Report to the Subcommittee on 

Transportation, Treasury, the Judiciary, 

Housing and Urban Development, and 

Related Agencies, Committee on 

Appropriations, U.S. Senate 

United States Government Accountability Office

GAO

March 2005 ANTI-DRUG MEDIA 

CAMPAIGN 

An Array of Services 

Was Provided, but 

Most Funds Were 

Committed to Buying 

Media Time and Space

GAO-05-175 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-05-175.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Laurie Ekstrand 

at (202) 512-8777 or ekstrandl@gao.gov. 

Highlights of GAO-05-175, a report to the 

Chairman and Ranking Member, 

Subcommittee on Transportation, 

Treasury, the Judiciary, Housing and 

Urban Development, and Related 

Agencies, Committee on Appropriations, 

U.S. Senate 

March 2005

ANTI-DRUG MEDIA CAMPAIGN 

An Array of Services Was Provided, but 

Most Funds Were Committed to Buying 

Media Time and Space 

Our analysis of contracts covering ONDCP’s National Youth Anti-Drug Media 

Campaign from fiscal years 2002 through 2004 revealed that four contractors 

provided many of the services required to execute the campaign. These four 

prime contractors provided an array of services that fell within three broad 

categories: (1) advertising, (2) public communications and outreach, and 

(3) evaluation services to gauge the campaign’s effectiveness. The prime 

contractors also acquired additional specialized expertise from 102 

subcontractors. Some of the specific tasks performed by the contractors 

and their subcontractors included conducting qualitative and quantitative 

research for advertising creation, working with the entertainment industry to 

portray the negative consequences of drug use in television and movies, and 

conducting an evaluation intended to measure the effectiveness of the media 

campaign. Based on our analysis of contracts covering fiscal years 2002 

through 2004, we estimated that $520 million was awarded to the four prime 

contractors, of which an estimated $373 million—72 percent—was 

committed to purchasing media time and space for campaign 

advertisements. The remaining $147 million—28 percent—was for the 

services provided by the prime contractors. Contractors, in turn, awarded 

$14 million of that amount to their subcontractors. 

Estimated Award Amounts for Contractor Services and Purchase of Media Time and Space 

(fiscal years 2002-2004) 

Advertising 

services

Evaluation sevices

Public communications

and outreach services

Purchase of media 

time and space

Total: $520

Subtotal: 147

Services provided

by prime contractors

Estimated 

award amount 

(in millions of dollars)

Oglivy & 

Mather

The Advertising

 Council, Inc.

Fleishman -

Hillard, Inc.

Westat, Inc.

0.9%

3.5%

5.2%

18.7%

19.6%

71.8%

$5

27

18

97

373

Source: GAO.

Prime

contractors

Media

activity

Note: Percentages may not add up to 100 percent due to rounding. 

The Office of National Drug 

Control Policy (ONDCP) was 

required by the Drug Free Media 

Campaign Act of 1998 (21 U.S.C. 

1801 et seq.) to conduct a national 

media campaign to reduce and 

prevent drug use among America’s 

youth. Since 1998, Congress has 

appropriated over $1 billion for the 

media campaign. However, a 2003 

report by the Senate Committee on 

Appropriations expressed some 

concerns about the media 

campaign, including concern that a 

large portion of the campaign’s 

budget had been used for 

consulting services rather than the 

direct purchase of media time and 

space. The report, therefore, 

directed GAO to review the use of 

consultants to support the media 

campaign. 

This report describes the services 

provided by consultants (defined 

by GAO as the prime contractors 

and their subcontractors) in 

support of the media campaign, 

along with the estimated award 

amounts for these services. 
Page i GAO-05-175 Anti-Drug Media Campaign 

Letter 1

Results in Brief 2 

Background 3 

Prime Contractors and Their Subcontractors Provided Three Broad 

Categories of Services, but Most of the Estimated Award Dollars 

Were Committed to Purchasing Media Time and Space 6 

ONDCP’s Comments and Our Evaluation 13 

Appendix I Scope and Methodology 16 

Appendix II Three Phases of Advertising Development 22 

Appendix III Ogilvy & Mather’s Subcontractor Services and 

Associated Estimated Award Amounts 25 

Appendix IV Fleishman-Hillard Subcontractor Services and 

Associated Estimated Award Amounts 27 

Appendix V Comments from the Office of National Drug Control 

Policy 32 

Appendix VI GAO Contacts and Staff Acknowledgments 35 

GAO Contacts 35 

Staff Acknowledgments 35 

Tables 

Table 1: Estimated Award Amounts to Subcontractors during 

Fiscal Years 2002-2004 9 

Table 2: Services Provided by the 102 Subcontractors in Support of 

the Media Campaign during Fiscal Years 2002 through 2004 12 

Contents 
Page ii GAO-05-175 Anti-Drug Media Campaign 

Table 3: Estimated Contract Award Amounts to Groups of 

Fleishman-Hillard Subcontractors by Fiscal Year (2002-

2004) 27 

Figures 

Figure 1: Media Campaign’s Advertising Development/Research 

Process 5 

Figure 2: Estimated Award Amounts for Contractor Services and 

Purchase of Media Time and Space during Fiscal Years 

2002-2004 7 

Figure 3: Example of Award-Based Data Calculation 18 

Figure 4: Example of Rate-Based Data Calculation 20 

Abbreviations 

BCEP Behavioral Change Expert Panel 

DCI data collection instrument 

FCEP Formative Creative Evaluation Panel 

MAM Madison Advertising Management, LTD. 

NIDA National Institute on Drug Abuse 

ONDCP Office of National Drug Control Policy 

PDFA The Partnership for a Drug-Free America 

SADD Students Against Destructive Decisions, Inc. 

VNR video news release 

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Page 1 GAO-05-175 Anti-Drug Media Campaign 

March 31, 2005 

The Honorable Christopher Bond 

Chairman 

The Honorable Patty Murray 

Ranking Member 

Subcommittee on Transportation, Treasury, the Judiciary, 

 Housing and Urban Development, and Related Agencies 

Committee on Appropriations 

United States Senate 

The Office of National Drug Control Policy (ONDCP) is charged with 

reducing illicit drug use, manufacturing and trafficking, drug-related crime 

and violence, and drug-related health consequences. To achieve these 

goals, the office formulates a National Drug Control Strategy that includes 

multipronged approaches to combating national drug use. Among these 

approaches is an effort to reduce and prevent drug use among America’s 

youth by conducting educational and community action programs, 

including a National Youth Anti-Drug Media Campaign. The campaign 

combines paid and donated advertising with public communications 

outreach in an effort to change teen and parental beliefs and behaviors 

regarding drug use. 

Congress first authorized funding for the media campaign in fiscal year 

1998, with the expectation that demonstrable changes in youth drug 

behaviors would be apparent within 3 years. Since then, over $1 billion has 

been appropriated for the media campaign. In a committee report for the 

fiscal year 2004 appropriations cycle, the Senate Appropriations 

Committee asserted that drug use was increasing in spite of the campaign 

and that some observers had concluded that the campaign was having no 

noticeable impact.1

 In addition, the report asserted that a large portion of 

the campaign’s budget pays for outside media and advertising consultants. 

As such, the report expressed concern about the amount of resources 

consumed by consultants and the extent to which funds were spent for 

 1

Senate Report No. 108-146, at 143 (2003) accompanied the media campaign’s proposed 

2004 appropriation in the Transportation, Treasury & General Government Appropriations 

Bill, 2004, S. 1589, 108th Cong. The media campaign’s 2004 appropriation was ultimately 

enacted as part of the Consolidated Appropriations Act, 2004, P.L. 108-199, 118 Stat. 325 

(2004). 

United States Government Accountability Office

Washington, DC 20548 
Page 2 GAO-05-175 Anti-Drug Media Campaign 

consulting services rather than media time and space for advertisements. 

Given these issues, the committee report directed us to review how 

consultants were used in support of the media campaign.2

 This report 

focuses on the following question: What services did contractors and their 

subcontractors provide in support of ONDCP’s media campaign and what 

were the estimated award amounts for these services for fiscal years 2002 

through 2004? We are currently conducting a separate review examining 

the design and execution of ONDCP’s primary effort to evaluate the media 

campaign’s effectiveness. 

To respond to the question for this report, we met with and obtained 

documentation from officials at ONDCP headquarters and contractor and 

subcontractor officials in Washington, D.C., and New York City that 

supported the media campaign. We analyzed the contracts of the prime 

contractors and their subcontractors to determine the services they 

provided and the associated estimated award amounts. We used estimated 

award data because at the time of our review actual expenditure 

information was not complete. We conducted our work from March 2004 

through February 2005 in accordance with generally accepted government 

auditing standards. Appendix I provides more detailed information about 

the scope and methodology of our work. 

During fiscal years 2002 through 2004, the four prime contractors we 

reviewed and their 102 subcontractors provided a variety of services that 

fell within three broad categories: (1) advertising, (2) public 

communications and outreach, and (3) evaluation services. Some of the 

specific tasks they performed included conducting qualitative and 

quantitative research for advertising creation, working with the 

entertainment industry to portray the negative consequences of drug use 

 2

The senate committee report that mandated our review did not define the term 

“consultants.” But given the concern expressed by the committee, we focused our review 

on the prime contractors and their subcontractors used by ONDCP to implement the media 

campaign. During the period of our review, ONDCP obtained acquisition services to award 

the contracts in support of its media campaign from the U.S. Navy Fleet Industrial Supply 

Center (FISC) and GovWorks (a service-for-fee federal acquisition center, operating under 

the U.S. Department of the Interior’s Franchise Fund). Acquisition services included 

planning, soliciting, awarding, administering, terminating, and closing out all contracts for 

ONDCP’s media campaign. ONDCP’s contract management responsibilities included, 

among other things, developing statements of work and tracking and reporting on 

contractors’ performance. Although the contracts were awarded and managed by FISC and 

GovWorks on behalf of ONDCP, because ONDCP provided the funding for these contracts, 

we refer to ONDCP as having used these contractors to implement the media campaign. 

Results in Brief 
Page 3 GAO-05-175 Anti-Drug Media Campaign 

in television and movies, and evaluating the campaign’s effectiveness. 

Based on our analysis of contracts awarded for fiscal years 2002 through 

2004, we estimated that $520 million was awarded to the four prime 

contractors. However, of this $520 million, an estimated $373 million—72 

percent—was committed to purchasing media time and space for 

advertisements. The remaining $147 million—28 percent—was for the 

services provided by the prime contractors. Of that amount, $14 million 

was awarded to the subcontractors by the prime contractors. 

In commenting on a draft of this report, the Director of the Office of 

National Drug Control Policy generally agreed with our findings. ONDCP 

provided technical comments that have been incorporated into this report 

where appropriate. 

The Drug-Free Media Campaign Act of 1998, 21 U.S.C. 1801 et seq., 

required the Office of National Drug Control Policy to conduct a national 

media campaign to reduce and prevent drug abuse among America’s 

youth. The act specified certain uses of funds provided for the media 

campaign to include (1) the purchase of media time and space; (2) out-ofpocket advertising production costs; (3) testing and evaluation of 

advertising; (4) evaluation of effectiveness; (5) partnerships with 

community, civic, and professional groups and with government 

organizations; (6) collaboration with the entertainment industry to 

incorporate anti-drug messages in movies, television, Internet media 

projects, and public information; (7) news media outreach; and 

(8) corporate sponsorship and participation, among other uses. The act 

also mandated a matching requirement. To implement this requirement, 

ONDCP developed a pro bono match program requiring media vendors 

who sell advertising time or space to the media campaign to provide (1) an 

equivalent amount of free public service time or space or (2) an equivalent 

in-kind contribution. 

Congress has appropriated over $1 billion for ONDCP’s media campaign 

since it was initiated in 1998. However, the media campaign’s annual 

appropriations have declined since Congress initially funded the program. 

ONDCP’s 2005 appropriation provides $120 million for the media 

campaign, which represents a $25 million decline from the 2004 

appropriation and a $75 million decline from the first-year funding in 1998. 

Background 

Congressional 

Authorization and Funding 

of the Media Campaign 
Page 4 GAO-05-175 Anti-Drug Media Campaign 

The media campaign employs an iterative three-phase advertising 

development and research process. The first phase, the exploratory 

research phase, occurs before advertisements are created. For example, 

before developing the “Monitoring/Love” advertisement series—a message 

targeting parents, promoting awareness of their children’s whereabouts—

extensive research was conducted to help ad creators understand methods 

of communicating effectively with parents of teens.3

 The second phase 

consists of creating advertisements and subjecting them to research and 

expert review. For example, in the “Monitoring/Love” series, focus groups 

were used to assess parents’ reactions to a set of advertising concepts. The 

concepts were subsequently revised in response to the feedback. Once the 

concepts were approved by ONDCP, the actual advertisements were 

produced and tested for effectiveness. The third and final phase begins 

after the advertisements have been determined to meet ONDCP’s 

effectiveness standards and involves the strategic placement of the 

advertisements in television, radio, and print media. For example, the 

“Monitoring/Love” series advertisements were aired during television 

shows and radio programs most popular with the target audience, the 

parents of teens. This phase also involves measuring the effectiveness of 

specific advertisements over time within target audiences. See figure 1 for 

a depiction of the three-stage process. Appendix II provides a more 

detailed description of the campaign’s advertising development and 

research process. 

 3

An advertising series is a set of three or four advertisements with a common theme. 

Media Campaign’s 

Advertising Development 

and Research Process 
Page 5 GAO-05-175 Anti-Drug Media Campaign 

Figure 1: Media Campaign’s Advertising Development/Research Process 

ONDCP uses advertising contractors to supplement its in-house 

capabilities regarding the development, production, and placement of paid 

advertisements on television, radio, print, and the Internet. The media 

campaign also used a contractor to provide assistance with public 

communications and outreach for the campaign, for example, encouraging 

the entertainment industry to portray the negative consequences of drug 

use in movies and television. In addition to developing advertisements and 

conducting public outreach, ONDCP is required to assess whether the 

media campaign’s efforts have been effective in changing American 

youths’ behavior regarding drug use. During fiscal years 2002 through 

2004, ONDCP used four prime contractors with varying responsibilities to 

carry out the campaign’s requisite tasks: Ogilvy & Mather, The Advertising 

Council, Inc. (The Ad Council), Fleishman-Hillard, Inc. (FleishmanContractor Services in 

Support of the Media 

Campaign 

Qualitative 

Research:

Consumer 

Insights

Qualitative 

Research:

Creative 

Evaluation 

Panel

Behavior

Change

Expert

Panel

On-Air

Outcome

Evaluation

Behavior

Change 

Expert 

Panel

Subject

Matter

Experts

Creative

Concept

Briefing

National

Studies

Creative 

Development 

of Campaign

Before ad creation: 

Exploratory Research

After ad creation: Media Planning 

and Placement On-Air/Tracking During ad creation: Qualitative/Quantitative Research/Expert Review

Finalization

of Creative

Development

Media 

Planning

Tracking 

Study

Copy 

testing

O 

N 

D 

C 

P

O 

N 

D 

C 

P

Feedback Loop

Source: Ogilvy & Mather.
Page 6 GAO-05-175 Anti-Drug Media Campaign 

Hillard), and Westat, Inc. (Westat).4 These contractors used funds from 

their contracts to secure additional specialized expertise from 

subcontractors.5

During fiscal years 2002 through 2004, the four major prime contractors 

were responsible for a variety of services that generally fall into three 

broad categories—advertising, public communications and outreach, and 

evaluation. According to our analysis, an estimated $520 million was 

awarded to the prime contractors, of which an estimated $373 million—72 

percent—was committed to purchasing media time and space for 

advertisements. The remaining $147 million—28 percent—was for the 

services provided by the prime contractors. 

 4

In its comments on our report, ONDCP disagreed that Westat is a prime contractor of the 

media campaign because Westat’s contract is with the National Institute on Drug Abuse 

(NIDA), not with ONDCP. Although we are aware that NIDA awarded the evaluation 

contract to Westat, we considered Westat as a prime contractor of the media campaign for 

purposes of this report. We did so because ONDCP has statutory responsibility for 

evaluating the media campaign’s effectiveness, see P.L. 105-61, 111 Stat. 1295 (1997), and it 

entered into an interagency agreement with NIDA for NIDA to award a contract to evaluate 

ONDCP’s media campaign. The interagency agreement provided that ONDCP would fund 

the evaluation contract through media campaign appropriations and would work with 

NIDA to ensure that the evaluation met ONDCP program and policy objectives of 

measuring the campaign’s impact. 

5

Two additional prime contractors, the National Clearinghouse of Alcohol and Drug Use 

Information and the National Institute of Justice, provided clearinghouse services in 

support of the media campaign. We did not include these contractors in our review because 

the focus of our review was to examine the services provided by advertising, public 

communications and outreach, and evaluation contractors. 

Prime Contractors 

and Their 

Subcontractors 

Provided Three Broad 

Categories of 

Services, but Most of 

the Estimated Award 

Dollars Were 

Committed to 

Purchasing Media 

Time and Space 
Page 7 GAO-05-175 Anti-Drug Media Campaign 

Figure 2: Estimated Award Amounts for Contractor Services and Purchase of Media 

Time and Space during Fiscal Years 2002-2004 

Note: Percentages may not add up to 100 percent due to rounding. 

Tasks associated with advertising and advertisement development were 

performed by prime contractors Ogilvy & Mather and the Ad Council. 

Ogilvy & Mather was responsible for managing the creative development 

and production of advertising that is targeted toward changing drug beliefs 

and behaviors among America’s youth and parents. More specifically, 

Ogilvy & Mather’s tasks included (1) media planning, placement, and 

purchase; (2) qualitative and quantitative research for advertising creation; 

and (3) advertising assessment and review. The total estimated amount 

awarded to Ogilvy & Mather for these services was about $97 million.6

The Ad Council was responsible for implementing several specific aspects 

of the advertising component of the media campaign, including 

(1) overseeing the use of media match space and time for public service 

 6

This estimated award amount does not include the approximate $373 million included in 

Ogilvy & Mather’s contract that was committed to purchasing media time and space for 

advertisements. The approximate sum of $373 million was to cover the cost of the media 

time and space only and does not include the cost of Ogilvy & Mather’s labor associated 

with negotiating and executing media purchases. 

Advertising 

services

Evaluation sevices

Public communications

and outreach services

Purchase of media 

time and space

Total: $520

Subtotal: 147

Services provided

by prime contractors

Estimated 

award amount 

(in millions of dollars)

Oglivy & 

Mather

Ad Council

Fleishman -

Hillard

Westat

0.9%

3.5%

5.2%

18.7%

19.6%

71.8%

$5

27

18

97

373

Source: GAO.

Prime

contractors

Media

activity
Page 8 GAO-05-175 Anti-Drug Media Campaign 

announcements that are not part of the media campaign, (2) creating and 

managing a community-based anti-drug strategy advertising campaign, and 

(3) administering reviews of media campaign advertisement production 

costs. The total estimated amount awarded to the Ad Council for these 

services was about $5 million. 

The purpose of public communications and outreach, which was 

implemented by Fleishman-Hillard, was to extend the reach and influence 

of the campaign through nonadvertising forms of marketing 

communications. To achieve this end, Fleishman-Hillard’s tasks included 

(1) conducting media outreach—for example, submitting articles relating 

to key campaign messages such as effective parenting or the effects of 

marijuana on teen health to newspapers and magazines; (2) building 

partnerships and alliances—for example, coordinating positive activities 

for teens with local school and community groups; (3) creating Web sites 

and exploring other alternative media approaches—for example, designing 

and hosting message-oriented Web sites such as theantidrug.com; and 

(4) entertainment industry outreach—for example, encouraging the 

entertainment industry to portray the negative consequences of drug use 

in movies and television. The total estimated amount awarded to 

Fleishman-Hillard for these services was about $27 million. 

To evaluate the effects of the campaign, ONDCP entered into an 

interagency agreement with the National Institute on Drug Abuse (NIDA). 

NIDA, in turn, contracted with Westat to design, develop, and implement 

an evaluation of the outcome and impact of the media campaign in 

reducing illegal drug use among youth.7

 To accomplish this, Westat 

designed a multiphase study to measure the attitudes and behavior of 

critical target audiences—preteens, teenagers, and parents. The total 

estimated amount awarded to Westat for these services was about 

$18 million. 

To fulfill their responsibilities, the prime contractors retained the 

expertise and services of 102 subcontractors for approximately 

$14 million. Table 1 shows the estimated award amounts for 

subcontractors during fiscal years 2002 through 2004. 

 7

Because Westat’s contract with NIDA implements ONDCP’s statutory requirement of 

evaluating the media campaign’s effectiveness, and because ONDCP funded the Westat 

contract through media campaign appropriations, we treated Westat as a prime contractor 

of the media campaign throughout the course of this review. 
Page 9 GAO-05-175 Anti-Drug Media Campaign 

Table 1: Estimated Award Amounts to Subcontractors during Fiscal Years 

2002-2004 

Dollars in thousands 

Prime contractor 

Number of 

subcontractors 2002 2003 2004 Total

Ogilvy & Mather 20 $1,059 $1,926 $1,880 $4,865

Ad Council 1 280 210 146 636

Fleishman-Hillard 80 4,165 2,910 834 7,909

Westat 1 218 224 343 785

Total 102 $5,722 $5,270 $3,203 $14,195

Source: GAO analysis of media campaign contracts. 

Ogilvy & Mather retained 20 subcontractors for nearly $5 million to 

provide two types of services: (1) multicultural media planning and buying 

agencies and (2) substance use behavioral change experts, who 

constituted the Behavioral Change Expert Panel (BCEP). The 

multicultural subcontractors received more than $4 million (about 90 

percent of the nearly $5 million awarded by Ogilvy & Mather to 

subcontractors) for providing marketing services and strategies with 

regard to specific minority audiences. For example, one subcontractor, 

Bromley Communications, was responsible for strategically purchasing 

media time and space for advertisements targeting Hispanic parents and 

youth. Bromley Communications also provided advice on how to develop 

effective advertising for Hispanic audiences. 

The BCEP received less than $500,000 (about 10 percent of the $5 million 

awarded by Ogilvy & Mather to subcontractors) for applying behavioral 

science expertise to several aspects of the campaign. For example, one 

behavioral change expert provided consulting services related to 

developing drug use prevention messages targeted to parents by reviewing 

advertising concepts and recommending revisions to enhance 

effectiveness. See appendix III for a more comprehensive description of 

these services. 

The Ad Council retained one subcontractor, Madison Advertising 

Management, LTD., (MAM), to provide advertising production cost review 

services for about $636,000. MAM was responsible for tracking, analyzing, 

and managing estimates and invoices detailing the production costs for 

media campaign advertisements to ensure that production costs were 

reasonable and adhered to ONDCP guidelines. MAM’s goals were to work 

with the pro bono advertising agencies, their production companies, 
Page 10 GAO-05-175 Anti-Drug Media Campaign 

ONDCP, The Partnership for a Drug-Free America (PDFA), and the Ad 

Council to minimize production costs without infringing on the creative 

process and to maximize the cost efficiency of the media campaign.8

Fleishman-Hillard awarded about $8 million of its total contract award to 

80 subcontractors for public communications and outreach services. 

These subcontractors provided a wide range of services, including 

photography and video services, research services, Internet technology 

services, and an assortment of speaker and panelist services. See appendix 

IV for a complete description of all services provided by Fleishman-Hillard 

subcontractors and the associated award amounts for these services. 

Of the estimated $8 million awarded by Fleishman-Hillard to 

subcontractors, the vast majority—89 percent—went to 14 subcontractors 

that provided campaign message promotion services. These services were 

designed to extend the reach and influence of the media campaign beyond 

the paid advertisements by using a variety of marketing techniques to 

publicize the media campaign’s anti-drug messages. For example, Rogers 

& Associates was responsible for promoting the campaign’s message by 

encouraging the entertainment industry to incorporate specific media 

campaign messages—such as the negative consequences of drug use—into 

television show and movie plots. Another campaign message promotion 

subcontractor, Campbell & Company, was responsible for using its social 

marketing and public health experience to conduct public outreach to the 

African American community—for example, developing partnerships with 

school and community organizations to lend credibility to and extend the 

reach of the media campaign. 

Westat retained one subcontractor—the Annenberg School of 

Communication at the University of Pennsylvania (Annenberg)—for an 

estimated $785,000. Although Annenberg was responsible for providing 

 8

In partnership with ONDCP and the advertising contractors, The Partnership for a DrugFree America engaged pro bono advertising agencies to create and develop the advertising 

concepts of the media campaign. Production companies selected by the pro bono agencies 

produced the actual advertisements. These production companies developed production 

estimates (i.e., estimates of the cost of producing the advertisement) and submitted them 

to MAM for review. Production of the advertisements occurred only after MAM 

recommended the production estimates to ONDCP for approval (and ONDCP granted 

approval). After producing the advertisements, the production companies submitted their 

invoices and cost reimbursement totals to MAM. After MAM approved the reimbursement 

request, Ogilvy & Mather reimbursed the production companies for the cost of producing 

the advertisements. 
Page 11 GAO-05-175 Anti-Drug Media Campaign 

overall support to Westat with respect to the entire scope of work detailed 

in the prime contract, it was specifically directed to provide particular 

support for the following six tasks: (1) project management, 

(2) development of the campaign evaluation plan, (3) instrument 

development, (4) data analysis and report generation, (5) preparation of 

contract reports, and (6) modification of the campaign evaluation plan. 

To determine the full range of subcontractor services, we reviewed the 

agreements between the prime contractors and their 102 subcontractors. 

From our analysis, we identified 16 distinct categories of services. Table 2 

contains definitions and examples for each category. 
Page 12 GAO-05-175 Anti-Drug Media Campaign 

Table 2: Services Provided by the 102 Subcontractors in Support of the Media Campaign during Fiscal Years 2002 through 

2004 

Service category Subcontract tasks Examples 

Administrative reporting 1. Project status reporting 

2. Meeting and coordinating with other campaign 

partners, contributors, and prime contractors 

3. Budget management and reporting 

Providing monthly summaries of spending 

on television, radio, and print time and 

space to air the media campaign 

advertisements 

Application of behavioral science 

expertise 

Participation in the Behavioral Change Expert Panel. 

Specifically, the application of specialized expertise 

to: 

1. development of a Behavioral Briefa

2. review and revision of ad concepts during the 

preliminary phase of the message creation 

process 

3. evaluation of ad effectiveness in the post 

production and the post distribution phases of 

the campaign 

Summarizing the major findings of 

behavioral science research that are 

relevant to drug use behavior change in 

youth and presenting this information to the 

pro bono advertising agencies responsible 

for developing and producing the media 

campaign advertisements 

Developing partnerships Initiating relationships and coordinating ONDCP’s 

anti-drug activities with professional, civic, and 

community associations; businesses; community 

anti-drug coalitions; and government organizations 

Identifying and building coalitions with 

school and community groups and using 

their support to extend the reach and 

strengthen the influence of the media 

campaign 

Entertainment industry outreach Influencing popular culture by promoting campaign 

messages about drug abuse and addiction issues 

through the entertainment industry, including 

television, movies, music, and other forms of popular 

entertainment 

Encouraging television shows popular 

among youth to incorporate specific media 

campaign messages—such as the negative 

consequences of drug use—into their plots 

Meeting and event planning Retaining experts as panelists or speakers to the 

public in support of ONDCP’s campaign, planning 

special events to highlight the campaign messages, 

or generating event attendance through promotional 

work 

Participating in media campaign 

roundtables—such as the Marijuana & Kids 

Media Briefings, which included discussions 

about the latest science on marijuana’s 

neurological, health, and developmental 

effects, particularly on young people 

Internet marketing Web site development and maintenance or design 

and production of banner ads 

Answering “Ask the Expert” questions that 

are submitted through and posted on 

theantidrug.com Web site 

Management of pro bono match 

activity 

Participation in “Pro Bono Match,” which refers to the 

media campaign program addressing Congress’ 

requirement that for every dollar of advertising that 

ONDCP spends, an equal dollar of match activity in 

time, space, or other in-kind contributions must be 

obtained. Management of pro bono match activity 

includes the negotiation, documentation, and 

tracking of all required match activity 

Ensuring that media vendors (such as 

television stations, radio stations, or 

newspapers) donate free time and space to 

air media campaign ads in amounts equal to 

the time and space purchased from them 

with media campaign money. 

Materials development and 

distribution 

Development and dissemination of materials such as 

brochures, fact sheets, and posters to support 

ONDCP’s campaign messages 

Distributing instructional brochures for 

parents on “Keeping Your Kids Drug Free” 
Page 13 GAO-05-175 Anti-Drug Media Campaign 

Service category Subcontract tasks Examples 

Media outreach Promoting campaign messages through broadcast 

media (radio, television); print media (magazines, 

newspapers); and display media (posters, signs), 

with the goal of educating the media and the public 

about youth drug use. This does not include buying 

advertising time 

Researching and writing feature articles on 

themes such as the influence of popular 

culture on youth drug use or substance 

abuse and related public health issues for 

submission to magazines and newspapers 

Media planning and buying Development and execution of a strategy to buy and 

monitor media advertising time and space designed 

to deliver maximum reach, frequency, and 

effectiveness of the campaign at the lowest cost 

Purchasing advertising media time and 

space strategically to target specific media 

campaign audiences, such as American 

Indian parents and youth 

Multicultural community outreach Anti-drug activities designed to ensure that ONDCP’s 

campaign reaches targeted multicultural populations 

Establishing connections within target 

multicultural communities for the purpose of 

ensuring that media campaign messages 

reach their intended audiences. 

Qualitative research Small-group methods such as focus groups, case 

studies, and the development of background 

information on a defined issue or problem 

Researching and reporting on the potential 

for using humor to address drug prevention 

goals 

Quantitative research Surveys, content analysis, and other statistical 

analysis of data 

Conducting a study on the prevalence and 

context of substance use and abuse in 150 

music videos most popular among youth for 

the purposes of determining both the 

negative and positive substance-related 

messages to youth audiences 

Stakeholder communications Communications designed to keep stakeholders (i.e., 

ONDCP, PDFA, the prime contractors, and other 

campaign partners) abreast of developments in the 

campaign and to generate further involvement and 

support 

Producing a bimonthly “Campaign Update” 

newsletter to be distributed to all campaign 

partners 

Strategic input General consultation and services given in support of 

the media campaign on an as-needed basis 

Providing advice on how to market to target 

audiences, such as how to create culturally 

sensitive advertising that appeals to 

Hispanic parents 

Trafficking of advertising Physical formatting of advertising and distribution to 

media vendors 

Ensuring that the correct advertisements 

(i.e., the actual film) are distributed to the 

television stations that are airing them 

Source: GAO analysis of subcontracts. 

a

The Behavioral Brief is a background document that describes the major insights of research and 

literature that should be taken into account when developing advertising intended to reach youth 

audiences. 

We provided a draft of this report to the Director of the Office of National 

Drug Control Policy for comment. In a March 14, 2005, letter, the Director 

commented on the draft. His written response is presented in its entirety 

in appendix V. In its comments, ONDCP generally agreed with our report’s 

findings, and we incorporated its technical comments where appropriate. 

At the same time, ONDCP expressed some concerns about our definition 

of consulting services as it had done throughout our review. Specifically, 

ONDCP’s Comments 

and Our Evaluation 
Page 14 GAO-05-175 Anti-Drug Media Campaign 

ONDCP argued that the “common use of the term” defines consultants as 

providing advice only, not services. As discussed with ONDCP officials 

throughout this review, we defined “consultants” as the prime contractors 

and their subcontractors that provided services, including expert advice, 

to implement the media campaign. Although the senate committee report 

that mandated our review did not define the term “consultants,” through 

our consultations and its previous hearings, the committee expressed 

concerns about the use of contractors and their subcontractors for the 

media campaign. We used our definition of consultants to 

comprehensively account for how campaign funds were being used to 

supplement ONDCP’s in-house capabilities regarding the advertising, 

public communications and outreach, and evaluation aspects of the media 

campaign. 

ONDCP also commented on a footnote in appendix IV of this report, which 

cites a GAO appropriations law decision holding that ONDCP violated 

publicity or propaganda prohibitions and the Anti-Deficiency Act when it 

is used appropriated funds to produce several prepackaged news stories 

which failed to disclose that ONDCP produced them for video news 

releases (VNRs) used in the media campaign. ONDCP commented that it 

has not produced a VNR since well before May 19, 2004, when GAO issued 

its first decision, B-302710, on VNRs and prepackaged news stories. 

ONDCP also said that it has no further plans to produce any VNRs, stating 

that GAO’s guidance on prepackaged news stories provided in our Circular 

Letter, B-304272, February 17, 2005, is “inherently incompatible with 

contemporary news gathering methods, thus rendering VNRs 

impracticable.” However, the guidance in the Circular Letter addresses 

the lack of attribution in prepackaged news stories, which are only one 

part of VNRs. The Circular Letter advises agencies that prepackaged news 

stories can be utilized without violating the law, so long as there is clear 

disclosure to the television viewing audience that this material was 

prepared by or in cooperation with the government department or agency. 
Page 15 GAO-05-175 Anti-Drug Media Campaign 

We are sending copies of this report to the Director, Office of National 

Drug Control Policy, appropriate congressional committees, and other 

interested parties. In addition, the report will be available at no charge on 

GAO’s Web site at http://www.gao.gov. If you or your staff have any 

questions on this report, please call Glenn Davis on (202) 512-4301 or me 

on (202) 512-8777. 

Laurie E. Ekstrand, Director 

Homeland Security and Justice 
Appendix I: Scope and Methodology 

Page 16 GAO-05-175 Anti-Drug Media Campaign 

Our review of contractor services and contract award amounts associated 

with the Office of National Drug Control Policy’s (ONDCP) National Youth 

Anti-Drug Media Campaign covered fiscal years 2002 through 2004. To 

develop background critical to describing and evaluating key aspects of 

the campaign, we conducted our work at the headquarters of ONDCP, The 

Partnership for a Drug Free America (PDFA), and media campaign prime 

contractors in Washington, D.C., and New York City. We reviewed the 

legislation authorizing the campaign—The Drug-Free Media Campaign Act 

of 1998—and subsequently enacted campaign legislation, as well as 

reports, testimony, interagency agreements, contracts, subcontracts, 

invoices, and vouchers. In addition, to obtain information on the media 

campaign process, we interviewed officials from ONDCP and PDFA. We 

also interviewed officials from the four prime contractors: Ogilvy & 

Mather, Fleishman-Hillard, the Ad Council, and Westat. To supplement our 

understanding of some of the kinds of services provided by 

subcontractors, we also interviewed officials from three of the 

subcontractors. In addition, we reviewed guidelines, reports, and other 

background documents relevant to the media campaign process provided 

by the officials we interviewed. Finally, we reviewed the contracts 

between the prime contractors and ONDCP, which laid out the objectives, 

strategies, and processes of the campaign, as well as the subcontracts 

issued under those prime contracts. While we reviewed the contract and 

subcontract documents, we did not review any of the products resulting 

from those contracts or subcontracts to determine whether they complied 

with any applicable laws. 

To describe the services provided by contractors and their subcontractors 

in support of the media campaign, we analyzed the contracts of the four 

prime contractors and the subcontracts of the 102 subcontractors. We 

obtained information about the roles and responsibilities of each of the 

four prime contractors from the background, scope of work, and task 

description sections of their respective contracts. Additionally, to describe 

services provided by the 102 subcontractors, we developed a data 

collection instrument (DCI) to allow us to analyze these services uniformly 

by capturing the following information: (1) the subcontract agreement 

date(s), (2) the prime contractor issuing the subcontract(s), and (3) what 

task categories captured the tasks listed in the subcontract agreement(s).1

 1

Two coders independently reviewed the subcontracts. If the coders disagreed with the 

coding of a particular task, they reconciled their responses before finalizing the DCI for the 

subcontract. 

Appendix I: Scope and Methodology 
Appendix I: Scope and Methodology 

Page 17 GAO-05-175 Anti-Drug Media Campaign 

We supplemented our analysis of the prime contracts and subcontracts 

with information from interviews with officials from ONDCP and PDFA 

and representatives from several prime contractors and subcontractors. 

We estimated the amounts awarded to each of the four prime contractors 

based on the award data contained in their contracts and any subsequent 

modifications to these contracts related to awards. Each of the four prime 

contracts was a “cost plus fixed fee” contract, meaning that with the 

exception of a fixed fee, payments were disbursed in the form of 

reimbursements for invoiced costs. Therefore, the award amounts listed in 

the contract agreements were estimates of the amounts the contractors 

would actually receive in reimbursements. Because these estimates were 

constantly revised based on the status of campaign projects or other 

information, contract modifications were used to update the contract 

award data. For the purposes of this review, we used the latest contract 

modifications to estimate the prime contractors’ awards as they contained 

the most recent information. Each of these contracts covered multiple 

years. Awards for each year of the contract were estimated at the 

beginning of the contract, and those yearly estimates were modified 

throughout the life of the contract. The year time frames established by 

the contracts (with the exception of the Westat contract) did not 

correspond to government fiscal years and differed with each contractor. 

For example, Ogilvy & Mather’s contract year was from January to January 

and Fleishman-Hillard’s contract year was from December to December. 

In order to estimate the prime contractors’ award amounts by fiscal year, 

it was necessary to prorate the award data listed in the contracts and 

modifications. By prorating the award data, we obtained estimated award 

data for each month and were then able to calculate estimated award 

amounts by fiscal year. An example of this type of calculation appears 

below. 
Appendix I: Scope and Methodology 

Page 18 GAO-05-175 Anti-Drug Media Campaign 

Figure 3: Example of Award-Based Data Calculation 

Note: Numbers may not add due to rounding. 

The major limitation of this method of analysis is that it assumes an equal 

distribution of the total estimated award over the term of the contract, 

which may not reflect the actual schedule of reimbursements to the 

contractor. Another limitation of our analysis is that it relies on estimates 

of the actual costs (i.e., estimated award amounts). We decided to use 

estimated award data instead of the expenditure data provided by ONDCP 

because the expenditure data were not complete. 

We estimated the amounts awarded to each of the 102 subcontractors 

based on the award data contained in their subcontracts and modifications 

to these subcontracts. In 18 cases where subcontract award data were 

insufficient, we used invoices and vouchers provided by the prime 

contractors to estimate expenditure data. Subcontract award data were 

determined to be insufficient if (1) the subcontract did not contain any 

estimated award data or (2) the subcontract listed a rate of compensation 

for services but did not specify a maximum term or compensation. 

We classified the award data contained in the subcontracts of the 102 

subcontractors into five types: (1) cost-reimbursable, (2) cost plus fixed 

fee, (3) indefinite quantity/indefinite delivery, (4) firm fixed price, and 

(5) rate-based. We analyzed each type of award data differently to produce 

Source: GAO.

Contract term

Total estimated award: $1,700,000 / 12 months = 

$141,667 per month (Prorated per month estimate – Total estimated award divided by number of months in contract term.)

Mar 2002 Apr May Jun Jul Aug Sep Nov Dec Jan 2003 Feb Oct Mar Apr

End of

fiscal year

6.33 months x $141,667 = $897,224 5.67 months x $141,67 = $802,778

3/22/02 3/21/03

Start

calendar year

Estimated award amount for FY 2002 

(prorated per month estimated times the number of 

months in contract term within FY 2002

If the contract award data for a contract is listed as follows: 

Contract term: 3/22/2002 - 3/21/2003 

Total estimated award: $1,700,000

We would calculate the total estimated awards for the contract for fiscal years 2002 and 2003 as follows:

Estimated award amount for FY 2003 

(prorated per month estimated times the number of 

months in contract term within FY 2003
Appendix I: Scope and Methodology 

Page 19 GAO-05-175 Anti-Drug Media Campaign 

estimated award data for the 102 subcontractors for fiscal years 2002 

through 2004. We analyzed the subcontracts containing cost-reimbursable, 

cost plus fixed fee, and indefinite quantity/indefinite delivery award data 

using the same method used to analyze the prime contractor award data. 

We analyzed the subcontracts containing firm fixed price award data using 

the prorating method described above only if the term of the subcontract 

covered multiple fiscal years. Many of these subcontracts had terms that 

fell completely within a single fiscal year, in which case we assigned the 

total award amount listed in the subcontract to the appropriate fiscal year. 

Firm fixed price subcontracts are agreements in which the subcontractor 

receives a fixed amount for the services it provides. Regardless of the time 

the subcontractor requires to complete its assigned tasks or whether the 

subcontractor incurs additional unexpected costs in the completion of its 

assigned tasks, it will not receive any additional funds without a 

subsequent modification to the subcontract. Consequently, the award data 

contained in the firm fixed price subcontracts represents the actual 

amount the subcontractor should have received.2

We analyzed subcontracts containing rate-based awards in a two-step 

process to produce estimated awards by fiscal year. Subcontracts 

containing rate-based data contain (1) a rate of compensation for the 

subcontractor (for example, $200 per hour), (2) a maximum term (such as 

10 hours) or maximum compensation (such as $2,000), and (3) a term or 

period of performance (i.e. the period of time during which the 

subcontractor will provide its service, such as between June 1, 2002, and 

June 30, 2002). We calculated the maximum possible award by multiplying 

the rate of compensation by the maximum term (unless the subcontract 

specified a maximum compensation). We considered this calculation of 

maximum possible awards as the total estimated award amounts for all 

rate-based subcontracts. If the term (period of performance) of the 

subcontract fell within a single fiscal year, then the total estimated award 

of the contract was assigned to the appropriate fiscal year. If the term 

(period of performance) of the subcontract covered multiple fiscal years, 

then the total estimated award was prorated as previously described, and 

total estimated awards for each fiscal year were calculated. An example of 

this type of analysis appears below. 

 2

Because this review is not a contract audit, and we focused on the estimated awards 

amounts for contractors and subcontractors, we did not verify that contractors received 

the exact amounts listed in their firm fixed price contracts. 
Appendix I: Scope and Methodology 

Page 20 GAO-05-175 Anti-Drug Media Campaign 

Figure 4: Example of Rate-Based Data Calculation 

In the 18 cases where we used invoices and vouchers to estimate 

expenditure data because subcontract award data were insufficient, we 

grouped the invoices and vouchers of each subcontractor by fiscal year 

and totaled the invoice/voucher amounts for each fiscal year. 

The methods of analysis used to produce estimated award data for 

subcontractors for fiscal years 2002 through 2004 have many of the same 

limitations as the method used to analyze the prime contract award data 

(i.e., much of the subcontract award data had to be prorated and some of 

the subcontract award data represented estimated reimbursements). In 

addition, we had to substitute expenditure data in the case of 18 

subcontracts that did not contain sufficient award data. Consequently, we 

based some of our calculations related to total subcontractor estimates on 

different types of data (expenditure or award). We decided to use 

estimated award data whenever possible to ensure data consistency (i.e., 

Source: GAO.

Contract term/period of 

compensation

Total estimated award amount for subcontract: $9,000 / 2.5 months = 

$3,600 per month (Prorated per month estimate – Total estimated award divided by number of months in contract term.)

Rate of compensation per day is $500 for a maximum term of 18 days = $9,000

Mar 2002 Apr May Jun Jul Aug Sep Oct Nov Dec Jan 2003 Feb Mar Apr

End of

fiscal year

9/16/02 12/2/02

Start

calendar year

.5 months available in FY 02 x $3,600 = $1,800 2 months available in FY 03 x $3,600 = $7,200

Estimated award amount for FY 2002 

(prorated per month estimated times the number 

of months in contract term within FY 2002

Estimated award amount for FY 2003 

(prorated per month estimated times the number 

of months in contract term within FY 2002

If the contract award data for a subcontractor is listed as follows: 

Contract term: 9/16/2002 - 12/02/2002 

Rate of compensation: $500 per day

Maximum number of days: 18

We would calculate the total estimated awards for the subcontractor for fiscal years 2002 and 2003 as follows:
Appendix I: Scope and Methodology 

Page 21 GAO-05-175 Anti-Drug Media Campaign 

to avoid comparing contractor awards based on estimated award data 

with subcontractor awards that were based on expenditure data). 

We conducted our work from March 2004 through February 2005 in 

accordance with generally accepted government auditing standards. 
Appendix II: Three Phases of Advertising 

Development 

Page 22 GAO-05-175 Anti-Drug Media Campaign 

To develop anti-drug television, print, Internet, and radio ads, the media 

campaign employs a three-phase advertising development and research 

process. The three phases of the advertising development and research 

process are (1) the exploratory research phase (pre-ad creation); (2) the 

qualitative and quantitative research and expert review phase (during ad 

creation); and (3) the media planning, placement, and tracking phase 

(post-ad creation). 

The initial exploratory phase consists of extensive research to understand 

the subject matter and covers many sources of information, including 

(1) consumer insights, (2) national studies, (3) behavioral change experts, 

and (4) subject matter experts. PDFA is a major source for this 

background research. In addition, the Behavioral Change Expert Panel 

(BCEP), assembled by Ogilvy & Mather, is composed of a number of 

individuals possessing specialized expertise relevant to specific aspects of 

the media campaign, such as the sociology of behavior change in youth or 

communicating with minority audiences. The BCEP is responsible for 

developing a Behavioral Brief, which is a background document that 

describes the major insights of research and literature to consider when 

developing advertising intended to reach youth audiences. The final goal 

of the exploratory research phase is for Ogilvy & Mather and PDFA to 

produce a Creative Brief for each advertising series.1

 The Creative Brief is 

a compilation of information provided by subject matter experts, including 

(1) information relevant to the specific messages of the campaign and 

(2) relevant portions of the qualitative research provided by PDFA 

regarding consumer insights and national studies. The pro bono agencies 

responsible for the creative development of a given advertising series use 

the Creative Brief and the Behavioral Brief to inform their efforts. 

The second phase involves ad creation and qualitative and quantitative 

research. PDFA is responsible for soliciting pro bono advertising agencies 

that create the advertising concepts using the Creative and Behavioral 

Briefs. The media campaign uses multiple pro bono advertising agencies to 

develop advertisements. One example of a media campaign advertising 

series is the “Monitoring/Love” series of advertisements—a message 

targeting parents, promoting awareness of their children’s activities. A 

single pro bono ad agency developed all of the advertisements within this 

series. After initial advertising concepts are developed, the Formative 

Creative Evaluation Panel (FCEP) and the BCEP review these initial 

 1

An advertising series consists of three or four similarly themed advertisements. 

Appendix II: Three Phases of Advertising 

Development 
Appendix II: Three Phases of Advertising 

Development 

Page 23 GAO-05-175 Anti-Drug Media Campaign 

concepts.2 Next, feedback from FCEP and BCEP is used to revise the 

advertising concepts. Any recommendations or observations that may be 

relevant to future campaign efforts are to be kept for possible applications 

to new Creative Briefs during the initial exploratory research phase (i.e., 

the feedback loop in this iterative process). 

Once the advertising concepts have been reviewed and revised, 

production estimates are calculated and reviewed for maximum cost 

efficiency. Once this process is completed, ONDCP is responsible for 

reviewing the ad concepts and approving funding for production of the 

advertisements. After advertisements are produced, they are submitted for 

copytesting, a process used to determine whether advertisements meet 

effectiveness standards for distribution. In the copytesting process, large 

sample audiences (usually consisting of 300 youths and 150 parents per 

copytest session) view the ads and are surveyed regarding their responses 

to the advertisement, drug attitudes, beliefs, and behaviors. Copytesting 

relies on a comparison of exposed audiences and nonexposed control 

audiences to determine effectiveness of advertisements. According to 

Ogilvy & Mather (the contractor responsible for implementing 

copytesting), the audience is split evenly across ethnic, gender, and age 

categories. One-half of the audience is exposed to the advertisement and 

the other half is not. Copytesting researchers then survey and compare the 

drug beliefs and intentions of each group to determine the effectiveness of 

the advertisement. If an advertisement does not meet effectiveness 

standards set by ONDCP, the advertisement is not aired. To successfully 

pass the copytesting process, an advertisement must significantly 

strengthen anti-drug beliefs or weaken intentions to use marijuana without 

creating any adverse effects. Copytesting questions are designed so that 

the information provided by the responses can be used to revise 

advertisements that fail to meet effectiveness standards. 

Media planning (determining where, when, and for how long to air or print 

the advertisements) occurs concurrently with the advertising development 

and assessment process. The media plan is finalized and executed (the 

advertisements are distributed to media vendors) once the advertisements 

have successfully completed the copytesting phase and the advertisements 

have undergone a final review by ONDCP. After the advertisements air, 

 2

FCEPs are evaluative discussion panels (i.e., focus groups), consisting of target audience 

individuals (teens or parents) who are carefully recruited and convened to review 

advertising concepts. 
Appendix II: Three Phases of Advertising 

Development 

Page 24 GAO-05-175 Anti-Drug Media Campaign 

audience reactions are to be tracked through an evaluative process that 

measures the effectiveness of specific ads over time within specific 

audience populations.3

 3

This evaluative process for the individual advertisements is separate from the evaluation 

of the effectiveness of the media campaign as a whole (the Westat study). 
Appendix III: Ogilvy & Mather’s 

Subcontractor Services and Associated 

Estimated Award Amounts 

Page 25 GAO-05-175 Anti-Drug Media Campaign 

During fiscal years 2002 through 2004, Ogilvy & Mather retained the 

services of two groups of subcontractors: (1) multicultural media planning 

and buying agencies and (2) substance use behavioral change experts—

the Behavioral Change Expert Panel. Ogilvy & Mather awarded nearly $5 

million to its 20 subcontractors. 

Six multicultural subcontractors provided services in support of Ogilvy & 

Mather’s media planning, placement, and purchase responsibilities. Each 

multicultural subcontractor provided marketing services and strategies 

with regard to a specific minority audience. Each multicultural 

subcontractor was responsible for planning and buying media advertising 

time and space targeting its minority audience, managing the pro bono 

match activity that accompanied its media purchases, and trafficking 

advertising to media vendors. The multicultural subcontractors also 

assisted Ogilvy & Mather with its advertising creation and assessment 

responsibilities by providing strategic input with regard to marketing to 

minority audiences, particularly at the preliminary qualitative research and 

initial ad concept review phases. 

Ogilvy & Mather awarded more than $4 million to the multicultural 

subcontractors, constituting about 90 percent of the nearly $5 million 

amount awarded by Ogilvy & Mather to subcontractors during fiscal years 

2002 through 2004. The awards received by multicultural subcontractors 

covered only the cost of labor, overheard, and fees and did not include any 

funding specifically designated for the purchase of media advertising time 

and space. 

BCEP subcontractors mainly applied their specialized expertise to three 

aspects of the advertising development and research process: (1) the 

development of the Behavioral Brief,1

 (2) the review and revision of initial 

advertising concepts, and (3) the evaluation of ad effectiveness in the 

postproduction and postdistribution phases of the campaign. During the 

initial exploratory research phase, the BCEP developed the Behavioral 

 1

The Behavioral Brief is a background document that describes the major insights of 

research and literature that pro bono ad agencies should be aware of when developing 

advertisements intended to reach youth audiences. 

Appendix III: Ogilvy & Mather’s 

Subcontractor Services and Associated 

Estimated Award Amounts 

Multicultural 

Subcontractors Services 

and Estimated Awards 

Behavior Change Expert 

Panel Subcontractors 

Services and Associated 

Estimated Award Amounts 
Appendix III: Ogilvy & Mather’s 

Subcontractor Services and Associated 

Estimated Award Amounts 

Page 26 GAO-05-175 Anti-Drug Media Campaign 

Brief and contributed to the development of the Creative Brief.2 The pro 

bono advertising agencies engaged by PDFA used the Behavioral and 

Creative Briefs to develop initial advertising concepts and preliminary ads. 

During the qualitative research and expert review portion of the ad 

creation phase, the BCEP reviewed the initial advertising concepts and 

preliminary ads and contributed to the qualitative research process by 

recommending improvements and revisions to the ads to foster behavior 

changes in the target audiences. After the final production of the ads, the 

BCEP worked with PDFA and Ogilvy & Mather to develop the questions 

used during the copytesting and postdistribution evaluation processes to 

determine the nature and extent of the effect of the ads on audience 

beliefs and intentions. At any point during the advertising development 

and research process, BCEP subcontractors were to provide strategic 

input and advice to any media campaign partner on an as-needed basis. 

Ogilvy & Mather awarded less than $500,000 to the BCEP subcontractors, 

constituting about 10 percent of the nearly $5 million awarded by Ogilvy & 

Mather to all of its subcontractors during fiscal years 2002 through 2004. 

 2

Creative Briefs are constructed by Ogilvy & Mather and PDFA for specific campaign 

messages. BCEP subcontractors are responsible for ensuring that the points listed in 

Creative Briefs are accurate and consistent with Behavioral Briefs. 
Appendix IV: Fleishman-Hillard 

Subcontractor Services and Associated 

Estimated Award Amounts 

Page 27 GAO-05-175 Anti-Drug Media Campaign 

To support its public communications and outreach efforts, FleishmanHillard retained the services of 80 subcontractors, which we categorized in 

the following 10 groups: (1) campaign message promotion, 

(2) photography and video production, (3) campaign message 

development, (4) contracting management, (5) research, (6) internet 

technology, (7) Marijuana & Kids Briefings panelists and speakers, 

(8) Library Working Group experts, (9) Asian American and Pacific 

Islander Marijuana Media Roundtable panelists and speakers, and 

(10) Teen Advisor Program experts. Fleishman-Hillard awarded about 

$8 million to its 80 subcontractors. 

Approximately 89 percent of the estimated $8 million dollars that 

Fleishman-Hillard awarded was provided to a single category of 

subcontractor—those responsible for campaign message promotion. Table 

3 depicts award amounts within the remaining 11 percent (about 

$900,000), which was awarded to nine categories of subcontractors. 

Table 3: Estimated Contract Award Amounts to Groups of Fleishman-Hillard Subcontractors by Fiscal Year (2002-2004) 

Group 

Number of 

subcontractors 2002 2003 2004 

Aggregated 

totals

Photography and video production 11 $28,875 $281,199 $34,665 $344,739

Campaign message development 14 $82,777 $108,466 $22,313 $213,556

Contract management 1 $61,376 $98,972 $13,931 $174,279

Research 5 $35,840 $45,198 $1,563 $82,601

Internet technology 4 $2,680 $25,800 $6,400 $34,880

Marijuana & Kids briefings 12 $2,300 $12,700 0 $15,000

Library Working Group meeting 5 $5,000 0 0 $5,000

Asian-American and Pacific Islander Marijuana 

Media Roundtable 10 0 $5,000 0 $5,000

Teen advisor program 4 0 0 $800 $800

Aggregated total $875,855

Source: GAO analysis of estimated subcontractor award amounts. 

Eleven photography and video production subcontractors provided a wide 

array of services, including photographing media campaign promotional 

events and creating audiovisual materials promoting media campaign 

Appendix IV: Fleishman-Hillard 

Subcontractor Services and Associated 

Estimated Award Amounts 

Photography and Video 

Production 
Appendix IV: Fleishman-Hillard 

Subcontractor Services and Associated 

Estimated Award Amounts 

Page 28 GAO-05-175 Anti-Drug Media Campaign 

messages.1 For example, one photography subcontractor was responsible 

for photographing the media campaign’s Boston Parent Wake-Up Rally and 

processing the photographs for Web display and digital reproductions. 

Gourvitz Communications, Inc. was responsible for producing a number of 

videos for the media campaign, including the Marijuana Initiative Video 

News Release and the Marijuana Community Coalition Video. 

Fleishman-Hillard awarded an estimated total of nearly $345,000 to 

photography and video production subcontractors during fiscal years 2002 

through 2004. Within this group, the two largest awards went to video 

production subcontractor Gourvitz Communications, Inc. (an estimated 

$262,000) and to Court TV (an estimated $77,000). The remaining nine 

awards were each for an estimated $1,500 or less. 

Fourteen campaign message development subcontractors provided a wide 

array of services, including planning and implementing promotional events 

and researching and drafting feature articles for submission to print and 

online media venues. For example, one campaign message development 

subcontractor, Students Against Destructive Decisions, Inc. (SADD), was 

responsible for raising public awareness of the risks of marijuana use by 

planning and executing five guerrilla “Wake-Up” student rallies in which 

students, dressed in distinctive clothing designed by ONDCP and SADD, 

distributed media campaign materials in highly public urban sites during 

rush hour. Another campaign message development subcontractor 

answered “Ask the Expert” questions submitted through the media 

campaign’s “theantidrug.com” Web site and researched and wrote feature 

articles on media campaign key messages that were placed on the Web site 

and submitted to print media venues. 

 1

A July 2004 congressional request asked us to examine several video news releases 

(VNRs) produced for the media campaign. Those releases included, among other things, 

several prepackaged news stories. Because those news stories did not disclose to the 

targeted television viewing audiences that they had been prepared at the government’s 

behest, we determined in B-303495, Jan. 4, 2005, Office of National Drug Control Policy—

Video News Release, and in B-303495.2, Feb. 15, 2005, Reconsideration of B-303495—

Office of National Drug Control Policy Prepackaged News Stories, that ONDCP violated 

the publicity or propaganda prohibitions and the Anti-Deficiency Act when it used 

appropriated funds to produce those stories. GAO subsequently issued a Circular Letter, B304272, Feb. 17, 2005, advising agencies that prepackaged news stories can be utilized 

without violating the law, so long as there is clear disclosure to the television viewing 

audience that this material was prepared by or in cooperation with the government 

department or agency. ONDCP commented that it ceased producing VNRs well before May 

2004, and has no plans to produce any further VNRs. 

Campaign Message 

Development 
Appendix IV: Fleishman-Hillard 

Subcontractor Services and Associated 

Estimated Award Amounts 

Page 29 GAO-05-175 Anti-Drug Media Campaign 

Fleishman-Hillard awarded an estimated $214,000 to campaign messagedevelopment subcontractors during fiscal years 2002 through 2004. Within 

this group, the four largest awards went to SADD (an estimated $44,000), 

to Pride Youth Programs (an estimated $30,000), and to two individual 

experts (estimated amounts of $54,000 and $25,500). The remaining 

10 awards were each for an estimated $14,000 or less. 

The sole subcontractor providing contract management services was a 

temporary placement agency. This subcontractor provided temporary 

personnel staff to Fleishman-Hillard to assist with the preparation of 

invoices to be submitted to ONDCP regarding Fleishman-Hillard projects. 

Fleishman-Hillard awarded an estimated $174,000 to this subcontractor 

during fiscal years 2002 through 2004. 

Five research subcontractors provided a wide array of services, including 

analyzing media campaign marketing strategies and reporting on the kinds 

of drug-related messages currently influencing America’s youth. For 

example, one research contractor, MarketBridge was responsible for 

demonstrating and quantifying the value of corporate partnerships to the 

media campaign. Another research subcontractor, Mediascope, was 

responsible for conducting a study on the prevalence and context of 

substance use and abuse in the 150 most popular music videos for the 

purposes of identifying the negative and positive substance-related 

messages targeting youth audiences. 

Fleishman-Hillard awarded an estimated $83,000 to research 

subcontractors during fiscal years 2002 through 2004. Within this group, 

the largest award, an estimated $56,000, went to MarketBridge. The 

remaining four awards were each for an estimated $10,000 or less. 

Four Internet technology subcontractors provided a wide range of services 

including e-mail distribution and Web site development. For example, an 

Internet technology subcontractor, Experian eMarketing Services, was 

responsible for creating and sending e-mail messages to recipient lists 

created by Fleishman-Hillard, using content provided by FleishmanHillard. Another Internet technology subcontractor, TestPros, assessed the 

usability of two media campaign Web sites. 

Fleishman-Hillard awarded an estimated $35,000 to Internet technology 

subcontractors during fiscal years 2002 through 2004. Within this group, 

Contract Management 

Research 

Internet Technology 
Appendix IV: Fleishman-Hillard 

Subcontractor Services and Associated 

Estimated Award Amounts 

Page 30 GAO-05-175 Anti-Drug Media Campaign 

the largest award, an estimated $17,500, went to Experian eMarketing 

Services. The remaining three awards were each for an estimated $11,000 

or less. 

Twelve Marijuana & Kids Briefings subcontractors served as panelists and 

speakers in roundtable discussions addressing the latest science on 

marijuana’s neurological, health, and developmental effects on youth. 

Fleishman-Hillard awarded an estimated $15,000 to these subcontractors 

during fiscal years 2002 through 2004 to panelists and speakers for its 

Marijuana and Kids Briefings. All of the Marijuana & Kids Briefings’ 

subcontractors were individual experts, rather than firms. Most of these 

subcontractors were paid at a daily rate of $500, with a maximum term of 

service of 1 day. Within this group, the largest award went to an individual 

expert for an estimated $9,000. The remaining 11 awards were each for an 

estimated $1,000 or less. 

The purpose of the Library Working Group was to explore how librarians 

and other adults can help kids find accurate, high-quality information 

about drugs on the Internet. Five Library Working Group subcontractors 

provided a range of services including advising on common library and 

Internet issues; assisting in the development of instructional products 

about cyberliteracy and illicit drugs; and recommending strategies, 

vehicles, and partnerships to accomplish program goals. 

Fleishman-Hillard awarded an estimated $5,000 to Library Working Group 

subcontractors during fiscal years 2002 through 2004. All of the Library 

Working Group subcontractors were individual expert, rather than firms. 

Each of the five subcontractors received a total estimated award of $1,000. 

Ten Asian American and Pacific Islander Marijuana Media Roundtable 

subcontractors served as panelists and speakers in roundtable discussions 

to address the latest scientific findings on marijuana’s neurological, health, 

and developmental effects on youth. 

Fleishman-Hillard awarded an estimated $5,000 to Asian American and 

Pacific Islander Marijuana Media Roundtable subcontractors during fiscal 

years 2002 through 2004. All of the Asian American and Pacific Islander 

Marijuana Media Roundtable subcontractors were individual experts, 

Marijuana & Kids Briefings 

Library Working Group 

Asian American and 

Pacific Islander Marijuana 

Media Roundtables 
Appendix IV: Fleishman-Hillard 

Subcontractor Services and Associated 

Estimated Award Amounts 

Page 31 GAO-05-175 Anti-Drug Media Campaign 

rather than firms. Each of these subcontractors received a total estimated 

award of $500. 

Four Teen Advisor Program subcontractors were responsible for 

providing insight and feedback on the campaign’s youth-oriented 

strategies in order to guide the development of teen programs, events, and 

Web site content. 

Fleishman-Hillard awarded an estimated $800 to Teen Advisor Program 

subcontractors during fiscal years 2002 through 2004. All of the Teen 

Advisor Program subcontractors were individual experts, rather than 

firms. Each of the four subcontractors received a total estimated award of 

$200. 

Teen Advisor Program 
Appendix V: Comments from the Office of National Drug Control Policy 

Page 32 GAO-05-175 Anti-Drug Media Campaign 

Appendix V: Comments from the Office of 

National Drug Control Policy 
Appendix V: Comments from the Office of National Drug Control Policy 

Page 33 GAO-05-175 Anti-Drug Media Campaign 
Appendix V: Comments from the Office of National Drug Control Policy 

Page 34 GAO-05-175 Anti-Drug Media Campaign 
Appendix VI: GAO Contacts and Staff 

Acknowledgments 

Page 35 GAO-05-175 Anti-Drug Media Campaign 

Laurie E. Ekstrand (202) 512-8777 

Glenn G. Davis (202) 512-4301 

In addition to those named above, the following individuals contributed to 

this report: David Alexander, Leo Barbour, R. Rochelle Burns, 

Christine Davis, Wendy C. Johnson, Weldon McPhail, Jean McSween, 

Brenda Rabinowitz, Tami Weerasingha, Bill Woods, and Kathryn Young. 

Appendix VI: GAO Contacts and Staff 

Acknowledgments 

GAO Contacts 

Staff 

Acknowledgments 

(440293) 
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