This s a repor t -on.work prm I X ipuruant to a reques. of the address.. whoe" nrtherailmi I should be obtained before furth rerlos of tsB rept. Examination Of Project Using Summer Interns For Programs Evaluation -16403,(,) Department of Health, Education, and Welfare BY THE COMPTROLLER GENERAL OF THE UNITED STATES flLE COPy . COMP E 9uY , 11 ) 7 3 ,?j n COMPTROLLER ENERAL OF THE UNITED STATE WAsHINGTON. D.C. D1. B-164031(1) Dear Mr. Patman: This . ur report on the Department of Health, Educa- tion, and Welfare project using summer interns for programs evaluation. Our examination wag made pursuant to your re- quest of June 6, 1970. In accordance with arransemunents made with your office, we are sending copies of this report to Congresswoman Edith Green and Congressman Robert 0. Price. We plan to make no fur±her distribution of this report unless copies are specifically requested, and then we shall make distribution only after your agreement has been ob- tained or public announcement has been made by you con- cerning the contents of the report. The Department of Health, Education, and Welfare and the contractor have rot been given an opportunity to formally comment on this report, Sincerely yours, Acting Comptroller General of the United States The Honorable Wright Patman house of Representatives 50TH ANNIVERSARY 1921- 1971 COMPTROLLER GENERAL'S EXAMINATION OF PROJECT USING SUMMER INTERNS REPORT TO THE FOR PROGRAMS EVALUATION HONORABLE WRIGHT PATMAN Department of Health, Education, and ROUSE OF REPRESENTATIVES Welfare B-164031(1) DIGEST WHY THE REVIEW WAS MADE During the summer of 1970 the Department of Health, Education, and Welfare (HEW) funded a project usinig summer interns to evaluate 15 of its programs. The project, known as the Programs Evaluation by Summer Interns project, was conducted by a contractor--The BLK Croup, Inc., a Washington, D.C., con- sulting firm--which employed 171 interns to evaluate programs in 14 loca- tions. At the request of Congressman Wright Patman, the General Accounting Office (GAO) examined into the --development of the project concept and the need for the project, --selection of a contractor, --legality of the contract, and --background of the contractor and its personnel. HEW and the contractor have not been given an opportunity to formally ex- amine and comment on this report. FINDINGS AND CONCLUSIONS Purpose of project The project was intended to test the feasibility of using summer interns to evaluate the effectiveness of 15 HEW programs. (See app. II.) The interns were to include graduate and undergraduate students and non- student residents of the communities where the HEW programs were located. (See p. 5.) Selection of a contractor Eight firms submitted proposals for the conduct of the project. Ai HEW review panel screened the proposals, and as a result, HEW asked four firms to revise their technical proposals and to make any desired changes in their cost proposals. The firms were not notified, however, as required by the Federal Procure- ment Regulations, that the revised proposals would be final. GAO believes that this irregularity is not sufficient cause to question the vaildity of the resulting contract award. (See p. 18.) Tear Sheet UG . 1 8, 1 9 7 1 Of the four revised proposals, two were determined by the panel to be ac- ceptable. The contract was awarded to The BLK Group because it had the lower cost proposal. On April 10, 1970, a letter contract was awarded to The BLK Group at an estimated total cost of $899,369. On June 23, 1970, a cost-plus-a-fixed- fee contract was awarded instead of the contemplated fixed-price contract. The type of contract was changed because the HEW Audit Agency questioned certain of the estimated costs. The PEW General Counsel informed the contracting officer that the\ 9 was nothing illegal about such a change. GAO believes that the contracting officer was justified, under the circumstances, in awct,ding the cost-plus- a-fixed-fee contract. (See p. 21.) Funding of project costs Amendments to the contract resulted in a total estimated cost of about $1 million. Funds aporopriated to evaluate each of the 15 programs were used to finance the project. GAO believes that the legal authorities for expenditure of these funds provided a statutory basis for financing the project. (See p. 10.) Evaluations of the project BLK Group evaluation The BLK Group report recommended that HEW regain some measure of delegated responsiblity for its programs, rather than leave supervision, enforcement, and technical assistance largely to local and State agencies. The report stated that using summer interns to evaluate programs was not only feasible but also potentially practical, economical, and valuable to HEW officials. (See p. 24.) HEW evaZluation The HEW project staff found that the project, if refined and expanded, would provide program managers with up-to-date information on the op- eration of HEW programs. Because the project had been closely monitored by HEW during the summer, the HEW staff did not recommend a separate evaluation of the 1971 project by a contractor. Such an evaluation was made of the 1970 project by Abt Associates, Inc. (See p. 24.) Abt Associates evaZuation Abt Associates conducted its evaluation under a $29,097 fixed-price con- tract. 2 The contract was awarded by HEW on a sole-source basis because the presi- dent of Abt Associates _s familiar with the project. He had assisted HEW in preparing the request for proposals for the project and had also been a member of the proposal review panel. GAO, however, believes that the president's prior involvement with the project did not necessarily qualify Abt Associates to evaluate the proj- ect. Other companies should have been solicited to compete with the Abt proposal. (See p. 25.) The Abt Associates report stated that the project seemed to demonstrate that student interns were capable of carrying out field evaluations of programs. The report indicated that by making certain improvements in the project and by concentrating on fewer programs a more cost-effective means of evaluation might be achieved than would be possible by using alternative methods of evaluation. The report stated further that if the project were continued in 1971 at approximately the same level and by the same contractor as in 1970, it would result in a lack of useful evaluation data simnilar to the 1970 project. (See p. 26.) Continuation of the project On April 26, 1971, HEW entered into a contract with the Small Business Administration to conduct the 1971 project under a subcontract with The BLK Group. The cost-plus-a-fixed-fee subcontract with The BLK Group pro-- vided for using about 67 interns to evaluate nine HEW programs, at an esti- mated cost of $502,900. Small Business Administration officials informed GAO that this contracting arrangement was made pursuant to section 8(a) of the Small Business Act (15 U.S.C. 637) which authorizes the agency, in fulfilling contracts with other Federal agencies, to subcontract with small business firms not yet able to compe'e effectively in the marketplace. The contract files showed that HEW informed the Small Business Administra- tion in January 1971 that it would award the contract to the agency condi- tional upon The BLK Group qualifying for section 8(a) subcontracts and being approved for the subcontract. (See p. 28.) The HEW program groups responsible for the operation of the 15 programs evaluated under the 1970 project had not completed their review of ' e BLK Group report at the time the 1971 contract was awarded to the Small Business Administration. GAO believes that comments of the HEW groups should have been obtained and that the comments and The BLK Group report should have been fully evaluated before a contract to continue the project in 1971 was awarded. (See p. 28.) Tear Sheet 3 BLK Group kty personne l The BLK Group was incorporated on March 26, 1969. In May 1970 it had 25 employees, 10 of whrmn were assigned to the project. The persons employed by The BLK Group appeared to possess the education and experience neces- sary to perform the type of work required by the contract. (See pp. 9 and 30.) 4 Contents DIGEST 1 CHAPTER 1 INTRODUCTI ON 5 2 DEVELOPMENT AND LEGALITY OF PEBSI PROJECT 7 Development of PEBSI concept 7 Legality of PEBSI project 10 Conclusion 10 3 CONTRACTUAL ARRANGEMENTS FOR CARRYING CUT PSBSI PROJECT 11 Request for proposals for a contract for PEBSI project 11 Selection of contractor 15 Conclusion 18 HEW Audit Agency review of proposed costs 19 Change from contemplated fixed-price contract to cost-plus-a-fixed-fee con- tract 21 Conclusion 21 Contract modifications and cost 21 4 RESULTS, EVALUATION, AND CONTINUATION OF PEBSI PROJECT 24 Results of PEBSI project 24 Contract for evaluation of PEBSI project 25 Conclusion 25 Report on PEBSI evaluation 26 Award of 1971 PEBSI contract 27 Conclusion 28 5 BACKGROUND OF PRINCIPAL CONTRACTOR PERSONNEL 29 Conclusion 30 APPENDIX I Letter dated June 6, 1970, irom Congressman Wright Patman to the Comptroller General 33 APPENDIX Page II Schedule of source of funds for the project and programs evaluated during PEBSI proj- ect 35 ABBREVIATIONS BLK The BLK Group, Inc. GAO General Accounting Office HEW Department of Health, Education, and Welfare PEBSI Programs Evaluaticn by Summer Interns SBA Small Business Administration COMP?.ROLLER GENERAL'S EXAMINATION OF PROJECT USING SUMMER INTERNS REPORT TO THE FOR PROGRAMS EVALUATION HONORABLE WRIGHT PATMAN Department of Health, Education, and HOUSE OF REPRESENTATIVES Welfare B-164031(1) DIGEST WHY THE RbYVIEW WAS MADE During the summer of 1970 the Department of Health, Education, and Welfare (HEW) funded a project using summer interns to evaluate 15 of its programs. The project, known as the Programs Evaluation by Summer Interns project, was conducted by a contractor--The BLK Group, Inc., a Washington, D.C., con- sulting firm--which employed 171 interns to evaluate programs in 14 loca- tions. At the request of Congressman Wright Patman, the General Accountiltg Office (GAO) examined into the --development of the project concept and the need for the project, --selection of a contractor, --legality of the contract, and --background of the contractor and its personnel. HEW and the contractor have not been given an opportunity to formally ex- amine and comment on this report. FINDINGS AND CONCLUSIONS 'urpose of project The project was intended to test the feasibility of using summer interns to evaluate the effectiveness of 15 HEW programs. (See app. II.) The interns were to include graduate and undergraduate students and non- student residents of the communities where the HEW programs were located. (See p. 5.) Selection of a contractor Eight firms submitted proposals for the conduct of the project. An HEW review panel screened the proposals, and as a result, HEW asked four firms to revise their technical proposals and to make any desired changes in their cost proposals. The firms were not notified, however, as required by the Federa' Procure- ment Regulations, that the revised proposals would be final. GAO believec that this irregularity is not sufficient cause to question the vaildity of the resulting contract award. (See p. 18.) I Of the four revised proposals, two were determined by the panel to be ac- ceptable. Tlie contract was awarded to The BLK Group because it had the lower cost proposal. On April 10, 1970, a letter contract was awardeJ to The BLK Group at an estimated total cost of $899,369. On June 23, 1970, a cost-plus-a-fixed- fee contract was awarded instead of the contemplated fixed-price contract. The type of contract was changed because the HEW Audit Agency questioned certain of the estimated costs. The HEW General Counsel informed the contracting officer tuat there was nothing illegal about such a change. GAO believes that the contracting officer was Justified, under the circumstances, in awarding the cost-plus- a-fixed-fee contract. (See p. 21.) ?undinS of project costs Amendments to the contract resulted in a total estimated cost of about $1 million. Funds appropriated to evaluate each of the 15 programs were used to finance the project. GAO believes that the legal authorities for expenditure of these funds provided a statutory basis for financing the project. (See p. 10.) Evaluations of the projeot BLK Group evaZuation The BLK Group report recommended that HEW regain some measure of delegated responsiblity for its programs, rather than leave supervision, enforcement, and technical assistance largely to local and State agencies. The report stated that using summer interns to evaluate programs was not only feasible but also potentially practical, economical, and valuable to HEW officials. (See p. 24.) HEW evaZuation The HEW project staff found that the project, if refined and expanded, would provide program managers with up-to-date information on the op- eration of HEW programs. Because the project had been closely monitored by HEW during the sumner, the HEW staff did not recommend a separate evaluation of the 1971 project by a contractor. Such an evaluation was made of the 1970 project by Abt Asseciates, Inc. (See p. 24.) Abt Associates evaluation Abt Associates conducted its evaluation under a $29,097 fixeJ-price con- tract. 2 The contract was awarded by 1HE' on a sole-source basis because the presi- dent of Abt Associates was familiar with the project. He had assisted HEW in preparing the request for proposals for the project and had also been a member of the proposal review panel, GAO, however, believes that the president's prior involvement with the project did not necessarily qualify Abt Associates to evaluate the proj- ect. Other companies should have been solicited to compete with the Abt proposal. (See p. 25.) The Abt Associates report sta" d that the project seemed to demonstrate that student interns were capable of carrying out field evaluations of programs. The report indicated that by making certain improvements in the project and by concentrating on fewer programs a more cost-effective means of evaluation might be achieved than would be possible by using alternative methods of evaluation. The report stated further that if the project were continued in 1971 at approximately the same level and by the same contractor as in 1970, it would result in a lack of useful evaluation data similar to the 1970 project. (See p. 26.) Continuation of the project On April 26, 1971, HEW entered into a contract with the Small Business Administration to conduct the 1971 project under a subcontract with The BLK Group. The cost-plus-a-fixed-fee subcontract with The BLK Group pro- vided for using about 67 interns to evaluate nine HFW programs, at an esti- mated cost of $502,900. Small Business Administration officials informed GAO that this contracting arrangement was made pursuant to section 8(a) of the Small Business Act (15 U.S.C. 637) which authorizes the agency, in fulfilling contracts with other Federal agencies, to subcontract with small business firms not yet able to compete effectively in the marketplace. The contract files showed that HEW informed the Small Business Administra- tion in January 1971 that it would award the contract to the agency condi- tional upon The BLK Group qualifying for section 8(a' subcontracts and being approved for the Rubcontract. 'See p. 28.) The HEW program groups responsible for the operation of the 15 programs evaluated under the 1970 project had not completed their review of The BLK Group report at the time the 1971 contract was awarded to the Small Business Administration. GAO believes that comments of the HEW groups should have been obtained and that the comments and The BLK Group report should have been fully evaluated before a contract to continue the project in 1971 was awarded. (See p. 28.) 3 BLK Group key pereonnel The BLK Group was incorporated on March 26, 1969. InMay 1970 it had 25 employees, 10 of whom were assigned to the project. The persons employed by The BLK Group appeared to possess the education and experience neces- sary to perform the type of work required by the contract. (See pp. 9 and 30.) 4 CHAPTER 1 INTRODUCTION Pursuant to a request dated June 6, 1970, from Congress- man Wright Patman (see app. I), we reviewed certain aspects of the Programs Evaluation by Summer Interns (PEBSI) project sponsored by the Department of Health, Education, and Wel- fare. The office of the Deputy Assistant Secretary for Eval- uation and Monitoring, HEW, was assigned administrative re- sponsibility for the project, and The BLK Group, Inc., (BLK), a Washington, D.C., based consulting firm, conducted the project work under an HEW contract at an estimated cost of about $991,000. In accordance with arrangements made with Congress- man Patman's office, we obtained information on the selec- tion and background of the contractor and the activities to be carried out under the contract, and we examined into the legal basis for the award of the contract. We examined the HEW records pertaining to the selection of the contractor and the operation and certain financial aspects of the project, and we met with HEW and BLK offi- cials to obtain background data and certain other informa- tion about the project. We did not evaluate the contractor's performance under the contract. The PEBSI project was designed to test the feasibility of using summer interns in the evaluation of the effective- ness of HEW programs. The interns were to include graduate and undergraduate students and nonstudent residents of the communities in which the HEW programs to be evaluated were located. HEW selected 15 programs to be evaluated and funded the PEBSI project from funds appropriated for the evaluation of these programs. (See app. II.) In conducting the project the contractor hired 171 summer interns. The HEW programs evaluated by the interns were located in Albuquerque, New Mexico; Atlanta, Georgia; Boston, Massachusetts; Cleveland, Ohio; Los Angcles, Cali- fornia; New York, N.Y.; and Washington, D.C.; and in Maricopa County, Arizona; San Joaquin County, California; Cumberland County, New Jersey; Dade County, Florida; Berrien 5 County, Michigan; Hildago County, Texas; and Sandusky County, Ohio. Counties with heavy concentrations of migra- tory farm workers (migrants) were selected. HEW decided to operate the PEBSI project in some migrant areas because no evaluation had been conducted by the Federal Government on the effect of the HEW programs on migrants. 6 CHAPTER 2 DEVELOPMENT AND LEGALITY OF PEBSI PROJECT DEVELOPMENT OF PEBSI CONCEPT The PEBSI project originated from a proposal submitter to the Under Secretary of HEW on September 16, 1969, by a summer employee on his staff. The employee's proposal in- dicated that student unrest in recent years had teen caused, in part, by- the students' belief that established channels for implementing change were not responsive to the ideas or participation of the young. Also the proposal pointed out that, although evaluations of programs conducted within an organization might be biased by past experiences of the evaluator, evaluations conducted by an outside organization could be hampered by a lack of familiarity with the organi- zation. The proposal stated therefore that both approaches to evaluation appeared to have inherent weaknesses that de- tracted frcm the effectiveness of the end product. The employee said that, by involving young people in an effectiveness evaluation of the HEW programs, HEW could serve the dual purposes of providing necessary evaluation by an outside group working inside the Department and of providing opportunities for youth to effectively participate in solving some very serious social problems confronting the Nation. The summer employee proposed a project which would em- ploy 25 interns at a total cost of about $93,500 and con- cluded that the cost of such a project would be rather small compared with the benefits that might result. In October 1969 a project officer was designated in the office of the Deputy Assistant Secretary for Evaluation and Monitoring to develop the employee's idea into a workable project. We were informed by the project officer that, while developing the project, he examined into the operations of 18 or 19 Government-funded intern projects to become aware of their strengths and weaknesses and that he con- tacted various people in HEW for their opinions and sugges- tions. 7 The Deputy Assistant Secretary stated that the exami- nation showed that HEW program managers were not satisfied with the results of prior intern projects because the goals were not realistic and the project operations were not ade- quately monitored. He said that HEW had tried to structure the PEBSI project to provide for adequate management, tech- nical support, and monitoring, to ensure that the project would be a success. The project officer told us that he had decided that the project would need a group of interns with a variety of skills who could successfully relate to the communities ih which they would be wozking. For this reason he decided that the group of interns should include graduate and under- graduate students and nonstudent residents of the communi- ties involved. The project officer told us also that, in designing the project, he had initially thought it should include an evaluation of only five or six programs and be conducted in several of the HEW regions, to preclude any accusation of regionoal bias in the final report. The Deputy Assistant Secretary told us that HEW wanted to test the concept of using interns in the evaluation of as many different types of programs as possible. He also pointed out that the sensitivities of managers of programs selected for evaluation would naturally be aroused and that, unless several programs were reviewed, these managers would believe they were being singled out. The project officer estimated that it would cost be- tween $500,000 and $1,000,000 to conduct the proposed proj- ect. HEW decided to use a portion of the funds appropriated ror the evaluation of 15 HEW programs and to evaluate the programs in several of the HEW regions. To conduct such a project, the project officer estimated that 100 to 150 in- terns would be needed. These decisions, however, were not based on any data obtained from a formal study. With regard to the selection of sites at which the 15 programs would be evaluated, the Depucy Assistant Secretary told us that HEW had selec ed sites which would give the PEBSI project a broad geographical representation. In ad- dition, he said that HEW had made an effort to select cities 8 involved in the Model Cities program of the Department of Housing and Urban Development because these were areas in which HEW programs were particularly abundant. The Model Cities program is an attempt to coordinate and concentrate Federal, State, and local resources in designated slum and blighted areas to substantially improve the living condi- tions and general welfare of the residents. The project officer told us that originally the eval- uEtions were to have been conducted in cities and in rural areas; but when it became evident that only large cities were operating all or most of the programs to be evaluated, the idea of evaluating programs in rural areas had been dropped. He said that HEW had decided to evaluate programs in areas with high concentrations of migrant workers. The project officer decided that the project should employ 150 interns to evaluate the 15 HEW programs. Eval- uations would be conducted in seven cities and in certain areas with high concentrations of migrants. The Deputy Assistant Secretary informed us that, be- cause the PEBSI project would be in operation for less than a year, it would have been difficult to build up an appro- priate professional staff within HEW to conduct the project. Also the project officer told us that inadequate management of some of the previously conducted intern projects which he had reviewed had resulted from using regular staffs to direct the piojects, in addition to their normal duties. For these reasons HEW officials decided to employ a contrac- ' tor to conduct the PEBSI project. HEW awarded a contract to BLK on April 10, 1970, at an estimated cost of $899,369. Modifications made to the con- tract increased the estimated cost to $991,065. BLK is a firm of management consultants in the field of human prob- lems and principally specializes in the areas of transpor- tation; social protlems, such as juvenile delinquency, wel- fare health services, and day care; staff training; and legislative matters. The firm was incorporated on March 26, 1969, aPd in May 1970 it had 25 employees, 10 of whom were assignee to the PEBSI project. The final volume of the firm's report on the project results was submitted to HEW on January 8, 1971. 9 LEGALITY OF PEBSI PROJECT Material prepared by HEW and furnished to us by Con- gressman Patman included F schedule of the source of funds for the PEBSI project, which showed that $950,000 would be needed to finance the project. Other material was furnished which made reference to the views of the National Education Association that the contract for the project was entered into without proper authority, without justifiable cause, and in violation of the intent of the Congress. We have revised the funding schedule supplied to us by Congressman PatmEn, to include the funding for all contract modifications and to include the citations to the legal authority to expend these funds for program evaluations. (See app. II.) We examined each of the authorities cited and in our opinion they provide a statutory basis for pro- gram evaluations such as the PEBSI project. An official of the National Education Association in- formed us that the statement that the contract for the proj- ect was entered into without proper authority was based on the wording of the Senate version of a bill which, in sev- eral sections, would have given authority to contract for the evaluation of elementary and secondary education pro- grams to the Commissioner of Education, rather than to the Secretary of HEW. When enacted into law as Public Law 91- 230, however, the evaluative authority was given to the Secretary. Conclusion The legal authorities for expenditure of these funds provided a statutory basis for financing the project. 10 CHAPTER 3 CONTRACTUAL ARRANGEMENTS FOR CARRYING OUT PEBSI PROJECT Under the contract awarded in April 1970, BLK was to conduct evaluations of 15 HEW programs, using 150 summer interns in the evaluative process. Evaluations were to be conducted in seven cities and seven counties across the Na- tion. BLK was to iecruit the interns; familiarize them with the HEW programs; and train them in program evaluation processes, including observation techniques, data organiza- tion, report writing, and measurement of changes effected by the programs. The interns were to conduct interviews with users, nonusers, and operators of the HEW programs; gather certain statistical data; make observations on program operations; organize the various types of information collected; and participate in an analysis of the effectiveness of the pro- grams they had reviewed, basing their findings on data they had collected and observations they had made. Further data analysis was to be do- ,ashington BLK headquarters by experienced analys.- The final report of BLK was to provide an evaluation of the 15 HEW programs reviewed and a self-assessment of the PEBSI project. Also as a part of the final report, a color film suitable for national television presentation was to be submitted, showing the operations and goals of some of the HEW programs which had been evaluated. We reviewed HEW's selection of BLK to conduct the PEBSI project and the procedures used in awarding the contract. These topics are discussed in the following sections. REQUEST FOR PROPOSALS FOR A CONTRACT FOR PEBSI PROJECT On December 10, 1969, the office of the Assistant Sec- retary for Planning and Evaluation secured the services of Abc Associates, Inc., to prepare specifications to be in- cluded in a request for proposals for a contract to be 11 awarded for the design and implementation of the PEBSI proj- ect. Abt Associates is a Cambridge, Massachusetts, consult- ing firm specializing in economic and educational research. The firm has had contracts with the Departments of Labor, Transportation, and HEW; the Office of Economic Opportunity; the Government of Canada; and with various municipalities. The services of Abt Associates were obtained under a pur- chase order in the amount of $2,495 for the period Decem- ber 10 through December 31, 1969. The Deputy Assistant Secretary for Evaluation and Mon- itoring told us that he had decided to hire Dr. Clark Abt, president of Abt Associates, to prepare the specifications to be included in the request for proposals because Dr. Abt- had the technical expertise to prepare a request for pro- posals which would protect HEW's interest and because he was capable of estimating the cost of various tasks which were to be considered for inclusion in the request for pro- posals. The Deputy Assistant Secretary said that time was a factor and that, unlike HEW personnel who had other pri- orities, Dr. Abt could devote his full time to preparing the request for proposals. He said also that the fee of $2,495 was agreed upon because time was of the essence and that purchases under $2,500 were subject to the simplified small purchase procurement regulations (41 CFR 1-3.600) which per- mitted oral solicitation of bids. On February 9, 1970, a request for proposals for a contract for the PEBSI project was announced in the Cou- merce Business Daily, a publication in which prospective Government contracts are advertised so that interested parties can obtain a copy of the request for proposals. To ensure an adequate response to the request for proposals, HEW sent announcements to 15 firms which had filed state- ments of their capabilities with HEW and which the project officer thought might be interested in submitting a proposal for the project. The request for proposals listed the fol- lowing six objectives for the PEBSI project. 1. Evaluate the effectiveness of a range of HEW pro- grams, using summer interns to conduct the evalua- tions. 2. Produce a self-assessment of the PEBSI project, in- cluding an evaluation of the effectiveness of the 12 interns as information gatherers and analysts and an assessment of the feasibility and effectiveness of a permanent and expanded summer intern project. 3. Educate and motivate the summer interns. 4. Contribute to public understanding and opinion of the HEW programs. 5. Produce a report representing the findings, conclu- sions, and recommendations resulting from the evalu- ations conducted by the interns. 6. Submit the interns' evaluations to the operators of the programs evaluated to see how they perceive evaluation accuracy, comprehensiveness, clarity, and feasibility; then send follow-up letters to interns to get their responses on the criticisms of their efforts. Examine the frequency of specific criti- cisms on both sides and assess the criticisms. The request for proposals stated that (1) consideration would be given to technical proposals as well as to price in the award of the contract and (2) the Government re- served the right to make an award to other than the low of- feror, to make multiple awards or to not make an award, and to make an award without further discussion of'the proposals submitted. The request stated also that both the price and the technical proposals submitted should be the most favor- able the offeror could propose to the Government. It stated further the weights that would be given to the principal areas (training, reporting, program management, field opera- tions, etc.) of the proposals during HEW's evaluation of them. After the requests for proposals were sent out, a con- ference was held with prospective contractors to allow them to ask questions on any part of the request for pro- posals which was not clear to them. According to the min- utes of the conference, a prospective contractor asked whether HEW had definitely determined that a fixed-price contract would be awarded, as indicated in the request for proposals, or whether it was possible that a cost- reimbursable contract would be awarded. The HEW represen- tative told him that HEW anticipated awarding a fixed-price 13 contract at that time but that HEW was not completely bound to do so. In answer to a question from another prospective con- tractor whether the price of the contract would be negoti- able, the HEW representative replied that the cost propos- als would not be opened until the HEW technical evaluation was completed, at which time there might be an award with- out further discussion or there might be negotiation. In answer to another question, he said that HEW had certain preconceived ideas as to the cost of the project but that this information could not be revealed to the prospective contractors. 14 SELECTION OF CONTRACTOR Eight firms submitted proposals in response to HEW's request for proposals. To select the most qualified pro- posals, a review panel was formed by HEW to evaluate the eight proposals. The panel consisted of 13 evaluators: two from the HEW Office of Child Development; one from the Office of Education; one from the HEW Center for Community Planning; one from the office of the HEW Assistant Secretary for Planning and Evaluation; one from the Department of Labor; and seven outside consultants, including Dr. Abt who had prepared the specifications for the request for pro- posals. According to the project officer, the individuals selected to be members of the panel had either been on such a panel before or had been involved in the operation of pro- grams similar to the PEBSI project. The proposal review panel met during March 12 through March 14, 1970. The panel members rated eacheof the eight' proposals, weighting each component of the proposals in ac- cordance with the criteria shown in the request for propos- als. A firm could get a maximum score of 100 points. The records kept by the proposal review panel show that 12 of the 13 panel members' average scores for each of the eight firms submitting proposals were as follows: Firm Score A 69.26 B 67.60 BLK 66.15 C 63.45 D 53.95 E 45.54 F 43.08 G 20.31 The records did not indicate nor could HLW officials tell us why the 13th panel member did not participate. The records show that the panel members found no one proposal technically acceptable to satisfy all phases of the project; but records of a discussion among the 12 panel members indi- cate that seven of them would have preferred having firm B conduct the project, if they had to select one firm to do it. Four of the members said that none of the firms seemed 15 capable and one of them stated that firm A should conduct the project. The records show also that the majority of the panel members were in favor of awarding the contract to a combination of two or three firms. The project officer informed us that HEW had decided against the panel's suggestion that the contract be awarded to a combination of firms because a combined award would have been a major change from the intent of the request for proposals and because it would have been difficult to choose the firm that would have had responsibility for overall di- rection and coordination of the project. The contracting officer for the PEBSI project advised us that the panel recommended that four firms, whose pro- posals were judged to be responsive but weak in certain as- pects, be asked to strengthen their proposals in the speci- fied areas. He added that, since none of the proposals ap- peared to be particularly acceptable--even though seven panel members preferred having firm B conduct the project if the panel had to select one firm to conduct it--he thought it would be beneficial to the Government to conduct negotia- tions with the four firms to obtain better proposals. At negotiation. conferences on March 18, 1970, the four firms were notified of the areas in which each of their technical proposals was judged to be weak. These areas included intern recruiting and training, data analy- sis, and field operations. The contracting officer told us that, at the time the four firms were asked to strengthen their technical proposals, they were also informed that they could make any changes they wanted in their cost pro- posals. He said, however, that the firms were not informed that such proposals would be final. He said also that, when these firms were asked to strengthen their technical proposals and to make any desired changes in their cost pro- posals, they should have known that they were among the final firms being considered, even though they would not have known how many firms they were competing with at that point. The proposal review panel met again on March 30, 1970, to review the revised proposals submitted by the four firms. At that time only eight of the 13 panel members were pres- ent. Although few records were kept on the proceedings at 16 this meeting, a final tally of votes was maintained which indicated the acceptability or unacceptability of the pro- posals. According to the file, the eight panel members voted as follows: Firm Acceptable Undecided Unacceptable B 6 1 1 BLK 3 1 4 D 1 1 6 A 1 0 7 The revised proposals were also sent to four addi- tional panel members, who voted as follows: Firm Acceptable Undecided Unacceptable B 3 0 1 BLK 4 0 0 D 1 0 3 A 1 0 3 Thus nine panel members found firm B's revised proposal ac- ceptable and two found it unacceptable; seven found BLK's revised proposal acceptable and four found it unacceptable. On April 1, 1970, the contracting officer was notified that the panel had determined that firm B and BLK, in that order of preference, had acceptable proposals. When the cost proposals were subsequently opened it was found that the proposals of the four firms were: Firm Amount A $862,733.00 BLK 899,369.00 D 916,633.00 B 993,619.58 The contracting officer stated that, because BLK's cost proposal was lower than that of firm B, HEW awarded a let- ter contract to BLK on April 10, 1970, at an estimated cost of $399,369. 17 With regard to the weight given to the cost component in HEW's evaluation of the various proposals, the request for proposals stated that: "Offerors are advised that paramount consider- ation shall be given to the evaluation of tech- nical proposals, as well as price, in the award of a contract her-under." HEW, however, reserved the right to award the fEBSI con- trac.t to other than the low offeror. The contracting officer to"' us that, subsequent to opening the cost proposals, he I contacted the HEW Audit Agency regarding the possibili ~ f its conducting a re- view of the proposed costs of uoth BLK and firm B. He said that the Audit Agency estimated that it would take about 2 weeks to complete such a review, and he said also that negotiations would take another week. This would have resulted i. the contract not being awarded until the end of April, at which time it would have been too late to organize the project for operation that surfer. The proj- ect officer stated that he had decided against postponing the project for a year because the project was to provide needed information and because funds which were available for the project in 1970 might not be available at a later date. With regard to the failure to notify the four firms that their revised proposals would be final, the Federal Procurement Regulations (41 CFk 1-3.805-1(b)) state that all offerors selected for negotiation: "*** shall be informed of the specified date (and time if desired) of the closing of negotia- tions and that any revisions to their proposals should be submitted by that date." Conclusion We can understand the need for an expeditious award by HEW; nevertheless it appears that the offerors were never officially informed of the closing of negotiations as prescribed by the regulations. This procedural irregularity, 18 however, did not constitute sufficient cause to question the validity of the award of the contract. HEW AUDIT AGENCY REVIEW OF PROPOSED COSTS The contracting officer informed think it prudent to award us that he did not a fixed-price contract without the benefit of a preaward review of proposed costs, cially since there was only espe- with which to compare BLK's one other acceptable proposal therefore that he had awardedcost proposal. He advised us a letter contract to BLK April 10, 1970, not only on contract but also to allow to allow BLK to begin work on the the a cost review before committing Audit Agency time to conduct contract. A letter contract HEW to the full cost of the is used to declare the intent of an agency to enter into a contract and authorizes tractor to proceed and to a con- expend a percentage of the mated cost as fixed by the esti- ceed 50 percent of the totalcontracting officer, not to ex- The contract must be finalizedestimated cost of the contract. timated cost has been incurred. before 50 percent of the es- The letter contract specified to make expenditures or incur that BLK was authorized obligations, not to exceed $360,000, in the performance finalization. It provided of the contract prior to its tion of the contract begin that negotiations for finaliza- by May 4, 1970, with a target date of May 18, 1970. The HEW Audit Agency review of BLK's costs took longer than had been anticipated; a draft report was not submitted to the contracting officer port questioned $298,040 of until June 1970. The draft re- Of this amount, $52,455 for the estimated cost of $899,369. was questioned, because it salaries and fringe benefits was had paid in the past or because higher than the contractor able to the contract; the it was not directly charge- were questioned because theentire indirect costs of $58,644 contractor had not submitted the required indirect cost proposal to HEW; $]76,562 of the subcontract costs of $268,570 lack of support for the proposedwas questioned because of a costs; and $10,379 of the proposed fee of $33,111 was questioned because this amount of the fee was based on questioned costs. 19 by the Audit Agency was issued on com- The final report the same 11, 1970, and included substantially draft re- September that had been included in the ments and exceptions port. 20 CHANGE FROM CONTEMPLATED FIXED-PRICE CONTRACT TO COST-PLUS-A-FIXED-FEE CONTRACT The contracting officer told us that, because expendi- tures were approaching the limit set in the letter contract, it became necessary to finalize the contract. He said that because BLK and HEW could not come to an agreement on the questioned costs he had decided that a cost-plus-a-fixed- fee contract would be more appropriate than a fixed-price contract. He said also that he had consulted with the HEW Office of General Counsel, concerning the legality of chang- ing from the type of contract contemplated in the request for propcoals, and had been informed that there woul. be nothing illegal in such a change. We noted that proposals to conduct the PEBSI project were requested on Li.e basis of a fixed-price contract and that it originally was intended that the letter contract be finalized as a fixed-price contract. The contract was finalized, however, as a cost-plus-a-fixed-fee contract. It appears that, at the time of finalization, the contract- ing officer was not satisfied that the contractor had fully si ported its proposed costs and that he therefore decided to proceed under a cost-plus-a-fixed-fee arrangement. On June 23, 1970, the contract was finalized as a cost- plus-a-fixed-fee contract at an estimated cost of $899,365, including a fixed fee of $33,111. Conclusion Although HEW had contemplated awarding a fixed-price contract, the use of a cost-plus-a-fixed-fee contract was justified under the circumstances. CONTRACT MODIFICATIONS AND COST On June 16, 1970, the first modification was made to the letter contract. This modification provided that the contractor could request and, subject to the contracting officer's approval, receive advance payments totaling $436,361, to be advanced in three payments as follows: 21 Date Amount June 15, 1970 $266,299 July 1, " 85,031 Aug. 1, " 85,031 The modification provided that all advance payments be deposited in a special bank account and each withdrawal be made by contractor's check, countersigned by the HEW cot tracting officer. These funds could be withdrawn by the contractor for the sole purpose of making payments for di- rect materials and labor and for administrative and overhead expenses required for the purposes of the contract. With regard to advance payments, the Federal Procurement Regula- tions (41 CFR 1-30.408) specify that, if--incident to a bid or proposal or after an award--an otherwise qualified con- tractor is found to require advance payments, there should be no hesitation in recommending to the approving authority that advance payments be established. The contract provided that interest on the amounts ad- vanced be charged to BLK at a rate of 8 percent of the daily amount outstanding. The contracting officer told us that he had recommended the 8-percent interest rate, on the bases of current commercial rates and the rate the Federal Government would have had to pay to borrow funds. On December 18, 1970, a further modification was made to the BLK contract whirh increased the contract costs. Correspondence betweei BLK and HEW indicated that the in- creased costs were due to unanticipated problems and events including (1) use of additional personnel and added printing costs caused by an unexpected requirement that the question- naires to be used by the interns be reviewed by the Office of Management and Budget, (2) hiring of 21 interns more than specified in the contract for the program, (3) an in- crease in the scope of the work of one subcontractor, au- thorized by HEW, resulting in additional costs being in- curred by the subcontractor, (4) problems in contacting and in obtaining clearances from operators of HEW programs prior to initiating reviews of their programs, and (5) time spent in aiding an independent consultant hired by HEW to review the operations of the PEBSI project. According to a BLK memorandum to the HEW contracting officer, the increased costs amounted to $166,700. HEW, 22 however, agreed to a reduction in the requirements for BLK's final report whereby BLK was required to provide a detailed analysis of only five of the HEW programs reviewed and a more general analysis of the other 10 programs. HEW agreed also to cancel a component of the project which was to be conducted during the fall of 1970 and which was to involve part-time interns in evaluating and reporting on certain education programs. This curtailment of the scope of work reduced the estimated increase in cost by $75,000, to $91,700, and resulted in a total estimated contract cost of about $991,000. The first three volumes of the BLK four-volume final report were presented to HEW on December 31, 1970. Accord- ing to correspondence between BLK and HEW, the fourth volume, ah appendix, had not been printed by December 31, due to factors beyond BLK's control; primarily a curtailed work schedule of printers and composers because of holidays. The final volume was delivered to HEW on January 8, 1971. As of February 11, 1971, the contractor had been paid $978,057 of the total estimated contract cost of about $991,000. The amount paid consisted of $959,919 on vouchers submitted by BLK, and $18,138 on outstanding advances. Pending resolution of any exceptions taken during the final audit, 15 percent of the BLK fee was withheld from each pay- ment. The final audit of the BLK contract by the HEW Audit Agency had been scheduled to begin on or about April 12, 1971. According to a representative of the Audit Agency, the BLK fiscal year ended on March 31, 1971; consequently, on April 12, BLK was not prepared for the HEW audit because its account books were being closed. On April 27, 1971, a representative of the Audit Agency told us that BLK had not submitted its final voucher to HEW on the PEBSI project and that a starting date for the final audit had not been established. 23 CHAPTER 4 RESULTS, EVALUATION, AND'CONTINUATION OF PEBSI PROJECT RESULTS OF PEBSI PROJECT The BLK final report contained the results of the eval- uations of the 15 HEW programs, conclusions based on these evaluations, and a self-assessment of the PEBSI project. PEBSI was a success according to the BLK report and showed that college students and community people could make ex- cellent evaluations of Government programs. The basic conclusion of the report was that HEW had not given direction to its programs. The report recommended that IIEW regain some measure of the presently delegated re- sponsibility for its programs, rather than leave supervision, enforcement, and technical assistance largely to local and State agencies. The report stated that most of the HEW pro- grams evaluated were providing services useful to those individuals they served but that they served only a limited number. The BLK report stated also that PEBSI was not only feasible as a concept but also potentially practical, eco- nomical, and valuable to the HEW decisionmakers at all management levels. In February 1971 the HEW-PEBSI project staff prepared a report on the project, which stated that the PEBSI proj- ect, if refined and expanded, would provide program opera- tors at all Federal, regional, State, and local levels with up-to-date information on the operation of HEW pro- grams. The HEW staff concluded that in this sense the proj- ect in 1970 was a success. The report dealt with each specific segment of the project and stated that, because PEBSI was extensively monitored by HEW, a separate evalua- tion as conducted by an HEW contractor during 1970 (see bilow) was of doubtful value and was not recommended for the 1971 PEBSI project. 24 The HEW groups responsible for the operation of the 15 HEW programs evaluated had not completed their review of the PEBSI report at the time we completed our review in May 1971. CONTRACT FOR EVALUATION OF PEBSI PROJECT On April 15, 1970, 5 days after the letter contract was awarded to BLK, Abt Associates submitted a proposal to HEW for an evaluation of the PEBSI project. The Deputy As- sistant Secretary for Evaluation and Monitoring told us that he had decided on an independent evaluation but that he did not want to spend more than $30,000 for it. He asked Dr. Abt to submit a proposal because Dr. Abt was a well- known consultant and his personal involvement would elimi- nate the additional costs and time which would be involved in acquainting someone new with the project. The Abt Associates proposal stated that the firm would (1) make on-site visits during recruitment, selection, and training of interns and at the start and in the middle of the field operation, (2) make regular monthly visits to the BLK Washington headquarters operation, and (3) submit five monthly letter reports and a final report. HEW awarded a fixed-price contract to Abt Associates on June 8, 1970, at a cost of $29,097, justifying the sole-source procurement on the basis that: "Because he prepared the original Request for Proposal for the Programs Evaluation by Summer Interns (PEBSI) project, and served on the Pro- posal Review Panel, Dr. Abt, who will be the principal analyst, is uniquely qualified to per- form the proposed contract to the advantage of the Government." Conclusion Dr. Abt's participation in the preparation of the re- quest for proposals and his involvement on the proposal review panel did not necessarily give Abt Associates special qualifications to perform the evaluation contract. In the interest of obtaining the fullest degree of competition, other companies should have been solicited. 25 REPORT ON PEBSI EVALUATION The Abt Associates assessment of the PEBSI project, contained in its final evaluation report of March 1, 1971, differed somewhat from the assessments by BLK and the HEW- PBBSI project staff. Abt Associates stated that HEW's first goal of recruiting,training, and mobilizing the in- terest of promising and capable young people for HEW ser- vice seemed to have been achieved but that the long-term mobilization of these interns for HEW service was indeter- minable at that time. The report indicated that achievement of the second goal of improved public understanding of HEW programs ap- peared to be inconclusive and that the third goal of in- creasing the efficiency of program evaluations was definitely not achieved. The report stated also that the cost of at- taining these goals did not appear to be less than it would have been if other known means of conducting evaluations had been used (e.g., internal HEW staff or external con- tractor evaluations). Abt Associates indicated also in its report that it was impressed by the job performed by BLK in recruiting a large group of interns from primarily disadvantaged minority backgrounds and by the level of performance of most of these interns, despite their brief and inadequate training. Tle report concluded that the project seemed to demonstrate that undergraduate and graduate students were capable of carrying out field evaluations. With respect to continuation of the project, the report indicated further that the deficiencies of the initial ef- for fort in intern training, contacting program personnel analy- clearances, research design, and data collection and sis could all be corrected. In addition, the report stated that, given improvements in these areas and a greater con- centration of interns on fewer programs in fewer locations and with better preparation, it was possible that a PEBSI project would show superior cost effectiveness over the other currently available evaluation alternatives. The report stated further that, if the PEBSI project were continued at approximately the same level and by the same contractor in calendar year 1971 without significant 26 change in project content, size, or management, the 1971 project would produce an absence of useful evaluative data similar to the 1970 project. Furthermore Abt reported that, because of HEW's lack of a clear administrative response to the 1970 project, the word would gradually get out to the many potential interns and HEW staff candidates for the project office that the project was yet another ineffectual evaluation and the initial hope that excited a great deal of enthusiasm in and around the project in 1970 would not be present in 1971. AWARD OF 1971 PEBSI CONTRACT An HEW official informed us that in October 1970 the Secretary of HEW made a verbal commitment to fund a PEBSI project in 1971. The official said that this commitment was made by the Secretary at a conference with the PEBSI interns and was reaffirmed in his speech before the Na- tional Student Symposium on the Presidency in December 1970. In a letter dated December 9, 1970, to the HEW Director of Field Evaluation, office of the Assistant Secretary for Planning and Evaluation, the president of BLK made refer- ence to the Secretary's commitment Pnd re-requested a modi- fication to the BLK contract to allow it to continue the PEBSI project for another year. The president stated that, if the contract could not be modified, BLK should be al- lowed on the basis of its performance to enter into a sole- source contract so that work on the project could continue without major interruption. HEW entered into a contract, effective April 26, 1971, with the Small Business Administration (SBA) for the con- duct of the 1971 PEBSI project. The contract stipulated that BLK, as a subcontractor, would perform and fulfill all the requirements of the contract, instead of SBA. SBA's cost-plus-a-fixed-fee subcontract with BLK involved about 67 interns evaluating nine HEW programs, at an estimated cost of $502,900. SBA officials informed us that this contracting ar- rangement was made pursuant to section 8(a) of the Small Business Act which authorizes SBA to subcontract with small business firms for the performance of SBA contracts with other Federal agencies. SBA regulations state that the 27 purpose of awarding such subcontracts is to assist small business firms not yet able to compete effectively in the marketplace. The contract files showed that HEW had in- formed SBA in January 1971 that it would award the contract to SBA conditional upon BLK's qualifying for section 8(a) subcontracts and being approved for the subcontract. An SBA official informed us that BLK was approved as a section 8(a) subcontractor on the basis of the determi- nation that BLK had not attained the goal of self- sufficiency. He stated that this determination was based primarily on the firm's financial position and lack of experience in business. Conclusion The Abt Associates final evaluation report was criti- cal, in part, of the PEBSI project but pointed out that with certain changes the project could become successful. The BLK report and the HEW-PEBSI project staff report both generally disagreed with the Aht Associates evaluation of the project and stated that 'he PEBSI project was a success. HEW recently requested its operating groups, responsible for the 15 programs evaluated by BLK, to comment on the BLK report. A contract was entered into for a 1971 PEBSI project, however, without benefit of these comments. Comments from the HEW groups responsible for the 15 programs should have been obtained and the comments and the BLK report should have been fully evaluated before a con- tract was awarded for a 1971 PEBSI project. 28 CHAPTER 5 BACKGROUND OF PRINCIPAL CONTRACTOR PERSONNEL In accordance with Congressman Patman's request, we obtained background information on the BLK key personnel. The information which we obtained follows. The president of BLK has a bachelor's degree from Roo- sevelt University in Chicago, Illinois, and is a specialist in programs for economic and manpower development. He has served as a manpower development and training specialist for the Department of Labor and has supervised work on the development and evaluation of educition, housing, child care, and economic development programs of migrants and seasonal farm workers for the Office of Economic Opportunity. He had been with another private consulting firm for 3 years prior to the establishment of BLK. The vice president of BLK has a master's degree in sociology and has completed the course work for a doctorate degree at the University of Chicago. he was actively in- volved as a worker in the civil rights movement from 1964 to 1968. During this period he worked as a consultant in the areas of urban development, juvenile and family prob- lems, and social organization. Prior to this he worked with the Joint Youth Development Committee of Chicago, where he designed and developed a law enforcement program and served as the committee's chief consultant to the Chicago Police Department, community leaders, and juvenile court of- ficials. The original BLK director for the PEBSI project, who resigned on August 14, 1970, due to ill health, had a doc- torate degree in sociology from American University. He specialized in the field of education evaluation, particu- larly education of the economically and culturally disadvan- taged. Just prior to joining BLK in 1969, he served as Chief of the Division of Program Experimentation at the De- partment of Labor, and for a year prior to that he served as Acting Director of the Research Development Branch of the Bureau of Research in the HEW Office of Education. 29 BLK's second director for the PEBSI project, who also served as the director of the PEBSI field operations, was employed by BLK in May 1970. She has a master's degree in social welfare administration and, prior to joining BLK, served as the Midwest Deputy Regional Director of the Com- munity Relations Service, Department of Justice. She has served also as an advisor to the Department of Housing and' Urban Development on the Model Cities program; as the di- rector of staff development for the Department of Public Welfare in Hamilton County, Ohio; and as a social services consultant to the Chicago Commission on Youth Welfare. The BLK Deputy Project Director for Research for the PEBSI project has a doctorate degree in sociology and has had experience as a consultant and researcher for the De- partment of Housing and Urban Development Model Cities pro- gram, and the Department of Labor's Study of Manpower Uti- lization in the Tidewater Area of Virginia. He also served on the Chicago Commission on Human Relations where he par- ticipated in the interview and analysis phases of migration studies of blacks and Puerto Ricans. The BLK Deputy Director for Operations has a master's degree in social work, and has served as an associate di- rector of the Model Cities program for the city of Chicago and as the director of development and planning for youth of the Chicago Commission on Youth Welfare. CONCLUSION On the basis of this information, it appears to us that the persons employed by the contractor generally pos- sessed the education and experience necessary to perform the type of work required by the contract. 30 APPENDIXES 31 APPENDIX I WhIGHI *I Ad CoMMlArrs STATE OP X JMT GCOwM.CoYrm.' ·"IWM&A JINT COMInTTYI MI _ Fl"ea[ P@ gIrM ..^HS.OU ., I.. Congrte of th)etniteb Stattes OrcTMU ,,,,,,_ ~ Roust of tprtesttntatib R' P.O. ox 'U. TEXuuARA. CA NM- =I (u~binPom. C 20516 June 6, 1970 Honorable Elmer B. Staats Comptroller General of the United States General Accounting Office 441 G Street, N. W. Washington, D. C. 20548 Dear General Staats: Enclosed for your kind attention is my file with respect to the Programs Evaluation by Summer Interns (PEBSI) project funded by the Department of Health, Education and Welfare and under the supervision of Dr. James 6. Abert, Deputy Assistant Secretary for Evaluation and Monitoring. The project involves a contract in the amount of almost qo90,000 with BLK, Inc., a private firm based here In Washington. As you will note in the attached correspondence, it is my contention and that of'a number of professionals in the field of education that the project represents an Indefensible waste of Federal funds. I also concur in the views of the National Education Association that the contract for the project was entered into without proper authority, without justifiable cause, and in violation of the Intent of Congress. If you have not already done so, I respectfully request that you order a prompt and thorough examination of this project and contract. Your assistance in this regard will be deeply appreciated. With kindest regards and best wishes, I am Sincerely yours, 33 SCalUWlE Or SURCE O FUNDS FOR THE PIRUOJT AD PR3G4HS EVALUATED DUING THE PUSI PRTOJiT Amounts Authority to Proarems provided expend funds vautad for PIBSl for evalua- under PEBSI A8socY Budset cateiory proet tion Durpoyes Proiect Office of Education Higher education $ 82,650 20 U.S.C. 1222 Upward Bound Student aid Do. Elementary and second- ary education 110,175 do. Bilingual educa Title I-cope tory and sigr education Do. Research and training 19 8 . 6 75 a do. Office of Education Libraries and comunmity Adult basic edu services 27,550 do. cation Health Services and Mental Health Ad- Comprehensive health ministration planning and services 5,500 42 U.S.C. 246(e) Rat control Do. Hental health 2 154,275 42 U.S.C. 688(p) Comunity mntc health centers Do. Haternal child health Maternity and i and welfare 164,525 42 U.S.C. 713(b) fant care Children and youth projects Family planning Social and Rehabili- Development of prograst Foster Grand- tation Service for the aging 55,100 42 U.S.C. 3031 parents 42 U.S.C. 3031(d) Title III, ld Americans Act 1965 Do. Cooperative rescarch or Social Services demonstration projects 88,150 42 U.S.C. 1310 recipients of a for dependent dren Do. Grants for rehabilita- tion services and facLl- Vncational rehal ities 55,100 29 U.S.C. 37(e) tation Office of Economic Economig opporttLnity Opportunity program 50,000 42 U.S.C. 2826 Project Head Sto $991 700 aFunds for a11 educational programs. bProJect Head Start is administered by HEW but is funded by the Office of Economic Opportunity. APPENDIX II Description of projrM Designed to develop skills and motivation necessary for success risk high school students, 90 in college in academic percent of whom must be from low-income families. Grants to 2- and 4 -year colleges assignments, on and off campus, and to nursing and vocational schools for work-study for students with financial need. Designed to meet the special educational years who have limited English-speaking needs of children aged three to eighteen dominant language is not English. ability and who come from families where the Grants to school systems throughout centration of low-income families the States, to be used in areas with to provide compensatory programs to a high con- tionally deprived children up bring educa- to normal achievement levels. Designed to provide basic curriculum ment levels in math, speaking, to people over 16 years of age, reading, or writing English whose achieve- are below the 8th grade. Provides direct grants to supplement tiate new ones. ongoing urban rat-control projects and to ini- Provides construction and seed money for community and mental Provides prenatal and postpartum health centers, care to women to reduce maternal and infant mortal- ity and morbidity. Designed to provide screening, dental, to children of preschooldiagnosis, and preventive service, both medical and and school age. Prov!Jes assistance in areas with high low-income families to any low-income infant mortality rates and a concentration of woman wishing family planning help. Men and women over 60, with low incomes, who work 20 hours deprived, and physically or mentally a week with years of age. handicapped children from infancy neglected, through 16 Designed to help the elderly maintain their independence and to help them stay actively while living in a community involved in community life. Provides a variety of social services to present and potential dependent children and to adult recipients of aid for services offered are determined relatives of dependent children. Eligibility and at State and local levels respectively. Provides counseling, work experience services designed to make employable and job training, and related rehabilitation or a person who is disadvantaged a person with physical or (sometimes interpreted to mean mental disabilities poor). Open to preschool children, 90 percent of whom must come help prepare them for school. from low-income families, to Each involvement, and education componentsprogram must include health, nutrition, parent and aides. and a career development program for teachers U.S. GAO, wob., D.C. 35
Examination of Project Using Summer Interns for Programs Evaluation
Published by the Government Accountability Office on 1971-08-18.
Below is a raw (and likely hideous) rendition of the original report. (PDF)