FEDERAL MOTOR 

CARRIER SAFETY 

ADMINISTRATION

Additional Actions 

Needed to Strengthen 

Grants Management

Report to Congressional Requesters

December 2011

GAO-12-158

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-158, a report to 

congressional requesters

December 2011

FEDERAL MOTOR CARRIER SAFETY 

ADMINISTRATION

Additional Actions Needed to Strengthen Grants 

Management 

Why GAO Did This Study

In 2011, the Department of 

Transportation (DOT) determined that 

the Federal Motor Carrier Safety 

Administration (FMCSA) had violated 

federal appropriations statues in 

awarding some grants for 1 of its 10

grant programs from fiscal years 2006 

to 2010. This was caused in part by 

weaknesses in FMCSA’s internal 

controls and may have affected 

FMCSA’s ability to carry out its mission 

to reduce motor carrier (large truck and 

bus) accidents and fatalities. To the 

extent that these weaknesses existed 

in FMCSA’s other grant programs, it is 

possible that FMCSA also incorrectly 

awarded other grant funds. 

As requested, this report examines (1) 

internal control weaknesses in

FMCSA’s other grant programs prior to 

fiscal year 2010 that could have 

increased the risk of irregularities in 

grant awards and (2) FMCSA’s actions

to improve grants management, and 

remaining challenges. GAO analyzed 

FMCSA grants management 

documents related to internal controls 

over grants both before and after fiscal 

year 2010 and recent actions, and 

interviewed FMCSA officials. 

What GAO Recommends

GAO recommends that FMCSA (1) 

conduct a strategic workforce analysis 

for its grants management staff; (2) 

add details to its grants management 

policy manual; (3) improve its tracking 

of staff taking grants management 

training; and (4) set and track metrics 

related to grants management goals 

and objectives. DOT generally agreed

with GAO’s recommendations and 

provided technical comments, which 

were incorporated as appropriate.

What GAO Found 

Prior to fiscal year 2010, FMCSA’s internal controls over management of all of its 

grant awards were weak, which increased the risk that FMCSA awarded grants 

that violated laws or FMCSA policies. Internal controls like those related to 

workforce training and policies and procedures can help provide assurance that 

operations, including grants management, are efficient and transactions comply 

with laws. However, FMCSA had only limited formal grants management training, 

limited documentation of grants management policies and procedures, and, 

according to FMCSA grants management staff, did not require legal review to 

help ensure that all awards complied with governing laws and regulations. As a 

result, FMCSA could not be certain that staff were trained in managing grant 

awards or followed relevant policies and laws in awarding grants, increasing the 

risk for mismanagement.

Since fiscal year 2010, FMCSA has taken a number of actions to transform its 

grants management practices, including planning to centralize oversight through 

a Grants Management Office, standardizing policies and procedures, developing 

grants management training, and implementing grants management systems to 

manage award processes and documentation. While these actions help address 

some existing internal control weaknesses—for example, clearly documented 

and standardized policies and procedures should help ensure that grants 

management staff follow policies when awarding grants—some challenges 

remain. Specifically, FMCSA has not conducted a strategic workforce analysis 

that could help it identify and fill gaps in expertise, as well as support its budget 

request to staff a Grants Management Office. Also, FMCSA’s grants 

management policies and procedures lack details on some grant program staff’s

roles and responsibilities, and the agency does not have a system to easily track 

and ensure that staff complete required training. The agency also has not set 

metrics related to its grants management program or developed a method to 

measure progress in meeting those metrics. Further, since FMCSA has only 

recently implemented these actions, it is unclear how effective these new 

initiatives will be in improving its grants management. Regardless, it will be 

important that the agency have leadership in place that can continue to drive its 

transformation, as well as metrics to measure its progress in achieving its grants 

management goals.

FMCSA’s Proposed Grants Management Office

View GAO-12-158. For more information, 

contact Susan Fleming at (202) 512-2834 or 

flemings@gao.gov. 
Page i GAO-12-158 Federal Motor Carrier Safety Administration

Letter 1 

Background 4

Internal Control Weaknesses Across FMCSA Grant Programs 

Increased the Risk of Mismanagement and Irregularities in PreFiscal Year 2010 Grant Awards 12

FMCSA Has Taken Steps to Strengthen Internal Controls, but 

Additional Actions Are Needed to Ensure Continued 

Improvement 17

Conclusions 27

Recommendations for Executive Action 28

Agency Comments and Our Evaluation 29

Appendix I Objectives, Scope, and Methodology 32

Appendix II GAO Contact and Staff Acknowledgments 34

Tables

Table 1: FMCSA Grant Programs 5

Table 2: Internal Control Standards for the Federal Government 8

Table 3: Summary of FMCSA Initiatives to Improve Grants 

Management 18

Figures

Figure 1: FMCSA Grants Management Stages 6

Figure 2: Planned GMO Responsibilities and Relationships with 

Other FMCSA Grants Management Positions 19

Contents
Page ii GAO-12-158 Federal Motor Carrier Safety Administration

Abbreviations

FMCSA Federal Motor Carrier Safety Administration

DOT Department of Transportation

EPA Environmental Protection Agency

OGD EPA’s Office of Grants and Debarment

NHTSA National Highway Traffic Safety Administration

CVISN Commercial Vehicle Information Systems and 

 Networks

EDMS Electronic Document Management System

GMO Grants Management Office

OMB Office of Management and Budget

SAFETEA-LU Safe, Accountable, Flexible, Efficient 

 Transportation Equity Act: A Legacy for Users

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Page 1 GAO-12-158 Federal Motor Carrier Safety Administration

United States Government Accountability Office

Washington, DC 20548

December 13, 2011

The Honorable Patty Murray

Chairman

The Honorable Susan Collins

Ranking Member

Subcommittee on Transportation, 

Housing and Urban Development 

 and Related Agencies

Committee on Appropriations

United States Senate

The Honorable Tom Latham

Chairman

The Honorable John W. Olver

Ranking Member

Subcommittee on Transportation, 

Housing and Urban Development 

 and Related Agencies

Committee on Appropriations

House of Representatives

According to the Federal Motor Carrier Safety Administration (FMCSA), in 

2009, there were over 124,400 crashes in the United States involving 

large trucks and buses, leading to over 3,600 fatalities. As an agency in 

the Department of Transportation (DOT), FMCSA’s mission is to reduce 

crashes, injuries, and fatalities related to motor carriers—large trucks and 

buses—and it relies heavily on 10 grant programs to achieve that 

mission. Of the $550 million Congress appropriated to FMCSA in fiscal 

year 2011, about $300 million went to states and other entities in the form 

of grants to help fund motor carrier safety efforts. For example, FMCSA’s 

Motor Carrier Safety Assistance Program (MCSAP) provides funds to 

reduce commercial motor vehicle-involved accidents, fatalities, and 

injuries, through safety activities such as inspections.

Effective internal controls over grants management can reduce the risk of 

mismanagement of grant awards by helping ensure that grants are 

awarded in accordance with law and FMCSA policy and in a way that 

advances agency objectives. In 2010 FMCSA discovered that it may have 

violated federal appropriations statutes in some Commercial Vehicle 

Information Systems and Networks (CVISN) grants from fiscal years 2006 

to 2010, including violations of the Antideficiency Act—which prohibits 

 
 

Page 2 GAO-12-158 Federal Motor Carrier Safety Administration

federal agencies from incurring obligations that exceed budget authority 

made available through appropriations or contract authority1

—and its 

authorizing statute, The Safe, Accountable, Flexible, Efficient 

Transportation Equity Act: A Legacy for Users (SAFETEA-LU).2

It is important for FMCSA to award grant funds in accordance with laws 

and FMCSA policies in order to help ensure that limited dollars effectively 

support its national motor carrier safety goals. The economic downtown 

has created unprecedented fiscal constraints for states. State revenues 

have decreased in recent years—total state and local tax receipts fell 

nearly 5 percent from 2008 to 2009—putting increased fiscal pressure on 

state governments.

In 2011, 

DOT determined that it had in fact violated federal appropriations 

statutes. These violations were caused in part by weak internal controls 

over FMCSA’s management of CVISN grants, such as a lack of oversight 

and inadequate grants management training for FMCSA staff. In part in 

response to these problems, FMCSA has begun to transform its grants 

management practices with activities that it largely began implementing in 

or after fiscal year 2010, including proposing the creation of a centralized 

grants management office and creating standardized grants management 

policies and procedures. To the extent that the weak internal controls that 

contributed to irregularities in CVISN awards existed in FMCSA’s other 

grant programs prior to fiscal year 2010, it is possible that FMCSA 

violated statutes in making other grant awards.

3

 

1

GAO, The Department of Transportation Found That It Improperly Obligated Motor 

Carrier Grant Funds, 

This challenge increases the importance of federal 

funds—such as grants from FMCSA—for state governments. For 

example, in the case of CVISN awards, because some states received 

more funds than they were legally authorized, other states may not have 

received as much as they could have, adding unfairly to the fiscal 

pressures on those states and potentially impacting those states’ 

commercial motor vehicle safety efforts.

GAO-11-517R (Washington, D.C.: May 5, 2011). Contract authority 

is a form of budget authority that permits an agency to incur obligations in advance of 

appropriations, including collections sufficient to liquidate the obligation or receipts. 

Contract authority is unfunded, and a subsequent appropriation or offsetting collection is 

needed to liquidate the obligations.

2

Pub. L. No. 109-59, § 4126, 119 Stat. 1144, 1738 (Aug. 10, 2005).

3

GAO, State and Local Governments’ Fiscal Outlook: April 2011 Update, GAO-11-495SP

(Washington, D.C.: Apr. 6, 2011).
 

Page 3 GAO-12-158 Federal Motor Carrier Safety Administration

Given these concerns, you asked us to review: (1) the extent to which, 

prior to fiscal year 2010, FMCSA’s other grant programs had internal 

control weaknesses that could have increased the risk for financial 

irregularities in grant awards and (2) actions FMCSA is taking to improve 

its grants management to reduce the risk for financial irregularities in 

awarding grants and the challenges that remain.

In order to address the extent to which, prior to fiscal year 2010, 

FMCSA’s other grant programs had internal control weaknesses that 

could have increased the risk of grant award irregularities, we reviewed 

Internal Control Evaluation reviews of FMCSA’s grants management 

procedures and practices and related external auditor reports and 

interviewed grants management staff in FMCSA headquarters, as well as 

a selected number of field office staff and state grant recipients.4 We did 

not review internal controls over CVISN prior to fiscal year 2010 given 

that we recently reported on internal control weaknesses in that program.5

We reviewed GAO’s internal control standards for the federal 

government6 to determine those standards most relevant to grants 

management7

 

4

We selected four states—Alabama, Alaska, Arizona, and Wisconsin—that were identified 

by FMCSA as having received irregular CVISN awards and a number of non-CVISN grant 

awards, which allowed us to interview fiscal year 2011 recipients of all of FMCSA’s grant 

programs aside from the Commercial Motor Vehicle Operator Safety Training Grant. We 

determined that not including interviews of recipients of this grant was acceptable given its 

small size (a total of $1 million in awards annually) and that recipients are generally 

private training providers and educational institutions as opposed to state government 

agencies, which are the primary recipients of FMCSA’s other grants.

and reviewed relevant FMCSA grants management 

documentation to determine the extent to which relevant internal controls 

were in place for each grant program prior to fiscal year 2010. In order to 

determine the extent to which actions FMCSA is taking to improve its 

grants management reduce the risk for financial irregularities in awarding 

grants, and the challenges that remain, we reviewed documentation 

related to these efforts such as FMCSA’s Grants Management Program

Roadmap and Grants Management Manual. We analyzed these 

5

GAO-11-517R. 

6

GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1 

(Washington, D.C.: November 1999). 

7

Although “risk assessment” is one of the internal controls, we did not review FMCSA’s 

risk assessment controls over grants management activities as we determined that they 

were only minimally relevant to activities related to managing grant awards.
 

Page 4 GAO-12-158 Federal Motor Carrier Safety Administration

documents and information obtained during interviews and compared 

them with GAO’s internal control standards to determine the extent to 

which they address the internal controls deficiencies we identified at 

FMCSA. We also interviewed FMCSA management about these efforts. 

Finally, we interviewed grants management officials at the Environmental 

Protection Agency (EPA) and the National Highway Traffic Safety 

Administration (NHTSA) and analyzed relevant grants management 

documents to determine how those agencies manage their grant 

programs and how their grants management practices may be relevant to 

FMCSA. We selected these agencies because they, like FMCSA, devote 

at least 50 percent of their budgets to grants and have a safety focus.

We conducted this performance audit from April 2011 to December 2011 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. Appendix I provides additional 

information on our objectives, scope, and methodology.

FMCSA’s primary mission is to reduce crashes, injuries, and fatalities 

involving large trucks and buses.8 In order to meet this mission FMCSA, 

among other things, establishes commercial motor carrier regulations, 

educates motor carriers, drivers, and the public, and partners with 

stakeholders such as state governments on efforts to reduce motor 

carrier crashes. FMCSA uses 52 division offices—one in each state as 

well as Washington, D.C. and Puerto Rico—and four regional service 

centers to help carry out its efforts. In order to undertake these activities, 

FMCSA received appropriations of approximately $550 million for fiscal 

year 2011 and obligated about $300 million of that for grant awards.9

 

8

FMCSA defines large trucks as trucks with a gross vehicle weight rating of more than 

10,000 pounds and buses as any motor vehicle designed, constructed, and or used for the 

transportation of passengers.

9

FMCSA is funded through contract authority and receives appropriations from the 

Highway Trust Fund to liquidate its obligations.

Background 
 

Page 5 GAO-12-158 Federal Motor Carrier Safety Administration

FMCSA manages 10 grant programs that span a range of areas and 

provides funding to states, localities, and others to improve commercial 

motor vehicle safety (see table 1). Nine of the 10 grant programs are 

discretionary—that is, FMCSA decides, through a competitive process 

based on a review of the merits of applications, which applicants to award 

funds. FMCSA considers its MCSAP Basic and Incentive program, which 

accounts for over one-half of FMCSA’s grant funding, to be a formula 

grant program as FMCSA awards funds through a predetermined formula 

set by FMCSA based on, among other factors, a state’s population and 

highway miles.10

Table 1: FMCSA Grant Programs

Dollars in millions

Program

Fiscal year 

2011 funding Key objectives

Motor Carrier Safety 

Assistance Program

(MCSAP) Basic and 

Incentive

$165 

a

To assist states in developing or implementing programs to improve commercial motor 

vehicle safety and reduce the number and severity of accidents through consistent, 

uniform, and effective commercial motor vehicle safety programs.

Border Enforcement $32 To assist states that share a land border with another country in carrying out border 

commercial motor vehicle safety programs and enforcement activities.

New Entrant Safety 

Audit 

$32 To reduce commercial motor vehicle crashes, fatalities, and injuries through safety audits 

on new entrant interstate carriers (all new entrant carriers must undergo a safety audit 

within 18 months of beginning operations). 

Commercial Drivers 

License Program 

Improvement 

$30 To support states’ Commercial Driver’s License programs in order to reduce the number 

and severity of commercial motor vehicle crashes by ensuring that only qualified drivers 

receive commercial driver’s licenses. 

Commercial Vehicle 

Information Systems 

and Networks

(CVISN) 

$25 To provide funding to states to support improved information technology exchanges 

between government agencies and the motor carrier industry to enhance motor carrier 

safety and other efforts.

Motor Carrier Safety 

Assistance Program

(MCSAP) High 

Priority 

$15 To support national projects, including public education, that increase public awareness 

and education, demonstrate new technologies, and reduce commercial motor vehicle 

accidents. 

Performance and 

Registration 

Information Systems 

Management 

(PRISM) 

$5 To reduce commercial motor vehicle accidents by using commercial vehicle registration 

systems to determine the safety of motor carriers before issuing license plates and by 

motivating carriers to improve safety.

 

10The formula FMCSA uses to award MCSAP Basic and Incentive grants is set by 

FMCSA regulation and is not set in statute.
 

Page 6 GAO-12-158 Federal Motor Carrier Safety Administration

Dollars in millions

Program

Fiscal year 

2011 funding Key objectives

Safety Data 

Improvement 

Program 

$3 To support collection of accurate, complete, and timely data on commercial truck and bus 

crashes.

Commercial Motor 

Vehicle Operator 

Safety Training 

$1 To expand the number of commercial driver’s license holders with enhanced safety 

training to reduce crashes and to assist economically distressed regions through 

workforce training for commercial motor vehicle operators. 

Commercial Drivers 

License Information 

System 

$0b To support state commercial driver’s license information systems modernization efforts.

Source: GAO analysis of FMCSA data.

a

FMCSA awards MCSAP Basic and Incentive grants based on a formula using four factors: highway 

miles, all vehicle miles traveled, population, and fuel consumption. States that demonstrate 

improvement in certain motor carrier safety initiatives such as a reduction in motor vehicle crashes 

are eligible to receive MCSAP incentive grants. FMCSA officials noted that the agency was 

authorized a total of $209 million in contract authority for MCSAP grants, which includes funding for 

discretionary grants—$32 million for New Entrant Safety Audit grants and $15 million MCSAP High 

Priority grants—leaving $162 million for MCSAP Basic and Incentive formula grants.

b

FMCSA currently manages its grants using the Office of Management 

and Budget’s (OMB) five phases of grants management (see fig. 1). The 

first three phases are most relevant to awarding grant funds, the focus of 

this report. These five phases broadly outline all steps that an agency 

needs to undertake in awarding and managing grants, including planning 

the grant program, soliciting and reviewing applications, awarding funds, 

overseeing grant recipients, and closing out grants. For example, 

management of grant application reviews and the award process includes 

creating a grant announcement, accepting and reviewing applications, 

making funding decisions, and obligating those funds to selected grant 

recipients.

FMCSA officials noted that because of the progress of the CDLIS Modernization effort from previous 

grants, and the diminishing need from states for dedicated grant funding for this purpose, FMCSA 

requested in FY 2011 that Congress apportion funding to the Commercial Driver’s License Program 

Improvement and the New Entrant Safety Assurance grant instead of the CDLIS grant program.

Figure 1: FMCSA Grants Management Stages
 

Page 7 GAO-12-158 Federal Motor Carrier Safety Administration

Generally speaking, grants management staff in FMCSA headquarters 

are responsible for managing the first three phases of grants. Once 

FMCSA awards grants to states, staff in FMCSA’s 52 division offices, 

headed by Division Administrators, generally assume responsibility of 

managing the grants, including oversight of the grantee and grant 

closeout. The four regional service centers also provide grants 

management support and oversight to each of the division offices. 

FMCSA has a small number of grant awards that are provided to national 

organizations, and these grants are managed entirely by FMCSA staff in 

headquarters.

Internal controls are mechanisms that help an organization, such as a 

federal agency, provide reasonable assurance that it is meeting its 

objectives, that operations are effective and efficient, and that the agency 

is in compliance with all applicable laws and regulations. We have issued 

standards for internal control in the federal government, and these 

standards provide an overall framework for establishing and maintaining 

internal controls and identifying and addressing major performance and 

management challenges, as well as areas at greatest risk of fraud, waste, 

abuse, and mismanagement.11 Effective internal controls, which include 

the plans, methods and procedures to meet agency goals and objectives, 

can assist in managing change to cope with shifting environments and 

evolving demands and priorities. As a result, internal controls play a 

significant role in helping managers achieve agency goals.12

We have previously reported that there are five standards for internal 

control (see table 2) that define the minimum level of quality acceptable 

for internal control in government and can be applied to all aspects of an 

agency’s operations. The standards are: (1) establishing a control 

environment, in which an agency creates an environment that sets a 

positive and supportive attitude toward internal controls such as 

management’s commitment to competence and setting an ethical tone 

 

11GAO/AIMD-00-21.3.1.

12The Government Performance and Results Act of 1993 (GPRA) has multiple purposes, 

including improving program effectiveness, accountability, and service delivery. Pub. L. 

No. 103-62, 107 Stat. 285 (Aug. 3, 1993). Congress subsequently passed the 

Government Performance and Results Act Modernization Act of 2010 (GPRAMA) which 

establishes a new framework aimed at taking a more crosscutting and integrated 

approach to focusing on results and improving government performance. Pub. L. No. 111-

352, 124 Stat. 3866 (Jan. 4, 2011). 
 

Page 8 GAO-12-158 Federal Motor Carrier Safety Administration

within the agency; (2) conducting risk assessment, in which an agency 

assesses both internal and external risks associated with achievement of 

agency objectives; (3) engaging in control activities, which helps 

management ensure that its directives, such as policies and procedures, 

are carried out; (4) disseminating information and communications to 

management and others; and (5) monitoring performance over time and 

ensuring that audit findings are addressed and promptly resolved. In the 

context of grants management, internal controls are the mechanisms that 

help an agency ensure that its grant programs are effectively and 

efficiently managed and that its grant awards comply with laws and 

regulations.

Table 2: Internal Control Standards for the Federal Government

Internal controls Internal control standards

Control Environment • An organizational environment that sets a positive attitude toward internal control and 

management.

• A commitment to competence including providing personnel with a level of competence 

allowing them to accomplish their duties.

• Organizational structure, framework, and delegation of authority for agency operations in 

order to achieve agency objectives.

• Appropriate policies for training staff.

Risk Assessment • The identification and analysis of risks associated with achieving agency objectives. 

Control Activities • Policies, procedures, techniques, and mechanisms that enforce management’s directives.

• Human capital management to ensure that skill needs are continually assessed and that the 

agency has a workforce with the skills needed to achieve success.

• Segregation of duties to reduce the risk of error or fraud and proper execution of 

transactions.

• Appropriate documentation of all transactions and significant events.

Information and Communications • Information should be communicated to those within the agency who need it in a manner 

and time frame that allows them to carry out their responsibilities.

• Communications within the agency should be relevant, reliable, and timely and be broadly 

based and flow down, across, and up the agency.

Monitoring • Assessing the quality of performance over time.

• Ensuring that the findings of audits and other reviews are promptly resolved.

Source: GAO.
 

Page 9 GAO-12-158 Federal Motor Carrier Safety Administration

FMCSA’s Internal Control Senior Assessment Team13 oversees FMCSA’s 

internal controls program, which includes, among other actions, annual 

internal control evaluations conducted by an external auditor to test the 

effectiveness of internal controls. The evaluations test a number of 

internal control areas at FMCSA, including grants management.14 In 

conducting the internal control evaluations, the external auditor uses an 

Internal Control Evaluation Tool to assess the effectiveness of internal 

control activities—which it does by interviewing key staff and testing 

controls to determine their effectiveness—and assigns an effectiveness 

rating to each control activity reviewed, and determines the relative

significance of internal control deficiencies identified during the 

evaluations.15

SAFETEA-LU authorized funding for all of FMCSA’s grant programs and 

established funding restrictions for the CVISN program. In May 2010, 

DOT and FMCSA determined that FMCSA might have violated statutory 

requirements in obligating CVISN awards. After FMCSA’s Chief Financial 

Officer and Office of the Chief Counsel staff noticed irregularities with 

CVISN awards, including potential statutory violations, in spring 2010, 

Although past reviews found internal control deficiencies 

related to grants management—including inadequate grants management 

oversight—the external auditor did not make an overall determination of 

FMCSA’s internal controls over grants management. In response to 

findings made in each review, the Internal Control Senior Assessment 

Team, in conjunction with subject matter staff at FMCSA, develops 

corrective action plans that include information on planned actions and 

time frames for addressing the finding. Once all actions have been 

implemented by FMCSA and then tested by the auditor, the auditor can 

close the corrective action plans.

 

13This team is chaired by FMCSA’s Chief Financial Officer and includes representatives of 

every FMCSA office responsible for a business practice subject to an internal control 

evaluation in any given year. FMCSA’s internal controls program addresses requirements 

of the Federal Managers’ Financial Integrity Act of 1982 (FMFIA), Pub L. No. 97-255, 96 

Stat. 814 (Sept. 8, 1982), and the Office of Management and Budget’s Circular A-123, 

revised Dec. 21, 2004, which provides the specific requirements for assessing the 

reporting on internal controls.

14Other internal controls assessed include human resources, cash management, financial 

reporting, and travel management. While not all areas are reviewed every year, grants 

management has been included in FMCSA’s internal control evaluations every year since 

fiscal year 2005.

15Internal Control rating categories are effective, moderately effective, minimally effective, 

or ineffective. 
 

Page 10 GAO-12-158 Federal Motor Carrier Safety Administration

DOT established an analysis team supported by Deloitte Consulting LLP 

(Deloitte), to review the CVISN program and determine the extent of the 

problem. Using the results of Deloitte’s review and its own follow-up 

assessment, FMCSA found widespread problems with CVISN grant 

awards, and DOT concluded that it violated the Antideficiency Act—which 

prohibits federal agencies from incurring an obligation that exceeds their 

available appropriation or contract authority amounts16

In May 2011, we reported on a number of internal control weaknesses 

that contributed to CVISN award violations including: problems with 

grants management policies and procedures, such as an erroneous 

internal policy FMCSA issued that provided incorrect guidance regarding 

the extent to which states were available to receive certain CVISN funds, 

as well as a lack of written policies and procedures; a failure to track 

CVISN grants awarded by the Federal Highway Administration, which 

managed CVISN before FMCSA,

—and SAFETEALU. FMCSA found that many awards exceeded statutory caps and that, in 

some cases, FMCSA awarded total CVISN funds in excess of the annual 

contract authority available. Specifically, FMCSA found that it committed 

47 statutory violations between fiscal years 2006 and 2010 totaling about 

$23 million. In response, FMCSA temporarily shut down the CVISN 

program in May 2010 to determine the problems and to prevent 

exacerbating any problems. According to FMCSA officials, the agency 

reopened the CVISN program in June 2011 and plans to award fiscal 

year 2012 CVISN grants. FMCSA awarded $17 million in grants in fiscal 

year 2011 to states that the agency determined had not previously 

received an improper CVISN grant award.

17 thus contributing to cumulative 

statutory cap violations for CVISN awards; insufficient FMCSA oversight 

over the CVISN program, including the lack of legal review by FMCSA’s 

Office of the Chief Counsel to ensure that all awards complied with 

relevant laws; and a lack of training provided to FMCSA staff on how to 

manage the CVISN program.18

 

1631 U.S.C. § 1341(a).

We did not make any recommendations at 

that time, pending completion of this broader review of FMCSA’s grant 

awards.

17The Federal Highway Administration also administered the MCSAP Basic and Incentive 

and High Priority, PRISM, and the Commercial Drivers License Program Improvement 

grant programs prior to FMCSA. 

18GAO-11-517R. 
 

Page 11 GAO-12-158 Federal Motor Carrier Safety Administration

Grants management is a key function at NHTSA and EPA—two agencies 

that, similarly to FMCSA, devote approximately one-half of their budgets 

to grants. EPA manages its grants through a single centralized office, 

while NHTSA manages its grants through two different offices—one for 

formula grants and one for discretionary grants. EPA’s mission is to 

protect human health and the environment, and it devotes about half of its 

budget to provide formula and discretionary grants to support this 

mission.19 These grant programs support a variety of efforts, including 

those that further the health of people and the environment. EPA’s Office 

of Grants and Debarment (OGD) provides centralized grants 

management support, which includes general oversight of award 

competitions for discretionary grants and the development of uniform 

grants management policies and procedures for all of EPA’s grant 

programs. Each of EPA’s 10 regional offices also has a grants 

management office that provides its region with grants management 

support. NHTSA’s primary mission, similar to FMCSA’s, is to save lives, 

prevent injuries, and reduce the costs of motor vehicle traffic and crashes. 

NHTSA uses its grant programs, totaling about $744 million in fiscal year 

2010, to help support that mission. NHTSA manages its formula grants 

through the Regional Operations and Program Delivery Office and 

discretionary grants through its Procurement Office, and has distinct grant 

award processes for each. In both cases, however, centralized staff 

provide administrative support and direction to programmatic grants 

management staff working on individual NHTSA grant programs.

 

19We have conducted several reviews of EPA’s grant management program in the past. 

See GAO, Grants Management: EPA Has Made Progress in Grant Reforms but Needs to 

Address Weaknesses in Implementation and Accountability, GAO-06-625 (Washington, 

D.C.: May 12, 2006). 
 

Page 12 GAO-12-158 Federal Motor Carrier Safety Administration

Prior to fiscal year 2010, FMCSA’s control environment for managing 

grant awards was inadequate, and issues such as a lack of centralized 

oversight of policies and procedures and limited grants management 

training, increased the risk of irregularities and mismanagement of grant 

awards. Specifically, each grant program was managed independently by 

a grant program manager, which decentralized oversight of policies and 

procedures for those grant programs. FMCSA reported that its grants 

were also managed through its 52 division offices and 4 service centers 

throughout the country, which created inconsistencies as employees 

performed multiple tasks and roles. As a result, FMCSA management 

could not be sure that grant programs were being managed consistently 

and in line with a single agency policy. In addition, grants management 

staff told us that FMCSA did not provide adequate grants management 

training to staff as it did not require any of its grant program management 

staff to complete formal grants management training. Our internal control 

standards state that training should be aimed at developing and retaining 

needed employee skills. Staff received grants management training 

informally through on-the-job training, some external training, and FMCSA 

conferences, which did not specifically focus on grants management 

training. While some grant managers said they received grants 

management training from an external training provider, this training was 

not focused on managing FMCSA grants, and attendance was not 

required by FMCSA. Similarly, FMCSA’s 2007 internal control evaluation 

reported that FMCSA grants management staff were not equipped with 

formal grants management training and recommended that FMCSA 

establish a team tasked with creating a formal grants management 

training program. These weaknesses in the control environment suggest 

that FMCSA grants management staff did not have the grants 

Internal Control 

Weaknesses Across 

FMCSA Grant 

Programs Increased 

the Risk of 

Mismanagement and 

Irregularities in PreFiscal Year 2010 Grant 

Awards 

Decentralized Grants 

Management and Limited 

Training Contributed to a 

Weak Control 

Environment 
 

Page 13 GAO-12-158 Federal Motor Carrier Safety Administration

management training necessary to adequately employ policies, laws, or 

grants management procedures in awarding grants—increasing the risk 

for award irregularities and mismanagement. Furthermore, without 

establishing a strong control environment, it can be difficult to 

successfully implement other control standards.

Prior to fiscal year 2010, FMCSA had limited documented policies and 

procedures guiding its grant programs. Our standards for internal control 

call for federal agencies to document their policies and procedures, which 

help managers exercise control over agency activities, including activities 

undertaken to manage and administer programs such as grant programs 

and help ensure that management directives are conveyed to staff and 

carried out. FMCSA released a Financial Management and Processing 

Manual for Grant Programs in 2006 that focused on administrative 

functions related to processing grant transactions; however, it did not 

focus on broader grants management policies and procedures such as 

how to review applications and make award determinations, which would 

be critical for employees to properly carry out these activities. FMSCA did 

create some documented policies and procedures related to managing 

grant awards, though they were limited in scope and did not apply to all 

grant programs. For example, while FMCSA staff created policy memos 

that detailed some required policies and procedures, such as retaining 

grant award documents, these memos were created only for the MCSAP 

program. According to FMCSA officials, these memos were created and 

provided to staff generally on an as-needed basis—for example, when 

staff had questions about specific issues. In general, grants managers for 

a majority of FMCSA’s grant programs told us that they received minimal 

direction on grants management policies and procedures from FMCSA. In 

terms of employees’ roles and responsibilities, FMCSA documented 

these in program managers’ performance plans and evaluated relevant 

staff through the agency’s performance management system on their 

performance in meeting stated performance grants management 

expectations. However, FMCSA did not document roles and 

responsibilities details in one centralized document, for instance into 

existing grant related policies and procedures. As a result, grants 

management staff did not have access to a single set of comprehensive 

documented policies and procedures to guide them in awarding and 

managing FMCSA grants, and FMCSA management could not have 

reasonable assurance that applicable laws and FMCSA policies were 

followed.

Limitations in Policies and 

Procedures, Legal Review, 

Workforce Planning, 

Demonstrate Control 

Activity Weaknesses
 

Page 14 GAO-12-158 Federal Motor Carrier Safety Administration

In addition, as was the case with CVISN grants,20

Finally, FMCSA had not conducted a strategic workforce assessment to 

determine the skills and staffing levels needed to manage its grants 

programs. GAO’s internal control standards for control activities maintain 

agencies should ensure that skill needs are continually assessed and that 

their workforces have the skills necessary to help the agency meet its 

goals. We have reported that strategic workforce planning is an integral 

part of human capital management and helps an agency, among other 

things, determine the critical skills and competencies that will be needed 

to achieve current and future programmatic results and then develop 

strategies tailored to address any gaps identified.

according to FMCSA 

grants management staff, prior to fiscal year 2010, FMCSA did not 

require and conduct a formal legal review of every grant award to ensure 

that awards adhered to laws and regulations. According to our internal 

control standards, transactions, such as grant awards, should be properly 

authorized and made in compliance with laws and regulations. FMCSA 

grants management officials told us that legal staff involvement in grant 

award review was limited to answering questions and providing support 

on issues such as whether grant recipients would be providing required 

matching funds. The absence of a required legal review to ensure 

compliance increases the risk that other FMCSA awards may have 

violated laws or regulations, as was the case with certain CVISN awards.

21 As a result, FMCSA 

could not be sure if it had sufficient staff, as well as the needed skills and 

competencies, to manage its grant programs and make grant awards, 

increasing the risk of ineffectively and inefficiently run grant programs and 

award irregularities.

Prior to fiscal year 2010, FMCSA had inconsistent practices related to 

retention of grant award documentation and dissemination of information 

to grants management staff. Our internal control standards state agencies 

need to record and communicate relevant and reliable information related 

to their operations. Grants management staff we interviewed generally 

kept hard copy folders of award documentation, and some also scanned 

and uploaded hard copies into FMCSA’s Electronic Document 

 

20GAO-11-517R. 

21GAO, Human Capital: Key Principles for Effective Strategic Workforce Planning, 

GAO-04-39 (Washington, D.C.: Dec. 11, 2003), and GAO/AIMD-00-21.3.1.

Information and 

Communications Were Not 

Consistently Disseminated
 

Page 15 GAO-12-158 Federal Motor Carrier Safety Administration

Management System (EDMS)—FMCSA’s official document repository for 

all grants management documentation. However, while FMCSA directed 

grants management staff to use EDMS for grant files beginning in 2006, 

some staff told us that FMCSA did not specify which grant award 

documents should be saved in EDMS or in hard copy files. An internal 

control evaluation also found that FMCSA’s grant documentation was not 

stored consistently in EDMS. The inconsistent use of FMCSA’s EDMS 

system to maintain grant documentation increases the risk that FMCSA 

management may not have had needed electronic access to grant 

documentation, such as grant applications and supporting documentation, 

when making grant award decisions, which could have contributed to 

poor decision making and award irregularities.

In addition to issues related to the maintenance of grant documentation, 

according to FMCSA staff, the communication of information from 

management to grants management staff and among grants 

management staff was ad hoc and informal prior to fiscal year 2010, 

providing limited assurance that grants management information was 

adequately disseminated to staff in a timely manner. FMCSA did not have 

a communications plan to guide the methods through which certain types 

of information should have been communicated amongst grants 

management staff. According to GAO’s internal control standards, 

information should be communicated to management and other relevant 

agency officials in a timely manner and should be useful, reliable, and 

continuous. According to some grants management staff, FMCSA 

management often relied on regional service center staff to pass 

communications, such as grant announcements and grants policies and 

procedures, on to other field staff, including those who had key grants 

management responsibilities. However, by not directly communicating 

with other field staff, management could not be certain that all 52 Division 

Administrators passed on communications to all intended recipients or 

that the messages communicated were those FMCSA intended. Despite 

the lack of a formal communications strategy, some FMCSA grants 

management officials told us that they communicated well with one 

another as needed.

While FMCSA conducted some internal control monitoring activities 

related to grants management prior to fiscal year 2010 by including grants 

management in its annual internal control evaluations, FMCSA did not 

always address findings of internal control reviews in a timely manner. 

Our standards for internal controls state that agencies should promptly 

address and resolve the findings of audits. The fiscal year 2005 internal 

Internal Control 

Monitoring Efforts Did Not 

Always Result in Timely 

Actions 
 

Page 16 GAO-12-158 Federal Motor Carrier Safety Administration

control evaluation led to a corrective action plan calling for FMCSA to 

develop a grant program policies and procedures manual and to 

implement a centralized grant management oversight function. According 

to FMCSA management, FMCSA was able to close out this corrective 

action plan by releasing the Financial Management and Processing 

Manual for Grant Programs in 2006. However, some FMCSA grants 

management staff said that the 2006 manual was narrowly focused and 

that FMCSA management did not fully address this finding until the 

release of a more complete Grants Management Manual in the beginning 

of fiscal year 2010 (October 2009). Furthermore, the fiscal year 2005 

review led to a corrective action plan for FMCSA to implement a 

centralized grant management oversight function. However, FMCSA did 

not first formally propose a centralized function in the form of its proposed 

Grants Management Office (GMO) until fiscal year 2010. According to 

FMCSA officials, the agency did not address these findings in a more 

timely manner because it faced limited resources and wanted to take a 

sequential approach to transform its grants management. As a result, the 

agency did not want to design and propose the GMO until the foundation 

of the Grants Management Manual was in place. FMCSA’s failure to act 

quickly to fully correct these weaknesses increased the time during which 

grant awards may have been mismanaged due to unaddressed internal 

control weaknesses.

Inadequate internal controls applicable to FMCSA’s grants management 

process, such as those noted above, increased the risk that 

mismanagement and financial irregularities could have potentially 

occurred in any of FMCSA’s grant programs and not been detected in a 

timely manner. As noted earlier, an effective system of internal controls 

provides an agency with reasonable assurance that the objectives of 

internal controls—effective and efficient operations, reliable financial 

reporting, and compliance with applicable laws and regulations—are 

being achieved. Without effective controls, there is an increased risk that 

FMCSA’s grant programs may not have been well managed, and funds 

may not have been awarded in accordance with law and FMCSA policy. 

However, with the exception of CVISN, FMCSA has not conducted a 

review of all award transactions in its other grant programs and, as a 

result, does not know if any appropriations law or other violations may 

have occurred in those programs. The Department of Transportation 

hired an outside auditor to conduct a review, including legal compliance 

reviews, of a sample of FMCSA grant awards (other than CVISN) and 

released the results of the review in July 2011. This review looked at the 

grants management processes and internal controls of FMCSA’s grant 

programs, assessed FMCSA’s Grants Management Manual, and 
 

Page 17 GAO-12-158 Federal Motor Carrier Safety Administration

reviewed financial data and legislative compliance of a sample of 180 

total obligations and 135 total disbursements covering each of FMCSA’s 

grant programs other than CVISN from fiscal years 2005 to 2010. For 

those transactions tested, the review did not report any instance of

noncompliance with laws and regulations.22 FMCSA officials said they 

were pleased that this audit did not find any legal compliance findings, 

and they are not aware of any serious systematic legal compliance issues 

in its grant programs other than CVISN.

Since fiscal year 2010, FMCSA has taken a number of steps to 

standardize and improve internal controls over the agency’s grants 

management. These actions are broadly outlined in the agency’s April 

2011 Grants Management Program Roadmap, and include (1) 

centralizing grants management oversight and planning to create a 

centralized GMO to oversee and administer many grants management 

practices, (2) standardizing and documenting policies and procedures in 

its finalized Grants Management Manual mentioned above, (3) requiring 

legal reviews of all grant awards, (4) establishing a new grants 

management training program, (5) implementing new systems to manage 

and automate aspects of the grants management process and manage 

grant award documentation, and (6) improving its communications. 

Although these actions address some of FMCSA’s internal control 

weaknesses previously described, such as having only limited policies 

 

22This review observed other problems with award transactions, however. For example, 

the review observed that some grant agreements were missing required signatures and 

dates, and that FMCSA recorded some obligations before grant agreements were 

executed.

FMCSA Has Taken 

Steps to Strengthen 

Internal Controls, but 

Additional Actions 

Are Needed to Ensure 

Continued 

Improvement 

FMCSA has Strengthened 

Internal Controls, but 

Some Challenges Remain
 

Page 18 GAO-12-158 Federal Motor Carrier Safety Administration

and procedures and training for grants management staff, internal control 

weaknesses and some grants management challenges remain (see table 

3).

Table 3: Summary of FMCSA Initiatives to Improve Grants Management 

FMCSA initiative

Improvement over pre-2010 grants 

management

Remaining challenges and agency 

actions

Plans to create a GMO GMO centralized oversight would help eliminate 

inconsistencies and ensure that all staff have and 

are following correct policies and procedures. 

Limited workforce analysis to support 

FMCSA’s budget request for the GMO, or 

assess its broader workforce needs.

Standardizing policies and 

procedures in Grants Management 

Manual

Documenting policies and procedures, which 

include added legal review and grants 

management staff roles and responsibilities, could 

reduce errors in grant awards by providing staff 

with clear policies and processes to follow for all 

grant programs. 

Manual lacks details on some grant 

program staff’s roles and responsibilities.

Required legal reviews of all grant 

awards

Standardized legal reviews of all awards, following 

a legal checklist, should help ensure that awards 

comply with all applicable laws and regulations.

None.

GrantSolutionsa Requiring all grants management staff to use the 

same electronic system for the entire grants 

process helps ensure that all staff are following 

the same standardized policies and procedures 

and documenting the same information.

: a new system to 

manage grant processes

Some staff reported difficulties using 

GrantSolutions; FMCSA is working to 

address this.

Additional grants management 

training

Additional training can help to reduce staff errors 

and increase the likelihood that staff follow 

policies and procedures.

No training tracking system to ensure staff 

complete required training.

Improved communications

• Adopted SharePoint

• E-mail groups

b

• Communication plan

Adding communications tools and formalizing a 

communications plan improves the ability of 

FMCSA management to effectively communicate 

grants management information with its staff.

Communication plan lacks details. 

However, the agency noted that the 

communications plan is sufficient at this 

time and will continue to refine its internal 

communications as needed. 

Source: GAO analysis of FMCSA information.

a

GrantSolutions is an electronic grants management system created by the Department of Health and 

Human Service’s Center of Excellence for the review, evaluation, and selection of grant applications; 

award and monitoring of grants. FMCSA officials said they selected GrantSolutions from a short list of 

grant information systems provided by OMB, noting that GrantSolutions was the most mature of the 

systems.

b

FMCSA requested funding in its fiscal year 2011 and 2012 budget 

requests to establish a stand-alone GMO to strengthen oversight of 

FMCSA’s grants management by centralizing many of its grant 

management-specific duties, such as establishing standards and policies, 

developing training tools and job aids, and monitoring to help ensure 

compliance with regulations and legislation. (See fig 2.) For example, the 

SharePoint is a Web-based Microsoft program that allows users to share information.

Grants Management Office 

Should Help to Improve 

Oversight, but FMCSA 

Conducted Limited Analysis to 

Support Project Costs and 

Staffing Needs of the Office
 

Page 19 GAO-12-158 Federal Motor Carrier Safety Administration

GMO would oversee the development of training and job aids designed to 

help grants management staff understand and implement agency policies 

and procedures. However, FMCSA has not yet received funding to staff a 

GMO and thus has used existing FMCSA staff—such as the Chief 

Financial Officer (CFO)—and an FMCSA contractor to implement the 

GMO’s functions. For example, since April 2011, the CFO has been in 

charge of establishing policies and procedures, and FMCSA’s Chief 

Counsel has been responsible for conducting legal reviews. The GMO 

should help reduce the risk of grant award mismanagement by providing 

centralized and consistent oversight and reviews of all grant programs 

and holding all grant programs and grant managers to the same standard 

policies. In addition, according to some FMCSA officials we interviewed, 

by assuming administrative grant responsibilities now held by program 

staff, the GMO could ease the burden on those programmatic staff so 

they could focus on responsibilities related to their subject matter 

expertise. As a result, management should be in a better position to help 

ensure that grants are managed consistently and in line with policies and 

procedures, reducing the risk for award irregularities.

Figure 2: Planned GMO Responsibilities and Relationships with Other FMCSA 

Grants Management Positions

However, despite the GMO being central to the agency’s grant 

management improvements, FMCSA has not conducted a workforce 

analysis that could help the agency identify and fill gaps in expertise, 

including those that might be needed for the proposed GMO. We have 

reported in the past that while the specific approach to strategic workforce 

planning varies by individual agencies based on needs and missions, 

such strategies should determine the workforce skills and competencies 
 

Page 20 GAO-12-158 Federal Motor Carrier Safety Administration

needed to achieve future results and develop strategies to address gaps 

to ensure the agency has the necessary skills and competencies.23 Such 

planning is especially important in times of budget constraints and 

organizational change, as FMCSA is undergoing its grants management 

transformation. FMCSA officials told us that the agency had considered 

conducting a workforce analysis that could systematically assess its 

grants management skill and staff needs, and then determine if it has 

these skills and staff, and if it does not, how to obtain them. Further, 

FMCSA stated in its fiscal year 2011 budget request that it currently does 

not employ individuals that are trained in grants management. Yet the 

only action FMCSA has taken to assess its workforce was to create a 

model to assess the number of staff needed in the field—but not in 

headquarters—to meet requirements in grants management, program 

delivery, and oversight. According to FMCSA officials, in preparing its 

fiscal year 2011 budget request for $399,000 and three full-time 

equivalent employees for the GMO, they did more of an anecdotal 

assessment to determine GMO staffing needs, for instance noting that the 

agency’s current attorneys had too heavy a workload to devote enough 

time to reviewing grants and concluding that the agency needed a 

dedicated grants attorney.24

Officials told us that if FMCSA does not receive funding to support the 

GMO, the agency will continue to use existing staff such as the CFO and 

an outside contractor to assume many of the intended GMO functions. 

FMCSA officials told us that while they are 

considering a strategic workforce analysis for their headquarters grants 

management staff, they have not yet done so in part because FMCSA 

may not have the resources to fund the staff levels that such an analysis 

might recommend. Further, they noted that it would be difficult to 

determine workload and staffing needs until they developed, 

implemented, and trained staff in new grants management processes. 

Until FMCSA conducts a thorough workforce analysis, it will not know if it 

has the staff and skills necessary to effectively manage its grant 

programs and support the proposed GMO, or if it requires additional 

resources as it continues its grants management transformation.

 

23GAO-04-39. 

24In September 2010, FMCSA awarded a 3-year contract to an auditing firm to identify the 

skills and expertise needed for GMO staff positions, the accompanying job descriptions, 

and draft any policies needed. The auditing firm will not, however, conduct a workforce 

analysis for the GMO, which would include assessing FMCSA’s current skills and abilities, 

identifying any gaps, and then creating job descriptions for those gaps only.
 

Page 21 GAO-12-158 Federal Motor Carrier Safety Administration

FMCSA reported that these interim changes in staffing responsibilities 

create additional risks to the agency’s grants management as they 

increase reliance on contractors and delay the agency’s ability to 

implement changes that would enhance its employees’ grants 

management skills. In other words, in the agency’s opinion this alternate 

plan would do less to strengthen FMCSA’s internal controls than would a 

GMO, potentially leaving FMCSA’s grant awards at risk of 

mismanagement.

One of the key internal control improvements that FMCSA has made is to 

standardize and document its grants management policies and 

procedures, in its Grants Management Manual, which were inconsistently 

documented prior to 2010. According to FMCSA, the Manual is designed 

to “establish strong internal controls in the form of grant process 

standardization and promote greater adherence to policies, processes, 

and procedures.” FMCSA first issued the Manual in early fiscal year 2010 

and issued an update in January 2011. The Manual provides information 

on the roles and responsibilities of grants management staff and 

describes the steps in each stage of the grant process—from the grant 

announcement, to application review and award, and finally to closeout—

as well as the steps that staff are expected to follow in each stage. In 

addition, the Manual publishes grants management staff’s roles and 

responsibilities in one place, instead of across individuals’ performance 

plans as was customary prior to 2010. Including these descriptions in a 

document that all grants management staff have access to helps ensure 

that all staff know their and others’ roles and responsibilities, which 

should help increase accountability and the likelihood that all staff fulfill 

their documented responsibilities. Further, by documenting and setting 

consistent policies across all grant programs, the Manual should provide 

staff with the information needed to help ensure that grants are managed 

and awarded in line with FMCSA policies and with all relevant laws.

While the Manual strengthens FMCSA’s internal controls, grant program 

staff’s roles and responsibilities are still not sufficiently documented. For 

example, grants management positions detailed in the Manual include 

program manager, for the person in headquarters who manages all 

aspects of a specific grant program. However, there is a single list of roles 

and responsibilities for staff who manage grants in the field, including field 

administrators, service center directors, and state program managers. 

FMCSA officials told us that these individuals have different roles in the 

field, yet they have a single list of roles and responsibilities. In addition, a 

2011 external review of the agency’s grants management found that the 

Manual did not clearly describe who has responsibility for managing grant 

Grants Management Manual

Should Help Address Control 

Weaknesses but Still Lacks 

Details on Program Staff Roles 

and Responsibilities
 

Page 22 GAO-12-158 Federal Motor Carrier Safety Administration

award documentation or have clear explanations of two steps in the grant 

cycle—grant concurrence and approval. FMCSA officials told us that they 

believe that the grant concurrence and approval workflow diagrams 

displayed in the Manual depict the approval flow and clearly denote each 

reviewer in the process. In addition, FMCSA officials said that they 

provided more detailed information on these topics through training and 

job aids and that the agency intends to provide additional, possibly grant 

program specific information in standard operating procedure documents. 

However, in that case, details on all programs would not be located in one 

central place, and grants management staff might face challenges in 

keeping track of and following these various guidance documents. The 

review also noted that the Manual does not include a description for the 

financial program specialist, an individual who assists with financial 

oversight, and that work flow diagrams in the Manual are not clear, which 

may confuse staff on certain grants management roles and 

responsibilities.

The Manual also describes a new requirement for all grants to be formally 

reviewed by the Office of Chief Counsel prior to award. FMCSA created 

checklists—one for each grant program—to guide these legal reviews to 

ensure that awards follow all applicable laws and regulations. Required 

and standardized legal reviews should reduce the risk that CVISN-type 

statutory violations occur in the future by providing a structured legal 

framework for attorneys to follow during legal reviews. EPA uses similar 

reviews and ensures that review checklists are updated annually to 

incorporate any new requirements and laws.25

FMCSA implemented a new electronic grants management system, 

GrantSolutions, to manage the process for all phases of grant awards. 

While there have been some challenges in implementing the system, 

FMCSA officials noted that requiring all grants management staff to use 

the new system for the entire grants process helps ensure that all staff 

are following the same standardized policies and procedures and 

documenting the same information, which was not necessarily the case 

prior to 2010. In addition, the system helps ensure that certain tasks are 

completed by building them into the system’s automated workflow. For 

Updating these checklists 

on a regular basis helps ensure that all relevant laws, regulations, and 

requirements are followed when awarding grants.

 

25In addition to a legal checklist, EPA staff also use checklists for budget reviews.

Required Legal Reviews of All 

Awards Should Help Ensure 

Compliance with Laws and 

Regulations 

The New Grants Management 

System Poses Some 

Challenges, but the System 

Should Help Standardize 

Process and Procedures
 

Page 23 GAO-12-158 Federal Motor Carrier Safety Administration

example, the Financial Management Office will conduct its financial 

review as part of the funding and approval processes in GrantSolutions.

FMCSA staff began using GrantSolutions to manage grant awards and as 

the official repository of grant-related documentation in fiscal year 2011. 

Some grant managers we interviewed said that GrantSolutions was 

challenging to use, particularly at first. FMCSA officials told us that 

because GrantSolutions was developed for the Department of Health and 

Human Services, it is not customized for FMCSA’s needs, making it 

challenging at times to use. FMCSA officials noted that they are working 

with GrantSolutions developers at the Department of Health and Human 

Services to customize the system to the extent possible and have had to 

supplement training on the system provided by the Department of Health 

and Human Services with FMCSA-provided training courses and 

materials. However, regardless of the challenges noted by some staff, 

FMCSA reported that GrantSolutions will help to ensure that all required 

grant documents are saved and stored in the system. Having a single 

system in which staff are required to store all relevant grant 

documentation will help ensure that documents are located together in 

one place when grant managers and other relevant individuals, such as 

those who serve on technical review panels, need to review them and 

make award decisions based on them.

FMCSA implemented additional required training for grant managers, 

which should help to strengthen its controls over grants management. 

FMCSA began training staff on the contents of the Manual in spring 2011 

and plans to add more comprehensive 2-day grants management training 

in 2012.26 FMCSA officials told us the agency has contracted with outside 

training providers for training it cannot provide itself, including 

appropriations law training.27

 

26FMCSA identified a need for this 2-day training through a review of its training 

curriculum conducted by an outside contractor. The contractor’s review found that FMCSA 

could best meet the needs of its employees by using contractors such as the U.S. 

Department of Agriculture Graduate School, to conduct some of its training and 

developing its own training for topics specific to FMCSA employees.

FMCSA reported that training will help 

grants management staff better understand the FMCSA policies, as well 

as the laws and regulations that they should follow when managing grant 

awards. This is particularly important in light of the agency’s 

27According to FMCSA officials, the agency will offer appropriations law training twice in 

2011 and will likely offer it three times per year starting in 2012.

New Grants Management 

Training Helps Strengthen 

Controls, but Lacks an 

Adequate Tracking System 
 

Page 24 GAO-12-158 Federal Motor Carrier Safety Administration

Antideficiency Act violations in its CVISN program, which, as mentioned 

previously, occurred in part because staff did not fully adhere to the 

funding restrictions governing the program. According to FMCSA’s Grants 

Management Program Roadmap, staff that attend this new 2-day training 

will be required to pass an exam before graduating from the course; 

however, FMCSA has not specified what will occur if staff do not pass the 

exam.

Despite the improvements in the curriculum, FMCSA does not have a 

system for management to easily track employee training to ensure that 

staff complete required training and are continuing to keep their skills and 

knowledge up to date. FMCSA currently documents required training in 

employees’ individual development plans. Separately, FMCSA’s 

electronic training system lists courses and the names of staff who have 

completed them. According to FMCSA officials, the training system does 

not contain information from individual development plans, 28

In contrast, though EPA also requires regular training for grants 

management staff, it uses a system that identifies staff who have not 

taken required training, which allows management to contact those 

individuals to ensure that they complete it. EPA also ensures its grants 

management staff complete required training by limiting access to the 

agency’s grants management system—a system staff need to perform 

their job functions—to only those staff that have completed the training 

required to become certified grant project officers. Grant project officers 

who do not take required training are unable to process grant awards. 

Moreover, staff must take a refresher course to maintain their certification 

so it cannot 

identify employees who have not taken certain training courses. As such, 

FMCSA relies on, but does not require, supervisors to monitor staff 

training. Supervisors keep track of which employees have not completed 

required training by cross-referencing the requirements in the individual’s 

development plan and the names of those who completed the 

requirements in the training system. Since the information is not all in one 

location, management may not know if staff fail to complete required 

training. The absence of a formal, centralized mechanism for tracking 

staff training increases the risk that a staff’s failure to take a required 

course could go undetected, increasing the risk that staff do not have the 

knowledge needed to appropriately manage grant awards.

 

28Individual development plans document employees’ roles and responsibilities. 
 

Page 25 GAO-12-158 Federal Motor Carrier Safety Administration

every 3 years. Finally, EPA reviews its training periodically to identify new 

regulations or other information that grant management staff need to 

know and incorporates it into the training. NHTSA also has required 

training for grants management staff, including required refresher training 

every 2 years for managers of discretionary grants. NHTSA discretionary 

grants managers are required by OMB to take “Contracting Officer’s 

Technical Representative” training.

FMCSA has improved its methods for communicating grants 

management information to staff and has created a communications plan 

to guide grants management communications. FMCSA hired contractors 

to implement SharePoint, a Web-based system developed by Microsoft, 

and began using it in October 2010. FMCSA uses SharePoint to share 

and disseminate grants management and other documents to internal 

staff. Currently, most of SharePoint is dedicated to the contents of the 

Manual, though FMCSA also uses it for grants management “frequently 

asked questions” and forums. Second, FMCSA set up e-mail groups for 

job categories, including grant Program Managers and Division 

Administrators, to help ensure that it can target communications to 

specific groups. Whereas, prior to 2010, FMCSA management in 

headquarters relied on Division Administrators to pass communications 

on to other field staff, management can now communicate directly with 

their intended recipients, thus increasing the likelihood that grant 

management staff receive the information management intended them to 

receive. Finally, in contrast to the ad hoc communications FMCSA relied 

on prior to fiscal year 2010, FMCSA created a communications plan in 

2011 that outlines a strategy for communicating with stakeholders during 

its grants management transformation. A communication strategy is 

essential to an organization undergoing significant change, like FMCSA, 

which is transforming its grants management program. A communication 

strategy helps ensure consistency of message, encourages two-way 

communication, provides information to meet specific needs of 

employees, and facilitates more frequent communication.29

 

29GAO, Results Oriented Cultures: Implementation Steps to Assist Mergers and 

Organizational Transformations, 

While 

FMCSA’s strategy lacks some details—for example, specific information 

on the types of messages that will be communicated to staff— the agency 

noted that its communication plan is sufficient at this time and will 

continue to evolve as it identifies additional communication needs.

GAO-03-669 (Washington, D.C.: July 2, 2003). 

New System and Plan Improve 

Communications and Plan 

Continues to Evolve
 

Page 26 GAO-12-158 Federal Motor Carrier Safety Administration

FMCSA has begun to initiate a number of improvements to internal 

controls over its grants management that should help reduce the risk for 

grant award irregularities and mismanagement, but there are additional 

challenges that could impact the agency’s ability to continue to 

successfully transform its grants management. When undergoing such 

transformations, we have reported30 that it is important for agencies to 

undertake certain practices like (1) establishing a coherent mission 

guiding the transformation, (2) involving employees in the transformation, 

(3) establishing a communication strategy to report progress, (4) ensuring 

that agency leadership drives transformational change, and (5) 

establishing results-oriented goals and a strategy and timeline for tracking 

performance towards achieving them.31

FMCSA’s ongoing initiatives reflect the agency’s progress in 

implementing the first three of these practices, but it is unclear if the 

agency will be able to make progress in the other two—ensuring it has 

appropriate leadership and establishing goals to measure its progress. 

For example, the Grants Management Program Roadmap, previously 

described, provides a coherent framework and mission guiding FMCSA’s 

grants management transformation. In addition, FMCSA employees were 

involved in developing both the Roadmap and the Manual and, as we 

previously noted, although its scope is limited, FMCSA created a 

communication plan. However, it is unclear if the agency will have 

sufficient leadership to drive this transformation in the future, as it may not 

receive funding for its centralized GMO in fiscal year 2012, and its CFO, 

who oversaw many of the new grants management initiatives and was 

designated as the individual to whom the GMO would report if it is 

created, left the agency in August of this year. We have previously

reported that top leadership must set the direction, pace, and tone for 

agency transformation.32

 

30

It is important for FMCSA’s next CFO to 

GAO-03-669. 

31This is based on GPRA. To promote improved federal management and greater 

efficiency and effectiveness, GPRA instituted a government-wide requirement that 

agencies set goals and report annually on performance, and encouraged federal agencies 

to conduct in-depth program evaluations to assess their program’ impact or learn how to 

improve results. Performance information is critical for achieving results and maximizing 

the return on federal funds.

32GAO-03-669. 

Additional Actions Could 

Help Ensure Continued 

Grants Management 

Improvements
 

Page 27 GAO-12-158 Federal Motor Carrier Safety Administration

continue to provide such leadership given that officer’s role in grants 

management.

Further, FMCSA has not set metrics to measure its performance in 

meeting grants management goals. While the Grants Management 

Program Roadmap includes milestones, they are for implementation 

steps only, such as dates by which FMCSA will roll out grants 

management training. Performance metrics could help FMCSA identify 

the extent to which the changes it is making contribute to reducing the 

risk for financial or management mistakes. This information, in turn, could 

help inform FMCSA’s decisions about which actions to continue and 

which need to be modified or discontinued. This information could also 

help FMCSA demonstrate to Congress that, despite its past violations, it 

is committed to improving its grants management. EPA’s grants 

management plan, for example, includes a system for monitoring the 

implementation of its grants management changes and evaluating the 

extent to which they meet certain performance targets.33 For instance, 

one of the grants management goals under the plan is to “enhance the 

management process for grants policies and procedures,” and one of the 

performance targets it will use to track its progress toward meeting this 

goal is to “offer training on 100% of new and revised policies at least 4 

weeks before required implementation.” In this way, EPA can measure its 

performance and progress in meeting grants management goals and 

determine additional improvements.

The federal government and state governments are experiencing severe

budgetary constraints, consequently it is essential that the federal 

government increase its attention to how federal grant funds are awarded 

and spent. FMCSA relies on states to deliver a number of motor carrier 

safety grant programs, and many states rely on FMCSA grant funds to 

help deliver these critical programs. In 2011, DOT determined that it had 

violated federal appropriations statutes, including the Antideficiency Act34

 

33For EPA’s grants management plan, see United States Environmental Protection 

Agency, “Grants Management Plan 2009 -2013,” 

http://www.epa.gov/ogd/EO/finalreport.pdf. For additional information on EPA’s grants 

management, see 

in awarding some CVISN grants from fiscal years 2006 to 2010. While 

GAO-06-625. 

34As stated above, the Antideficiency Act prohibits federal agencies from incurring an 

obligation that exceeds their available appropriation or contract authority. GAO-11-517R. 

Conclusions 
 

Page 28 GAO-12-158 Federal Motor Carrier Safety Administration

these violations were specific to the CVISN program, some of the internal 

control weaknesses that contributed to those violations existed across 

FMCSA’s additional nine grant programs.

FMCSA’s recent grants management initiatives, such as the Grants 

Management Manual and grants management training, appear to be 

positive steps in addressing internal control weaknesses that were 

prevalent in FMCSA’s grant programs prior to fiscal year 2010, including 

those found to have contributed to statutory violations pertaining to 

CVISN awards. However, many of the initiatives are relatively new, and it 

is too soon to tell whether they will ultimately be successful in addressing 

internal control weaknesses. In particular, while FMCSA plans to staff a 

centralized Grants Management Office—an important component of its 

grants management transformation—the agency has yet to conduct a 

strategic analysis of its grants management workforce needs including 

resources needed for this office. For the initiatives that FMCSA has 

implemented, additional improvements could help ensure their success. 

For example, adding information to the Grants Management Manual on 

staff roles and responsibilities and adequately tracking required training 

will ensure grants management staff are equipped to effectively manage 

grant awards. Finally, setting goals and measures and tracking progress 

toward meeting those goals can help ensure that the agency continues to 

head in the right direction in its grants management transformation. 

Without implementing some of these additional efforts, FMCSA’s grants 

management initiatives could fall short of their objective to achieve 

effective internal controls, and the agency’s grant awards will continue to 

be at risk of financial irregularities.

Given the importance of FMCSA’s grants programs in helping meet the 

agency’s goals, we recommend that the Secretary of Transportation 

direct the FMCSA Administrator to take the following four actions:

• In order to better determine its staffing and skill needs for grants 

management, conduct a strategic grants management workforce 

planning evaluation, including an analysis of the needed staff 

resources for the proposed GMO.

• To further improve grants management policies and procedures, add 

details regarding staff roles and responsibilities in the Grants 

Management Manual so that grants management staff are 

appropriately informed to manage each program.

Recommendations for 

Executive Action
 

Page 29 GAO-12-158 Federal Motor Carrier Safety Administration

• To improve its tracking of grants management training, work with the 

appropriate DOT individuals to modify its training system to allow 

management to easily determine which staff have taken required 

training.

• In order to track the progress of its grants management 

transformation, create a series of measurable grants management 

goals and objectives and timelines for completing them, as well as a 

series of metrics to measure progress in meeting these goals. FMCSA 

should detail these goals and metrics in its Grants Management

Program Roadmap, track progress in meeting these goals over time, 

and report to Congress on its progress.

We provided a copy of our draft report to DOT for review and comment. 

DOT generally agreed with our recommendations and provided 

comments via e-mail that were primarily technical in nature, which we 

incorporated as appropriate. DOT did comment on two of the 

recommendations in our draft report. First, in response to our 

recommendation that FMCSA modify its training system, FMCSA officials 

noted that FMCSA uses a DOT-mandated Training Management System 

to track grants management training, and that they do not have control 

over the features or functionality of this system. As such, we modified the 

language in our report to recommend that FMCSA work with appropriate 

individuals at DOT to modify the training system. Second, our draft 

recommendation that FMCSA create grants management goals and 

objectives and report to Congress on their progress in meeting them 

stated that FMCSA should report to Congress annually. In response, 

FMCSA officials noted that the agency already updates Congress on its 

programs regularly and that an annual report on its grants management 

goals would be administratively burdensome. We agreed that FMCSA 

could keep Congress informed without submitting a separate annual 

report, and thus removed the reference to “annually” from our 

recommendation.

We also provided a copy of our draft report to EPA for review and 

comment. EPA did not have any comments.

Agency Comments 

and Our Evaluation
 

Page 30 GAO-12-158 Federal Motor Carrier Safety Administration

We are sending copies of this report to the appropriate congressional 

committees, DOT, EPA, and other interested parties. The report also is 

available at no charge on the GAO website at http://www.gao.gov.

If you or your staff members have any questions about this report, please 

contact me at flemings@gao.gov or (202) 512-2834. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found 

on the last page of this report. Key contributors to this report are listed in 

appendix II. 

Susan A. Fleming

Director, Physical Infrastructure Issues
 

Page 31 GAO-12-158 Federal Motor Carrier Safety Administration

List of Requesters

The Honorable Patty Murray

Chairman

The Honorable Susan Collins

Ranking Member

Subcommittee on Transportation, 

Housing and Urban Development 

 and Related Agencies

Committee on Appropriations

United States Senate

The Honorable Tom Latham

Chairman

The Honorable John W. Olver

Ranking Member

Subcommittee on Transportation, 

Housing and Urban Development 

 and Related Agencies

Committee on Appropriations

House of Representatives
Appendix I: Objectives, Scope, and 

Methodology

Page 32 GAO-12-158 Federal Motor Carrier Safety Administration

In order to address the extent to which, prior to fiscal year 2010, the 

Federal Motor Carrier Safety Administration’s (FMCSA) grant programs 

had internal controls in place that reduce the risk of grant award 

irregularities, we reviewed GAO’s Standards for Internal Control in the 

Federal Government to determine internal control standards relevant to 

the management of grant programs. In addition, we reviewed GAO’s prior 

work on FMCSA’s Commercial Vehicle Information Systems and 

Networks (CVISN) grant program to determine internal control 

weaknesses that contributed to financial irregularities with CVISN grant 

awards. We interviewed the grant program manager for each program 

other than CVISN prior to fiscal year 2010 to discuss how each grant 

program was managed at that time and the internal controls that were in 

place over the grant programs. We did not include CVISN in this review 

given the work we had already conducted on that grant program. We 

collected and analyzed relevant documentation, such as grant policy 

memos, related to internal controls over grants. We also interviewed 

FMCSA headquarters officials, including the Chief Financial Officer 

(CFO), regarding internal controls.

We also interviewed FMCSA officials and FMCSA grant recipients from 

four states—Alabama, Alaska, Arizona, and Wisconsin. We selected 

these four states because they were among those identified by FMCSA 

as having received irregular CVISN awards and also received a number 

of non-CVISN grant awards, which allowed us to interview fiscal year 

2011 recipients of all of FMCSA’s grant programs, aside from the 

Commercial Motor Vehicle Operator Safety Training Grant. We 

determined that not including interviewing any recipients of this grant was 

acceptable given its small size (a total of $1 million in awards) and that 

recipients are generally private training providers and educational 

institutions as opposed to state government agencies, which are the 

primary recipients of FMCSA’s other grants. In each state we interviewed 

key grants management FMCSA staff at the Division Office—primarily 

Division Administrators and State Program Specialists—regarding their 

role in managing FMCSA grants as well as internal controls that were in 

place for managing those grants prior to fiscal year 2010. We also 

interviewed recipients of each grant in each state regarding their 

experiences with receiving FMCSA grants and of FMCSA’s management 

of making grant awards.

Finally, we reviewed audits related to internal controls and grants 

management, including grants management internal control evaluations 

and corrective action plans for FMCSA for fiscal years 2007 through 2010 

and two audits conducted by an outside auditor (Deloitte) following the 

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 33 GAO-12-158 Federal Motor Carrier Safety Administration

discovery by FMCSA of irregular CVISN awards to review findings made 

by other audits regarding grants management internal control 

weaknesses at FMCSA prior to fiscal year 2010. We also interviewed 

FMCSA staff, as well as representatives of FMCSA’s independent internal 

control auditor.

In order to determine actions FMCSA is taking to improve its grants 

management to reduce the risk for financial irregularities in awarding 

grants and the challenges that remain, we interviewed FMCSA 

management about the agency’s efforts to improve grants management 

and reviewed documentation related to these efforts including the Grants 

Management Program Roadmap, Grants Management Manual, and 

documentation on FMCSA’s proposed grants management office. We 

analyzed these documents and staff responses to determine the extent to 

which they addressed the internal control weaknesses we and others 

identified at FMCSA. We also analyzed these documents and interviews 

to identify any internal control weaknesses or challenges that persisted 

despite FMCSA’s improvements. We also interviewed select FMCSA field 

office staff discussed earlier regarding their views on FMCSA’s current 

grants management transformation initiatives.

We also conducted a literature search and reviewed prior GAO work on 

grants management practices, particularly as it relates to internal controls 

over the awarding of grants. Finally, we met with grants management 

officials at the Environmental Protection Agency (EPA) and the National 

Highway Traffic Safety Administration (NHTSA) to discuss how those 

agencies manage their grant programs and analyzed relevant grants 

management documentation from those agencies. We selected these 

agencies because they, like FMCSA devote at least 50 percent of their 

budgets to grants, and have a safety focus. We interviewed EPA and 

NHTSA grants management officials to discuss how their agencies 

manage grants, what challenges they face in doing so, and what internal 

controls they employ over grants management. We reviewed relevant 

documentation related to grants management at both agencies such as 

EPA’s grants management plan and NHTSA’s discretionary grants 

management manual.
Appendix II: GAO Contact and Staff 

Acknowledgments

Page 34 GAO-12-158 Federal Motor Carrier Safety Administration

Susan A. Fleming, (202) 512-2834, or flemings@gao.gov

In addition to the individual above, Sharon Silas, Assistant Director; Sarah 

Farkas; Tom James; Delwen Jones; SaraAnn Moessbauer; John J. Reilly; 

Matthew Rosenberg; and Crystal Wesco made key contributions to this 

report.

Appendix II: GAO Contact and Staff

Acknowledgments 

GAO Contact 

Staff 

Acknowledgments

(541080)
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