prompt_front: You are given two reports by the government agency.



Question: Write a one-page summary of the report 1.

Report 1: The EFMP provides support to families with special needs at their current and proposed locations  Servicemembers relocate frequently, generally moving every 3 years if in the Army, Marine Corps, and Navy, and every 4 years if in the Air Force  In fiscal year 2016, the Military Services relocated approximately 39,000 servicemembers enrolled in the EFMP to CONUS installations  To implement DOD’s policy on support for families with special needs, DOD requires each Service to establish its own EFMP for active duty servicemembers  EFMPs are to have three components—identification and enrollment, assignment coordination, and family support  Identification and enrollment: Medical and educational personnel at each installation are responsible for identifying eligible family members with special medical or educational needs to enroll in the EFMP  Once identified by a qualified medical provider, active duty servicemembers are required to enroll in their service’s EFMP  Servicemembers are also required to self-identify when they learn a family member has a qualifying condition  Assignment coordination: Before finalizing a servicemember’s assignment to a new location, DOD requires each Military Service to consider any family member’s special needs during this process, including the availability of required medical and special educational services at a new location  Family support: DOD requires each Military Service’s EFMP to include a family support component through which it helps families with special needs identify and gain access to programs and services at their current, as well as proposed, locations  Servicemembers assigned to a joint base would receive family support from the Service that is responsible for leading that installation  For example, an Airman assigned to a joint base where the Army is the lead would receive family support from the Army installation’s EFMP  As required by the NDAA for Fiscal Year 2010, DOD established the Office of Community Support for Military Families with Special Needs (Office of Special Needs or OSN) to develop, implement, and oversee a policy to support these families  Among other things, this policy must (1) address assignment coordination and family support services for families with special needs; (2) incorporate requirements for resources and staffing to ensure appropriate numbers of case managers are available to develop and maintain services plans that support these families; and (3) include requirements regarding the development and continuous updating of a services plan for each military family with special needs  OSN is also responsible for collaborating with the Services to standardize EFMP components as appropriate and for monitoring the Services’ EFMPs  OSN has been delegated the responsibility of implementing DOD’s policy for families with special needs by the Undersecretary of Defense for Personnel and Readiness through the Assistant Secretary for Manpower and Reserve Affairs according to DOD officials  Currently, OSN is administered under the direction of the Deputy Assistant Secretary of Defense for Military Community and Family Policy through the Office of Military Family Readiness Policy  In addition, each Military Service has designated a program manager for its EFMP who is also responsible for working with OSN to implement its EFMP (see fig  1)  DOD’s guidance for the EFMP (1) identifies procedures for assignment coordination and family support services; (2) designates the Assistant Secretary of Defense for Manpower and Reserve Affairs as being responsible for monitoring overall EFMP effectiveness; (3) assigns the OSN oversight responsibility for the EFMP, including data review and monitoring; and (4) directs each Service to develop guidance for overseeing compliance with DOD requirements for their EFMP  Table 1 provides an overview of the procedures each Service must establish for the assignment coordination and family support components of the EFMP  As a part of its guidance for monitoring military family readiness programs, DOD also requires each Military Service to certify or accredit its family readiness services, including family support services provided through the EFMP  In addition, DOD states that each Service must balance the need for overarching consistency across EFMPs with the need for each Service to provide family support that is consistent with their specific mission  To accomplish this, each Service is required to jointly work with DOD to develop a performance strategy, which is a plan that assesses the elements of cost, quality, effectiveness, utilization, accessibility, and customer satisfaction for family readiness services  In addition, each Military Service is required to evaluate their family readiness services using performance goals that are linked to valid and reliable measures such as customer satisfaction and cost  DOD also requires each Service to use the results of these evaluations to inform their assessments of the effectiveness of their family readiness services for families with special needs  According to DOD officials, each Military Service provides family support services in accordance with DOD guidance as well as Service-specific guidance  However, we found wide variation in each Service’s requirements for family support personnel as well as the practices and expectations of EFMP staff  As a result the type, amount, and frequency of assistance enrolled families receive varies from Service to Service and when a servicemember from one Service is assigned to a joint base led by another Service (see table 2)  For example, in terms of a minimum level of contact for families with special needs enrolled in the EFMP, the Services vary in the frequency with which they require family support providers to contact families with special needs: The Marine Corps specifies a frequency (quarterly) with which families with special needs should be contacted by their family support providers  The Air Force has each installation obtain a roster of families with special needs enrolled in the EFMP on a monthly basis, but it does not require family support providers to, for example, use this information to regularly contact these families  The Navy assigns one of three service levels to each family member enrolled in the EFMP  These service levels are based on the needs of each family with special needs; family support providers are responsible for assigning a “service level” that directs the frequency with which the family must be contacted  The Army has no requirements for how often families with special needs should be contacted  The Services also vary as to whether they offer legal assistance to families with special needs as follows: The Marine Corps employs two attorneys who can represent families with special needs who fail to receive special education services from local school districts, as specified in their children’s individualized education programs (IEP)  They can also advise EFMP-enrolled families on their rights and options if a family believes their child needs special education services from a local school district (e g , an IEP)  The Air Force, Army, and Navy choose not to employ special education attorneys  Officials with whom we spoke said families with special needs in these Services can receive other types of assistance that may help them resolve special education legal issues  For example, Air Force officials said servicemembers and their families can receive support from attorneys that provide general legal assistance on an installation, Army officials said installation EFMP managers can refer families with special needs to other organizations that provide legal support, and Navy officials said families can find support through working with their installation’s School Liaison Officers  The NDAA for Fiscal Year 2010 requires DOD’s policy to include requirements regarding the development and continuous updating of a services plan (SP) for each family with special needs, and DOD has specifically required these plans as part of the provision of family support services  These plans describe the necessary services and support for a family with special needs and document and track progress toward meeting related goals  According to DOD guidance, these plans should also document the support provided to the family, including case notes  In addition, the DOD reference guide for family support providers emphasizes that timely, up-to-date documentation is especially important each time a family relocates, as military families regularly do  Therefore, SPs are an important part of providing family support during the relocation process, and provide a record for the gaining installation  Requiring timely and up-to-date documentation is consistent with federal internal control standards, which state that agencies should periodically review policies, procedures, and related control activities for continued relevance and effectiveness in achieving their objectives  SPs follow families with special needs each time they relocate and without timely and up-to-date documentation, DOD cannot ensure that all families continue to receive required medical and/or special educational services once they relocate to another installation  For every Service the number of SPs was relatively few when compared to the number of servicemembers (known as sponsors) or the number of family members enrolled in the EFMP (see table 3)  The Services and OSN provided a range of reasons as to why the Services do not develop and maintain a SP for each family with special needs  For example, Air Force officials said their family support providers consider the needs of each family with special needs before determining whether a SP will help them receive the required services  In addition, Army and Marine Corps officials said they may not develop these plans if families do not request them  Further, according to a Navy official, some families lack the required SPs because installations may not have the staff needed to develop them—even though DOD requires the Services to maintain sufficient staff and certify their EFMPs  OSN officials with whom we spoke also said that the Services may not have developed many SPs during fiscal year 2016 because DOD had not yet approved a standardized form that could be used to meet this requirement  Finally, OSN officials also said that each family with special needs enrolled in the EFMP may not need a SP because their condition does not require this type of family support  To meet requirements of the NDAA for Fiscal Year 2010, in April 2017, DOD issued to the Services guidance that directed them to “rogram, budget, and allocate sufficient funds and other resources, including staffing,” to meet DOD’s policy objectives for the EFMP  According to OSN officials, DOD relies on each Service to determine what level of funds and resources is sufficient and what constitutes an appropriate number of family support personnel  To determine family support providers and related personnel staffing levels, the Service officials with whom we spoke said they consider a number of factors, including the number of families with special needs enrolled in the EFMP at any given installation (see app  II for more information about the EFMP data by installation)  See Table 4 for a summary of EFMP family support providers and other key personnel at CONUS installations  As required by DOD, all of the Services employ family support providers to assist families with special needs  In addition, some Services employ additional personnel to support implementation of the EFMP (see sidebar)  For example, the Air Force employs family support coordinators to administer its EFMP and no other personnel are dedicated to assisting these coordinators or enrolled families  The Army employs “system navigators” who provide individualized support to families with special needs at selected installations through its EFMP, as well as other personnel to administer the EFMP  workers at most of its CONUS installations to administer individualized support to families with special needs  In addition, the Marine Corps employs program managers, administrative assistants, as well as training and education outreach specialists  The Navy contracts regional case liaisons and case liaisons at selected CONUS installations to administer individualized support to families with special needs  In addition, the Navy employs collateral duty case liaisons who assist with the delivery of family support services at all other CONUS installations  Senior OSN officials said they rely on each Service to determine the extent to which its EFMP complies with DOD’s policy for families with special needs because they consider OSN to be a policy-making organization that is not primarily responsible for assessing compliance  In addition, these officials said the Services need flexibility to implement DOD’s policy for families with special needs because they each have unique needs and the number of enrolled families in the EFMP is constantly changing  However, DOD has not developed a standard for determining the sufficiency of funding and resources each Service allocates for family support  Air Force officials at one of the installations we visited said the Air Force identified the lack of staff and funding to provide individualized support to most families with special needs as an issue  In addition, officials from the Army and Navy said they have not received any guidance from OSN officials about their Service-specific guidance, including requirements for resources and services plans  Further, the Services may not know the extent to which their Service- specific guidance complies with DOD’s policy for families with special needs  The NDAA for Fiscal Year 2010 requires DOD to identify and report annually to the congressional defense committees on gaps in services for military families with special needs and to develop plans to address these gaps  However, DOD’s most recent reports to the congressional defense committees did not address the relatively few SPs being created for families with special needs, or whether the Services are providing sufficient resources to ensure an appropriate number of family support providers  Federal internal control standards require that agencies establish control activities, such as developing clear policies, in order to accomplish agency objectives such as those of the Services’ EFMPs  Without fully identifying and addressing potential gaps in family support across these programs, some families with special needs may not get the assistance they require, particularly when they relocate  Each Service monitors EFMP assignment coordination and family support using a variety of mechanisms, such as regularly produced internal data reports  However, DOD has not yet established common performance measures to track the Services’ progress in implementing its standard procedures over time or developed a process to evaluate the overall effectiveness of each Service’s assignment coordination and family support procedures  DOD requires each Service to monitor implementation of their EFMP, including their procedures for assignment coordination and family support  To comply with this requirement, each Service has developed guidance that establishes monitoring protocols and assigns oversight responsibilities  Officials from each Service told us they use internal data reports from each installation to monitor assignment coordination and family support  To monitor assignment coordination, officials from each Service told us their headquarters reviews proposed assignment locations for families with special needs enrolled in the EFMP  These officials said monitoring proposed assignment locations helps ensure that enrolled families will be able to access required services at their new installations  In addition, Army officials said each Army unit commander is responsible for tracking the number of families with special needs that have expired enrollment paperwork because it affects assignment coordination worldwide  Several years ago, the Army determined that 25 percent of soldiers (over 13,000) enrolled in the EFMP had expired enrollment paperwork, complicating the task of considering each enrolled family’s special medical or educational needs as part of proposed relocations  In response, in August 2011, the Army revised its policies and procedures for updating enrollment paperwork which would help ensure a family member’s special needs are considered during the assignment coordination process  To monitor family support provided by installations worldwide, each Military Service told us they use a variety of mechanisms (see table 5)  The Marine Corps pays particular attention to customer satisfaction  Marine Corps officials told us that every three years Marine Corps headquarters administers a survey of family members enrolled in the EFMP  We previously reported that organizations may be able to increase customer satisfaction by better understanding customer needs and organizing services around those needs  This survey is one of the primary ways Marine Corps headquarters measures customer satisfaction with family support services at installations worldwide  Marine Corps officials also said this survey helps ensure its EFMP is based on the current needs of families with special needs  To improve its oversight of the EFMP and implement its policy for families with special needs, DOD, through OSN, has several efforts under way to standardize the Services’ procedures for assignment coordination and family support  However, DOD has not developed common performance measures to monitor its progress toward these efforts and has not developed a process for assessing the Services’ related monitoring activities  Federal internal control standards emphasize the importance of assessing performance over time and evaluating the results of monitoring activities  To help improve family member satisfaction by addressing gaps in support that may exist between Services, OSN has begun to standardize procedures for assignment coordination and family support  To date, OSN’s efforts have focused on ensuring each Service’s EFMP considers the needs of family members during the assignment process and helps family members identify and gain access to community resources  According to OSN’s April 2017 Report to Congress, the long-term goal of these efforts is to help ensure that all families with special needs enrolled in the EFMP receive the same level of service regardless of their Military Service affiliation or geographic location  In addition, OSN officials told us its standardized procedures will also help DOD perform required oversight by improving its access to Service-level data and its ability to validate each Service’s monitoring activities  To date, efforts to standardize assignment coordination and family support have included efforts such as developing new family member travel screening forms which will be the official documents used during the assignment coordination process and completing a DOD-wide customer service satisfaction survey on EFMP family support (see table 6)  Despite its efforts to begin standardizing assignment coordination and family support services, DOD is unable to measure its progress in standardizing assignment coordination and family support procedures for families with special needs and assessing the Services’ performance of these processes because it has not yet developed common metrics for doing so  Federal internal control standards emphasize the importance of agencies assessing performance over time  We have also reported on the importance of federal agencies engaging in large projects using performance metrics to determine how well they are achieving their goals and to identify any areas for improvement  By using performance metrics, decision makers can obtain feedback for improving both policy and operational effectiveness  Additionally, by tracking and developing a baseline for all measures, agencies can better evaluate progress made and whether or not goals are being achieved—thus providing valuable information for oversight by identifying areas of program risk and causes of risks or deficiencies to decision makers  Through our body of work on leading performance management practices, we have identified several attributes of effective performance metrics relevant to OSN’s work (see table 7)  OSN officials said each Service is currently responsible for assessing the performance of its own EFMP, including the development of Service- specific goals and performance measures  OSN officials said that they recognize the need to continually measure the department’s progress overall in implementing its policy for families with special needs, and are considering ways to do so  They also said they have encountered challenges to developing common performance measures  In addition, OSN officials said its efforts to reach consensus among the Services about performance measures for the overall EFMP are still ongoing because each Service wants to maintain its own measures, and DOD has not required them to reach a consensus  Absent common performance measures, DOD is unlikely to fully determine whether its long-standing efforts to improve support for families with special needs are being implemented as intended  DOD requires each Service to monitor its own family readiness programs, including procedures for assignment coordination and family support through the EFMP, but lacks a systematic process to evaluate the results of these monitoring activities  To monitor family readiness services, as required by DOD, each Service must accredit or certify its family support services, including the EFMP, using standards developed by a national accrediting body not less than once every 4 years  In addition, personnel from each Service’s headquarters are required to periodically visit installations as a part of their monitoring activities for assignment coordination, among other things  The Services initially had the Council on Accreditation accredit family support services provided through their installations’ EFMPs using national standards developed for military and family readiness programs, according to the officials with whom we spoke  However, by 2016, each Service was certifying installations’ family support services using standards that meet those of a national accrediting body, Service-specific standards, and best practices  According to officials from each Service with whom we spoke, this occurred due to changes in the funding levels allocated to this activity  Table 8 provides an overview of the certification process currently being used by each Service  OSN officials said they do not have an ongoing process to systematically review the results of the Services’ activities, including the certification of EFMPs because they choose to rely on the Services to develop their own monitoring activities and ensure they provide the desired outcomes  In doing so, DOD allows each Service to develop its own processes for certifying installations’ family support services, including the selection of standards  In addition, OSN officials told us that efforts to standardize certification of EFMPs are ongoing because the Military Services have not been able to reach consensus on a set of standards that can be used across DOD for installations’ family support services  Further, OSN has not established a process to assess the results of the Services’ processes for certifying installations’ family support services  Federal standards for internal control state that management should evaluate the results of monitoring efforts—such as those the Services are conducting on their own—to help ensure they meet their strategic goals  The lack of such a process hampers OSN’s ability to monitor the Services’ EFMPs and determine the adequacy of such programs as required by the NDAA for Fiscal Year 2010  OSN’s job of developing a policy for families with special needs that will work across DOD’s four Services is challenging given the size, complexity, and mission of the U S  military  It has had to consider, among other things, the Services’ mission requirements, resource constraints, and the myriad demands on servicemembers and their families during their frequent relocations  Anything that further complicates a relocation—such as not receiving the required family support services for family members with special needs—potentially affects readiness or, at a minimum, makes an already stressful situation worse  By providing little direction on how the Services should provide family support or what the scope of family support services should be, some servicemembers get more—or less—from the EFMP each time they relocate, including when a servicemember from one Service is assigned to a joint base led by another Service  By largely deferring to the Services to design, implement, and monitor their EFMPs’ performance, DOD cannot, as required by the NDAA for Fiscal Year 2010, fully determine the adequacy of the Services’ EFMPs in serving families with special needs, including any gaps in services these families receive, because it has not built a systematic process to do so  Instead, it relies on the Services to self-monitor and address, within each Service, the results of monitoring activities  However, because servicemembers relocate frequently and often depend on the EFMP of a Service other than their own, a view of EFMP performance across all of the Services is essential to ensuring, for example, that relocating servicemembers get consistent EFMP service delivery no matter where they are stationed  Evaluating and developing program improvements based on the results of the Services’ monitoring would help DOD ensure the Services’ EFMPs achieve the desired outcomes and improve its ability to assess the overall effectiveness of the program  We are making the following three recommendations to DOD: We recommend the Secretary of Defense direct the Office of Special Needs (OSN) to assess the extent to which each Service is (1) providing sufficient resources for an appropriate number of family support providers, and (2) developing services plans for each family with special needs, and to include these results as part of OSN’s analysis of any gaps in services for military families with special needs in each annual report issued by the Department to the congressional defense committees  (Recommendation 1) We recommend that the Secretary of Defense direct the Office of Special Needs (OSN) to develop common performance metrics for assignment coordination and family support, in accordance with leading practices for performance measurement  (Recommendation 2) We recommend that the Secretary of Defense implement a systematic process for evaluating the results of monitoring activities conducted by each Service’s EFMP  (Recommendation 3) We provided a draft of this report to the Department of Defense (DOD) for comment  DOD provided written comments, which are reproduced in appendix IV  DOD also provided technical comments, which we incorporated as appropriate  DOD agreed with all three of our recommendations  In its written comments, DOD stated that additional performance metrics need to be developed for assignment coordination and that it is in the process of measuring families’ satisfaction with family support provided through the EFMP  DOD also stated that it is developing plans for evaluating the results of each Service’s monitoring activities for the EFMP  We are sending copies of this report to the appropriate congressional committees, the Secretaries of Defense and Education, and other interested parties  The report also is available at no charge on the GAO website at http://www gao gov  If you or your staff have any questions about this report, please contact me at (617) 788-0580 or nowickij@gao gov  Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report  GAO staff who made key contributions to this report are listed in appendix V  The National Defense Authorization Act (NDAA) for Fiscal Year 2017 includes a provision for GAO to assess the effectiveness of the Department of Defense’s (DOD) Exceptional Family Member Programs (EFMP)  This report focuses on the assignment coordination and family support components of the EFMP for dependents with special needs and examines: (1) the extent to which each Service has provided family support as required by DOD, and (2) the extent to which the Services monitor and DOD evaluates assignment coordination and family support  To address these objectives, we used a variety of data collection methods  Key methods are described in greater detail below  For both objectives, we reviewed relevant federal laws, regulations, and DOD guidance and documentation that pertain to the EFMP, including the following: The NDAA for Fiscal Year 2010, which established the Office of Special Needs and defined program requirements for assisting families with special needs, including assignment coordination and family support  DOD’s guidance for administering the EFMP  We assessed how DOD implements the requirements in the NDAA for Fiscal Year 2010; how each Service implements assignment coordination and family support; and how the Services and DOD monitor assignment coordination and family support using performance measures  Specially, we reviewed DOD Instruction 1315 19 - Exceptional Family Member Program; Service-specific guidance and related documents from the Air Force, Army, Marine Corps, and Navy; and DOD Instruction 1342 22 - Military Family Readiness  Standards for internal control in the federal government related to the documentation of responsibilities through policies, performance measures, and evaluating the results of monitoring activities  We compared each Service’s procedures for monitoring assignment coordination and family support to these standards  To determine the extent of the Services’ EFMP family support, we obtained and analyzed fiscal year 2016 EFMP data (the most recent available) for each Service  We reviewed DOD policy to identify data variables that each Service maintains related to its EFMP  We used these data to summarize key characteristics of each Service’s EFMP  The selected variables provided Service-wide and installation-specific EFMP information on, the number of continental United States (CONUS) and outside the continental United States (OCONUS) installations; the number of servicemembers (sponsors) enrolled in the EFMP; the number of family members with special needs enrolled in the EFMP; the number of EFMP family support personnel; and the number of services plans created for families with special needs enrolled in the EFMP  We determined that the selected data variables from each Service are sufficiently reliable for the purposes of providing summary results about family support for fiscal year 2016  To learn more about how the Services implement their EFMPs, we visited seven installations in five states  We selected the seven installations based on their location in states with the largest number of military- connected students in school year 2012-2013 (the most recent available and reliable data) or in states with the largest percentage of students enrolled in U S  DOD schools as of May 2017, as well as their status as a joint base  At each installation, we interviewed installation officials, EFMP managers, selected family support personnel, and family members and caregivers enrolled in the program  In states we visited that had the largest number of military-connected students, the EFMP personnel we interviewed collectively served 66 percent of students who attend local public schools and 42 percent of the students attending U S  DOD schools  To obtain illustrative examples about how the EFMP serves families with special needs, we conducted seven group interviews with EFMP-enrolled family members and caregivers (one at each of the seven installations we visited)  Using a prepared script, we asked participants to describe how they were identified and enrolled in the EFMP, how they were assigned to new installations, and the types of family support services they received  We also asked about how these services aligned with their family member’s EFMP-eligible condition, the benefits and challenges they experienced, as well as their overall satisfaction  A total of 38 self- selected volunteers participated in the seven group discussions  While the participants in these groups included a variety of family members and caregivers, the number of participants and groups were very small relative to the total number of family members enrolled in the EFMP  Their comments are not intended to represent all EFMP-enrolled family members or caregivers  Other EFMP-enrolled family members and caregivers may have had other experiences with the program during the same period  Finally, for both objectives, we conducted interviews with a variety of DOD, Service-level, and nonfederal officials  We spoke with DOD officials from the Office of the Assistant Secretary of Defense–Offices of Manpower and Reserve Affairs, Military Community and Family Policy, Military Family Readiness Policy, and Special Needs  We also spoke with EFMP Managers from Air Force, Army, Marine Corps, and Navy headquarters  We also met with officials from selected national military family advocacy organizations including the National Military Family Association; the Military Family Advisory Network; and the Military Officers Association of America to discuss the EFMP  We conducted this performance audit from February 2017 to May 2018 in accordance with generally accepted government auditing standards  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  Each Service has an Exceptional Family Member Program (EFMP) that provides support to military families with special needs  The tables below present the following information on selected EFMP and family support categories for each Service’s program at continental United States (CONUS) and outside the continental United States (OCONUS) installations in fiscal year 2016: City, state or country; Number of exceptional family members; Number of family support providers (by Full-Time Equivalent); Number of family support provider vacancies; Number of services plans; Number of indirect contacts; and Number of direct contacts  The information below is listed sequentially in alphabetical order by Service  We held small group discussions with Exceptional Family Member Program (EFMP) participants at the seven military installations we visited  Family members and caregivers who attended each session reported they had children or spouses with EFMP-eligible conditions  The discussion group participants were self-selected; and their comments are not intended to represent all EFMP -enrolled family members or caregivers in fiscal year 2016  In addition, other EFMP -enrolled family members and caregivers may have had different experiences with the program during the same period  There were a total of 38 participants representing all the Services  The following issues were discussed by one or more participants during the small group discussions at the installations we visited  The issues that emerged relate to the current and future overall effectiveness of the EFMP  Overall Satisfaction with EFMP (Discussed by 30 of 38 participants): Measure of participants’ approval of the family support services offered and experience with the EFMP  Many participants expressed overall satisfaction with the EFMP  Several participants expressed dissatisfaction with the EFMP  A participant expressed dissatisfaction with the lack of consistency in the provision of family support services (i e , special education advocacy) across installations  School Liaison Officers (Discussed by 20 of 38 participants): Serve as the primary point of contact for school-related matters as well as assist military families with school issues  Several participants noted that they received no response to their request for assistance from their School Liaison Officer or they only received general information  Several participants said School Liaison Officers were not helpful  Some participants found School Liaison Officers were helpful  Some participants were unaware of School Liaison Officers being available at their installation and the service(s) they provide  A few participants said School Liaison Officers did not follow up on requests for information  A participant noted there seems to be a disconnect between family support services provided through the EFMP and services provided by School Liaison Officers  Family Support Personnel (Discussed by 12 of 38 participants): Provide information and referral to military families with special needs  Some participants at one installation noted that the EFMP was understaffed  Some participants at one installation noted high turnover of family support personnel  Some participants noted family support personnel did not provide support for their family with special needs  Stigma (Discussed by 12 of 38 participants): A perception that participating in the EFMP may limit a soldier’s assignment opportunities and/or compromise career advancement  Several participants believe there is still stigma associated with participating in the EFMP  Some participants said participating in the EFMP has not affected career advancement  Assignment Coordination (Discussed by 10 of 38 participants): The assignment of military personnel in a manner consistent with the needs of armed forces that considers locations where care and support for family members with special needs are available  Some participants found the assignment coordination process challenging  Some participants described limitations with the assignment coordination process  A few participants noted there is a lack of information among families with special needs regarding how to express the need for stabilization and /or continuity of care  A few participants cited the challenges of assignment coordination as contributing to their decision to retire  One participant commented that the opinion of a medical professional was not reflected in the assignment coordination process  Special Education Services (Discussed by 10 of 38 participants): The provision of staff capable of assisting families with special needs with special education and disability law advice and/or assistance and attendance at individualized education program (IEP) meetings where appropriate  Several participants who had a family support provider assist them with preparing for or attending a school-based meeting, including IEP meetings, spoke positively of their experience(s)  Some participants at one installation agreed that assistance from family support providers during meetings with school officials regarding special education services is helpful  A few participants who were unable to get assistance with special education services from the EFMP sought the services of private attorneys at their own expense  Family Support Services (Discussed by 9 of 38 participants): The non-clinical case management delivery of information and referral for families with special needs, including the development and maintenance of a services plan  Some participants found that family support providers were helpful  Some participants could not identify needed resources or were unaware of the resources or services available to them  One participant noted that the family support provider had minimal contact  One participant said navigating the system can be challenging  Surveys (Discussed by 8 of 38 participants): The process of collecting data from a respondent using a structured instrument and survey method to ensure the accurate collection of data  Several participants noted that they had not or rarely had the opportunity to evaluate the family support services provided through the EFMP  One participant noted that comment cards used by each service are not effective for evaluating the EFMP  Warm hand-off (Discussed by 6 of 38 participants): Assistance to identify needed supports or services and facilitating the initial contact or meeting with the next program  Many participants at one installation agreed that the warm hand-off process worked well for them  Several participants said they found the warm hand-off process helpful when moving from one installation to the next  Outreach (Discussed by 5 of 38 participants): Developing partnerships with military and civilian agencies and offices (local, state, and national), improving program awareness, providing information updates to families, and hosting and participating in EFMP family events  Some participants found it difficult to obtain information regarding the types of family support services that are available  A few participants noted that communications regarding the EFMP were not targeted to address their needs  A few participants noted communications regarding the EFMP are untimely, (e g , newsletters not issued periodically)  Joint Base Family Support Services (Discussed by 1 of 38 participants): Family support services provided by the lead Service of the Joint Base that is different from that of the servicemember enrolled in the EFMP  One participant said that using family support services on joint bases may pose a challenge as each Service has different rules and procedures and as a result provides different types of family support services  In addition to the contact named above, Bill MacBlane (Assistant Director), Brian Egger (Analyst-in-Charge), Patricia Donahue, Holly Dye, Robin Marion, James Rebbe, Shelia Thorpe, and Walter Vance made significant contributions to this report  Also contributing to this report were Lucas Alvarez, Bonnie Anderson, Connor Kincaid, Brian Lepore, Daniel Meyer, and Mimi Nguyen 


Report 2: DOJ and its components, as well as the judiciary, play important roles in requesting and collecting restitution  DOJ and select components: Prosecutors in DOJ’s Criminal Division and the Criminal Divisions of the 94 USAOs are responsible for overseeing criminal matters, including identifying and notifying victims, determining their losses as part of a case investigation, prosecuting cases and negotiating the terms of plea agreements, of which restitution may be a part  Within DOJ’s Criminal Division, the Money Laundering and Asset Recovery Section manages DOJ’s Asset Forfeiture Program  As previously stated, FLUs within each USAO undertake activities to collect restitution from offenders in their district  Additionally, all USAOs have asset forfeiture staff responsible for forfeiting property seized by law enforcement agencies because the property was used in criminal activities or purchased with the proceeds of criminal activities  According to EOUSA guidance, coordination between the FLU and Asset Forfeiture units is highly encouraged to use forfeited assets as a means to collect on unpaid restitution debts  DOJ requires each USAO to have its own policies and procedures related to debt collection efforts but allows them discretion in developing these policies and procedures to ensure that they are appropriate for local conditions  DOJ also requires USAOs to have policies and procedures to make early, effective, and coordinated asset investigations and recovery a routine part of every case involving victims but allows USAOs to specify these policies and procedures  DOJ’s EOUSA provides USAOs with management assistance, guidance, training, and administrative support  Among other activities, EOUSA provides management assistance to USAOs by administering internal evaluations for each USAO, which are intended to provide on-site management support for that office  Further, EOUSA provides guidance to enhance offices’ efforts to request and collect restitution  Judiciary: Within the judiciary, the 94 federal district courts order restitution, receipt restitution payments, and disburse restitution to victims  Within the federal district where the offender was convicted, a probation officer prepares the presentence investigation report (PSR) for the court, which includes information on the victim’s losses and an offender’s financial information  Probation officers may obtain this information from DOJ, which has the statutory responsibility for the enforcement and collection of criminal debt  The court uses the PSR, among other things, to determine whether to order restitution  If an offender is released to the community by the court and placed on supervision, probation officers are responsible for ensuring the offender abides by the terms of release, including paying any restitution owed to victims  The Clerk of each District Court is responsible for the receipt of restitution from offenders and for disbursing payments to victims  The Judicial Conference is the national policy-making body for the federal courts  The Conference operates through a network of committees created to address and advise courts on a wide variety of subjects such as information technology, personnel, probation and pretrial services, space and facilities, security, judicial salaries and benefits, budget, defender services, court administration, and rules of practice and procedure  The Judicial Conference has taken policy positions on restitution-related issues and has supported legislative proposals to improve the restitution process  AOUSC is the agency within the judiciary that provides a broad range of legislative, legal, financial, technology, management, administrative, and program support services to federal courts  AOUSC is responsible for carrying out Judicial Conference policies and a primary responsibility of AOUSC is to provide staff support and counsel to the Judicial Conference and its committees  USSC is an independent agency within the judiciary which, among other activities, establishes and promulgates detailed sentencing guidelines that judges are to consider in sentencing offenders convicted of federal crimes, including guidelines on when and how to order restitution  Additionally, each district court is required to submit to USSC a report of each offender’s sentence that includes, among other information, details on the offenses for which the offender was convicted; the sentence imposed on the offender; and if the judge departed from the sentencing guidelines, information on reasons why  USSC maintains a database containing sentencing data on federal offenders convicted of felonies or serious misdemeanors, analyzes it and publishes these data on an annual basis  USSC is also statutorily required to annually report to Congress its analysis of sentencing-related documents, including an accounting of districts USSC believes have not submitted appropriate information to the commission, among other things  During the course of a federal criminal investigation, federal prosecutors identify and notify victims, as well as determine their losses in conjunction with the federal agents investigating the case  If a defendant pleads guilty or is found guilty at trial, the prosecutor has the burden of proving the victims’ losses in court  To facilitate this, a Victim-Witness coordinator within the USAO responsible for the case provides victims the opportunity to explain their losses in detail, usually through a Victim Impact Statement  This information is then to be provided to a federal probation officer who uses it to begin a PSR  To develop the PSR, probation officers use information provided by the USAO and may contact victims and verify the loss amounts  Additionally, probation officers will investigate an offender’s economic circumstances— such as if the offender has a job, any assets or any dependents  If a judge determines that restitution is to be ordered, the judge must order restitution for the full amount of a victim’s losses for offenses without consideration of the economic circumstances of the defendant  Judges may decline to order restitution in certain instances, for example, where restitution is discretionary, or in certain cases where the number of identifiable victims makes restitution impracticable or the complexity of calculating restitution would unduly prolong the sentencing process  If the court does not order restitution, or orders only partial restitution, the judge must provide the reason, and judges usually do so in a written Statement of Reasons document  Figure 1 provides an overview of the federal restitution process  Upon imposition of a restitution debt by the court, FLU staff use two mechanisms to determine the collectability of the debt and what collection actions to take  First, FLU staff classify the debt into one of four categories to determine the extent to which the FLU will pursue enforcement actions to collect upon the debt  FLUs classify debts from a Priority Code 1 debt (indicating that FLUs will make collection of this debt the highest priority) to a Priority Code 4 debt (indicating that FLUs will make collection of this debt the lowest priority)  Second, FLUs may suspend collection action on criminal debts, regardless of their categorization, under certain circumstances if they determine the debts are uncollectible  FLU staff may also determine that debts are permanently uncollectible and categorize them as Priority Code 4 debts  If a debtor does not provide payment, FLU staff then use various enforcement actions to collect the restitution debt  These can include, among other actions, filing liens against an offender’s property, coordinating with asset forfeiture staff to use forfeited assets to pay the restitution debt, and garnishing wages an offender may earn  Victims can be compensated for losses with the proceeds of forfeited assets through DOJ’s Asset Forfeiture Program and in accordance with law and regulation  Federal regulations provide that the proceeds from forfeited assets are first used to cover program costs associated with forfeiture-related activities and next to pay valid owners, lien-holders, and federal financial regulatory agencies  Forfeited assets can then be distributed to other victims of crime as compensation for their losses if their loss is a direct result of the commission of the offense underlying forfeiture or a related offense  Any remaining funds from the forfeited asset may be placed into official use, distributed to foreign governments, state or local law enforcement agencies as part of the equitable sharing program to enhance cooperation with federal investigations  When victims are eligible for compensation using forfeited assets, DOJ employs two processes: restoration and remission  The restoration process involves the USAO staff requesting funds on behalf of a victim when there is both an order of forfeiture and an order of restitution  Under the restoration process, USAO staff request DOJ’s Money Laundering and Asset Recovery Section to use the forfeited asset to pay a restitution debt  If DOJ approves the request for restoration, the funds from the forfeited property are then transferred to the Clerk of the Court who disburses this money to the victim  The remission process requires a victim of a crime to directly petition DOJ to receive funds from the forfeited property  According to officials in DOJ’s Criminal Division, the courts may not order restitution on behalf of victims who suffered a specific actual loss as a direct result of a crime for a variety of reasons, and therefore the remission process serves as a complement to the restoration process to ensure victims are made whole  For example, these officials stated that, among other reasons, the courts may not order restitution if a defendant dies prior to sentencing or if the case is one in which a court is not required to, and does not, order restitution, but the victim has suffered eligible losses  EOUSA and USAO officials in all six of the offices with whom we spoke told us that prosecutors document requests for restitution in their case files and that their offices employ other internal controls, such as the use of templates and forms, throughout the prosecution process to ensure that prosecutors request restitution as appropriate  EOUSA officials told us that although the agency does not track this information, they believed all USAOs generally document requests for restitution in their offices’ case files  Further, USAO officials in all six offices told us that prosecutors document requests for the court to order restitution in their case files by including this information in a written memorandum  To support prosecutors in documenting this information, all six offices we selected provide prosecutors with a prosecution memorandum template  Of the six templates we reviewed, four explicitly include a section for prosecutors to indicate whether victims have been identified and the extent of any victim losses  In addition to these templates, four of six USAOs we selected had forms that prosecutors could use to identify whether cases have victims and their need for restitution when drafting criminal charging documents  Moreover, officials from two of the six USAOs told us their offices use this form as an internal control to ensure prosecutors have identified all victims and considered their need for restitution, if applicable  All six offices we selected also provided prosecutors templates for drafting plea agreements, and templates we reviewed from all six USAOs included language requesting the offender pay restitution, if applicable  However, prosecutors are not required to use plea agreement templates, nor are they required to request restitution as part of a plea agreement  USAO officials from one office stated that including this language in the plea agreement template served to remind prosecutors of their requirement to consider requesting restitution as stated in the U S  Attorney’s Manual  Select USAO officials also described various forms of management oversight to ensure prosecutors request restitution as appropriate  Specifically, four USAOs we selected require supervisory review of the form that prosecutors fill out when drafting criminal charging documents, which includes information on victims  Additionally, officials in all six USAOs told us that they require supervisory review of plea agreements for every case  For example, officials from two USAOs told us their office requires the Criminal Chief, the supervisor of all criminal cases, to approve documents in the plea agreement, which may include requests for restitution  Federal courts sent information on sentencing decisions to USSC and USSC had information on restitution decisions for 95 percent of all offenders from fiscal years 2014 through 2016  According to our analysis of USSC data, 214,578 federal offenders were sentenced from fiscal years 2014 through 2016 and restitution was ordered for 33,158 of those offenders, or 15 percent  Collectively, courts ordered these offenders to pay $33 9 billion in restitution during this period  Courts did not order restitution for the remaining 181,420 offenders, or 85 percent  Table 1 shows the number of federal offenders sentenced and ordered to pay restitution for fiscal years 2014 through 2016, as well as the total amount of restitution ordered by the courts  The majority of federal offenders were sentenced for immigration or drug- related offenses, and USAO officials in all six offices we selected told us that these types of offenses do not typically have victims with actual losses  For example, from fiscal years 2014 through 2016, USSC data showed that 131,088 offenders, 61 percent of offenders sentenced, were sentenced for immigration or drug-related offenses and courts ordered 999 (or less than 1 percent) of these offenders to pay restitution  USSC data show that courts ordered restitution more often for offenders sentenced for other offenses, such as fraud  For example, courts sentenced 21,551 offenders for fraud offenses from fiscal years 2014 through 2016, and courts ordered restitution for 15,902 of these offenders, or 74 percent  Table 2 shows the number of offenders sentenced and the number ordered to pay restitution by offenses for which restitution was most often and least often ordered by courts from fiscal years 2014 through 2016  The percentage of federal offenders ordered to pay restitution varied across federal court districts; from 2 percent of offenders in one district to 42 percent in another district  USAO officials we interviewed stated that some of this variation may be due to the types of offenses prosecuted within different districts  For example, officials from one USAO stated that their office, which had a high volume of immigration–related offenders, had few cases in which restitution was applicable  Our analysis of USSC data showed that from fiscal year 2014 through fiscal year 2016 and across all districts, districts with a higher than average rate of immigration-related offenders had lower than average rates of restitution ordered  Conversely, districts with above-average rates of offenders convicted of financial offenses such as fraud, embezzlement, money laundering, tax offenses, counterfeiting or bribery had higher than average rates of restitution ordered, as shown in table 3  Judges indicated on documents sent to USSC that restitution was not applicable and thus did not order it for most offenders sentenced from fiscal years 2014 through 2016—167,230 offenders—or 78 percent of all offenders sentenced during this time period  Our analysis of sentencing information for the remaining offenders found that courts ordered restitution at a higher rate as compared to all offenders  Specifically, after excluding offenders for whom restitution was not applicable and were not ordered to pay it, we found that courts ordered restitution for 70 percent of the remaining 47,348 offenders  EOUSA and USAO officials told us that in cases where there are identifiable victims, restitution may not be ordered for other reasons  EOUSA officials told us that restitution may not be ordered for several reasons, such as when victims provide no proof of their losses or when victims recover compensation through other means, such as through civil proceedings  Further, officials from one USAO told us that victims must provide documentation of their losses for restitution and, if victims are not able to provide this documentation, courts may decline to order restitution  Also, in certain cases, courts are not required to order restitution—such as when there is no identifiable victim or, on the other hand, when the number of identifiable victims is so large as to make restitution impractical, among other reasons  Additionally, the court might not order, or order only partial restitution for other reasons, such as when the value of property the defendant returned to the victim was deducted from the restitution award or because the victim received compensation from insurance  If a court does not order restitution, or orders partial restitution, it is required to provide the reason for its decision and to provide that reason to USSC, but our analysis showed USSC did not always have these data  Specifically, from fiscal years 2014 through 2016, we found that restitution was not ordered—and no reason was documented in USSC data for that decision—for 9,848 offenders (5 percent of the 214,578 offenders sentenced during this time period)  Information on offenders’ sentences, including restitution, assists USSC in its continuous reexamination of its guidelines and policy statements and ensures that various sentencing practices are achieving their stated purposes  Further, Standards for Internal Control in the Federal Government state that management should evaluate issues identified through monitoring activities or reported by personnel to determine whether any of the issues rise to the level of an internal control deficiency  In response to our questions about the missing information on reasons why restitution was not ordered, AOUSC and USSC officials stated that they were unaware of the missing information or why it was missing  Judiciary officials stated that because various entities within the judiciary participate in the process of collecting and recording information on reasons restitution was not ordered, they did not know which entities could take action to improve USSC data  However, as previously discussed, if the court does not order restitution, or orders only partial restitution, the judge must provide the reason, and judges usually do so in a written Statement of Reasons form  The Judicial Conference, along with USSC, has developed guidance to help judges fill out the Statement of Reasons form and AOUSC supports the Judicial Conference in carrying out its policies  Further, courts must provide USSC the written Statement of Reasons form for sentences imposed  USSC is also responsible for collecting, analyzing, and distributing information on federal sentences provided by each district court, including information related to orders for restitution  However, judicial officials, including from the entities listed above, agreed that further studying the missing data may inform the judiciary of the cause of the missing data, as well as any efforts needed to improve USSC information  Courts are required to provide reasons for not ordering restitution and to provide this information to USSC so that the agency can analyze and report on sentencing data  Determining why USSC data are incomplete could help inform the judiciary whether the issue rises to the level of an internal control deficiency and whether additional action can be taken to improve the transparency of sentencing decisions  Doing so could help the judiciary ensure reasons for not ordering restitution are provided consistently in all cases and potentially improve data provided to USSC, in turn supporting its mission to promote transparency in sentencing decisions  Our analysis of DOJ data showed that DOJ collected $2 95 billion in restitution debt from fiscal years 2014 through 2016, half of which was collected on debts imposed during this period  The extent of collections across the 94 USAOs ranged from a high of $848 million in one USAO to a low of $1 2 million in another USAO  The median amount collected for USAOs was $10 7 million  DOJ was more successful at collecting restitution on newer debts—debts imposed from fiscal years 2014 through 2016  Of the $2 95 billion in restitution debt collected, about half was collected from new debts imposed by courts during this time period  Specifically, DOJ collected $1 5 billion (4 percent), of the $34 billion ordered from fiscal years 2014 through 2016  The remaining half of the debt collected during this time frame was collected from debts imposed between fiscal year 1988 and fiscal year 2014  New debts—imposed in fiscal years 2014 through 2016—were also more likely to be fully paid during this time period compared to all debts  Specifically, from fiscal years 2014 through 2016, DOJ collected the full amount of restitution on 4,003 of the 24,950 debts imposed during this time, 16 percent  However, across all debts, including debts imposed prior to fiscal year 2014, DOJ collected the full amount of restitution ordered on only 5 percent of debts  Across all restitution debts, DOJ collected at least some of the debt for one-third of debts and did not collect any restitution on the remaining two-thirds  More than 60 percent of the restitution DOJ collected in fiscal years 2014 through 2016 was owed to non-federal victims ($1 8 billion), including individuals, corporations and state and local governments  An additional 37 percent of restitution was collected on behalf of federal agencies that were victims of crimes  One percent of restitution collected was community restitution, which is restitution collected for drug offenses that otherwise have no victims and which is disbursed to state victim assistance agencies and state agencies dedicated to the reduction of substance abuse, as shown in table 4  AOUSC officials noted that some collected restitution is not disbursed to non-federal victims due to a lack of accurate contact information for these victims  Specifically, according to AOUSC, as of June 2017, courts had more than $132 million in restitution due to 113,260 victims that could not be disbursed because of a lack of accurate contact information for these victims  DOJ is required to provide courts with victim contact information, and victims are to notify DOJ if their contact information changes  However, AOUSC and USAO officials told us that this notification by victims may not always occur  For example, officials in one USAO told us that due to the length of court proceedings, victims may move without notifying the court prior to the disbursement of restitution and, as a result, the court is unable to disburse restitution to those victims  According to our analysis of DOJ data, at the end of fiscal year 2016, $110 billion in restitution was outstanding and USAOs had identified $100 billion of that debt as uncollectible, as shown in figure 2  USAOs may identify debts as uncollectible and suspend collection actions on a debt for a variety of reasons, including that the offender has no, or only a nominal, ability to pay the debt  Probation officials, EOUSA officials, and officials from five of six USAOs we interviewed stated that most outstanding restitution debt is identified as uncollectible and collection action is suspended because many offenders have little ability to pay the debt—a conclusion supported by USSC data  For example, according to USSC data, 95 percent of offenders ordered to pay restitution from fiscal years 2014 through 2016 received a waiver from paying a court-ordered fine, indicating their inability to pay  While courts are allowed to take an offender’s economic circumstances into consideration when issuing fines, they generally may not do so when ordering restitution  As a result, EOUSA and federal probation officials with whom we spoke stated that offenders ordered to pay restitution often do not have an ability to do so and therefore a large amount of restitution orders is uncollectible  Through various guidance documents, DOJ has identified and recommended numerous practices for DOJ prosecutors and FLU staff to use throughout the restitution process to help ensure full and timely restitution for victims  USAO officials in all six offices with whom we spoke stated that, based on their experience, these practices were generally effective  Specifically, DOJ and EOUSA officials identified practices for prosecutors and FLU staff to use when requesting restitution, facilitating court orders for restitution, and collecting restitution and documented these practices in several guidance manuals  Officials we interviewed from all six USAOs stated they were generally satisfied with the guidance from EOUSA and that they thought most of DOJ’s recommended practices were effective when requesting restitution, facilitating court orders for restitution, and collecting restitution  Requesting restitution  Officials we interviewed from three USAOs identified coordination between prosecutors and case investigators prior to sentencing to identify victims and their losses as an important practice for requesting restitution  USAO officials from three of the six offices stated that gathering detailed information on an offender’s financial resources, which include assets that could be forfeited and used to pay a restitution debt, was a very effective practice related to requesting restitution  Facilitating court orders of restitution  Although the courts, and not prosecutors, are responsible for ordering restitution, DOJ guidance identifies several practices that prosecutors can use to facilitate orders of restitution that may increase the likelihood of full and timely restitution for victims  Officials from three of six USAOs stated that the most effective practice related to ordering restitution was ensuring courts ordered restitution as due and payable immediately  Specifically, when offenders cannot pay restitution in an immediate lump-sum payment, the courts must specify a payment schedule through which the offender will pay restitution based on the offender’s ability to pay  In these cases, USAO officials stated that it is effective for prosecutors to ensure the restitution order specifies that restitution is due and payable immediately  According to an EOUSA official, this permits the agency to immediately pursue all collection remedies allowed by law whenever the debtor has or subsequently obtains the ability to pay  Collecting restitution  Officials from all six USAOs stated that using the Treasury Offset Program (TOP), a program that allows for the reduction or withholding of a debtor’s federal benefits, such as a tax refund, was one of the most effective practices for collecting restitution  Specifically, officials in one USAO told us that TOP requires minimal effort for FLU staff and can result in a high amount of collections  As an example, officials from two USAOs told us their respective offices each recovered more than $500,000 dollars in restitution debt in fiscal year 2016 through TOP  Officials from three of the six offices also identified using wage garnishment as an effective practice for collecting restitution  Across all parts of the restitution process, USAO officials we spoke with also consistently identified DOJ recommended practices related to internal and external communication and collaboration as effective for improving the restitution process  Specifically, the officials identified collaboration between various units in the USAO as an effective practice to ensuring restitution for victims  For example, USAO officials in two of the six offices highlighted coordination between Victim-Witness coordinators and prosecutors to help identify victims and quantify their losses as effective to assisting in the request for restitution  Additionally, USAO officials in all six offices stated that strong coordination between FLU personnel and criminal prosecutors to identify an offender’s financial resources and available assets was an effective practice to help ensure FLU staff could collect restitution using those resources or assets  USAO officials from five of six offices identified external communication between FLU and the federal probation office as an effective practice  Specifically, officials from these USAOs stated that FLUs coordinating with probation officers during the offender’s supervision period to enforce restitution terms was an effective practice for collecting restitution  Additionally, according to EOUSA guidance, FLU staff can use outreach and training with other partners such as the probation office to facilitate information sharing on restitution collection issues and officials from five of six USAOs told us that FLUs conducting training and outreach is a very effective practice  In addition, probation officials we interviewed in each of the six federal judicial districts we selected stated that ongoing communication between USAO staff and probation officers is effective to ensuring victims are identified and receive full and timely restitution  Probation officials from one court district emphasized the importance of a good working relationship with the USAO, stating that the probation office and USAO are better able to ensure victims and their losses are accurately identified and defendants’ ability to pay is adequately addressed when working collaboratively  A probation official from another office said that probation officers regularly coordinated with the USAO’s FLU, and this coordination was particularly important on cases involving complex financial crimes, where the offender has a complicated financial portfolio  Further, probation officials from five of six probation offices also stated that attending training conducted by the FLU is a very effective practice  EOUSA and selected USAO officials told us that while these practices may be useful in some circumstances, they may not be effective or applicable in all cases or in all districts  Specifically, practices DOJ recommends may be effective when offenders have the ability to pay restitution but are simply unwilling to do so; however, USAO officials in five of six offices stated that these practices cannot mitigate the fact that many offenders lack the ability to pay restitution because they lack assets and income  Additionally, while EOUSA guidance recommends that FLU staff contact co-defendants or victims for information on the whereabouts or assets of offenders who owe restitution, officials from three USAOs told us this was not effective  According to one official, although co- defendants are sometimes eager to share information, the information is usually unreliable  USAO officials also identified some recommended practices as not applicable to their district  For example, EOUSA recommends that FLU units request Asset Investigation assistance from EOUSA for complex cases involving large amounts of valuable assets  However, USAO officials in a small, rural district with whom we spoke stated that the types of cases their office prosecutes tend not to be the type of financial cases that warranted use of this resource  DOJ has identified improving debt collection—including court-ordered restitution—as a major management initiative in its 2014-2018 Strategic Plan  However, it does not have any measures or goals in place to assess its performance in meeting this initiative or meet requirements that it evaluate its performance in seeking and recovering restitution as required by statute  In 2001, we recommended that DOJ adequately measure its criminal debt collection performance against established goals to help improve collections and stem the growth in uncollected criminal debt  DOJ concurred with this recommendation, and as of fiscal year 2003, annually assessed each district based on established collection goals for that district  However, as of September 2017, DOJ no longer evaluates each district based on established goals  EOUSA officials stated that DOJ no longer uses these performance goals and that the agency did not maintain records for when or why it stopped  EOUSA officials stated that while the agency does not have any measures or goals to assess USAOs’ performance in improving debt collection, including the collection of federal restitution, they are working with DOJ’s Justice Management Division to develop a suite of analytical tools to monitor the collection of debt across all offices  According to DOJ, some of these analytical tools have been implemented and additional tools will be implemented by March 2018  EOUSA officials stated that these tools will help the agency determine which cases are most likely to result in significant collections and the types and timing of enforcement actions that generate maximum debt recovery results  EOUSA officials further stated the analytical tools will allow the agency to compare districts’ efforts based on a variety of factors (e g , caseload, staff size, and enforcement actions)  These analytical tools may provide EOUSA with valuable insight into the present condition of the collection of restitution across USAOs, but they will not provide DOJ with a baseline performance standard that could be used to indicate if USAOs’ efforts to collect restitution debts are having a measurable impact in meeting DOJ’s objective of improving debt collection  Additionally, EOUSA conducts evaluations of each USAO every 4 years, which include a review of FLU operations, but EOUSA officials stated that these reviews do not include oversight of the collection of restitution  Among other aspects of USAO operations, these internal evaluations review the extent to which each FLU is complying with statutory and DOJ requirements related to debt collection, has sufficient program resources, and adequately manages its caseload  However, DOJ and EOUSA officials told us that it did not plan to use these internal evaluations to meet the Justice for All Reauthorization Act of 2016 requirement to evaluate each USAO on its performance in seeking and recovering restitution for victims  Specifically, the officials stated that these internal evaluations are not an appropriate mechanism to meet the law’s requirements because the internal evaluations do not specifically review the seeking and recovery of restitution for victims  According to DOJ officials responsible for the internal evaluation program, these evaluations are largely intended to provide onsite management assistance and analysis of how the USAO allocates its administrative and legal personnel resources rather than the office’s efficacy in collecting restitution  Consistent with requirements outlined in the Government Performance and Results Act Modernization Act of 2010 (GPRAMA), performance measurement is the ongoing monitoring and reporting of program accomplishments—particularly towards pre-established, objective and quantifiable goals—and agencies are to establish performance measures to assess progress towards those goals  While GPRAMA is applicable to the department or agency level, performance measures and goals are important management tools at all levels of an agency, including the program, project, or activity level  Agencies can use performance measurement to make various types of management decisions to improve programs and results, such as developing strategies and allocating resources, including identifying problems and taking corrective action when appropriate  Further, the Justice for All Reauthorization Act of 2016 requires DOJ to evaluate each USAO in its performance in recovering restitution for victims  DOJ and EOUSA officials told us that DOJ does not require USAOs to establish performance measures or goals to assess their progress in improving the collection of restitution  DOJ and EOUSA officials also told us that each USAO could develop performance goals but that they were unaware of the extent to which USAOs did so, and further, they do not track the extent to which USAOs met performance goals  Additionally, these officials stated that because each USAO faces different constraints in its ability to collect restitution, establishing a uniform and consistent performance measure and goal would be challenging  EOUSA officials noted that some USAOs may have more resources, such as more FLU staff or specialized asset investigators, available to pursue collections as compared to other offices and therefore offices with fewer resources could have difficulty meeting a performance goal  Further, EOUSA and USAO officials stated that the extent to which DOJ can collect on a debt is heavily influenced by factors outside of the agency’s control, such as an offender’s ability to pay  USAOs could use information provided by performance measures and goals—such as an office’s ability to meet a performance goal—to make managerial decisions to help address these constraints, such as by increasing the allocation of staff resources  Further, to avoid comparing USAOs to a nationally set performance goal that does not account for specific constraints faced by each office, DOJ could—as it did in fiscal year 2003—require each USAO to establish its own objective, quantitative collection goals based on historical, district-specific collection statistics  Finally, as previously discussed, each USAO already accounts for external factors that affect the collectability of a debt, such as an offender’s ability to pay, by suspending collection action on debts it identifies as uncollectible  Therefore, any performance measures and goals developed could be based solely on debts that the USAO already has determined to be collectible  Stakeholders we interviewed—including officials from one USAO, probation officials in two districts, and officials with DOJ’s Office of Crime Victims—noted that receiving restitution is both emotionally and financially important to victims  Specifically, officials from one USAO and one probation office noted that while many victims may never receive the full amount of restitution ordered, receiving even a minimal amount of restitution is a symbolic victory and that it is important for victims to know the government is making efforts to collect restitution on their behalf  The legislative history of the MVRA echoes these sentiments, providing that even nominal restitution payments have benefits for the victim of crime, and that orders of restitution are largely worthless without enforcement  Yet, according to our analysis, $10 billion of restitution debt DOJ identified as collectible remained outstanding at the end of fiscal year 2016  Further, the extent to which USAOs collected restitution varied widely— from a high of one USAO district collecting nearly 350 percent of all collectible debt in fiscal years 2014 through 2016 to a low of one district collecting less than one percent of collectible debt in the same period  Without performance measures, including the establishment of goals, DOJ cannot assess if this variation is due to factors outside the control of USAOs or due to management deficiencies that require corrective action  Developing performance measures and goals for each USAO related to the collection of restitution would allow DOJ to assess its progress in achieving its major management initiative in improving debt collection— including debts owed to victims as court-ordered restitution  Doing so would also better position DOJ to meet the requirements of the Justice for All Reauthorization Act of 2016 to evaluate offices in their performance in recovering restitution on behalf of victims and to use performance information to improve the practices of offices as needed  Although asset forfeiture and restitution are separate parts of a criminal sentence, DOJ guidance states that using forfeited assets to benefit victims is a way that DOJ can help ensure eligible victims of crime are compensated for their losses  Further, DOJ regulations and policy require that eligible victims receive compensation from forfeited assets before certain other uses, such as official use or equitable sharing  However, while DOJ tracks the amount of compensation provided to victims through forfeited assets, it does not have assurances that forfeited assets are being used to compensate victims to the greatest extent possible  According to DOJ information, the agency made payments of about $595 million to eligible victims other than owners of the property from the Assets Forfeiture Fund from fiscal years 2014 through 2016, or 15 percent of $3 9 billion in paid expenditures during this period, as shown in table 5  As table 5 shows, DOJ can account for cases in which forfeited assets were used to compensate eligible victims who were not owners or lienholders  However, DOJ does not have information on the overall universe of victims who could have been eligible to receive compensation from forfeited assets  Further, it does not have insight into any reasons why funds from forfeited assets were not used for these victims  Specifically, DOJ officials stated that the department collects information on whether victims have been identified in cases associated with forfeited assets, and if restitution is anticipated in these cases, but it does not track the extent to which these victims were ultimately compensated using forfeited assets  Further, DOJ also does not collect information on reasons why victims were not compensated using funds from forfeited assets  While DOJ is required to use forfeited assets to compensate victims before using those assets for certain other purposes, the agency is unable to provide assurances that it is always doing so because it does not have information on the overall universe of victims or reasons why victims were not compensated using forfeited assets  As a result, DOJ does not have a basis to know whether the $595 million provided to victims from fiscal years 2014 through 2016 is the maximum amount of compensation the agency could have provided to victims using forfeited assets  Full use of forfeited assets for victim compensation has long been, and continues to be, a goal of DOJ  In 2005, an interagency task force—led by DOJ and including the Department of Treasury, Office of Management and Budget and AOUSC—developed a strategic plan to improve the collection of criminal debt  Among other goals included in its strategic plan, the task force stated a goal of examining how asset seizure and forfeiture procedures can be used to maximize recoveries for victims  More recently, DOJ reported in its 2014-2018 Strategic Plan that it would make every effort to recover full and fair restitution for victims using the federal forfeiture statutes to preserve and recover criminal proceeds  Specifically, DOJ stated that using federal forfeiture statutes to recover full and fair restitution for victims is one part of its strategy to protect the rights of the American people and enforce the rule of law  Finally, DOJ officials told us they considered providing compensation to victims as one goal of the Asset Forfeiture Program and EOUSA stated in guidance that asset forfeiture is the most widely available and effective tool to seize assets for restitution purposes  Standards for Internal Control in the Federal Government call on federal managers to design control activities to achieve the agency’s objectives  These controls can include using quality information to make informed decisions, evaluate the entity’s performance in achieving key objectives, and address risks  DOJ officials told us that they do not track the extent to which victims were not compensated using forfeited assets because USAO staff are not required to request that these assets be used for victim compensation  DOJ officials explained that staff are required to indicate in the agency’s forfeited asset database, the Consolidated Asset Tracking System, if victims exist in cases associated with forfeited assets and if restitution is anticipated in these cases  However, these officials stated that staff are not required to then compensate these victims using the forfeited assets or to indicate why these assets were not used for this purpose  DOJ officials told us that decisions to compensate victims using forfeited assets are best left to the judgment of the USAO staff familiar with the case, such as the prosecuting attorney or asset forfeiture staff  DOJ officials pointed to informal communication and coordination among prosecutors, the FLU, and the Asset Forfeiture unit in each USAO as a means to provide compensation to victims as appropriate  However, communication and coordination among these groups has been a challenge for USAOs, as the DOJ Inspector General found in a June 2015 review of DOJ’s debt collection program  Similarly, during our current review, EOUSA and USAO officials we spoke with identified communication and coordination as an area for improvement  EOUSA officials told us that while they thought that FLU staff and Asset Forfeiture unit staff were collaborating more frequently to use forfeited assets to collect restitution debts since the issuance of the DOJ Inspector General’s report, the extent of collaboration between these two units still varied across USAOs  Further, officials we talked to in two USAOs and one probation office noted that USAO staff could improve their use of forfeited assets for restitution payments  For example, officials in one probation office noted that it was their practice to identify forfeited assets that could be used for compensation in the PSR because they had observed that USAO staff were frequently not applying such assets to victim compensation  While DOJ may allow USAO staff to use discretion when requesting restoration or alerting victims to assets available for compensation, increasing the agency’s understanding of the extent to which assets could have been—but were not—used for victim compensation, and the reasons for those decisions, does not affect that discretion  There are legitimate reasons why victims might not be compensated using forfeited assets; for example, the assets may have other owners or lienholders that must be compensated prior to victims, or offenders may have other means by which to pay victims restitution  However, there are also instances where victims may have not received compensation through forfeited assets as a result of unintentional circumstances  For example, according to DOJ’s Asset Forfeiture Manual, forfeiture actions can proceed faster than the parallel criminal case  Consequently, assets might be equitably shared, placed into official use, or remitted to victims who file petitions long before restitution is ordered, and therefore would not be available for other victims who wait for restitution to be ordered after an offender is sentenced  To avoid this outcome, DOJ recommends that USAOs coordinate to ensure the retention of property for victim compensation  However, although DOJ officials responsible for leading DOJ’s asset forfeiture efforts highlighted the need for expedient coordination when USAO staff are considering using forfeited assets to compensate victims, they stated this may not always occur  As a result, otherwise eligible victims may not always be compensated through forfeited assets  By gathering information about the extent to which assets were used for victim compensation—including when they were not used and reasons why not—DOJ could have a better understanding of potential instances where victims could be, but are not, receiving compensation through forfeited funds and could take steps to address them accordingly  Options for gathering such information could include doing a one-time retrospective study of forfeited assets with victims or anticipated restitution to determine the extent that assets were used for victim compensation, or creating a tracking mechanism through its forfeited assets database, or another system  Gathering information on the extent to which forfeited assets were used for victim compensation, including when not used and reasons why not, could position DOJ to take action to increase the use of these assets for victim compensation if warranted  These actions could include providing funds for increased asset forfeiture staff in USAOs, providing additional training or changing policies or procedures for using forfeited assets to compensate victims  Fully and systematically understanding the extent to which issues, such as a lack of coordination within USAOs, result in victims not being compensated using forfeited assets would give DOJ a basis upon which to develop improvements to the Asset Forfeiture Program  Such information would also provide DOJ and staff at all USAOs with information to evaluate its performance in achieving one of the goals of the Asset Forfeiture Program and taking action to meet the agency goal of protecting the rights of the American people—including the right to full and fair restitution for victims  Restitution serves the criminal justice goal of holding offenders accountable and, to the extent possible, restoring victims of federal crimes to their prior position had the crime not occurred  Many victims are unlikely to receive any meaningful portion of court-ordered restitution owed to them because of offenders’ inability to pay these debts  However, the fact that restitution is difficult to collect does not negate the important responsibilities of the judiciary and DOJ to properly manage and oversee all aspects of the restitution process  By law, courts are to state why they did not order restitution and provide that information to USSC  While this information was collected and recorded in USSC data for most offenders, we found that this information was missing for thousands of offenders  It is important for the judiciary to ensure that this information is consistently collected and recorded to assist USSC in its continuous re-examination of its guidelines and policy statements and ensure that various sentencing practices are achieving their stated purposes  The judiciary could support USSC in this endeavor by determining why this information is missing  Results from this study could help inform the judiciary whether this issue rises to the level of an internal control deficiency and whether additional action can be taken to improve the transparency of sentencing decisions  While DOJ has delegated collection activities for restitution to USAOs, it could provide better oversight to ensure it is making reasonable efforts to collect restitution and meeting its responsibility to victims  USAOs have identified a significant portion of outstanding restitution debt as uncollectible, but they have also identified $10 billion of outstanding restitution debt that could be collected  Developing and implementing performance measures and goals for each USAO would allow DOJ to gauge USAOs’ success in collecting this restitution and, by extension, the department’s success in achieving its major management initiative to increase the collection of debt  Further, DOJ could use performance information to improve the practices of offices in seeking and recovering restitution, consistent with a requirement in the Justice for All Reauthorization Act of 2016  Finally, DOJ could gain greater visibility into the use of forfeited assets to compensate victims by gathering information on cases in which victims have been identified and restitution is anticipated but forfeited assets are not used, and any reasons why  Doing so would better position DOJ to take action to increase the use of forfeited assets to compensate eligible victims if warranted and to provide assurance that it is maximizing the use of asset forfeiture in satisfying restitution debts, one of the agency’s most effective mechanisms for satisfying restitution  We are making three recommendations, including one to the judiciary and two to DOJ  Specifically: Judiciary officials, including AOUSC, USSC, and the Judicial Conference, should determine why USSC data on the reasons restitution was not ordered are incomplete  Additionally, if warranted based on this information, judiciary officials should take action to ensure USSC data records include all required information for orders of restitution  (Recommendation 1) To improve oversight of the collection of restitution we recommend that the Attorney General: Develop and implement performance measures and goals for each USAO related to the collection of restitution, and measure progress towards meeting those goals  (Recommendation 2) In cases where forfeited assets were not used to compensate victims, gather information on reasons why forfeited assets were not used for victims  If warranted based on this information, take action to increase the use of forfeited assets to compensate eligible victims  (Recommendation 3) We provided a draft of this report for review and comment to DOJ, the Judicial Conference of the United States, AOUSC, USSC, and the Federal Judicial Center  DOJ concurred with our recommendations and provided technical comments, which we incorporated as appropriate  AOUSC provided written comments, which are reproduced in appendix III  In its written comments, AOUSC noted that it would work with the USSC to address our recommendation  We are sending copies of this report to the appropriate congressional committees and the Attorney General, the Judicial Conference of the United States, the Directors of AOUSC, the Staff Director of USSC, the Federal Judicial Center and other interested parties  In addition, the report is available at no charge on the GAO website at http://www gao gov  If you and your staff have any questions about this report, please contact me at (202) 512-8777 or goodwing@gao gov  Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report  GAO staff who made key contributions are listed in appendix IV  According to our analysis of data from the U S  Sentencing Commission (USSC), 214,578 federal offenders were sentenced from fiscal years 2014 through 2016  Table 6 shows the number of offenders sentenced and the number and percentage of offenders ordered to pay restitution for each primary offense of conviction in fiscal years 2014 through 2016  The Department of Justice (DOJ) has identified and recommended numerous practices for federal prosecutors and Financial Litigation Unit (FLU) staff to use throughout the restitution process through various guidance documents  We conducted semi-structured interviews with officials from six U S  Attorneys’ Offices (USAO) to obtain their views on the restitution process and the extent to which they believed DOJ- recommended restitution practices related to the restitution process were effective  In particular, we spoke with USAO officials from the District of Connecticut; the Southern District of California; the District of New Jersey; the Southern District of Ohio; the District of South Dakota; and the District of Wyoming  Tables 7 through 9 show the results of our semi-structured interviews  In particular, table 7 shows practices related to requesting restitution and the extent to which USAO officials found these practices effective  Table 8 shows practices related to facilitating orders of restitution and the extent to which USAO officials found these practices effective  Table 9 shows practices related to collecting restitution and the extent to which USAO officials found these practices effective  Each table also indicates practices that officials we interviewed considered as most important or effective for helping ensure victims receive full and timely restitution  In addition to the contact named above, Chris Ferencik (Assistant Director); Kathleen Donovan (Analyst-in-Charge); Enyinnaya David Aja; David Alexander; Lacinda Ayers; Carla Brown; Emily Hutz; Janet Temko- Blinder; and Adam Vogt, made key contributions to this report 

ground_truth: Military families with special medical and educational needs face unique challenges because of their frequent moves. To help assist these families, DOD provides services plans, which document the support a family member requires. The National Defense Authorization Act for Fiscal Year 2017 included a provision for GAO to review the Services' EFMPs, including DOD's oversight of these programs. This report examines the extent to which (1) each Service provides family support and (2) the Services monitor and DOD evaluates assignment coordination and family support. GAO analyzed DOD and Service-specific EFMP guidance and documents; analyzed fiscal year 2016 EFMP data (the most recent available); visited seven military installations, selected for their large numbers of military-connected students; and interviewed officials responsible for implementing each Service's EFMP, as well as officials in OSN that administer DOD's EFM policy. The support provided to families with special needs through the Department of Defense's (DOD) Exceptional Family Member Program (EFMP) varies widely for each branch of Military Service. Federal law requires DOD's Office of Special Needs (OSN) to develop a uniform policy that includes requirements for (1) developing and updating a services plan for each family with special needs and (2) resources, such as staffing, to ensure an appropriate number of family support providers. OSN has developed such a policy, but DOD relies on each Service to determine its compliance with the policy. However, Army and Navy officials said they have not received feedback from OSN about the extent to which their Service-specific guidance complies. Federal internal control standards call for developing clear policies to achieve agency goals. In addition, DOD's most recent annual reports to Congress do not indicate the extent to which each Service provides services plans or allocates sufficient resources for family support providers. According to GAO's analysis, the Military Services have developed relatively few services plans, and there is wide variation in the number of family support providers employed, which raises questions about potential gaps in services for families with special needs (see table). Each Service uses various mechanisms to monitor how servicemembers are assigned to installations (assignment coordination) and obtain family support, but DOD has not established common performance measures to assess these activities. DOD has taken steps to better support families with special needs, according to the DOD officials GAO interviewed. For example, DOD established a working group to identify gaps in services. However, OSN officials said that DOD lacks common performance measures for assignment coordination and family support because the Services have not reached consensus on what those measures should be. In addition, OSN does not have a process to systematically evaluate the results of the Services' monitoring activities. Federal internal control standards call for assessing performance over time and evaluating the results of monitoring activities. Without establishing common performance measures and assessing monitoring activities, DOD will be unable to fully determine the effect of its efforts to better support families with special needs and the adequacy of the Services' EFMPs as required by federal law. GAO makes a total of three recommendations to DOD. DOD should assess and report to Congress on the extent to which each Service provides sufficient family support personnel and services plans, develop common performance metrics for assignment coordination and family support, and evaluate the results of the Services' monitoring activities. DOD agreed with these recommendations and plans to develop performance metrics for assignment coordination and develop plans to evaluate the Services' monitoring activities.

prompt_front: You are given two reports by the government agency.



Question: Write a one-page summary of the report 2.

Report 1: The Forest Service’s mission includes sustaining the nation’s forests and grasslands; managing the productivity of those lands for the benefit of citizens; conserving open space; enhancing outdoor recreation opportunities; and conducting research and development in the biological, physical, and social sciences  The agency carries out its responsibilities in three main program areas: (1) managing public lands, known collectively as the National Forest System, through nine regional offices, 154 national forests, 20 national grasslands, and over 600 ranger districts; (2) conducting research through its network of seven research stations, multiple associated research laboratories, and 81 experimental forests and ranges; and (3) working with state and local governments, forest industries, and private landowners and forest users in the management, protection, and development of forest land in nonfederal ownership, largely through its nine regional offices  According to the Forest Service, it employs a workforce of over 30,000 employees across the country  However, this number grows by thousands in the summer months, when the agency hires seasonal employees to conduct fieldwork, respond to wildland fires, and meet the visiting public’s needs  The Office of the Chief of the Forest Service is located in Washington, D C , with 27 offices reporting directly to the Office of the Chief, as illustrated in figure 1  The nine national forest regions, each led by a regional forester, oversee the national forests and grasslands located in their respective regions  Each national forest or grassland is headed by a supervisor, the seven research stations are each led by a station director, and a state and private forestry area is headed by an area director  The Forest Service collectively refers to its forest regions, research stations, and area as RSAs  The RSAs are organized differently according to their operations, and comparable operations within the RSAs, such as collections from reimbursable agreements, may be processed differently in the various regions and stations, resulting in highly decentralized operations  In addition, the offices of the Chief Financial Officer (CFO); Deputy Chief of Business Operations (includes the budget office); and eight other offices located in the Washington, D C , headquarters also report directly to the Office of the Chief of the Forest Service  The Forest Service receives appropriations for its various programs and for specific purposes to meet its mission goals  Prior to fiscal year 2017, the Forest Service’s budgetary resources consisted primarily of no-year funds  Its budget office in Washington, D C , initiates apportionment requests and monitors the receipt of Department of the Treasury (Treasury) warrants  Upon receipt of the warrant, the apportionment is recorded in the financial system and then the budget office develops an allocation summary detailing the allocation of its budget authority by fund, programs within the funds, and distribution of funds at the regional, station, and area levels  The Forest Service may also transfer funds from other appropriations to the appropriations account that funds its fire suppression activities when available funds appropriated for fire suppression and the Federal Land Assistance, Management, and Enhancement (FLAME) fund will be exhausted within 30 days  The Forest Service’s administrative policies, practices, and procedures are issued in its Directive System, which provides a unified system for issuing, storing, and retrieving internal direction that governs Forest Service programs and activities  The Directive System consists of the Forest Service’s manuals and handbooks  The manuals contain management objectives, policies, and responsibilities and provide general direction to Forest Service line officers and staff directors for planning and executing their assigned programs and activities  The handbooks provide detailed direction to employees and are the principal source of specialized guidance and instruction for carrying out directions issued in the manuals  Line officers at the national and RSA levels have authority to issue directives in the manuals and handbooks under their respective jurisdictions  The Forest Service’s policy states that the Directive System is the only place where Forest Service policy and procedures are issued  In addition to the Directive System, Forest Service staff have also developed standard operating procedures (SOP) and desk guides to supplement guidance provided in directives  However, the SOPs and desk guides are not part of the Forest Service Directive System and therefore are not official policy and procedures  While the Forest Service had documented processes for allotting its budgetary resources, it did not have an adequate process and related control activities for reasonably assuring that (1) amounts designated in appropriations acts for specific purposes are used as designated and (2) unobligated no-year appropriation balances from prior years were reviewed for their continuing need  In addition, the Forest Service did not have a properly designed and documented system for administrative control of funds  Finally, the Forest Service had not properly designed control activities for fund transfers for fire suppression activities under its Wildland Fire Management program  While the Forest Service had documented processes for allotting its budgetary resources, it did not have an adequate process and related control activities to reasonably assure that amounts designated in appropriations acts for specific purposes are used as designated—as required by the purpose statute, which states that “appropriations shall be applied only to the objects for which the appropriations were made except as otherwise provided by law ” We reviewed Forest Service documents about its budget authority processes, which included control objectives, related control activities, and processes over the allotment of its budgetary resources  We found that these documents, including manuals and handbooks, did not include an adequate process and related control activities for assuring that appropriated amounts are used for the purposes designated  For example, such a process would include the Forest Service allotting appropriated funds for specific programs or objects as provided in the applicable appropriation act, by either using specific budget line items already defined in the Forest Service’s financial system or creating new budget line items, as needed  Standards for Internal Control in the Federal Government states that management should define objectives clearly to enable the identification of risks and design appropriate control activities to achieve objectives and respond to the risks identified  As a result of the Forest Service not having an adequate process and related control activities for assuring that appropriated amounts are used for the purposes designated, the Forest Service did not properly allocate certain funds for specific purposes detailed in the appropriations acts for fiscal years 2015 and 2016  For example, in fiscal year 2015, the Forest Service did not set aside in its financial system the $65 million specified in the fiscal year 2015 appropriations act for acquiring aircraft for the next- generation airtanker fleet  According to Forest Service documents, as of January 6, 2016, $35 million of the designated funds was used for other purposes  In February 2017, we issued a legal opinion, related to the Forest Service’s use of the $65 million, which concluded that the Forest Service had failed to comply with the purpose statute  According to USDA’s Office of General Counsel, “this lack of any separate apportionment or account for the next-generation airtanker fleet was due to the fact that it was a new item, not included in the agency’s budget request, and added late in the appropriations process ” Similarly, in fiscal year 2016, the Forest Service did not create new budget line items to reserve in its financial system $75 million for the Forest Inventory and Analysis Program specified in the fiscal year 2016 appropriations act  Rather than creating a new budget line item for the program specified in the appropriations act, the funds were combined with an existing budget line item, making it difficult to track related budget amounts and actual expenditures  The lack of an adequate process and related control activities to reasonably assure that appropriated amounts are used for the purpose designated also increases the risk that the Forest Service may violate the Antideficiency Act  The Forest Service did not have a process and related control activities to reasonably assure that unobligated, no-year funds from prior years were reviewed for continuing need  We reviewed the Forest Service’s budget authority process document and related manuals and handbooks, which documented control objectives and procedures over its budgetary resources and the guidance for administrative control of funds  We found that these documents did not include a process for reviewing the Forest Service’s unobligated, no-year funds from prior years and related control activities to reasonably assure that such funds were reviewed for continuing need  Such reviews, if performed, may identify unneeded funds that could be reallocated to other programs needing additional budgetary resources, if consistent with the purposes designated in appropriations acts  The USDA Budget Manual states as a department policy that “agencies of the Department have a responsibility to review their programs continually and recommend, when appropriate, deferrals or rescissions ” The USDA Budget Manual further states the following: “Agency officials should remain alert to this responsibility since the establishment of reserves is an important phase of budgetary administration  If it becomes evident during the fiscal year that any amount of funds available will not be needed to carry out foreseeable program requirements, it is in the interest of good management to recommend appropriate actions, thereby maintaining a realistic relationship between apportionments, allotments, and obligations ” However, the Forest Service did not develop a directive addressing the control objectives, related risks, and control activities for implementing this USDA policy  Up until fiscal year 2017, Forest Service budgetary resources consisted primarily of no-year funds  At the beginning of each fiscal year, unobligated balances of no-year funds are carried forward and reapportioned to become part of budget authority available for obligation in the new fiscal year  Unobligated balances can increase during the fiscal year due to deobligation of prior years’ unliquidated obligations that the Forest Service determines it no longer needs  These resources are immediately available to the Forest Service to the extent authorized by law without further legislation or action from Office of Management and Budget (OMB) unless the apportionment states otherwise  According to Forest Service officials, unobligated funds reported in the Forest Service’s September 30, 2016, Statement of Budgetary Resources included $351 million in discretionary unobligated no-year funds, appropriated as far back as fiscal year 1999  The Forest Service did not identify and define a process and control objectives related to its review of unobligated no-year funds from prior years for continuing need  As a result, the Forest Service did not have reasonable assurance that prior no-year unobligated balances were properly managed and considered in its annual budget requests  This increased the risk that the Forest Service may make budget requests in excess of its needs  Additionally, the Forest Service could miss opportunities to use its prior year unobligated no-year funds more timely and effectively, for example, using these funds for other Forest Service program needs, if consistent with the purposes designated in appropriations acts  During our work, we brought this issue to management’s attention, and in response, Forest Service officials stated that the Forest Service is planning to develop a quarterly process to review available balances and, as needed, redirect funds to agency priorities  However, as of July 2017, the Forest Service had not yet developed this review process  Further, Congress rescinded about $18 million of the Forest Service’s prior year unobligated balances and required it to report unobligated balances quarterly within 30 days after the close of each quarter and appropriated multi-year funds instead of no- year funds to the Forest Service for fiscal year 2017  The Forest Service issued guidance related to administrative control of funds in manuals and handbooks, which USDA did not review and approve prior to their issuance  Based on our review of these documents, we found that the processes and related control activities over the administrative control of funds were dispersed in numerous manuals and handbooks, which may hamper a clear understanding of the overall system  Further, the system lacked key elements that would allow it to serve as an adequate system of administrative control of funds  For example, in its manuals and handbooks the Forest Service did not identify, by title or office, those officials with the authority and responsibility for obligating the service’s appropriated funds, such as funds for contracts, travel, and training  As a result, the responsibility for obligating funds was not clearly described and properly assigned in Forest Service policy as required by the USDA Budget Manual and OMB Circular No  A-11  OMB Circular No  A-11 states that the Antideficiency Act requires that the agency head prescribe, by regulation, a system of administrative control of funds, and OMB provided a checklist in appendix H to the circular that agencies can use for drafting their fund control regulations  This requirement is consistent with those in the USDA Budget Manual, which prescribes budgetary administration through a system of administrative controls for its component agencies, including the Forest Service  The USDA Budget Manual states that to the extent necessary for effective administration, (1) the heads of USDA component agencies may delegate to subordinate officials responsibilities in connection with the administrative distribution of funds within apportionments and allotments and the monitoring, control, and reporting of the occurrence of obligations and expenditures under apportionments and allotments and (2) the chain of such responsibility shall be clearly defined  In addition, USDA requires its component agencies to promulgate and maintain administrative control of funds regulation and to send such regulation to USDA’s Office of Program and Budget Analysis for review and approval prior to issuance  Because the Forest Service has not developed and issued a comprehensive system for administrative control of funds that considers all aspects of the budget execution processes, it cannot reasonably assure that (1) programs will achieve their intended results; (2) the use of resources is consistent with the agency’s mission; (3) programs and resources are protected from waste, fraud, and mismanagement; and (4) laws and regulations are followed  We also found that the Forest Service had not reviewed and updated most of its administrative control of funds guidance in the manuals and handbooks for over 5 years  The USDA Budget Manual requires each component to periodically review its funds control system for overall effectiveness and to assure that it is consistent with its agency programs and organizational structures  Further, Forest Service policy also requires routine review, every 5 years, of policies and procedures in its Directive System  According to Forest Service officials, when directives are up for review and update, a staff from the Office of Regulatory and Management Services (ORMS) sends an e-mail reminder to notify responsible personnel that updates to applicable directives are needed  However, we found that the Forest Service does not have adequate controls in place to monitor the reviews and any updates of the manuals and handbooks in its Directive System to reasonably assure that their efforts resulted in timely updates  As a result, the Forest Service is at risk that guidance for its system for administrative control of funds may lose relevance as processes change over time and control activities may become inadequate  The Forest Service did not have properly designed control activities over its process for fund transfers related to wildland fire suppression activities  The Forest Service receives appropriations for necessary expenses for (1) fire suppression activities on National Forest System lands, (2) emergency fire suppression on or adjacent to such lands or other lands under fire protection agreement, (3) hazardous fuels management on or adjacent to such lands, and (4) state and volunteer fire assistance  Transfer of funds from other Forest Service programs to its fire suppression activities occurs when the Forest Service has exhausted all available funds appropriated for the purpose of fire suppression and the FLAME fund  A key aspect of this process is assessing the FLAME forecast, which the Forest Service uses to predict the costs of fighting wildland fires for a given season, and developing a strategy to identify specific programs and the amounts that may be transferred to pay for fire suppression activities when needed  The process for reviewing the FLAME forecast and strategizing the fund transfers was documented in the Basic Budget Desk Guide created by staff in the Forest Service’s Strategic Planning and Budget Analysis Office  However, the desk guide did not contain evidence of review by responsible officials  As a result, the Forest Service lacked reasonable assurance that the desk guide was complete and appropriate for its use  The Basic Budget Desk Guide included a listing of actions to be performed by the analyst for reviewing the FLAME forecast report and developing a strategy for fund transfer from other programs  However, the desk guide did not specify the factors to be considered when developing the strategy  For example, it did not call for documentation addressing the rationale for the strategy or an assessment of the risk that the fund transfer could have on the programs from which the funds would be transferred  The desk guide also did not describe the review and approval of the strategy by a responsible official(s) prior to the fund transfer request sent to the Chief of the Forest Service  According to Standards for Internal Control in the Federal Government, management should design control activities to achieve objectives and respond to risks and that such control activities should be designed at the appropriate levels in the organizational structure  Further, management may design a variety of transaction control activities for operational processes, which may include verifications, authorizations and approvals, and supervisory control activities  The lack of properly designed control activities for supervisory review of the desk guide and strategy to identify the amounts for fund transfers does not provide the Forest Service reasonable assurance that the objectives of the fund transfers—including mitigating the risk of a shortfall of funding for other critical Forest Service program activities, such as payroll or other day-to-day operating costs—will be efficiently and effectively achieved  The Forest Service enters into various reimbursable agreements with agencies within USDA, other federal agencies, state and local government agencies, and nongovernment entities to carry out its mission for public benefit  The reimbursable agreements may be for the Forest Service to provide goods and services to a third party or to receive goods and services from a third party, or may be a partnership agreement with a third party for a common goal  According to Forest Service officials, the two distinct types of Forest Service reimbursable agreements are (1) fire incident cooperative agreements and (2) reimbursable and advanced collection agreements (RACA)  The Forest Service did not have documented processes and related control activities for its fire incident cooperative agreements to reasonably assure the effectiveness and efficiency of its related fire incident operations  In addition, processes and related control activities applicable to RACAs were not adequately described in applicable manuals and handbooks in the Directive System, to reasonably assure that control activities could be performed consistently and effectively  Further, certain RACA processes in the Directive System had not been timely reviewed by management and did not reflect current processes  Moreover, as previously discussed, SOPs and desk guides developed in field offices related to RACA processes were not in the Forest Service’s Directive System  Finally, the Forest Service lacked control activities segregating incompatible duties performed by line officers and program managers in creating reimbursable agreements and the final disposition of related receivables  The Forest Service did not have documented processes and related control activities for its fire incident cooperative agreements to reasonably assure the effectiveness and efficiency of its related fire incident operations and reliable reporting internally and externally  As part of the service’s mission objective to suppress wildland fires, Forest Service officials stated that they enter into 5-year agreements referred to as master cooperative agreements with federal, state, and other entities  These agreements document the framework for commitment and support efficient and effective coordination and cooperation among the parties in suppressing fires, when they occur  The master cooperative agreements do not require specific funding commitments as amounts are not yet known  These agreements vary from region to region because of the differing laws and regulations pertaining to the participating states and other entities  These variations can also result in different billing and collection processes between regions  When a fire occurs, supplemental agreements, which are based on the framework established in the applicable master cooperative agreements, are signed by relevant parties for each fire incident  These agreements establish the share of fire suppression costs incurred by the Forest Service and amounts related to entities that benefitted from those fire suppression efforts  These supplemental agreements require commitment and obligation of funds  As indicated in figure 2, the Forest Service’s obligations for fire suppression activities ranged from $412 million to $1 4 billion over the 10-year period from fiscal years 2007 through 2016  In response to our request for documentation of processes and related control activities over its fire incident cooperative agreements, Forest Service officials stated that processes and related control activities over reimbursable agreements were applicable to both fire incident cooperative agreements and RACAs  However, based on our review of the Forest Service’s processes and related control activities over its reimbursable agreements, we found that the unique features of fire incident cooperative agreements (as compared to features of RACAs) were not addressed in the processes and related controls for reimbursable agreements  For example, there was no process and related control activities over the negotiation and review of (1) a fire incident master cooperative agreement, which is developed before a fire occurs, and (2) supplemental agreements, which are signed by all relevant parties after the start of a fire incident  These supplemental agreements detail, among other things, the terms for (1) fire department resource use, (2) financial arrangements, and (3) specific cost-sharing agreements  Another unique feature of fire incident cooperative agreements, which was not covered in process documents for its reimbursable agreements, was the preparation of the Cost Settlement Package  The preparation of this package does not start until after the fire has ended and the Forest Service has received and paid all bills  According to Forest Service officials, a fire incident is deemed to have ended when there are no more resources (firefighters and equipment) on the ground putting out the fire  However, this definition was not documented in the Forest Service’s manuals and handbooks in the Directive System  Based on our review of documentation that the Forest Service provided for four fire incidents, we found that for these incidents the Cost Settlement Packages and the billings took several months to years to complete after the fire incident  According to Forest Service officials, delays in preparing the Cost Settlement Package in many cases were due to parties involved in suppressing the fires taking a long time to submit their invoices to the Forest Service for payment  Because the preparation of Cost Settlement Packages was not included in the process documents, the Forest Service did not have a defined time frame for when, in relation to the end of the fire, the Cost Settlement Package must be completed  For example, in one case we reviewed, the bill for a cost settlement was sent 9 months after the fire occurred, and in another case, settlement occurred approximately 2 years after the fire occurred  For both fire incidents, based on the reports we reviewed, the fires were contained within a week or two, but the Forest Service does not have a policy for documenting the date when the fire incident is deemed to have ended  Because of the complexity of the process for negotiating and determining the reimbursable amounts from all the costs that the Forest Service pays for a fire incident, the reimbursable amounts may take time to negotiate, and subsequent billing to and collection from parties may take much longer  Forest Service officials stated that some receivables that were not going to be collected until after its financial system’s aging process for receivables deemed such receivables uncollectible and a bad debt are tracked in a spreadsheet outside its financial system  We found that the Forest Service did not have a documented process and related control activities to reasonably assure that its Budget Office was informed of these older receivables being tracked in a spreadsheet and the related progress of collection activities that local program managers and line officers perform, which could affect the reliability of the reported reimbursable receivable amounts  According to Standards for Internal Control in the Federal Government, management should internally communicate the necessary quality information to achieve the entity’s objectives  Without proper communication, important information, such as amounts that the Forest Service will receive from fire incident cost settlement negotiations, may not be considered in the Forest Service’s strategy for the effective and efficient management of fund transfers for fire suppression activities  Processes and related control activities applicable to RACAs were not adequately described in Forest Service manuals and handbooks in its Directive System  RACAs, which may be for research or other nonemergency purposes, are billed and collected based on previously agreed upon billing and collection terms  In accordance with the Forest Service’s Directive System, policies related to business processes, such as RACAs, are documented in its manuals while procedures for performing specialized activities are documented in its handbooks  We found that the manuals and handbooks in the Directive System did not adequately describe the processes and related control activities over the RACA processes to enable efficient and effective performance of the work by appropriate and responsible personnel  The manuals and handbooks related to RACAs state that a manager review the documentation to ensure that the funding supports the objective of the agreement, the agreement is the correct instrument for funding the project, all relevant terms and conditions have been included in the agreement, the entity’s financial strength and capability are acceptable, and all applicable regulations and OMB circulars have been addressed  However, there was no discussion in the manuals and handbooks about when the manager needs to perform the reviews and how these reviews were to be documented  Further, in response to our inquiry regarding procedures performed to assess the entity’s financial strength and capability are acceptable before a RACA is signed, Forest Service officials stated that there is currently no formal process for determining financial capability for RACAs  For reimbursable agreements, the Forest Service’s process documented in its handbook consisted of completing a creditworthiness checklist  However, the handbook did not describe procedures for (1) completing the checklist and (2) documenting responsible personnel’s review and approval of an entity’s acceptable financial capability  Standards for Internal Control in the Federal Government states that management should design control activities to achieve objectives and respond to risks  Management’s design of internal control establishes and communicates the who, what, when, where, and why of internal control execution to personnel  Documentation also provides a means to retain organizational knowledge and mitigate the risk of having that knowledge limited to a few personnel  Further, the standards also explain that management clearly document internal control in a manner that allows the documentation to be readily available and properly managed and maintained  In addition, the manuals and handbooks applicable to the RACAs have not been timely reviewed by management, and had not been updated to reflect current processes


Report 2:  For example, the document that serves as direction for Forest Service personnel on how to enter into RACAs referred to an outdated financial system that was replaced in fiscal year 2013  Further, the manuals and handbooks for the RACA processes had no indication that they had been reviewed within the past 5 years  Forest Service policy requires routine review, every 5 years, of policies and procedures in its Directive System  According to Forest Service officials, a staff member from ORMS sends an e-mail to officials responsible for updating these policies and procedures  However, appropriate control activities have not been designed to reasonably assure that updates were made, reviewed, approved, and issued as needed for continued relevance and effectiveness  Without adequate descriptions of processes and related control activities in its manuals and handbooks over RACAs, the Forest Service is at risk that processes and related control activities may not be properly, consistently, and timely performed  Further, because it lacks a process and related controls for monitoring and reviewing the updates of the guidance and various process documents in the Directive System, the Forest Service is at risk that its policies and procedures may not provide appropriate agency-wide direction in achieving control objectives, particularly when financial systems change and old processes may no longer be applicable  SOPs and desk guides related to RACA processes were not in the Directive System and are not considered official Forest Service policy and procedures  Forest Service field staff responsible for various processes generally developed SOPs and desk guides to document day-to-day procedures for employees in carrying out RACA processes to supplement the manuals and handbooks  However, the SOPs and desk guides did not reference the applicable manuals and handbooks they supplemented  Further, the SOPs and desk guides did not provide descriptions of (1) review procedures for authorization, completeness, and validity of RACAs and related receivables; (2) detailed review procedures to be performed and by whom; (3) timing of review procedures; and (4) how to document the completion of the review procedures  Finally, SOPs and desk guides did not have evidence that responsible officials reviewed and approved them to authorize their use  These SOPs and desk guides are only available in the field office where these were developed, and if similar SOPs and desk guides were developed in other field offices, control activities and how they are performed could vary  We also noted that these SOPs and desk guides were not timely updated to reflect processes and systems currently in use  For example, there were many instances where the SOPs and desk guides referred to systems that the Forest Service no longer used  Standards for Internal Control in the Federal Government states that management should establish an organizational structure, assign responsibility, and delegate authority to achieve the entity’s objectives  Effective documentation assists in management’s design of internal control by establishing and communicating the who, what, when, where, and why of internal control execution to personnel  Documentation also provides a means to retain organizational knowledge and mitigate the risk of having that knowledge limited to a few personnel and to achieve the entity’s objectives  Management assigns responsibility and delegates authority to key roles throughout the entity  As a result of the issues discussed above, the Forest Service is at risk that control activities may not be properly and consistently performed and its related control objectives may not be achieved efficiently and effectively  In addition, the Forest Service is at risk that knowledge for performing the control activities may be limited to a few personnel or lost altogether in the event of employee turnover  The Forest Service lacked control activities over the segregation of incompatible duties performed by line officers and program managers for reimbursable agreements and any adjustments affecting the final disposition of related receivables  Field offices manage the majority of Forest Service projects, including authorizing the agreements and monitoring related collection  The Forest Service line officer for fire incident cooperative agreements and program managers for RACA at the RSA, unit, or field levels initiate and develop the terms of the agreements and are also responsible for any subsequent negotiation of the agreements  In the process of negotiating and settling costs, the line officer or program manager has the authority to cancel or change related receivables that they deemed uncollectible  For example, in a fire incident, the line officer at the region or field level is involved in both developing a Cost Share Agreement and after the fire incident has ended, negotiating the Cost Settlement Package with parties involved in the agreement to determine the final settlement amount that the Forest Service will be reimbursed for expenses paid in suppressing the fire incident  Therefore, the line officer is responsible for initiating the Cost Share Agreement, modifying the Cost Settlement Package, and changing or canceling the related receivable, which represent conflicting duties  We also found that the Forest Service did not have any mitigating controls, such as independent approval of any adjustments affecting the final disposition of receivables, to mitigate the risk of these incompatible duties  Standards for Internal Control in the Federal Government states that management should design control activities to achieve objectives and respond to risks  Segregation of duties contributes to the design, implementation, and operating effectiveness of control activities  To achieve segregation of key functions, management can divide responsibilities among different people to reduce the risk of error, misuse, or fraud  This may include separating the responsibilities for authorizing or approving transactions, processing and recording them, and reviewing the transactions so that no one individual controls all key aspects of a transaction or event  Forest Service officials stated they did not consider segregating the conflicting duties related to reimbursable agreements because these line officers and program managers were most familiar with the terms of the agreement and the activities performed  However, a lack of adequate segregation of conflicting duties or proper monitoring and review of conflicting duties for receivables from reimbursable agreements could result in receivables not being collected, and an increased risk of fraud  The Forest Service’s processes and related control activities over review of unliquidated obligations were not properly designed to reasonably assure optimum utilization of funds and were inconsistent with USDA and Forest Service policy  Further, Forest Service manuals and handbooks related to the review of unliquidated obligations did not clearly describe control activities and were not timely reviewed by management  The Forest Service reported unliquidated obligations of approximately $2 6 billion and $2 5 billion in its financial statements as of September 30, 2015, and 2016, respectively  In fiscal year 2016, the Forest Service deobligated about $319 million of its unliquidated obligations from prior years  The Forest Service’s procedures related to the review of unliquidated obligations were not properly designed and were inconsistent with USDA and Forest Service policy  In accordance with USDA Departmental Regulation (Regulation 2230-001) and related Forest Service policy, the Forest Service identifies and reviews unliquidated obligations that have been inactive for at least 12 months to determine whether delivery or performance of goods or services is still expected to occur  Once a determination has been made that an unliquidated obligation can be deobligated, program or procurement personnel are to notify finance personnel, in writing, within 5 days of the determination to process the deobligation  Within 15 days of receipt of the written notification, the unliquidated obligations are to be adjusted in the financial management system  The Forest Service CFO is then to be notified in writing that the deobligation was processed  Within 1 month of the close of each quarter, the Forest Service CFO is to submit to USDA’s Associate CFO for Financial Operations a certification stating that the Forest Service has performed reviews of its unliquidated obligations and taken appropriate actions, such as promptly deobligating an unliquidated obligation that is no longer needed  However, the Forest Service’s quarterly certifications are inconsistent with USDA and Forest Service policy because the months included in each quarterly review do not line up with the months outlined in policy  For example, as shown in table 1, based on policy the certification due on October 31, covers the months July through September  However in practice, the certification that the Forest Service prepared for October 31 covers May through July  As a result, the review and certification for August and September would be delayed an entire quarter  According to Forest Service officials, it takes considerable time to produce accurate unliquidated obligations reports from USDA’s financial system and then distribute them to field offices  Therefore, there is not sufficient time for the field offices to review and deobligate amounts not needed from the unliquidated obligations balances to meet USDA’s certification timing and requirements  However, the Forest Service has not developed other processes and control activities that could help meet USDA and Forest Service policy and reasonably assure that unliquidated obligations are reviewed timely and appropriate actions are taken  As a result, there is an increased risk that the Forest Service may not achieve its control objectives of optimum utilization of funds and timely adjustments of obligated balances  The Forest Service’s process and related control activities over its review of unliquidated obligations and resulting certifications were not adequately described in manuals and handbooks in its Directive System  Further, the manuals and handbooks were not timely reviewed and updated to reflect processes and systems currently in use  In accordance with the Forest Service’s Directive System, policies are documented in its manuals while procedures for performing specialized activities are documented in its handbooks  However, we found that the Forest Service’s processes and related control activities for reviewing unliquidated obligations were not adequately described and documented in such manuals and handbooks  Although parts of the applicable section of the handbook referred to procedures, there were no detailed descriptions of the processes, and only references to objectives of the procedures for reviewing unliquidated obligations were listed  For example, in identifying unliquidated obligations for review, the narrative description of the procedures in the handbook states that the responsible obligating official must review each selected unliquidated obligation to determine whether (1) delivery or performance of goods or services has occurred or is expected to occur and (2) accounting corrections to the obligation data in the accounting system are necessary  The handbook also refers to an unliquidated obligations report listing the unliquidated obligations that must be reviewed  The narrative does not provide any detailed procedures that obligating officials or responsible personnel need to perform, how to perform those procedures, and how those control activities are to be documented  The guidance in the handbook was supplemented by two desk guides  However, the desk guides are outside the Forest Service’s Directive System and, as previously noted, the Directive System is the only place where the Forest Service’s policy and procedures are issued  In addition, these desk guides did not reference the applicable guidance in the Directive System that they were supplementing  Further, the process and related control activities for adjusting unliquidated obligations within 15 days of receipt of written notification, as stated in USDA’s policy, were not described in either the handbooks or the desk guides  Standards for Internal Control in the Federal Government states that management should design control activities to achieve objectives and respond to risks to achieve an effective internal control system  Management’s design of internal control establishes and communicates the who, what, when, where, and why of internal control execution to personnel  Documentation also provides a means to retain organizational knowledge and mitigate the risk of having that knowledge limited to a few personnel  Further, the standards also explain that management clearly document internal control in a manner that allows documentation to be readily available and that documentation be properly managed and maintained  In addition, manuals and handbooks for processes related to review and certification of unliquidated obligations had no evidence that they had been reviewed within the past 5 years for ongoing relevance and effectiveness  According to a Forest Service manual, all service-wide directives, except interim directives, shall be reviewed at least once every 5 years  The Forest Service does not have an effective process in place to monitor the reviews and any updates of the manuals and handbooks in its Directive System  As previously discussed, while ORMS sends an e- mail requesting that the applicable officials review and update the guidance in the manuals and handbooks, there is no follow-up process to help ensure that documents were reviewed and updated as needed  Because the Forest Service’s process and related control activities over its review and certification of unliquidated obligations were not adequately described in its manuals and handbooks, the Forest Service is at risk that its control activities may not reasonably assure that control objectives provide (1) optimum utilization of funds and (2) for unliquidated obligations that are no longer needed to be efficiently and effectively deobligated and made available for other program needs  Adequate processes and related control activities over the Forest Service’s budgetary resources are critical in reasonably assuring that these resources are timely and effectively available for its mission operations, including fire suppression  However, we identified deficiencies in the Forest Service’s processes and related controls over allotments, unobligated no-year funds from prior years, administrative control of funds, fund transfers, reimbursable agreements, and available funds from deobligation of unliquidated obligations  Deficiencies ranged from a lack of processes to control activities that were not properly designed, resulting in an increased risk that Forest Service funds may not be effectively and efficiently monitored and used  In addition, the Forest Service’s manuals and handbooks, which provide the directives for the areas we reviewed, had not been reviewed by management in accordance with the Forest Service’s 5-year review policy  Further, Forest Service staff prepared SOPs and desk guides that documented control activities, but they were not issued as official policy and had not been reviewed and approved by responsible officials  As a result, the Forest Service is at increased risk that the control activities may not be consistently performed across the agency and that the guidance in the SOPs and desk guides may not comply with agency policy in the Directive System  To improve internal controls over the Forest Service’s budget execution processes, we are making the following 11 recommendations: The Chief of the Forest Service should (1) revise its process and (2) design, document, and implement related control activities to reasonably assure that amounts designated in appropriations acts for specific purposes are properly used for the purposes specifically designated  (Recommendation 1) The Chief of the Forest Service should (1) develop a process and (2) design, document, and implement related control activities to reasonably assure that unobligated no-year funds from prior years are reviewed for continuing need  (Recommendation 2) The Chief of the Forest Service should (1) design, document, and implement a comprehensive system for administrative control of funds and (2) submit it for review and approval by USDA before issuance, as required by the USDA Budget Manual  (Recommendation 3) The Chief of the Forest Service should design, document, and implement control activities over the preparation and approval of a fire suppression fund transfers strategy, to specify all appropriate factors to be considered in developing and documenting the strategy, and incorporate these control activities into the Directive System  (Recommendation 4) The Chief of the Forest Service should design, document, and implement processes and related control activities for its fire incident cooperative agreements to reasonably assure efficient and effective operations and timely and reliable reporting of reimbursable receivables related to fire incident cooperative agreements, and incorporate them in the Directive System  (Recommendation 5) The Chief of the Forest Service should update the RACA manuals and handbooks to adequately describe the processes and related control activities applicable to RACAs to reasonably assure that staff will know (1) how and when to perform processes and control activities and (2) how to document their performance  (Recommendation 6) The Chief of the Forest Service should design, document, and implement segregation of duties or mitigating control activities over reimbursable agreements and any adjustments affecting the final disposition of related receivables  (Recommendation 7) The Chief of the Forest Service should modify, document, and implement control activities consistent with USDA and Forest Service policy to reasonably assure that unliquidated obligations are reviewed timely and appropriate actions are taken  (Recommendation 8) The Chief of the Forest Service should adequately describe the processes and related control activities for unliquidated obligations review and certification processes in manuals and handbooks within the Directive System  (Recommendation 9) The Chief of the Forest Service should develop, document, and implement a process and related control activities to reasonably assure that manuals and handbooks for allotments, reimbursable agreements, and review of unliquidated obligations are reviewed and updated every 5 years, consistent with Forest Service policy  (Recommendation 10) The Chief of the Forest Service should develop, document, and implement a process and related control activities to reasonably assure that SOPs and desk guides (1) clearly refer to guidance in the Directive System for allotments, reimbursable agreements, and review of unliquidated obligations and (2) are reviewed and approved by responsible officials prior to use  (Recommendation 11) We provided a draft of this report to USDA for comment  In its comments, reproduced in appendix III, the Forest Service stated that it generally agreed with the report and that it has made significant progress to address the report’s findings  Specifically, the Forest Service stated that its financial policies concerning budget execution have been revised to address our concerns with allotments, unliquidated obligations, commitments, and administrative control of funds as prescribed by OMB Circular No  A-11  Further, the Forest Service stated that it has undertaken an in-depth review of its unliquidated obligations and modified the certification process to comply with the USDA requirement  We are sending copies of this report to the appropriate congressional committees and to the Secretary of Agriculture and the Chief of the Forest Service  In addition, this report is available at no charge on the GAO website at http://www gao gov  If you or your staff members have any questions about this report, please contact me at (202) 512-9869 or khana@gao gov  Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report  GAO staff members who made key contributions to this report are listed in appendix IV  Our objectives were to determine the extent to which the Forest Service properly designed control activities over (1) allotments of budgetary resources, its system for administrative control of funds, and any fund transfers between Forest Service appropriations; (2) reimbursables and related collections; and (3) unliquidated obligations  We reviewed the Forest Service’s process documents and control activities, policies and procedures from its manual and handbooks in its Directive System, and other guidance in the form of standard operating procedures (SOP) and desk guides to obtain an understanding of internal controls at the Forest Service related to our three objectives  We reviewed the control activities that the Forest Service identified to determine whether the activities would achieve the control objectives that the service identified and whether the activities were consistent with Standards for Internal Control in the Federal Government  We also reviewed recent relevant GAO and U S  Department of Agriculture (USDA) Office of Inspector General reports to obtain background information related to the Forest Service’s budget execution processes  We evaluated the design of the Forest Service’s control activities based on data for fiscal year 2016  To address our first objective, we reviewed Forest Service process documents related to allotments and budget authority to obtain an understanding of control activities over the allotments of budgetary resources, its system for administrative control of funds, and any related fund transfers between Forest Service appropriations  The process documents included a list of control objectives and related control activities that the Forest Service had used to assess its internal controls  We also reviewed the related guidance in appendix H to Office of Management and Budget Circular No  A-11, Preparation, Submission, and Execution of the Budget for Administrative Control of Funds, to identify requirements that agencies must meet to ascertain whether their controls over funds management are properly designed  We interviewed key officials from the Forest Service’s Strategic Planning, Budget and Accountability Office to gain an understanding of their processes for allotments of budgetary resources, its system for administrative control of funds, and fund transfers between Forest Service appropriations for wildland fire suppression activities, including how each of their risk assessments were performed and their plans to mitigate the risks  We reviewed and analyzed the processes documented in the manuals and handbooks collectively referred to as directives to determine whether the processes and control activities were designed to achieve the Forest Service’s stated objectives  Specifically, we examined the Forest Service’s control activities to determine whether these sufficiently communicated the procedures to be performed and the documentation to be prepared  We also reviewed USDA Budget Manual to determine whether Forest Service guidance was consistent with USDA’s requirements for all of its component agencies, specifically requirements related to the administrative control of funds  To address our second objective, we reviewed the Forest Service’s policies, procedures, and other documentation and interviewed agency officials to develop an understanding of its processes related to reimbursable agreements and related collection activities  We first identified, through interviews with Forest Service officials, the different kinds of reimbursable agreements that the Forest Service enters into with other USDA components, other federal agencies, state and local government agencies, and nongovernment entities to carry out its mission for the benefit of the public  Two distinct types of reimbursable agreements include (1) fire incident cooperative agreements and (2) reimbursable and advanced collection agreements  We reviewed Forest Service process documents and templates related to these two types of reimbursable agreements provided to obtain an understanding of control activities over reimbursable processes  We reviewed the list of control objectives and related control activities that the Forest Service identified to determine whether the control activities were designed to achieve the applicable control objectives  To address our third objective, we reviewed the Forest Service’s policies, procedures, and other documentation related to and interviewed agency officials about unliquidated obligations to develop an understanding of the Forest Service’s review and certification processes for unliquidated obligations balances  We reviewed the Forest Service’s control activities related to its process for reviewing unliquidated obligations to obtain an understanding of control activities around its process and to determine whether the control activities were designed to achieve the applicable control objectives  Based on the results of our evaluation of the Forest Service’s design of internal control activities over the budget execution processes, we did not evaluate the implementation of the control activities or whether they were operating as designed  While our audit objectives focused on certain control activities related to (1) allotments of budgetary resources, the Forest Service’s system for administrative control of funds, and related fund transfers; (2) reimbursables and related collections for reimbursable agreements; and (3) unliquidated obligations, we did not evaluate all control activities and other components of internal control  If we had done so, additional deficiencies may or may not have been identified that could impair the effectiveness of the control activities evaluated as part of this audit  We conducted this performance audit from August 2016 to January 2018 in accordance with generally accepted government auditing standards  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  Standards for Internal Control in the Federal Government provides the overall framework for establishing and maintaining internal control  Internal control represents an agency’s plans, methods, policies, and procedures used to fulfill its mission, strategic plan, goals, and objectives  Internal control is a process by an entity’s oversight body, management, and other personnel to provide reasonable assurance that the objectives of the entity will be achieved  When properly designed, implemented, and operating effectively, it provides reasonable assurance that the following objectives are achieved: (1) effectiveness and efficiency of operations, (2) reliability of internal and external reporting, and (3) compliance with applicable laws and regulations  Internal control is not one event, but a series of actions that occur throughout an entity’s operations  The five components of internal control are as follows: Control Environment - The foundation for an internal control system that provides the discipline and structure to help an entity achieve its objectives  Risk Assessment - Assesses the risks facing the entity as it seeks to achieve its objectives and provides the basis for developing appropriate risk responses  Control Activities - The actions management establishes through policies and procedures to achieve objectives and respond to risks in the internal control system, which includes the entity’s information system  Information and Communication - The quality information management and personnel communicate and use to support the internal control system  Monitoring - Activities management establishes and operates to assess the quality of performance over time and promptly resolve the findings of audits and other reviews  An effective internal control system has each of the five components of internal control effectively designed, implemented, and operating with the components operating together in an integrated manner  In this audit, we assessed the design of control activities at the Forest Service related to its (1) allotments of budgetary resources and any related fund transfers between Forest Service appropriations, (2) reimbursables and related collections, and (3) review of unliquidated obligations  In addition to the contact named above, the following individuals made key contributions to this report: Roger Stoltz (Assistant Director), Meafelia P  Gusukuma (Auditor-in-Charge), Tulsi Bhojwani, Cory Mazer, Sabrina Rivera, and Randy Voorhees 

ground_truth: One of the goals of federal criminal restitution is to restore victims of federal crimes to the position they occupied before the crime was committed by providing compensation. Various entities within the federal government are involved in the process of requesting, ordering, and collecting restitution for crime victims, including DOJ and the judiciary. The Justice for All Reauthorization Act of 2016 includes a provision for GAO to review the federal criminal restitution process for fiscal years 2014 through 2016. This report addresses, among other things: (1) the extent to which information is available on restitution requested by DOJ and ordered by courts; (2) the amount of restitution debt DOJ collected and the amount that remains outstanding; and, (3) the extent to which DOJ has conducted oversight on the collection of restitution. GAO analyzed laws, policies and procedures as well as USSC data on restitution orders and DOJ data on restitution collected from fiscal years 2014 through 2016. GAO also selected a non-generalizable sample of six federal judicial districts based on restitution collections and spoke with USAO officials and federal probation officers. Officials from selected U.S. Attorney's Offices (USAO) stated that they document requests for restitution in case files and employ other internal controls, such as the use of templates and forms, throughout the prosecution process to ensure that prosecutors request restitution as appropriate. GAO's analysis of U.S. Sentencing Commission (USSC) data—an agency within the judiciary—showed that information on restitution orders was available for 95 percent of all offenders sentenced from fiscal years 2014 through 2016. Specifically, 214,578 federal offenders were sentenced during this time period and restitution was ordered for 33,158, or 15 percent, of those offenders. Collectively, courts ordered these offenders to pay $33.9 billion in restitution. Most federal offenders sentenced during these years were sentenced for immigration or drug-related offenses. In interviews, USAO officials stated that these offenses do not typically have victims requiring restitution. GAO found that data on reasons why restitution was not ordered were incomplete for 5 percent of all offenders sentenced from fiscal years 2014 through 2016. Determining why data on restitution orders are incomplete may inform the judiciary of the cause of the incomplete data and any efforts needed to improve USSC data. GAO's analysis of Department of Justice (DOJ) data showed that USAOs collected $2.95 billion in restitution debt in fiscal years 2014 through 2016, see figure below. However, at the end of fiscal year 2016, $110 billion in previously ordered restitution remained outstanding, and USAOs identified $100 billion of that outstanding debt as uncollectible due to offenders' inability to pay. DOJ identified improving debt collection—including restitution—as a major management initiative in its 2014-2018 Strategic Plan. While DOJ is developing analytical tools to monitor the collection of restitution, it has not established performance measures or goals. Performance measures and goals would allow DOJ to gauge USAOs' success in collecting restitution and, by extension, the department's success in achieving a major management initiative. GAO is making three recommendations. GAO is making one to the judiciary to determine why data on restitution orders are incomplete. GAO is making two recommendations to DOJ, including one to implement performance measures and goals for the collection of restitution. The judiciary and DOJ concurred with the recommendations.