly predict
targets for measures. Because there is limited avaiiabJe research and no
"industry" standard available to guide expectations for performance, generally
we have used the performance of prior cohorts on the measure to establish
targets for subsequent cohorts. Because of the need to establish targets for
Mure cohorts before a single cohort has completed project implementation and
submitted final data, we have based targets on Information provided over a fairly
limited amount of time, often reflecting the results of less than a single cohort of
oomplete performance information . Indial cha llenges with data quality also
resutted in situations where only a limited number of grantees in a cohort were
able to provide valid performance data. This situation introduced two possible
problems into the target setting process - that targets are baing based in some
part on a subset of grantees that are not representative of the cohort as a whole,
and that those sites able to provide valid data more quickly may also have
superior capacity to effectively implement program interventions. While we have
placed a Significant emphasis on improving data quality and have worked to
improve the response rates for measures over the life of the cohort, this causes
performance resuijs from a relatively small set of grantees in year one to be


                                          9

compared to results for a significa ntly larger percentage of the cohort by the end
of project.

Increasi ngly, it is clear that a series of variables serve to make each cohort
unique, and that the issue of how we have established targets for this measure
has been problematic. Revised processes for establishing targets for this
measure are discussed in the FY 2010 Performance Targets section below.

FY 2010 Performance Ta rgets. We established targets for the percentage of
grantees experiencing a 5 percent reduction in current illegal drug use after
reviewing the first two years of data for the FY 2003 cohort of grant sftes.
Consistent with research that suggests that changes in student behavior related
to student drug testing may not be realized immediately, we assumed that we
could look for an increased number of grantees to experience positive change
and, using our professional judgment, set that target at 50 percent of grantees.
We have since received data for three projec1 years from this single cohort of
sftes (the FY 2003 cohort). and the information provided by the grantees does
not provide an adequate basis for revisiting targets for future cohorts. Th is
cohort was very small (eight grantees), and also experienced extensive delays in
implementation and data co llec1ion activities. Because only a handful of
grantees were able to eventually provide data specific to the measure, we do not
believe that it would be appropriate to base expectations about the performance
of other cohorts on this limited infonnation.

Similar problems with data qualfty for the FY 2005 cohort of grant sites mean that
data from that cohort will not be helpful in determining if targets for the program
will need to be readjusted. Challenges with data qualfty have resulted in only a
very limfted proportion of grant sftes that provided approximately comparable
data. Conversely, because the data from the evaluation are being collected by a
contractor using comparabl e survey items and collection procedures (in contrast
to the varying procedures used by individual grant sites in the other cohorts).
data for the 2006 cohort similarly do not provide an appropriate basis for making
adjustments in existing targets under the program. Performance for the FY 2006
cohort declined significantly from the FY 2008 level. but the reasons for the
decrease are not clear. As a result, we have retained the established targets for
this measure at this time.

Given these cha llenges, and improvements we have made in data quality
(including generally requiring grantees to collect baseline data for their projects
before interventions are implemented), we intend to modify our process for
establishing targets. While prior cohort performance may provide some insights
about general patterns of performance that we can incorporate into our targeting
setting processes, for any future cohorts for th is program we will establish
numerical performance targets after baseline data is received for the new cohort
We will enter these targets into the Department's Visual Performance System
(VPS) as "administrative" targets (for example. baseline plus 5 percent), and then


                                        10 

convert the targets to numerical targets after baseline data is collected and
aggregated. We believe that this process revision will help us better match
targets to cohort performance.

Methodology Wnh the exception of the FY 2006 cohort, data are collected by
grantees using student surveys. Data are provided as part of the grantees'
annual perfonnance reports. Generally, grantees do not use the same survey
items to collect data for this measure but, rather, self-select survey items (often
from surveys already administered) in order to provide these data. Survey nems
may relate to different substances, but must collect information conceming
current use in order to be included in the data reported for this measure.
Beginning with the FY 2008 cohort, we asked grantees to provide data for current
(prior 30-<lay) use of marijuana. Grantees did not provide baseline data in their
applications, so we have to wait until grantees provide data both from project
year one and two in order to determine if they have experienced a decrease in
substance abuse. Beginning wnh the FY 2008 cohort, we instructed grantees to
collect baseline data for this measure before beginning implementation of their
student drug tesbng program.

The FY 2005 cohort of grant sites has provided data for FY 2006 and 2007, but
only a small percentage of grant sites provided valid data for the measure. Many
sites requested and received no-cost extensions for their projects, and data for
this measure is included in final reports due at the end of December 2009.
Significant data quality issues (including inconsistent use of survey items and
c1hanges in respondent populations) affect the majority of grant snes in the
cohort, resutting in no valid data for this oohort

Authorized representatives for the grant site sign the annual performance report
and, in doing so, certify that to the best of the signer's knowledge and belief, all
data in the performance report are true and correct and that the report fully
discloses all known weaknesses concerning the accuracy, reliabilify, and
completeness of the data included. Generally, the Department relies on the
certification concerning data supplied by grantees and does not conduct further
reviews.

Data for the FY 2006 cohort are being collected as part of an evaluation of
student drug testing. Data for the measures are being collected by the
evaluation contractor, using common survey items and co llection procedures.
Survey responses are analyzed by the contractor and data are provided to the
Department.

The antiCipated levels of decrease in substance abuse are consistent with the
national goals for the reduction of underage drug use included in the National
Drug Control Strategy in effect when SOT grants were awarded- five percent per
year. Targets were initially established following the report of baseline data for
grant sites from the FY 2003 cohort. As discussed above, we do not currently


                                         11 

have data of sufficient quality to support adjustment of targets for this program at
this time.

Measure 5: The percentage of student drug testing grantees that experience a 5
percent reduction in past-year illegal drug use by students in the target
population. (Student Drug Testing - FY 2005, 2006, 2007 and 2008 cohorts)

Table 5

Cohort      FY        FY      FY 2007        FY 2008      FY        FY         FY
           2005      2006      Actual         Actual     2009      2009      2010
          Actual    Actual                              Target    Actual    Taraet
2005      nfa       nfa       no valid      no va lid   nfa       nfa       nJa
                              data         data
                              a vailable   available
2006      nfa       nfa       nJa          55.5        60         12.5      60
2007      nfa       nJa       nfa          established 50         33.3      60
                                            baseline
2008      nfa       nJa       nJa           nJa         33        57.5      60

The measure. This measure is one of two measures for the Student Drug­
Testing Programs grant competition. The competition provides discretionary
grants to LEAs, community-based organizations, or other public and private
entities to support implementation of drug testing of students, consistent with the
parameters established by the U.S. Supreme Court or for students and their
families that voluntarily agree to participate in the student drug testing program.

This measure is directly related to the National Drug Control Strategy's goal
related to preventing drug use before it starts . Student drug testing was
prominently featured in annual edttions of the National Drug Control Strategy
between 2003 and 2009 as a recommended drug prevention intervention.

FY 2009 Perfonnance Resu ~s . FY 2009 perfonnance data for the FY 2006,
2007, and 2008 cohorts are included in the chart for this measure above.

During FY 2008 we completed a preliminary review of data submitted to date by
the FY 2005 cohort for this measure and identified significant concems about the
quality and comparability of the data. Grant sites have reported on prevalence
rates for a variety of illegal drugs and have not always provided data from the
same items/elements across project years one and two. Also, some sites
surveyed their entire student population and others surveyed only students in the
testing pool.

Based on these concerns, we obtained assistance from the U.S. Department of
Education's Data Qua l ~y Initiative contractor. With the contractor's help, we
created and disseminated detailed data collection and reporting guidance for the

                                           12 

program, as well as data standards that we will use to determine what constitutes
valid data for this measure. We disseminated this guidance to FY 2007 grantees
during project implementation, but were able to provide the guidance to the new
cohort of 2008 grantees at the start of their projects. Based on that guidance, as
well as data quality and aggregation checks, in FY 2009 we aggregated available
data from the FY 2007 and FY 2008 cohorts and recorded those data in the
Departmenfs scltware that houses GPRA measures and data.

Data for the FY 2006 cohort come from the evaluation being conducted for the
Department of Education by a contractor.. Data for this cohort were collected by
the contractor annually; the data reported in the chart above reflects the progress
of cohort grant sites based on aggregate information at the grantee level about
changes in prevalence of drug use among each grantee's students surveyed by
the contractor. An important note is that data supplied for the measure for the
2006 cohort represents student drug use in the six months prior to the survey
(rather than the one-year period called for in the measure.)

Because of the concerns about data quality discussed previously, including
receiving valid data from only a small percentage of grantees in the cohort, no
aggregate data for the FY 2005 can be provided.

It is difficuH to assess why performance results for the 2006 and 2007 cohorts fell
short of the established targets for this measure. We have carefully considered
performance reports submitted by grantees, as well as our experience in
monitoring and providing technical assistance to grantees, and have identified
some challenges that may have impeded grant performance. Some common
problems include turnover in leadership (at the school board, authorized
representative or project director level) and challenges with collecting and
reporting valid data about the measure. Another variable that might affect
performance in sites is related to project design. For example, we're not certain
how to assess the likely impact of a random student drug testing intervention on
students that volunteer to be included in the testing pool, versus students who
are forced to be tested as a condition of participation in extracurricular activities.
Finally, cohort size and compos~ion varies from cohort to cohort. In some years
funding for a large amount of new awards is available and in others only a
handful of s~es will receive grants. To the extent that our peer review resuHs that
are used to rank order applications and select grantees accurately predict project
quality, the range of scores funded (and perhaps the range of project quality)
varies from fiscal year to fiscal year.

We believe that an equally important dimension in assessing performance
against established targets for this measure is our ability to correctly predict
targets for measures. Because there is limited available research and no
Nindustry" standard available to guide expectations for performance, generally
we have used the performance of prior cohorts on the measure to establish
targets for subsequent cohorts. Because of the need to establish targets for


                                         13 

Mure cohorts before a single cohort has completed project implementation and
submitted final data, we have based targets on infonnation provided over a fairly
limited amount of time, often refiecting the results of less than a single cohort of
complete performance information. Initial challenges with data quality also
resulted in situations where only a limited number of grantees in a cohort were
able to provide valid performance data. This situation introduced two possible
problems into the target setting process - that targets are being based in some
part on a subset of grantees that are not representaUve of the cohort as a whole,
and that those sites able to provide valid data more quickly may also have
superior capacity to effectively implement program interventions. Whi le we have
placed a Significant emphasis on improving data quality and have worked to
improve the response rates for measures over the life of the cohort, this causes
performance results from a relatively small set of grantees in year one to be
compared to results for a significantly larger percentage of the cohort by the end
of project.

Increasingly. it is clear that a series of variables serve to make each cohort
unique, and that the issue of how we have established targets for this measure
has been problematic. Revised processes for establishing targets for this
measure are discussed in the FY 2010 Performance Targets section below.

FY 2010 Performance Targets. We established targets for the percentage of
grantees experiencing a 5 percent reduction in annual illegal drug use after
reviewing the first two years of data for the FY 2003 cohort of grant sites.
Consistent with research that suggests that changes in student behavior related
to student drug testing may not be realized immediately, we assumed that we
could look for an increased number of grantees to experience positive change
and, using our professional judgment, set that target at 50 percent of grantees.
We have since received data for three project years from this single cohort of
sites (the FY 2003 cohort), and the information provided by the grantees does
not provide an adequate basis for revisiting targets for future cohorts. This
cohort was very small (eight grantees), and also experienced extensive delays in
implementation and data collection activities. Because only a handful of
grantees were able to eventually provide data specific to the measure, we do not
believe that H would be appropriate to base expectations about the performance
of other cohorts on this limited information.

Similar problems with data quality for the FY 2005 cohort of grant sites mean that
data from that cohort will not be helpful in determining if targets for the program
wi ll need to be readjusted. Challenges wHh data quality have resulted in only a
very limHed proportion of grant sites that provided approximately comparable
data. Conversely, because the data from the evaluation are being collected by
the contractor using comparable survey Hems and collection procedures (in
contrast to the va rying procedures used by individual grant sites in the other
cohorts), data for the 2006 cohort similarly do not provide an appropriate basis
for making adjustments in existing targets under the program for the FY 2007

                                         14 

cohort. As a result, we have retained the established targets for this measure at
this time.

Given these challenges, and improvements we have made in data quality
(including generally requiring grantees to collect baseline data for their projects
before interventions are implemented), we intend to modify our process for
establishing targets. While prior cohort performance may provide some insights
about general patterns of perfonmance that we can incorporate into our targeting
setting processes, for any future cohorts for this program we will establish
numerical performance targets after baseline data is received for the new cohort.
We will enter these targets into the Department's Visual Perfonmance System
(VPS) as "administrative" targets (for example, baseline plus 5 percent), and then
convert the targets to numerical targets after baseline data is collected and
aggregated. We believe that this process revision will help us better match
targets to cohort perfonmance.

Methodology With the exception of the FY 2006 cohort, data are collected by
grantees using student surveys. Data are provided as part of the grantees'
annual perfonmance reports. Generally, grantees do not use the same survey
items to collect data for this measure but, rather, se~"sel ect survey items (often
from surveys already administered) in order to provide these data. Survey items
may relate to different substances, but must collect infonmation concerning
annual use in order to be included in the data reported for this measure.
Beginning with the FY 2008 cohort, we asked grantees to provide data for annual
(prior year) use of marijuana. Grantees did not provide baseline data in their
applications, so we have to wait until grantees provide data both from project
year one and two in order to determine if they have experienced a decrease in
substance abuse. Beginning with the FY 2008 cohort, we instructed grantees to
collect baseline data for this measure before beginning implementation of their
student drug testing program.

The FY 2005 cohort of grant sites has provided data for FY 2006 and 2007, but
only a small percentage of grant sites provided valid data for the measure. Many
sites requested and received no·cost extensions for their projects, and data for
this measure is included in final reports due at the end of December 2009.
Significant data quality issues (including inconsistent use of survey items and
changes in respondent populations) affect the majority of grant sites in the
cohort, resulting in no valid data for this cohort.

Authorized representatives for the grant site sign the annual performance report
and, in doing so, certify that to the best of the signers knowledge and belief, all
data in the perfonmance report are true and correct and that the report fully
discloses all known weaknesses concerning the accuracy, reliability, and
completeness of the data included. Generally, the Department relies on the
certification concerning data supplied by grantees and does not conduct further
reviews.


                                         15 

Data for the FY 2006 cohort are being collected as part of an evaluation of
student drug testing. Data for the measures are being collected by the
evaluation contractor, using common survey items and collection procedures.
Survey responses are analyzed by the contractor and data are provided to the
Department.

The anticipated levels of decrease in substance abuse are consistent with the
national goals for the reduction of underage drug use included in the National
Drug Control Strategy in effect when SDT grants were awarded - five percent
per year. Targets were initially established following the report of baseline data
for grant s~es from the FY 2003 cohort. As discussed above, we do not currently
have data of sufficient quality to support adjustment of targets for this program at
this time.

          Safe and Drug-Free Schools and Communities State Grants

Measure 6: The percentage of students in grades 9-12 who were offered , sold,
or given an illegal drug on school property during the past 12 months. (Safe and
Drug-Free Schools and Communities State Grants)

Table 6

 FY2005     FY2006       FY 2007     FY2008       FY 2009    FY 2009      FY 2010
 Actual      Actual       Actual      Actual       Target     Actual       Target
25.4        None        22.3         None        26          Pending      None

The measure. This measure is one of three measures directly related to
reducing student drug or alcohol use for the Safe and Drug-Free Schools and
CommunHies (SDFSC) State Grants. This formula grant program provides funds
to the States, based on school-aged population and the State's relative share of
Elementary and Secondary Education Act THle I concentration grant funds, to
support drug and violence prevention programs. The measure directly relates to
the National Drug Control Strategy Goal of preventing youth drug use by focusing
on the extent to which illegal drugs are available on school property.

FY 2009 Performance Results. Data for this measure were collected in 2009, but
will not be released by the Centers for Disease Control and Prevention until
summer 2010.

FY 2010 Performance Targets. No target is established for this measure for FY
2010 because data is collected only every other year, in odd-numbered years.
The target identified for this measure in FY 2009 was 26 percent. Although the
FY 2007 results exceeded the established FY 2009 target, we did not go through
the process to revise the 2009 target because the SDFSC State Grants program



                                        16 

was terminated in FY 2010. We will provide FY 2009 data in the FY 2010
perionnance summary report. but will end reporting for the measure at that time.

Methodology. Data for this measure are collected from a nationally
representative sample of students in grades 9-12 as part of the Youth Risk
Behavior Surveillance System (YRBSS), sponsored by the Centers for Disease
Control and Prevention (CDC). Data are collected in odd years and reported in
the following even years. No data are collected for even years and, as a resuH,
no targets have been established for even years.

Detailed information about the methodology used to sample and report data for
the YRBSS is available at the CDC website at:
httpJ/www.cdc.gov/mmwr/preview/mmwrhtml/ss5505al.htm. We rely on the
assertions provided about methodology presented by CDC in using this data to
report on performance of SDFSC State Grants.

Measure 7: The percentage of students in grades 9-12 who used marijuana one
or more times during the past 30 days. (SDFSC State Grants)

Table 7

 FY 2005   FY2006       FY 2007     FY 2008     FY2009     FY2009      FY 2010
  Actual    Actual       Actual      Actual     Target      A ctual     Tar get
20.2       None        19.7        None        18          PendinQ     None

The measure. This measure is one of three measures directly related to
reducing student drug and alcohol use for SDFSC State Grants. This formula
grant program provides funds to the States, based on school-aged population
and the State's relative share of Elementary and Secondary Education Act Title I
concentration grant funds, to support drug and violence prevention programs.
The measure is directly related to the National Drug Control Strategy Goal of
preventing youth drug use by focusing on the extent of current use by high
school aged-youth of the most prevalent illegal drug.

FY 2009 Performance Resuns. Data for this measure were co llected in 2009, but
wi ll not be released by the Centers for Disease Control and Prevention until
summer 201 O.

FY 2010 Periormance Targets. No target is established for th is measure for FY
2010 because data is collected only every other year, in odd-numbered years.
The target for this measure in FY 2009 is 18. Given the limited progress made
toward achieving the established target level in FY 2007, we have not revised
this target. Because the SDFSC State Grants was program was terminated in
FY 2010, we will provide FY 2009 data in the FY 2010 performance summary
report. but will end reporting for the measure at that time.



                                       17 

Methodology. Data for this measure are collected from a nationally
representative sample of students in grades 9-12 as part of the Youth Risk
Behavior Surveillance System (YRBSS), sponsored by the Centers for Disease
Control and Prevention (CDC). Data are collected in odd years and reported in
the following even years. No data are collected for even years and. as a result,
no targets have been established for even years.

Detailed information about the methodology used to sample and report data for
the YRBSS is available at the CDC website at:
http://www.cdc.gov/mmwr/preview/mmwrhtmVss5505a1.htm. We rely on the
assertions provided about the methodology presented by CDC in using this data
to report on performance of SDFSC State Grants.

Measure 8: The percentage of students in grades 9-12 who had five or more
drinks of alcohol in a row one or more times during the past 30 days. (SDFSC
State Grants)

Table 8

 FY2005     FY 2006      FY 2007     FY 2008    FY 2009      FY 2009     FY2010
 Actual      Ac tual      Ac tual     Actual     Tanlet       Actual      Taraet
25.5        None        26          None        25           Pendina     None

The measure. This measure is one of three measures related to reducing
student drug or alcohol use for SDFSC Grants. This formula grant program
provides funds to the States, based on schoo~aged population and the State's
relative share of Elementary and Secondary Education Act Title I concentration
grant funds, to support drug and violence prevention programs. The measure is
directly related to the National Drug Control Strategy Goal of preventing youth
drug use by focusing on the prevalence of binge drinking by high school aged­
students. While alcohol is not explicitly an emphasis of the National Drug Control
Strategy, illegal use of alcohol can be associated with use of other illegal drugs.

FY 2009 Performance Results. Data for this measure were collected in 2009, but
will not be released by the Centers for Disease Control and Prevention until
summer 201 O.

FY 2010 Performance Targets. No target is established for this measure for FY
2010 because data is collected only every other year, in odd-numbered years.
The target for this measure for FY 2009 is 25. Given that there was no change in
the data for this measure between 2005 and 2007, we did not revise the target
for FY 2009. Because the SDFSC State Grants program was terminated in FY
2010, we will provide FY 2009 data in the FY 2010 performance summary report,
but will end reporting for the measure at that time.




                                        18 

Methodology. Data for this measure are collected from a nationally
representative sample of students in grades 9-12 as part of the Youth Risk
Behavior Surveillance System (YRBSS). sponsored by the Centers for Disease
Control and Prevention (CDC). Data are collected in odd years and reportee in
the following even years. No data are collected for even years and as a result no
targets have been established for even years.

Detailee information about the methodology used to sample and report data for
the YRBSS is available at the CDC website at:
http://www.cdc.gov/mmwr/preview/mmwrhtmVss5505a1.htm. We rely on the
assertions provided about the methodology presentee by CDC in using this data
to report on performance of SDFSC State Grants.

Measure 9: The percentage of drug and violence prevention programs/practices
supportee with SDFSC State Grant funds that are research based. (SDFSC
State Grants)

Table 9

 FY2005      FY 2006    FY2007       FY2008      FY 2009    FY 2009       FY 2010
  Actual      Actual     Actual       Actual      Target     Actual        Target
7.8         None        None         None        13      l oendina       None

The measure. This measure examines the extent to which programs and
practices supportee with SDFSC State Grant funds are basee on research. The
measure supports attainment of National Drug Control Strategy goals by focusing
on the quality of programs supported with SDFSC State Grants funds and the
likelihood that the programs will recuce or prevent youth drug use. The 2005
data constitute the baseline for this measure.

FY 2009 Performance Results. A contract to collect data to implement this
measure could not be issued in time to permit data collection during FY 2008 as
originally scheduled . As a result. we established a 2009 target against the 2005
baseline that is a linear extrapolation of a previously established FY 2008 target
for this measure. Data collection for the measure began under the contract. but
was cancellee based on the enaclee appropriations statute for FY 2010 that did
not provide funding for the State Grants program. No additional data will be
available for this measure.

FY 2010 Performance Targets. Data for this measure were scheeuled to be
collected only every three years. As a result. no target was established for this
measure for FY 2010. We do not intend to establish Mure targets given the
termination of this program in FY 2010.

Methodology. Baseline data for this measure were collected from a nationally
representative sample of schools under a contract supported by ED. As a first

                                        19 

step, the contractor developed a large list of research-based programs and then
screened those programs to identify programs that were relevant to the SDFSC
State Grants program; had at least two empirical studies completed that met
stringent methodological standards; had implementation materials available;
used at least two independent samples in program evaluations; and
demonstrated an adequate level of program effectiveness.

The contractor collected data for the measure using surveys of national
probability samples of public elementary and secondary schools and the school
districts with which they were associated. The surveys - conducted using both
mail and web-based approaches - gathered information on prevention programs
operating during the 2004-2005 school year. Survey information was collected
between fall 2005 and spring 2006.

The sample design included 2,500 districts, and nearly 6 ,000 schools that were
sampled from the 2,500 districts. The contractor used the National Assessment
of Educational Progress (NAEP) national sample frame. The NAEP sample
frame is derived from the 2003-2004 National Center for Education Statistics
Common Core of Data (CCD) Public Elementary and Secondary School
Universe and Agency files . Using the NAEP sample frame allowed the
contractor to take advantage of ed~s already made to the CCD files (for example
eliminating administrative school districts from the sample frame).

Survey instruments used included 89 prevention programs; respondents were
also able to write in any programs omitted from those listed. The contractor
received responses from 91 percent of the districts included in the sample and 86
percent of schools.

The study conducted by the contractor to obtain data for this measure has some
limitations that are the result of both the research synthesis and survey data
collections. Despite significant efforts to be comprehensive, it is possible that the
literature searches used may not have identified some published studies on
prevention programs and, as a result, the number of research-based program
may be understated.

Some other study lim~ation s pertain to the quality of data collected via the
surveys. Recall problems and responses from less knowledgeable respondents
in some schools and districts (particularly among schools and districts that
provided information late in the collection period) may have affected the quality of
data. Schools may have a lso over-reported the prevention programs operating
in their schools if respondents confused the specific named program in the
sUivey with other similarly named but different programs.

Measure 10: The percentage of drug and violence prevention curriculum
programs that are implemented with fidelity. (SDFSC State Grants)



                                         20 

Table 10

FY2005      FY 2006     FY2007      FY2008       FY 2009       FY 2009   FY2010
Actual       Actual      Actual      Actual       Target        Actual    Target
44.3        None        None        None         53.1       I pendinQ    None

The measure. This measure examines the extent to which research-based
currculum programs supported with SDFSC State Grant funds are implemented
with fidelity. The measure supports attainment of National Drug Control Strategy
goals by focusing on the quality of implementation of the research-based
programs and practices supported with SDFSC State Grants funds, and the
corresponding likelihood that the programs will reduce or prevent youth drug use.
The 2005 data constitute the baseline for this measure.

FY 2009 Performance Results. A contract to collect data to implement this
measure could not be issued in time to permit data collection during FY 2008 as
originally scheduled. As a resutt, we established a 2009 target against the 2005
baseline that is a linear extrapolation of a previously established FY 2008 target
for this measure. Data collection for the measure began under the contract, but
was cancelled based on the enacted appropriations statute for FY 201 0 that did
not provide funding for the State Grants program. No add~ional data will be
available for this measure.

FY 201 0 Performance Targets. Data for this measure were scheduled to be
collected only every three years. As a resutt, no target was established for this
measure for FY 2010. We do not intend to establish a target given the
termination of this program in FY 201 0.

Methodology. Baseline data for this measure were collected from a nationally
representative sample of schools under a contract supported by ED. Data were
collected In the fall of 2006, and refiected information about programs and
practices Implemented during the 2004-2005 school year. The contractor
developed a list of research-based programs and compared information about
programs and practices being implemented with SDFSC State Grants funds with
the list of research-based program and practices. (See discussion for Measure
9)

The contractor then followed up with a subset of respondents to examine the
extent to which research-based programs and practices were implemented in a
manner consistent with implementation keys for individual programs (as
determined by program developers). The contractor focused ~s review on the 10
programs (from the list of 21 research-based programs) that were implemented
most frequently by respondents in the initial phase of the study.

The contractor mailed copies of questionnaires to principals and program
implementers to each school that reported operating at least one research-based

                                        21 

program in the response to the earlier survey. The response rate for the
questionnaire supplied to program Implementers was 78 percent; the response
rate for questionnaires completed by principals was 70 percent.

The study developed program-specific measures of quality implementabon for
each of the research-based programs identified by the study. The standards
were based on program developer's specifications for individual programs.
Aspects of implementation considered included issues such as frequency of
student participation; number of lessons delivered; and topics covered. Based
on applying these quality standards to data supplied on the two questionnaires,
the contractor identified the percentage of research-based programs that were
implemented according to the standards identified by the program developer
(which the study refers to as being implemented with "fidelity").

This aspect of the study has some limitations related to the application of the
program-specific standards used for assessing the quality of program
implementation to responses provided from respondents concerning their
program implementation. Valid measurement of quality of implementation
required that a program developer's program specifications be applied to
implementer reports on that specific program. In some cases, responses raised
questions about whether respondents were reporting on the correct program.
Study staff worked to confirm that implementers were reporting on the correct
program; in cases where the implementer reported on the wrong program, that
report was considered invalid and not included in the final data. If responses
suggested that the program implementer reported on the wrong program and
confirmation could not be made, those cases were also excluded from analyses.

Similar problems occurred for programs that had multiple components or different
versions that are implemented for different ages or grade levels. Study staff
reviewed program materials for different components or versions and worked to
identify the program standards most closely related to the various components or
versions. If a meaningful standard for a component or measure could be
developed, the case was included in the analyses; if not, the program was
omitted.

limitations related to data quality from questionnaires also exist. Because a
substantial number of cases were ineligible for inclusion in the study analyses for
the reasons described above, the number of valid cases was reduced, leading in
tum to decreased precision in estimates and larger than expected standard
errors and confidence intervals. Similar recall problems caused by the gap
between program implementation and data oollection (as discussed for the
previous measure) may have also impacted data quality. Finally, the quality of
reports va ried by the extent to which respondents were in a position to observe
acrual implementation and intentionally bias reports. Program implementers may
have difficuHy in providing objective information about programs they are



                                        22 

responsible for establishing. However, previous research using similar measures
suggests that this "social desirability" bias is likely to be low.

                            Grants to Reduce Alcohol Abuse

Measure 11: The percentage of grantees whose target students show a
measurable decrease in binge drinking. (Grants to Reduce Alcohol Abuse
Program - FY 2005,2007, and 2008 cohorts - no new grants were awarded
under this program in FY 2006.)

Table 11

Cohort     FY         FY          FY          FY         FY       FY        FY
           2005       2006        2007         2008      2009    2009       2010
           Actu al    Actual      Actual       Actual    Tamet   Actua l    TarQet
2005       nJ.        nJa         65         I pending   nJ.     nJa        nJa
2007       nJa        nJa         nJa          61 .5     76.87   47         49.4
2008       nJa        nJa         nla         nJa        61 .5   50.7       53.2

The measure. This measure examines a key outcome for the Grants to Reduce
Alcohol Abuse (GRAA) program - reduction in binge drinking for the target
population. While the National Drug Control Strategy is focused most intensively
on preventing the use of controlled substances, the strategy does address the
role of alcohol as a drug of choice for teenagers. Research suggests that early
use of alcohol is more likely to resuH in heavy later use of alcohol.

FY 2009 Performance ResuHs.         Grantees from the FY 2005 cohort are currently
operating in no-cost extensions; generally, their final reports are due at the end of
2009. Data will be aggregated and available in March 2010.

We used data from the 2008 reports from prior cohorts to establish the FY 2009
target for the FY 2007 cohort. However, it tumed out that the FY 2007 cohort
performed worse in 2009 than in 2008 and fell significantly short of the
established performance target for 2009. The FY 2008 cohort also
underperformed in its first year (2009) if compared to the year one resuHs from
the prior cohort. As we receive data from across cohorts for this measure, we
are finding it difficult to discern a pattern of performance that can serve as a
basis for establishing Mure targets. 

It is difficult to assess why performance results for the 2007 and 2008 cohorts fell 

short of the established targets for this measure. We have carefully conSidered 

performance reports submitted by grantees, as well as our experience in 

mon;toring and providing technical assistance to grantees, and have identified 

some challenges that may have impeded grant performance. Some common 

problems include turnover in leadership (at the authorized representative or 

project director level) and challenges with collecting and reporting valid data 

about tl1e measure. Another variable that might affect performance in sites is 


                                           23 

related to project design. For example, we're not certain how to assess the likely
impact of a site that is implementing a single research-based program versus
sites that have adopted a more comprehensive strategy that Includes a
community-based intervention that complements school-based curricula. Finally,
cohort size and composition varies from cohort to cohort In some years funding
for a large amount of new awards is available and in others only a handful of
sites will receive grants. To the extent that our peer review results that are used
to rank order applications and select grantees accurately predict project quality,
the range of scores funded (and perhaps the range of project quality) varies from
fiscal year to fiscal year.

We believe that an equally important dimension in assessing performance
against established targets for this measure is our ability to correctly predict
targets for measures. Because there is limited available research and no
·industrY standard available to guide expectations for performance, generally
we have used the performance of prior cohorts on the measure to establish
targets for subsequent cohorts. Because of the need to establish targets for
future cohorts before a single cohort has completed project implementation and
submitted final data. we have based targets on information provided over a fairly
limited amount of time, often reflecting the results of less than a single cohort of
complete performance information. Initial challenges with data quality also
resuHed in situations where only a limited number of grantees in a cohort were
able to provide valid performance data. This situation introduced two possible
problems into the target setting process - that targets are being based in some
part on a subset of grantees that are not representative of the cohort as a whole,
and that those sites able to provide valid data more quickly may also have
superior capacity to effectively implement program interventions. While we have
placed a significant emphasis on improving data quality and have worked to
improve the response rates for measures over the life of the cohort, this causes
performance results from a relatively small set of grantees in year one to be
compared to results for a Significantly larger percentage of the cohort by the end
of project.

Increasingly, it is clear that a series of variables serve to make each cohort
unique, and that the issue of how we have established targets for this measure
has been problematic. Revised processes for establishing targets for this
measure are discussed in the FY 2010 Performance Targets section below.

FY 2010 Performance Targets. We established an FY 2009 target for the FY
2007 cohort based on the performance of prior cohorts in 2009. This cohort
achieved performance levels after one year that were close to those met after
two years by a prior cohort, but experienced a significant decline in FY 2009.
Based on lower than anticipated levels of performance for this measure, we
revised the FY 2010 targets for both the FY 2007 and FY 2008 cohorts for this
measure. The 2010 target for the FY 2007 cohort was reduced from 80 percent
to 49.4 percent (or a target level that represents a 5 percent increase of the FY


                                         24 

2009 actual data for this measure)., The 2010 target for the FY 2008 cohort was
reduced from 76.87 percent to 53.2 percent (or a target level that represents a 5
percent increase of the FY 2009 actual data for this measure).

Given these challenges. and improvements we have made in data quality
(including generally requiring grantees to cellect baseline data for their projects
before interventions are implemented). we intend to modify our process for
establishing targets. While prior cohort performance may provide some insights
abcut general patterns of performance that we can incerporate into our targeting
setting processes, for any Mure cehorts for this program we will establish
numerical performance targets after baseline data is received for the new cohort.
We will enter these targets into the Department's Visual Performance System
(VPS) as "administrative" targets (for example, baseline plus 5 percent), and then
cenvert the targets to numerical targets after baseline data is ce llected and
aggregated. We believe that this process revision will help us better match
targets to cohort performance.


Methodology. Data for this measure are cellected by grantees and reported as
part of annual performance reports. If data for this measure are not available at
the time that performance reports are submitted, staff follow up with sites to
attempt to obtain data for the measure. Grantees that fail to provide data are not
included in the tabu lation of data for the measures. Also, grantees that did not
provide data for two censecutive project years (so that we could determine if a
decrease in binge drinking had occurred) are not included in the aggregate data
reported for the measure. Authorized representatives for the grant site sign the
annual performance report and, in doing so, certify that to the best of the Signer's
knowledge and belief, all data in the performance report are true and cerrect and
that the report fully discloses all known weaknesses cencerning the accuracy,
reliability, and cempleteness of the data included. Generally, the Department
relies on the certrfication conceming data supplied by grantees and does not
conduct further reviews.

ED does not mandate data collection protocols or instruments for grantees.
Grantees select a survey item that reflects the concept of binge drinking, and
cellect and report data abcut that survey item as part of their performance
reports. As a resun. data are not comparable across grant sites, but individual
grant sites are required to use the same survey items across performance
periods. We consider sites that have experienced a decrease in the rate of binge
drinking of one percent or greater to have achieved a measurable decrease in
binge drinking.

Initially, applicants were not required to furnish baseline data as part. of their
applications. Data supplied after year one were considered baseline data for the
projects. Projects required two years of data in order to determine if a decrease
in binge drinking among target students has occurred.


                                        25
We have provided significantly increased guidance and technical assistance to
grantees beginning with the FY 2007 cohort, and believe that these efforts have
produced data that are of higher quality and more comparable across s~es than
those of previous cohorts. These cohorts we re instructed to provide baseline
data in their application, or if that data was not available, to collect ~ before
beginning project implementation.

Measure 12: The percentage of grantees that show a measurable increase in
the percentage of target students who believe that alcohol abuse is hamnful to
their health. (Grants to Reduce Alcohol Abuse - FY 2005, 2007, and 2008
cohorts - no new grants were awarded under this program in FY 2006.)

Table 12

Cohort     FY        FY         FY           FY        FY        FY         FY
           2005      2006       2007         2008      2009      2009       2010
           Actual    Actual     Actu al      Actual    Target    Actual     Target
2005       nla       nla        70           pending   nla       nla        nla
2007       nla       nla        nla          69.2      86.5      76.5       80.3
2008       nla       nla        nla          nla       69.2      58. 6      6 1.5

The measure . This measure examines a key outcome for the Grants to Reduce
Alcohol Abuse (GRAA) program - perception of hea ~h risk for alcohol abuse
among target students. While the National Drug Control Strategy is focused
most intensively on preventing the use of controlled substances, the Strategy
does address the ro le of alcohol use as a drug of choice for teenagers. Data do
suggest that changes in perceptions about risks to health resu ~i ng from alcohol
use are positively correlated with reductions in alcohol use.

FY 2009 Perfomnance Results. Grantees from the FY 2005 cohort are currently
operating in no-cost extensions; generally, their final reports are due at the end of
2009. Data will be aggregated and avaitable in March 2010.

We used data from the 2008 reports to establish the FY 2009 target for the FY
2007 cohort. However, ~ turned out that the FY 2007 cohort perfomned worse in
2009 than in 2008 and fell short of the established perfomnance target for 2009.
The FY 2008 cohort also underperfomned in its first year (2009) if compared to
the year one results from the prior cohort. As we rece ive data from across
cohorts for this measure, we are finding it difficult to discern a pattem of
perfomnance that can serve as a basis for establishing future targets.

It is difficu~ to assess why perfomnance results for the 2007 and 2008 cohorts fell
short of the established targets for this measure. We have carefully considered
perfonnance reports submitted by grantees, as well as our experience in
monitoring and providing technical assistance to grantees, and have identified

                                          26 

some challenges that may have impeded grant performance. Some common
problems include turnover in leadership (at the authorized representative or
project director level) and challenges with collecting and reporting valid data
about the measure. Another variable that might affect performance in sites is
related to project design. For example, we're not certain how to assess the likely
impact of a site that is implementing a single research-based program versus
sites that have adopted a more comprehensive strategy that includes a
community-based intervention that complements school-based curricula. Finally,
cohort size and composition varies from cohort to cohort. In some years funding
for a large amount of new awards is available and in others only a handful of
sites will receive grants. To the extent that our peer review results that are used
to rank order applications and select grantees accurately predict project quality,
the range of scores funded (and perhaps the range of project quality) va ries from
fiscal year to fiscal year.

We believe that an equally important dimension in assessing performance
against established targets for this measure is our ability to correctly predict
targets for measures. Because there is limited available research and no
Mindustry" standard available to guide expectations for performance, generally
we have used the performance of prior cohorts on the measure to establish
targets fo r subsequent cohorts. Because of the need to establish targets for
future cohorts before a single cohort has completed project implementation and
submitted final data, we have based targets on information provided over a fairly
limited amount of time, often refiecting the resuns of less than a single cohort of
complete performance information. Initial challenges with data quality also
resulted in situations where only a limited number of grantees in a cohort were
able to provide valid performance data. This situation introduced two possible
problems into the target setting process - that targets are being based in some
part on a subset of grantees that are not representative of the cohort as a whole,
and that those sites able to provide valid data more quickly may also have
superior capacity to effectively implement program interventions. While we have
placed a Significant emphasis on improving data quality and have worked to
improve the response rates for measures over the life of the cohort, this causes
performance results from a relatively small set of grantees in year one to be
compared to results for a significantly larger percentage of the cohort by the end
of project.

Increasingly, it is clear that a series of variables serve to make each cohort
unique, and th at the issue of how we have established targets for this measure
has been problematic. Revised processes for establishing targets for this
measure are discussed in the FY 2010 Performance Targets section below.


FY 2010 Performance Targets. We had established an FY 2009 target for the
FY 2007 cohort based on the performance of prior cohorts in 2008. However,
this cohort experienced a Significant decline in performance in FY 2009. Based


                                         27 

 on lower than anticipated levels of performance for this measure, we revised the
 FY 201 0 targets for both the FY 2007 and FY 2008 cohorts for this measure.
 The 2010 target for the FY 2007 cohort was reduced from 86.5 percent to 80.3
 percent (or a target level that represents a 5 percent increase of the FY 2009
 actual data for this measure). The 2010 targetforthe FY 2008 cohort was
 reduced from 86.5 percent to 61.5 percent (or a target level that represents a 5
 percent increase of the FY 2009 actual data for this measure)

Given these challenges, and improvements we have made in data quality
(including generally requiring grantees to collect baseline data for their projects
before interventions are implemented), we intend to modify our process for
establishing targets. While prior cohort performance may provide some insights
about general pattems of performance that we can incorporate into our targeting
setting processes, for any future cohorts for this program we will establish
numerical performance targets after baseline data is received for the new cohort.
We will enter these targets into the Department's Visual Performance System
(VPS) as "administrative" targets (for example, baseline plus 5 percent), and then
convert the targets to numerical targets after baseline data is collected and
aggregated. We believe that this process revision will help us better match
targets to cohort performance.


  Methodology. Data for this measure are collected by grantees and reported as
  part of annual performance reports. If data for this measure are not available at
  the time that performance reports are submitted, staff follow up with sites to
  attempt to obtain data for the measure. Grantees that fail to provide data are not
  included in the tabulation of data for the measures. Also, grantees that did not
  provide data for two consecutive project years (so that we could determine if an
  increase in the percentage of students who believe that alcohol abuse is harmful
  to their heatth had occurred) are not included in the aggregate data reported for
  the measure. Authorized representatives for the grant site sign the annual
  performance report and, in doing so, certify that to the best of the signer's
  knowledge and belief, all data in the performance report are true and correct and
  that the report fully discloses all known weaknesses concerning the accuracy,
  reliability, and completeness of the data included. Generally, the Department
. relies on the certification concerning data supplied by grantees and does not
  conduct further reviews.

ED does not mandate data collection protocols or instruments for grantees.
Grantees select a survey item that refiects the concept of perceived harm to
heallh, and collect and report data about that survey item as part of performance
reports. As a resutt, data are not comparable across grant sites, but individual
grant sites are required to use the same survey items across performance
periods, We consider sites that have experienced an increase in the percentage
of students reporting perceived risk of harm to health of one percent or greater to
have achieved a measurable increase for this measure.

                                         28 

Initially, applicants were not required to lumish baseline data as part 01 their
applications. Data supplied after year one were considered baseline data lor the
projects. Projects required two years of data in order to detennine if a decrease
in binge drinking among target students has occurred.

We have provided significantly increased guidance and technical assistance
beginning with the FY 2007 co hort, and believe that these efforts have produced
data that are 01 higher quality and more comparable across sites than those of
previous cohorts. These cohorts were instructed to provide baseline data in their
application, or if that data was not available, to collect n belore beginning project
implementation.


Measure 13: The percentage of grantees that show a measurable increase in
the percentage of target students who disapprove 01 alcohol abuse. (Grants to
Reduce Alcohol Abuse - FY 2005, 2007, and 2008 cohorts - no new grants were
awarded under this program in FY 2006.)

Table 13

Cohort     FY        FY         FY          FY        FY         FY         FY
           2005      2006       2007        2008      2009       2009       2010
           Ac tual   Actual     Actual      Actual    Target     Actual     Target
2005       n/a       n/a        71        I pending   nla        n/a        n/a
2007       nla       n/a        n/a         69.2      86,5       47         49.4
2008       nla       n/a        n/a         nla       69.2       49.3       51 .8

The measure. This measure examines a key outcome for the Grants to Reduce
Alcohol Abuse (GRAA) program - perception of heanh risk for alcohol abuse
among target students. While the National Drug Control Strategy is focused
most intensively on the preventing the use of controlled substances, the Strategy
does address the role of alcohol use as a drug of choice for teenagers. Data do
suggest that increases in the percentage of target students who believe that
alcohol abuse is not socially acceptable are associated wnh declines in
consumption of alcohol.

FY 2009 Performance Results. Grantees from the FY 2005 cohort are currently
operating in no-cost extensions; generally, their final reports are be due at the
end of 2009. Data will be aggregated and available in March 2010.

We used data from the 2008 reports to establish the FY 2009 target lor the FY
2007 cohort. However, nturned out that the FY 2007 cohort performed worse in
2009 than in 2008 and fell short of the established performance target for 2009.
The FY 2008 cohort also significantly underperformed in its lirst year (2009) ~
compared to the year one results from the prior cohort. As we receive data from

                                         29 

across cohorts for this measure, we are finding H difficuH to discern a pattern of
performance that can serve as a basis for establishing future targets, and have
elected not to revise the target for FY 2010.

It is difficult to assess why performance resu"s for the 2007 and 2008 cohorts fell
short of the established targets for this measure. We have carefully considered
performance reports submitted by grantees, as well as our experience in
monitoring and providing technical assistance to grantees, and have identified
some challenges that may have impeded grant performance. Some common
problems include turnover in leadership (at the authorized representative or
project director level) and challenges wHh co llecting and reporting valid data
about the measure. Another variable that might affect performance in sites is
related to project design. For example, we're not certain how to assess the likely
impact of a site that is implementing a single research based program versus
                                                       4




sites that have adopted a more comprehensive strategy that includes a
community-based intervention that complements school-based curricula. Finally,
cohort size and composition varies from cohort to cohort. In some years funding
for a large amount of new awards is available and in others only a handful of
sites will receive grants. To the extent that our peer review results that are used
to rank order applications and select grantees accurately predict project quality,
the range of scores funded (and perflaps the range of project quality) varies from
fiscal year to fiscal year.

We believe that an equally important dimension in assessing performance
against established targets for this measure is our ability to correctly predict
targets for measures. Because there is limited available research and no
"industry" standard available to guide expectations for performance, generally
we have used the performance of prior cohorts on the measure to establish
targets for subsequent cohorts. Because of the need to establish targets for
future cohorts before a single cohort has completed project implementation and
submitted final data, we have based targets on information provided over a fairly
limHed amount of time, often reflecting the results of less than a single cohort of
complete performance information. Initial challenges wHh data quality also
resulted in situations where only a limited number of grantees in a cohort were
able to provide va lid performance data. This situation introduced two possible
problems into the target setting process - that targets are being based in some
part on a subset of grantees that are not representative of the cohort as a whole,
and that those sites able to provide valid data more quickly may also have
superior capacity to effectively implement program interventions. While we have
placed a significant emphasis on improving data quality and have worked to
improve the response rates for measures over the life of the cohort, this causes
perfonnance results from a relatively small set of grantees in year one to be
compared to resuRs for a significantly larger percentage of the cohort by the end
of project.




                                        30 

Increasingly, it is clear that a series of variables serve to make each cohort
unique, and that the issue of how we have established targets for this measure
has been problematic. Revised processes for establishing targets for this
measure are discussed in the FY 2010 Performance Targets section below.


FY 2010Performance Targets. We had established an FY 2009 target for the FY
2007 cohort based on the performance of prior cohorts in 2008. However, this
cohort experienced a significant decline in performance in FY 2009. Based on
lower than anticipated levels of performance for this measure, we revised the FY
2010 targets fo r both the FY 2007 and FY 2008 cohorts for this measure. The
2010 target for the FY 2007 cohort was reduced from 86.5 percent to 49.4
percent (or a target level that rep resents a 5 percent increase of the FY 2009
actual data for this measure), The 2010 target for the FY 2008 cohort was
reduced from 86.5 percent to 51 .8 percent (or a target level that represents a 5
percent increase of the FY 2009 actual data for this measure).

Given these challenges, and improvements we have made in data quality
(including generally requiring grantees to collect baseline data for their projects
before interventions are implemented ), we intend to modify our process for
establishing targets. While prior cohort performance may provide some inSights
about general patterns of performance that we can incorporate into our targeting
setting processes, for any future cohorts for this program we will establish
numerical performance targets after baseline data is received for the new cohort.
We will enter these targets into the Department's Visual Performance System
(VPS) as "administrative" targets (for example, baseline plus 5 percent), and then
convert the targets to numerical targets after baseline data is collected and
aggregated. We believe that this process revision will help us better match
targets to cohort performance.


Methodology. Data for this measure are collected by grantees and reported as
part of annual performance reports. If data for this measure are not ava ilable at
the tim e that performance reports are submitted, staff follow up with snes to
attempt to obtain data for the measure. Grantees that fail to provide data are not
included in the tabulation of data for the measures. Also, grantees that did not
provide data for two consecutive project years (so that we could determine if an
increase in the percentage of students that disapprove of alcohol abuse had
occurred) are not included in the aggregate data repo rted for the measure.
Authorized representatives for the grant site sign the annual performance report,
and in doing so, certify that to the best of the Signer's knowledge and belief, all
data in the performance repert are true and correct and that the repert fully
discloses all known weaknesses conceming the accuracy, reliability. and
completeness of the data included. Generally, the Department relies on the
certification conceming data supplied by grantees and does not conduct further
reviews.

                                         31 

ED does not mandate data collection protocols or instruments for grantees.
Grantees select a survey tlem that reflects the concept of disapproval of alcohol
abuse, and collect and report data about that survey item as part of perfonnanoe
reports. As a result, data are not comparable across grant sites, but individual
grant srtas are required to use the same survey items across performance
periods. We consider sites that have experienced an increase in the percentage
of students reporting disapproval of alcohol use of one percent or greater to have
achieved a measurable increase for this measure.

Initially, applicants were not required to fumish baseline data as part of their
applications. Data supplied after year one were considered baseline data for the
projects. Projects required two years of data in order to detennine ~ a decrease
in binge drinking among target students has occurred.

We have provided Significantly increased guidance and technical assistance
beginning wtlh the FY 2007 cohort, and believe that these efforts have produced
data that are of higher qualtly and more comparable across stles than those of
previous cohorts. These cohorts were instructed to provide baseline data in their
application, or ~ that data was not available, to collect tl before beginning project
implementation.



Assertions
                          Perfonnance Reporting System

The Department of Education has a system in plaoe to capture perfonnance
infonnation accurately and that system was prope~y applied to generate the
perfonnanoe data in this report. In instances in which data are supplied by
grantees as part of required periodic perfonnanoe reports, the data that are
supplied are accurately reflected in this report.

Data related to the drug control programs included in this Perfonnance Summary
Report for Fiscal Year 2009 are recorded in the Department of Education's
software for recording perfonnance data and are an integral part of our budget
and management processes.


               Explanations for Not Meeti ng Perfonnance Targets

The explanations provided in the Perfonnance Summary report for Fiscal Year
2009 for not meeting perfonnance targets and for recommendations for plans to
revise performance targets are reasonable given past experience, available
information, and available resources.



                                         32
               Methodology for Establishing Performance Targets

The methodology described in the Perfonnance Summary Report for Fiscal Year
2009 to establish perfonnance targets for the current year is reasonable given
past perfonnance and available resources_

          Performance Measures for Significant Drug Control Activities

The Department of Education has established at least one acceptable
performance measure for each Drug Control Decision Unit identified in its
Detailed Accounting of Fiscal Year 2009 Drug Control Funds_

Criteria for Asse rtions



No workload or participant data support the assertions provided in this report_
Sources of quantitative data used in the report are well documented_ These data
are the most recently available and are identified by the year in which the data
was collected_

                           Other Estimation Methods

No estimation methods other than professional judgment were used to make the
required assertions. When professional judgment was used, the objectivity and
strength of those judgments were explained and documented_ Professional
judgment was used to establish targets for programs until data from at least one
grant cohort were available to provide add~iona l infonnation needed to set more
accurate targets. We routinely re-evaluate targets set using professional
judgment as additional information about actual perfonnance on measures
becomes available.

                               Reporting Systems

Reporting systems that support the above assertions are current. reliable, and an
integral part of the Department of Education's budget and management
processes. Data collected and reported for tI1e measures discussed in this report
are stored in the Department of Education's Visual Perfonnance System (VPS)_
The VPS includes appropriate disclosures about data quality issues associated
~h measures_ Data from the VPS are used in developing annual budget
requests and justifications, and in preparing reports required under the
Government Perfonnance and ResuR" Act of 1993_




                                       33 

                                      UNITED STATES DEPARTMENT OF EDUCATION
                                                             OFFICE OF         '~SPECTOR          GB\ERAL

                                                                                                                               AUDIT Sr:RVICES




                                                                    February 25,2010

MEMORANDUM


To: 	                 Kevin Jermings
                      Assistant Deputy Secretary
                      Offi ce of Safe and Drug-Free Schools

From: 	               Keith West J
                      Assistant Inspector General for Audit

Subject: 	            Office of Inspector General's Independent Report on the U. S. Department of
                      Education' s Performance Summary Report/or Fiscal Year 2009, dated
                      February 19, 20 10

Attached is our authentication of management's assertions contained in the U.S. Department of
Education's Performance Summary Report for Fiscal Year 2009, dated February 19. 2010, as
required by section 70S(d) of the Office of National Drug Control Policy Reauthorization Act of
1998 (21 U.S.C. § 1704(d)).

Our authentication was conducted in accordance with the guidelines stated in the Office of
National Drug Control Policy Circular: Drug Control Accounting, dated May 1, 2007.

If you have any questions or wish to discuss the contents of this authentication. please contact
Michele Weaver·Dugan, Director, Operations Internal Audit Team, at (202) 245-6941.



Attachment




Tht Do:panment (It l,dUUII{)ln nll$.~1C'fl is Ul r"JlTlOk:ltudl:n[ BChIC'Y~[ IIIld prq:gm1Ol'l fi.>r glOOal ~ompetlU'C'II~~' ~ fostcrll'l~ t"dOCIJUQ1131
                                                        ~'«(dl= and msunng equal Kl;eSS
                                       UNITED STATES DEPARTMENT OF EDUCATION
                                                                   OFFICE OF INSPECTOR G8-iERAl.

                                                                                                                                      AC OIT SERVICES

                                                                               February 25, 2010


Office of Insoector General's Independent Report on the U.S. Department of Education's
PerfOrmance Summary Report tor Fiscal Year 2009. dated February 19. 20 10

We have reviewed management' s assertions contained in the accompanying Performance
Summary Reportfor Fiscal Year 2009. dated February 19, 2010 (perfonnance Sununary Report).
The U.S. Department of Education's management is responsible fo r the Performance Summary
Report and the assertions contained therein.

Our review was conducted in accordance with attestation standards established by the American
Institute of Certified Public ACCOlUltantS. A review is substantially less in scope than an
examination, the objective of which is the expression of an opinion on management's assertions.
Accordingly, we do not express such an opinion.

We perfonned review procedures on the "Performance Swnmary Information," "Assertions,"
and "Criteria for Assertions" contained in the accompanying Performance Summary Report. In
general, our review procedures were limited to inquiries and analytical procedures appropriate
for our review engagement. We did not perform procedures related to controls over the reporting
system noted in the attac-h ed report

Based on our review, nothing came to our attention that caused us to believe that management's
assertions, contained in the accompanying Performance Summary Report, are not fairly stated in
all material respects, based upon the Office of National Drug Control Policy Circular: Drug
Control Accounting, elated May 1, 2007.



                                                                              Keith West
                                                                              Assistant fnspector General for Audit




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                                                             act:l!ern:c and crnmrllll equal IICCeo;<