oversight

Administration of Grants by LEAA

Published by the Government Accountability Office on 1971-07-22.

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

                                                                                                        i.
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                                                                                For release on delivery
                                                                                Expected at 10:00 a.m. EDT
                                                                                Thursday,  July 22, 1971



                                 UNITED STATES GENERAL ACCOUNTING OFFICE
                                         WASHINGTON, D.C.  20548

                                            STATEMENTOF
                          GREGORY J. AHART, DEPUTY DIRECTOR, CIVIL                                 DIVISION          bc/
                                                                                                                      Lo3
                        BEFORE THE LEGAL AND MONETARY AFFAIRS SUBCOMMITTEE
                             OF THE COMMITTEE ON GOVERNMENTOPERATIONS
                                     HOUSE OF REPRESENTATIVES



                                        c
                                      ADMINISTaATION OF GRANTS BY
                             THE LAW ENFORCEMENTASSISTANCE ADMINISTRATION-j


        Mr.    Chairman      and Members of the Subcommittee:

                We are here          today     to discuss        reviews         we are making                of programs               3

        authorized        by title      I of the Omnibus            Crime Control                 and Safe Streets                Act

        of 1968 and administered                   by the Law Enforcement                  Assistance             Administration
    I   (ml,         Department        of Justice.
i
                The objective          of the act is           simply           stated     in 12 words:                   '"To pte-

        vent    crime     and to,insure            the greater      safety           of the people."

                Declaring      crime         to be essentially            a local        problem,             the act provides

        for    planning      and lawenforcementgrants                     to State         and local            governments,

        namely:

                --planning       grants        to State      Planning           Agencies     for        development

                   of State-wide             comprehensive        plans         which    establish             priority

                  programs       for    the improvemeAt            of law enforcement                        throughout

                   each State.
         --action            grants       to State          Planning           Agencies       for     subgranting

             to State           and local           governments           to be used for                projects

             conforming            with         the comprehensive                plans.           These grants,

             which         account        for     85 percent         of the funds                 provided          for

             action          grants , are called                 block         grants      and are allocated

             among the States                    according        to their          respective           populations.

         --action            grants       to units          of State           and local          governments              as

             LEAA may determine.                       These grants 9 which                   account         for         15

             percent           of the funds            provided          for     action       grants,         are

             commonly           referred          to as discretionary                     grants.

As the result                of amendment on January                      2, 1971,           the act         also         provides        for

grants       for         correctional            institutions            and facilities               with     the stipulation

that     50 percentof                   the funds          appropriated            for     that     purpose          be made

,avaiPable          to State            Planning       Agencies          and that          the remaining                  50 percent

be allocated               as LEAA may determine.

         In addition              to the foregoing                planning          and action           grants,               the act

provides           for      training,           education,        research,              demonstration,              and special

grants       and,         among other            things,        authorizes          the Administration                         to carry

out programs               of academic            educational            assistance           to improve             and strengthen

law enforcement.




                                                                                                                                  -2-
                                                        BLOCK GRANTS


        We have recently                  completed            field      work on a review               of the block

grant    program         and are evaluating                      the results.            The block         grant     program

accounts      for       the major            part            of the total           funds     appropriated           to LEAA

in fiscal       years        1969 and 1970 and administration                                 of the program              forms

the principal            focus       of LEAA activities.

        In the course               of our review,                we visited          State      Planning         Agencies        in

California,           Illinois,           and New York,                 as well      as selected          local     agency

subgrantees           in those         States.           These States               were chosen for              review     be-

cause they           collectively             received           about      one-fourth          of all     block      grant

funds    awarded.

        While        we have not yet arrived                           at firm      conclusions          on our findings,

we are concentrating                   our attention                   on several       basic     areas      which may be

of interest           to the Subcommittee.

PROGRAMINERTIA

     The high priority   which Congres_s placed on the need to fight    crime
      .
and improve the criminal   justice system--police,  courts, and corrections--

is evidenced            by the rapid                growth       in funds         made available           for      LEAA

activities.            Appropriations                  for     fiscal       years     1969,      1970,     and 1971 totaled

$63 million,            $268 million,                 and $529 million,               respectively.               Appropriations

authorizations             for      fiscal          years      1972 and 1973 are $1.15                    billion         and

$1.75     billion,         respectively.

        There has been a slowness                             in using          the appropriated           funds.          For

the three         States          which      we visited;               LEAA allocated           $49.5     million         in block

grant     funds       appropriated              for     fiscal          years     1969 and 1970.             As of

December 31, 1970:


                                                                                                                           -3-
         --only          $11,9 million          had been withdrawn                  by the three               States.

         --only          $9.2 million         of this        amount had been forwarded                          by the

               State      Planning         Agencies     to State          and local          units       of govern-

               ment.       As will         be discussed         later,          not all      of the $9.2

               million       had been expended               since       some part          represented           cash

               being      held     by the subgrantees.

While         expenditures          should      be made only             when it         appears        that     a useful

result         will      obtain,       we believe       that     the inertia              evidenced            by the

aforementioned               figures        is a matter        which           should     be of concern             both

to the Congress               and LEAA, particularly                     in light         of the high            priority

assigned          the program,

         It     may be that            expectations          have been too great,                       The sudden

infusion          of substantial             amounts of money on the one hand,                                 and a

stated         policy      of reliance          on local        initiative              and administrative

machinery             on the other,          could     be expected              to open the door to dif-

ficulties     and delay.
       t
         Some difficulties                  of LEAA which            may have contributed                      to delay

have already              been well         publicized--        such as the inability                     of the

administrator               and the two associate                administrators                to reach          a con-

sensus on certain                  matters      and the recent                 lo-month      period        during        which

the position              of administrator             was vacant,

         Other,          more specific          explanations             for     delay     iwhich we have heard
                                                                                             1
in our discussions                  with     State     PlanningrAgencies’                   officials           have been:

         --an         unwillingness          by State        and local           agencies        to undertake

               some of the projects                  under     programs          planned       by the State

               Planning          Agencies,      and


                                                                                                                       -4-
         --various     difficulties        in arranging     for matching funds.

         Within the past year LEAA:, evidencing                concern about the small
percentage of block grant funds which have been received                       by sub-
grantees,      requested comments by the State Planning Agencies.                     In a

February 1971 summary of excerpts                   from the responses received,       LEAA
stated that it was difficult                to draw conclusions       from the comments pro-

vided.      The summary presented a wide-range of comments on problems
encountered,         including    the aforementioned         categories.

         In this connection,           one of the goals identified         in May 1971 by
an LEAA Task Force, which was appointed                    by the Administrator      to study
the LEAA program, was to improve the t1delivery'8 system.                     It proposed
to. accomplish this by greater               delegation     of authority   within    the
organization,         including       decentralization      of LEAA operations      by ex-

panding the authority,            responsibility,         and capability   of the regional
offices.
PROJECTS SIMILAR TO THOSE OF OTHER PROGRAMS

          It     is clear      that     in enacting          the Oma-Gbus Crime Control                     and Safe

Streets          Act Congress          intended      a comprehensive              attack     on the crime

problem          including      concentrated           efforts        at improvements          of the criminal

justice          system.

          The Act authorized                  the Administration              to make grants          for     certain

enumerated           purposes         which     included:

          public        protection;

          recruiting         and training           of law enforcement              personnel;

          organizing,       educating , and training      of special units
          to combat organized        crime and to prevent,        detect, and
          control     riots   and other violent     civil   disorders;

          recruiting9   organizing,                 training,         and educating          com-
          munity service officers;

          developing     and operating   community-based    delinquent     pre-
          vention and correctional       programs* emphasizing      rehabil-
          itation    centers;   expanded probation    programs; community
          service centers     for the guidance and supervision         of
          potential    repeat youthful    offenders;

          construction     of facilities         to fulfill    or implement the
          foregoing    purposes,      including     local   correctional      facili-
          ties,   centers for the treatment             of narcotic    addicts,       and
          temporary courtroom         facilities      in areas of high crime
          incidence.

          We have found,              however,      that     about     30 percent          of the grant         funds

approved          through      December 31, 1970,                by the State         Planning        Agencies          in

California          and New York have been for                       projects      dealing     with         the under-

lying          causes    of crime       rather      than     the criminal          justice     system.          Many

of these          projects      are in program              areas     that      are administered             by other

Federal          departments          and agencies,          notably         the Departments          of Health,

Education,           and Welfare         and Labor,          and the Office           of Economic

Opportunity.

                                                                                                               -6-
          Examples        of these         projects           are:

          1.       Two consecutive        6-month subgrants af $108,000                                  each were
                                         4
awarded to.sustain                a youth employment service project.                                  The project             was

to provide            vocational          education           and training,             individual           and group

counseling,            remedial          education,           job development:             and placement,               and had

been previously                 funded     by OEO through                 a city       manpower and career                 de-

velopment           agency.        This         project       is similar             to the Department            of LaborIs

Neighborhood            Youth      Corps program                which      also       provides       an out-of-school

program           to assist       economically               deprived        school      dropouts         to obtain

practical           work experience               and on-the-job              training        as well         as in-school

and summer programs.                      Another          Department         of Labor        program         provides

occupational            training          for     unemployed            and underemployed              persons         who could

not     reasonably
               *              obtain      appropriate            full-time            employment.            Zn addition,

HEW’s Social            and Rehabilitation                    Service        provides       grants       to assist

State       and other          public      or private            non-profit           agencies        in providing

training           services       to clients              to prepare         them for       gainful       employment.



          2.      A subgrant           of $75,602          was made to a county                  board       of education             to

aid kindergarten                 pupils         with      potential        chronic        learning       problems.             Under

this      pilot      project,          to be operated                 in a selected         school,          special       student

observation            techniques               and parent            interviews        were to be used to identify

the roots           of potential           learning           problems        at      the kindergarten            level.

Project           personnel       and special              consultants            were to assist             teachers       in the

use of individualized                     instructional                techniques        and interested            parents

were to be provided                    advice          on preparing          their      children       for     progress          in

school,.       The theory          underlying              the development              of the project            was that

                                                                                                                         -7-
by assisting             schools       in reducing          the incidence              of chronic          student         failure

this      progra;n       would,     over       the long      run,     have an influence                   in helping            a

broader         spectrum       of young people              to become less              delinquency          prone.             Under

the Elementary              and Secondary           Education         Act,      HEW makes funds              available               to

assist         States     in providing           programs      for     educationally               disadvantaged

children        e Also,        grant     programs       in the juvenile                 delinquency          area are conducted

by HEW under             the Juvenile           Delinquency          Prevention           and Control         Act      of 1968.

          3.      A subgrant        of $100,000        was made for              participation              in a city               metha-

done project             designed       to test      the feasibility              and efficiency               of methadone

maintenance             as a treatment           modality      for     heroin          addicts.           The block         grant

funds      were part         of the $1.8 million               estimated          project          budget      for     the

period         November 1969 through                June 30, 1970,              $1 million          of which         was pro-

vided      by the National              Institute      of Mental             Health,       HEW.

          While      the funding         of projects          such as these               are permissable             under           the

broad      coverage         of the act,          the substantial              funding       of projects             outside

the criminal             justice       sys tern is somewhat at odds with                          the emphasis             of the

program         as publicly         expressed        by LEAA.          In its      December 1970 “LEAA News-

letter”         LEAA stated. .

          It* * * LEAA does not seek to solve social and economic                                            problems
          which contribute      to crime.    That is the resg*ns ibil ity                                     of other
          Federal and State agencies.         The purpose of LEAA is to                                      give
          large-scale    financial    and technical    aid to strengthen                                    criminal
          justice    at every level throughout      the nation.”

Also,      in congressional              testimony        an LEAA Associate                 Administrator             stated

that      there     are other          Federal      programs        and State           programs          designed         to

work in areas             deaiing       with     the causes         of crime.

          We think        the funding          of such projects               logically           gives     rise     to

several        questions       .    Are monies        appropriated             by the Congress               for     LEAA block

grant      activities         to some extent           merely         financing           old programs             under
                                                                                                                          -8-
a new label?                Will         the diffusive             effect       of channeling                    funds          into      projects

which         deal   with        the underlying                causes         of crime            detract         from          the attention,

as well         as the funding,                   which     will       be focused             on the police--courts--cor-

ret t ion areas ?                Which leads              to a final           question...                Is prevention                   of

crime         a workable           criteria          in delineating                 block         grant     program              limits            when

the causes           of crime             are commonly thought                      to be related                 to education,

employment,             housing,           and so forth--fields                      where Federal                 activities                  are

administered              by other            departments            and agencies?

           LEM guidelines                  require         that      the State             comprehensive                 plans          include

discussion           of programs               within       the States              that      have a relationship                             to

law enforcement,                   such as urban               renewal,         model cities,                    comprehensive                     man-

power,         poverty,          or education             programs.             Specific            information                  is also

required          on the plans’                relationship             to,     and coordination                        with,          the juvenile

delinquency             programs           of HEW and the law enforcement                                  aspects          of the model

cities         program       and Highway              Safety        Act.        We found            that,         for      the most part,

the 1970 State               plans         of California,               Illinois,             and New York                 included

mere1y.a          brief      description              of the programs                 available             and,         in some instances,

listings         of funds           received.             There       was little             mention             of the extent                     of

coordination              by the          State      Planning          Agencies            with     other         agencies.

         It     has been recognized                     that       crime       is primarily               a local           problem                to

be dealt         with      by the State              and local             governments              and State             agencies                 have

been established                   for     the purpose             of coordinating                  activities              in this                area.

These State             agencies           should       provide         the focal             point        for     determining                     the

types         of projects           needed-- those                directly          related         to the criminal                       justice

system         and those           related        to the underlying                   causes          of crime--and                     for

coordinating              with      the appropriate                 agencies          for      the necessary                    support.

                                                                                                                                         -9-
EVALUATION OF PROGRAMAND PROJECT EFFECTIVENESS

          Title     I of the act authorizes                         LEAA to "conduct              evaluation         studies

of the programs and activities                            assisted           under the title"              and also

authorizes          LEAA"s National               Institute           of Law Enforcement                  and Criminal

Justice       to make continuing                  studies           of the effectiveness                  of projects

and programs carried                 out under title                  I.       In turn,       LEAA has advised

the State Planning              Agencies           that       their         responsibilities              include

evaluations          of the total           State effort                   in implementing              plans and im-

proving       law enforcement;

          LEAA has done little                toward making its                    own evaluation             of the

effectiveness             of programs or projects                          funded with        block grants,

Also,      LEAA has not provided                   the State Planning                  Agencies           with     the

assistance          necessary        to    perform         such evaluations                in their          respective

States,

          In the SPA Guide for                1969 (a manual issued                       by LEAA to the State

Planning          Agencies     for guidance               on application,              award,           and administra-

tion'of       planning        and block           grants),           LEAA stated          that     it     would issue

guidelines          suggesting        appropriate              procedures,           techniques,             and measures

for     evaluating         the contribution                to crime control                of the block grant

projects          and expenditures.                The Guide provided                  that       the State Planning

Agencies , pending             issuance           of the guidelines,                 outline            in their     1969

State plans a tentative                    program for               project       evaluation            and measure-

ment of overall              plan performance.

          Prior     to    submission        of the 1969 State plans,                          however,        LEAA, in

the interest             of saving        time,      simplified              the plan requirements                  and

elilninated         the provision           calling           for     an evaluation              program description,,

Subsequent editions              of the SPA Guide for                          1970 and 1971 also omitted

reference          to such a program.
                                                                                                                    - 10 -
         We were advised            by LEAA that                it    had not issued                guidelines              to

the State       Planning       Agencies          on evaluation                 methods          because        of a

shortage       of manpower0            Also,      we noted             that      on occasions                information

or guidance        has been requested                   from         LEAA on monitoring                    and evaluation

methods      and LEAA has been unable                          to provide         the assistance.

         A somewhat better             picture          is seen at the State                        level      but,     there

also,      more remains        to be done than has been done.                                     All      three      States

we visited       had taken          steps      to measure              the effectiveness                     of individual

projects       and consultants              were used for                such purposes.

         In California        we found           that      all        projects          were required               to have

an evaluation           component       and that           evaluations             were being                made, but

procedures       had not been developed                        for     systematic              utilization            of the

final      evaluation       reports.           In Illinois              we noted          instances            where the

consultants        stated      that     they      were not able                  to fully           evaluate          the

projects      because       they      believed          project         goals      and objectives                   were in-

adequately       defined      and/or        necessary                records      for     an evaluation                were

not established            or maintained.                In New York only                      a minimal           number of

evaluation       reports      had been received                       at the time              of our review            and none

had been accepted            by the State               Planning          Agency staff                  as final.           However,

none of the three            States      had developed                   systems         for      evaluating           the

effectiveness           of State-wide            efforts             to improve          law enforcement                programs,

         LEAA officials         told     us that2              although          evaluations              had been made

of certain       specific       activities,              an overall              assessment              of the law

enforcement       assistance           program          will         not be possible               for       a number of

years.       They also       told      us that,          with         some exceptions,                   the State

Planning      Agencies       had not attempted                       to measure          the impact            of their

                                                                                                                       - 11 -
projects           because of a shortage                 of planning          funds,     especially        in the

smalier           States.       In a statement             to the $reau            of, the Budget         in April

1970,       LFAA explained             that      the State         Planning      Agencies      in the first

few years           of operation,             had been so totally               involved      with    planning

and program            development            that    virtually        no resources         had been devoted

to project            evaluation.

          We do not           think    the matter          can be allowed           to rest.         Evaluations

of project            effectiveness            are vital          to. the administration             of a program

where :

          --it       is hoped that State and local governments will                                  be
                 induced to assume the costs of improvements    after                                a
                 reasonable  period of Federal assistance,  and

          --the basic planning                   is performed  by 55 different  plan-
              ning organizations,                  all having a use for such information,

And, finally,               the cost      and urgency             of the program           demand some re-

porting           as to whether         the individual              projects,       the State        comprehensive

plans , and the LEAA program                         are reaching         toward       the statutory        goals    of

preventing            crime     and ensuring           the greater         safety       of the people.




                                                                                                                 - 12 -
DZSSEMTNATIQN OF INFORMATION ON RESE&RCN ACTIVITIES

          The act        authorizes       LEAA to collect             and disseminate                    information              on

 the condition            and progress           of law enforcement                  in the States.                 It     also

authorizes          the LEAA Na.tional               Institute       to collect              and disseminate                 infor-

mation         obtained      by recipients            of LEAA funds               and to recommend actions

 which        can be taken       to improve           law enforcement.                    LEAA, however,                 has not

 been in a position              to provide           the State       Planning             Agencies         with         infor-

 mation        on block      grant      projects        which      have been proven                 to have an impact--

 or no impact--           on the criminal             justice       system.

          In a September              1970 reply        to an Illinois               State        Planning         Agency

 official’s         request      for     information             on programs             and projects          that        had

 been successful             and that       had failed,            LEAA stated             that     it     was in the

.process        of, developing          an information             system         but:

          ‘I* *    *At present,     we have to rely on LEAA’s annual report,
          soon      to be released,     and upon discussions       and contacts    that
          take      place at regional     and national     meetings of SPA personnel.
          The     former may be too sketchy to provide an adequate insight
          into      the nature of demonstration        programs,    and the latter      are
          not     well structured     for in-depth     exchange of information.

          ‘At the moment,              therefore,        we are unable               to respond            to you
          with sufficient              infomation.         * * *‘I

          As we have just              discussed,         the fact         that      evaluations            of project
   --
 effectiveness            are not being            made in an organized                    and systematic                 way

 is the first            stumbling       block       to adequately            informing            State     Planning

Agencies         about     projects       in other        jurisdictions.

         There     remains      the matter           of simply       informing             th3 State         Planning             Agencies

of the research             projects       (such as studies            , experiments,                demonstration                 of

pilot     projects)         which have been or are being                          supported         with     block         grant

funds.         Some progress           has been made, but it                 has been slow and much

remains        to be done.            The major       effort       to date has been the Institutes’
                                                                                                                              - 13 -
Federal-State          Criminal            Justice          Research           Index       which         was

released       to the State               Planning          Agencies            in January              1971.       This        index

was corKpiled.        from     replies            to requests                sent     to the State               Planning             Agen-

‘ties    for   summaries        of all             research          projects            that     they         were funding.

        The Index          is only         a partial              listing.            Apart       from         the fact         that

only     19 States         furnished             items      for      inclusion,            it     appears          that        those        con-

tributing       did    not     report            all     research            projects.            Two of the States--

California        and New York--included                           in our review                 accounted             for     118 of

the projects          listed       in the Index.                    Our review             of projects                 approved         by

the two State          Planning            Agencies           turned          up 187 projects                   which         appeared

eligible       for    inclusion.

        The Institute            is planning                to establish               and operate               a national

reference       service        which        it         envisions        will         disseminate               infonnation             on

law enforcement              research,including                      research            under         block     grants,and             will

aid     in prevention          of needless                 repetition               of projects            and in the widespread

adoption       of those        which        have merit.                 We understand,                   however,             that     the

Institute       is only        in the process                     of awarding             a contract             for         design     of

the service          and that        it     will         not be operational                      for     several             more years.

        The importance            of dissemination                      of      information              on LEAA block                 grants

is underlined          by the substantial                         amounts           of monies           being      channeled            into

research       projects.          As an illustration,                           the 187 research                   projects

approved       in California               and New York accounted                          for         $14.7     million,             or 54

percent,       of the total          $27.1’             million        approved           for     funding          in those            Stat2s.
UNANCING OF PRQJECTS

         When a grant           has been awarded                 to a State           Planning        Agency,       LEXA uses

the letter-of-credit                 method for           financing           cash advances.                  The letter           of

credit       is a commitment             specifying             an amount which              the recipient              may

withdraw,        when needed,            through         any commercial               bank which         it     selects,by

issuance        of a payment            voucher.          The purpose           of this        method of financing

is to reduce           Federal       debt    levels            and the interest              cost     of borrowings.

         We reviewed           letter-of-credit                 reports       submitted         to LEAA headquarters

by 52 of the 55 State                   Planning         Agencies           and found         that,      contrary             to

the Federal        Government's             policy        and LEAA instructions,                      excessive           cash

balances        were maintained             at the State             level.           The Agencies             had main-

tained       a combined         average      monthly            cash balance           of about        $11 million              for

planning        and action         grants         (the    major      part      of which         is block          grant       funds)

from the time           that     LEAA adopted             the letter-of-credit                      system      in July         1969

through       December 1970.              These balances                  resulted       in interest            costs      of

about       $973,000      to the Government.                     We believe           that    interest          costs      could

have been reduced               substantially             if     withdrawals           had been more in line

with     the immediate           cash needs.

         When we brought             the matter           of excess           funds     to the attention                  of the

California        State        Planning      Agency , we were advised                        that     the Agency would

begin       withdrawing         funds     on a weekly             basis       instead        of monthly          as it      had

been doing,        which        should      reduce        the outstanding               balances.              The Treasury

Department        instructions            provide         that      the timing          and amount of cash

advances       be as close           to actual           daily     disbursements              as is administratively

feasible.                                                                                                                 - 15 -
        We also noted             that     the State       Planning      Agencies      were advancing

grant     funds to subgrantees            in amounts greater                than     necessary       to .meet
                                        8
their     actual        needs,     thus further  increasing               the interest        cost     to the

Federal        Government.          In the three           States      reviewed,      we visited       27 sub-
           .
grantees        and found         that     13 of them had funds             in excess      of current       re-

qui remen ts .          For example,         in Illinois        4 of 7 subgrantees            were advanced

funds      3 to 5 months           before     the funds        were needed.           One subgrantee        had

received        about     $58,700        of a $117,000         grant     in August      1970 and in

January        1971 the subgrantee             still       had the funds           and did not anticipate

spending        them for         several     more months.




                                                                                                          - 16 -
LEAA AUDIT OF STATE PLANNING AGENCIES

          In May 1969 LEAA informed                     the State               Planning          Agencies         that     it

intended      to conduct         an annual             audit     of grant            fiscal         administration                     of

each agency with            major       emphasis         on evaluation                 of grant            accounting             and

control      systems       and limited            sampling         of individual                   grant      programs            at

both      the State       and local'level.                 Since         that       time      overall         reviews            have

been made in only             four      States--Florida,                   Maryland,           Alabama,            and

Massachusetts--and             a report           has been prepared                    on only          one of these

reviews--Florida.              However,           LEAA has conducted                       miscellaneous             audits,
     .
reviews,      and investigations                  under        various           programs          and prepared             reports

on those      reviews0

          At June 1, 1971,            LEAA's audit              staff           had 26 professional                  auditors,

including       seven transferred                 on a temporary                  basis       from      the Department

of Justice       central       staff.           LEAA, in its               fiscal          year      1972 budget,                re-

quested      additional        positions           to increase                  the staff          to 38.          We believe

that      LEAA's audit        staff      would have to be increased                                substantially                 over

the 38 professional              positions             requested           to provide              adequate         audit

coverage      of the 55 State                Planning          Agencies           and the 50,000               active            grants
                                                               /
and contracts         estimated          for      1972.

          We were recently            told      that     LEAA's audit                staff         began on-site                 sur-

veys of the State            Planning          Agencies          and that            all      States        will     be visited.

Following      the surveys,             the staff          plans         to make financial~compliance

audits      at 21 selected            States.           Also,      at the direction                     of LEAA head-

quarters,      LEAA regional             office         personnel               recently       visited         the State

Planning      Agencies        and completed               check         lists       covering          their        operations.

We noted      that    information              shown on the check lists                            indicated         that         no

audits      of subgrants         had been made in many States,


                                                                                                                            - 17 -
STATE PLANNIN(; AGENCY AUDITS OF SUBGRANTS

        LEAA’s objective                     is    to assist              the State        Planning           Agencies          in

developing          sufficient              audit         capability            so that        it     can delegate             certain

audit    functions            to them.                  According          to LEAA’s survey                data,      only       a few

State    Planning          Agencies               now have sufficient                     capability            to audit         subgrantee

activities          and some agencies                       have no audit             staffs          at all.         It      appears

that    there       will      be very             limited          auditing        of subgrantee               activity          until

LEAA succeeds              in developing                  audit       capability           at the State              level.

        During       our visits               to the three                States      and to selected                 subgrantees,

wa found        a variety            of administrative                        and financial            deficiencies              indicat-

ing a need for             more State                   audit      efforts.          Some cases            in point:

        --Records            kept      by some subgrantees                        were not adequate                  to

             properly         account             for     grant       funds.         For example,              the books

             of account             of one New York                   subgrantee           were incomplete                 and

             disorganized              rendering                them unauditable.                    The subgrantee,

             a nongovernmental                     agency,          has since         contracted              with    an

             accounting             firm      to revise             its       accounting            system.

        --The       entire          salaries             and fringe            benefits        of the probation

             officers         were included                     as the subgrantee’s                   matching        con-

             tribution         in a New York project                            to train        paraprofessionals

             to perform             the routine                 duties        of probation            officers.            We

             were informed                 by the project                 director         that,       in addition             to

             the probation                 officers         ’ training           of the paraprofessionals,

             they    were to perform                      their       normal       duties.            While       records        of

             the time         actually             spent         training        the paraprofessionals                      were


                                                                                                                                     - 18 -
  not maintained,              it     appears       that     only     part     of the probation

  officers       ’ salaries,          should       have ‘qualified           for    matching

  purposes.

-4ommunity         aides’who,            by the terms           of a New York project,

  were specifically                  limited       to police-community                relations

  work,      were spending             a portion           of their       time     on functions

  which      were within             the jurisdiction               of other       city     agencies.

  For example,            aides       assigned           to one community           service        center

  were performing              clerical          duties      in neighborhood              health     and

  urban      progress        centers.

--Timely       follow-up            on reported          deficiencies            in a public        defender

  services        project           was not made by an Illinois                     State      Planning’

  Agency.         The monitor             was advised          by an independent               evaluator

   that:       clearly       defined           functions       and responsibilities                 were

  not established,                  personnel       were involved            in unnecessary

   duplication           of effort,            certain      professional           personnel        were

   being     poorly       utilized,            and administrative                delays     were

   occurring       in the filing                of appeal       briefs.




                                                                                                            - 19 -
                                          &AW ENFORCEMENTEDUCATION PROGRAM


                 In the Law Enforcement                    Education          Program         LEAA advances                funds         to

     educational            institutions             primarily          on the basis                of estimates            of program

     needs submitted              by the’ institutions.                       In fiscal           year     1970,         about       $18

     million         was advanced            to 735 educational                     institutions.                Because          insti-

     tutions         averestimated               their     program          needs and because                   they     were allowed

     to carry         unexpended            funds        forward      for     use in the succeeding                        fiscal          year,

     large       amounts       of unexpended               funds      remained             in the possession                of many

     institutions,             thereby           increasing         Federal           interest         costs.           In addition,

     interest         costs      were further              increased          because         funds       were advanced                  to
 ,‘i,
 i;!linstitutions             too far        ahead of the time                     that     students       normally           pay their

     tuition         and expenses,
. .A      * Wa.estimated                 that,      from     inception         of the program                   in January           1969

     through        August       1970,       these        practices         have resulted                in unnecessary                  interest

     costs       to the Government                  of about        $440,000.              This      estimate           was based on

     the amount of unexpended                        funds      on hand at the end of each fiscal                                   year.

               We brought         this      matter         to the attention                 of Department               of Justice

     officials         who told          us that         they      were taking             actions       to eliminate               the

     unnecessary            interest        costs        by (1)       delaying            the issuance           of funds           to

     schools        until      the last          possible        moment and (2) completely                             revising          the

     funding        and billing            system        to prov-ide         for      the funding          of institutional

     needs on a term basis.                       This      new system was put in operation                                on July            1,

     1971.




di


                                                                                                                                     - 20 -
    reorganization.                  In May 1971 the recently                      appointed          Administrator             re-

    leased        the report           of a Task Force              which    he had appointed                   to study        the

    LEAA program            and to recommend ways that                       it     could       be made more effec-

    tive.         The Task Force                   recommended a more decentralized                       organization

    for     LEAA, which            the Administrator                approved.             Major,changes           include

             --increased             authority          for     the regional             offices,       which

                  were increased                   from seven to ten,             with      the regional

                  staffs      doubled              or in some cases almost                  tripled      and

             --reorganized                 staff      functions      at LEAA Headquarters                  into

                  five     offices          directly          responsible         to the Administrator.

             In announcing                 the reorganization,              the Administrator                  stated      that       it

    had two objectives                 :      ( 11 to provide         .’ Lang-range          program&. for“%mproving

    the criminal             justice          system and (2)‘.develop                    program        Which-have         an

    immediate            Impact,       especially             on street     crime.

             It    remains         to be seen whether                the reorganization                  and increased
.   emphasis         in certain             areas      will     have a favorable               impact     on the problems

    we have observed.

            That         concludes          my statement,           Mr. Chairman.




                                                                                                                            - 21 -