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



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

Report 1: The Land and Water Conservation Fund (LWCF) Act of 1965 was enacted to "assist in preserving, developing, and assuring accessibility to     outdoor recreation resources " Two main goals of the law were to facilitate participation in recreation and "to strengthen the health and vitality" of U S  citizens  To accomplish these goals, purposes of the law included "providing funds" for federal land acquisition and for federal assistance to states generally related to outdoor recreation  The fund is authorized to receive $900 million in revenues annually under the LWCF Act  Each year the fund accrues revenues at this level  The fund accumulates the majority of its revenues from oil and gas leases on the Outer Continental Shelf (OCS)  It also accumulates revenues from the federal motorboat fuel tax and surplus property sales  However, revenues that accrue under the LWCF Act are available only if appropriated by Congress through the discretionary appropriations process  The LWCF receives additional revenue (beyond the $900 million) from OCS leasing under the Gulf of Mexico Energy Security Act of 2006 (GOMESA)  Unlike revenues under the LWCF Act, GOMESA revenues are mandatory appropriations (and thus are not subject to annual appropriation by Congress)  They can be used only for grants to states for outdoor recreation purposes  The overall level of annual appropriations (discretionary and mandatory combined) has varied widely since the fund's origin in FY1965  Of the total revenues that have accrued throughout the program's history ($40 9 billion), less than half have been appropriated ($18 9 billion) through FY2019  Thus, the unappropriated balance in the fund is estimated at $22 0 billion through FY2019  The LWCF Act outlines uses of the fund for federal and state purposes  It states that of the total made available to the fund, not less than 40% is to be used for "federal purposes" and not less than 40% is to be used to provide "financial assistance to states " The act lists the federal purposes for which the President is to allot LWCF funds "unless otherwise allotted in the appropriation Act making them available " These purposes primarily relate to the acquisition of lands and waters (and interests therein) by the federal government  With regard to state purposes, the act authorizes a matching grant program to states for outdoor recreation purposes  In practice, over the history of the LWCF, appropriations acts have provided funding for three general purposes  First, for each year since FY1965, appropriations for land acquisition have been provided to some or all of the major federal land management agencies—the Bureau of Land Management (BLM), Fish and Wildlife Service (FWS), National Park Service (NPS), and Forest Service (FS)  Second, for nearly every year since FY1965, appropriations have funded the outdoor recreation matching grant program, to assist states in recreational planning, acquiring recreational lands and waters, and developing outdoor recreational facilities  Third, beginning in FY1998, appropriations from the LWCF have been provided each year, except FY1999, to fund other federal programs with related natural resource purposes  Hereinafter, the third type of appropriations is referred to as funding other purposes   The $18 9 billion appropriated from the fund through FY2019 has been allocated in different proportions among federal land acquisition, the state grant program, and other purposes  The largest portion of the total—$11 4 billion—has been appropriated for federal land acquisition  The state grant program has received the second-largest portion, $4 8 billion  Other purposes have received the remaining $2 7 billion  Appendix A shows the total LWCF appropriation for other purposes  Congress continues to consider the extent to which the LWCF should fund purposes other than federal land acquisition and outdoor recreation grants to states  Some traditional LWCF advocates and beneficiaries have expressed concern about expanding the use of the funds, particularly if such expansion results in lower appropriations for land acquisition and outdoor recreation grants to states  Some Members of Congress, Presidents, and stakeholders have supported funding other purposes in order to draw on the balance in the fund for policy priorities, to shift the focus of the fund from land acquisition, or to achieve other goals  A number of measures introduced in recent Congresses sought to authorize funding from the LWCF for various other purposes  These measures were not enacted  They included proposals to specify an amount or percentage of funding for two programs that are currently funded by the LWCF—the Forest Legacy Program and Cooperative Endangered Species Conservation grants—although the LWCF Act does not specifically authorize this funding  Other proposals sought to authorize programs or activities that have not been funded by LWCF in the past, or that have been rarely funded by LWCF in the past  For instance, one 115 th Congress bill would have authorized LWCF funding for certain programs and activities of the major land management agencies, including deferred maintenance, critical infrastructure, visitor services, and clean-up efforts; the Payments in Lieu of Taxes Program; and certain offshore energy exploration, innovation, and education activities  As another example, one 115 th Congress bill proposed to authorize LWCF funding for financial assistance from the Secretary of Housing and Urban Development for park and recreation infrastructure projects  The balance of this report discusses the other purposes for which LWCF appropriations have been provided throughout the fund's history  It identifies the amount of funding contained in annual appropriations laws for other purposes and the types of purposes for which funds have been appropriated  A total of $72 0 million was appropriated from the LWCF for other purposes in FY1998, the first year in which LWCF was used to fund other purposes  The total included $60 0 million for maintenance needs of the four land management agencies and $12 0 million for rehabilitation and maintenance of the Beartooth Highway (in Wyoming and Montana)  In FY1998, total LWCF appropriations had spiked to approximately $969 million from the FY1997 level of about $159 million  Both the dollar amounts and the percentages of annual LWCF appropriations for other purposes have varied widely since FY1998  (See Appendix B  ) Over the most recent 10 years, LWCF appropriations for other purposes fluctuated, declining overall from $132 5 million in FY2010 to $93 3 million in FY2019 (in current dollars)  However, the FY2019 level was the highest appropriation since FY2010  Beginning in FY2011, appropriations for other purposes in each year have been less than $100 million, as was the case for FY1998-FY2000  Appropriations for other purposes were at their lowest dollar amount in FY1999, when no funds for other purposes were appropriated  The next-lowest dollar value was provided for FY2000, when a total of $20 0 million was appropriated for three purposes: Elwha River Ecosystem restoration (in Washington), deferred maintenance of the NPS, and the FS Forest Legacy program  By contrast, from FY2001 to FY2010, appropriations for other purposes exceeded $100 million in each year  In fact, during four of these years (FY2004-FY2007), the annual appropriation was between $200 million and $225 million  The appropriation surpassed $400 million in another year during the period  Specifically, the $456 0 million appropriation in FY2001 was more than double the amount provided for other purposes in any other year  These appropriations were used to fund more than a dozen programs in the Clinton Administration's Lands Legacy Initiative  In that year, total LWCF appropriations exceeded the annual authorization level, totaling nearly $1 billion  This record level of funding was provided partly in response to President Clinton's Lands Legacy Initiative, which sought $1 4 billion for about two dozen resource-protection programs, including the LWCF  It also was provided partly in response to some congressional interest in securing increased and more certain funding for the LWCF  The highest percentage of annual funds provided for other purposes occurred in FY2006 and FY2007 (59% in both years), in response to President George W  Bush's request for funding for an array of programs  For instance, in FY2007 the Bush Administration sought funding from the LWCF for 15 programs in addition to land acquisition and state grants  For that year, the appropriation for five other purposes was $216 1 million, out of a total LWCF appropriation of $366 1 million  In some years, the appropriation for other purposes was significantly less than the Administration requested  For example, for FY2008 the Bush Administration sought $313 1 million for other purposes, or 83% of the total request of $378 7 million  The FY2008 appropriation for other purposes was $101 3 million, or 40% of the LWCF total of $255 1 million  The $2 7 billion appropriated from the LWCF from FY1998 to FY2019 for other purposes represents 27% of the $10 0 billion total appropriations from LWCF during the period  FWS and FS have received the largest shares of the appropriations for other purposes, about $1 4 billion (53%) and $1 0 billion (38%), respectively  BLM, NPS, the U S  Geological Survey, and the Bureau of Indian Affairs have shared the remaining $0 2 billion (9%) of the appropriations for other purposes  (See Figure 1  ) Because there is no set of other purposes specified in the LWCF Act to be funded from the LWCF, presidents have sought funds for a variety of purposes  Congress has chosen which of these requests to fund from the LWCF, and whether to fund any additional programs from the LWCF not suggested by the President  Appropriations for other purposes have been provided for more than a dozen diverse natural resource-related programs, including facility maintenance of the land management agencies, ecosystem restoration, the Historic Preservation Fund, the Payments in Lieu of Taxes program, the FS Forest Legacy program, FWS State and Tribal Wildlife Grants, the FWS Cooperative Endangered Species Conservation Fund, U S  Geological Survey science and cooperative programs, and Bureau of Indian Affairs Indian Land and Water Claim Settlements  (See Appendix A  ) Although in earlier years several other purposes typically were funded from LWCF, since FY2008, funds have been appropriated annually only for grants under two programs: Forest Legacy and Cooperative Endangered Species Conservation Fund  (See Appendix B and Figure 2   ) The total appropriation from LWCF for these two programs (since FY1998) is $1 7 billion, or 63% of all appropriations for other purposes ($2 7 billion)  These two programs and a third grant program funded prior to FY2008 from LWCF—FWS State and Tribal Wildlife Grants—have received more than three-quarters ($2 1 billion, 79%) of the total appropriations for other purposes  The appropriations through FY2019 are $944 4 million for Forest Legacy (35% of the other purposes total), $753 3 million for Cooperative Endangered Species Conservation Fund (28% of total), and $448 5 million for State and Tribal Wildlife Grants (17% of total)  Grants under the Forest Legacy program are used to acquire lands or conservation easements to preserve private forests threatened by conversion to non-forest uses, such as agriculture or residences  FS provides matching grants to states through a competitive process that requires state approval and then national approval and ranking  The ranking is based on the importance of the project (potential public benefits from protection), the likelihood of the forest's conversion to non-forest uses, and the strategic relevance of the project, among other factors  The program is implemented primarily through state partners, usually state forestry agencies  State partners generally acquire, hold, and administer the easements or land purchases, although the federal government also may do so  The Cooperative Endangered Species Conservation Fund provides grants "for species and habitat conservation actions on non-Federal lands, including habitat acquisition, conservation planning, habitat restoration, status surveys, captive propagation and reintroduction, research, and education " In addition to appropriations from LWCF, the Cooperative Endangered Species Conservation Fund typically receives additional appropriations  In recent years, the appropriations from LWCF generally have been used for two types of land acquisition grants provided to state and territories on a matching basis  Recovery land acquisition grants have been made for acquisition of habitats in support of species recovery goals and objectives  Habitat conservation plan land acquisition grants have been made for acquisition of lands that are associated with habitat conservation plans  State and Tribal Wildlife Grants are provided to states, territories, and tribes to develop and implement programs for the benefit of fish and wildlife and their habitats, including nongame species  State and Tribal Wildlife Grants received funding from the LWCF for FY2001-FY2007; subsequently, funding has been provided from the General Fund of the U S  Treasury  Currently, the largest portion of the program is for formula grants to states and territories on a matching basis  Funds from the formula grants may be used to develop state conservation plans and to implement specific conservation projects  Smaller amounts of funding have been appropriated for competitive grants to states and territories, and to tribal governments  The competitive grant programs do not have matching requirements  Appendix A shows the total LWCF appropriations for other purposes summed from FY1998 to FY2019  Appendix B shows the other purposes that received LWCF appropriations each year, the amount of LWCF appropriations for each purpose, and the total annual appropriations for other purposes  Appendix A  Total LWCF Appropriations for Other Purposes Appendix B  Annual LWCF Appropriations for Other Purposes 


Report 2: Justice Management Division (JMD) JMD provides the Federal Bureau of Prisons senior management with guidance as it relates to Department of Justice (DOJ) policy for all matters pertaining to organization, management, and administration, including the use of human capital flexibilities such as retention incentives  BOP is responsible for incarcerating all federal offenders sentenced to prison  To carry out its mission, BOP, under the oversight of DOJ’s JMD, manages the human resource operations of its institutions, including the use of retention incentives  BOP administers, monitors, and oversees retention incentives through its Central Office, regional offices, and institutions  Central Office  The Central Office serves as BOP’s headquarters and provides oversight of BOP operations and program areas  Within the Central Office is BOP’s Human Resource Management Division (HRMD) which is responsible for developing, implementing and administering human resource policies and programs, including the use of retention incentives that meet OPM and DOJ requirements  In addition, the Central Office’s Program Review Division (PRD) is responsible for assessing BOP programs, including human resources, to ensure that they are managed and operated effectively  Regional offices  BOP has six regional offices that cover the Mid- Atlantic, North Central, Northeast, South Central, Southeast, and Western regions of the United States  These offices, each led by a regional director, oversee the operations of the 122 federal institutions within their respective geographic regions of the country  According to BOP officials, regional office staff also provide local level oversight of institutions’ human capital programs, such as retention incentives, among other things  Institutions  BOP institutions are managed by a warden and other officials, including an executive assistant and associate warden who generally provide overall direction and, in part, administer the institution’s human capital policies, including policies on retention incentives  Correctional services staff represent the largest segment of each institution’s workforce and are responsible for the correctional treatment, custody, and supervision of inmates  Non-correctional services staff include, among others, those employees assigned to non-correctional services management, facility operations, and the health services unit  Workers in health services and psychology services are responsible for providing inmates with medical, dental, and mental health services and include, for example, dentists, pharmacists, physicians, nurses, psychologists, and drug treatment specialists  The Federal Employees Pay Comparability Act of 1990 first authorized OPM to allow federal agencies to give incentives, including retention incentives, to employees  The Federal Workforce Flexibility Act of 2004 provided federal agencies increased flexibilities regarding these incentives  For example, individual retention incentives that were capped at 25 percent of an employee’s basic pay rate could be increased up to 50 percent in cases of critical agency need with OPM’s approval  Generally, under OPM regulations, an agency is authorized to pay a retention incentive to employees  This happens when the agency determines that the unusually high or unique qualifications of the employee or a special need of the agency for the employee’s services makes it essential to retain the employee and that the employee would be likely to leave federal service in the absence of an incentive  In addition, OPM requires agencies to develop plans for using retention incentives outlining, in part, the required documentation for justifying the retention incentive and any criteria for determining the amount of incentive and the length of the service period  Generally, agencies must require that employees sign a written service agreement that outlines the terms of the service such as the employee’s agreement to remain a certain length of time with the agency  Additionally, according to OPM regulations, to qualify for a retention incentive, each employee must have a performance rating of at least “fully successful” or an agency’s equivalent performance rating  BOP funds the majority of its retention incentives through its Salaries and Expenses appropriation account which represented almost 93 percent of BOP’s budget in FY 2016  According to BOP officials, BOP’s Central Office allocates funding from the Salaries and Expenses account to the regional offices  These regional offices then determine how to allocate their budget among various salary and expense activities, including retention incentives  HRMD delegates retention incentive determinations to each institution  In accordance with OPM requirements and BOP’s October 2016 Program Statement on Compensation, the wardens make retention incentive requests based on documented evidence that the employee possesses unusually high or unique qualifications or meets a special need of the agency and has a performance rating of at least “successful or its equivalent ” These incentives are calculated as a percentage of the employee’s basic pay and are disbursed in installments to the employee each pay period  In addition to retention incentives, BOP has authority to provide other compensation-based human capital flexibilities to employees, in certain circumstances  The following summarizes some of the compensation- based human capital flexibilities that BOP uses in addition to retention incentives, to retain and recruit staff: Recruitment and relocation incentives  BOP pays recruitment incentives to new hires and relocation incentives to current employees who elect to move to a different geographic area, when a position is likely to be difficult to fill in the absence of an incentive  Student loan repayments  Using this authority, BOP may repay federally-insured student loans to attract job candidates or retain current employees  Special salary rates  With OPM approval, BOP may establish higher rates of pay for an occupation or group of occupations nationwide or in a local area when it finds the government’s recruitment or retention efforts are, or would likely become, significantly handicapped without those higher rates  Physicians and dental comparability allowances  Comparability allowances may be paid to certain eligible physicians or dental professionals who enter into service agreements  These allowances are paid only to categories of physicians and dentists for which the agency is experiencing recruitment and retention problems and are fixed at the minimum amounts necessary to deal with such problems  BOP retention incentive expenditures generally increased from $10 7 million in fiscal year 2012 to $14 0 million in fiscal year 2016  Additionally, as illustrated in table 1, the number of employees who received retention incentives increased each year from 2,024 employees in fiscal year 2012 to 2,460 employees in fiscal year 2016  In general, BOP employees who received retention incentives received the incentive for more than one year  For example, from fiscal year 2012 through fiscal year 2016, a total of 3,382 BOP employees received retention incentive payments  Of those, 82 percent (2,766 of 3,382) received retention incentive payments for at least 2 years and 39 percent received retention incentives all 5 years, as shown in figure 1  From fiscal years 2012 through 2016, BOP spent more than 97 percent of its total retention incentive expenditures on employees at four California institutions and for medical professionals nationwide  BOP’s total retention incentive expenditures for the four California institutions and medical professionals nationwide in fiscal year 2016 are provided in figure 2  Four California Institutions  The California institutions—United States Penitentiary (USP) Atwater, Federal Correctional Institution (FCI) Herlong, FCI Mendota, and Federal Correctional Complex (FCC) Victorville—constituted the largest portion of BOP’s total retention incentive expenditures, and the level of their expenditures remained relatively steady from fiscal year 2012 through 2016  BOP provides group retention incentives for staff at the General Schedule (GS) grades level 12 and below and those in the Federal Wage System at three institutions—USP Atwater, FCI Herlong, and FCC Victorville  BOP also provides individual retention incentives to its employees at GS grades level 12 and below and in the Federal Wage System at FCI Mendota  As shown in figure 3, our analysis of BOP data found that from fiscal years 2012 through 2016, these four California institutions had the largest percentage of retention incentive expenditures across institutions as well as the largest percentage of employees who received retention incentives  Additionally, the four California institutions’ retention incentive expenditures remained relatively steady—around $8 1 to $8 2 million during the 5-year period—even though the overall number of employees who received the incentives generally increased  BOP officials told us that these California institutions’ retention incentive expenditures remained relatively steady in spite of an overall increase in the number of employees receiving incentives, in part, because in fiscal year 2013 BOP reduced the retention incentive rate—the percentage of an employee’s basic pay that determines the employee’s retention incentive— by 3 percent at the four California institutions  BOP officials reported using retention incentives primarily at these four institutions to supplement correctional officers’ salaries and compensate for the gap between BOP’s and other institutions’ salaries  Specifically, officials told us that these four California institutions were consistently understaffed as a result of their lower salaries in comparison to salaries offered at California state and local prisons and at other BOP institutions in California metropolitan areas  The Department of Labor’s Bureau of Labor Statistics reports that the average salary for correctional officers in California in 2016 was $70,020  For the same year, the annual average salary for BOP correctional officers at these four institutions was $50,859  To bring these four California institutions’ salaries in line with those offered by state, local, and other BOP institutions in California metropolitan areas, BOP officials told us that they first use recruitment incentives to attract and hire staff and then provide retention incentives to employees with a performance rating of at least “successful ” Medical Professionals  From fiscal years 2012 through 2016, BOP retention incentive expenditures for medical professionals increased by an average of approximately 21 percent per year  Our analysis showed that most recently—for fiscal years 2015 and 2016—BOP retention incentive expenditures for medical professionals accounted for the largest portion of BOP’s total retention incentive expenditures across the various occupation groups and was primarily responsible for the overall increase in BOP’s total retention incentive expenditures from fiscal year 2012 through fiscal year 2016  For example, in fiscal year 2016, BOP spent approximately 42 percent of total retention incentives expenditures for medical professionals ($5 8 million), 27 percent on correctional officers ($3 8 million), and the remaining 31 percent on employees in other occupations  In total, BOP retention incentive expenditures for medical professionals increased from approximately $2 7 million in fiscal year 2012 to $5 8 million in fiscal year 2016, as shown in figure 4  The increase accounted for 92 percent of BOP’s total increase in retention incentive expenditures during the five-year period  In comparison, BOP’s retention incentive expenditures for correctional officers and all other occupations remained relatively steady from fiscal year 2012 through fiscal year 2016, increasing by an average of approximately 1 percent per year  According to our analysis, the increase in retention incentive expenditures for medical professionals during the five years is partially explained by the increase in the number of institutions providing retention incentives to medical professionals  Specifically, from fiscal years 2012 through 2016, the number of institutions providing retention incentives to medical professionals increased from 53 institutions with 341 employees in medical occupations receiving retention incentives to 84 institutions providing retention incentives to a total of 646 employees in medical occupations  According to BOP officials, BOP primarily uses retention incentives for medical professionals in an effort to retain these employees by supplementing BOP salaries which are generally lower than salaries offered to medical professionals in the private sector  Officials told us that BOP has designated medical professional positions as hard-to-fill and, therefore, BOP retaining these professionals in a correctional setting requires the use of a variety of incentives, including retention incentives, in order to increase pay  BOP has a number of internal controls in place to ensure that retention incentive applications meet BOP and other requirements  BOP officials told us that these controls are part of a multilayered application and review process that begins at the institution and culminates at BOP’s Central Office  Our review of a random sample of 40 application packet case files for retention incentives awarded from fiscal year 2014 through fiscal year 2016 found that they all generally incorporated the internal controls described by officials  The key controls in this process include: Application review at the institution and regional levels  According to BOP officials, the retention incentive application process begins with an institution’s human resources office, whose staff complete a retention incentive application on behalf of an employee  The institution’s human resources office verifies that the information in the application justifies a retention incentive and that funds are available to pay the incentive  Although it is not required, BOP officials said that they use a retention incentive application checklist to help institutions ensure that retention incentive applications are complete  The institution’s human resources office then submits the completed application packet, which includes supporting documentation, to the warden for review  Next, the application packet is forwarded to the respective BOP regional director who also reviews it for accuracy and completeness  The regional director then adds an approval statement and forwards the packet to the Central Office for final review and approval  Of the 40 randomly selected application packet case files that we reviewed, 36 included a retention incentive checklist used by the institutions and all contained information to justify the retention incentive as well as a statement of the regional director’s approval  Central Office’s final application approval  BOP policy requires that all retention incentive applications undergo two levels of review in BOP’s Central Office: first by the Human Resource Management Division’s (HRMD) Staffing and Employee Relations Section (SERS) and next by HRMD’s Personnel Director, for final review and approval  According to BOP officials, during the review process there is ongoing communication between the various entities to ensure that applications are complete and accurate; for example, if SERS finds an error in the application or requests additional information, SERS returns the application to the regional or institutional level for correction and re-review  All of the 40 BOP application packet case files that we reviewed included approvals by HRMD’s Personnel Director or an authorized official, as required by BOP policy  Annual review and re-certification to continue retention incentives  According to BOP policy, on an annual basis, institutions’ human resources offices are required to review employees’ retention incentives to determine whether the incentive is still warranted  Payment of a retention incentive may be recertified and continued as long as the conditions giving rise to the original determination to pay the incentive still exist and funds are available  For each retention incentive, an institution’s human resources office must determine whether to continue, adjust, or terminate the incentive within one year of the initial or most recent approval  If the human resources office decides to continue the retention incentive, the institution’s warden must again submit a retention incentive application  Applications to continue the retention incentive proceed through the same review and approval process as initial applications  Of the 40 application files that we reviewed, 29 were continuations and 8 were initial requests for a retention incentive  According to BOP officials, after the initial approval of a retention incentive, an institution’s human resources office has primary responsibility for the monitoring of retention incentive payments  According to officials, institutions use a variety of internal controls to monitor the expiration, continuation, or termination of retention incentives, for example: Monitoring expiration dates  BOP officials stated that institutions’ human resources offices monitor retention incentives in order to identify incentives that are approaching their expiration date and need to be terminated or renewed  For example, according to BOP officials from USP Atwater, FCC Butner and FCI Phoenix, staff from their institutions’ human resources offices may generate a retention incentive activity report and cross reference this report with their locally generated tracking sheets  This process helps identify retention incentives approaching their expiration dates so that the human resources offices can submit a request for continuation before the incentive expires  Using automated reminders to prompt file review  BOP officials stated that institutions use automated reminders to alert human resources staff to check the records of retention incentive recipients for human resources-related events such as promotions or relocations that could affect the continuation of a retention incentive  Following a checklist of steps for relocation processes  BOP officials told us that in April 2016 they instituted a checklist that outlines steps that an institution’s human resources staff must take when employees relocate to a different institution  Based on our review of this checklist, one step on the sheet prompts human resources staff to review the employee’s retention incentive  According to BOP policy, when an employee receiving a retention incentive transfers to another location, the human resources office where the employee was receiving the retention incentive is responsible for submitting a request to terminate the incentive  The termination must be effective the last day of the pay period that the employee occupies the position  Submitting forgiveness waivers  BOP officials told us that institutions submit forgiveness waivers if a request to continue a retention incentive is not submitted and approved prior to the retention incentive expiring  BOP officials said that a forgiveness waiver is considered an acknowledgement of an administrative error and is a late submission of a retention incentive renewal that was still warranted  The waiver is not a request to forgive an overpayment since the employee was still considered to be eligible for the retention incentive  Of the 40 retention incentive applications that we reviewed, 5 applications included forgiveness waivers to excuse the tardiness of the filing and request continuations of the retention incentive  According to BOP officials, BOP conducts periodic audits and reviews of its human capital activities and related internal controls, to ensure that retention incentives are being used appropriately  The following offices conduct various audits and reviews involving BOP’s retention incentives: BOP’s Program Review Division (PRD) audits regional and institutional human resources functions  PRD audits BOP’s regional and institutional human resources offices to ensure that they are in compliance with BOP policies and procedures  According to BOP officials, as part of the audit process, PRD audits retention incentives to ensure that they have the proper approvals and are justified  PRD audits each institution’s human resources office at least every three years  During these audits, PRD generates retention incentive activity reports (the same reports that institutions run when monitoring for expiration dates), to check the accuracy of retention incentive programs under review  Following each audit, PRD issues a final report with findings to the institution and to the staff operating the program area under audit  Institutions respond to the report with corrective actions that the institution will take to address the findings  When the institution has resolved all corrective actions from the audit, the audit is closed  Additionally, each quarter, PRD provides HRMD with a report that summarizes its quarterly audit findings  According to BOP officials, HRMD uses these reports to identify any agency-wide trends that need to be addressed  Our review of BOP data showed that between fiscal years 2012 and 2016, PRD conducted nearly 200 audits  For example, in the fourth quarter of fiscal year 2016, PRD audited five institutions’ and regional offices’ human resource management functions  During these audits, PRD identified nine deficiencies, one of which pertained to retention incentives  Specifically, it found that one audited institution did not terminate an employee’s retention incentive after the employee had relocated to another institution  To correct the deficiency, the institution cancelled the retention incentive which discontinued future disbursements  According to BOP officials, a bill was generated to recoup the overpayment from the employee  BOP institutions conduct annual operation reviews of internal functions, such as human resources  BOP officials told us that each institution conducts annual operational reviews of various internal functions, such as human resources  According to BOP’s Program Review Guidelines for Human Resource Servicing Offices, during these reviews, institutions are required to review supporting documentation for staff currently receiving an incentive to determine if the incentives are still warranted  If the initial request for the retention incentive was made over the preceding 12 months, institutions are also required to ensure that it was approved  According to BOP officials, the results of these reviews are reported to PRD through the Central Office  DOJ’s Justice Management Division (JMD) audits BOP’s human resources programs  According to BOP officials, JMD conducts audits of component-level human resources programs to determine whether BOP’s systems are compliant with DOJ policy and aligned with DOJ’s Human Capital Strategic Plan  JMD’s most recent audit of BOP’s human resources programs that included a review of BOP’s retention incentives occurred in September 2010 at BOP’s Human Resource Service Center in Grand Prairie, Texas  JMD found that in some cases BOP granted retention incentives prior to the signing of service agreements  JMD also found that BOP lacked documentation to authorize a group retention incentive for employees at its Victorville, California institution  BOP’s written response to the findings stated that JMD incorrectly applied the service agreement requirement, as service agreements were not warranted in the specific case that it identified  Additionally, BOP stated that the documents JMD identified as missing from the case files in question were kept in separate files and not required to be part of the retention incentive application  JMD agreed with BOP’s responses and in January 2013, JMD closed out the audit’s findings noting that these responses satisfied all required corrective actions  While BOP takes a number of steps to determine current workforce needs and how to fill those needs, BOP does not strategically plan for how retention incentives can be used to meet long-term human capital goals  BOP officials stated that planning for human capital needs is conducted at institutions during quarterly workforce utilization meetings or manpower salary meetings  During these meetings, executive staff at the institution discuss the current state of the institution’s workforce  According to the BOP officials, while considering attrition, hiring, and turnover rates, the executive staff decide strategies they will employ to attract and retain employees for their current needs  While officials we spoke with at four institutions have discussed retention incentives at their workforce utilization meetings, details about the content of these discussions ranged  According to these officials and our review of meeting minutes from the four institutions, discussions about retention incentives respond to each institution’s short-term staffing situation rather than address future staffing needs based on an overall strategic human capital plan  For example: USP Atwater officials told us that they review the current turnover rate, budget, projected vacancies, and use of retention incentives at annual budget development meetings  Meeting minutes reflected the following on retention incentives: “retention … still necessary to retain staff and hard-to-fill positions ” FCC Butner is a medical facility that offers retention incentives to all medical officers (all types of doctors) and nurses (practitioners, registered, etc ) at the institution  According to Butner officials, during workforce utilization meetings, Butner officials discuss recruitment and staffing trends for the institution and plans for how to address any staffing challenges  Meeting minutes we reviewed did not indicate specific discussions about the use of retention incentives  FCC Pollock executive staff discuss current institutional salary expenditures and projections and the status of vacant positions at workforce utilization meetings  While meeting minutes we reviewed indicated discussions about projected expenditures for incentive awards, the minutes did not differentiate between retention incentive awards, and other incentive awards such as recruitment or relocation incentive awards  FCI Phoenix officials stated that in their workforce utilization meetings, executive staff discuss salary projections and vacancy statuses  Meeting minutes we reviewed did not indicate specific discussions about the use of retention incentives  BOP decisions about retention incentives are currently not tied to any strategic human capital plan for how to use human capital flexibilities— such as retention incentives—to address their ongoing challenge of retaining staff in hard-to-fill positions  According to officials, retention incentives are awarded on an as-needed basis, determined by an institution’s warden, if funds are available  According to key principles for effective strategic human capital planning, such planning is an important component of an agency’s effort to develop long-term strategies for acquiring, developing, and retaining staff needed for an agency to achieve its goals  Specifically, senior leaders should be involved in developing, communicating, and implementing strategic human capital plans  Within an agency’s strategic human capital plan, the human capital policies, practices, and programs—for example, an agency’s retention incentive program—should clearly link to the human capital and program goals of the organization  By not having a strategic human capital plan that clearly establishes strategies that will be used to achieve specific human capital goals, BOP cannot ensure that its institutions are strategically managing their workforces in a manner that meets the agency’s human capital needs  In August 2017, BOP officials told us that they began drafting a strategic human capital operating plan that will include strategic objectives, action plans, performance objectives and measures, and evaluation/reporting requirements  Officials stated that the plan will also include planning regarding the use of human capital flexibilities, such as retention incentives  BOP officials told us that they anticipate that the strategic human capital operating plan will be a supplement to their workforce utilization meetings and that an agency-wide plan will provide a set of strategies for all institutions to consider  However, BOP could not provide documentation of the project beginning or whether it would include a strategic approach specific to retention incentives  Including retention incentives in BOP’s strategic human capital operating plan would create a roadmap for the agency and the institutions to use to move from being reactive in their current workforce needs—for example, awarding retention incentives on an ad hoc basis when funds are available—to being strategic in how retention incentives are used and to ensure that these and other flexibilities help the agency achieve its long-term workforce goals  From fiscal year 2012 through fiscal year 2016, BOP spent more than $59 million on retention incentives but has not established any measures to evaluate their effectiveness  According to officials, BOP has not evaluated the effectiveness of its use of retention incentives because BOP officials consider a retention incentive successful if an employee does not leave the agency  However, BOP also uses other human capital flexibilities along with retention incentives to help retain staff  For example, BOP uses physician and dental comparability allowances—additional pay to a physician or dentist who enters into an agreement for a specified period of service—to help retain these medical personnel  According to officials, it would otherwise be difficult to compete with private sector salaries without the use of all available incentives  However, BOP has not studied whether or how retention incentives have contributed to employees’ retention in relation to other incentives such as physician and dental comparability allowances  According to our work on strategic human capital management and OPM’s guidance, it is crucial for organizations to evaluate the success of their human capital strategies, such as the use of retention incentives  In measuring the performance of these strategies and their contribution to key programmatic results, agencies can make adjustments, if necessary  For example, agencies can use evaluation results to make targeted investments in certain human capital strategies—such as the use of retention incentives—creating a cycle of strategic workforce management, where evaluation informs planning, planning dictates strategies, and strategies are evaluated for effectiveness  While BOP uses retention incentives to address critical skills gaps—such as with medical professionals—evaluating the effectiveness of retention incentives would help BOP determine whether and how retention incentives, as well as other human capital flexibilities, contribute to an employee’s continued employment at BOP or if adjustments to BOP retention strategies must be made for improved results  BOP officials agreed that evaluating the effectiveness of retention incentives would help them be more strategic about their human capital needs and spending on incentives  By including and implementing such an evaluation in its upcoming strategic human capital operating plan, BOP could better determine if it is making maximum use of its funds to retain the necessary qualified personnel or if changes must be made to most effectively retain its staff  As the largest employer within DOJ with some staff working in remote locations and undesirable conditions, BOP relies on a number of available flexibilities, including retention incentives, to help retain its employees  However, BOP currently lacks a strategic approach for using and evaluating retention incentives to address human capital goals  Given BOP’s ongoing staffing challenges, for example, retaining staff in hard-to- fill medical positions, developing a plan that includes a thoughtful blueprint for using retention incentives could help BOP better anticipate and address staffing needs  Moreover, evaluating its use of retention incentives could help BOP determine whether these incentives are effective or whether adjustments are needed to better retain its employees  By using evaluation results to inform planning, and planning to inform how retention incentives are used, BOP would be better positioned to achieve its long-term human capital goals and address its critical staffing needs  We are making two recommendations to BOP: 1  The Director of BOP should include in the forthcoming strategic human capital operating plan, 1) human capital goals and 2) strategies on how human capital flexibilities—including retention incentives—will be used to meet these goals  (Recommendation 1) 2  The Director of BOP should evaluate the effectiveness of BOP’s use of retention incentives to help determine whether the incentives have helped BOP achieve its human capital goals or if adjustments in retention incentives are needed  (Recommendation 2) We requested comments on a draft of this report from DOJ  In an email received November 15, 2017, the DOJ liaison stated that DOJ concurred with our recommendations  The Department did not provide official written comments to include in our report, but did provide written technical comments, which we incorporated as appropriate  As agreed with your office, unless you publicly announce the contents of this report earlier, we plan no further distribution until 30 days from the report date  At that time, we will send copies of this report to the Attorney General and the Director of BOP  In addition, the report 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 (202) 512-9627 or maurerd@gao gov  Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report  GAO staff who made key contributions to this report are listed in Appendix III  This report examines (1) how BOP has used its authority to pay retention incentives; (2) what internal controls are in place for the use of retention incentives; and (3) the extent to which BOP plans for and evaluates the use of retention incentives  To determine how BOP has used its authority to pay retention incentives, we reviewed BOP’s July 2012 report on its use of recruitment, relocation, and retention (3R) incentives  We then obtained underlying retention incentive expenditure data from DOJ’s Justice Management Division because it serves as the focal point for performance and financial information for all Department of Justice components and employees, including BOP  In particular, we obtained employee-level retention incentive payroll data for fiscal years 2012 through 2016  We selected this time period because it includes the most recent five complete fiscal years for which data were available and because we believe five years is sufficient time to identify trends in BOP’s retention incentive expenditures  We analyzed and aggregated the employee-level data by institution, occupation, and employee grade level  To identify trends, we compared per fiscal year expenditures across the various categories of occupations and locations across the five years  Additionally, we categorized institutions by BOP region, institutions that use group retention incentives, and institutions that use individual retention incentives  We also categorized occupations as medical professionals, correctional officers, and all other occupations and compared aggregate retention incentive expenditures for the different groups  Using information from BOP’s website and testimonial evidence from BOP officials on its health care system, for the purposes of this report, we defined medical professionals as BOP employees in occupations that provide medical, dental, and mental health care services and who do not solely provide these services in an administrative function  For the purposes of our analyses, medical professionals are dentists, dental assistants and hygienists, diagnostic radiological technologists, health aid and technicians, medical doctors (including psychiatrists), medical technologists, nurses, pharmacists, pharmacy technicians, physician assistants, and practical nurses and psychologists  To assess the employee-level retention incentive payroll data’s reliability, we obtained and analyzed documentation on systems’ capabilities and data control, interviewed data users and managers responsible for maintaining data, conducted checks for completeness and logical consistency, and compared the employee-level data to aggregated institution-level retention incentive expenditure data from BOP’s Financial Management Information System  We found the employee-level data to be sufficiently reliable for the purpose of this report  Additionally for this objective, we reviewed documents such as the DOJ’s Financial Management Information System Sub-Object Classification Code Guide and the Office of Personnel Management (OPM) Handbook of Occupational Groups and Families to respectively identify the system codes used to track retention incentives expenditures and to identify the names for each occupational series code in the datasets  We also interviewed BOP Human Resource Management headquarters officials to obtain information on the primary purposes for BOP’s use of retention incentives and their views on identified retention incentive expenditures trends  We also interviewed U S  Department of Health and Human Services’ (HHS) Public Health Service (PHS) officials to better understand how BOP and PHS manage costs, including retention incentive expenditures, for PHS staff assigned to BOP  BOP partners with PHS to acquire medical staff to provide medical care for BOP’s inmate population  BOP reimburses PHS for the costs of compensation and benefits—including retention incentive payments, if applicable—for PHS staff assigned to BOP  PHS has final approval authority for retention incentives paid to PHS staff assigned to BOP facilities  Furthermore, we obtained aggregated retention incentive expenditure data from PHS on the total amount of funds BOP reimbursed PHS for fiscal years 2012 through 2016  For the reliability of PHS’s data, we reviewed the system’s data fields to check that the appropriate fields were used to provide data and interviewed data users and managers to discuss how expenditures are recorded and maintained  We found the PHS data to be sufficiently reliable for the purpose of this report  To identify and describe the internal controls that BOP has in place related to retention incentives, we obtained and analyzed documentation regarding BOP requirements and guidance for the use of retention incentives  We also interviewed officials from BOP’s Central Office who are responsible for the administration, management, and oversight of BOP’s human capital management systems, including retention incentives  We focused on the management and administrative controls used by BOP to review, approve, re-certify, and monitor retention incentives  Additionally, we interviewed the warden and human capital officers at 4 of the 122 institutions to obtain illustrative examples regarding the internal controls in place at these institutions to ensure the proper disbursement of retention incentives  We interviewed BOP officials at Federal Correctional Complex Pollock in Pollock, LA; Federal Correctional Complex Butner in Butner, NC; United States Penitentiary, Atwater in Atwater, CA and Federal Correctional Institution Phoenix, in Phoenix, AZ  These institutions were selected to ensure variation in the number and types of employees receiving retention incentives, BOP region, and security-level  Although the information we obtained from the interviews with officials at these four institutions cannot be generalized to other BOP institutions, these interviews provided important insights and perspectives about the use of retention incentives at BOP institutions  We also reviewed a non-generalizable random sample of 40 retention incentive application packet case files to determine the extent to which these files contained documentation on the internal control activities in place to monitor the application, approval, and funds disbursement processes of BOP’s retention incentive program  To identify our sample, we used employee-level expenditure data to randomly select 40 application files from the universe of BOP employees who received retention incentives from fiscal years 2014 through 2016  Each application file was reviewed by two GAO analysts who each assessed the extent to which each application contained the appropriate justification, approval signatures, and other documentation such as an application checklist and whether the application was an initial or continuation application  To determine the extent to which BOP plans for and evaluates the use of retention incentives, we interviewed BOP officials regarding their experiences with retention incentives, how they use retention incentives to strategically manage their workforce needs, how the agency evaluates the effectiveness of retention incentives, and how retention incentives contribute to BOP’s broader human capital goals  We then compared these efforts to our work on strategic human capital planning, specifically in terms of planning for and evaluating the use of human capital flexibilities  Additionally, we interviewed the warden and human capital officers at four BOP institutions mentioned above to obtain illustrative examples of how workforce planning occurs at these institutions  We also reviewed the DOJ’s Office of Inspector General Report 16-02 “Review of the Federal Bureau of Prisons’ Medical Staffing Challenges” (March 2016) and our past work to better understand the challenges that BOP faces in retaining medical professionals and other staff  Table 2 provides the Bureau of Prisons’ (BOP) fiscal year 2016 retention incentive expenditures by various occupations and groups of occupations, such as medical professionals, correctional officers, and other occupations  A range of occupations are reflected in the table primarily as a result of four California institutions—United States Penitentiary (USP) Atwater, Federal Correctional Institution (FCI) Herlong, FCI Mendota, and Federal Correctional Complex Victorville—providing retention incentives to all employees at General Schedule grades level 12 and below and those in the Federal Wage System  In addition to the contact named above, Dawn Locke (Assistant Director) and Meghan Squires (Analyst-in-Charge) managed the work  Also, David Alexander, Renee Caputo, Willie Commons III, Jamarla Edwards, Robert Goldenkoff, Chelsa Gurkin, Eric Hauswirth, Janice Latimer, Lerone Reid, Rachel Stoiko, and Adam Vogt made significant contributions to this report 

ground_truth: The Land and Water Conservation Fund (LWCF) Act of 1965 (P.L. 88-578) created the LWCF in the Treasury as a funding source to implement the outdoor recreation goals set out by the act. The LWCF Act authorizes the fund to receive $900 million annually, with the monies available only if appropriated by Congress (i.e., discretionary appropriations). The fund also receives mandatory appropriations under the Gulf of Mexico Energy Security Act of 2006 (GOMESA). The level of annual appropriations for the LWCF has varied since the origin of the fund in FY1965. The LWCF Act outlines uses of the fund for federal and state purposes. Of the total made available through appropriations or deposits under GOMESA, not less than 40% is to be used for "federal purposes" and not less than 40% is to be used to provide "financial assistance to states." The act lists the federal purposes for which the President is to allot LWCF funds "unless otherwise allotted in the appropriation Act making them available." These purposes primarily relate to acquisition of lands and waters (and interests therein) by the federal government. With regard to state purposes, the act authorizes a matching grant program to states for outdoor recreation purposes. Throughout the LWCF's history, appropriations acts typically have provided funds for land acquisition and outdoor recreational grants to states. Beginning in FY1998, appropriations also have been provided each year (except FY1999) to fund other purposes related to natural resources. The extent to which the LWCF should be used for purposes other than federal land acquisition and outdoor recreation grants to states, and which other purposes should be funded from the LWCF, continue to be the subject of legislation and debate in Congress. In the past few decades, Presidents have sought LWCF funds for a variety of other purposes. Congress chooses which if any of these requests to fund, and has chosen programs not sought by the President for a particular year. Among other programs, appropriations have been provided for facility maintenance of the land management agencies, ecosystem restoration, the Historic Preservation Fund, the Payments in Lieu of Taxes program, the Forest Legacy Program, State and Tribal Wildlife Grants (under the Fish and Wildlife Service), the Cooperative Endangered Species Conservation Fund, U.S. Geological Survey science and cooperative programs, and Bureau of Indian Affairs Indian Land and Water Claim Settlements. Since FY1998, a total of $2.7 billion has been appropriated for other purposes, of a total LWCF appropriation of $18.9 billion over the history of the fund. The Fish and Wildlife Service and the Forest Service have received the largest shares of the total appropriations for other purposes, about $1.4 billion (53%) and $1.0.billion (38%), respectively, from FY1998 to FY2019. Several agencies shared the remaining $0.2 billion (9%) of the appropriations. Both the dollar amounts and the percentages of annual LWCF appropriations for other purposes have varied widely since FY1998. The dollar amounts have ranged from $0 in FY1999 to $456.0 million in FY2001. The percentage of annual funds provided for other purposes ranged from 0% in FY1999 to a high of 59% in both FY2006 and FY2007. In some years, the appropriation for other purposes was significantly less than the Administration requested. For instance, for FY2008, the George W. Bush Administration sought $313.1 million; the appropriation was $101.3 million. The appropriation for other purposes last exceeded $100.0 million in FY2010, and most recently was $93.3 million, in FY2019. Prior to FY2008, several other purposes typically were funded each year from LWCF. Since FY2008, funds have been appropriated annually only for grants under two programs: Forest Legacy and Cooperative Endangered Species Conservation Fund. These two programs and a third grant program—State and Tribal Wildlife Grants—have received more than three-quarters ($2.1 billion, 79%) of the total appropriation for other purposes since FY1998.

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



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

Report 1: Created in 1968, the SFSP is authorized under the Richard B  Russell National School Lunch Act and generally provides free meals to children age 18 and under in low-income areas during certain periods when school is not in session  Specifically, the SFSP operates during school summer vacation periods between May through September, vacation periods in any month for programs operating on a continuous school calendar, and certain other times for areas affected by an unanticipated school closure, such as for a natural disaster  However, the majority of SFSP meals are served to children during the summer months  In fiscal years 2007 through 2016, federal expenditures on SFSP increased, according to FNS data, though there was a slight decrease between fiscal years 2015 and 2016 (see fig  1)  The SFSP is administered at the federal level by FNS through its national and regional offices  FNS is responsible for issuing regulations, instructions, and guidance; reviewing states’ program management and administration plans; overseeing program administration; and reimbursing states for meals served that meet program requirements  At the state level, the program is administered by state agencies and locally operated by state-approved sponsors, such as school districts, local government entities, or private nonprofit organizations  State agencies are responsible for approving, providing training to, and inspecting and monitoring sponsors and meal sites  Sponsors, in turn, are responsible for monitoring their SFSP meal sites, managing the meal service, and providing training to administrative staff and site operators  A sponsor may operate one site or multiple sites  Sites are physical locations in the community where children receive and consume meals in a supervised setting  According to FNS guidance, sites may be located in a variety of settings, including schools, parks, community centers, health clinics, hospitals, apartment complexes, churches, and migrant camps  States may approve different types of SFSP meal sites, including open sites, closed enrolled sites, and camps  Open sites operate in an area where at least half of the children are eligible for free or reduced-price school meals (referred to as “area eligible”), according to data from entities such as schools or the U S  Census Bureau  Children are generally eligible for free or reduced-price school meals if their households have incomes at or below 185 percent of federal poverty guidelines  At open sites, meals are made available to all children in the area, and all meals served that meet program requirements are reimbursable  Closed enrolled sites, on the other hand, are open only to enrolled children, as opposed to the community at large  At closed enrolled sites, meals served to all children in attendance are reimbursable as long as at least half of the enrolled children are eligible for free or reduced-price school lunch  Unlike other types of sites, camps are reimbursed only for meals served to children who have been individually determined to be eligible for free or reduced-price school meals  SFSP meals must meet certain requirements in order to be eligible for federal reimbursement; for example, the meals must be served and consumed on-site at an approved site  Federal reimbursements for summer meals are provided for each breakfast, lunch, supper, or snack served to an eligible child at an eligible site that also meets federal requirements for menu components, scheduled meal times, and nutrition  For example, to meet nutritional requirements, a lunch or a supper must, at a minimum, include four components: 2 ounces of meat or a comparable serving of a meat alternate, 3/4 cup of fruits and/or vegetables (at least two kinds), a slice of bread or a comparable serving of another grain, and a cup of milk  In 2017, the federal reimbursement rate was $3 83 or $3 77 for each eligible SFSP lunch or supper served, depending on the type of meal site  Each site may serve up to two meals or one meal and one snack per day  Some flexibilities are available to FNS in implementing the SFSP program, under its waiver and demonstration authorities  Specifically, the National School Lunch Act authorizes the Secretary of Agriculture to waive, upon request of a state or eligible service provider, certain program requirements established under the National School Lunch Act or the Child Nutrition Act of 1966, as amended, including some for the SFSP  In order to grant a waiver request, the Secretary must determine that the waiver would facilitate the state or service provider’s ability to carry out the purpose of the program, and that the waiver will not increase the overall cost of the program to the federal government, among other things  In the event a waiver request is submitted, the Secretary is required to act promptly and state in writing whether the waiver request is granted or denied, and why  The Secretary is also required to periodically review the performance of waiver recipients, and submit an annual report to Congress summarizing the use of waivers and their effectiveness, among other details  In addition to this waiver authority, the Secretary is also authorized to carry out demonstration projects to develop and test methods of providing access to summer meals for low-income children in urban and rural areas, to reduce or eliminate the food insecurity and hunger of low-income children and improve their nutritional status  The Secretary is required to provide for an independent evaluation of the demonstration projects carried out under this authority, and submit an annual report to Congress on the status of each project and the results of the evaluations  The total number of SFSP meals served nationwide during the summer— one indicator of program participation—increased from 113 million meals in fiscal year 2007 to 149 million meals in fiscal year 2016, or by 32 percent, according to our analysis of FNS data  The number of SFSP meals served has generally increased from year to year over this 10-year period  Most recently, meals decreased by 6 percent from 156 million meals in summer 2015 to 149 million meals in summer 2016, according to our analysis of FNS data (see fig  2)  Factors that may have affected year-to-year fluctuations include changes in funding for summer programs, sponsor participation, weather, and the number of weekdays available for sites to serve meals within a given summer, according to FNS and state agency officials we interviewed  For example, state agency officials in one of the three selected states we visited said they believe that reductions in state and local funding for summer programs that also provide meals, and turnover of sponsors, including losing one of the state’s largest sponsors in a recent summer, affected the total number of SFSP meals served in their state in 2016  According to our analysis of FNS data, SFSP lunches served in the summer months increased by over 17 million from fiscal year 2007 through fiscal year 2016, accounting for almost half of the total increase in the number of SFSP meals served in that period  However, when comparing across each of the meal types, supper and breakfast had the largest percentage increases over the 10-year period, 50 and 48 percent, respectively (see table 1)  In comparison, the number of SFSP lunches served increased by 26 percent from fiscal years 2007 through fiscal year 2016  From fiscal year 2007 through fiscal year 2016, there were increases in the numbers of meals served in both SFSP and NSLP, the largest child nutrition assistance program  Specifically, SFSP lunches served in July increased from 32 million to 40 million, or 24 percent, from fiscal year 2007 to 2016, and NSLP lunches served in March increased from 328 million to 376 million meals, or 15 percent, according to our analysis of FNS data  Although the programs generally serve similar populations, different factors likely affected the number of meals served by each program, in part because NSLP serves children in schools during the school year and SFSP serves children in a variety of settings during the summer months  Although states report the actual number of SFSP meals served to FNS, they estimate the number of children participating in SFSP, and information obtained from our state survey and FNS indicate that these participation estimates have been calculated inconsistently  FNS instructs state agencies on how to calculate a statewide estimate of children’s participation in the SFSP, referred to as average daily attendance (ADA), using sponsor-reported information on the number of meals served and days of operation in July of each year  However, states’ methods for calculating ADA have differed from state to state and from year to year, according to our review of states’ survey responses and FNS documents  For example, although FNS directed states to include the number of meals served in each site’s primary meal service— which may or may not be lunch—some states, according to our survey and FNS data, were calculating ADA using only meals served at lunch  FNS officials told us that these states were therefore not following the agency’s instructions  Further, some states have changed their methods for calculating ADA over time—five states reported in our survey that the method they used to calculate ADA in fiscal year 2016 differed from the one they used previously  While FNS clarified its instructions in May 2017 to help improve the consistency of states’ ADA calculations moving forward, ADA remains an unreliable estimate of children’s daily participation in SFSP for at least two reasons, according to our analysis  (See sidebar for the revised ADA calculation instructions ) First, ADA is based on summary data that does not account for existing variation in site days of operation, and second, it is based on July data, which does not reflect the month with the greatest number of meals served in every state  According to our analysis, ADA is an unreliable estimate of children’s participation in SFSP because it currently does not account for existing variation in the number of days that each site serves meals to children  Specifically, because FNS’s instructions indicate that sites’ ADAs are to be combined to provide a statewide ADA estimate, differences in the number of days of meal service are disregarded  As a result, ADA does not reflect the average number of children served SFSP meals daily throughout the month  Our analysis of site-level data from one of the selected states illustrates this limitation  In this state, multiple sites reported an ADA of 60 for July, yet two of those sites served meals to children on only 1 day of the month and another site served meals to children on 20 days  Although 120 children were served SFSP meals only 1 day in July across two of these sites, the combined ADA across all three sites, which we calculated following FNS’s instructions, inaccurately suggests an average of 180 children were participating in SFSP at these sites on a daily basis in July  According to our analysis, ADA is also an unreliable estimate of children’s participation in SFSP because it currently does not account for state variation in the month with the greatest number of SFSP meals served, potentially leading to an underestimate  According to FNS officials, the agency instructs states to calculate ADA for July because officials identified this as the month with the largest number of meals served nationwide  However, because of reasons such as state variations in school calendars, July is not the month with the largest number of meals served in every state  In one of the selected states, Arizona, using July to calculate ADA cuts the estimate almost in half  Specifically, we followed FNS’s instructions and calculated that Arizona’s ADA was 14,987 in July 2016 compared to 26,772 in June 2016  Nationwide, in summer 2016, 26 states served more SFSP meals in June or August than in July, according to our analysis of FNS data  However, without site level data on meals served and operating days, the extent to which these states had higher ADAs in June or August as compared to July is unknown  In its May 2017 memo to states revising the ADA calculation instructions, FNS said that it is critical that the agency’s means of estimating children’s participation in the SFSP is as accurate as possible because it helps inform program implementation at the national level and facilitates strategic planning and outreach to areas with low participation  In addition, Standards for Internal Control in the Federal Government state that agencies should maintain quality data and process it into quality information that is shared with stakeholders to help achieve agency goals  Although FNS has also collected information on other data that states collect on the SFSP, the agency has not yet used this information to help improve its estimate of children’s participation in the program  In 2015, FNS published a Request for Information, asking whether states or sponsors collect any SFSP data that are not reported to FNS  While FNS received responses from only 15 states, these responses suggest that some states collect additional data, such as site-level data that may allow for an improved estimate of children’s SFSP participation, potentially addressing the issues we found in our analysis  In response to the information FNS received, they followed up with up to 9 of the 15 states in 2016 and 2017 to explore the feasibility of collecting additional data and improving estimates of children’s participation  Although they took these steps, FNS officials told us they are cognizant of the burden on states and site operators that would be associated with additional reporting requirements  At this time, the agency has not taken further action to improve the estimate, such as addressing the reliability issues caused by variation in the number of operating days of meal sites and in the months with the greatest number of meals served by state  As a result, FNS’s understanding of children’s participation in the SFSP remains limited, which impairs its ability to both inform program implementation and facilitate strategic planning and outreach to areas with low participation  Other federal programs that operate solely in the summer, as well as those operating year-round, help feed low-income children in the summer months  These programs include the NSLP Seamless Summer Option, which provides nutrition assistance benefits solely in the summer, and several federal programs that operate year-round  In July 2016, in addition to the 70 million meals provided through the SFSP, 26 million meals were provided to low-income children through school food authorities participating in the NSLP’s Seamless Summer Option, according to FNS data  The Seamless Summer Option was established in 2004, and according to FNS, streamlines administrative requirements to encourage school food authorities providing free or reduced-price meals during the school year under the NSLP and SBP to continue providing meals to low-income children when school is not in session  For example, officials from a national organization involved in summer meals told us the Seamless Summer Option makes it easier for school food authorities to provide summer meals because they continue working with the same state agency, reporting the same information to the state, and operating without having to transition to a separate program  Nonetheless, school food authorities can choose to provide free summer meals to children through either the SFSP or Seamless Summer Option, and the majority of states (34) reported in our survey that a greater proportion of school food authorities participated in the SFSP than the Seamless Summer Option in summer 2016  According to FNS and selected state officials, this may be related to the generally lower meal reimbursement rates school food authorities participating in the Seamless Summer Option receive compared to the rates received by those participating in the SFSP  In summer 2016, the Seamless Summer Option added to the geographic availability of summer meal sites in two of the three states we visited as part of our review  School food authorities provided summer meals through the Seamless Summer Option in Arizona and Illinois, but not in Massachusetts, based on our analysis of data provided by these states  In Arizona and Illinois, school food authorities participating in the Seamless Summer Option added 643 and 298 summer meal sites, respectively, in the month with the largest number of SFSP meals served in each state (see fig  3)  In addition, some of the Seamless Summer Option sites in these two states provided meals to children in areas where there were no SFSP sites  For example, Seamless Summer Option sites provided meals in areas near the northeastern and southwestern corners of Arizona that lacked nearby SFSP sites  In addition to the SFSP and the Seamless Summer Option, the Summer Electronic Benefit Transfer for Children (Summer EBT) demonstration provided nutrition assistance benefits to 209,000 low-income children in summer 2016 in select areas across 6 states and 2 Indian Tribal Organizations, according to FNS officials  Since the summer of 2011, Summer EBT benefits have been provided to eligible households on an electronic benefits transfer card, which households use to purchase eligible foods at authorized retailers  Specifically, the demonstration has provided monthly benefits of $30 or $60 per eligible child to households with children in areas with a perceived high level of need, based on the demonstration grantees’ assessments of the percentage of children eligible for free or reduced-price school meals and the availability of the SFSP  Consistent with this, three of the states that participated in Summer EBT in 2016 reported through our survey that these benefits helped children who were unable to access summer meals through the SFSP or the Seamless Summer Option  Further, according to an FNS- funded evaluation, Summer EBT improved food security among low- income children who participated in the demonstration  Specifically, the evaluation found the receipt of these benefits reduced the number of children in the demonstration experiencing very low food security between 2011 and 2013 by one-third  Some low-income children also receive nutrition assistance in the summer through federal programs that operate year-round  According to FNS data, in June 2016, 5 8 million infants and children participated in the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) and 3 million children participated in the Child and Adult Care Food Program (CACFP)  In addition, an average of 19 2 million children participated each month in the Supplemental Nutrition Assistance Program (SNAP) in fiscal year 2016, according to FNS data  These benefits are provided year-round, including when school is in session and children may also be eligible to receive school meals  In our previous work on federal domestic food assistance programs, we reported that no one program alone is intended to meet a household’s full nutritional needs  At that time, several officials and providers told us that the variety of food assistance programs offers eligible individuals and households different types of assistance and can help households fill the gaps and address the specific needs of individual members  For example, a mother with two children may rely on SNAP for her household’s basic groceries, the NSLP to feed a school-age child during the school year, and WIC to obtain supplemental foods for herself and an infant  Some low-income children also receive summer meals through nonfederal programs, according to our state survey and interviews with organizations involved in summer meals  Twenty-seven states reported in our survey that they were aware of other state- or non-state-funded programs that provided children of low-income households with meals in their states during the summer months  According to our analysis of state survey responses, local faith-based organizations and foodbanks were the most common types of entities operating these types of programs  Similarly, officials from FNS and two regional organizations we interviewed said they were aware of children receiving summer meals through nonfederal programs operated by faith- based and other community organizations  In addition, SFSP site operators at 6 of the 30 meal sites we visited in the selected states told us nearby foodbanks and faith-based organizations may also be providing children with free meals to some extent  For example, one of the meal sites we visited was operated by a foodbank that, in addition to the SFSP, provided food boxes to those in need and distributed food to other local community organizations to provide to persons in need of immediate assistance, including families with children  Although FNS and the majority of states do not collect data on nonfederal programs, results from our state survey and interviews with SFSP providers and organizations involved in summer meals indicate the reach of nonfederal programs is limited  In our survey, states reported that the geographic coverage of these nonfederal programs varied by state, with 11 states indicating that they operated in some portions of the state—the most common state response  In addition, 16 states reported that they were not aware of any nonfederal programs providing summer meals to children in their state (see fig  4)  Similarly, SFSP site operators at 24 of the 30 meal sites we visited were unaware of nonfederal programs providing meals to children in the areas in which they operated  In addition, officials from several national organizations involved in summer meals told us children have very few options for receiving summer meals beyond the federal summer meals programs  Specifically, officials from one national organization explained that food is often a significant part of the cost of a summer activity program for children and suggested that is one reason why organizations choose to participate in the SFSP  Although the SFSP provides for federal reimbursement of eligible meals and certain administrative and operating costs, nonfederal programs that provide children with summer meals may choose not to participate in the SFSP for several reasons, according to officials we interviewed from several organizations involved in summer meals  For example, some nonfederal program providers may not participate in the SFSP because they are unaware the program exists  Additionally, some nonfederal program providers may be aware of the SFSP, but choose not to participate because they do not want to follow certain program requirements, such as the nutrition or meal pattern standards  In addition, some providers may not participate in the program because they do not think they can handle certain aspects of the administrative workload associated with the SFSP  For example, a state official we interviewed told us the administrative workload associated with the SFSP can be particularly challenging, especially for smaller sponsors  Similarly, officials from a regional organization involved in summer meals told us one of the providers they work with who operated 10 meal sites chose to leave the SFSP because the paperwork required to operate the sites was too administratively burdensome for their volunteer site operators  States and SFSP providers reported challenges with meal sites, participation, and administration, though federal, state, and local entities have taken steps to improve these areas  Half or more of states reported in our survey that SFSP issues related to meal site availability, such as in rural areas, increasing children’s participation, and program administration were moderately to extremely challenging (see fig  5)  Overall, 41 states reported facing at least one challenge with the SFSP, while 9 reported facing none  Availability of transportation, low population density, and limited meal sites pose challenges for SFSP in rural areas, according to states we surveyed, selected national organizations, and state and local officials in the three selected states we visited  More than two-thirds of states in our survey reported they faced a moderate to extreme challenge with limited options in rural areas to transport children to summer meal sites (37), as well as with the distance to summer meal sites in rural areas resulting in low child turnout that affects the financial viability of site sponsorship (36)  As officials from one national organization explained, it may not be cost- effective for sponsors to operate in remote or rural areas if there are not enough meal sites or children participating in the program  Similarly, a sponsor in one of the selected states indicated that there are large parts of the state where the distances between meal sites are substantial, and travel between them takes several hours  An official from one of the selected states said transportation challenges can lead to underserved rural areas, including Indian reservations  Of the three states we reviewed, each had rural areas with few or no federally funded meal sites in summer 2016  However, a majority of the children in some of those areas were eligible for free or reduced price school meals, according to Census data provided by FNS, and would therefore be “area eligible” for the purposes of SFSP  For example, as shown in figure 6, “area eligible” locations in rural western parts of Arizona did not have any SFSP or Seamless Summer Option meals sites in June 2016, the month with the greatest number of summer meals served in that state  States and SFSP providers have responded to challenges with meal sites in rural areas by using other meal delivery approaches—efforts that FNS has supported through information sharing and grants  For example, according to one national organization involved in summer meals, some SFSP providers offer vans or buses to transport children to meal sites or partner with local bus authorities to give children free rides to meal sites  Instead of transporting children to sites, other sponsors transport meals to children through mobile meal delivery, an alternative summer meal model used in 48 states according to our survey  In this model, sponsors deliver meals by bus, using a route with state-approved stops in a community, and children consume the meal at the stop under a supervised setting  According to FNS officials and representatives from national organizations, this approach can be particularly helpful for providing summer meals to children in rural areas  State officials in two selected states told us they use mobile meal delivery to help fill gaps in meal service and help children overcome the lack of transportation or resources in their community  To serve children in very remote areas with limited resources, a sponsor in one of the selected states reported piloting a model involving delivering frozen meals every other week to such areas and supplying equipment, such as freezers and microwaves, to support meal service  To help sponsors address challenges related to meal sites in rural areas, FNS has shared information on alternative delivery models through its SFSP toolkit and webinars and has also provided related grant funding  For example, in summer 2011 and 2012, FNS funded the Meal Delivery demonstration project to provide meals to children in rural areas where low population density, long distances, and transportation issues made it difficult for children to get to SFSP sites, making site and sponsor operation financially unsustainable  The demonstration project funded meals to children in rural areas of Delaware, Massachusetts, and New York, providing food delivery to homes or drop-off sites near homes of eligible children  More than half the states (30) in our survey reported they faced a moderate to extreme challenge reaching low-income children in communities that are not area eligible  Areas in which fewer than 50 percent of children qualify for free or reduced-price meals during the school year are not eligible to have open summer meal sites at which all children who come to the site can receive a free meal  As a result, some children who are eligible for free and reduced-price meals during the school year do not have open summer meal sites located in close proximity to their residences, according to several national organization officials and SFSP providers  Eligible children in these areas may instead be limited to other types of SFSP sites, such as closed enrolled summer meal sites, or nonfederal programs providing meals, if available  For example, in one of the selected states, a sponsor of SFSP sites funded meals without federal support at one site that they operated as an open site in order to serve low-income children residing in low-income housing  These children did not otherwise have access to a federally funded summer meals site, according to these officials, because the broader area was part of a school district that had a greater than 50 percent proportion of children from higher-income families  Recognizing that some children may reside in an area that is not area eligible but is immediately adjacent to such an area, FNS has allowed additional flexibility in establishing area eligibility for open meal sites  Specifically, in 2014 and 2016 policy memos, FNS expanded the ways in which states and sponsors can use Census data to establish area eligibility  For example, FNS has allowed states and sponsors to average Census data across adjacent geographic areas to determine area eligibility  FNS noted that these additional flexibilities help ensure meal sites can be located in more areas in which poor economic conditions exist  Nearly all states (50) reported in our survey that the availability of meal sites throughout the summer months was a factor critical to the success of the SFSP, yet more than half the states (27) also reported they faced a moderate to extreme challenge with limited meal site days of operation  Nineteen of the 40 states that provided information about site days of operation reported 1 day as the shortest length of operation for SFSP sites in their state in fiscal year 2016  Limited meal site days of operation was a significant challenge in one of the three selected states we visited, as almost one-quarter of sites operated for only 1 to 2 weeks across a 2-month period in summer 2016, and an additional half of sites operated for 3 to 4 weeks across that same period, according to our analysis of state data  In contrast, in the other two selected states, the majority of sites (64 and 76 percent, respectively) operated for 5 or more weeks during a 2-month period  SFSP sites may have limited days of operation for various reasons, such as constraints with program administration and costs, according to interviews with a national organization official and a sponsor in one of the selected states  Some SFSP providers and national organizations involved in summer meals have responded to these challenges by working to extend the days of operation of meal sites—efforts that FNS has supported through related grant funding  Officials from one meal site located at a school in one of the selected states told us that 2017 was the first year the site stayed open an additional 4 weeks after summer school classes ended in an effort to expand participation, an extension made possible through support from an experienced sponsor  In addition, officials from a national organization involved in sponsoring summer meals told us they encourage their local sites to operate in August—a month where there are generally fewer summer meal service offerings—to meet children’s needs  At the federal level, under its demonstration authority, FNS funded the Extending Length of Operation Incentive project, a grant which provided an additional 50-cent reimbursement for all lunch meals served at sites in Arkansas in 2010 that offered meals for 40 or more days  Two-thirds of states (34) reported through our survey that they also faced a moderate to extreme challenge with a lack of awareness of summer meal sites among children and families, a challenge also mentioned by SFSP providers in the selected states  Meal site operators in one selected state noted that making families aware that all children may receive a meal for free at open sites can be a challenge  For example, one sponsor operating a meal site in a school said the perception among some is that the meal program is only for children attending summer school, and not for others in the community  Although that site had outside banners and advertising to help address that misperception, another SFSP provider explained that having sufficient funds to market the SFSP and increase awareness among families is also a challenge  To address these challenges, state agencies, some SFSP providers, and FNS have taken steps to help promote awareness of the SFSP  For example, nearly all states (47) reported in our survey that they have increased their outreach efforts for the SFSP in the last 5 years  More than half of states (36) also reported increases in overall SFSP participation during that time, which they believe were related to their outreach efforts  The majority of states in our survey reported conducting outreach on the SFSP to groups including children, parents and guardians, and schools, among others, using methods such as flyers, email, newspapers, and social media (see fig  7)  Further, state agency officials and sponsors in the selected states reported that they have developed partnerships with state and local advocacy groups and community leaders, among others, to promote the SFSP  For example, one state agency official said they partner with local advocacy organizations to field calls from parents seeking information about summer meal sites through their hunger hotline  FNS has promoted the use of such partnerships, as well as traditional and social media, to raise awareness of the SFSP  In addition, FNS developed the Summer Meals Site Finder, an online mapping tool that provides information on summer meal sites nationwide  Attracting children of all ages to SFSP meal sites can also be a challenge, according to states and SFSP providers  More than half of the states (31) reported in our survey that they faced a moderate to extreme challenge with limited youth and teen participation at summer meal sites, and an official from a national organization involved in the SFSP explained that it is difficult to attract children to a meal site when the site is focused solely on food  Similarly, 46 states in our survey reported that providing age- appropriate programming and enrichment activities for children at summer meal sites is a factor critical to the success of the SFSP  However, some meal sites may lack the resources to add activities, according to some SFSP providers in the selected states as well as FNS and national organization officials


Report 2:  Attracting teens can be particularly challenging, in part because of meal service time periods, a lack of age- appropriate activities, and stigma, according to national organizations and providers we interviewed  For example, early morning meal sites generally attract younger kids as teens may be apt to sleep later in the summer, and teens may also perceive a stigma in participating in a free meal program and may face peer pressure not to eat  In addition, meal offerings at SFSP sites may also present challenges to teen participation  Specifically, because FNS bases minimum portion size requirements for meals on the needs of younger children, meals are not always adequate to meet the nutritional needs of teens, according to one sponsor we interviewed  Across the 30 meal sites in the 3 states we visited in summer 2016, we observed variety in the meals served during different meal services  (see fig  8 ) States and SFSP providers have collaborated with others and sought specific types of sites to help provide enrichment activities and attract certain age groups—efforts that FNS has supported through information sharing and related grant funding  Sponsors in the selected states said they have focused on partnerships with groups such as those focused on youth development, churches, libraries, and police or fire departments, to offer age-appropriate activities for children (see fig  9)  For example, programs with local police departments, such as Cops N Kids in one selected state, or libraries in two selected states, provided meal services in combination with youth development or other enrichment activities  (See sidebar for highlights on the Cops N Kids program ) One national organization official said activities at SFSP sites can help take away the stigma around the program because children are not just there for the meal  Efforts to rebrand the SFSP as a community event where entire families can participate at the meal site also can have this effect, which is why some sponsors in the selected states said they partnered with foodbanks to donate meals for adults  In addition, a sponsor in one selected state told us they adjusted their meal offerings to match the needs of children of different age groups, for example, by serving meals to younger children earlier in the day and meals to teens later in the day  To support participation from children of all ages, FNS has shared information on age-appropriate activities through its SFSP toolkit and provided related grant funding  For example, in 2010, FNS funded the Activity Incentive demonstration project, in which sponsors in Mississippi were provided with mini-grants to increase enrichment and recreational activities, such as education, tutoring, sports and games, arts and other activities, to draw children to meal sites  More than half the states reported in our survey that they faced a moderate to extreme challenge with limited state agency staffing (27), a limited amount of federal funding for SFSP administration (27), as well as ensuring sponsor participation to meet needs (28)  In addition, 28 states reported in our survey that they faced a moderate to extreme challenge with sponsors not following program requirements  Limited staffing can affect a state agency’s ability to conduct efforts aimed at increasing participation, identifying potential sponsors, and reviewing and monitoring sponsors, according to national organization and state officials we interviewed  For example, increases in sponsors and sites requires additional staff and time to conduct pre-approval visits, sponsor and site reviews, vendor reviews, and technical assistance visits, which directly affects the amount of funding needed to support staff salaries and travel reimbursement, according to one state in our survey  However, because the SFSP administrative funds FNS provides to states are based on the number of meals served in the previous year, increasing the number of staff to help increase SFSP participation is difficult, according to a national organization official we interviewed  States reported a moderate to extreme challenge with the following issues related to ensuring sponsor participation: a lack of sponsors to meet summer meal needs, a lack of awareness of the summer meal program among potential sponsors or sites, completing federal requirements for monitoring of SFSP sponsors, and identifying potential sponsors  State agencies responsible for administering the SFSP reported relying on other resources and partners to help with program administration— strategies that FNS has supported through information sharing and its online tools  As discussed earlier, all three selected state agencies we interviewed told us they partner with advocacy groups to help expand and conduct outreach on the SFSP  Additionally, more than half the states in our survey reported several factors—which may ease the administrative burden on states—as critical to the success of the SFSP, including partnerships with SFSP sponsors (49) and retaining sponsors and sites over multiple summers (51)  To support states’ use of alternative funding sources to help administer the SFSP, FNS has shared information on federal, state, and private funding and grant opportunities  FNS also developed the online Capacity Builder tool, which 35 states reported in our survey was moderately to extremely useful in identifying or confirming meal site eligibility in fiscal year 2017  Seventeen states reported in our survey that ensuring summer meal sites are in safe locations was moderately to very challenging, a challenge that some states and SFSP providers have taken steps to help address  State officials and SFSP providers in the selected states reported that when crime has occurred near a site, there are concerns about ensuring children’s safety while they are consuming meals at the site, as well as the safety of site staff delivering meals  Some sponsors noted, in particular, parents’ concerns for the safety of their children at meal sites in light of criminal activities in the surrounding area  To ensure children continue to have access to meals, some sponsors noted that in the event of an immediate threat at an outdoor meal site, site staff are sometimes able to bring children to a nearby indoor space instead  States and SFSP provider officials in two selected states told us they have also used other strategies, including partnerships with local law enforcement agencies, to help address safety concerns during the meal service and ensure children have access to meals  For example, national organizations involved in summer meals and sponsor officials in the selected states said they encourage partnerships with local police departments to use police escorts at meal sites or to follow mobile meal routes in situations where safety at the meal site is a concern  When violence or crime has occurred near a site, some states and SFSP sponsors have also sought flexibility from FNS with respect to the federal requirement that children consume summer meals on site, according to state and local officials  FNS has used its available authorities to grant some states and sponsors flexibility with respect to the requirement that children consume summer meals on site, such as when safety at the site is a concern; however, FNS has not clearly communicated to all states and sponsors the circumstances it considers when deciding whether to grant this flexibility  According to our review of letters FNS sent to multiple states approving their requests for this type of flexibility, the agency identified a consistent set of circumstances that needed to be met for it to grant this flexibility  These circumstances were described in the letters the agency sent to states and generally included verification that violent crime activities occurred within both a 6-block radius of the meal site and 72 hours prior to the meal service  FNS’s letters to states indicate that when documentation was provided to the agency showing that these circumstances existed at a summer meals site on a particular day or days, meals consumed by children off site on those days were eligible for federal reimbursement  Although FNS has issued guidance on the general processes for requesting flexibility from program requirements under its waiver and demonstration authorities, these guidance documents do not detail the specific circumstances that the agency considers when deciding whether to grant flexibility from the on-site requirement due to safety concerns  FNS has communicated this information only in its responses to specific state and sponsor requests, and it has not communicated these circumstances more broadly to all states and sponsors  FNS officials explained that they review state and sponsor requests for flexibility due to safety concerns on a case-by-case basis  However, they also acknowledged that the set of circumstances used for approval of state and sponsor requests for flexibility, which we identified in their letters to states, has been used repeatedly  Further, states and sponsors reported challenges obtaining the specific data needed for approval of a site for this type of flexibility, hampering some providers’ efforts to ensure safe delivery of meals  For example, state agency and sponsor officials in one selected state said obtaining the crime data needed to qualify for the flexibility can be an administrative burden on sponsors, and these data are not consistently available in a timely manner  According to state agency and sponsor officials in one of the selected states, daily crime statistics are not available in all areas, and while a sponsor can sometimes access current data on crime in a city, the most recent available data on crime in suburban areas are sometimes one year old  FNS is aware of state and local challenges obtaining the necessary crime data, according to our discussions with FNS officials  FNS officials acknowledged that while they have granted some state and sponsor requests to allow children to consume meals off site in certain areas where violence or crime has occurred, some sponsors were unable to implement the flexibility because they could not obtain the necessary crime data  To help achieve agency objectives and address related risks, the Standards for Internal Control in the Federal Government state that agencies should communicate key information to their internal and external stakeholders  Although FNS officials told us they do not have one set of circumstances under which they approve these requests, our review found only one set of circumstances under which this type of flexibility has been approved  However, FNS has not broadly communicated the circumstances it considers in deciding whether to approve requests for flexibility with respect to the requirement that children consume summer meals on site in areas with violence or crime  Unless FNS shares this information with all states and sponsors, states and sponsors will likely continue to be challenged to use this flexibility, hindering its usefulness in ensuring safe summer meal delivery to children  In addition, FNS has issued reports to Congress evaluating some of its demonstration projects, as required under its statutory authorities, but the agency has not issued any such reports to Congress specifically on the use of flexibilities with respect to the on-site requirement in areas where safety is a concern  As previously discussed, the agency is required to annually submit certain reports to Congress regarding the use of waivers and evaluations of projects carried out under its demonstration authority  Furthermore, Standards for Internal Control in the Federal Government state that management should use quality information to make informed decisions and evaluate the entity’s performance in achieving key objectives and addressing risks  Yet, FNS has not evaluated nor reported on the use of waivers and demonstration projects in cases where safety was a concern  Although FNS requests reports from state agencies or sponsors that have received flexibility with summer meals delivery under FNS’s demonstration and waiver authorities, FNS officials told us they have not assessed whether their use of these flexibilities to address safety issues has been effective in ensuring safe meal delivery  FNS officials told us that they have not evaluated or reported on these flexibilities, in part, because they have limited information on their outcomes  Without understanding the impact of its use of these flexibilities, neither FNS nor Congress knows whether these flexibilities are helping provide meals to children  In addition to the challenges with safety at meal sites, sponsors also sometimes face administrative challenges when participating in multiple child nutrition programs that are operated by different state agencies or divisions within the same agency, according to officials from national and regional organizations and sponsors we interviewed  For example, officials from national organizations involved in summer meals told us the management of each child nutrition program and processes related to applications, funding, and oversight are fragmented in many states  For example, a sponsor in one of the selected states told us aspects of the SFSP and CACFP sponsor applications are highly duplicative and estimated it took 42 hours last year to complete duplicative paperwork  Another sponsor that provides school meals during the school year told us they had to fill out 60 additional pages of paperwork to provide summer meals, which coupled with having a state contact for the SFSP that was different from the one they worked with for the NSLP, was a significant burden for them  Officials from one national organization told us a lack of interoperability of some state agencies’ data systems has caused challenges and administrative burden for some sponsors  For example, in some states, different agencies oversee child nutrition programs, yet are unable to share data on sponsor approval, and therefore, sponsors are required to submit similar information to both, according to these officials  Duplicative paperwork can be particularly burdensome for some SFSP providers, as national organization officials and SFSP providers in the selected states said completing SFSP application paperwork can be especially challenging when a sponsor has staff shortages or no dedicated SFSP staff  Some selected states have worked with SFSP sponsors to help minimize the administrative burden  For example, state agency officials from one of the selected states said they have connected less-experienced sponsors to more-experienced sponsors in the community to help them with program administration  In one case, an experienced SFSP sponsor partnered with a small sponsor new to the program to help with SFSP administration, including helping them understand program rules and paperwork requirements  One SFSP sponsor also noted that their state agency took additional steps to ease administrative burden, such as making the forms for the CACFP more consistent with those for the SFSP and streamlining certain requirements for large and experienced sponsors, which the sponsor found helpful  At the federal level, FNS has established program and policy simplifications to help lessen the administrative burden on sponsors participating in multiple child nutrition programs, though the persistence of these challenges indicate that information about these simplifications has not reached all relevant state agencies  While FNS officials told us that some of the duplicative requirements may be a function of differences in statute, FNS provided guidance to states in 2011 and 2014 on simplified application procedures for institutions participating in CACFP that also wish to apply for SFSP  FNS noted in its guidance that in states where CACFP and SFSP are administered by different state agencies, state agencies are encouraged to work together to share information and streamline the application and agreement process as much as possible  FNS also addressed these simplifications in a state agency meeting in November 2017  Additionally, FNS provided guidance to states in 2012 on simplified application and review procedures for school food authorities participating in the NSLP that wish to also participate in the SFSP  Although FNS has shared this information with states in an attempt to make them aware of streamlining options, FNS officials noted that some states may choose not to implement them  Standards for Internal Control in the Federal Government state that management should externally communicate the necessary quality information to achieve the entity’s objectives, as well as periodically evaluate the methods of communication to ensure communication is effective and appropriate  FNS’s existing guidance addresses options for streamlining administrative requirements for sponsors participating in multiple child nutrition programs  However, information on program and policy simplifications available for sponsors participating in both NSLP and SFSP has not been shared with states recently, and challenges in this area persist, indicating this information has not reached all relevant state agencies  Without further efforts from FNS to disseminate information on current options for streamlining administrative requirements across child nutrition programs, overlapping and duplicative administrative requirements may limit children’s access to meals by discouraging sponsor participation in child nutrition programs  The purpose of the SFSP is to continue to provide children in low-income areas with nutritious meals over the summer when school is no longer in session, and to that end, the program provided 149 million SFSP meals to children in fiscal year 2016  Although meals served are one indicator of participation, FNS’s current estimates of children participating in SFSP are unreliable  Without additional understanding of children’s participation in the SFSP, FNS lacks information critical for informing program implementation, strategic planning, and outreach  The majority of states nationwide and SFSP providers in the three states we visited reported experiencing a number of challenges with the SFSP, and FNS has taken important steps to address these challenges  Two key challenges identified by officials in the selected states and national organizations we interviewed are ensuring summer meal sites are in safe locations, and meeting administrative requirements when participating in multiple child nutrition programs  FNS has taken steps to address these challenges by providing flexibilities in how meals are delivered to children and streamlining options for those providers participating in more than one child nutrition program  However, a lack of clarity concerning the circumstances under which FNS grants flexibilities in areas of violence and crime, and a lack of information on its use of these flexibilities and their impact on program administration, hinder efforts to ensure program goals are met  Furthermore, absent a reminder to states regarding existing options for streamlining administration across multiple nutrition programs, some providers may continue to be discouraged from participating in these programs due to duplicative and burdensome administrative requirements, which may ultimately limit the provision of nutritious meals to children  We are making the following four recommendations to FNS: The Administrator of FNS should improve its estimate of children’s participation in the SFSP by focusing on addressing, at a minimum, data reliability issues caused by variations in the number of operating days of meal sites and in the months in which states see the greatest number of meals served  (Recommendation 1) The Administrator of FNS should communicate to all SFSP stakeholders the circumstances it considers in approving requests for flexibility with respect to the requirement that children consume SFSP meals on-site in areas that have experienced crime and violence, taking into account the feasibility of accessing data needed for approval, to ensure safe delivery of meals to children  (Recommendation 2) The Administrator of FNS should evaluate and annually report to Congress, as required by statute, on its use of waivers and demonstration projects to grant states and sponsors flexibility with respect to the requirement that children consume SFSP meals on-site in areas experiencing crime or violence, to improve its understanding of the use and impact of granting these flexibilities on meeting program goals  (Recommendation 3) The Administrator of FNS should disseminate information about existing flexibilities available to state agencies to streamline administrative requirements for sponsors participating in the SFSP and other child nutrition programs to help lessen the administrative burden  For example, FNS could re-distribute existing guidance to state agencies that explains available flexibilities and encourage information sharing  (Recommendation 4) We provided a draft of this report to the Secretary of the USDA for review and comment  FNS officials provided technical comments, which we incorporated as appropriate  In addition, in oral comments, FNS officials, including the Deputy Administrator for Child Nutrition Programs, generally agreed with the recommendations in the report  As agreed with your offices, unless you publicly announce the contents of this report earlier, we plan no further distribution until 30 days from the report date  At that time, we will send copies to the Secretary of the USDA and interested congressional committees  The report will also be available at no charge on the GAO website at www gao gov  If you or your staff have any questions about this report, please contact me at (202) 512-7215 or larink@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 IV  This appendix discusses in detail our methodology for addressing three research objectives: (1) What is known about participation in the Summer Food Service Program (SFSP) and how has it changed in the last 10 years? (2) What other programs help feed low-income children over the summer? and (3) What challenges exist, if any, in providing summer meals to children, and to what extent does the U S  Department of Agriculture’s (USDA) Food and Nutrition Service (FNS) provide assistance to states and sponsors to address these challenges? In addition to the methods we discuss below, to address all three research objectives, we reviewed relevant federal laws, regulations, and guidance; interviewed FNS officials in its headquarters and seven regional offices; and interviewed a broad range of regional and nationwide organizations involved in the SFSP  In addition, we coordinated with officials in USDA’s Office of Inspector General on their ongoing work in this area  To address our first objective about participation in the SFSP, we analyzed FNS data on meals served for fiscal years 2007 through 2016  Specifically, we analyzed the total number of meals served nationwide through the SFSP from fiscal year 2007 through fiscal year 2016  Each month, states report to FNS the number of meals served by meal type (breakfast, lunch, snack, and supper) and the number of meals served by meal and sponsor type (e g , government, nonprofit, etc ) using the FNS- 418 form  To add context on these trends, we also analyzed and compared the number of SFSP lunches served in July with the number of free and reduced-price lunches served to children in March through the National School Lunch Program (NSLP), the largest child nutrition assistance program, from fiscal year 2007 through fiscal year 2016  Each month, states report to FNS the number of meals served through the NSLP using the FNS-10 form  To assess the reliability of SFSP and NSLP data, we (1) performed electronic testing of relevant data elements, (2) reviewed existing information about the data and the system that produced them, and (3) interviewed agency officials knowledgeable about the data  Electronic testing included, but was not limited to, checks for missing data elements, duplicative records, and values outside a designated range or valid time period  We determined that these data were sufficiently reliable to identify the number of SFSP meals served and assess change over time  To further examine what is known about participation in the SFSP, we also reviewed FNS’s data on estimates of children’s participation in the program and determined that these estimates have been calculated inconsistently and are unreliable  To assess the reliability of these data, we reviewed documentation about the estimates, interviewed FNS officials, and asked states about the estimate calculation in our survey  As described in our findings, FNS does not collect data on the number of children participating in the SFSP  Instead, FNS relies on states’ estimates of children’s participation, which are based on other data reported by sponsors, such as the number of meals served and meal service days in July  To address our second objective about other programs that help feed children in the summer, we reviewed FNS’s estimate of the number of meals served through the NSLP’s Seamless Summer Option in fiscal year 2016  FNS does not collect data on the number of meals served through the Seamless Summer Option  Instead, FNS annually estimates the number of Seamless Summer Option meals served nationally by aggregating the number of free and reduced-price breakfasts, lunches, and snacks served through the School Breakfast Program (SBP) and NSLP in July  As previously noted, states report these data monthly to FNS  Although FNS does not know the actual number of meals served through the Seamless Summer Option, agency officials told us they believe the number of summer meals provided through the NSLP is small relative to the number of meals served through the Seamless Summer Option during the summer months  They noted that their use of July NSLP data to estimate the Seamless Summer Option meals likely overestimates the number of these meals for July and underestimates the number of these meals for the entire summer  To assess the reliability of the July NSLP data, we (1) performed electronic testing of relevant data elements, (2) reviewed existing information about the data and the system that produced them, and (3) interviewed agency officials knowledgeable about the data  Electronic testing included, but was not limited to, checking for missing data and data that fell outside of a reasonable range or date for the specific time period (July)  We determined that these data were sufficiently reliable to describe the number of meals served  In addition to the data FNS requires states to report, some states collect summer meals data at the meal site level and we used such data from the three selected states to address all three objectives  For objective one, to examine the number of meals served and days of operation at each summer meals site, we analyzed site-level data for 2 months from summer 2016, including the month with the largest number of SFSP meals served in each selected state: Arizona (June and July 2016), Illinois (July and August 2016), and Massachusetts (July and August 2016)  Each state also provided us with data on the number and types of meals served at each SFSP site, the site location, and the duration of time each site operated over the summer  Using the data provided by the states, we calculated the average daily attendance (ADA) for each meal site based on FNS’s instructions and examined the variation in ADA across sites and months  For our second objective on other programs, these selected states provided similar site level data for the state’s Seamless Summer Option sites, if applicable  We assessed the reliability of these data by (1) performing electronic testing of relevant data elements, (2) reviewing existing information about the data and the system that produced them, and (3) interviewing agency officials knowledgeable about the data  We determined that the data were sufficiently reliable for the purposes of this report  For both our second objective on other programs and third objective about challenges in providing summer meals to children, we also examined meal site availability in the three selected states by mapping the locations of meal sites  On the maps, we included fiscal year 2016 area eligibility data from FNS’s Capacity Builder mapping tool, as provided by FNS  The site area eligibility data from FNS’s Capacity Builder is based on the U S  Census Bureau’s 5-Year American Community Survey (ACS) estimates of children ages 0-12 and 0-18 eligible for free and reduced-price meals by Census block group and tract  According to FNS officials, FNS obtains 5-Year ACS estimates annually from the U S  Census Bureau and updates its site area eligibility in the Capacity Builder accordingly  For fiscal year 2016, FNS used 2009- 2013 ACS data to identify and include site area eligibility in its Capacity Builder  To help inform all of our research objectives, we conducted a survey of the state agencies that oversee the SFSP in the 50 states and the District of Columbia  We administered our web-based survey between August and October 2017 and received 100 percent response rate  The survey included questions about participation in the SFSP, factors critical to the overall success of the SFSP, outreach efforts, federal technical assistance, barriers and challenges in providing summer meals, alternative summer feeding models, the NSLP’s Seamless Summer Option and the federal Summer Electronic Benefit Transfer for Children demonstration, and nonfederal programs that provide children of low- income households with meals during the summer months  The survey also requested data on SFSP sites participating in the program in fiscal year 2016 and the method state agencies used to calculate ADA in SFSP on the FNS-418 form in fiscal year 2016  Because this was not a sample survey, there are no sampling errors  However, the practical difficulties of conducting any survey may introduce nonsampling errors, such as variations in how respondents interpret questions and their willingness to offer accurate responses  We took steps to minimize nonsampling errors, including pretesting draft instruments and using a web-based administration system  Specifically, during survey development, we pretested draft instruments with SFSP staff from four states (Michigan, New Mexico, North Carolina, and South Dakota) in May 2017  We selected the pretest states based on information provided by officials from FNS’s regional offices and national organizations involved in summer meals about state administration of summer meals programs, with the goal of selecting a group of states with varied experiences  In the pretests, we were generally interested in the clarity, precision, and objectivity of the questions, as well as the flow and layout of the survey  For example, we wanted to ensure definitions used in the surveys were clear and known to the respondents, categories provided in close-ended questions were complete and exclusive, and the ordering of survey sections and the questions within each section were appropriate  We revised the final survey based on pretest results  Another step we took to minimize nonsampling errors was using a web-based survey  Allowing respondents to enter their responses directly into an electronic instrument created a record for each respondent in a data file and eliminated the need for and the errors associated with a manual data entry process  We did not fully validate specific information that states reported through our survey  To help inform all of our objectives and gather information about the SFSP directly at the local-level, we conducted 30 site visits in three states: Arizona (12 sites), Illinois (8 sites), and Massachusetts (10 sites) between June and July 2017, and interviewed organizations involved with the SFSP in each site visit state  We used U S  Census Bureau data to select states and local areas within those states based on a high proportion of children in poverty, a mix of urban and rural locations, as well as a mix of sponsor and site type and diverse locations  We visited a wide variety of site locations including, but not limited to, schools, parks, community recreation areas, and libraries  At each SFSP site, we gathered information on local level factors related to SFSP participation and administration by interviewing the organization sponsoring the site, the site operators and staff, and those participating at the site using semi-structured questions  While interviewing SFSP sponsor organizations, we collected information on the sponsors’ roles in the SFSP, characteristics of the sites the organizations sponsored, outreach efforts, any challenges or barriers to SFSP administration and any efforts to address such challenges, relationships with the state agencies that administer the SFSP, relationships with FNS (national and regional offices), and the availability of nonfederally funded programs that provide meals to low-income children over the summer  During the interviews with site operators and staff, we collected information about site operation (e g , site operating days, meals offered, etc ), any challenges to providing SFSP meals to children and any efforts to address such challenges, outreach efforts, and the proximity of the next closest meal site  The information we collected from those participating at the sites included their perspectives on the SFSP food, site food consumption habits, ease of travel to the site, and access to other SFSP sites  At each site, we made observations as to how the food was provided to the children, food consumption and waste, the approximate age range of the children being served, and availability of programs or activities (e g , recreational sports)  Using semi-structured questions, we also interviewed the state agencies responsible for administering the SFSP in the site visit states to gather further information on how the SFSP is administered in each state, statewide participation in the program, related data collection activities, any challenges to administering the program and any efforts to address such challenges, related outreach efforts, alternative meal delivery models being employed by SFSP sponsors, FNS guidance or technical assistance, and the availability of nonfederally funded programs that provide meals to low-income children over the summer  For states that indicated there were other challenge(s), we provided an open-ended question that requested a description of the challenge(s) and 14 states provided descriptions of other challenges, not shown here  For states that indicated there were other challenge(s), we provided an open-ended question that requested a description of the challenge(s) and 8 states provided descriptions of other challenges, not shown here  In addition to the contact named above, Rachel Frisk (Assistant Director), Claudine Pauselli (Analyst-in-Charge), Melissa Jaynes, and Matthew Nattinger made key contributions to this report  Also contributing to this report were Susan Aschoff, Sarah Cornetto, Ying Long, Jean McSween, Mimi Nguyen, Almeta Spencer, and Ashanta Williams 

ground_truth: BOP is the largest employer within DOJ and is responsible for the care and custody of an inmate population of about 186,000. BOP has faced challenges retaining staff at correctional facilities, although it has used retention incentives, along with other human capital flexibilities. GAO was asked to review BOP's use of retention incentives. This report addresses: (1) how BOP used its authority to pay retention incentives; (2) internal controls BOP has in place for the use of retention incentives; and (3) the extent to which BOP plans for and evaluates the use of retention incentives. GAO obtained employee-level retention incentive expenditure data from DOJ's Justice Management Division for fiscal years 2012 through 2016. GAO also reviewed agency documentation, such as policy statements and 40 randomly selected retention incentive application packet case files from fiscal years 2014 through 2016. GAO also interviewed officials from BOP's Central Office and four correctional facilities that use retention incentives, selected to reflect variation in the number and types of employees receiving retention incentives, BOP regions, and BOP institution security levels. From fiscal years 2012 to 2016, the Department of Justice's (DOJ) Federal Bureau of Prisons' (BOP) total retention incentive expenditures generally increased from $10.7 to $14.0 million and the number of employees receiving retention incentives increased from 2,024 to 2,460. During those five years, BOP spent more than 97 percent of its total retention incentive expenditures on employees at four BOP institutions in California and for medical professionals nationwide. Further, total retention incentive expenditures for medical professionals increased by an average of 21 percent per year (see figure). According to BOP officials, BOP uses retention incentives, for example, to supplement BOP's medical professionals' salaries which are generally lower than private sector salaries. BOP has a variety of internal controls in place throughout the retention incentive process that help ensure retention incentive applications and approvals meet requirements. For example, each application goes through multiple levels of review to verify its accuracy and completeness. BOP takes steps to determine workforce needs and how to fill those needs, but has not strategically planned for and evaluated its use of retention incentives. According to BOP, planning for human capital needs is conducted at institutions during quarterly meetings, but discussions about these incentives respond to short-term staffing situations rather than proactively addressing future staffing needs. Including human capital goals and strategies in BOP's human capital plan would create a roadmap so the agency could move from being reactive to its current workforce needs to being strategic in trying to achieve its long-term workforce goals. Additionally BOP has not evaluated the effectiveness of its use of retention incentives in retaining staff. As a result, BOP does not know whether retention incentives have contributed to employees' retention in relation to other incentives used by BOP. Consistent with key principles for strategic human capital planning, planning for and evaluating the use of retention incentives could help BOP better determine if these incentives are an efficient and effective means by which to retain staff. GAO recommends that BOP (1) include human capital goals and how retention incentives will be used to achieve these goals in its human capital plan; and (2) evaluate the use of retention incentives. BOP concurred with GAO's recommendations.