oversight

Justice Grant Programs: DOJ Should Do More to Reduce the Risk of Unnecessary Duplication and Enhance Program Assessment

Published by the Government Accountability Office on 2012-07-12.

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

             United States Government Accountability Office

GAO          Report to Congressional Committees




July 2012
             JUSTICE GRANT
             PROGRAMS
             DOJ Should Do More
             to Reduce the Risk of
             Unnecessary
             Duplication and
             Enhance Program
             Assessment




GAO-12-517
                                              July 2012

                                              JUSTICE GRANT PROGRAMS
                                              DOJ Should Do More to Reduce the Risk of
                                              Unnecessary Duplication and Enhance Program
                                              Assessment
Highlights of GAO-12-517, a report to
congressional committees




Why GAO Did This Study                        What GAO Found
Since fiscal year 2005, approximately         The Department of Justice’s (DOJ) grant programs overlap across 10 justice
$33 billion has been appropriated to          areas contributing to the risk of unnecessarily duplicative grant awards for the
DOJ for the administration of more            same or similar purposes. For example, GAO reviewed all 253 grant award
than 200 federal financial assistance         announcements that DOJ’s Office of Justice Programs (OJP), the Office on
solicitations, such as grants, that           Violence Against Women (OVW), and the Community Oriented Policing Services
support criminal justice activities at the    (COPS) Office published on their websites for fiscal year 2010 and found overlap
state and local levels. Pursuant to           across the justice areas. For example, 56 of DOJ’s 253 grant solicitations—or
section 21 of Public Law 111-139, this        more than 20 percent—were providing grant funds for victim assistance and
report addresses the extent to which
                                              related research. GAO also found instances where applicants used the same or
(1) overlap exists across DOJ grant
                                              similar language to apply for funding from these overlapping programs. In one
programs and if it contributes to the
risk of unnecessary duplication in grant
                                              example, a grant recipient applied for, and received, funding from both OJP’s
awards, (2) DOJ has taken steps to            Internet Crimes Against Children program and the COPS Office’s Child Sexual
reduce overlap and the potential for          Predator Program to provide training for cyber crime investigations and establish
unnecessary duplication in its grants         an Internet safety program. In some instances, DOJ may deem it appropriate for
awards, and (3) DOJ uses monitoring           distinct grant programs to serve one goal, or for one community or grantee to
and assessment to determine grant             benefit from multiple streams of grant funding. However, DOJ generally lacks
program effectiveness and uses the            visibility over the extent to which its grant programs overlap and thus is not
results to enhance its grant programs.        positioned to minimize the risk of potential, unnecessary duplication before
GAO assessed DOJ’s fiscal year 2010           making grant awards.
announcements of grant award
funding; categorized them according to        DOJ has taken some actions that address overlap in its grant programs; for
key justice areas to identify any             example, by requesting statutory authorization in some instances to consolidate
overlap; and interviewed DOJ officials        programs that are similar. However, DOJ has not conducted an assessment of its
about their grant making practices,           grant programs to systematically identify and reduce overlap. Doing so would
systems, and assessment methods.              enable DOJ to identify program areas where overlap may be desirable and
Further, GAO interviewed officials from       where a consolidation of programs may be more efficient. Further, OJP and
11 states receiving DOJ grants,               OVW use a separate grants management system than the COPS Office uses,
selected for the levels and types of
                                              limiting their ability to share information on the funding they have awarded or are
funding received. Though not
                                              preparing to award to a recipient. According to COPS Office officials, its mission
generalizable, the interviews provided
their perspectives on funding.                and grant management processes are unique enough to necessitate a separate
                                              system. However, OJP officials told GAO that its system has been and can be
What GAO Recommends                           modified with minimal investment to accommodate different grant processes.
                                              DOJ has initiated a study to assess the feasibility, costs, and benefits of unifying
GAO recommends, among other                   the systems among other options. By ensuring that such a study accounts for the
things, that the department assess its
                                              effort necessary to harmonize departmental grant processes, DOJ could ensure
grant programs for overlap, ensure its
                                              that variations in such processes do not encumber system unification.
comprehensive study of DOJ grant
management systems also includes an
analysis of steps necessary to                DOJ’s Office of Audit, Assessment, and Management (OAAM) oversees
harmonize business processes, and             monitoring of grantees’ compliance and conducts grant program assessments to
examine its mix of grant monitoring           gauge program effectiveness. GAO found that OAAM’s program assessments
and program assessment activities.            yield richer information than its monitoring reports because they identify
DOJ agreed with GAO’s                         improvement areas. OAAM officials believe additional assessments could be
recommendations.                              beneficial. They also said they lacked resources to conduct more, but had not
                                              conducted a feasibility analysis to confirm this. By OAAM examining its mix of
                                              monitoring and assessment activities, including the costs and benefits of current
View GAO-12-517. For more information,
contact David C.Maurer at (202) 512-9627 or
                                              resource allocations, it could better ensure continuous improvement in grant
maurerd@gao.gov.                              programs.

                                                                                       United States Government Accountability Office
Contents


Letter                                                                                 1
               Background                                                              6
               DOJ Grant Programs Overlap, Contributing to the Risk of
                 Unnecessarily Duplicative Grant Awards for the Same or Similar
                 Purposes                                                             12
               DOJ Has Taken Actions That Address Overlap in Grant Programs
                 but Could Further Reduce the Risk of Unnecessary Duplication
                 in Grant Funding                                                     20
               DOJ Could Benefit from Examining Its Programmatic Grant
                 Monitoring and Assessment Functions and Considering
                 Expansion of OAAM’s Authorities                                      36
               Conclusions                                                            47
               Recommendations for Executive Action                                   49
               Agency Comments and Our Evaluation                                     50

Appendix I     Objectives, Scope, and Methodology                                     56



Appendix II    DOJ Granting Agencies’ Organizational Structure                        59



Appendix III   Structure, Purpose, and Funding of DOJ Granting Agencies               60



Appendix IV    Consolidated, Braided, and Blended Grant Program Solicitations         62



Appendix V     Office of Audit Assessment and Management Structure                    65



Appendix VI    Comments from the Department of Justice                                67



Appendix VII   GAO Contact and Staff Acknowledgments                                  74




               Page i                                    GAO-12-517 DOJ Grants Management
Tables
          Table 1: Types and Examples of Federal Financial Assistance              7
          Table 2: Breakdown of Fiscal Year 2010 DOJ Grant Solicitations by
                   Granting Agency and Justice Area                               14
          Table 3: Consolidation and Coordination of DOJ Grant Programs
                   and Illustrative Examples                                      21
          Table 4: Comparison of Programmatic Grant Monitoring and
                   Program Assessment Activities                                  38
          Table 5: Comparison of OVW and OAAM Measurement of Grant
                   Program Effectiveness                                          45


Figures
          Figure 1: DOJ Grant Funding Appropriated from Fiscal Years 2005
                   through 2012                                                    8
          Figure 2: Grant Life Cycle of Federal Awarding Agency                    9
          Figure 3. DOJ Grant and Subgrant Award Information Flow to
                   USASpending.gov                                                34
          Figure 4: Consolidated Grant Programs                                   62
          Figure 5: Braided Grant Programs                                        63
          Figure 6: Blended Grant Programs                                        64




          Page ii                                    GAO-12-517 DOJ Grants Management
Abbreviations

BJA               Bureau of Justice Assistance
BJS               Bureau of Justice Statistics
CMS               COPS Management System
COPS              Community Oriented Policing Services
CSPP              Child Sexual Predator Program
CTAS              Coordinated Tribal Assistance Solicitation
DHS               Department of Homeland Security
DOJ               Department of Justice
FEMA              Federal Emergency Management Agency
FFATA             Federal Funding Accountability and Transparency
                  Act
FMIS 2            Financial Management Information System 2
GAT               Grant Assessment Tool
GMS               Grants Management System
GSA               General Services Administration
ICAC              Internet Crimes Against Children
IG                Inspector General
JAG               Edward Byrne Memorial Justice Assistance Grant
NIJ               National Institute of Justice
OAAM              Office of Audit, Assessment, and Management
OJJDP             Office of Juvenile Justice and Delinquency
                  Prevention
OJP               Office of Justice Programs
OMB               Office of Management and Budget
OVC               Office for Victims of Crime
OVW               Office on Violence Against Women
PAD               Program Assessment Division
SAA               state administering agency
VAWA              Violence Against Women Act



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Page iii                                              GAO-12-517 DOJ Grants Management
United States Government Accountability Office
Washington, DC 20548




                                   July 12, 2012

                                   Congressional Committees

                                   Since fiscal year 2005, approximately $33 billion has been appropriated 1
                                   to support crime prevention, law enforcement, and crime victim services
                                   through more than 200 federal financial assistance programs that the
                                   U.S. Department of Justice (DOJ) manages. 2 In fiscal year 2010, DOJ
                                   awarded nearly $3.6 billion in grants through its three granting agencies—
                                   the Office of Justice Programs (OJP), the Office on Violence Against
                                   Women (OVW), and the Community Oriented Policing Services (COPS)
                                   Office. Many of the grant programs that OJP, OVW, and the COPS Office
                                   administer are, pursuant to their originating statutes, similar in scope, and
                                   grant applicants can apply for and receive grant awards from more than
                                   one program. Moreover, statutes may also require that grant recipients
                                   award a portion of their grants to subgrantees. Where statutes do not
                                   require subgranting, a grantee may voluntarily choose to award all or a
                                   portion of its funds to subgrantees. 3 These subgrantees may also apply
                                   directly to DOJ for funding through other grant programs for purposes that
                                   are the same or similar to the purpose for which they received the
                                   subgrant. The number of grant programs and recipients, and the billions
                                   of dollars in funds awarded annually, present administrative challenges
                                   for DOJ.



                                   1
                                    In addition to fiscal year funding from 2005 through 2012, this amount includes $4 billion
                                   appropriated in fiscal year 2009 through the American Recovery and Reinvestment Act of
                                   2009 (Recovery Act) (Pub. L. No. 111-5, 123 Stat. 115, 129-30), which includes $10
                                   million for salaries and expenses to manage, administer, and oversee the grant programs.
                                   This approximate amount does not reflect amounts, if any, that have been rescinded,
                                   reprogrammed, or transferred.
                                   2
                                    Federal financial assistance programs provide funding pursuant to statutory authorization
                                   through formula grants, discretionary grants, cooperative agreements, and other payment
                                   programs, but are all generally referred to as grants. Formula grant programs are
                                   noncompetitive awards based on a predetermined formula, typically established in statute.
                                   Discretionary grants are usually awarded on the basis of a competitive selection process.
                                   A cooperative agreement is a type of federal financial assistance similar to a grant except
                                   the federal government is more substantially involved with the grant. Payment programs
                                   typically take the form of reimbursements to state and local law enforcement entities for
                                   purchases such as body armor.
                                   3
                                    COPS Office, however, prohibits grantees from subawarding any portion of COPS Office
                                   grants.




                                   Page 1                                                GAO-12-517 DOJ Grants Management
We have identified management of programs that support state and local
crime reduction efforts as a major performance and accountability
challenge for DOJ. 4 We previously reported on evaluations of grant
programs to assist communities in addressing gang problems, and the
quality of DOJ’s tool to measure grantees’ performances under Recovery
Act funding for one of OJP’s largest grant programs. 5 Moreover, the DOJ
Inspector General (IG) has listed grant management as one of the top 10
challenges for DOJ every year from 2000 through 2011 and has identified
overlap in grant programs and duplicative oversight and monitoring
services. Specifically, a 2003 IG audit found overlap in grant programs
between OJP and the COPS Office, which it noted resulted from statutes
that created multiple grant programs to fund similar justice areas. 6 The IG
audit also found that no formal communication procedures between OJP
and the COPS Office existed to ensure that grantees did not receive
funds for similar purposes from both granting agencies and made
recommendations to address this coordination issue as discussed later in
this report. In addition, DOJ’s Acting IG testified in June 2011 that certain
monitoring and oversight performed by OVW and the COPS Office are
duplicative of services that are available through OJP. 7

As the United States experiences budgetary constraints, there is an ever-
increasing need to ensure that governmental resources—including those
awarded through grants and subgrants—are appropriately targeted and
that overlap and unnecessary duplication are mitigated. In February 2012,
we reported that DOJ had not assessed its grant programs to identify


4
 GAO, Major Management Challenges and Program Risks: Department of Justice,
GAO-03-105 (Washington, D.C:. Jan. 1, 2003).
5
 GAO, Community Policing Grants: COPS Grants Were a Modest Contributor to Declines
in Crime in the 1990s, GAO-06-104 (Washington, D.C.; Oct. 14, 2005); Combating Gangs:
Better Coordination and Performance Measurement Would Help Clarify Roles of Federal
Agencies and Strengthen Assessment of Efforts, GAO-09-708 (Washington, D.C.: July 24,
2009); and Recovery Act: Department of Justice Could Better Assess Justice Assistance
Grant Program Impact, GAO-11-87 (Washington, D.C.: Oct. 15, 2010).
6
 U.S. Department of Justice Office of the Inspector General, Audit Division, Streamlining
of Administrative Activities and Federal Financial Assistance Functions in the Office of
Justice Programs and the Office of Community Oriented Policing Services, Audit Report
03-27 (Washington D.C.: Aug. 2003).
7
 Hearing before the U.S. House of Representatives Committee on Oversight and
Government Reform Subcommittee on Technology, Information Policy, Intergovernmental
Relations and Procurement Reform concerning Improving Oversight and Accountability in
Federal Grant Programs, June 23, 2011.




Page 2                                                GAO-12-517 DOJ Grants Management
overlap and that DOJ did not routinely coordinate grant awards to avoid
unnecessary duplication. 8 This report provides further elaboration on the
February 2012 report’s findings, as well as addresses DOJ’s ability to
assess the results of its grant programs.

To examine overlap and potential duplication within DOJ—and in support
of our ongoing efforts to explore duplication, overlap, and fragmentation
governmentwide 9—this report addresses the following three questions:
(1) To what extent does overlap across DOJ grant programs exist and
contribute to the risk of unnecessary duplication in grant awards? (2) To
what extent has DOJ taken steps to reduce overlap in its grant programs
and the potential for unnecessary duplication in grant awards? (3) To
what extent does DOJ use grant monitoring and assessment to determine
grant program effectiveness and use the results to enhance its grant
programs?

Using the framework established in our prior work addressing overlap and
duplication, we use the following definitions for purposes of assessing
DOJ’s grant programs: 10

•     Overlap occurs when multiple granting agencies or grant programs
      have similar goals, engage in similar activities or strategies to achieve
      these goals, or target the same or similar beneficiaries. Overlap may
      result from statutory or other limitations beyond an agency’s control.

•     Duplication occurs on multiple levels. It occurs when a single grantee
      uses grant funds from different federal sources to pay for the exact
      same expenditure. Duplication also occurs when two or more granting
      agencies or grant programs engage in the same or similar activities or
      provide funding to support the same or similar services to the same
      beneficiaries. Duplication thus stems from overlap. When granting


8
 GAO, 2012 Annual Report: Opportunities to Reduce Duplication, Overlap, and
Fragmentation, Achieve Savings, and Enhance Revenue, GAO-12-342SP (Washington,
D.C.: Feb. 28, 2012).
9
 We conducted this work in support of our mandate to conduct routine investigations to
identify programs, agencies, offices, and initiatives with duplicative goals and activities
within departments and governmentwide, and report annually to Congress. See Pub. L.
No. 111-139, § 21, 124 Stat. 8, 29-30 (2010) (31 U.S.C. § 712 Note). As such, we
included portions of this report in our 2012 annual report. See GAO-12-342SP.
10
    GAO-12-342SP.




Page 3                                                  GAO-12-517 DOJ Grants Management
    agencies do not identify overlap, assess its impact, or coordinate their
    activities in acknowledgment of the overlap, there is a heightened risk
    of unnecessary duplication because one granting agency may not
    be knowledgeable of the ways in which its funding decision duplicates
    another’s. At times, federal funding is leveraged by design to achieve
    a single purpose through multiple federal funding streams. These
    funding arrangements are not characterized as unnecessary
    duplication for purposes of this review so long as federal agencies are
    aware of them or have deliberately planned for grant programs to be
    complementary.

To determine potential areas of overlap across DOJ’s grant programs, we
identified a total of 253 DOJ grant solicitations—announcements to
applicants of funding opportunities—for fiscal year 2010 by reviewing the
solicitation lists posted on the OJP, OVW, and COPS Office websites and
confirming the accuracy of the information with DOJ officials. We
established 10 categories of criminal justice areas and then sorted the
solicitations into each category to determine whether these solicitations
were announcing grant funding available for similar purposes. We
developed these 10 categories after reviewing comparable justice areas
identified within DOJ materials, such as a website it operates to discuss
criminal justice research and strategic planning documents. After
identifying solicitations with similar scopes, we reviewed a nonprobability
sample of 26 successful grant applications that were awarded under
similar solicitations to identify and assess specific examples of how the
recipients planned to use funds from multiple programs in the same or
similar manner and whether this creates the risk of unnecessary
duplication in DOJ grant funding. The sample was selected based upon
applicants receiving multiple grant awards from overlapping grant
programs. The sample we reviewed is not generalizable to all DOJ grant
programs because an ideal sample size based upon nearly 11,000
funded grant applications was impractical to select, review, and analyze.
However, the results from our sample illustrate the potential for
unnecessary duplication.

To examine the extent to which DOJ has taken action to reduce or
mitigate overlap and ensure that DOJ does not unnecessarily award
funds from multiple grant programs to support similar purposes, we
analyzed agency policies, procedures, and guidance, current as of 2012,
on grant program design and award, such as the OJP Grant Manager’s
Manual. In addition, we interviewed DOJ officials from OJP, OVW, and
the COPS Office to discuss, among other topics, their grant program
design and award processes and the extent to which they coordinate and



Page 4                                       GAO-12-517 DOJ Grants Management
share information with one another. We also visited or conducted phone
interviews with officials from 11 states to discuss the type and timeliness
of information on grant awards and subawards that they provide to or
receive from DOJ. 11 We selected these states based on the amount of
Edward Byrne Memorial Justice Assistance Grant (JAG) funding they
receive and the existence of other recipients in their communities
receiving DOJ discretionary grants for potentially similar purposes. 12 The
results of these contacts are not generalizable to all states, but provided
insight into how DOJ grant funds were used locally and communication
occurred between states and DOJ. We also compared agency grant
design and award practices against Standards for Internal Control in the
Federal Government and promising practices identified in the Domestic
Working Group Grant Accountability Project’s Guide to Opportunities for
Improving Grant Accountability. 13

To analyze the extent to which DOJ uses grant monitoring and
assessment to determine program effectiveness and uses the results to
enhance its grant programs, we analyzed DOJ documentation, such as
assessments DOJ conducted of its programs and specific programmatic
grant monitoring reports. 14 We also interviewed DOJ officials from the



11
 We selected California, Florida, New York, North Dakota, Pennsylvania, South Dakota,
Rhode Island, Tennessee, Texas, Vermont, and Wyoming.
12
  DOJ established the JAG program following enactment of the Violence Against Women
and Department of Justice Reauthorization Act of 2005, which merged the Edward Byrne
Memorial State and Local Law Enforcement Assistance Program with the Local
Government Law Enforcement Block Grants Program. See Pub. L. No. 109-162, § 1111,
119 Stat. 2960, 3094-3102 (2006). The JAG program is the leading source of federal
justice funding to state and local jurisdictions. JAG provides funding to support a range of
program areas, including law enforcement; prosecution and courts; prevention and
education; corrections and community corrections; drug treatment and enforcement;
planning, evaluation, and technology improvement; and crime victim and witness
initiatives. The program provides 60 percent of the JAG awards directly to the state
agencies that administer JAG funds—known as state administering agencies (SAA)—and
40 percent of the awards directly to local units of government. Local recipients of JAG
funding can receive money either as a direct payment from the JAG program, as a pass-
through from the SAA, or, in some cases, from both the program and the SAA.
13
  GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1
(Washington, D.C.: November 1999); Domestic Working Group, Grant Accountability
Project, Guide to Opportunities for Improving Grant Accountability (Washington, D.C.:
October 2005).
14
 Programmatic monitoring is conducted by federal grant program staff and includes,
among other requirements, a general review of grant compliance and grantee progress.




Page 5                                                 GAO-12-517 DOJ Grants Management
             granting agencies, including those tasked with assessment, as well as
             grantees responsible for measuring the effectiveness of grant programs
             for OVW.

             We conducted this performance audit from May 2011 to July 2012 in
             accordance with generally accepted government auditing standards. 15
             Those standards require that we plan and perform the audit to obtain
             sufficient, appropriate evidence to provide a reasonable basis for our
             findings and conclusions based on our audit objectives. We believe that
             the evidence obtained provides a reasonable basis for our findings and
             conclusions based on our audit objectives. Appendix I contains further
             information on our scope and methodology.


             DOJ awards federal financial assistance to state and local governments,
Background   for-profit and nonprofit organizations, tribal jurisdictions, and educational
             institutions to help prevent crime, assist victims of crime, and promote
             innovative law enforcement efforts. Federal financial assistance can take
             the form of discretionary grants, formula grants, cooperative agreements,
             and payment programs, which all are generally referred to as grants.
             Grant programs are generally created by statute and funded through
             annual appropriations. As such, Congress has a central role in
             determining the scope and nature of federal financial assistance
             programs. In addition, the Office of Management and Budget (OMB)
             establishes general guidance which governs administration of all such
             federal financial assistance and DOJ has flexibility in how to administer
             assistance that is discretionary in nature.

             In fiscal year 2010, DOJ provided direct grant funding to nearly 11,000
             grantees. 16 Table 1 describes the various forms of federal financial
             assistance.




             15
              We reported some of our findings in February 2012. See GAO-12-342SP.
             16
               Grant recipients awarded funds directly from OJP and OVW may in turn award them to
             subrecipients. The COPS Office Prohibits subawarding. In the case of the JAG State
             program, for example, grantees are required to pass through—or award through a
             subgrant—a predetermined portion of the funding to local communities. Direct grant
             funding includes all funding awarded by DOJ, including awards made to recipients from
             DOJ’s various payment programs.




             Page 6                                             GAO-12-517 DOJ Grants Management
Table 1: Types and Examples of Federal Financial Assistance

Types of assistance                                                     Examples
Discretionary grant: Applicants generally compete for funding Enhanced Collaborative Model to Combat Human Trafficking funds
that agencies award at their discretion.                      sites that use a comprehensive approach to combating all forms of
                                                              trafficking—sex trafficking and labor trafficking of foreign nationals
                                                              and U.S. citizens (male and female, adults and minors).
Formula grant: Recipients and award amounts are generally               Edward Byrne Memorial JAG State Grant Program supports all
based on statutorily defined calculations that may incorporate          components of the criminal justice system, from multijurisdictional
a state’s population and violent crime rate. Formula grants are         drug and gang task forces to crime prevention and domestic violence
usually administered and managed by state administering                 programs, courts, corrections, treatment, and justice information-
agencies. States use part of their grant to pass through their          sharing initiatives. JAG-funded projects may address crime through
funds to local subrecipients. These subrecipients may be                the provision of services directly to individuals or communities and by
nonprofit organizations or other units of government.                   improving the effectiveness and efficiency of criminal justice systems,
Formula grants can take the form of either block grants or              processes, and procedures.
categorical grants. Block grants are generally broad in scope
and allow the states discretion in the use of the grant funds.
Categorical grants are generally limited to more narrowly
defined activities.
Cooperative agreements: Typically awarded at DOJ’s                      Violence Against Women Act (VAWA) Measuring Effectiveness
discretion. According to OJP, a cooperative agreement is a              Initiative supports, among other things, the collection and
legal instrument that permits DOJ to transfer money or                  documentation of performance information to measure the work of
something of value to accomplish a public purpose of support            OVW grantees nationwide.
authorized by federal statute and used when substantial
involvement of DOJ may be required in completion of the
grantee’s activity.
Payment programs: Provide recipients with funds for specific            Southwest Border Prosecution Initiative reimburses state and local
purposes. These are unique types of programs that provide               governments for their costs associated with the prosecution and
funds for designated purposes and do not involve activities             pretrial detention of federally initiated criminal cases that are declined
after the funding has been awarded.                                     by U.S. Attorneys’ offices and referred to state and local jurisdictions
                                                                        for prosecution.
                                            Source: GAO analysis of DOJ information.


                                            DOJ administers its grant programs through three granting agencies—
                                            OJP, OVW, and the COPS Office. Appendix II illustrates this organization.
                                            OJP is the largest of DOJ’s granting agencies and in fiscal year 2011 had
                                            approximately $2.4 billion in funding for grants. Its mission to develop the
                                            nation’s capacity to prevent and control crime, administer justice, and
                                            assist crime victims is broader than that of OVW or the COPS Office. For
                                            example, OJP’s bureaus and offices administer grant programs that
                                            address victim assistance, technology and forensics, and juvenile justice,
                                            among other things. The COPS Office had approximately $495 million in
                                            funding for grants in fiscal year 2011, and its grant programs focus on
                                            advancing community policing. OVW had approximately $420 million for
                                            grant awards in fiscal year 2011. OVW administers grant programs
                                            related to domestic violence, dating violence, sexual assault, and stalking.
                                            Trends in amounts appropriated to these DOJ components since fiscal
                                            year 2005 for grant funding are illustrated in figure 1. For additional


                                            Page 7                                                          GAO-12-517 DOJ Grants Management
information on the structure, purpose, and funding of DOJ granting
agencies, see appendix III.

Figure 1: DOJ Grant Funding Appropriated from Fiscal Years 2005 through 2012




Note: Funding levels in fiscal year 2009 include amounts appropriated through the American
Recovery and Reinvestment Act of 2009. See Pub. L. No. 111-5, 123 Stat. 115, 129-30. These
amounts do not reflect any applicable rescinded, reprogrammed, or transferred funding.




Page 8                                                   GAO-12-517 DOJ Grants Management
The Grant Life Cycle   The grants that OJP, OVW, and the COPS Office award generally follow
                       a similar life cycle, including pre-award, award, implementation, and
                       closeout stages, which is shown in figure 2. 17

                       Figure 2: Grant Life Cycle of Federal Awarding Agency




                       17
                         GAO, Federal Grants: Improvements Needed in Oversight and Accountability
                       Processes, GAO-11-773T (Washington, D.C.: June 23, 2011).




                       Page 9                                            GAO-12-517 DOJ Grants Management
                       In the pre-award phase for a competitive grant, the agency announces
                       the grant opportunity with a grant solicitation, which notifies potential
                       applicants of the grant’s purpose, the terms of the award, the amount
                       available, and the eligibility criteria, among other information. During the
                       pre-award phase, the agency also receives and reviews applications and
                       makes award decisions based on requirements set by statute and the
                       grantor agency, as appropriate. Once the agency makes the award, it
                       must report the grant information to USAspending.gov. 18

                       During the implementation stage, the agency is responsible for monitoring
                       the grant. After the end date of a grant, the closeout process should
                       ensure that each recipient has met all of the grant’s financial
                       requirements, returned any unused funds, and provided final reports. OJP
                       and OVW use a web-based system—the Grants Management System
                       (GMS)—to manage this process, while the COPS Office uses a separate
                       COPS Management System (CMS), which is a desktop application that
                       communicates with a centralized database. In our June 2011 report on
                       the grant life cycle, we noted that effective internal control systems are
                       important at each stage in the process. 19


Grant Monitoring and   OJP, OVW, and the COPS Office are responsible for monitoring their
Assessment             grants to ensure that the grants are being implemented as intended and
                       that grantees are compliant with statutory or regulatory requirements as
                       well as any applicable policy guidelines. The granting agencies conduct
                       programmatic grant monitoring by collecting information through
                       telephone calls to grantees, file reviews of the documents and reports that
                       grantees submit, and on-site visits to monitor grantees’ activities at their
                       locations. OJP’s Office of the Chief Financial Officer provides fiscal policy
                       guidance and financial monitoring of grantees for the three agencies.


                       18
                         OMB established USASpending.gov in 2007 to comply with the Federal Funding
                       Accountability and Transparency Act (FFATA) of 2006. See Pub. L. No. 109-282, § 2, 120
                       Stat. 1186. FFATA required OMB to ensure the existence and operation of a single
                       searchable website that includes for each federal award: (1) the name of the entity
                       receiving the award, (2) the amount of the award, (3) information on the award including
                       transaction type and funding agency, (4) the location of the entity receiving the award and
                       the primary location of performance under the award, and (5) a unique identifier of the
                       entity receiving the award; among other information. As of October 2010,
                       USASpending.gov has been updated to include first-tier subaward data, such as
                       subawards states may distribute using a DOJ grant that was awarded to the state.
                       19
                        GAO-11-773T.




                       Page 10                                               GAO-12-517 DOJ Grants Management
Financial monitoring generally consists of reviewing expenditures of
grantees compared with their approved budgets and allowable grant
expenditures, and reviewing compliance with grant requirements such as
the submission of required grant reports.

In addition, pursuant to the Violence Against Women Act of 2000, the
Attorney General reports biennially on the effectiveness of OVW grantee
activities carried out with VAWA grant funds. 20 To meet this requirement,
OVW entered into a cooperative agreement with a university to develop
and implement reporting tools to measure the effectiveness of projects
and activities that OVW funds through its grants. In 2006, the Violence
Against Women and Department of Justice Reauthorization Act of 2005,
established an Office of Audit, Assessment, and Management (OAAM)
within OJP and gave it statutory authority to provide additional oversight
for OJP and the COPS Office programs, as well as any other DOJ grant
program the Attorney General considers appropriate. 21 DOJ’s Acting
Associate Attorney General approved the organizational structure of
OAAM in 2007, the same year the office became operational and was
staffed. The office was not fully staffed until 2009, but OJP reports that as
of May 2012, its staff level is 20 percent below the office’s authorized
number of positions.

Currently, OAAM oversees OJP and the COPS Office granting activities.
According to OJP, among its other activities, OAAM has the following four
main responsibilities (see app. V for more details):

1. ensures financial grant compliance and auditing of OJP’s internal
   controls to prevent waste, fraud, and abuse;




20
  Specifically, the Violence Against Women Act of 2000 provided that the Attorney
General or Secretary of Health and Human Services, as applicable, shall require grantees
under any program authorized or reauthorized under the act to report on the effectiveness
of the activities carried out with amounts made available for the program. See Pub. L. No.
106-386, Div. B, § 1003(a), 114 Stat. 1464, 1491 (2000) (codified at 42 U.S.C. §
3789p(a)). It further required the Attorney General or Secretary, as applicable, to report
biennially to the Committees on the Judiciary of the Senate and House of Representatives
on the grant programs described, including any information reported by grantees. See 42
U.S.C. § 3789p(b).
21
  See Pub. L. No. 109-162, § 1158, 119 Stat. 2960, 3114-16 (2006) (codified as amended
at 42 U.S.C. § 3712h).




Page 11                                              GAO-12-517 DOJ Grants Management
                            2. conducts program assessments of OJP and COPS Office grant
                               programs;

                            3. oversees programmatic monitoring activities of OJP and COPS Office;
                               and

                            4. serves as a central source for OJP grant management policy.



DOJ Grant Programs
Overlap, Contributing
to the Risk of
Unnecessarily
Duplicative Grant
Awards for the Same
or Similar Purposes

DOJ’s Grant Solicitations   We reviewed all 253 of the fiscal year 2010 grant solicitations that OJP,
Overlap across 10 Key       OVW, and the COPS Office published on their respective websites and
Justice Areas               found overlap across 10 justice areas—as table 2 illustrates. These
                            solicitations announced funding available to grantees for criminal and
                            juvenile justice activities, including direct assistance for crime victims and
                            the hiring of police officers. These solicitations also announced funding
                            available for grantees to collect criminal justice data, conduct research, or
                            provide related training and technical assistance. 22 We developed these
                            10 categories of justice areas after reviewing comparable justice areas
                            identified within OJP’s CrimeSolutions.gov website, which OJP officials
                            stated covers a variety of justice topics, including some topic areas that
                            OVW and the COPS Office fund; OJP’s Fiscal Year 2010 Program Plan;
                            and other materials from OVW and the COPS Office, such as justice


                            22
                              The 253 solicitations that we reviewed in August 2011 represent those for new grant
                            programs available in fiscal year 2010 that agency officials told us were archived on their
                            websites. These solicitations are in addition to grant programs that DOJ continues to
                            administer from prior fiscal years or more recently began administering. Because DOJ’s
                            grant awards can last from 1 to 5 years, the total number of active DOJ grant programs
                            can be higher than what is presented in table 2, which is a single year of grant program
                            solicitations.




                            Page 12                                                GAO-12-517 DOJ Grants Management
program themes from their respective websites. Within the justice areas,
a variety of activities—including research, direct service provision, or
technical assistance—can be conducted. We examined the purpose
areas of the 253 grant solicitations and then categorized them by justice
area.

In conducting this analysis, we recognize that overlapping grant programs
across common programmatic areas result in part from authorizing
statutes, and that overlap itself may not be problematic. However, the
existence of overlapping grant programs is an indication that agencies
should increase their visibility of where their funds are going and
coordinate to ensure that any resulting duplication in grant award funding
is purposeful rather than unnecessary. Overlap and the associated risk of
unnecessary duplication occur throughout the government, as we have
reported previously, and are not isolated to DOJ. 23 However, when
coupled with consistent programmatic coordination, the risk of
unnecessary duplication can be diminished.




23
 GAO-12-342SP.




Page 13                                     GAO-12-517 DOJ Grants Management
Table 2: Breakdown of Fiscal Year 2010 DOJ Grant Solicitations by Granting Agency and Justice Area

                                                                       Justice Area
                                                                                     Mental
                                                                     Community      illness,
Component            Technology                         Justice            crime substance Corrections,
/ program     Victim        and Juvenile Enhancing information        prevention     abuse, recidivism,   Multi-
office    assistance   forensics justice   policing    sharing Courts strategies and crime and reentry purposea                            Total
COPS                0          1        0               2                0          0       3            1              0            0          7
Jointb              0          0        1               0                0          0       0            0              2            3          6
OVW                15          0        0               0                0          1       0            0              0            1          17
OJPc
BJA                 2          2        0               7                3          7       3            6              7            5          42
BJS                 5          2        2               3                6          4       1            1              4            2          30
CCDOd               0          0        0               0                0          0       2            0              0            0          2
NIJ                 3         36        0               4                0          1       4            0              5            8          61
OJJDP               8          0       30               7                1          8       4            0              0            3          61
OVC                23          0        0               0                0          0       0            0              0            0          23
SMART               0          0        0               0                2          0       0            0              2            0          4
Total              56         41       33             23                12         21      17            8             20           22       253
solicitations
Total award      $872       $325     $264           $386              $98          $77   $77          $53            $430        $810    $3,393f
amount (in
millions)e
                                        Source: GAO analysis of DOJ information.


                                        Notes: Solicitations in this table reflect those for direct assistance, such as funds DOJ provides for the
                                        hiring of police officers, as well as those for research, data collection, and technical assistance on the
                                        related justice areas.
                                        a
                                        Multipurpose solicitations were solicitations for grants that addressed more than one justice area
                                        within a single solicitation.
                                        b
                                         Joint refers to solicitations issued jointly by multiple program offices, components, or departments
                                        (e.g., DOJ and the Department of Health and Human Services, or DOJ’s Bureau of Justice
                                        Assistance and Office of Juvenile Justice and Delinquency Prevention).
                                        c
                                        OJP is composed of a number of smaller bureaus and offices. BJA is the Bureau of Justice
                                        Assistance; BJS is the Bureau of Justice Statistics; CCDO is the Community Capacity Development
                                        Office; NIJ is the National Institute of Justice; OJJDP is the Office of Juvenile Justice and
                                        Delinquency Prevention; OVC is the Office for Victims of Crime; and SMART is the Sex Offender
                                        Sentencing, Monitoring, Apprehending, Registering, and Tracking Office.
                                        d
                                         Federal funding reductions in fiscal year 2011 included CCDO’s Weed and Seed Program. Without
                                        funding for this program, CCDO closed, and all remaining open, active CCDO grants were transferred
                                        to and are presently managed by BJA effective June 6, 2011.
                                        e
                                         Actual amount awarded to grantees in millions. Total award amounts will not sum because of
                                        rounding.
                                        f
                                            This amount excludes benefits paid through DOJ’s Public Safety Officers’ Benefits Program.




                                        Page 14                                                        GAO-12-517 DOJ Grants Management
                             As table 2 illustrates, we found overlap across the various DOJ grant
                             programs. For example, 56 of DOJ’s 253 grant solicitations—or more
                             than 20 percent—were providing grant funds available for activities
                             related to victim assistance or to support the research and prevention of
                             violence against women. Eighteen of these 56 programs were
                             administered by offices other than OVW and OJP’s Office for Victims of
                             Crime. 24 In addition, more than 50 percent of all grant solicitations
                             provided funding that could be used in support of the same three justice
                             areas—victim assistance, technology and forensics, and juvenile justice—
                             indicating concentrated and overlapping efforts. The justice area with the
                             least overlap was juvenile justice, with 30 of 33 grant programs
                             administered by the Office of Juvenile Justice and Delinquency
                             Prevention.

                             There are some instances in which overlap occurs because of the statute
                             that established programs. Further, we recognize that overlap among
                             DOJ’s grant programs may be desirable because such overlap can
                             enable DOJ’s granting agencies to leverage multiple funding streams to
                             serve a single justice purpose. However, coordination across the
                             administering granting agencies is critical for such leveraging to occur. In
                             the section below, we discuss the ways in which overlapping grant
                             programs increase the risk of unnecessarily duplicative grant awards for
                             the same or similar purposes. In subsequent sections, we discuss the
                             steps DOJ has taken to enhance coordination and some ways in which
                             DOJ’s efforts can be improved.


In Some Instances, DOJ       We found that in some instances, DOJ’s granting agencies awarded
Awarded Grant Funding        multiple grants to the same grantees for the same or similar purposes.
from Overlapping             Applicants can apply directly to DOJ for funding through a variety of grant
                             programs that DOJ announces annually. Recipients of such grant awards
Programs to the Same         are referred to as prime grantees. Since many of DOJ’s grant programs
Applicants for the Same or   allow prime grantees to award subgrants, applicants also can apply
Similar Purposes             directly to a prime grantee for award funding. As a result, prime grantees
                             receiving money from DOJ through one funding stream also can be



                             24
                               OVW’s mission is to provide federal leadership in developing the nation’s capacity to
                             reduce violence against women and administer justice for and strengthen services to
                             victims of domestic violence, among others. OVC’s mission is to enhance the nation’s
                             capacity to assist crime victims and to provide leadership in changing attitudes, policies,
                             and practices to promote justice and healing for all victims of crime.




                             Page 15                                                GAO-12-517 DOJ Grants Management
subgrantees receiving money from a prime grantee through another
funding stream. If an applicant, either as a prime grantee or as a
subgrantee, receives multiple grant awards from overlapping programs,
the risk of unnecessary duplication increases since the applicant may
receive funding from more than one source for the same or similar
purpose without DOJ being aware that this situation exists. Such
duplication may be unnecessary if, for example, the total funding received
exceeds the applicant’s need, or if neither granting agency was aware of
the original funding decision.

After reviewing a sample of 26 grant applications from recipients who
received funds from grant programs we identified as having similar
purpose areas, we found instances where applicants used the same or
similar language to apply for multiple streams of funding. For example,
one grant recipient applied for funding to reduce child endangerment
through cyber investigations from both the COPS Office’s Child Sexual
Predator (CSPP) Program 25 and OJP’s Internet Crimes Against Children
(ICAC) program. In both of these applications, the applicant stated that it
planned to use the grants to increase the number of investigations in the
state, provide training for cyber crime investigations, serve as a forensic
resource for the state, and establish an Internet safety program. Further,
included in this applicant’s proposed budgets for both funding streams
were plans to purchase equipment, such as forensic computers and the
same specialized software to investigate Internet crimes against children.
Another grant recipient from a different jurisdiction also applied for
funding from OJP and the COPS Office programs to support the same
types of investigations. In a third instance, an applicant received fiscal
year 2010 grant funding for planned sexual assault victim services from
both OJP’s Office for Victims of Crime and OVW. The applicant used
similar language in both applications, noting that it intended to use the
funding to support child victim services through its child advocacy center.

After we shared these examples with DOJ, DOJ officials followed up with
the grant recipients involved and reported to us that the grantees were
not using awarded funds for duplicative purposes—which DOJ defines as
grantees using funds to pay for the exact same item. However, such
follow-up for the purpose of assessing duplication is not a routine practice



25
  DOJ’s fiscal year 2013 performance budget justification does not include a request for
funding to continue this grant program.




Page 16                                               GAO-12-517 DOJ Grants Management
for DOJ. Further, DOJ’s narrow definition of duplication curtails it from
assessing the use of funds for the same or a similar overall purpose on a
grant project.

In fiscal year 2010, DOJ’s three granting agencies awarded nearly 11,000
prime grant awards, 26 but officials told us that they do not consider the
flow of grant funds to subgrantees when making grant award decisions. 27
Because DOJ does not have visibility of the flow of funds to these
recipients, agency officials were not positioned to tell us what activities, or
for what purposes, the subgrantees were spending their federal funds.
Thus, to obtain more information, we surveyed JAG SAAs, who are
responsible for managing the subgrants they make, to obtain information
related to the purpose areas of their funding. 28

In our survey, we asked the JAG SAAs if they or their subgrantees used
grant funding in fiscal year 2010 for key justice areas such as funding sex
offender registry notification systems; correctional officer salaries, and
sexual assault services; purchasing bullet-resistant vests; and hiring
police officers. DOJ supports all of these areas through JAG, as well as
through targeted grant programs specifically addressing each of these
topics. On the basis of survey responses, we found several instances
where SAAs reported that JAG funds were used to support activities that
could have been funded through other DOJ grants. For instance, 11 of 50
responding SAAs, or 22 percent, reported that they or their subgrantees
used JAG funding to support correctional officer salaries. Further, 23 of


26
 This number includes all formula, discretionary, and payment program awards.
27
 The public website USASpending.gov is designed to make such information transparent.
28
   Survey of Indigent Defense Funding from Byrne Memorial Justice Assistance Grants,
GAO (2012). This survey and the results are published in Indigent Defense: Surveys of
Grant Recipients, Select Tribes, and Indigent Defense Providers GAO-12-661SP, May
2012, an E-supplement to GAO-12-569, GAO-12-661SP (Washington, D.C. May 30,
2012). The survey was conducted to support the GAO report: Indigent Defense: DOJ
Could Increase Awareness of Eligible Funding and Better Determine the Extent to Which
Funds Help Support This Purpose, GAO-12-569 (Washington, D.C.: May 9, 2012).
“Indigent defense,” as we used the term in that report, refers to direct and indirect
activities that help ensure indigent defendants are afforded counsel in criminal cases, and
includes activities such as hiring additional public defenders, investigators, or other
support staff; providing training for public defenders; and making technological
improvements in defenders’ offices or systems. In fiscal year 2010, all SAA JAG
recipients, except for U.S. territory SAAs, subawarded some of their awards. Thirty-two of
the 50 state SAAs subawarded a majority of their JAG funding. More information on the
survey is included in appendix I.




Page 17                                               GAO-12-517 DOJ Grants Management
the 50 SAAs, or nearly 50 percent, reported that they or their subgrantees
used JAG funding to hire police officers, even though a separate DOJ
program dedicates funding exclusively to hiring law enforcement
personnel. 29

The survey results indicate an increased risk of DOJ funding
unnecessarily duplicative grant awards. If DOJ were aware that an
applicant had received JAG funding through a subgrant to conduct
community policing patrols, DOJ would be better positioned to decide
whether that applicant should receive additional funding as a prime
grantee from its community policing discretionary grant program. The
results from our site visits confirmed this heightened risk. For example, in
one state we visited, a county had received a JAG program subaward
and used the funding for its officers to conduct community policing. The
same county also received a COPS Office hiring grant and used the
funding for an officer to conduct community policing. 30 Additionally, the
largest city in this county received a COPS Office hiring grant to conduct
community policing. Because this city received the COPS Office funding
to conduct community policing and grant-supported officers conducted
patrols in geographical areas that overlapped with areas in the county
already served by JAG-funded police officers, three DOJ grant awards
were used to provide community policing to overlapping areas in the
county. During the course of our audit work, COPS Office officials told us
that community policing is not an activity but rather a philosophy for how
policing should be conducted. As such, the officials consider multiple
awards to the same communities to be complimentary. Since the COPS
Office does not routinely consider the variety of federal funding that
current and prospective grantees already use or may soon benefit from
before making grant award decisions, they are not positioned to
determine whether such funding arrangements are complementary.
Further, officials from two additional counties in this state told us they



29
  Eight of the 50 responding SAAs, or about 16 percent, reported that they or their
subgrantees used JAG funding to support sex offender registry and notification systems;
11 out of the 50, or 22 percent, reported JAG funding was used to support sexual assault
services; 15 out of the 50, or 30 percent, reported funding was used to support bullet-
resistant vest purchases.
30
  The COPS Office hiring grant awarded to this county was for fiscal year 2009. COPS
Office hiring grants last up to 3 years, and the county used the grant in fiscal years 2010
and 2011 as well. These grants support the hiring or the rehiring of career law
enforcement officers to increase community policing and crime prevention strategies.




Page 18                                                GAO-12-517 DOJ Grants Management
received funding for drug court–assisted substance abuse treatment and
mental health counseling through both a JAG program subaward and a
grant directly from OJP’s Adult Drug Court Grant Program. Officials from
one of these counties informed us that they received so much DOJ
funding from the two grant programs that it exceeded the county’s need
and they planned to return a portion to DOJ. 31

The IG has previously identified the risk of OJP and the COPS Office
funding duplicative grant awards. For example, in 2003, the IG identified
duplication between the COPS Office Hiring Program and the Local Law
Enforcement Block Grant Program, the predecessor to the JAG grant
program. The IG reported that while the COPS Hiring Grant program is
required to advance community policing, the Local Law Enforcement
Block Grant Program grants are sometimes used for the same or similar
purposes. According to the IG, in such cases the grants are duplicative. 32
In 2010, the IG reported that it had identified potential overlap between
the COPS Office Hiring Recovery Program and OJP’s JAG Formula
Program and Edward Byrne Competitive Grant Program. As a result, the
IG recommended that the COPS Office work with OJP to avoid
duplication of future funding by coordinating closely on grantee selection
decisions, as discussed later in this report. 33




31
   According to DOJ officials, existing oversight mechanisms, such as programmatic and
financial monitoring, as well as IG audits, help them ensure that grantees only expend
federal financial assistance for allowable costs approved by DOJ in applicants’ budgets.
32
  U.S. Department of Justice Office of the Inspector General, Audit Division, Streamlining
of Administrative Activities and Federal Financial Assistance Functions in the Office of
Justice Programs and the Office of Community Oriented Policing Services, Audit Report
03-27 (Washington D.C.: Aug. 2003).
33
  U.S. Department of Justice Office of the Inspector General, Audit Division, A Review of
the Selection Process for the COPS Hiring Recovery Program, Audit Report 10-25
(Washington D.C.: May 2010).




Page 19                                               GAO-12-517 DOJ Grants Management
DOJ Has Taken
Actions That Address
Overlap in Grant
Programs but Could
Further Reduce the
Risk of Unnecessary
Duplication in Grant
Funding
DOJ Has Taken Some          According to DOJ officials, the statutory creation of grant programs with
Action to Consolidate and   similar purposes requires grant design coordination within and among
Coordinate Similar Grant    DOJ’s granting agencies to limit the risk of unnecessary duplication from
                            overlapping programs. The primary purpose of consolidation or
Programs                    coordination may not be to limit this risk, but officials reported that
                            reducing the risk may be a secondary benefit. Officials from all three
                            granting agencies stated that they meet with one another to coordinate
                            the goals and objectives of their grant programs, especially joint grant
                            programs that they believe are complementary. For example, the Bureau
                            of Justice Assistance and the Office for Victims of Crime issued a joint
                            solicitation for anti-human trafficking programs where each office issued
                            separate awards based on coordinated proposals from collaborating
                            police departments and community-based victim service organizations.
                            Further, according to officials, DOJ recently launched the Coordinated
                            Tribal Assistance Solicitation to provide a single application for most of
                            DOJ’s tribal grant programs.

                            Consolidating two programs with similar purposes into one, with unified
                            management, is the most comprehensive way to reduce overlap,
                            according to DOJ officials. However, they stated that the statutory
                            creation of grant programs with similar purposes can create
                            administrative challenges because in many cases, DOJ must seek
                            statutory authorization to discontinue or consolidate enacted programs
                            that DOJ believes may be overlapping. Officials told us they have sought
                            congressional action in a few instances for these purposes and will
                            continue to do so, but because the process is complex, they have also
                            taken administrative steps on an ad hoc basis to mitigate overlap of
                            purpose areas as illustrated in table 3.




                            Page 20                                     GAO-12-517 DOJ Grants Management
Table 3: Consolidation and Coordination of DOJ Grant Programs and Illustrative Examples

Consolidation: Statutory authority is generally             •     In accordance with DOJ’s fiscal year 2012 appropriations act, OVW will
required to merge two or more existing grant                      consolidate four existing youth victim-oriented grant programs into a
                                                                                   a
programs. Once programs have been consolidated, a                 single program. By creating one solicitation, an OVW official reported
single DOJ office announces and manages the newly                 that the grant application process may be streamlined, and cost
merged grant program.                                             efficiencies related to reviewing applications may be achieved (see app.
                                                                  IV for more details).

Coordination: Congressional action is not required,         •     OJJDP coordinated 9 of its youth grant programs to create 1 grant
and officials explained two approaches they have                  program known as SafeFutures. The program assisted recipients and
taken to improve coordination. The first approach is              communities through a single program (see app. IV for more details).
“blending,” whereby DOJ coordinates grant                   •     In fiscal year 2010, DOJ coordinated several of its tribal grant programs
management from within a single office while keeping              to create the Coordinated Tribal Assistance Solicitation (CTAS), which
funding streams from separate appropriations distinct.            involves OJP’s, OVW’s, and the COPS Office’s tribal grant programs.
The second approach is “braiding,” whereby DOJ                    The CTAS program combined 10 DOJ tribal grant program solicitations
continues to manage the programs through separate                 into 1 for purposes of streamlining the application and selection process,
offices and separate funding streams but issues a                 and OJP officials reported reducing the administrative burden on its
single grant announcement.                                        applicants as a result. These programs continue to be managed by
                                                                  separate DOJ bureaus and offices (see app. IV for more details).
                                            Source: GAO analysis of DOJ information.

                                            a
                                             See Pub. L. No. 112-55, Div. B, 125 Stat. 552, 612-13 (2011).


                                            Officials stated that they meet with one another when they determine it is
                                            needed to coordinate the goals and objectives of their grant programs,
                                            especially those programs that they believe are complementary. In
                                            addition, an OJP official told us that in 2010 the office prioritized
                                            coordination as 1 of its 10 management goals and cited benefits that
                                            resulted from this focus, including reduced administrative costs, fewer
                                            grant solicitations, and a reduced number of competitive grant peer
                                            reviews. However, these officials told us that these coordination and
                                            consolidation efforts, as well as those illustrated in table 3, do not occur
                                            routinely.


DOJ Has Not Assessed Its                    Even with efforts to coordinate its programs, DOJ officials told us they
Grant Programs to Identify                  have not conducted a formal assessment or study of their grant programs
and Reduce Overlap                          to determine if and to what extent they overlap and where opportunities
                                            exist to more consistently pursue consolidation or better coordinate grant
                                            programs. Further, we found that coordination among granting agencies
                                            occurred on an ad hoc basis and that without an assessment of its
                                            overlapping programs, DOJ was not well positioned to identify and
                                            describe areas of potential for unnecessary duplication across its grant
                                            programs.




                                            Page 21                                                     GAO-12-517 DOJ Grants Management
A senior OJP official told us that the department had not formally
assessed or studied its grant programs to determine the extent of overlap
because of the significant investment of time and staff resources that it
would require. DOJ officials emphasized that since these programs were
statutorily established as distinct programs, they are not certain that any
attempt at harmonization—beyond what they have already done—would
be viable. For example, they said that in some cases, statutes creating
what may appear to be similar programs also create very different
eligibility criteria for grant applicants. Thus, the officials stated, some
programs may not be easily merged through administrative efforts such
as announcing similar grant programs in a single solicitation. We agree
that similar grant programs may have unique features that could render
grant consolidation or coordination impractical, but DOJ has not taken the
steps to catalogue all of its programs across each of the three granting
agencies, and then determine which have the potential to be consolidated
or coordinated and what barriers might exist to achieve such changes.

The IG continues to include DOJ’s grants management among its list of
top challenges affecting the department, and in previous reports, has
identified fragmentation and duplication among DOJ’s granting agencies
as an area of concern. Further, developing agency procedures to avoid
grant duplication is one of the promising practices that the federal
Domestic Working Group Grant Accountability Project suggested in its
Guide to Opportunities for Improving Grant Accountability. 34 Given the
specific knowledge of these grant programs’ statutory authorities, their
histories of funding certain types of activities, and the nuances related to
their administration, officials within OJP, OVW, and the COPS Office are
uniquely positioned to assess their programs for overlap. Doing so could
yield positive dividends for the granting agencies and the department over
the longer term. Specifically, such assessments could include
understanding the areas in which individual granting agencies may be
awarding funds for the same or similar purposes, determining whether
these grant programs appropriately channel the department’s resources
across the justice areas it funds, and determining whether any existing
overlap is desirable. By conducting an assessment of its grant programs
of this kind, DOJ would be better positioned to take action, such as
through consolidation and coordination of its programs, in a more


34
  The Domestic Working Group is composed of 18 federal government inspectors
general, other state and local audit organizations, and is chaired by the Comptroller
General of the United States.




Page 22                                               GAO-12-517 DOJ Grants Management
                            systematic way to limit overlap and mitigate the risk of unnecessary
                            duplication.


DOJ’s Granting Agencies     OJP, OVW, and the COPS Office do not routinely share lists of current
Do Not Have Policies and    and potential awardees to consider both the current and planned
Procedures to Ensure        dispersion and purposes of all DOJ grant funding before finalizing new
                            award decisions. Not having routine coordination in the pre-award phase
Coordination to Limit the   limits each of DOJ’s granting agencies’ visibility of the funds each
Risk of Unnecessary         respectively awards rather than to the overall flow of department dollars.
Duplication                 Thus, in the instances where DOJ made multiple grant awards to
                            applicants for the same or similar purposes, officials made these awards
                            without always being aware of the potential for unnecessary duplication or
                            whether funding from multiple streams was warranted. DOJ officials
                            stated that their annual process to formulate budgets for grant
                            administration, OJP’s annual planning process to develop solicitations,
                            and the department’s overall grant oversight functions address the risks
                            of unnecessary duplication in grant awards. However, these activities do
                            not specifically relate to the pre-award phase when any potential for
                            unnecessary duplication can best be avoided. DOJ officials also stated
                            that they meet bi-monthly to discuss grantees on DOJ’s High Risk List to
                            avoid funding grantees who in the past have demonstrated deficiencies in
                            properly managing their federal awards. 35 However, the purpose of these
                            discussions is not to prevent or reduce duplication. Developing agency
                            policies and procedures to avoid unnecessary grant duplication in the
                            awarding of funds is one of the promising practices that the federal
                            Domestic Working Group Grant Accountability Project suggested in its
                            Guide to Opportunities for Improving Grant Accountability.

                            As a result of our work, OJP officials informed us that as of March 2012,
                            they had begun to pilot solicitation language in two of its grant programs
                            requiring grant applicants to disclose any pending applications submitted
                            in the last 12 months for other federally funded assistance to support the


                            35
                              DOJ designates grantees as high risk based on a number of factors, including but not
                            limited to, a history of unsatisfactory performance, financial instability, an inadequate
                            financial management system, or nonconformance to terms and conditions of previous
                            awards. Additional reporting requirements are imposed on high-risk recipients. OAAM’s
                            Audit and Review Division coordinates the high-risk grantee list and works to either
                            resolve the issues underlying the high-risk designation or to impose conditions on high-
                            risk grantees to ensure appropriate stewardship of federal funds and enhance
                            programmatic results.




                            Page 23                                               GAO-12-517 DOJ Grants Management
same costs associated with the same projects outlined in applicants’
budgets. Additionally, officials stated they are currently developing a grant
special condition for all fiscal year 2012 grant awards that would require
grantees to report to OJP if they receive any funding for a specific project
cost that is duplicative of the funding OJP provides. 36 OJP officials told us
that if grantees report duplicative funding for a specific project cost, OJP
staff will work with the grantees to ensure return of the OJP funds. We
believe this requirement will improve OJP’s ability to limit the risks of
duplicative funding for single items; however, OJP continues to take a
more narrow view of the term “duplication.” OJP defines duplicative
funding to include only instances where grantees are using federal money
for the same exact item. In doing so, OJP excludes from its purview all
federal funding that grant applicants have been awarded to carry out the
same or similar activities within a proposed project. Thus, in making
funding decisions without asking for information about and considering
other sources of an applicant’s federal funding to carry out the same or
similar activities, OJP may be awarding funds for proposed projects that
are already partially or fully funded. It may also be doing so at the
expense of other applicants who, in the absence of other funding sources,
may demonstrate to OJP greater financial need for their proposals.
Further, DOJ’s new approach—while an important step—relies solely on
grantee reporting. By independently assessing its own lists of actual and
prospective grantees prior to awarding funds, DOJ could have additional
assurance that it is taking actions to mitigate the risk of unnecessary
duplication.

In addition, OVW officials stated that for fiscal year 2013, they intend to
require those applying to four of its grant programs to identify in their
grant applications all federal funding that they recently applied for or have
received. By enhancing visibility over various sources of grant funding,
OVW would be better positioned to avoid unnecessary duplication in
awarding grants for these four programs. It could also provide OVW with
opportunities to best leverage OVW funding in a manner that
complements other funding streams the applicant already has available or
may soon receive. For example, if an applicant reports to OVW that it
already receives money through a non-OVW grant to provide counseling
services to victims, OVW can ensure that OVW funds are available for



36
  Special conditions set forth specific terms that grantees must meet, in addition to the
general conditions associated with the grant, in order to receive funds.




Page 24                                                GAO-12-517 DOJ Grants Management
other project-related activities such as providing training to counselors
who serve victims. However, beyond what OJP is piloting and what OVW
has proposed for four of its programs, DOJ generally does not require
grant applicants to identify other funding that they have received or any
pending funding yet to be awarded, including funding received through a
subgrant. 37 Further, while the COPS Office’s grants management system
automatically includes information on other COPS Office funding a COPS
Office applicant may already be receiving, it does not identify other DOJ
grant funding or any other federal funding sources. As a result, DOJ’s
three granting agencies could take additional steps to increase their
visibility over what applicants may already be receiving before awarding
new funds.

OJP, OVW, and the COPS Office have not established policies and
procedures requiring consistent coordination and information sharing
among its granting agencies. Having such policies and procedures would
provide guidance to DOJ granting agencies to help ensure they take
action to mitigate the risks of unnecessary duplication before finalizing
award decisions. By routinely coordinating to ensure the sharing of grant
applications and potential grant awards among DOJ granting agencies
prior to finalizing grant award decisions and documenting its methods for
doing so, DOJ could also improve its oversight and better leverage
information already at its disposal.

The IG recommended in August 2003 that OJP and the COPS Office
establish procedures to coordinate to ensure that grantees do not receive
funds for the same purpose from both agencies. 38 In response, OJP and
the COPS Office signed a memorandum of understanding to establish
procedures for avoiding duplication by coordinating grants and grant
programs that were identified by the IG and grant programs where the


37
   In fiscal year 2009, OVW required applicants from its OVW Recovery Act grant program
to identify other sources of DOJ funding on their grant applications and as a grant special
condition, required recipients to inform OVW if they receive any other DOJ funding during
the term of the grant. This process was repeated for a different OVW grant program in
fiscal year 2010. Additionally, OJP issued 2 grant program solicitations for fiscal year 2012
requiring applicants to report all pending federal and state grant applications which
propose to support the same project and the same costs in both applications.
38
  U.S. Department of Justice Office of the Inspector General, Audit Division, Streamlining
of Administrative Activities and Federal Financial Assistance Functions in the Office of
Justice Programs and the Office of Community Oriented Policing Services, Audit Report
03-27 (Washington D.C.: Aug. 2003).




Page 25                                                GAO-12-517 DOJ Grants Management
potential for duplication exists. Further, the agencies committed to
reviewing any new guidance affecting grants or grant programs where the
potential for duplication exists. Specifically, for grants and grant programs
identified as having potential for duplication, OJP and the COPS Office
agreed to minimize potential duplicative grant awards in a manner
consistent with statutory provisions, and include a grant award special
condition requiring that grantees not use OJP and COPS Office grant
funds to pay for the same expenses. 39 During the course of our audit
work, we asked COPS Office and OJP officials for examples of the type
of coordination they have been engaging in since the IG’s
recommendations. Officials provided evidence from fiscal year 2009,
when they coordinated funding decisions with OJP prior to awarding
grants for two similar grant programs funded under the Recovery Act. 40
However, in some cases, granting agencies continue to provide funding
for the same or similar purposes without each being aware of the others’
actions. Further, we examined grant special conditions for the COPS
Office CSP program and OJP’s ICAC grant program and neither agency
included special conditions in the grant awards requiring grantees to
identify and report duplication. However, the 2010 COPS Child Sexual
Predator Program Grant Owner’s Manual did include a requirement that
grantees inform the COPS Office if they receive other funding for the
same cost or service already funded by the COPS Office while their grant
is underway. The Grant Manager’s Manual used by OJP lists grant award
special conditions, and except for the duplication condition that
specifically applies to CTAS, there were no other grant duplication special
conditions listed.

Officials from OJP and the COPS Office told us that state and local
communities have expansive criminal justice needs and therefore they
encourage applicants to seek out as much DOJ grant funding as possible,
including from grant programs that may have similar objectives or allow


39
  The IG’s understanding of OJP and the COPS Office’s approach to addressing the IG’s
recommendation, as stated in their response to the agencies’ review of the report, was
that the agencies will develop procedures to ensure that duplicative awards are not made
to the same grantee for similar purposes.
40
  The American Recovery and Reinvestment Act of 2009 (Recovery Act), Pub. L. No. 111-
5, 123 Stat 115, was enacted on February 17, 2009. See Pub. L. No. 111-5, 123 Stat.
115. Purposes of the act include promoting economic recovery, providing investments
needed to increase economic efficiency, and stabilizing state and local government
budgets to minimize and avoid reductions in essential services. DOJ awarded grants
under a variety of Recovery Act grant programs.




Page 26                                              GAO-12-517 DOJ Grants Management
for similar activities. In some instances, DOJ may deem it appropriate for
distinct grant programs to serve the same goal, or for one community or
grantee to benefit from multiple streams of grant funding. For example, if
DOJ granting officials are coordinating their activities across overlapping
grant programs and are aware that a grantee is receiving funds from
more than one DOJ program, making funding decisions of this kind may
be warranted. However, DOJ’s granting agencies are not routinely
engaging in such coordination. Unless DOJ improves granting agencies’
coordination, and considers information available on current, past, and
prospective funding, it cannot know where all of its funding goes, how it is
being or will be used, and whether it is awarding grant dollars in the most
efficient way possible. Further, if the granting agencies are not aware of
which recipients are receiving funds from multiple grants, they may be
inadvertently awarding multiple grants that exceed the demonstrated
need of a recipient or community at the expense of another applicant or
community with similar demonstrated needs. In addition, they may be
missing opportunities to award grants to recipients who may use funding
in a complementary way, whereby funding may be leveraged by a
grantee or a community to accomplish a single goal. With the exception of
OVW’s plan to have four grant program recipients identify all federal
funding they receive and OJP’s solicitation pilot and plan to have
applicants identify duplicative cost items, DOJ does not have policies and
procedures that require grant applicants to identify all sources of current
or pending DOJ funding in their grant applications in a manner that
provides DOJ a complete picture of DOJ grant project funding. If DOJ had
(1) a coordinated approach to share applicants’ funding intentions, and
(2) policies and procedures to share lists of applicants that each granting
agency plans to fund, DOJ could improve its understanding in the pre-
award phase as to whether its funding would complement or
unnecessarily duplicate other federal funding.

DOJ officials told us that the timeline for reviewing applications, making
recommendations, and processing awards each year is compressed and
that it would be difficult to build in the extra time and level of coordination
required to complete an intradepartmental review for potentially
unnecessary duplication of funding prior to making awards. The officials
added that it would take even more time if granting agencies were to
attempt a pre-award duplication review at the subgrantee level. Thus,
officials told us that they rely upon post-award activities through grant
monitoring, Single Grant Audits, and IG audits to determine if duplicative
expenses have occurred after grants are under way. However, relying
upon monitoring and external audits to identify duplication after it has
occurred should not substitute for the mitigation of potential unnecessary


Page 27                                        GAO-12-517 DOJ Grants Management
                          duplication in the pre-award phase. We acknowledge that the time
                          necessary to complete annual grant awards makes such a review
                          process more difficult; however, actions to make coordination more
                          consistent and efficient as well as the leveraging of grant award
                          information, including subgrants, could help overcome this challenge.
                          Moreover, using tools such as existing grant data available on
                          USASpending.gov, which we address later in this report, could aid DOJ in
                          validating other grant funding that grant applicants report and allow for an
                          expedient way to search for subgrant funding. In addition, DOJ could limit
                          its pre-award coordination to those grant programs that DOJ identifies as
                          overlapping with other DOJ grant programs. For certain grant programs,
                          OJP and OVW have taken important first steps to require grant applicants
                          to report other sources of funding, but expanding this requirement to all
                          grant programs across all granting agencies, such that every applicant
                          would report both past and prospective sources of DOJ grant funding,
                          could provide broader coverage and help DOJ better mitigate the risk of
                          unnecessary duplication.


DOJ Uses Separate Grant   While OJP and OVW use a single grants management system called
Management Systems, a     GMS, the COPS Office uses a separate grants management system—
Fact That Limits Award    CMS—which limits the sharing of grant award information across the
                          granting agencies. 41 Specifically, OJP, OVW, and the COPS Office use
Coordination
                          GMS and CMS to track and manage awards throughout the grant life
                          cycle. For example, agency grant staff in OJP, OVW, and the COPS
                          Office use their grant management systems to review and approve
                          applications and to plan and document grant monitoring activities.
                          Grantees use the grant management systems to submit financial status
                          reports that include summary information on grant expenditures and
                          program income as well as progress or performance reports. DOJ has
                          spent about $36 million from 2008 through 2010 to maintain and upgrade




                          41
                            There is a cross-DOJ system for financial management, the Financial Management
                          Information System 2 (FMIS 2), that can be used to identify awards and grant
                          disbursements, but it does not show the intended purpose of the grants or grant
                          information related to grant activities grantees currently have under way.




                          Page 28                                           GAO-12-517 DOJ Grants Management
these two separate grants management systems, including about $8
million for CMS and $28 million for GMS. 42

DOJ’s continued use of two systems to manage grant programs impedes
coordination because GMS and CMS are not linked with each other, and
the agencies’ access is limited to the grants management systems they
utilize. OJP and OVW can access information through GMS about grants
awarded by each other, but they cannot access CMS to see the grantees
that have received COPS Office funds. As a result, these granting
agencies cannot use these grants management systems to inform
themselves of all of the funding DOJ has awarded or is preparing to
award to a recipient and consider this information before making
additional awards. According to an OJP official, over the long term, it
would be helpful if GMS could connect to CMS. Pursuant to the statute
establishing OAAM—the office overseeing programmatic grant monitoring
and assessment across OJP and COPS Office programs—the Director of
OAAM was required to establish and maintain a modern, automated
system for managing all information relating to grants made under
programs within its purview. 43 However, GMS and CMS remain distinct
grant management systems in the department.

Standards for Internal Control in the Federal Government highlights the
importance of program managers having access to operational and
financial data to determine whether they are meeting their goals for
accountability and efficient use of resources. In addition, the Domestic
Working Group Grant Accountability Project’s Guide to Opportunities for
Improving Grant Accountability identified consolidating systems as a
promising practice. Further, in 2010, the IG found that, as of 2009, OJP’s
Office of the Chief Financial Officer, which has oversight over the COPS
Office, did not have access to basic data in CMS needed for financial
monitoring site visits and other financial compliance reviews. The IG
recommended that the COPS Office improve coordination with OJP by
providing OJP additional grants management documentation for oversight



42
  These costs include software and hardware upgrade acquisitions and maintenance but
do not include costs such as user training for each system. In the case of GMS costs, a
portion of the costs was capitalized from 2008 through 2013. Had those costs not been
capitalized, GMS costs would appear higher for this 3-year period.
43
 See 42 U.S.C. § 3712h(g) (providing that the OAAM Director shall establish and
maintain such a system in consultation with the chief information officer of the office).




Page 29                                                 GAO-12-517 DOJ Grants Management
and monitoring, such as through remote access to CMS. 44 The IG
concluded that oversight agencies should have direct, instant, and
complete access to grant information, which is not provided using the
current system, which relies on hard copies of documents. In response,
COPS Office officials reported that they would provide OJP with real-time
hard copy reports necessary to carry out oversight work and that CMS
could be accessed only by employees using remote access to the COPS
Office or through a COPS Office laptop.

DOJ contractors completed a gap analysis of CMS and GMS in 2006 to
outline the differences—or gaps—between the two systems and propose
solutions for reconciling them. At the time, the contractor found key gaps
between the two systems related to business processes—in particular,
programmatic grant monitoring, financial monitoring, and progress-
reporting capabilities. Thus, the contractor recommended either building a
new single grants system or maintaining the status quo because in the
analysis, business process differences between OJP and the COPS
Office were reportedly obstacles that made using either one of the two
grants systems for both agencies untenable. Since 2007, OJP has
upgraded GMS, which has closed some of the system gaps that the
contractor initially identified, but the two systems remain distinct and
unlinked.

According to COPS Office officials, CMS continues to better meet their
needs than GMS could because CMS captures and stores data in such a
way that it can be more easily queried than data in GMS and CMS
uniquely aligns with COPS Office grant processes. This is helpful to the
officials when the COPS Office is evaluating grant applications for its
largest program, the COPS Hiring Program. Rather than evaluating
qualitative grant project narratives through external peer review, the
COPS Office considers quantitative data related to applicant fiscal
distress, reported crime statistics, and community policing strategies
when determining where to award COPS Hiring Program grants. Because
COPS Hiring Program grant applicants use CMS to upload their data,
COPS officials are positioned to use CMS for automated aggregation and
analysis of applicant responses.



44
  U.S. Department of Justice Office of the Inspector General, Audit Division, A Review of
the Selection Process for the COPS Hiring Recovery Program, Audit Report 10-25
(Washington D.C.: May 2010).




Page 30                                               GAO-12-517 DOJ Grants Management
In contrast, OJP officials said that because of recent upgrades, GMS
could be used or modified in order to query individual searchable
elements. They also stated that variation in the information required by
individual grant programs would not present an insurmountable barrier to
unifying systems. In addition, GMS has served multiple agencies in the
past and can be modified when circumstances warrant. For example, in
2010 and 2011, COPS Office officials successfully used GMS for
awarding purposes under CTAS. According to OJP officials, the initial
coordination with the COPS Office for CTAS purposes required additional
modifications to GMS, but these were not onerous or costly. The officials
said that with relative ease, after the modifications, OJP, OVW, and
COPS Office grant managers all accessed GMS to perform some of the
phases of the CTAS grant process. For example, GMS supports the
management of CTAS by storing all applications, managing peer review
comments, and registering awards once decisions are final. Besides
OVW’s use of GMS to award and manage its grants, the Department of
Homeland Security’s (DHS) Federal Emergency Management Agency
(FEMA) also uses GMS to award and manage grants, though it has future
plans to use a DHS grants system. 45 Further, OJP officials stated that
GMS has a current storage capacity well in excess of what it currently
uses. They also emphasized that OVW and FEMA have grant business
processes that do not completely align with OJP’s, but with small
investments, OJP has been able to adjust GMS to accommodate OVW
and FEMA.

In June 2012, DOJ officials informed us they had engaged a contractor to
assess whether a single grants management system, among a range of
other options, can best serve DOJ’s granting agencies. They plan for the
contractor to report back within 6 months of beginning the analysis and
said that they envision the assessment including an evaluation of costs,
benefits, and technical requirements, such as those needed to harmonize
business processes. Engaging a contractor for this purpose is an
important first step, and doing so could help DOJ make better investment
decisions about the most efficient way to manage its grants systems,
especially when it considers the costs and benefits of having fragmented
grants systems. In the interim, however, DOJ could take a more
immediate solution to foster information sharing across GMS and CMS by



45
  Both OVW and FEMA pay OJP to use GMS through an interagency agreement, and the
rates they have paid in the last 5 years have remained relatively stable.




Page 31                                        GAO-12-517 DOJ Grants Management
                            providing system access to appropriate OJP, OVW, and COPS Office
                            staff—for example, through common login names and passwords, just as
                            department staff have done in limited instances such as the CTAS
                            Program.


DOJ Does Not Timely         DOJ’s granting agencies are not submitting grant award information to
Submit Grant Data to        USASpending.gov in a timely way. In accordance with the Federal
USASpending.gov and Is      Funding and Transparency Act of 2006 (FFATA), USASpending.gov was
                            created to increase the transparency and accountability for federal
Not Fully Leveraging the    funding awarded through contracts, loans, grants, and other awards. 46
Website’s Subgrant Award    OMB issued guidance on reporting the receipt and use of federal funds.
Information before Making   OMB also launched USASpending.gov in December 2007 to allow the
Grant Award Decisions       public to view federal spending and engaged the General Services
                            Administration (GSA) to build and maintain USASpending.gov, among
                            other FFATA-related websites. 47 In August 2010, OMB established
                            guidelines for agencies related to the requirement for prime grantees to
                            report all subgrants over $25,000 in fiscal year 2011. The
                            USASpending.gov website includes the subgrantees’ names,
                            geographical locations of funded activities, specific subgrant amounts,
                            and the funded purposes. A GSA official told us that the FFATA reporting
                            infrastructure is the first time that comprehensive federal grant and
                            subgrant information, including DOJ grant information, has been made
                            widely available on a single website. Through the steps that granting
                            agencies, as well as the grantees, take to supply this website’s content,
                            the public and DOJ’s granting agencies can better track the flow of funds
                            and identify communities receiving funds from multiple streams.

                            OMB’s FFATA guidance requires agencies to submit grant award data by
                            the 5th of each month. USASpending.gov contains validation software
                            used to validate agency data submissions, and if data are rejected,
                            agencies receive automated notification. OMB guidance then requires
                            agencies to resubmit the corrected data to USASpending.gov within 5



                            46
                             See Pub. L. No. 109-282, 120 Stat. 1186 (2006).
                            47
                              To support OMB efforts, GSA hired a vendor to maintain the FFATA reporting
                            infrastructure including the FFATA Subaward Reporting System (FSRS.gov), a federal
                            government website used by federal contractors and grantees to submit data such as
                            subaward information to USASpending.gov, and the USASpending.gov websites. In 2010,
                            USASpending.gov logged 1.8 million website visits.




                            Page 32                                            GAO-12-517 DOJ Grants Management
working days of the rejection notification. 48 OJP manages submissions to
USASpending.gov for all of DOJ—that is for OJP, OVW, and the COPS
Office—and an OJP official reported that DOJ submits grant award
information to USASpending.gov twice per month. However, more than a
quarter of the grant award information that DOJ submitted to
USASpending.gov in fiscal year 2011 was rejected and resubmission took
more than 80 days after the fiscal year ended. 49 Figure 3 illustrates the
flow of grant award information from both DOJ and grantees and some
issues we identified related to DOJ’s fiscal year 2011 reporting.




48
  Office of Management and Budget, Memorandum for the Heads of Departments and
Agencies: Guidance on Data Submission under the Federal Funding Accountability and
Transparency Act, M-09-19 (Washington, D.C.: June 1, 2009).
49
  DOJ typically submits batches of grant award information, and each batch can contain
hundreds of distinct grant awards. Under current OMB guidelines, if more than 10 percent
of the awards in the batch contain errors, such as mistakes in the codes uniquely
assigned to grantees, the entire batch of grant award information is rejected. Upon receipt
of the batch returned, DOJ is then charged with reviewing the entire batch and correcting
the identified errors before GSA will post it.




Page 33                                               GAO-12-517 DOJ Grants Management
Figure 3. DOJ Grant and Subgrant Award Information Flow to USASpending.gov




                                      Agency reporting of prime grant award information in USASpending.gov
                                      is a critical step in the FFATA reporting process because prime grantees
                                      cannot upload their subgrant award information until it occurs. For fiscal
                                      year 2011, DOJ submitted 4,346 distinct prime grant award records to
                                      USASpending.gov; however, GSA rejected 1,152 of these because of
                                      incomplete or inaccurate data associated with some of these grant files,
                                      and DOJ did not resubmit the records within 5 working days as required



                                      Page 34                                      GAO-12-517 DOJ Grants Management
under OMB guidance. Specifically, DOJ did not correct and resubmit the
rejected records until December 22, 2011, which was after we raised this
issue with DOJ and 83 days after the end of the fiscal year. Five out of 11
DOJ prime grantees we interviewed who had awarded subgrants
indicated that, after searching, they could not view their prime DOJ grant
awards on FSRS.gov or USASpending.gov and indicated that DOJ had
not uploaded the information to the websites. Further, another prime
grantee among the 11 with whom we spoke indicated that it was unaware
that subgrant reporting was a requirement. As a result, these prime
grantees were unable to submit their subgrant award information and thus
were unable to comply with OMB subgrant reporting requirements. DOJ
has taken action to help ensure that prime grantees and DOJ grants staff
are aware of FFATA reporting requirements. For example, OJP offered
FFATA reporting training for all DOJ grants staff and grantees, and all
three granting agencies required a special condition in grant awards that
included FFATA reporting requirements. These steps may have informed
grantees of their FFATA responsibilities, but DOJ’s untimely submission
of grant award information to USASpending.gov led to prime grantees
being unable to access their grant awards to submit their subgrant award
information as required by OMB.

OJP officials stated that since 2007 they have been coordinating with
OMB, other federal agencies, and contractors on issues related to
reporting guidelines and other technical requirements related to subgrant
reporting, but that it was not until August 2010 that OMB established
guidelines for the collection and reporting of subgrant information.
Nevertheless, OJP officials stated that the current allotment of 5 days for
agencies to review and resubmit data that GSA originally rejected is an
unreasonable time frame given the time-intensive nature of checking and
correcting errors. Officials also noted that OJP would like to see GSA
allow for the posting of individual records that pass system validation
rather than waiting for entire blocks to be corrected at once before GSA
will post award information to USASpending.gov. In addition, OJP officials
indicated that the information prime grantees ultimately posted about their
subgrantees was limited and in most cases very brief. As a result, the
officials said they were not considering such information before making
new awards.

We recognize that 5 days may not be adequate to correct errors in grant
award information, but we also believe that timely submission of grant
award information on USASpending.gov is key to transparency and the
overall utility of the system for grant decision makers, the criminal justice
community, Congress, and taxpayers. By DOJ ensuring that it submits its


Page 35                                       GAO-12-517 DOJ Grants Management
                           grant award information to USASpending.gov in as timely a manner as is
                           possible, prime grantees’ abilities to report their subgrant activities would
                           likely improve. As a result, DOJ could have greater visibility over which
                           subgrantees were using its money and for what purposes before DOJ
                           makes its grant award decisions. Further, even if DOJ does not believe
                           that the information that prime grantees ultimately post about their
                           subgrantees is ideally descriptive in every instance, the information could
                           provide DOJ with important details—that it currently does not consider or
                           otherwise have access to before finalizing award decisions—related to
                           how subgrantees are using their funds.



DOJ Could Benefit
from Examining Its
Programmatic Grant
Monitoring and
Assessment Functions
and Considering
Expansion of OAAM’s
Authorities
OAAM Uses Programmatic     The statute establishing OAAM tasked the OAAM Director with selecting
Grant Monitoring and       and carrying out program assessments of not less than 10 percent of the
Program Assessment for     aggregate amount of grant funding awarded annually by OJP, the COPS
                           Office, and any other grant programs carried out by DOJ that the Attorney
Grant Oversight, but       General considers appropriate. 50 OAAM officials told us that to meet the
Program Assessments        directive to conduct program assessments, and in recognition of its own
Yield Richer Information   resource constraints, OAAM relies on the programmatic grant monitoring
                           that OJP’s and the COPS Office’s grant staff already conduct. To oversee
                           and track these monitoring efforts, OAAM develops and implements
                           standards and protocols, including a framework and methodology for




                           50
                            See 42 U.S.C. § 3712h(b), (c).




                           Page 36                                       GAO-12-517 DOJ Grants Management
systematically identifying high-risk grantees. 51 OAAM also tracks OJP’s
and the COPS Office’s monitoring progress and compares it against an
established annual monitoring plan. For example, in its fiscal year 2010
annual report—the latest available—on both OJP and the COPS Office’s
monitoring goals and activities, OAAM found that both offices exceeded
their goals of monitoring 10 percent of total award funding. OJP
monitored 1,447 grantees with awards totaling $3.05 billion, and the
COPS Office monitored 185 grantees with awards totaling $234.74
million. In addition to overseeing monitoring activities, OAAM also
conducts program assessments of OJP and COPS Office grant
programs. OAAM considers monitoring—and its oversight of it—as
responsive to its originating statute’s intent, but it also recognizes that
assessments have utility and serve a separate but important function in
helping the office improve grant management. Table 4 illustrates the
distinction between OJP’s and the COPS Office’s monitoring and OAAM’s
assessment functions.




51
  DOJ designates grantees as high risk based on a number of factors, including but not
limited to, a history of unsatisfactory performance, financial instability, an inadequate
financial management system, or nonconformance to terms and conditions of previous
awards. Additional reporting requirements are imposed on high-risk recipients. OAAM’s
Audit and Review Division coordinates the high-risk grantee list and works to either
resolve the issues underlying the high-risk designation or to impose conditions on high-
risk grantees to ensure appropriate stewardship of federal funds and enhance
programmatic results.




Page 37                                                GAO-12-517 DOJ Grants Management
Table 4: Comparison of Programmatic Grant Monitoring and Program Assessment Activities

OJP’s and the COPS Office’s programmatic grant monitoring                  OAAM’s grant program assessments
Who conducts:                                                              Who conducts:
•  Grant staff in OJP’s program offices and COPS Office’s Grant            •  Analysts in OAAM.
   Monitoring Division.                                                    Scope:
Scope:                                                                     •  Can focus on a whole or one aspect of a grant program.
•  Focuses on individual grant recipients one at a time.                   Characteristics:
Characteristics:                                                           •  Systematic review and evaluation of programs to gauge
•  Checks that the grantee complies with the programmatic,                    effectiveness, identify promising practices, and document
   administrative, and financial requirements.                                impediments.
•  Advocates responsible stewardship of awarded funds.                     •  Begins with research into a grant program’s issue area,
•  Verifies that grant implementation is consistent with the                  origin, and original purpose, along with key program
   grantee’s stated plan, policy guidelines, and applicable DOJ               challenges and issues.
   rules and regulations.                                                  •  Uses a variety of analytical approaches, depending on the
•  Observes and verifies project implementation for promising                 goals of the assessment, to provide bureaus and program
   practices.                                                                 offices with information to improve their programs.
Results:                                                                   Results:
•  Provides guidance to the grantee on DOJ policies and                    •  May result in recommendations to grant-making offices and
   procedures, and programmatic, administrative, and financial                bureaus for improving their grant programs.
   reporting requirements.                                                 •  When recommendations are made, OAAM staff work with
•  Works with the grantee to identify any problems and provide                program offices to implement recommendations.
   assistance to resolve them.
•  Recommends appropriate and available training or technical
   assistance.
                                          Source: GAO analysis of DOJ information.


                                          In general, both monitoring and assessment are important and
                                          complementary tools for grant oversight. Nevertheless, we found that
                                          OAAM’s program assessments yield richer information to enhance grant
                                          programs than either OJP’s or the COPS Office’s individual monitoring
                                          reports or the summary reports that OAAM’s Program Assessment
                                          Division (PAD) compiles because the program assessments are more
                                          analytical and broader in perspective. OAAM’s PAD Standard Operating
                                          Procedures define a program assessment as “a systematic review and
                                          evaluation of programs to gauge effectiveness, identify promising
                                          practices, document impediments, and when necessary, make
                                          recommendations for improvement.” OAAM reported to us that from 2008
                                          through mid-February, 2012, its staff had produced 28 products; however,
                                          when we reviewed the 28, we found that 7 met OAAM’s definition for a




                                          Page 38                                                      GAO-12-517 DOJ Grants Management
program assessment. 52 For example, in 2012, OAAM completed an
assessment report on the COPS Office Methamphetamine Initiative. In
2011, it completed one on BJA payment programs, and in 2010, it
assessed the ICAC Training and Technical Assistance Program. The
other 21 publications were user guides; summaries of monitoring reports,
such as those described earlier; or Recovery Act risk indicator reports,
which identify potentially high-risk grantees so that the program offices
can work with those grantees to resolve issues and prevent potential
problems. According to OJP, all of OAAM’s publications contribute to
improving OJP’s grant programs and operations by strengthening internal
controls, streamlining processes to be more efficient, or reporting on how
well programs and policies are meeting their objectives.

Of the 7 publications meeting OAAM’s definition for program
assessments, 2 reviewed a single aspect of the grant cycle—program
awarding—within a particular grant program rather than the grant
program overall. 53 Nevertheless, all 7 were based on a much more
thorough review of the extent to which a grant program is meeting its
intended purpose. Moreover, each recommended specific actions to
address identified program deficiencies, and implementation of these
recommendations has helped DOJ enhance its grant programs. For
example, the 2010 ICAC assessment report contained 11
recommendations related to the collection and use of performance
measurement data, financial management, fair and open competition for
awards, and improving grant management and oversight. In our review of
the six monitoring reports that the ICAC grant manager completed for the
ICAC program’s sole grantee, there was no mention of the same
deficiencies. In particular, none of the six monitoring reports identified the
unallowable costs, conflict of interest, or inadequate oversight and
documentation of grant activity that the OAAM assessment report
identified. Instead, the monitoring reports showed that the grantee was
progressing as expected on implementation of the program, and was on
schedule with no problems noted.



52
  OAAM considered eight of its products to be program assessments. However, we
eliminated one because it did not specifically look at a DOJ grant program.
53
 In 2011, OAAM issued assessment reports for the Bureau of Justice Assistance
Recovery Act Programs Combating Criminal Narcotics Activity Stemming from the
Southern Border of the United States (CCNA program), and the Assistance to Rural Law
Enforcement to Combat Crime and Drugs (RLE program).




Page 39                                            GAO-12-517 DOJ Grants Management
OAAM also assessed BJA’s payment programs, which otherwise are not
subject to BJA grant monitoring. In the November 2011 report, OAAM
assessed the processes that BJA used to verify the eligibility and
accuracy of reimbursement requests submitted by grantees. 54 The
assessment concluded that BJA is administering its payment programs
appropriately to verify the eligibility and accuracy of payments, but it also
determined that additional internal controls were necessary and that
procedures were not sufficient to identify duplicate payment requests from
grantees. As a result of the assessment, OAAM made six
recommendations to BJA, including implementing additional procedures
to identify duplicate requests for payments of detention expenses. In
particular, one of OAAM’s recommendations was that BJA implement a
process to identify overlapping requests for reimbursement between two
of the programs for expenses related to detention of criminal aliens. In
response, BJA compared all of those programs’ applications for
reimbursement for fiscal year 2011 to identify whether jurisdictions were
requesting reimbursement for the detention of the same individuals over
the same period of time. BJA’s review led to the removal of approximately
$5.8 million in requests for reimbursement prior to generating the final
reimbursement awards.

Standards for Internal Control in the Federal Government calls for
managers to compare actual performance with planned or expected
results throughout the organization and analyze significant differences.
These standards also identify that program managers need both
operational and financial data to determine whether they are meeting their
agencies’ strategic and annual performance plans and meeting their
goals for accountability for effective and efficient use of resources. The
programmatic grant monitoring reports that each of the granting agencies
compile contribute to meeting these standards at the grantee level by
tracking the progress and, when necessary, providing assistance to
individual grant recipients. OAAM’s summaries of these reports then roll


54
  This assessment included the following programs: the Bulletproof Vest Partnership
Program, which assists state, local, and tribal law enforcement agencies with purchasing
body armor for sworn personnel; the State Criminal Alien Assistance Program
(SCAAP),which provides assistance to states and localities by reimbursing them for
correctional officer salary costs associated with incarcerating undocumented criminal
aliens; the Southwest Border Prosecution Initiative (SWBPI); and the Northern Border
Prosecution Initiative (NBPI), which reimburses state, local, and tribal jurisdictions for
prosecuting criminal cases declined by U.S. Attorneys’ offices and for pretrial detention
expenses in states along the southern and northern borders, respectively.




Page 40                                               GAO-12-517 DOJ Grants Management
up the statistics and ensure the compliance monitoring occurs as
required. However, OAAM’s program assessments are more
comprehensive than both the individual grant monitoring reports and the
summary reports OAAM prepares because their broader perspective
allows for reporting on program successes, impediments, and potential
areas for improvement. While monitoring 10 percent or more of the
aggregate amount of grant funding awarded annually is important and
beneficial to the grant management process, the 7 program assessment
reports that OAAM has issued since 2008 have led to more than 50
recommendations for the improvement of OJP and COPS Office grant
programs.

According to OAAM officials, additional program assessments would be
beneficial; however, they told us that OAAM does not have sufficient
resources to conduct more. They said that conducting program
assessments on 10 percent of the aggregate amount of grant funds
awarded annually would not be possible given current resources, but they
also noted that the department has not conducted a feasibility analysis
that considers the costs and benefits of having OAAM conduct
assessments on a larger number of grant programs. Further, OJP officials
stated that since the establishment of OAAM, the administration has
never requested, and the department has not received, the full amount
authorized for appropriation under OAAM’s governing statute. 55 DOJ
officials did not explain the rationale for the administration’s budget
proposals and officials did not report any plans to increase OAAM’s
resources. As of December 2011, out of a total of 49 staff (26 federal staff
authorized by DOJ and 23 contractors) spread across OAAM’s three
divisions, OAAM had 8 staff (5 federal staff authorized by DOJ and 3
contractors)—or less than 20 percent—in its PAD dedicated to performing
program assessments in addition to overseeing OJP and COPS Office
programmatic monitoring. 56 OAAM also has 18 staff (10 federal staff


55
  Pursuant to its authorizing statute, not more than 3 percent of all funding made available
for programs under OAAM’s purview in a fiscal year shall be available to OAAM for,
among other things, carrying out and coordinating program assessments. See 42 U.S.C. §
3712h(a)(2).
56
  In a March 2011 report the IG reported that, as of May 2009, OAAM had filled all of its
49 federal employee and contractor positions, but in May 2012, OJP reported that OAAM
has undergone attrition and is currently 20 percent below its authorized staffing level. See
U.S. Department of Justice, Office of the Inspector General, Audit Division, Audit of the
Office of Justice Programs’ Monitoring and Oversight of Recovery Act and Non-Recovery
Act Grants, Audit Report 11-19 (Washington D.C.: March 2011).




Page 41                                                GAO-12-517 DOJ Grants Management
authorized by DOJ and 8 contractors)—or more than 30 percent—
working in its Audit and Review Division to coordinate IG, GAO, and
Single Grant Audit resolutions, 57 and to conduct A-123 reviews—activities
that are not specifically addressed in OAAM’s authorizing statute. 58
Appendix V contains further discussion of the different activities of
OAAM’s three divisions. Because DOJ considers its resources to be
limited, it is important that OAAM’s resources be used as efficiently as
possible to maximize the investment in grant programs. Thus, given the
different roles that grant monitoring and program assessment play in
assessing the overall effectiveness of grant programs, considering
whether it employs an appropriate mix of monitoring and program
assessments could aid DOJ in awarding grant funds in the most efficient
and effective way possible.




57
  Pursuant to the Single Audit Act, as amended, each nonfederal entity that expends
$500,000 or more in federal awards, including grants and other assistance, in a fiscal year
must obtain an annual “Single Audit,” which includes an audit of the entity’s financial
statements and a schedule of the expenditure of federal awards, as well as, among other
things, a review of related internal controls. See 31 U.S.C. §§ 7501-07.
58
  OAAM annually reviews OJP’s critical business processes in the areas of financial
management, information technology, and grant management and makes
recommendations to enhance and strengthen internal controls as required by OMB
Circular A-123, “Management’s Responsibility for Internal Control.”




Page 42                                               GAO-12-517 DOJ Grants Management
Not Including OVW in         Consistent with the 2000 reauthorization of the Violence Against Women
OAAM’s Oversight Has         Act, the Attorney General submits a biennial report to Congress on the
Resulted in Inconsistent     effectiveness of VAWA-funded grant programs. 59 OVW uses the VAWA
                             Measuring Effectiveness Initiative, conducted under a noncompetitive
Assessment of the
                             cooperative agreement with a university to develop and implement
Effectiveness of DOJ Grant   reporting tools, as the primary way it meets statutory requirements to
Programs                     report on the effectiveness of VAWA-funded programs. 60 Staff from the
                             university also provide data collection training to grantees to ensure that
                             they use the forms and database properly, and then use the information
                             collected to summarize grantee performance in semiannual summary
                             data reports. The results of this initiative are summary data reports that
                             university staff compile from the semiannual or annual progress reports
                             that grantees submit to OVW. OVW then uses these summaries to meet
                             biennial reporting requirements for its discretionary grant programs under
                             VAWA and, for example, the Services, Training, Officers, Prosecutors
                             (STOP) Violence Against Women Formula Grant Program (STOP
                             Program). 61 The STOP Program promotes a coordinated,
                             multidisciplinary approach to improving the criminal justice system’s
                             response to violent crimes against women and increasing the availability
                             of victim services.

                             OVW’s biennial reports are composed of three main components:

                             •    a literature review of research showing (where available) the
                                  effectiveness of grant-funded activities and (when such research is
                                  not available) information on promising or best practices in the field of
                                  victims services;


                             59
                               Specifically, the Violence Against Women Act of 2000 provided that the Attorney
                             General or Secretary of Health and Human Services, as applicable, shall require grantees
                             under any program authorized or reauthorized under the act report on the effectiveness of
                             the activities carried out with amounts made available for the program. See Pub. L. No.
                             106-386, Div. B, § 1003(a), 114 Stat. 1464, 1491 (2000) (codified at 42 U.S.C. §
                             3789p(a)). It further required the Attorney General or Secretary, as applicable, to report
                             biennially to the Committees on the Judiciary of the Senate and House of Representatives
                             on the grant programs described, including any information reported by grantees. See 42
                             U.S.C. § 3789p(b).
                             60
                               Information on which the Attorney General shall report related to the effectiveness of
                             activities carried out with VAWA grant funds includes the number of persons served and, if
                             applicable, the number of persons seeking services who could not be served.
                             61
                               Prior to enactment of the Violence Against Women Act of 2005, VAWA required that the
                             Attorney General report annually on the STOP Program.




                             Page 43                                              GAO-12-517 DOJ Grants Management
•   a summary of performance measure data, such as the number of
    grant-funded staff, the number of people trained, and the number of
    victims/survivors seeking services that are served, partially served,
    and not served, as reported by the grantees to OVW through OJP’s
    GMS; and

•   anecdotal evidence from grantees on the benefit of what they are able
    to do with grant funds.

The statute establishing OAAM did not give it oversight authority for OVW
programs. Provisions in the authorizing statute, however, provide the
Attorney General with discretion to expand OAAM’s scope beyond OJP
and COPS Office programs, which the Attorney General has not
undertaken. As a result, while OVW uses its data collection and analysis
to report on grant program effectiveness, in accordance with the VAWA
requirement, by providing information on activities carried out with grant
funds and the number of persons served using those funds, it does not
benefit from the monitoring oversight and grant program assessments
that OAAM provides. Such assessments could provide OVW with more
substantive information on its grant programs.

Table 5 contains a comparison of the analytical approaches that OVW
uses when it reports to Congress on the effectiveness of its grant
programs against those that OAAM uses in its program assessments. On
the basis of a review of seven OVW reports and seven OAAM grant
program assessment reports, we found that OVW’s reports contain less
analysis than the OAAM reports do. Specifically, these OVW reports
summarized performance measurement data rather than analyzed it.
Further, these OVW reports did not address grant program operations
and management. OAAM, in contrast, used more varied approaches to
analyze grant programs, which provided information on both grant
program performance and operations, identified areas for improvement,
and resulted in specific recommendations to OJP’s bureaus and program
offices, and the COPS Office.




Page 44                                      GAO-12-517 DOJ Grants Management
Table 5: Comparison of OVW and OAAM Measurement of Grant Program Effectiveness

                                                                                                                Number of OVW               Number of OAAM
                                                                                                               reports including            reports including
Analytical approaches                                                                                                  approach                     approach
Comparative analysis—seeks to identify the strengths and weaknesses of two or                                                           0                  1
more comparable programs or processes
Compliance analysis—determines whether a program is being operated within                                                               0                  2
the laws and regulations under which it is funded
Grant administrative requirements review—examines the extent to which                                                                   0                  5
grants comply with grant administrative requirements
Financial/grant expenditure review—reviews the financial history of a grant to                                                          0                  3
ensure that grantees properly accounted for expenditures
Literature review—examines related research on the effectiveness of grant-                                                              7                  1
funded programs or best practices in the field
Output analysis—identifies the direct products or services delivered by a                                                               7                  2
program
Performance measurement analysis—determines whether a grant program or                                                                  0                  3
its grantee has useful and appropriate performance data to measure program
effectiveness
Process analysis—determines the extent to which a program is operating under                                                            0                  7
its original intent or whether there are particular processes that could be improved
Trend analysis—examines historical results to attempt to identify patterns and                                                          0                  2
trends in order to predict a future outcome
                                             Source: GAO analysis of information from DOJ and the Measuring Effectiveness Initiative.


                                             Unlike the OAAM analysts who conduct assessments of OJP and COPS
                                             Office grant programs, the university staff responsible for the Measuring
                                             Effectiveness Initiative do not have access to grant program financial data
                                             or OVW grant monitoring reports. Additionally, university staff involved in
                                             the initiative do not conduct site visits to validate the data provided by
                                             grant recipients and the work they perform. Instead, OVW staff in each
                                             program area review the results of the biennial reports and the
                                             semiannual summary data reports compiled from grantee progress
                                             reports to identify priority areas where there is an unmet need. The OVW
                                             reports contain sections on “remaining areas of need” identified by grant
                                             recipients. However, the areas of need that OVW identified are based on
                                             comments grant recipients provided on gaps in service, rather than being
                                             based on an independent assessment that OVW conducted on the overall
                                             grant programs. Moreover, unlike the grant program assessments that
                                             OAAM conducts, beyond identifying areas of need, the biennial reports do
                                             not result in concrete recommendations for improving OVW’s grant
                                             programs. OVW officials told us that for the upcoming 2012 biennial
                                             report, they plan to focus more attention to the discussion of remaining
                                             areas of need.


                                             Page 45                                                                       GAO-12-517 DOJ Grants Management
According to OVW’s 2010 Biennial Report to Congress on the
Effectiveness of Grant Programs Under the Violence Against Women Act,
demonstrating the effectiveness of services provided by agencies funded
under OVW presents a challenge for those charged with meeting the
reporting mandate of VAWA 2000. An OVW official told us that it is
difficult to discern between output and outcomes when dealing with the
grant programs in OVW and that it is difficult to measure outcomes with
service grant programs. 62 For example, OVW might consider whether an
abuse victim not only gets a protective order but also receives additional
services. Additionally, according to OVW officials, it would be difficult to
track how many victims received different types of services in multiple
areas, because OVW service provider grantees only track the first
instance in which a victim receives services and do not follow up on
related services.

According to the federal Domestic Working Group Grant Accountability
Project’s Guide to Opportunities for Improving Grant Accountability,
agencies need a process for managing performance once grants are
awarded, and the ability to assess grant results and use those results
when awarding future grants. The Working Group identified engaging
outside experts to assess program performance, inspecting projects after
completion, and conducting evaluations to identify factors affecting results
among its promising practices to improve program performance. These
activities are not part of OVW’s current approach to program oversight.

OVW conducts its grant program monitoring as well as IG audit follow-up.
Additionally, OVW has a Grant Assessment Tool (GAT)—designed by the
same company that produced the GAT for OJP. 63 OAAM currently
conducts Single Audit follow-ups; manages the high-risk grantee list; and
oversees DOJ’s combined programmatic and financial monitoring plan,
which is the combined monitoring list of all the sites that OJP, OVW, and
the COPS Office plan to visit for the year. In a March 2011 audit, the IG
found that OVW and the COPS Office perform certain monitoring and
oversight services that are duplicative of the services available through
OJP and recommended that DOJ standardize the oversight services



62
  Outputs are the direct products or services delivered by a program. Outcomes are the
results of those products and services.
63
  OVW’s Grant Assessment Tool is a database containing 18 standard elements to
evaluate the level of risk associated with grantees in order to prioritize monitoring.




Page 46                                                GAO-12-517 DOJ Grants Management
              provided to OVW and the COPS Office to eliminate such duplication and
              provide uniformity in oversight among DOJ granting agencies. OAAM
              provides certain administrative services that facilitate grant program
              management, but DOJ officials told us the reason OAAM does not have
              oversight over OVW is because the Attorney General has not extended
              OAAM’s purview. OJP officials told us that they have not been provided
              the scope of work that OVW oversight may encompass and, as such,
              OAAM has not conducted any analyses using a workforce model to
              determine the staffing levels, associated resources, and other possible
              impacts (i.e., costs and benefits) of having OVW under its purview on
              OAAM operations.

              OVW officials expressed concern that OAAM staff would not have any
              expertise in violence against women issues. However, OAAM currently
              has oversight over specialized bureaus and offices such as the Office for
              Victims of Crime and the Office of Sex Offender Sentencing, Monitoring,
              Apprehending, Registering, and Tracking. Additionally, OVW officials
              stated that OAAM does not perform data collection and analysis activities,
              which are the primary activities of the Measuring Effectiveness Initiative.
              However, as a part of its assessments, OAAM has collected performance
              measures and conducted analysis. For example, in its assessment of the
              ICAC Training and Technical Assistance Program, OAAM collected and
              analyzed national performance metrics related to training. Given the
              nature of OAAM assessments, along with the other oversight services it
              provides to OJP and the COPS Office, the information resulting from
              OAAM assessments of OVW grant programs could better inform OVW
              about its grant programs and funding to assist with future program design
              and award decisions while also providing Congress with a more complete
              picture on the effectiveness of programs funded under VAWA.
              Accordingly, DOJ could benefit from assessing the feasibility, costs, and
              benefits of OAAM providing grant program assessments for OVW.


              The statutory design of DOJ’s grant programs has contributed to overlap
Conclusions   across a number of justice areas. We recognize that even when programs
              overlap, there may be meaningful differences in their eligibility criteria or
              objectives, or they may be providing similar types of services in different
              ways. We also recognize that a number of grant programs are formula-
              driven and therefore grantees’ eligibility is predetermined. However,
              because DOJ exercises independent judgment when making
              discretionary awards and therefore has full responsibility for how it
              conducts its pre-award reviews, it will be important for the department to
              maximize visibility over how grantees plan to spend the funds they


              Page 47                                      GAO-12-517 DOJ Grants Management
receive from multiple funding streams. In some instances, DOJ may
deem it appropriate for large numbers of distinct grant programs to serve
one goal, or for the same communities to benefit from multiple streams of
its grant funding. In these cases, duplication may be warranted. However,
because we found routine coordination and consistent policies and
procedures for sharing information across the granting agencies during
DOJ’s pre-award phase limited, we do not believe DOJ knows with
certainty if such duplication is always necessary.

DOJ’s three granting agencies have taken some steps to coordinate their
grant-related activities and have sought congressional approval in some
instances for grant program consolidation. Further, they have initiated
other, limited actions to ensure that grantees report additional streams of
funding. However, DOJ limits its view of duplication to instances where
grant applicants apply for and receive multiple streams of funding,
including DOJ funding, to support single costs associated with a single
grant project. Using this definition, DOJ believes that any unnecessary
duplication can be identified through monitoring grantees post-award. We
take a broader view of duplication and consider it potentially unnecessary
when DOJ is unaware that grantees have applied for and are receiving
funding for potentially the very same or similar purposes. Therefore, we
believe it is incumbent that DOJ take steps in the pre-award phase to
make purposeful judgments about funding necessity before finalizing the
awards. Doing so would help the department better mitigate this risk for
potential, unnecessary duplication. Specifically, by conducting a broad
examination of all DOJ grant programs to systematically identify justice
areas for which funding overlaps, DOJ would have greater visibility over
how its funding can be used and whether it is awarding grant dollars in
the most efficient way possible. Further, developing and implementing
policies and procedures to require granting agencies to routinely share
and consider information each may have about past or prospective
grantee funding could provide DOJ with more strategic visibility over its
awarding decisions. In addition, requiring all grantees to report current or
prospective federal funding sources when applying for DOJ grants could
provide DOJ with more information to better target its limited financial
resources before it finalizes new grant awards.

Additionally, by taking interim steps to expand access to the two distinct
grant management systems—CMS and GMS—DOJ could better ensure
that grant managers and decision makers can leverage all existing tools
while a longer-term study to consider the feasibility, costs, and benefits of
potential options for DOJ grant management systems is underway. Such
options could include unifying the systems, creating a DOJ-wide system,


Page 48                                       GAO-12-517 DOJ Grants Management
                      or using off-the-shelf software to bridge information gaps. Related, DOJ
                      can have greater confidence that any variation in how the granting
                      agencies are currently managing their portfolios does not hinder any
                      potential unification by ensuring that its planned study include an
                      assessment of the steps needed to harmonize DOJ grant processes.
                      Further, with additional steps to ensure that DOJ is submitting grant
                      award information to USASpending.gov in the most timely manner
                      possible, the department could facilitate prime grantees’ uploading of
                      information on subgrantees’ use of funds and therefore make the website
                      a more useful resource to DOJ’s own grant decision makers. Finally,
                      recognizing the value of OAAM’s role, assessing whether the office relies
                      on an appropriate mix of programmatic grant monitoring and program
                      assessment—as well as considering expansion of OAAM’s coverage to
                      include OVW—could improve the overall operation of grant programs
                      departmentwide.


                      To ensure that DOJ can identify overlapping grant programs to either
Recommendations for   consolidate or coordinate similar programs, mitigate the risk of
Executive Action      unnecessary grant award duplication in its programs, and enhance DOJ’s
                      ability to gauge grant program effectiveness, we recommend that the
                      Attorney General take the following eight actions:

                      1. Conduct an assessment to better understand the extent to which the
                         department’s grant programs overlap with one another and determine
                         if grant programs may be consolidated to mitigate the risk of
                         unnecessary duplication. To the extent that DOJ identifies any
                         statutory obstacles to consolidating its grant programs, it should work
                         with Congress to address them, as needed.

                      2. Coordinate within and among granting agencies on a consistent basis
                         to review potential or recent grant awards from grant programs that
                         DOJ identifies as overlapping, including subgrant awards reported by
                         prime grant awardees, to the extent possible, before awarding grants.
                         DOJ should also take steps to establish written policies and
                         procedures to govern this coordination and help ensure that it occurs.

                      3. Require its grant applicants to report all federal grant funding,
                         including all DOJ funding, that they are currently receiving or have
                         recently applied for in their grant applications.

                      4. Provide appropriate OJP and COPS Office staff with access to both
                         GMS and CMS and appropriate OVW staff with access to CMS.



                      Page 49                                     GAO-12-517 DOJ Grants Management
                     5. As part of DOJ’s evaluation of its grant management systems, DOJ
                        should ensure that it assesses the feasibility, costs, and benefits of
                        moving to a single grants management system, including the steps
                        needed to harmonize DOJ grant processes, so that any variation in
                        how the granting agencies manage their portfolios is not an
                        encumbrance to potential system unification.

                     6. Ensure the most timely reporting possible of grant award information
                        to USASpending.gov according to OMB guidelines, which would
                        enable its grantees to comply with their reporting responsibilities
                        according to the same guidelines.

                     7. Assess whether OAAM relies on an appropriate mix of programmatic
                        grant monitoring and program assessment, and determine whether
                        the office could support additional program assessments.

                     8. Assess the feasibility, costs, and benefits of OAAM providing
                        assessments for OVW, in addition to OJP and the COPS Office. If
                        DOJ determines that OAAM assessments of OVW grant programs
                        would be more cost-effective and provide greater insight into the
                        effectiveness of OVW grant programs than OVW’s current approach,
                        then the Attorney General should extend OAAM’s oversight to include
                        OVW.


                     We provided a draft of this report to DOJ for comment. DOJ provided
Agency Comments      written comments, which are reproduced in full in appendix VI, and
and Our Evaluation   concurred with all eight of the recommendations. DOJ also described
                     actions it has underway or plans to take to address the recommendations.

                     •   DOJ agreed with the first recommendation that it conduct an
                         assessment to better understand the extent to which the department’s
                         grant programs overlap with one another. DOJ stated it will explore
                         options for carrying out such an assessment in an effort to reduce the
                         risk associated with unnecessary or inappropriate program
                         duplication. For example, DOJ stated it is considering tasking OAAM
                         to conduct such an assessment. Since DOJ is developing options for
                         how it will implement this recommendation, it is too soon to know what
                         specific actions DOJ will take, when they will be completed, and
                         whether they will fully address the intent of the recommendation.

                     •   DOJ agreed with the second recommendation that it coordinate within
                         and among granting agencies, to the extent possible, before awarding
                         grants. DOJ stated that its grant-making agencies will continue to


                     Page 50                                      GAO-12-517 DOJ Grants Management
    closely collaborate and share information prior to making grant
    awards. DOJ also stated it plans to use the results of the assessment
    referenced in the first recommendation to develop a targeted and
    strategic approach for reviewing grant applications during the pre-
    award process. Since DOJ is considering how it will implement this
    recommendation, it is too soon to know what specific actions DOJ will
    take, when they will be completed, and whether they will fully address
    the intent of the recommendation.

•   DOJ agreed with the third recommendation that DOJ require its grant
    applicants to report all federal grant funding, including all DOJ
    funding, that they are currently receiving or have recently applied for
    in their grant applications. DOJ stated it plans to use a risk-based
    approach to implement this recommendation, using the results from
    its assessment in response to the first recommendation. This is a
    positive step toward ensuring that DOJ has a more complete picture
    of an applicant’s access to other federal funding. However, since DOJ
    has not yet developed its approach, it is too soon to tell whether
    DOJ’s actions will address the intent of the recommendation.

•   DOJ agreed with the fourth recommendation that DOJ provide
    appropriate OJP and COPS Office staff with access to both GMS and
    CMS and appropriate OVW staff with access to CMS. DOJ noted that
    OJP will provide read-only GMS access to COPS Office staff and that
    the COPS Office will provide reports to OJP and OVW from CMS,
    given the technological barriers to providing external system access.
    These actions, when implemented, should address the intent of this
    recommendation.

•   DOJ agreed with the fifth recommendation that as part of its
    evaluation of its grant management systems, DOJ should ensure it
    assesses the feasibility, costs, and benefits of moving to a single
    grants management system. DOJ stated that it had initiated such a
    study and plans to complete it within the next six months. When
    effectively completed, this study, along with any actions taken to
    implement its findings, should address the intent of this
    recommendation.

•   DOJ agreed with the sixth recommendation that DOJ ensure the most
    timely reporting possible of grant award information to
    USASpending.gov. DOJ committed to doing its best to ensure timely
    reporting, but did not provide specific actions or plans to address the
    intent of the recommendation.




Page 51                                      GAO-12-517 DOJ Grants Management
•   DOJ agreed with the seventh recommendation that DOJ assess
    whether OAAM relies on an appropriate mix of programmatic grant
    monitoring and program assessment, and whether the office could
    support additional program assessments. DOJ stated that additional
    program assessments would be beneficial and contribute to the
    improvement of grant programs and operations. DOJ also stated it
    would explore ways to conduct more program assessments, but did
    not provide specific actions or plans to address the intent of the
    recommendation.

•   DOJ agreed with the eighth recommendation that DOJ assess the
    feasibility, costs, and benefits of OAAM providing assessments for
    OVW, in addition to OJP and the COPS Office. DOJ stated that
    discussions have been initiated between OAAM and OVW related to
    this recommendation. This is a positive first step, but it is too soon to
    know whether the results of these discussions and any resulting
    potential future actions will address the intent of the recommendation.

In addition, DOJ raised concerns about the methodology we used to
identify overlap in DOJ’s fiscal year 2010 grant program solicitations
across 10 broad justice themes. DOJ stated that our analysis of potential
overlap between DOJ funding solicitations substantially overstated the
number of programs that might be duplicative. DOJ commented that the
table we used to show the overlap was an indication that DOJ was
involved in “wasteful duplication.” Our analysis, as summarized in table 2
of this report, demonstrates overlap in the justice areas that DOJ’s grant
programs aim to support. Having several overlapping grant programs
within individual justice areas requires greater visibility and pre-award
coordination on the part of DOJ to diminish the risk of unnecessary
duplication at the grant project level. As such, our analysis does not, on
its own, indicate unnecessary duplication among DOJ grant programs,
but instead identifies the potential risk of unnecessary duplication.
Implementing the recommendations in this report that DOJ assess grant
program overlap and coordinate grant award decisions will help DOJ
identify areas of overlap and mitigate the risk of unnecessary duplication
in grants. DOJ also considered the categories we developed for our
analysis such as “community crime prevention strategies” as too broad
and exclusive of specialized programs such as community policing. We
developed our 10 broad justice areas based mainly on programmatic
information contained on DOJ granting agency websites and other DOJ
literature and believe they fairly demonstrate overlap among DOJ’s
various grant programs. We recognize that the more detailed analysis we




Page 52                                       GAO-12-517 DOJ Grants Management
recommended and DOJ agreed to undertake is necessary to determine
the extent of any unnecessary duplication.

DOJ also commented that our sample size of grant applications was too
small in number and was not generalizable. As discussed in this report,
our sample size was not intended to be generalizable across the entire
scope of DOJ grant program awards, but instead was meant to illustrate
the potential for unnecessary duplication. DOJ further commented that
their investigation of the examples of unnecessary duplication we
provided proved that no duplication actually existed in the grant
programs. DOJ conducted its review after we provided our examples and
focused on how grantees were using the funds they had received. Our
analysis of potential duplication focused on grant applications—how
applicants proposed to spend federal grant dollars—and not on the
verification of activities grantees carried out once DOJ funded them.
DOJ’s plans to improve pre-award coordination are positive steps and we
believe that by doing so, DOJ will be better positioned to make better
informed decisions about the financial needs of grantees and
communities for their proposed projects.

Finally, DOJ expressed concern that the report implies that DOJ is not
tracking subgrantees’ activities. Our analysis focused on pre-award
coordination, not DOJ’s efforts to track subgrantee activities. As such, we
recommended that DOJ use the subgrant award information it does have
to help inform DOJ’s grant award decision making. We believe that
subgrant award information could provide DOJ decision makers with a
more complete financial picture of applicants and the projects they
propose to be funded by DOJ.


We are sending copies of this report to the Attorney General, selected
congressional committees, and other interested parties. In addition, the
report is available at no charge on the GAO website at
http://www.gao.gov.




Page 53                                      GAO-12-517 DOJ Grants Management
If you or your staff have any questions about this report, please contact
me at (202) 512-9627 or maurerd@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. Key contributors to this report are listed in
appendix VII.




David C. Maurer
Director, Homeland Security and Justice Issues




Page 54                                       GAO-12-517 DOJ Grants Management
List of Congressional Committees

The Honorable Patrick J. Leahy
Chairman
The Honorable Chuck Grassley
Ranking Member
Committee on the Judiciary
United States Senate

The Honorable Lamar Smith
Chairman
The Honorable John Conyers, Jr.
Ranking Member
Committee on the Judiciary
House of Representatives




Page 55                            GAO-12-517 DOJ Grants Management
Appendix I: Objectives, Scope, and
              Appendix I: Objectives, Scope, and
              Methodology



Methodology

              This report answers the following questions: (1) To what extent does
              overlap across Department of Justice (DOJ) grant programs exist and
              contribute to the risk of unnecessary duplication in grant awards? (2) To
              what extent has DOJ taken steps to reduce overlap in its grant programs
              and the potential for unnecessary duplication in grant awards? (3) To
              what extent does DOJ use programmatic grant monitoring and
              assessment to determine grant program effectiveness and use the results
              to enhance its grant programs?

              To examine the extent to which overlap across DOJ grant programs
              exists, we identified the total number of DOJ grant solicitations for fiscal
              year 2010. To do this, we reviewed the lists posted on the Office of
              Justice Programs (OJP), Office on Violence Against Women (OWV), and
              Community Oriented Policing Services (COPS) Office websites and
              confirmed the currency of the information with DOJ officials. To determine
              whether these solicitations were announcing grant funding available for
              similar or overlapping purposes, we first established 10 categories of
              criminal justice areas. We developed these 10 categories after reviewing
              comparable justice areas identified within OJP’s CrimeSolutions.gov
              website, which OJP officials stated includes themes addressed through
              OVW and COPS Office programs; OJP’s Fiscal Year 2010 Program Plan;
              and other materials from OVW and the COPS Office, such as justice
              program themes from their respective websites. Next, through analyst
              consensus, we sorted the grant solicitations according to the 10 justice
              categories. After identifying solicitations with similar scopes, we then
              reviewed 26 successful grant applications that were awarded under
              similar solicitations to identify and assess specific examples of how the
              recipients planned to use funds from multiple programs in the same or
              similar manner. The sample we reviewed is not generalizable to all DOJ
              grant programs because we did not review all of the more than 11,000
              grant applications that DOJ funded in fiscal year 2011, but it illustrates the
              potential for unnecessary duplication. To determine if DOJ could take
              more action to avoid program overlap that can lead to unnecessary
              duplication, we applied the Domestic Working Group Grant Accountability
              Project’s Guide to Opportunities for Improving Grant Accountability.

              To examine the extent to which DOJ has taken steps to reduce overlap in
              its grant programs and the potential for unnecessary duplication in grant
              awards, we reviewed agency policies, procedures, and guidance on grant
              program design and award, such as the COPS Office Program
              Development Team charter and template, and the OJP Grant Manager’s
              Manual. Further, we interviewed DOJ officials from the three granting
              agencies to obtain additional information on grant program design and


              Page 56                                       GAO-12-517 DOJ Grants Management
Appendix I: Objectives, Scope, and
Methodology




award processes, and the extent to which the three agencies coordinate
and share information. We also visited or conducted phone interviews
with officials from 11 states, including the five largest and five smallest
state recipients of Edward Byrne Memorial Justice Assistance Grant
(JAG) funding. These officials represent the state administering agencies
(SAA) responsible for distributing JAG and other DOJ formula block grant
funds to subrecipients in California, Florida, New York, North Dakota,
Pennsylvania, South Dakota, Rhode Island, Tennessee, Texas, Vermont,
and Wyoming. These officials provided their views regarding the type and
timeliness of information on grant awards and subawards they provide to
and receive from DOJ. We selected these 11 states based on the amount
of JAG funding they receive and the existence of other recipients in their
communities receiving DOJ discretionary grants for potentially similar
purposes. The results of these contacts are not generalizable to all states,
but provided insight into how DOJ grant funds are used locally and into
the communication between states and DOJ. To determine if JAG
recipients expended grant funds in fiscal year 2010 on sexual assault
services, bullet and stab-resistant vests, sex offender registry and
notification systems, Internet crime against children task forces, hiring
police officers, and correctional officer salaries, we conducted a web-
based survey of all recipients of DOJ JAG grant funding who received an
award from fiscal years 2005 through 2010. The survey response rate
related to SAAs was 89 percent, with 50 out of 56 SAAs answering the
questionnaire. We compared agency grant design and award practices
against Standards for Internal Control in the Federal Government and
promising practices identified in the Domestic Working Group Grant
Accountability Project’s Guide to Opportunities for Improving Grant
Accountability.

To analyze the extent to which DOJ uses programmatic grant monitoring
and assessment to determine grant program effectiveness and uses the
results to enhance its grant programs, we analyzed DOJ documentation,
such as assessments DOJ conducted of its own programs and specific
programmatic grant monitoring reports. We also interviewed DOJ officials
from the granting agencies, including those tasked with assessment, as
well as contractors responsible for assessing grant programs for OVW.
This report focuses solely on the types of assessment conducted by DOJ
granting agencies on its grant programs. Training and technical
assistance provided by the department and its program offices and
bureaus to grantees to support the evaluation of individual grant projects,
such as the Bureau of Justice Assistance (BJA) Center for Program
Evaluation and Performance Measurement, is not included in this report.
Also excluded from this report are the outcome evaluations of the impact


Page 57                                      GAO-12-517 DOJ Grants Management
Appendix I: Objectives, Scope, and
Methodology




of grant programs such as those funded by the National Institute of
Justice (NIJ).




Page 58                                     GAO-12-517 DOJ Grants Management
Appendix II: DOJ Granting Agencies’
              Appendix II: DOJ Granting Agencies’
              Organizational Structure



Organizational Structure




              Page 59                               GAO-12-517 DOJ Grants Management
Appendix III: Structure, Purpose, and
                                       Appendix III: Structure, Purpose, and Funding
                                       of DOJ Granting Agencies



Funding of DOJ Granting Agencies


                              OJP                                          OVW                                  COPS Office
Establishment and structure   OJP, established by the Justice              Following the enactment of the       The Attorney General
                              Assistance Act of 1984, is the               Violence Against Women Act of        established the COPS Office
                              primary grant-making arm of                  1994, the department established     in October 1994 to
                              DOJ. A presidentially appointed              the Violence Against Women           administer community
                              Assistant Attorney General leads             Office, which later became OVW       policing grants authorized
                              OJP. The Assistant Attorney                  under OJP. OVW now functions         under the Violent Crime
                              General and all OJP bureau                   as a separate and distinct office    Control and Law
                              heads are presidentially                     within DOJ and is headed by a        Enforcement Act of 1994.
                              appointed and confirmed by the               presidentially appointed, Senate-    The Attorney General
                              Senate.                                      confirmed Director.                  appoints a Director to head
                              OJP Bureaus and Offices:                                                          the COPS Office.
                              •   Bureau of Justice Assistance
                              •   Bureau of Justice Statistics
                              •   National Institute of Justice
                              •   Office of Juvenile Justice
                                  and Delinquency Prevention
                              •   Office for Victims of Crime
                              •   Office of Sex Offender
                                  Sentencing, Monitoring,
                                  Apprehending, Registering
                                  and Tracking
Purpose                       OJP provides grants to various               OVW administers financial and        The COPS Office provides
                              organizations, including state and           technical assistance to local,       grants to and shares
                              local governments, universities,             state, and tribal governments;       information with the state,
                              and private foundations, which               courts; nonprofit organizations;     local, territory, and tribal law
                              are intended to develop the                  community-based organizations;       enforcement agencies to
                              nation’s capacity to prevent and             secondary schools; institutions of   advance community policing.
                              control crime, administer justice,           higher education; and state and
                              and assist crime victims.                    tribal coalitions. OVW provides
                                                                           grants for developing programs,
                                                                           policies, and practices aimed at
                                                                           ending domestic violence, dating
                                                                           violence, sexual assault, and
                                                                           stalking.
Programs and funding          From fiscal years 2005 to 2012,              From fiscal years 2005 to 2012,      From fiscal years 2005 to
                              OJP received approximately $24               OVW received approximately           2012, the COPS Office
                              billion for OJP grant programs.              $3.4 billion for OVW grant           received approximately $5.3
                              In 2010, almost 3 billion was                programs.                            billion to fund COPS Office
                              available to OJP to fund grants,             In 2010, OVW received $418.5         grant programs.
                              and OJP issued 223 solicitations             million for OVW grant programs,      In 2010, the COPS Office
                              for grants.ª According to OJP, it            and OVW issued 19 solicitations      received $791.6 million to
                              awarded nearly 5,000 grants in               for grants.                          fund COPS Office grants,
                              2010.                                                                             and the COPS Office issued
                                                                                                                nine solicitations for grants.
                                       Source: GAO analysis of information from DOJ.

                                       Note: Funding levels in fiscal year 2009 include amounts appropriated through the American
                                       Recovery and Reinvestment Act of 2009. See Pub. L. No. 111-5, 123 Stat. 115, 129-30.




                                       Page 60                                                         GAO-12-517 DOJ Grants Management
Appendix III: Structure, Purpose, and Funding
of DOJ Granting Agencies




a
 Solicitations are announcements of new grant funding available and explain areas for which funding
can be used. These numbers reflect solicitations provided by each individual office and do not reflect
any joint solicitations, which are those offered in tandem with other program offices, either within or
external to DOJ (e.g., other DOJ components or federal agencies).




Page 61                                                       GAO-12-517 DOJ Grants Management
Appendix IV: Consolidated, Braided, and
                                        Appendix IV: Consolidated, Braided, and
                                        Blended Grant Program Solicitations



Blended Grant Program Solicitations

                                        According to DOJ officials, there are three ways in which DOJ grant
                                        programs can be merged or better coordinated—through consolidation,
                                        braiding, and blending. Figures 4,5, and 6 explain these mechanisms.

Figure 4: Consolidated Grant Programs




                                        Page 62                                   GAO-12-517 DOJ Grants Management
                                   Appendix IV: Consolidated, Braided, and
                                   Blended Grant Program Solicitations




Figure 5: Braided Grant Programs




                                   Page 63                                   GAO-12-517 DOJ Grants Management
                                   Appendix IV: Consolidated, Braided, and
                                   Blended Grant Program Solicitations




Figure 6: Blended Grant Programs




                                   Page 64                                   GAO-12-517 DOJ Grants Management
Appendix V: Office of Audit Assessment and
                            Appendix V: Office of Audit Assessment and
                            Management Structure



Management Structure

                            The three divisions within OAAM—the Audit and Review Division, the
                            Program Assessment Division, and the Grants Management Division—
                            together carry out the following primary functions of OAAM for one or
                            more of DOJ’s three granting agencies:


Audit and Review Division   •   coordinates audits, such as Single Audits that independent
                                nongovernmental auditors conduct, as well as those that the Inspector
                                General (IG) and GAO conduct, 1

                            •   reviews internal control processes (A-123), 2 and

                            •   manages DOJ’s High Risk Grantee Program, which applies criteria to
                                identify grantees most at risk of fraud, waste, or abuse in use of their
                                grant funds.

Program Assessment          •   oversees OJP and COPS Office programmatic monitoring, including
Division                        development and implementation of standards and protocols, and

                            •   assesses grant programs and initiatives of OJP and the COPS Office,
                                as well as operational activities.

Grants Management           •   serves as the primary resource for OJP grants management policies
Division                        and procedures by producing authoritative guidance,

                            •   develops and facilitates grants related training to staff and grantees,




                            1
                             Pursuant to the Single Audit Act, as amended, each nonfederal entity that expends
                            $500,000 or more in federal awards, including grants and other assistance, in a fiscal year
                            must obtain an annual “Single Audit,” which includes an audit of the entity’s financial
                            statements and a schedule of the expenditure of federal awards, as well as, among other
                            things, a review of related internal controls. See 31 U.S.C. §§ 7501-07.
                            2
                             Office of Audit, Assessment, and Management (OAAM) annually reviews OJP’s critical
                            business processes in the areas of financial management, information technology, and
                            grant management and makes recommendations to enhance and strengthen internal
                            controls as required by OMB Circular A-123, “Management’s Responsibility for Internal
                            Control.”




                            Page 65                                               GAO-12-517 DOJ Grants Management
Appendix V: Office of Audit Assessment and
Management Structure




•   manages Grants Management System (GMS) and other tools and
    systems, and

•   facilitates OJP’s business process improvement efforts.




Page 66                                      GAO-12-517 DOJ Grants Management
Appendix VI: Comments from the
             Appendix VI: Comments from the Department
             of Justice



Department of Justice




             Page 67                                     GAO-12-517 DOJ Grants Management
Appendix VI: Comments from the Department
of Justice




Page 68                                     GAO-12-517 DOJ Grants Management
Appendix VI: Comments from the Department
of Justice




Page 69                                     GAO-12-517 DOJ Grants Management
Appendix VI: Comments from the Department
of Justice




Page 70                                     GAO-12-517 DOJ Grants Management
Appendix VI: Comments from the Department
of Justice




Page 71                                     GAO-12-517 DOJ Grants Management
Appendix VI: Comments from the Department
of Justice




Page 72                                     GAO-12-517 DOJ Grants Management
Appendix VI: Comments from the Department
of Justice




Page 73                                     GAO-12-517 DOJ Grants Management
Appendix VII: GAO Contact and Staff
                  Appendix VII: GAO Contact and Staff
                  Acknowledgments



Acknowledgments

                  David C. Maurer, (202) 512-9627 or maurerd@gao.gov
GAO Contact
                  In addition to the contact named above, Joy Booth, Assistant Director,
Staff             and Christian Montz, Analyst-in-Charge, managed this assignment. Julie
Acknowledgments   E. Silvers, Marya Link, Caitlin Carlberg, and Michael Sweet made
                  significant contributions to the work. Michele Fejfar assisted with design
                  and methodology. Janet Temko and Tom Lombardi provided legal
                  support. Lara Miklozek provided assistance in report preparation.




(440971)
                  Page 74                                      GAO-12-517 DOJ Grants Management
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