ACCOUNTABILITY
FOR
BLOCK GRANTS
COMME 
AN 
INSPECTON  EVALUATION
PRESIDENT'S COUNCIL
INGRIT AN 
ON  EFFICIENCY
JULY 1996 EXECUTIVE  SUMMAR 

PUROSE 
To help determine the sufficiency of the accountability provisions in the statutes of 
Federal block grant programs.

BACKGROUN 
In December 1995, the Deputy Director for Management in the Executive Office of

Management and Budget (OMB) asked the Vice Chair of the President s Council on

Integrity and Efficiency (PCIE) to determine if there were sufficient provisions for

accountabilty in Federal  block  grant programs. The Vice Chair assigned this

responsibilty to the PCIE's Committee on Inspection and Evaluation which worked

with the Inspection Roundtable to produce this report. 
We respond to the original OMB request primarily by focusing on the statutes of 

Federal programs commonly referred to as block grants. We concentrate on the

statutes because of their fundamental significance in establishing a framework for

accountability. We recognize that a detailed review of Federal regulatory and non-

regulatory guidance and an in-depth analysis of actual practice in enforcing statutory, 
regulatory, and other guidance would be necessary to definitively determine the 
sufficiency of oversight. Such a comprehensive review is, however, impractical within 
current resource limitations. We hope our more 
limited review of the statutes wil 
provide valuable insights on the sufficiency of block grant accountability provisions. 
GENERA ACCOUNABILIT 
CONCEPTS 
A fundamental precept of block grant accountabilty is that the Federal Governent 
must be assured that the funds are spent for purposes designated by the Federal 
legislation establishig the program. 
There is some basis for concern as to whether the Federal Government can be 
adequately assured that block grant funds wil be spent for the designated 
purposes. 
Historically, there have been widely varyg views on how much accountabilty is 
necessary in Federal legislation. 
On one end of the continuum are those who hold that Federal intervention must 
be kept to a bare minimum, that the focal point of accountability must be the 
citizens of the States and localities. On the other end are those who believe that 
proper accountability must include numerous programmatic and process 
conditions imposed on grantees and various oversight authorities conferred on 
Federal agencies.
 , there appears to be an emergig 
In recent years consensus that the Federal 
Governent should hold grantees accountable for results but free them from many 
process and conditional requirements. 
This convergence is apparent in a number of Federal activities. They include 
the Vice President s Report on the National Performance Review, the Chief 
Financial Officers Act of 1990, the Government Performance and Results Act 
, various amendments to block grant programs, recent GAO and OIG 
of 1993
reports, the proposed Public Health Service Performance Partnership Act of 
1995, and the proposed Medicaid Transformation Act of 1995. 
SPECIFIC ACCOUNABILIT ISSUE 
The block grant statutes themselves offer little basis for the Federal Governent to 
determe the adequacy of the control and oversight of fiancial management. 
The statutes, in effect, rely heavily on each State s own laws and procedures 
concerning the obligation and expenditure of funds and each State s own 
systems for grants management and recordkeeping. 
About hal of the block grant statutes devote no attention to measurable program 
results that faciltate an understanding of performance. 
Seven of the 13 statutes do not call for performance goals and indicators 
expressed in tangible, measurable terms as called for by the Government 
Performance and Results Act (GPRA). 
Most (10) require the grantee and/or Federal agency to perform some 
kind of program evaluation during some period of time, but only 6 have 
an explicit evaluation requirement directed to the grantee. 
None of the statutes include provisions callng for verification of the accuracy of 
performance or other evaluative data used by the grantee or the Federal 
agency. 
Most block grant statutes include conditions governg who gets served and what 
servces are offered; however, the range of specifcity is quite broad. 
Eleven statutes include earmarks that call for a designated proportion of funds 
to be spent on certain categories of recipients. Eight stipulate a proportion of 
funds for certain types of services. 
Nearly all (12) require the grantees to provide explicitly defined services, to 
coordinate with other relevant bodies or groups, and/or to carry out services in 
particular ways. Some of these provisions are quite broad, however.  CONCLUSION 
At root, decisions concerning accountability for block grants are political ones. These 
decisions rest heavily on one s views of the respective roles of the Federal Government 
and the 50 State governments. 
If those who craft legislation to develop new or modify existing block grant programs 
believe that the Federal Government ought to have a significant role in ensuring the 
proper and effective use of block grant funds, then they must provide an adequate 
basis for doing so. Toward that end, we offer the following four suggestions: 
Require that the Federal Uniform Administrative Requirements or similar 
provisions apply to these programs. 
Establish an appropriate mechanism for measuring and verifying program 
performance. It would be helpful in this context to look to the Government 
Performance and Results Act of 
1993 for guidance. 
Be specific about programmatic requirements in the statute itself. This might 
involve earmarks for certain categories of recipients and/or certain types of 
funds and an explicit listing of the tyes of services covered or unallowable. 
Examine other provisions that we have identified in this report to determine 
the kind of accountability that is desired for any specific block grant program. 
We have developed a checklist of them in Table 2 of this report. 
On the other hand, if the intention is minimize the Federal role, then provisions such 
as those noted above, which move toward the categorical end of the Federal grant 
continuum, become less pertinent and available State government mechanisms become 
much more significant. It is important to recognize, however, that this is likely to 
leave Federal officials with little or no capacity to ensure that funds are used for the 
purposes intended and to move block grants much closer to the general revenue 
sharing end of the continuum.  ................................... 
. . . . . . . . . . . . . . . . . . . . . . . . . . . " 
 . . . . . ..  . ..  .. ..   ...  .  ....   .  ....    ... ..    ... ..    ....   .  ....   .  ....    ... ..    .... . .    ......    .   ......     . . .....      ......     .....     .....     .....     .....     .....     .....     .....     .....     .....     .....     ......    .  ... ..   .  . .....      ......      ......      ......      ......      ..... ..    .  ... .. .     ......      ......      ......      ..... .   .  .. ...  .   . .... .    . .... .   .  ... . .  ..  ..  . ..  .  .. .. .   . ...    .....   .. 
TABLE OF CONTENTS

PAGE 
EXECU SUMY 
BACKGROUN. . 

GENERA ACCOUNABILIT CONCEPT . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

. Concerns about Expenditures.  . . 4

Other Accountability Issues  . . . . . . . . . . . . . . . . . . 5

. Contrasting Perspectives on 
. Emerging Interest in Performance

SPECIFIC ACCOUNABILIT ISSUE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

. Financial Management. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  . . . . . . . 8

. Performance  . . . . . . . . . . . . . . . 9

. Programmatic Requirements  .. 10

. Quality Assurance

CONo.USION 
COMMNT ON TH DRA REPORT 
APPENDICE 
A: Accountability Provisions in Block Grant Statutes 
B: Endnotes  ................................................... B
 PUROSE 
To help determine the sufficiency of the accountability provisions in the statutes of 
Federal block grant programs.

BACKGROUN 
Rationale for the Report 
In December 1995, John A. Koskinen, Deputy Director for Management in the 
Executive Office of Management and Budget, asked June Gibbs Brown, as Vice Chair 
of the President's Council on Integrity and Efficiency, to examine accountabilty issues 
associated with Federal funding. His request involved two major components. The 
first was to determine accountabilty issues that need to be addressed in the proposed 
Local Flexibility bil introduced in the U.S. Senate as S.88 and entitled "The Local 
Empowerment and Flexibility Act of 1995." The second was to review current block 
grant programs to determine if there are sufficient provisions for accountability in 
them. 
This report is a response to the second request. A response to the first request is in a 
March 1996 memorandum from June Gibbs Brown to John A. Koskinen. 
Federal Block Grants 
It is helpful to think of block grants as one of three basic types of Federal grants 
distinguished from one another by the degree of discretion afforded the grantee (see 
l On the end of the continuum providing for the least discretion are 
Figure 1 below).
categorical grants, which by far are the most prominent in both numbers of programs 
and amount of dollars. On the other end, providing for the most discretion are 
general revenue sharig grants, which Congress introduced in 1972 and terminated in 
1986.  Block grants occupy a middle ground between these extremes. In terms 
the degree of discretion they afford, they cover a wide range, with some edging very 
, and in some respects being indistinguishable from, categorical grants and 
close to
others being much closer to the general revenue sharing mode. 
FIGURE 
Continuum of Federal Grants by Recipient Discretion 
Least Restrictive  Most Restrictive 
General  Block  Categorical 
Revenue Sharing  Grants  Grants  ....
this report we focus on 13 Federal programs commonly referred to as block grants 
In 
3 Some
(see Table 1). , such as the Community Development and Social Services 
programs, are more than two decades old. Others, such as the Surface Transportation 
Program and the Child Care and Development Program, are products of the 1990s. 
Most block grants have been amended since their inception, usually with additional 
accountabilty  , these programs account for about $19 bilion in 
provisions. Overall
Federal expenditures for Fiscal year 1995, far less than expenditures for categorical 
grants. 
Table 1: Federal Bloc Grants 
Dement of Health and Human Serce  FY 199 awa" 
Soc Serce 
Provides States with funding for a broad range of social services directed  $2,800,000.000

to children, adults, and the aged.
 Pro: 
Lo Income Home Ener Asislance  Makes grants available to States to assist  419 202,479"

eligible households to meet the costs of home energy.

Substace Abus Preention and Tretment: Provides financial assistance to States for  23,107,000

prevention, treatment, and rehabilitation activities directed to alcohol and drug abuse.

Chd Ca and Development: Makes grants available to States to assist low-income  934 641.777

familes with child care services.

Matcm and Olild Health: Assists States to provide/assure access to health services and  572 259.000

to improve the health status of mothers and children, particularly those with low incomes.

Sece: 
Community  Provides services and activities having a measurable impact on causes  391 500 000

of poverty in areas where poverty is an acute problem.

Serce 
Community Menta Health  Provides financial assistance to States for  277 919,000

comprehensive community mental health services to adults and children.

Preentive Heath and Heath Servce Provides resources to States to improve the health  151,952,987

status of grantee populations. 
Dement of Transporttion 
Prom: 
SUIace Transporttion  Assists State highway agencies in the development  000 000 000' " 
improvement, and rehabilitation of transportation projects. 
Feder Transit Capita and Operating Asislance Provides for capital projects and the  933 761.000 
financing, planning, and operating costs of equipment, facilities, and associated 
maintenance items for use in mass transportation. 
Depment of Labor 
Job Training and Parnership Act: Establishes programs to prepare youth and adults facing 
653 462.000
barrers to employment for participation in the labor force. 
Depment of I lousing and Urban Development 
Community Development: Provides funding to States and local governments to support for  157.000.000 
housing and community development activities directed to low income individuals. 
Depment of Education 
Inovtive Education Progrm Strateges: A sists State and local educational agencies to  370 000,000" " 
improve elementary and secondary education. 
Source: Catalo  e o  Federal Domestic Assistance Offce of Mallagemell alld Budget (1995).

Tota Funds

"Dollars do lIot reflect budget obfigatiol/; they are estimated gram awards for the fiscal year. 
$19,525 805,23 
Report Focus and Methodology 
The objective of this report is to contribute to a better understanding of the 
accountability provisions in Federal block grants by assessing their statutory basis. We 
focus on the statutes because of their fundamental significance in establishing a 
framework for accountability in the block grant programs. We recognize that a review 
of accountability provisions in regulatory and non-regulatory guidance provided by  Federal agencies could contribute further understanding on the sufficiency 
We also recognize that a review of actual 
accountability provisions for block grants. 
practice in enforcing statutory, regulatory, and other forms of guidance would offer 
valuable insights. Because the statutes establish a basic framework for accountabilty, 
we determined that they also afforded a valuable focus for our limited, brief review of 
the suffciency of accountability provisions. 
Our methodology was threefold: First, we identified various approaches to 
accountabilty. We did this by drawing on the extensive literature on the subject, in 
particular a review of that literature in a recent report issued by the Office of 
Inspector General in the U.S. Department of Health and Human Services. 
Second, this brief review of accountability approaches provided vital context for our 
subsequent examination of the accountabilty provisions that appear in the statutes 
establishing 13 current Federal block grant programs. In this examination, we 
distinguished four basic types of accountability provisions--those focusing on financial 
management, performance, programmatic requirements, and quality assurance. Within 
each of these types, we offered further classifications that specify conditions imposed 
6 For key

on grant recipients and oversight authorities afforded to Federal agencies.

terms used in our inventory of performance accountability provisions, we relied upon 
definitions set forth in the Government Performance and Results Act of 1993 (see 
appendix A for the terms and definitions). 
Third, although we did not seek to document the accountabilty provisions existing in 
other relevant statutes or in the regulations concerning block grant statutes, our 
inquiry led us to review a number of such statutes and regulations. These include: the 
Single Audit Act of 1984, the Chief Financial Officers Act of 1990, the Government 
Performance and Results Act of 1993, the Department of Health and Human Services 
regulations implementing the block grants of 1982 (45 C.F.R. Part 96), and the 
Uniform Administrative Requirements for Grants and Cooperative Agreements to 
State and Local Governments. 
Our approach offers both a perspective and information about current accountability 
provisions. It provides a convenient checklist for those designing or implementing 
block grants to use in deciding how much accountability to build into the underlying 
statutes and regulations. In itself this report does not provide a basis for drawing hard 
conclusions about the efficacy of specific accountability provisions; however, it does 
give rise to some broad issues that may warrant further discussion and analysis. 
GENERA ACCOUNABILIT CONCEPT

The essence of a block grant is to afford the grant recipient substantial discretion in 
using the block grant funds. The great challenge for Federal policymakers is to 
develop approaches that afford suffcient accountability while preserving the flexibility 
inherent in a block grant.  Notwithstanding the extensive literature on the subject, there is no standard reference 
document explaining how this challenge can be met. There are texts in accounting, 
political science, and even political philosophy that afford pertinent guidance, but in 
themselves none is adequate. Further, how one perceives accountability is likely to 
depend heavily on how one views the role of the Federal Government on the one 
hand and State and local governments on the other. 
In this context, we examine various aspects of accountability. They wil not offer the 
elusive standard reference document, but they can help in developing a framework for 
steps that can be taken by those in the executive and legislative branches of the 
Federal Government interested in developing accountability provisions consistent with 
the block grant funding mechanism. 
Concerns about Exenditures 
There is one fundamental precept of block grant accountability that rests on 
widespread support and that must not be overlooked when considering the many 
complexities of accountability: 
The Federal government must be assured that Federal block 
grant fund are spent for purposes designated by the Federal 
legislation establishing the block grant program. 
The critical accountability question is whether there is reasonable assurance that 
Federal block grant funds are being spent for purposes designated in the authorizing 
legislation. We cannot be sure of the answer, but there are reasons for some concern. 
Recognizing that the Uniform Administrative Requirements for Grants and 
Cooperative Agreements to State and Local Governments does not apply to Federal 
block grants, many in the Federal inspector general community and in other positions 
involving oversight of Federal grants indicate that the exclusion of this requirement 
which applies to other Federal grants, impedes assurances that records wil be kept 
and maintained in a manner that allows for proper audits. One commenter added 
that the Uniform Administrative Requirements provide adequate tlexibility to the 
States for financial, equipment, procurement, and subgrantee management, while 
establishing a consistent framework for fundamental accountability on such matters as 
cash management of Federal advances, allowable costs, non-Federal audits, and grant 
closeout. 
Others, at Federal and State levels, would respond that State and local governments 
have their own administrative requirements that provide sufficient safeguards for 
audits. The essence of the block grant approach is to vest substantial discretion and 
accountability for these matters with the grantees, without imposing costly 
administrative burdens. Indeed, this was the frame of reference in the combined 
regulations developed by the Department of Health and Human Services (HHS) for 
the block grant programs included in the 1982 legislation. Particularly pertinent in this 
regard is the following HHS instruction of fiscal and administrative requirements:  Except where otherwise required by Federal law or regulation, a State shall obligate 
and expend block grant funds in accordance with the laws and procedures applicable 
to the obligation and expenditure of its own funds. 
We did not conduct any review of our own of how the State administrative 
requirements for grants and contracts compare with those of the Federal Government; 
nor did we become aware of any such studies performed by other parties. 
A second reason for concern has to do with the adequacy of the statewide single audit 
mechanism. The General Accounting Office (GAO) has reported that this mechanism 
has contributed to better financial management practices in State and local 
governments. The GAO also noted limitations that impede its usefulness to Federal 
9 These limitations 
agencies responsible for program oversight. concern the time it 
takes to issue a report after the close of the audit period, the limited manner in which 
audit results are sometimes presented, and the sufficiency of information acquired on
lO Other concerns expressed by auditors in Federal 
internal control structures.
 offices
of inspector general concern the limited number of transactions reviewed for any given 
program and the exclusion of grantees below a certain threshold level. At this writing, 
there are proposals under consideration in the House of Representatives and the 
Senate that address many of the concerns that GAO and others have expressed about 
the Single Audit ACt.

Contrasting Perspectives on Other Accountabilty Issues 
Historically, there have been widely varying views on how and how much the Federal 
Government should seek accountability that involves more than assuring that funds are 
spent for intended purposes. On the most permissive end have been those arguing 
that not much more is necessary. Those holding to this school of thought have tended 
to emphasize that the basic accountability is to the citizens of the States and localities 
in which block grant funds are being used. This perspective is clearly conveyed in the 
following excerpt from the preamble to regulations that the Department of Health and 
Human Services (HHS) issued in July 1982 and that applied to the seven HHS block 
grant programs established by the Omnibus Budget Reconciliation Act of 1981: 
The fundamental check on a State s use of block grant 
funds is the State s accountability to its citizens, which is 
implemented by public disclosure within the State of 
information concerning use of funds. Accordingly, when 
an issue arises as to whether a State has complied with its 
assurances and the statutory provisions, the regulations 
provide that the Department wil 
ordinarily defer to the 
State s interpretation of its assurances and the statutory 
provisions. Unless the interpretation is clearly erroneous 
State action based on that interpretation wil not be 
challenged by the Department.  At the other end of the spectrum are those arguing that accountability as spelled out 
above affords grant recipients far too much discretion. Proper accountability, they 
contend, must include various programmatic and process conditions imposed on 
grantees. Programmatic conditions could include earmarking certain portions of funds 
for certain tyes of service recipients or certain types of services. They could also 
include specifications on how services are to be delivered. Process conditions could 
address a wide variety of provisions addressing such matters as planning and 
evaluation requirements, advisory group roles, and complaint mechanisms. 
Proper accountability, they have also pointed out, must include various oversight 
authorities conferred on Federal agencies. These could include the authority to review 
and approve planning applications, to conduct compliance reviews, to respond to 
complaints from parties affected by the grantees' actions , and to impose penalties or 
corrective actions. 
Emergig Interest in Performance 
In recent years, it appears that the distance between these extremes may be narrowing 
somewhat and that an increasing consensus may be emerging about proper 
accountability. This position is well articulated in the Vice President s Report on the 
National Performance Review, issued in September 1993. In part, that report noted: 
The federal government must shift the basic paradigm it uses in 
managing state and local affairs. It must stop holding programs 
accountable for process and begin holding them accountable for results. 
At the Federal level there have been a number of actions that reinforce this kind of 
emphasis on performance. Consider the following: 
The Chef Financial Offcers Act of 1990. Calls for Federal agencies to 
establish management systems engaged in the systematic measurement 
of performance. 
Governent Performance and Results Act of 1993. Requires Federal 
agencies to develop annual performance plans incorporating to the 
maximum extent possible the use of measurable performance goals and 
indicators. 
Amendments to Block Grant Programs. Congress has amended some of 
these programs to place greater emphasis on accountability for 
performance. This is most clearly apparent for Maternal and Child 
Health. 
Recent Report. An HHS OIG report called for a performance based 
approach to block grant funding for public health programs and 
delineated a research and demonstration strategy toward that end. 
 GAO report called for focusing Federal management and accountabilty 
on program results and outcomes. It added the warning that such a 
focus may be critical in preserving the discretion that is central to block 
grants. 
Proposed Public Health Servce Performance Partnership Act of 1995. 
This Administration proposal calls for combining 35 narrowly focused 
grants into 5 partnership grants that afford States greater flexibilty and 
involve joint Federal-State efforts in specifying performance objectives. 
Proposed Medicaid Transformation Act of 1995. This congressional 
proposal calls for converting the current Medicaid program to a block 
grant. It includes provisions requiring States to develop performance 
goals and to describe how program performance wil be measured. 
This increasing convergence toward an approach that enhances the discretion of 
grantees but holds them accountable for performance is reinforced by other basic 
developments in our society. One such development is the continuing advance in 
information technology. This advance makes it much more possible than it would 
have been only a few years ago for those awarding grants to allow for broad 
delegation of authority and yet stay closely attuned to performance, perhaps on a real-
time basis. Another reinforcing development is the widespread movement in private 
corporations to enhance productivity by reducing central planning and management 
roles while delegating additional authority and responsibility to the operating entities. 
In the American Federal system, the States and local governments serve as the 
public s operating entities. 
SPECIFIC ACCOUNABILIT ISSUE 
In Table 2, we present an inventory of accountabilty provisions that we developed. It 
provides a reasonable framework for addressing the sufficiency of the accountability 
provisions in the statutes of Federal block grant programs. In appendix A, we indicate 
the number of block grant programs including each provision. This compilation, we 
must reiterate, does not in itself provide a basis for judgments about the efficacy, 
appropriateness, or feasibility of particular accountability provisions. It does, however 
provide a baseline of information concerning congressional intent about the conditions 
that should be imposed on block grant recipients and about the extent to which and 
manner in which Federal agencies should oversee grantees.  :..
.:.
Pro 
Table 2: Accunlability Proviions for Bloc Grant 
Perfonnance

Developing Program Plans

Setting Performance Goals

Establishing Performance Indicators 
Collecting and Verifying the Accuracy of Performance Data 
Conducting Program Evaluations 
Preparing Reports

.YlIancial Managcmcnt.

Report of Expenditures

Conducting Audits 
Conducting Pre-Audits 
Fund Accounting Procedures 
Assuring Level of Expenditures 
Remittance of Certain Amounts 
Penalties

: Progrmmatic. Requircmcnts

Earmarking Funds

Asuring Access

Providing Services

Quality Asc;urance

Assuring Minimum Standards of Personnel 
Assuring Minimum Standards of Facilities 
Offering Complaint, Grievance, or Appeals Mechanisms 
Financial Management 
The block grant statutes themselves offer little basis for the Federal Governent to 
determe the adequacy of the control and oversight of fiancial management. 
The statutes, in effect, rely heavily on each State s own laws and procedures 
concerning the obligation and expenditure of funds and each State s own 
systems for grants management and recordkeeping. 
how often audits have to be 
Eight of 13 statutes have provisions indicating 
submitted to the Federal agency overseeing the program.  A minority of the statutes have provisions requiring that an audit be 
made available to the general public (5) or to general purpose 
government (4). 
The extensive reliance on State laws, procedures, and systems is consistent with the 
block grant philosophy of maximizing the discretion available to the grant recipient. 
We must be sure, however, that this approach does not result in any diminution of the 
Federal Government s capacity to assure itself that block grant funds are spent only 
for intended purposes. In this context it is important to note that the Single Audit Act 
applies to all 13 block grant programs, even though in our review we found that only 3 
of the statutes explicitly reference the single audit mechanism. 
Performance 
About half of the block grant statutes devote no attention to measurable program 
results that facilitate an understanding of performance. 
Seven of the 13 statutes do not call for performance goals and indicators 
expressed in tangible, measurable terms as called for by the Government 
Performance and Results Act. 
Most statutes (10) require the grantee and/or Federal agency to perform 
some kind of program evaluation during some period of time, but only 
6 have an explicit evaluation requirement directed to the grantee. 
Most statutes require both the grantee to submit a report to the Federal agency 
(10) and for the Federal agency to submit one to Congress (11), but, with a few 
exceptions, the data called for in these reports are for outputs rather than 
outcomes. 
None of the statutes includes provisions calling for verification of the accuracy 
of performance or other evaluative data used by either the grantee or the 
Federal agency. 
These limitations indicate a clear gap between the increasing consensus on 
accountability for performance and the reality of what is currently required in Federal 
block grant statutes. This gap warrants serious concern because in large measure the 
case for enhancing the discretion available to grantees (by minimizing various process 
conditions) rests on holding grantees accountable for demonstrating their expected and 
actual performance in precise, measurable, and reliable ways. This demonstration of 
accountability is as important to the citizenry of the States and localities as it is to the 
Federal agency disbursing the grant funds. 
Without developing and disseminating measurable performance data, citizens, funding 
agencies, and other interested parties will be hard-pressed to assess the comparative 
performance of block grant programs over time. Without such data presented in  accord with a common national format, they wil also be hard-pressed to compare the 
performance of grantees across the Nation. Generally stated goals and objectives 
which in one way or another are called for in all the programs, do not in themselves 
provide an adequate foundation for performance accountability or for countering 
pressures for increasing recategorization of block grant programs; too often they fail to 
identify relevant performance goals and measures for judging results. 
should be noted that the Job Training and Partnership Act and the Maternal and 
. It 
Child Health Block Grant statute have the most explicit and extensive references to 
performance goals and indicators. The latter statute and the Preventive Health and 
Health Servces Block Grant statute focus heavily on achieving the Year 2000 
performance objectives developed by the Public Health Service in the Department of 
Health and Human Servces. 
Programmatic Requirements 
Most block grant statutes include conditions governng who gets served and what 
servces are offered; however, the range of specifcity is quite broad. 
Nine statutes include earmarks that call for a designated proportion of funds to 
be spent on certain categories of recipients. Eight stipulate a proportion of 
funds for certain types of services. 
Nearly all (12) require the grantees to provide explicitly defined services, to 
coordinate with other relevant bodies or groups, and/or to carry out servces in 
particular ways. Some of these provisions are quite broad, however. 
The earmarking provisions serve as a means for Congress to channel funds to certain 
groups of service recipients and certain types of service providers that it regards as 
warranting special attention. Earmarking also serves as a means of protecting such 
recipients or providers from the sudden elimination of Federal support. The other 
conditions are typically quite general in nature (underscoring, 
tyes of programmatic 
for instance, the need to coordinate planning and service delivery). In a few cases 
however, they offer quite prescriptive instructions on how some services are to be 
delivered. For those statutes including such provisions, the range of specificity is quite 
broad. 
Quality Assurance 
Block grant statutes by and large leave quality assurance issues to State and local 
statutes include specific provisions addressing such issues. 
grantees. Few 
The most frequently addressed provisions bearing on quality assurance concern 
complaint, grievance, or appeals mechanisms. Four statutes call for the 
grantees to establish such mechanisms. Two of these statutes and four others 
call for the Federal agency to establish such mechanisms.  Two statutes (Job Training Partnership Act and the Elementary and Secondary 
Education Act) call for these mechanisms to be in accordance with Federally 
prescribed procedures; the others that address the issue leave it up to the grantees. 
References to standards for per onnel or facilties offer minimal guidance. For 
instance, the Social Servces statute indicates that funds may not be used for child care 
servces that do not meet applicable State and local standards. 
CONCLUSION 
Decisions concerning accountability for block grants are political ones and such 
decisions rest heavily on one s views of the roles of Federal and State governments. 
If those who craft legislation to develop new or modify existing block grant programs 
believe that the Federal Government ought to have a significant role in ensuring the 
proper and effective use of block grant funds, then they must provide an adequate 
Toward that end, we offer the following four suggestions: 
basis for doing so. 
Require that the Federal Uniform Administrative Requirements or similar 
provisions apply to all block grant programs. 
Establish an appropriate mechanism for measuring and verifying program 
performance. It would be reasonable in this context to look to the Government 
Performance and Results Act of 1993 for general guidance. 
Specify programmatic requirements in the statute itself. This might involve 
earmarks for certain categories of recipients and/or certain types of funds and 
an explicit listing of the types of services covered or unallowable. 
Examine other provisions that we have identified in this report to determine 
the kind of accountability that is desired for any specific block grant program. 
We have developed a checklist of them in Table 2 of this report. 
On the other hand, if the intention is minimize the Federal Government s role, then 
provisions such as those noted above, which move toward the categorical end of the 
Federal grant continuum pertinent and State mechanisms become much
, become  less 
more important. It is important to recognize, however, that this is likely to leave 
Federal offcials with little or no capacity to ensure that funds are used for the 
purposes intended and to move block grants much closer to the general revenue 
sharing end of the continuum.  COMMENTS ON THE DRAFT REPORT

We asked the Inspector Generals of the five Federal departments covered in our 
We did the same for various 
review for comments on a working draft report. 
programmatic representatives of specific block grant programs. With these comments 
we were able to make a number of corrections and important clarifications in the 
report. 
Within the Inspector General community, there was strong support for greater Federal 
Government attention to the accountability issues raised in the report. There was 
particular support for the suggestion that Federal Uniform Administrative 
Requirements or similar provisions apply to all block grant programs. 
On the other hand, a Federal representative of a block grant program emphasized 
that such a requirement would go against the very grain of block grants and would add 
unnecessary costs to State administration of the grants. 
Finally, a few commenters underscored the limitation of the report in that it focuses 
block grant 
only on those accountability provisions which are set forth in Federal 
statutes. They agreed with our advisory that a more complete understanding of 
accountabilty for block grants would call for a review of regulatory and non-regulatory 
guidance provided by Federal agencies and of actual Federal practice in enforcing 
statutory and regulatory requirements.  . . ..  ..  ..  ..  ..  ..  ...   ....    ....    ....    .......   . ........ .   .........  .  ........ .   ......... .   ........ .   ......... .    .....     .....     .....    . . ... .    .....     .........     ..........  .   ......... .   . ........ . .   ..... ...  .    .....     .....     .....     .....     .....     .....  .   . ....     .....     .....     .....    . ... .   . .. ..  . . . .  ... .    .....    .....     ....    ....    ......    .. . 
APPENDIX A 
ACCOUNTABILIT PROVISIONS

STATUTES 
IN BLOCK  GRAT 
TABLE OF CONTNT 
OVERVIW. . 
PROGRA ACRONYS. 
PERFORMCE 
FINANCIAMAAGEMENT 
PROGRAATIC REQUIMENT 
QUALIT ASSURNCE 
DEFINONS OF PERFORMCE TERMS
 .- ...... .. .  .-. . '" 
... ..
ACCOUNABILIT PROVISIONS IN BLOCK GRANT STATU: OVERVIW

Number of Block Grant 
Specifg 
Programs  1 or 
More Requirements 
Accountabilty Provision 
Concerng the 
Accountabilty Provision 
JPeff6fnance 
Developing Program Plans 
Setting Performance Goals 
Establishing Performance Indicators 
Collecting and Verifying the Accuracy of 
Performance Data 
Conducting Program Evaluations 
Preparing Reports 
Management 
Financial-
Report of Expenditures 
Conducting Audits 
Conducting Pre-Audits 
Fund Accounting Procedures 
Assuring Level of Expenditures 
Remittance of Certain Amounts 
Penalties 
Programmatic Requirements 
Earmarking Funds 
Assuring Access 
Providing Services 
Quality Assurance 
Assuring Minimum Standards of Personnel 
Assuring Minimum Standards of Facilities 
Offering Complaint, Grievance, or Appeals 
Mechanisms 
A - 2
 GRA 
ACRONYS FOR BLOCK  PROGRAS 
CCDBG  Child Care Development Block Grant 
CDBG  Community Development Block GrantlEntitlement Program 
CMHS  Community Mental Health Services 
CSBG  Community Services Block Grant 
EDU  Elementary and Secondary Education Act, Title VI: 
Innovative Education Program Strategies

FTCOA  Federal Transit Capital and Operating Assistance

JTPA  Job Training Partnership Act, Titles IIa & IIc: 
Training for Youth and Disadvantaged Adults

LIHEAP  Low Income Home Energy Assistance Program

MCH  Maternal and Child Health 
PHHS  Preventive Health and Health Services

SAPT  Substance Abuse Prevention and Treatment

SSBG  Social Services Block Grant

STP  Surface Transportation Program

A - 3
 ..  . .
... . . . 
.... 
.."....".............".." ........".. ... ...  . ... .... .. ...  '" 
GRA STATU: 
ACCOUNABILIT PROVISIONS IN BLOCK 
PERFORMACE 
FEERA 
GRA 
REQUIMENT  STATIDRY  BLDCK  PRDGRAS 
MAATE 
.PrOg YES(l3) .  MCH, SSBG EDU, FrCDA CMHS SAPT LtHEAP
....ti  Ql..Plar  . CCDBG, JTPA, CDBG  PHHS,STP CSBG. 
Grantee must develop  MCH, SSBG, EDU, FrCDA, CMHS, SAPT, LIHEAP

program plan  CCDBG, JTPA, CDBG, PHHS, STP, CSBG

Grantee must develop plan  STP 
jointly with Federal agency 
Grantee must coordinate  MCH, EDU, FrCDA, LIHEAP, CCDBG, CDBG, JTPA

with other bodies in  PHHS, STP, CSBG

developing plan

Grantee must submit plan  MCH, SSBG, EDU, FrCDA, CMHS, SAPT, LIHEAP 
to Federal agency  CCDBG, JTPA, CDBG, PHHS, STP, CSBG 
Grantee must submit plan in  MCH, EDU, FrCDA, CMHS, SAPT, LIHEAP, CCDBG

specified time frame  CDBG, STP, CSBG

Plan must specify staffng  FrCDA, CMHS, PHI-IS, STP 
resources 
Plan must specify intended  MCH, SSBG, EDU, CMHS, SAPT, LIHEAP, JTPA, CDBG 
expenditures  PHHS, STP, FrCDA 
Plan must describe needs  MCH, FrCDA, CMHS, JTPA, STP, SAPT, CSBG 
assessment procedure 
Plan must describe service  FrCDA, CMHS, LIHEAP, JTPA, CDBG, STP 
delivery approaches 
Plan must offer specified  MCH, EDU, FrCDA, CMHS, SAPT, LIHEAP, CCDBG

programmatic assurances  JTPA, CDBG, PHHS, STP, CSBG

Plan must conform to  MCH, CMHS, STP, LIHEAP, CDBG, CSBG 
format prescribed by

Federal Government 
Plan must be reviewed by  FrCDA, CMHS , SAPT, JTP A, CCDBG, CDBG, STP 
general purpose government 
Plan must be reviewed by  CMHS, JTPA, STP, FrCDA

advisory body

Plan must be reviewed at  FrCDA, LIHEAP, CCDBG, JTPA, CDBG, PHHS, STP

public hearing  CSBG

Plan must be made available  MCH, SSBG, FrCDA, CMHS, SAPT, LIHEAP, JTPA

CDBG, PHHS, STP, CSBG

to public 
Federal agency must  MCH, EDU, FrCDA, CMHS, SAPT, CCDBG, JTPA 
approve plan  CDBG, STP 
SetingPerformance Goals  YES (5)  MCI-I, CMHS, JTPA, PHHS, LIHEAP 
A - 4  ::'):: .. , - -
Grantee must develop  MCH, CMHS, JTP A, PHHS

performance goals

Grantee must develop  LlHEAP 
performance goals jointly 
with Federal agency

Grantee must submit  MCH, CMHS, PHHS

performance goals to

Federal agency

Grantee must submit  MCH, CMHS, PHHS

performance goals to

Federal agency in specified 
time frame 
Grantee must submit  MCH, JTP A, PHHS

particular performance goals

specified by Federal agency

Performance goals must  MCH 
conform to format 
prescribed by Federal agency

Performance goals must be  CMHS

reviewed by general purpose

government

Performance goals must be  CMHS 
reviewed by advisory body 
Performance goals must be

reviewed at public hearing

Performance goals must be  MCH, JTP A, CMHS, PHHS

made available to public

Federal agency must  MCH, CMHS 
approve goals 
Federal agency must tie  JTPA 
funding to meeting 
performance goals 
EStablishigPerorme  YES (6)  MCH, CMHS, JTP A, PHHS  CSBGjLIHEAP 
liiaJrs 
GranteemustdeveloP  MCH, Ci\1HS, PHHS, CSBG 
performance indicators 
Grantee must develop  , LlHEAP 
performance indicators  I PHHS 
jointly with Federal agency 
Grantee must submit  MCH, CMHS, JTP A, PHHS, CSBG 
performance indicators to 
Federal agency

Grantee must submit  MCH, CMHS, PHHS 
performance indicators to 
Federal agency in specified 
time frame 
A - 5  '.. ...........".
Grantee must submit  MCH, JTP A, PHHS 
particular performance 
indicators specified by 
Federal agency 
Performance indicators must  MCH, PHHS 
conform to format 
prescribed by Federal agency 
Performance indicators must 
be reviewed by general 
purpose government 
Performance indicators must  CMHS 
be reviewed by advisory 
body 
Performance indicators must 
be reviewed at public 
hearing 
Performance indicators must  MCH, PHHS, CMHS 
be made available to public 
Federal agency must  MCH, CMHS 
approve indicators 
Federal agency must tie  JTPA, CSBG 
funding to performance 
indicators 
gerfygAccuac of NONE 
Peiorme 
DaJa 
Grantee must verify 
accuracy of performance 
data 
Federal Government must 
verify accuracy of 
performance data 
Conductig Pram  YES (10)  EDU, FrCOA, CMHS, SAPT, CCDBG, CDBG, PHHS 
EviJuans  STP, CSBG, JTPA 
Grantee must conduct  EDU, CMHS, SAPT, CDBG, PHHS, JTPA 
evaluation of program 
Grantee must conduct  STP 
evaluation jointly with 
Federal agency 
Grantee must conduct 
evaluation in coordination 
with other agencies 
Grantee must conduct 
evaluation which indicates 
results in terms of specified 
performance goals and 
indicators 
A - 6  Grantee must submit  EOU, COBG 
evaluation to Federal agency 
Grantee must submit  EOU, COBG 
evaluation in specified time 
frame 
Evaluation must conform to  COBG 
format prescribed by 
Federal Government 
Evaluation must be reviewed  JTPA 
by general purpose 
government 
Evaluation must be reviewed  JTP A, CMHS 
by advisory body 
Evaluation must be reviewed 
atpublichearing 
Evaluation must be made  JTPA, EOU, COBG, STP 
available to general public 
Federal agency must  CMHS, SAPT, STP, CSBG 
perform evaluation of 
grantee program 
Federal agency must  FrCOA, CCOBG, PHHS, CSBG, JTPA, LIHEAP, CMHS 
perform compliance reviews  SAPT 
Report  YES (13)  MCH, SSBG, EOU CMHS  SAPT UHEAP, CCOBG 
.1fepg  JTPA, COBG PHHS, STP  CSBG  FrCOA 
Grantee must prepare  MCH, SSBG, EOU, CMHS, SAPT, LIHEAP, CCOBG 
report  JTP A, PHHS, STP 
Grantee must submit report  MCH, SSBG, EOU, CMHS, SAPT, LIHEAP, CCOBG 
to Federal agency  JTP A, PHHS, STP 
Report must include the  MCH, SSBG, EOU, LIHEAP, CCOBG, CMHS, JTPA 
number of individuals served 
Report must include the  MCH, SSBG, EOU, CCOBG, PHHS, CMHS 
amount spent in providing 
services 
measures 
Report must include output MCH, SSBG, EOU, CMHS, SAPT, CCDBG, PHHS 
Report must include  MCH, SAPT, JTP A, PHHS, CMHS 
outcome measures 
Report must include criteria  SSBG 
applied in determining 
eligibility 
Report must include  SSBG 
methods by which services 
were provided 
Report must conform to  MCH, JTP A, PI-IHS 
format prescribed by 
Federal Government 
A - 7  Report must be made  MCH 
available to general purpose 
government 
Report must be made  MCH, SSBG, EDU, CMHS, SAPT, PHHS 
available to public

Federal agency must report  MCH, CMHS, SAPT, LIHEAP, CCDBG, JTPA, CDBG 
to Congress  PHHS, STP, CSBG, FrCDA 
A - 8
 . .
. .
:' , ... .. . .. ... " ,

GRA STATU: 
ACCOUNABILIT PROVISIONS IN BLOCK 
FINANCIA MAAGEMENT 
FEERA 
GRA 
REQUIMENT  STATIORY  BLOCK  PROGRAS 
MAATE 
ExndiJes  . YES (10) MCH,SSFBTG CEDOU, CACD B. G JTPA  CDBG PHHS, S'I, 
1Jepol1 of 
CSBG, 
Grantee must prepare report  MCH, SSBG, EDU, CCDBG, JTPA, CDBG, PHHS, STP 
of actual expenditures  CSBG 
Grantee must submit report  MCH, SSBG, EDU, CCDBG, JTPA, CDBG, PHHS, STP 
CSBG 
to Federal agency 
Grantee must submit report  MCH, SSBG, EDU, CCDBG, CDBG, PHHS, S11, CSBG 
in specified time frame 
Report must conform to	 MCH, JTPA, PHHS, FTCOA 
format specified by Federal 
Government 
Report must be reviewed by

general purpose government 
Report must be reviewed by  JTPA 
advisory body 
Report must be reviewed at 
public hearing 
Report must be made  MCH, SSBG, EDU, PHHS 
available to general public 
Federal agency must report  MCH, CCDBG, PHHS, STP, FTCOA 
to Congress on expenditures 
Condtig Audit  YES (11)	 MCH, SSBG, FrCOA, CMI-IS, SAPT, UHEAP CCDBG 
J11 A, CDBG, PHHS, CSBG 
Grantee must have financial  MCII, SSBG, FrCGA, LII-IEAP, CCDBG, PHHS, CSBG 
audit performed by 
independent party 
Grantee must have financial  CMHS, SAPT, UHEAP 
audit performed under single 
audit mechanism 
Grantee must submit  MCI-I, SSBG, LII-EAP, CCDBG, PHHS, CSBG, CMHS 
financial audit to Federal  SAPT 
agency 
Grantee must submit  MCH, SSBG, LII-EAP, CCDBG, PHHS, CSBG, CMHS 
financial audit to Federal  SAPT 
agency in specified time 
period 
Financial audit must be  SSBG, LIHEAP, CCDBG, CSBG 
reviewed by general purpose 
government  : .
Financial audit must be 
reviewed by advisory body 
Financial audit must be 
reviewed at public hearing 
Financial audit must be made  MCH, CMHS, SAPT, LIHEAP, PHHS 
available to general public 
Federal agency must perform  FrCGA, CMHS, SAPT, LIHEAP, COBG, CSBG 
audit of grantee program 
S. Comptroller General  LIHEAP, PHHS, CSBG

must perform audit of

grantee program 
(;orUtigPre-AudiJ  NGNE 
Federal agency must conduct 
pre-audit preceding 
application approval 
predures  YES (5)  MCH, LIHEAP; JTP A, PHHS, CSBG 
fWt. accouning 
Grantee must establish fund  MCH, LIHEAP, JTPA, PHHS, CSBG 
accounting procedures 
4fgLe 
l of YES (13)  MCH, SSBG, EOU, FrCGA, CMHS, SAPT, LIHEAP
!#ndes 
CCOBG, JTPA  COBG, PHHS, STP, CSBG 
Grantee must assure  MCH, EOU, FrCGA, CMHS, SAPT, CCOBG, PHHS 
maintenance of financial  JTP A, STP 
effort 
Grantee must provide  MCH, FrCGA, SAPT, STP, JTPA 
specified matching shares of 
expenditures 
Grantee must adhere to  MCH, EOU, CMHS, SAPT, JTPA, COBG, PHHS, STP 
specified limits on  CSBG 
administrative costs

Grantee must adhere to  SSBG, JTPA, PI-HS, STP, CSBG 
limits on the transfer of funds 
Payments to grantee must be  MCH, SSBG, STP, CSBG, JTPA, CMHS, SAPT, CCOBG 
expended within given time 
frame 
R.imitane o/Cerai  MCH, FrCGA, SSBG, LIHEAP, CCOBG, JTPA,PHHS, 
YES (11) 
Amwz  STP  CSBG, CMI-S, SAPT 
Grantee must remit  MCH, FrCGA, LIHEAP, STP, CMHS, SAPT 
unobligated funds to Federal

agency 
Grantee must remit funds  MCH, SSBG, LII-EAP, CCOBG, PHI-S, CSBG, JTPA 
not expended in accordance 
with the block grant 
Piiti 
YES (11)  MCI-, EDU, CMHS, SAPT, LIHEAP, CCDBG JTPA, 
PHHS, STP, CSBG, FrCGA 
A - Federal agency must withhold  MCH, EDU, CMHS, SAPT, LIHEAP, CCDBG, JTPA 
funds from grantee in  PHHS, STP, CSBG, FrCDA 
noncompliance 
Federal agency must reduce  CMHS, JTP A 
allotment for incomplete plan 
implementation 
A -
 .""  . .
.........".   
.. '"' 
......\.\,'.\.. ...  ...... ........ .... . .
GRA STATU: 
ACCOUNABILIT PROVISIONS IN BLOCK 
PROGRATIC REQUIMENT

REQumMENT	 FEERA  BLOCK GRA PROGRAS 
STATUORY 
MAATE 
gFui 
YES (11)	 MCR  EDU, CMHS, SAPT CCDBG JTPA; CDBG;STP, 
CSBG  FrCOA UHEAP 
Statute earmarks designated  MCR, EDU, CMRS, SAPT, JTPA, CDBG, STP, CSBG

proportion of funds for  FrCOA

certain categories of

recipients

Statute earmarks designated  MCR, SAPT, CCDBG, JTPA, STP, CSBG, FTCOA

proportion of funds for  LIREAP

certain types of services

##llnngAccess.  YES (8)	 MCR, EDU, CMRS, SAPT CCDBG JTPA  CDBG;

LIREAP

Grantee must assure access  MCR, EDU, CMRS, SAPT, CCDBG, JTP A, CDBG

to certain categories of  LIREAP

recipients

n... .. 
l:oVUiHgSeres  YES (12)  MCR, SSBG, EDU, FTCOA  CCMSRSB SGAP T.  URpAP,. 
CCDBG, JTPA, CDBG, STP, 
Grantee must coordinate  MCR, EDU, FrCOA, CMRS, SAPT, UREAP, CCDBG 
delivery of services with other  JTP A, CSBG, STP 
bodies 
Grantee must provide  MCR, SSBG, EDU, CMRS, SAPT, LIREAP, CCDBG,

explicitly defined services  JTPA, CDBG, STP, CSBG

Grantee must carry out	 FrCOA, CMRS, SAPT, CCDBG, STP, CDBG 
servces in a prescribed

manner 
A -
 .... 
.". .... 
."...,.  
....  . ... . . .
....... . . .. . .... ................
GRA STATU:

ACCOUNABILIT PROVISIONS IN BLOCK 
QUALIT ASSURCE 
-=RY  GRA 
REQUIMENT  BLOCK  PROGRAS 
MAATE

gi1stands 
YES (4) .. CCDBG  STP  CMHS, FrCDA

pFjJotil 
Grantee must assure that  CCDBG, STP, CMHS, FrCOA 
personnel be licensed/certified I
g1n 
YES (5)  SSDG, CMHS, CCDDG, STP, FrCDA
stanards 
P!!tiiIiJ 
Grantee must assure that  SSDG, CMHS, CCDDG, STP, FrCDA 
facilities be accredited 
Grantee must assure that  SSDG, CMHS, CCDDG, STP, FrCDA 
facilities comply with health 
and safety standards 
YES (9)  EDU, FrCDA, CMHS, SAPT, LIHEAP, CCDBG, JTPA 
Offerg compla grane, 
pr: CDDG, CSDG 
appeal mechams 
Grantee must establish  LIHEAP, CCDDG, JTPA, CDDG, EDU 
complaint, grievance, or 
appeals mechanisms 
Grantee must establish  EDU, JTPA 
complaint, grievance, or 
appeals mechanisms in 
accordance with prescribed 
Federal procedures 
Federal agency mus,t e sotablrish  i  FrCOA, SAPT, LIHEAP, CCDDG, CMHS, CSDG 
complaint, grievance
appeals mechanisms 
A -
 DEFINITIONS OF PERFORMCE TERMS

Following are definitions of key terms concerning performance accountability. The 
definitions are those set forth in Section 1115(f) of the Government Performance and 
Results Act of 1993.

means a target level of performance expressed as a tangible 
Performance goal 

measurable objective, against which actual achievement can be compared, including a 
goal expressed as a quantitative standard, value, or rate. 
means a particular value or characteristic used to measure
Performance indicator 
output or outcome.

means the tabulation, calculation, or recording of activity or effort and 
Output measure 

can be expressed in a quantitative or qualitative manner. 
means an assessment of the results of a program activity compared 
Outcome measure 

to its intended purpose. 
means an assessment, through objective measurement and 
Program evaluation 

systematic analysis, of the manner and extent to which Federal programs achieve 
intended objectives. 
A - 14
 APPENDIX B

ENDNOTES

degree of discretion, we are thinking of 
1. In distinguishing block grants by their 
They 
discretion across the four categories of accountabilty we use in this report. 
include Federal accountability provisions concerning financial management 
performance, programmatic requirements, and quality assurance. 
2. Congress terminated General Revenue Sharing for State governments in 1981 and 
for local governments in 1986. 
3. As we have noted, there is no definitive dividing line between a block grant and a 
categorical grant. As a result, there can be differing views as to what programs are 
properly regarded as block grants. Our approach was to use as a starting point the 
15 block grant programs identified by the general Accounting Office in its February 
1995 report entitled  Block Grants: Characteristics, Experience, and Lessons Learned 
(GAOIHEHS-95-74). From that universe, we eliminated one program because it was 
discontinued as a block grant ("Projects for Assistance in Transition from 
Homelessness ) and we combined the Community Development Block Grant (CDBG) 
Entitlement Program and the CDBG State and Small Cities Program into one for our 
purposes. The latter two programs serve the same basic purposes and have essentially 
the same accountability provisions. 
4. The extent of the difference is well ilustrated in a 1993 report of the Advisory 
Commission on Intergovernmental Relations. It indicated that in 1993, 593 categorical 
grant programs accounted for $147.4 bilion in appropriations. This compared with 
15 block grant programs accounting for $17. 6 bilion. See Advisory Commission on 
Intergovernmental Affairs  Characteristics of Federal Grant-in-aid Programs to State and 
1993, January 1994.

Local Governments: Grants Funded FY 
, U.S. Department of Health and Human Service 
5. Office of Inspector General
Federal Approaches to Funding Public Health Programs  OEI-94-00160, July 1995. 
6. Our taxonomy provides a comprehensive, but not exhaustive listing of the kinds of 
It is offered with the intent of 
accountability provisions that exist in the statutes. 
facilitating an understanding of the extent and types of accountability provisions, not of 
providing an accounting of all those that exist. Further, it is limited to a review of 
those provisions included within the block grant statutes themselves. There are other 
Federal statutes , and other forms of 
, such as: (1) those prohibiting racial, age
discrimination, (2) the Inspector General Act of 1978 as amended, (3) the Single State  , p.

Audit Act of 1984, and (4) others that apply to block grant recipients even if they are 
not specifically addressed in the Federal block grant legislation. 
and A-102. For the 
7. Essentially, these are reflected in OMB circular  87 
Department of Health and Human 
Services they are set forth in 45 C.F.R. Part 92. 
Other departments have their own regulatory citations. 
8. See 45 C.F.  , sec. 96.30. The regulation also states: "Fiscal control and accounting 
procedures must be sufficient to (a) permit preparation of reports required by the 
statute authorizing the block grant and (b) permit the tracing of funds to a level of 
expenditure adequate to establish that such funds have not been used in violatjon of 
the restrictions and prohibitions of the statute authorizing the block grant. 
9. A 1993 report by the President s Council on Integrity & Efficiency also noted some 
Council on Integrity & Efficiency Standards 
limitations. See President's 
Subcommittee  Study on Improving the Single Audit Process  September 1993. 
10. See General Accounting Office  Single Audit Act: Refinements Can Improve 
Usefulness  GAO/AIMD-94-133, June 1994 and General Accounting Office  Block 
Grants: Characteristics, Experience, and Lessons Leamed  GAOIHEHS-95- , February 
1995. 
11. The proposal under consideration in the House of Representatives is H.  3184. 
The proposal under consideration in the Senate is S. 1579. 
12. In a recent report, the GAO has noted three options available to policymakers 
seeking to establish accountability without burdensome provisions. They include: "(1) 
relying on state processes both to manage block grant funds and to monitor and assess 
compliance, (2) assessing the nature of requirements imposed on states, including the 
applicability of cross-cutting requirements for national policy for block-granted 
programs, and (3) emphasizing results-based evaluation rather than examining specific 
1I See U.
program or administrative activities. S. General Accounting Office  Block 
Grants: Issues in Designing Accountability Provisions GAO/AIMD-95-226, September 
1995