DRUG CONTROL

Additional 

Performance 

Information Is Needed 

to Oversee the 

National Guard's 

State Counterdrug 

Program

Report to Committee on Armed 

Services, U.S. Senate

October 2015

GAO-16-133

United States Government Accountability Office
Highlights of GAO-16-133, a report to the 

Committee on Armed Services, U.S. Senate 

October 2015

DRUG CONTROL

Additional Performance Information Is Needed to 

Oversee the National Guard's State Counterdrug 

Program 

Why GAO Did This Study

Since 1989 the National Guard has 

received hundreds of millions of dollars 

to help enhance the effectiveness of 

state-level counterdrug efforts by 

providing military support to assist 

interagency partners with their 

counterdrug activities. The program 

funds the drug interdiction priorities of 

each state Governor; counterdrugrelated training to interagency partners 

at five counterdrug schools; and statelevel counterthreat finance 

investigations, all of which are part of 

DOD’s broader counterdrug efforts.

Senate Report 113-176 included a 

provision for GAO to conduct an 

assessment of the state operations of 

the National Guard’s counterdrug 

program. This report: (1) identifies the 

changes in funding for the program 

since fiscal year 2004, and (2) 

assesses the extent to which 

performance information is used to 

evaluate the program’s activities. GAO 

analyzed the program’s budgets and 

obligations data, performance 

measures, and program guidance, and 

interviewed knowledgeable officials.

What GAO Recommends

GAO recommends that DOD (1)

identify additional information needed 

to evaluate the performance of state 

programs and oversee counterdrug 

schools’ training; and (2) subsequently 

collect and use performance 

information to help inform funding 

distribution decisions to state programs

and to conduct oversight of the training 

offered by the counterdrug schools.

DOD concurred with GAO’s 

recommendations.

What GAO Found

The National Guard Bureau (NGB) counterdrug program’s budget data show that 

funding has ranged from about $219.3 million to $242.1 million in fiscal years 

2004 through 2014–with a peak of $247 million in fiscal year 2013–but in fiscal 

year 2015 funding was reduced substantially. Based on Department of Defense 

(DOD) data, every year since 2004 Congress has directed funding above the

requested amount, thus keeping program amounts steady through 2014. In fiscal 

year 2013, DOD reported requesting $117 million for the program, about a 40 

percent decrease from the prior year’s request. While DOD reduced its request, 

however, Congress in fiscal years 2013 and 2014 directed funding at generally 

comparable amounts from prior years. In fiscal year 2015 Congress directed less 

of an increase above DOD’s request, leaving the program with lower total funding

of $175.5 million. 

Funding for National Guard’s State Counterdrug Program, Fiscal Years 2004-2015

The NGB has developed performance measures to report on its counterdrug 

program; however, the information collected is not used to evaluate and inform 

funding for state-level programs or oversee the counterdrug schools’ training. 

GAO has previously reported that setting useful measures is important for 

oversight; without them, managers cannot monitor and evaluate the performance 

of programs’ activities. NGB officials stated that they developed the current 

measures in response to DOD guidance to report on the program’s aggregate 

performance and did not fully consider the types of measures or information that 

would be useful to evaluate individual state-level programs and oversee the 

counterdrug schools. Without collecting and using useful performance 

information to evaluate state-level programs and oversee the counterdrug 

schools, DOD and Congress cannot ensure that the counterdrug program is 

achieving its desired results and is distributing its funding most efficiently.

View GAO-16-133. For more information, 

contact John Pendleton at (202) 512-3489 or 

pendletonj@gao.gov.

United States Government Accountability Office
Letter 1

Background 3

Funding Was Generally Steady for Past Decade but Decreased in 

Fiscal Year 2015 5

NGB Has Performance Measures, but Does Not Use the 

Information Collected to Inform State-Level Programs or 

Oversee the Counterdrug Schools 8

Conclusions 13

Recommendation for Executive Action 14

Agency Comments and Our Evaluation 14

Appendix I Scope and Methodology 16

Appendix II Obligations by State Project 21

Appendix III Overview of National Guard State Plans’ Counterdrug Activities and 

Supported Organizations, Fiscal Years 2011 through 2014 22

Appendix IV Overview of DOD’s Drug Interdiction and Counterdrug Activities Account 

Fund Transfer Process 27

Appendix V National Guard Counterdrug Program's Fiscal Year 2015 Performance 

Measures 29

Appendix VI Overview of the Threat-Based Resource Model and Funding Amounts 

by State and Territory 31

Appendix VII Comments from the Department of Defense 35

Contents

Page i GAO-16-133 Drug Control
Appendix VIII GAO Contact and Staff Acknowledgments 39

Related GAO Products 40

Tables

Table 1: Distribution Percentages of National Guard State Plans’ 

Funding to States and Territories Based on Assessment 

of Drug Threats, Fiscal Year 2015 12

Table 2: Obligation Amounts of the National Guard Counterdrug 

Program by State Project, Fiscal Years 2004 through 

2014 21

Table 3: State Plans’ Mission Categories and Support Activities 22

Table 4: State Plans’ Staff Days by Type of Support Activity, 

Fiscal Years 2011 through 2014 24

Table 5: State Plans’ Staff Days by Supported Organizations, 

Fiscal Years 2011 through 2014 25

Table 6: State Plans’ Staff Days by Support Federal Agencies, 

Fiscal Years 2011 through 2014 26

Table 7: Performance Measures of National Guard Counterdrug 

Program, Fiscal Year 2015 29

Table 8: Fiscal Year 2015 Threat-Based Resource Model Threat 

Percentages by State or Territory Program 32

Table 9: State Plans’ Funding by State and Territories, Fiscal 

Years 2014 and 2015 33

Figures

Figure 1: Funding for the National Guard’s State Counterdrug 

Program, Fiscal Years 2004 through 2015 6

Figure 2: Obligation Amounts for the National Guard’s 

Counterdrug Program, Fiscal Years 2004 through 2014 7

Figure 3: State Plans’ Staff Days by Mission Category, Fiscal 

Years 2011 through 2014 23

Figure 4: Drug Interdiction Account Fund Transfer Process 28

Page ii GAO-16-133 Drug Control
Abbreviations

CBP Customs and Border Protection

DEA Drug Enforcement Administration

DOD Department of Defense

HIDTA High Intensity Drug Trafficking Areas

HSI Homeland Security Investigations

NGB National Guard Bureau

OMB Office of Management and Budget

ONDCP Office of National Drug Control Policy

This is a work of the U.S. government and is not subject to copyright protection in the 

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without further permission from GAO. However, because this work may contain 

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Page iii GAO-16-133 Drug Control
441 G St. N.W.

Washington, DC 20548

October 21, 2015

The Honorable John McCain

Chairman

The Honorable Jack Reed

Ranking Member

Committee on Armed Services

United States Senate

To assist state efforts to address illicit drug production, trade, and 

consumption, Congress has provided the Department of Defense (DOD) 

with hundreds of millions of dollars since 1989 to fund the National 

Guard’s participation in domestic drug interdiction and counterdrug 

activities. The type of military support provided by the National Guard can 

range from reconnaissance to analytical support, but it generally reflects 

the drug interdiction priorities of the Governors of the 50 states, the 

District of Columbia, and three U.S. territories; the capabilities of each 

state’s National Guard; and the needs of interagency partners. These 

interagency partners include state, local, and tribal law enforcement 

organizations, as well as several federal agencies—Department of 

Justice, Department of Homeland Security, and Department of 

Treasury—all of whom are involved in efforts to disrupt and dismantle the 

leadership and financial infrastructure of major drug-trafficking 

organizations. Given ongoing fiscal constraints within the federal 

government, the National Guard’s counterdrug program, like all federal 

programs, must use resources efficiently and achieve results. 

A Senate Armed Services Committee report accompanying a bill for the 

National Defense Authorization Act for Fiscal Year 2015 included a 

provision for GAO to conduct an independent assessment of the statelevel activities of the National Guard’s counterdrug program.1 In this 

report, we (1) identify the changes in funding for the National Guard’s 

counterdrug program since fiscal year 2004; and (2) assess the extent to 

which performance information is used to evaluate the counterdrug 

program’s activities. 

1

S. Rep. No. 113-176, at 177-78 (June 2, 2014).

Letter

Page 1 GAO-16-133 Drug Control

 
To identify the changes in funding for the National Guard counterdrug 

program, we conducted an analysis of the relevant appropriations and 

program budget-related documents provided by DOD for fiscal years 

2004 through 2015.2 We began our analysis with fiscal year 2004 to 

ensure that our review included data covering at least a 10-year period. 

We also reviewed documentation on funding allocations and financial

management policy and interviewed DOD and interagency partner 

officials regarding the changes in funding. To assess the extent to which 

performance information is used to evaluate the counterdrug program’s 

activities, we reviewed documentation and interviewed counterdrug 

officials about program activities, types of performance information 

collected, and funding levels for individual state counterdrug programs. 

Specifically, first, we evaluated the counterdrug program’s 26 fiscal year 

2015 performance measures against nine key attributes of successful 

performance established by GAO.3 Next, we evaluated the counterdrug 

program’s use of performance information against leading practices for 

results-oriented management that help agencies develop useful 

performance measures and use performance information for 

management decision making as identified by GAO.4 We selected 8 of 

the 53 participating states and territories for a nongeneralizable case 

study, identifying 2 states within each of the four counterdrug program 

regions by selecting 1 state with high and 1 state with low drug threat 

assessments that also had a counterdrug school or an international 

boundary. In each of the 8 states, we interviewed officials from the 

state’s counterdrug program. We also selected and interviewed officials 

2

Obligation data included in the report are through fiscal year 2014. 

3

GAO, Tax Administration: IRS Needs to Further Refine Its Tax Filing Season 

Performance Measures, GAO-03-143 (Washington, D.C.: Nov. 22, 2002). GAO developed 

nine attributes of performance goals and measures based on previously established GAO 

criteria, consideration of key legislation, and review of performance management 

literature. In GAO-03-143, GAO applied the attributes to assess Internal Revenue Service 

performance measures. However, because the attributes are derived from sources 

generally applicable to performance measures, they are also relevant for assessing 

counterdrug program performance measures.

4

GAO, Managing for Results: Enhancing Agency Use of Performance Information for 

Management Decision Making, GAO-05-927 (Washington, D.C.: Sept. 9, 2005). GAO 

developed a conceptual framework identifying four uses of performance information for 

management decision making and five practices that can contribute to greater use of 

performance information from a review of the literature and interviews with experts and 

staff from five agencies (the U.S. Departments of Commerce, Labor, Transportation, and 

Veterans Affairs, and the Small Business Administration). 

Page 2 GAO-16-133 Drug Control

 
from interagency partners who received support from the counterdrug 

program in order to obtain their perspectives on the program. We 

interviewed officials from the National Guard Bureau; Deputy Assistant 

Secretary of Defense for Counternarcotics and Global Threats; Office of 

the Under Secretary of Defense (Comptroller); Office of National Drug 

Control Policy; nine High Intensity Drug Trafficking Areas 5

; Drug 

Enforcement Administration Office of Training and eight field divisions; 

three Customs and Border Protection field units; and three U.S. 

Immigration and Customs Enforcement’s Homeland Security 

Investigations field offices. Additional details on our scope and 

methodology can be found in appendix I. 

We conducted this performance audit from August 2014 to October 2015 

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.

DOD’s counterdrug mission focuses on supporting local, state, federal, 

and foreign government agencies in addressing the illegal drug trade and 

narcotics-related terrorism. DOD conducts its mission in three primary 

areas: detecting and monitoring drug trafficking into the United States, 

sharing information on illegal drugs with U.S. and foreign government 

agencies, and building the counterdrug capacity of U.S. and foreign 

partners.6

The National Guard identifies three state-specific projects as comprising 

its counterdrug program—state plans, counterdrug schools, and 

counterthreat finance. 7 The authority to provide funding for the first state 

5

The High Intensity Drug Trafficking Areas are a federally funded program that brings 

officials from federal, state, and local law enforcement agencies together into task forces 

to conduct investigations of drug trafficking organizations engaged in the production, 

manufacturing, importation, or distribution of illegal drugs. See, 21 U.S.C. § 1706.

6

DOD is the lead federal agency for detection and monitoring of aerial and maritime transit 

of illegal drugs into the United States.

7

The National Guard counterdrug program also includes several projects that support 

federal operations, which we did not examine as part of this review.

Background

Page 3 GAO-16-133 Drug Control

 
project—state plans—began in 1989 when DOD was authorized by 

Congress under section 112 of Title 32 of the United States Code to fund 

the National Guard’s drug interdiction and counterdrug activities.8 Each 

participating state counterdrug program must develop an annual plan of 

activities, in coordination with the state’s Governor and Attorney General. 

In developing their plans, states use annual guidance issued by DOD 

outlining the department’s domestic counterdrug program priorities. Once 

the state plans have been developed, they are reviewed by National 

Guard counterdrug program officials, and are then sent to DOD for 

approval. National Guard policy9 states that state counterdrug programs 

can provide assistance to interagency partners in 5 mission areas: 

reconnaissance, technical support, general support, civil operations, and 

counterdrug training.10 In 2006, Congress provided authority to the Chief 

of the National Guard Bureau (NGB) to operate up to five counterdrug 

schools.11 These five schools, located in Florida, Iowa, Mississippi, 

Pennsylvania, and Washington, provide training in drug interdiction and 

counterdrug activities to personnel from federal agencies; state, local, and 

tribal law enforcement agencies; community-based organizations; and 

other non-federal governmental and private organizations. In 2011 the 

program added a third state project—counterthreat finance—to assist

interagency partners with investigations of drug trafficking and 

transnational criminal organizations’ money laundering schemes. 

Appendix II provides funding information by project and appendix III 

provides details on the state plans’ activities and supported organizations.

The National Guard counterdrug program is part of DOD’s larger 

counterdrug effort. Congress appropriates funds to DOD’s Drug 

Interdiction and Counterdrug Activities, Defense account, and DOD is 

authorized to transfer Drug Interdiction account funds to other armed 

8

The National Guard, when acting under the control of the Governor, also known as Title 

32 status, may participate in civilian law enforcement activities.

9

Chief National Guard Bureau Instruction 3100.01, National Guard Counterdrug Support

(Sep. 30, 2014). 

10The National Guard has other state missions but they were excluded because they 

relate to managing the program and do not provide support to interagency partners’

counterdrug efforts. 

11The National Drug Control Policy Reauthorization Act of 2006, Pub. L. No. 109-469, § 

901, as amended, authorizes the National Guard to establish and operate not more than 5 

National Counterdrug schools. 

Page 4 GAO-16-133 Drug Control

 
services’ and defense agencies’ appropriation accounts. It is from this 

account that DOD funds the National Guard’s participation in domestic 

interdiction and counterdrug activities.12 In his fiscal year 2016 budget the 

President requested approximately $850.6 million for this account to 

support DOD-wide drug interdiction efforts. Budget data provided by 

DOD identify $87.9 million intended for the National Guard counterdrug 

program’s state-specific projects—a little more than 10 percent of the 

overall fiscal year 2016 Drug Interdiction account request.

The National Guard counterdrug program budget data provided by DOD 

show that for fiscal years 2004 through 2014 the program’s total directed 

funding ranged between $219.3 million and $242.1 million–with a peak of 

$247 million in fiscal year 2013–but in fiscal year 2015 was reduced 

substantially. Congress appropriates funds into DOD’s Drug Interdiction 

account but through its committee reports provides direction to DOD on 

the specific amounts to allocate for the counterdrug program.

13 Based on 

DOD data, in every year since fiscal year 2004, Congress has directed 

funding above DOD’s requested amount, keeping program amounts 

generally steady through 2014. In fiscal year 2013, when DOD began to 

reduce the amount of funding within the budget request for this program 

in order to prioritize funding for other DOD counterdrug programs, 

Congress directed program amounts generally comparable to those of 

prior years. Specifically, in fiscal year 2013, DOD requested $117 million 

for the National Guard counterdrug program, about a 40 percent 

decrease from the prior year’s request. From fiscal years 2013 to 2016, 

DOD reduced its budget request for counterdrug intelligence and 

technology support, as well as domestic efforts such as those supported 

by the National Guard more than international interdiction support 

activities. DOD officials stated that by decreasing requested funding for 

the counterdrug program they planned to address spending limits 

required by the Budget Control Act of 201114 and to fund counternarcotics 

12The Drug Interdiction and Counterdrug Activities account was established by the Fiscal 

Year 1989 Defense Appropriations Act in November 1989. 

13In fiscal year 2015 DOD was directed to establish a separate budget activity for the 

National Guard’s state counterdrug program to provide Congress with visibility into the 

specific funds for this program.

14The Budget Control Act of 2011 (Pub. L. No. 112-25), as amended, established limits on 

discretionary spending for fiscal years 2012 through 2021.

Funding Was 

Generally Steady for 

Past Decade but 

Decreased in Fiscal 

Year 2015

Page 5 GAO-16-133 Drug Control

 
programs in locations deemed a priority, such as Central and South 

America. According to DOD’s data, Congress directed $130 million more 

than requested in fiscal years 2013 and 2014. These additions offset 

DOD’s reduced request and kept overall counterdrug program funding 

generally steady. DOD’s data show that DOD’s budget request for the 

counterdrug program continued to decline from $112.1 million in fiscal 

year 2014 to $89.5 million in fiscal year 2015.15 In fiscal year 2015 

Congress directed $86 million more than DOD requested for the program, 

ultimately leaving the program with a lower total funding of $175.5 million.

Figure 1 details DOD’s budget data on the counterdrug program’s 

congressionally directed funding, including the DOD’s request and the 

increases above DOD’s request. 

Figure 1: Funding for the National Guard’s State Counterdrug Program, Fiscal Years 2004 through 2015

According to DOD’s data, in recent years the program has not obligated 

all of the funding allocated to it from the Drug Interdiction account. In 

15DOD requested $87.9 million for the National Guard Counterdrug Program for fiscal year 

2016. 

Page 6 GAO-16-133 Drug Control

 
fiscal years 2004 through 2010 the program obligated at least 95 percent 

of its allocation. However, from fiscal years 2011 through 2014 the 

program’s obligations fluctuated between 83 percent and 96 percent of 

DOD’s allocations, partly due to the timing and amount of allocations 

received by the program. Funds transferred or allocated from the Drug 

Interdiction account to various other DOD drug interdiction accounts or 

programs, including the National Guard program, can be transferred back 

to the account upon a determination that all or part of the funds are not 

necessary and remain unobligated. Once funds are returned to the Drug 

Interdiction account, they are available for reallocation to other DOD 

counterdrug programs for obligation. Figure 2 details the counterdrug 

program’s obligations from fiscal years 2004 through 2014. 

Figure 2: Obligation Amounts for the National Guard’s Counterdrug Program, Fiscal Years 2004 through 2014

Note: DOD’s obligations may be above or below the congressionally directed program level which 

does not equal total budget authority available for the National Guard’s Counterdrug Program in a 

given year. In no year did programmatic obligations exceed actual budget authority available. 

NGB and state counterdrug programs officials stated that DOD’s internal 

transfer process for the Drug Interdiction account causes delays when 

funds become available for the program, thereby impacting the program’s 

Page 7 GAO-16-133 Drug Control
ability to obligate funds for planned activities.16 For example, state 

program officials stated that in many cases the program cannot provide 

long-term analytical support, such as investigative and counterthreat 

finance analysts, throughout the year, and must wait for additional funding 

before assigning personnel. In some instances, the program can offer 

partial-year support, but some interagency partners may not accept 

support for only part of the year because it is difficult for them to provide 

the necessary training and access to appropriate databases necessary 

for investigative case work to be assigned before the fiscal year ends and 

the funding for the position is no longer available. DOD is examining 

whether it can improve upon the transfer process in order to reduce 

delays. 

According to DOD’s data, DOD has reallocated some of the National 

Guard counterdrug program’s unobligated funds that were returned to the 

Drug Interdiction account to other DOD counterdrug programs. 

Specifically, in fiscal years 2013 and 2014, DOD reallocated a total of 

$51.8 million of amounts returned to the Drug Interdiction account from 

the National Guard’s counterdrug program to counternarcotic capacity 

building efforts in the U.S. Africa Command and U.S. Southern Command 

areas of responsibility.

The NGB has developed performance measures to report on its 

counterdrug program; however, we found that the information collected is 

not used to evaluate and inform funding for state-level programs or 

oversee the counterdrug schools’ training. Without performance 

information to inform funding decisions for state-level programs and 

oversee the counterdrug schools, DOD and Congress cannot ensure that 

the counterdrug program achieves its desired results and uses its 

resources most efficiently.

16Further details on the internal transfer process are presented in appendix IV. 

NGB Has 

Performance 

Measures, but Does 

Not Use the 

Information Collected 

to Inform State-Level 

Programs or Oversee 

the Counterdrug 

Schools 

Page 8 GAO-16-133 Drug Control

 
In 2012 the Deputy Assistant Secretary of Defense for Counternarcotics 

and Global Threats issued the Counternarcotics and Global Threats 

Performance Metrics System Standard Operating Procedures to be used 

in the development and documentation of performance metrics for all 

DOD counternarcotics activities.17 In response to the guidance, National 

Guard counterdrug program officials stated that they developed a set of 

performance measures for use by their program. In fiscal year 2015 the 

counterdrug program included 26 performance measures that officials 

stated they used to evaluate the counterdrug program and report on its 

aggregate performance. These measures include indicators such as the 

number of cases supported, analytic products produced, students trained, 

mobile training courses delivered, and reconnaissance hours flown. 

Appendix V provides details on each of the 26 measures.

Our review of the counterdrug program’s fiscal year 2015 performance 

measures against key attributes of successful performance measures 

identified by GAO18 found that the set of measures provided information 

across the program’s broad goals,19 measured three of the program’s five

core activities, and had limited overlap with each other. We also found 

that the individual performance measures were linked to the overall 

objectives of the program and were focused on measurable goals. Some 

17In December 2006 Congress directed the Office of National Drug Control Policy 

(ONDCP) to produce an annual report describing its national drug control performance 

measurement system and identifying the activities of national drug control program 

agencies, including DOD. In May 2007 ONDCP issued guidance requiring DOD and other 

national drug control program agencies to submit an annual performance summary report, 

including performance measures, targets, and results, to the Director of ONDCP.

18GAO-03-143.GAO developed nine attributes of performance goals and measures based 

on previously established GAO criteria, consideration of key legislation, and review of 

performance management literature. In GAO-03-143 GAO applied the attributes to assess 

Internal Revenue Service performance measures. However, because the attributes are 

derived from sources generally applicable to performance measures, they are also 

relevant for assessing counterdrug program performance measures.

19ONDCP is responsible for overseeing and coordinating national counterdrug policies 

and goals. In this role, ONDCP has issued a national strategy and supplemental strategies 

for geographic areas. See, Executive Office of the President of the United States, Office of 

National Drug Control Policy, National Drug Control Strategy 2014; National Northern 

Border Counternarcotics Strategy (August 2014); National Southwest Border 

Counternarcotics Strategy 2013; and Caribbean Border Counternarcotics Strategy

(January 2015). Also, DOD has developed a supplemental strategy to guide the 

department’s counternarcotics effort. See Deputy Assistant Secretary of Defense, 

Counternarcotics and Global Threats, Department of Defense Counternarcotics and 

Global Threats Strategy (April 27, 2011).

NGB Has Developed a Set 

of Performance Measures 

to Report on the 

Counterdrug Program’s 

Activities 

Page 9 GAO-16-133 Drug Control

 
key attributes, such as a clarity, reliability, and objectivity, were reflected 

to varying degrees, but we found that the National Guard had actions 

underway to better define and document the program’s individual 

performance measures to improve the clarity and reliability of those 

individual measures. In February 2015 the National Guard officials 

completed the Fiscal Year 2015-2016 Counterdrug Analyst Performance 

Metrics Guide and stated that they were drafting guides for other program 

activities. 

We found that the NGB does not use the performance information it 

collects to help evaluate and inform funding for state-level programs and 

oversee the type of training offered by counterdrug schools. We have 

previously reported that setting useful performance measures can assist 

oversight; with them, program managers can monitor and evaluate the 

performance of the program’s activities, track how the activities contribute 

to attaining the program’s goals, or identify potential problems and the 

need for corrective measures. 20 According to leading practices for resultsoriented management, to ensure that performance information will be 

both useful and used in decision making throughout the organization, 

agencies need to consider users’ differing policy and management 

information needs. Performance measures should be selected specifically 

on the basis of their ability to inform the decisions made at each 

organizational level, and they should be appropriate to the responsibilities 

and control at each level.

21

NGB officials stated that they are using performance information to report 

on the program’s aggregate performance to DOD and to respond to other 

20For example, see GAO, Managing for Results: Agencies’ Trends in the Use of 

Performance Information to Make Decisions, GAO-14-747 (Washington, D.C.: September 

26, 2014); Special Education: Improved Performance Measures Could Enhance Oversight 

of Dispute Resolution, GAO-14-390 (Washington, D.C.: August 25, 2014); Managing for 

Results: Executive Branch Should More Fully Implement the GPRA Modernization Act to 

Address Pressing Governance Challenges, GAO-13-518 (Washington, D.C.: June 26, 

2013); and Results-Oriented Government: Using GPRA to Address 21st Century 

Challenges, GAO-03-1166T (Washington, D.C.: September 18, 2003).

21GAO-05-927. GAO developed a conceptual framework identifying four uses of 

performance information for management decision making and five practices that can 

contribute to greater use of performance information from a review of the literature and 

interviews with experts and staff from five agencies (the U.S. Departments of Commerce, 

Labor, Transportation, and Veterans Affairs, and the Small Business Administration). 

NGB Does Not Use its 

Performance Information

to Evaluate and Inform 

Funding for State-Level 

Programs and Oversee 

the Counterdrug Schools

Page 10 GAO-16-133 Drug Control

 
requests for information, such as regarding whom the program supports. 

DOD officials further stated that they use performance information on an 

ad hoc basis to inform the funding request for the Drug Interdiction 

transfer account, but that they do not collect information that could be 

used to evaluate the effectiveness of individual state-level programs or 

could be used in decision making about funding distributions to states. 

Such information could include a measure of the quality of the support 

provided by the National Guard to interagency partners, among other 

things. Instead, NBG officials were making funding distribution decisions 

for individual state programs based solely on assessments of threat. 

According to NGB officials, in 2012 they began using a model to 

determine the severity of the drug threat in each state and using the 

assessments of threat to determine funding levels for state counterdrug 

programs to implement their plans. 22 NGB officials stated that to employ 

the threat-based resourcing model, NGB uses statistics from nationallevel databases to develop a distribution percentage for each state that 

reflects its relative drug threat. This percentage is then applied to the 

funding provided to the National Guard’s counterdrug program. In fiscal 

year 2015 the amount distributed to the states was $146.1 million. Table 

1 shows the distribution percentage to the states and territories, and table 

8 in appendix VI provides a detailed breakout by state.

22We did not assess the validity of the threat-based resource model because it was 

beyond the scope of this review. 

Page 11 GAO-16-133 Drug Control

 
Table 1: Distribution Percentages of National Guard State Plans’ Funding to States 

and Territories Based on Assessment of Drug Threats, Fiscal Year 2015

Distribution Percentage States and Territories

5 percent or more California, Texas, Florida, and Arizona

Between 2 and 5 percent New York, Illinois, Puerto Rico, Tennessee, Georgia, 

Missouri, Ohio, Pennsylvania, and Kentucky

Between 1 and 2 percent North Carolina, New Jersey, Michigan, Indiana, Virginia, 

Washington, Maryland, Louisiana, Massachusetts, 

Oklahoma, South Carolina, Alabama, Kansas, and Oregon

Less than 1 percent New Mexico, Mississippi, Colorado, Nevada, Iowa, 

Arkansas, and Wisconsin Minnesota, Vermont, District of 

Columbia, Nebraska, Connecticut, Delaware, Guam, Hawaii, 

Idaho, Maine, Montana, New Hampshire, North Dakota, 

Rhode Island, South Dakota, U.S. Virgin Islands, Utah, West 

Virginia, Wyoming

Source: GAO analysis of National Guard Bureau data. | GAO-16-133

Moreover, during the course of our review, we found that the 

performance information collected did not assist the DOD 

Counternarcotic Program to oversee the type of training offered by the 

counterdrug schools. Specifically, the performance measures 

employed by the NGB focused on the number of students trained and 

the number of courses available, among other aspects. The officials 

stated these measures were not useful in the evaluation of the 

counterdrug school’s training activities because they did not provide 

information on the type of training being offered, such as whether it 

had a counterdrug focus. In addition, DOD Counternarcotics Program 

officials acknowledged that they did not have a full understanding of 

the counterdrug schools’ activities. To improve their oversight of the 

schools, DOD Counternarcotics Program officials began a review in 

December 2014 of the counterdrug schools’ activities to assess their 

training efforts. In May 2015, based on the preliminary findings of the 

review, the DOD Counternarcotics Program included guidance in its 

memorandum, Preparation of the Fiscal Year 2016 National Guard 

State Drug Interdiction and Counterdrug Activities Plan, that clarified 

the mission of the counterdrug schools and the department’s priorities 

for their training, including that all training offered be explicitly linked to 

counterdrug efforts. As a result, the counterdrug schools are required 

to submit annual training plans that detail course offerings for review 

by the NGB and DOD to ensure that the training is focused on DOD’s 

priorities. However, the guidance did not include any changes to the 

performance information that would be collected by the NGB on the 

counterdrug schools. We continue to believe that collecting additional 

Page 12 GAO-16-133 Drug Control
performance information, such as on the type of training offered, could 

help inform evaluations and identify any need for corrective actions in 

the future for the counterdrug schools. 

According to NGB officials, their current performance measures were 

developed in response to DOD guidance to report on the program’s 

aggregate performance to support DOD’s annual performance 

summary report to ONDCP. NGB officials stated that the guidance did 

not specifically require them to assess the performance of state-level 

programs; therefore, they did not fully consider the types of measures 

or information that would be useful to evaluate the effectiveness of 

individual state-level programs and oversee the counterdrug schools. 

NGB officials stated that their performance measures were evolving 

and they believed incorporating performance information in future 

funding distribution decisions for state programs would be helpful. 

Officials stated that they were working to develop an approach that 

uses performance information to inform future funding decisions.

Without performance information to evaluate state-level programs and 

oversee the counterdrug schools, DOD and Congress cannot ensure 

that the counterdrug program achieves its desired results and uses its 

resources most efficiently. 

The National Guard’s counterdrug program was established more 

than 25 years ago to assist efforts of the Governors of 50 states, the 

District of Columbia, and three U.S. territories in addressing illicit drug 

production, trade, and consumption. In recent years DOD has sought 

to focus its counterdrug efforts on international interdiction support 

activities with less emphasis on other activities including supporting 

domestic efforts like the National Guard’s counterdrug program. 

Congress has resisted the reductions to domestic efforts, and has 

directed increased funding to the program.

Given the resources that the program offers to individual states and 

the interagency partners it supports, it is important to ensure that the 

program uses these resources efficiently and effectively. While threat 

is an important factor to consider in funding distributions, performance 

information can also be used to better inform such decisions. DOD 

and NGB have taken steps to develop performance measures, but 

DOD has used performance information only in an ad hoc basis to 

inform the funding request for the Drug Interdiction transfer account, 

and has not used performance information to evaluate the 

effectiveness of individual state programs or to oversee training 

Conclusions

Page 13 GAO-16-133 Drug Control
offered by the counterdrug schools. Therefore, the effectiveness of 

state efforts is not being considered in DOD’s funding distribution 

decisions, and useful information is not being collected to support 

oversight of the counterdrug schools’ training. Without an approach 

that enables decision makers to objectively judge the performance of 

all elements of the program, neither DOD nor Congress will have 

assurance that the counterdrug program is achieving its goals in an 

effective manner.

To ensure that resources are being efficiently applied to meet the 

National Guard counterdrug program’s objectives, we recommend 

that the Secretary of Defense direct the National Guard Bureau in 

consultation with the Deputy Assistant Secretary of Defense for 

Counternarcotics and Global Threats to take the following two actions:

• Identify additional information needed to evaluate the performance 

of the state programs and oversee counterdrug schools’ training; 

and 

• Subsequently collect and use performance information to help 

inform funding distribution decisions to state programs and to

conduct oversight of the training offered by the counterdrug 

schools.

In the written comments on a draft of this report, DOD concurred with 

our two recommendations and identified specific steps it planned to 

take to address them. With respect to the first recommendation to 

identify additional information needed to evaluate the performance of 

state programs and to oversee the counterdrug schools’ training, DOD 

stated that it will hold discussions with the counterdrug program’s 

stakeholders to reassess the current performance criteria and to 

identify new performance criteria to allow it to assess the support the 

program provides. DOD then will evaluate the criteria to ensure it is 

reflective of the current information needs of the program both 

internally and externally and meets national objectives. These steps, 

once implemented, should help DOD obtain useful information to 

better inform decision making and to conduct oversight of the program 

and would satisfy the intent of our recommendation. With respect to 

the second recommendation to collect and use performance 

information to help inform funding-distribution decisions to state 

programs and to conduct oversight of the training offered by the 

counterdrug schools, DOD stated that it will apply the criteria it 

Recommendation for 

Executive Action 

Agency Comments

and Our Evaluation

Page 14 GAO-16-133 Drug Control
identifies to evaluate the effectiveness of each state program to 

provide support and to meet its objectives. Furthermore, DOD stated 

that it would take steps to assist states with any needed correctiveaction plans. These steps, once implemented, should help to ensure 

that the program uses resources efficiently and effectively and would 

satisfy the intent of our recommendation. DOD’s comments are 

printed in their entirety in appendix VII. DOD also provided technical 

comments, which we incorporated into the report as appropriate.

We also provided a draft of this report to DOJ, DHS, and ONDCP for 

review and comment. DOJ, DHS, and ONDCP officials provided 

technical comments, which we incorporated as appropriate.

We are sending copies of this report to the appropriate congressional 

committees, the Secretary of Defense, the Secretary of Homeland 

Security, the Attorney General of the United States, and the Director 

of National Drug Control Policy. In addition, the report is available at 

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

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

contact me at (202) 512-3489 or pendletonj@gao.gov. Contact points 

for our Offices of Congressional Relations and Public Affairs may be 

found on the last page of this report. GAO staff who made key 

contributions to this report are listed in appendix VIII.

John H. Pendleton

Director, Defense Capabilities and Management

Page 15 GAO-16-133 Drug Control
Appendix I: Scope and Methodology

To address our objectives, we reviewed documentation and 

interviewed officials from the Department of Defense (DOD) who 

oversee and manage the National Guard’s counterdrug program, 

select state counterdrug programs, and select interagency partners 

that receive support from state counterdrug programs. Our analysis 

focused on the state-level operations of the National Guard’s 

counterdrug program, which includes three state-specific projects: 1) 

state plans, 2) counterdrug schools, and 3) counterthreat finance. We 

excluded any counterdrug program projects that were specific to 

federal operations. Also, we used a nongeneralizable case study 

approach to obtain the perspectives of state counterdrug program 

officials and interagency partners receiving support from the program. 

Specifically, we selected 8 of the 53 participating states and territories 

identifying 2 states within each of the four counterdrug program 

regions (selecting 1 state with high and 1 state with low drug threat 

assessments) that also had a counterdrug school or an international 

boundary. The 8 states that we included in our review were: 

Connecticut, Florida, Iowa, Mississippi, Pennsylvania, Texas, Utah, 

and Washington. In the states selected for case study, we interviewed 

state counterdrug program officials and officials from the following 

interagency partners, where applicable: High Intensity Drug 

Trafficking Areas (HIDTA)1

, Drug Enforcement Administration, 

Customs and Border Protection, and U.S. Immigration and Customs 

Enforcement’s Homeland Security Investigations. We selected 

interagency partners based on their receiving support from the 

counterdrug program and on logistics associated with travel. In 

addition, we obtained and analyzed information fiscal years 2011 

through 2014 from a National Guard counterdrug program database2

that included descriptive statistics of the number of staff days by 

mission category, support activities, and supported organization. To 

ensure the accuracy and reliability of the information from the 

database, we took steps to review the data fields for consistency and 

1

The High Intensity Drug Trafficking Areas program is federally funded and brings 

together federal, state, and local law enforcement agencies in task forces that conduct 

investigations of drug trafficking organizations engaged in illegal drug production, 

manufacturing, importation, or distribution. 

2

The National Guard began using the program database in fiscal year 2009. We selected 

fiscal years with full-year data for all the programs participating in the counterdrug 

program.

Appendix I: Scope and Methodology

Page 16 GAO-16-133 Drug Control

 
Appendix I: Scope and Methodology

missing data; we found that these data were sufficiently reliable for 

the purposes of the audit.

To identify the changes in funding for the National Guard counterdrug 

program, we conducted an analysis of relevant appropriations and 

program budget-related documents provided by DOD for fiscal years 

2004 through 2015.3 We began our analysis with fiscal year 2004 data 

to ensure that our review included data covering at least a 10-year 

period. To ensure the reliability of our data, we reviewed 

documentation on funding distributions and financial management 

policy and interviewed knowledgeable officials about DOD’s Drug 

Interdiction and Counterdrug Activities account, and about how 

counterdrug program funds are transferred from the account. We also 

reviewed financial documentation and interviewed DOD, counterdrug 

program, and interagency partner officials to obtain information on 

obligations of available funding. We determined that the data were 

sufficiently reliable for the purposes of this audit.

To assess the extent to which the performance information is used to 

evaluate the counterdrug program’s activities, we reviewed 

documentation and interviewed counterdrug officials about program 

activities, types of performance information collected, and funding 

levels for individual state counterdrug programs. First, we evaluated 

the counterdrug program’s 26 fiscal year 2015 performance measures 

against nine key attributes of successful performance established by 

GAO.4 Next, we evaluated the counterdrug program’s use of 

performance information against leading practices for results-oriented 

management that help agencies develop useful performance 

measures and use performance information for management decision 

3

Obligation data included in the report are through fiscal year 2014. 

4

GAO, Tax Administration: IRS Needs to Further Refine Its Tax Filing Season 

Performance Measures, GAO-03-143 (Washington, D.C.: Nov. 22, 2002). GAO developed 

nine attributes of performance goals and measures based on previously established GAO 

criteria, consideration of key legislation, and review of performance management 

literature. In GAO-03-143, GAO applied the attributes to assess Internal Revenue Service 

performance measures. However, because the attributes are derived from sources 

generally applicable to performance measures, they are also relevant for assessing 

counterdrug program performance measures.

Page 17 GAO-16-133 Drug Control

 
Appendix I: Scope and Methodology

making as identified by GAO through a review of literature and 

interviews with experts and staff from five U.S. agencies.5

Specifically, we interviewed officials from:

Department of Defense:

• National Guard Bureau Counterdrug Program

o Connecticut Counterdrug Program

o Florida Counterdrug Program

 Multijurisdictional Task Force Training Center

o Iowa Counterdrug Program

 Midwest Counterdrug Training Center

o Mississippi Counterdrug Program

 Regional Counterdrug Training Academy

o Pennsylvania Counterdrug Program

 Northeast Counterdrug Training Center

o Texas Counterdrug Program

o Utah Counterdrug Program

o Washington Counterdrug Program

 Western Region Counterdrug Training Center

• National Guard Bureau Budget Execution Office

• Deputy Assistant Secretary of Defense for Counternarcotics and 

Global Threats

• Office of the Undersecretary of Defense, Comptroller

• Army Budget Office

Department of Justice:

• Drug Enforcement Administration (DEA) 

o DEA Miami Division 

o DEA Houston Division 

5

GAO, Managing for Results: Enhancing Agency Use of Performance Information for 

Management Decision Making, GAO-05-927 (Washington, D.C.: Sept. 9, 2005). GAO 

developed a conceptual framework identifying four uses of performance information for 

management decision making and five practices that can contribute to greater use of 

performance information from a review of the literature and interviews with experts and 

staff from five agencies (the U.S. Departments of Commerce, Labor, Transportation, and 

Veterans Affairs, and the Small Business Administration). 

Page 18 GAO-16-133 Drug Control

 
Appendix I: Scope and Methodology

o DEA Philadelphia Division 

o DEA Denver Division 

o DEA New Orleans Division 

o DEA Seattle Division 

o DEA St. Louis Division 

o DEA New England Division 

o DEA Office of Training 

• Federal Bureau of Investigation 

• United States Marshals Service 

• Executive Office for United States Attorneys

Department of Homeland Security:

• Federal Law Enforcement Training Centers

• Homeland Security Investigations (HSI) 

o HSI Special Agent in Charge, Miami, Florida

o HSI Special Agent in Charge, Seattle, Washington

o HSI Special Agent in Charge, Houston, Texas

• Customs and Border Protection (CBP) 

o CBP, Miami, Florida – Sector Intelligence Unit

o CBP, Spokane, Washington – Oroville Station

o CBP, Spokane, Washington – Sector Intelligence Unit

o CBP, Laredo, Texas – Special Operation Detachment

• United States Coast Guard 

High Intensity Drug Trafficking Areas: 

• North Florida HIDTA

• South Florida HIDTA

• Rocky Mountain HIDTA

• Houston HIDTA

• Philadelphia/Camden HIDTA

• New England HIDTA

• Gulf Coast HIDTA

• Northwest HIDTA

• Midwest HIDTA

Office of National Drug Control Policy

We conducted this performance audit from August 2014 to October 2015 

in accordance with generally accepted government auditing standards. 

Page 19 GAO-16-133 Drug Control
Appendix I: Scope and Methodology

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.

Page 20 GAO-16-133 Drug Control
Appendix I: Scope and Methodology

The National Guard identifies three state-specific projects as comprising 

its counterdrug program—state plans, counterdrug schools, and 

counterthreat finance. Table 2 provides the obligations by each state 

project.

Table 2: Obligation Amounts of the National Guard Counterdrug Program by State Project, Fiscal Years 2004 through 2014

(Nominal dollars in millions)

Project Code 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

7403 – State Plans $190.3 $206.6 $213.4 $211.6 $216.8 $218.8 $219.1 $174.6 $196.1 $176.5 $172.8

7415 – Counterdrug 

Schools 18.2 16.6 16.2 21.9 22.7 23.1 27.3 20.0 22.3 19.5 7.0

9301 –Counterthreat 

Finance n/a n/a n/a n/a n/a n/a n/a n/a 1.5 2.3 2.2

Total $208.4 $223.2 $229.6 $233.5 $239.6 $241.9 $246.4 $194.6 $219.9 $198.2 $182.0

Source: GAO analysis of Department of Defense (DOD) data. I GAO-16-133

Appendix II: Obligations by State Project 

Page 21 GAO-16-133 Drug Control
Appendix III: Overview of National Guard State 

Plans’ Counterdrug Activities and Supported 

Organizations, Fiscal Years 2011 through 2014

The National Guard’s state plans include 15 support activities, which are 

grouped into five broad mission categories, as shown in table 3. 

Table 3: State Plans’ Mission Categories and Support Activities 

Technical support

a. Linguist and translator 

b. Investigative case analysis 

c. Drug detectiona 

d. Communications 

e. Engineer 

f. Subsurface and diver 

g. Counterthreat finance analysis 

h. Imagery and mapping analysis 

General support

a. Domestic cannabis suppression and eradication 

b. Transportation 

Reconnaissance and observation

a. Ground reconnaissance

b. Aerial reconnaissance

Civil operations

a. Educational programs to community organizations

b. Support to community organizations 

c. Support to coalitions

Counterdrug-related training

Source: GAO analysis of National Guard counterdrug missions and activities. I GAO-16-133

Note: The program also includes mission categories for internal program management. Since these 

missions do not provide support to interagency partners, we did not include the missions in the table. 

a Drug detection includes the use of military equipment to assist supported organizations in detecting 

illegal drugs.

The National Guard counterdrug program collects information on the 

activities and supported organizations and uses staff days to measure its 

resource investment. Our analysis of this information found that from 

fiscal years 2011 through 2014 the state plans invested most of their staff 

days in the mission categories of technical support and reconnaissance. 1

1

The National Guard began using its program database in fiscal year 2010. We selected 

fiscal years with full year data.

Appendix III: Overview of National Guard State 

Plans’ Counterdrug Activities and Supported 

Organizations, Fiscal Years 2011 through 2014

Page 22 GAO-16-133 Drug Control

 
Appendix III: Overview of National Guard State 

Plans’ Counterdrug Activities and Supported 

Organizations, Fiscal Years 2011 through 2014

During this period, the number of staff days invested in civil operations 

decreased, as shown in figure 3. 

Figure 3: State Plans’ Staff Days by Mission Category, Fiscal Years 2011 through

2014

Of the 15 support activities, investigative case and analyst support was 

the support activity most frequently provided from fiscal years 2011 

through 2014, as shown in table 4. 

Page 23 GAO-16-133 Drug Control
Appendix III: Overview of National Guard State 

Plans’ Counterdrug Activities and Supported 

Organizations, Fiscal Years 2011 through 2014

Table 4: State Plans’ Staff Days by Type of Support Activity, Fiscal Years 2011 through 2014

Activity

Fiscal Year

Technical support 2011 2012 2013 2014 Total

Linguist and translator 4,329 3,589 5,498 3,548 16,964

Investigative case and analyst 235,387 225,660 209,238 215,305 885,590

Prosecution case 6,621 n/a n/a n/a 6,621

Drug detection n/a 3,671 2,940 5,695 12,306

Communications 17,457 10,809 10,527 4,750 43,543

Engineer 5,368 8,770 5,656 4,664 24,458

Subsurface and diver 77 0 119 0 196

Counterthreat finance n/a 8,785 11,437 11,164 31,386

Imagery and mapping analysis n/a n/a n/a 433 433

Training or administrative 5,321 1,431 3,650 2,878 13,281

General support

Cannabis eradication 23,679 16,087 20,685 25,336 85,787 

Transportation 433 623 1145 755 2,956

Training or administrative 5,723 0 5,956 8,920 20,599

Counterdrug-related training 

Training 11,630 14,880 15,506 6,718 48,734

Reconnaissance

Ground reconnaissance 64,155 58,867 43,539 58,983 225,544

Aerial reconnaissance 97,680 82,121 70,907 74,870 325,577

Training or administrative 7,544 8,737 3,693 7,961 27,935

Civil Operations

Demand reduction 116,162 n/a n/a n/a 116,162

Support to coalitions and community 

organizations

14,300 25,426 28,379 25,747 93,852

Blank 1,325 0 0 0 1,325

Total 627,306 556,757 460,161 468,607 2,112,831

Source: GAO analysis of National Guard activities data. I GAO-16-133

Notes: “Not applicable” signifies that in the fiscal year, the activity was discontinued or was not an 

approved activity. “Training or administrative” signifies the staff days that personnel assigned to a 

specific mission category spent in training or completing required administrative tasks. Numbers may 

not total, due to rounding.

Page 24 GAO-16-133 Drug Control
Appendix III: Overview of National Guard State 

Plans’ Counterdrug Activities and Supported 

Organizations, Fiscal Years 2011 through 2014

Among the various categories of supported organizations, law 

enforcement received the most support from the state plans, as shown in 

table 5.

Table 5: State Plans’ Staff Days by Supported Organizations, Fiscal Years 2011 through 2014

Organization category 2011 2012 2013 2014

Government 497,427 445,2015 397,687 409,770

Law enforcement 220,980 207,849 181,323 199,116

Military 172,284 139,681 121,908 103,242

High Intensity Drug Trafficking Areas 36,407 30,625 35,690 34,943

Task force 35,452 35,402 28,541 33,196

Other government 29,063 26,934 26,568 34,850

Fusion centera 3,241 4,710 3,656 4,384

Not assigned to a specific organizationb 82,748 78,410 41,255 42,886

Schools 27,984 13,532 803 812

Community-based organizations 14,285 12,399 5,681 1,841

Coalitions 2,085 7,210 14,743 12,004

Otherc 2,772 4 0 1,333

TOTAL 627,306 556,757 460,161 468,607

Source: GAO analysis of National Guard activities data. I GAO-16-133 

a

Fusion centers gather and analyze threat information and share it among all levels of government 

and the private sector. Federal agencies support these centers by providing personnel, funding, and 

other assistance. 

b

“Not assigned to a specific organization” signifies the hours when personnel are not assigned to 

support a specific organization but are completing training and required administrative tasks. 

C

Other includes the categories of “unknown” and “vendor”. 

Lastly, the federal agencies to which state plans provided the most 

support were the Department of Justice and Department of Homeland 

Security. The specific components that received the most support 

included the Drug Enforcement Administration, Customs and Border 

Protection, and Immigration and Customs Enforcement, as shown in table 

6. 

Page 25 GAO-16-133 Drug Control
Appendix III: Overview of National Guard State 

Plans’ Counterdrug Activities and Supported 

Organizations, Fiscal Years 2011 through 2014

Table 6: State Plans’ Staff Days by Support Federal Agencies, Fiscal Years 2011 through 2014

Federal Agency Component

Fiscal Year

2011 2012 2013 2014

Department of Agriculture 1,799 1,553 1,516 1,053

Forest Service 1,799 1,553 1,507 1,038

Department of Health and Human Services 282 326 171 344

Food and Drug Administration 282 319 171 344

Department of Homeland Security 46,835 49,695 40,353 38,224

Coast Guard 1,206 1,278 1,614 1,082

Customs and Border Protection 32,079 32,842 20,810 18,317

Immigration and Customs Enforcement 12,686 12,915 15,996 14,587

Secret Service 420 511 -- --

Department of Interior 458 297 152 143

Bureau of Land Management 164 55 54 101

National Park Service 294 242 31 42

Department of Justice 78,117 76,195 70,452 68,633

Alcohol, Tobacco, Firearms and 

Explosives 

982 1,205 658 629

Drug Enforcement Administration 62,880 62,223 56,851 57,693

Federal Bureau of Investigations 7,868 6,527 7,255 6,237

U.S. Marshals Service 5,510 5,351 4,940 3,189

Department of Transportation 1,137 137 466 900

Federal Aviation Administration 1,137 137 466 900

Department of Treasury 724 1,925 1,578 2,926

Internal Revenue Service 724 1,618 1,249 2,926

U. S. Courts 172 11 -- --

U.S. Postal Service 2,306 2,900 3,350 3,017

Othera 2 -- 363 --

TOTAL 130,382 133,038 118,399 115,330

Source: GAO analysis of National Guard counterdrug missions and activities. I GAO-16-133

a

Other includes Veterans Affairs and the Office of National Drug Control Policy. 

Page 26 GAO-16-133 Drug Control
Appendix IV: Overview of DOD’s Drug 

Interdiction and Counterdrug Activities 

Account Fund Transfer Process

After Congress appropriates amounts to the Drug Interdiction account, 

there are multiple steps by various organizations before the funds are 

received by each individual state counterdrug program. To begin each 

transfer process, DOD Counternarcotic Program officials prepare and 

submit to the Office of the Under Secretary of Defense (Comptroller) a 

DD1415-3, which details the allocation of funds by appropriation or 

budget activity account for each program. If no defense appropriations act 

has been passed and DOD is operating under a continuing resolution, 

amounts transferred are based on a rate-per-day formula developed by 

DOD. Once a defense appropriation act is enacted, the Comptroller is 

required to submit to Congress the department’s intended budget 

execution based on the appropriation act and congressional directions as 

expressed in House and Senate Appropriation committee reports.1 This 

report, which DOD calls the base for reprogramming and transfer 

authorities (DD1414), is to be submitted no later than 60 days from the 

enactment of an appropriation. After this baseline is submitted, 

Comptroller officials review and approve the DD1415-3 and forward it to 

the Office of Management and Budget. 2 Once approved by the Office of 

Management and Budget, the Comptroller issues a funding authorization 

document to transfer funds to the military services appropriation accounts 

(such as military personnel or operation and maintenance). The military 

services then transfer funds to appropriation accounts managed by Army 

National Guard and Air National Guard, which, in turn, distribute the funds 

onto each state National Guard participating in the program. Figure 4 

outlines the fund transfer process to the counterdrug program.

1

The DD1414 is the report that DOD submits to Congress to establish the baseline from 

which it will make reprogramming and transfer proposals.

2

The Office of Management and Budget (OMB) manages and approves apportionments at 

the Treasury appropriation fund level. Apportionment is part of the government-wide 

system for the administrative control of funds. Unless exempted by statute or 

automatically apportioned, all DOD appropriated resources require OMB approval through 

the apportionment process before they are available for distribution and legal obligation.

Appendix IV: Overview of DOD’s Drug 

Interdiction and Counterdrug Activities 

Account Fund Transfer Process

Page 27 GAO-16-133 Drug Control

 
Appendix IV: Overview of DOD’s Drug 

Interdiction and Counterdrug Activities 

Account Fund Transfer Process

Figure 4: Drug Interdiction Account Fund Transfer Process

The National Guard Bureau’s Counterdrug Program office coordinates the 

process involving the DOD Counternarcotic Program, the Army and Air 

National Guard budget and financial management offices, and the 

individual state counterdrug programs. 

Page 28 GAO-16-133 Drug Control
Appendix V: National Guard Counterdrug 

Program's Fiscal Year 2015 Performance 

Measures

In fiscal year 2015 the counterdrug program officials used 26 

performance measures to report on the program’s aggregate 

performance to DOD and respond to requests for information, as shown 

in table 7.

Table 7: Performance Measures of National Guard Counterdrug Program, Fiscal Year 2015 

Mission Category: Technical Support

Project Code Performance Measure 

State Plans Percentage of criminal analyst mission request supports

State Plans Number of cases supported per 321 staff days

State Plans Number of deconflictions

State Plans Number of analytical products produced

State Plans Number of cases closed per 321 staff days

State Plans Number of drug trafficking organizations disrupted

State Plans Number of drug trafficking organizations dismantled

Counterthreat Finance Number of laundering cases supported

Counterthreat Finance Number of laundering targets identified

Counterthreat Finance Number of laundering methods identified

Counterthreat Finance Number of analytical reports produced

Counterthreat Finance Number of targets dismantled laundering greater than $5 million per year

Counterthreat Finance Number of targets dismantled laundering less than $5 million per year

State Plans and Counterthreat Finance Total value in U.S. dollars interdicted through Department of Defense counternarcotics 

funded National Guard programs (western hemisphere)

Mission Category: General Support

Project code Performance Measure 

State Plans Percentage of requests supported

Mission Category: Counterdrug Related 

Training

Project code Performance Measure 

Counterdrug Training Number of students trained

Counterdrug Training Percentage of fulfilled continental United States training requests 

Counterdrug Training Total number of courses (by events) available at counterdrug schools

Counterdrug Training Number of mobile training team courses delivered

Counterdrug Training Percentage of Joint Task Force - North mobile training team requests supported by the 

National Guard

Mission Category: Reconnaissance and 

Observation

Project code Performance Measure 

State Plans Number of reconnaissance hours flown in support of law enforcement

Appendix V: National Guard Counterdrug 

Program's Fiscal Year 2015 Performance 

Measures

Page 29 GAO-16-133 Drug Control
Appendix V: National Guard Counterdrug 

Program's Fiscal Year 2015 Performance 

Measures

Mission Category: Technical Support

Mission Category: Civil Operations

Project code Performance Measure 

State Plans Total mission events conducted that employ military skills in building community strategies 

State Plans Total population served by implementing comprehensive community strategies 

State Plans Total civil operations personnel capable of supporting combatant commands 

State Plans Total coalition strategic prevention framework surveys conducted

State Plans Increase in sector and law enforcement agency representation in supported coalitions

Source: National Guard Bureau. I GAO-16-133

Page 30 GAO-16-133 Drug Control
Appendix VI: Overview of the Threat-Based 

Resource Model and Funding Amounts by 

State and Territory

Each state within the counterdrug program develops an annual plan of 

activities, in coordination with the state’s Governor and Attorney General, 

that identifies its counterdrug priorities and how it intends to obligate its 

available funds. To develop these plans, states use annual guidance from 

DOD that identifies approved activities for the counterdrug program. For 

instance, investigative case support, ground and aerial reconnaissance, 

and counterthreat finance analysis are approved activities.

The threat-based resource model uses 22 variables to assess the drug 

threat across the 53 counterdrug programs. Almost half of the variables

are based on information from the National Seizure System database.1

Other variables are based on information from federal agencies such as 

the Substance Abuse and Mental Health Services Administration and the 

Federal Bureau of Investigation. 

To ensure that every state has a viable counterdrug program, the Chief of 

the National Guard Bureau established $500,000 as the minimum level of 

funding for each state. According to counterdrug program officials, this 

amount enables all the states to maintain some capability to address drug 

threats while limiting the impact on states with higher threats. Table 8 

provides details on the state plans distribution percentages by state and 

territories for fiscal year 2015.

1

The National Seizure System is a DEA database of drug seizures made by U.S. law 

enforcement agencies, which are reported to the El Paso Intelligence Center. 

Appendix VI: Overview of the Threat-Based 

Resource Model and Funding Amounts by 

State and Territory

Page 31 GAO-16-133 Drug Control

 
Appendix VI: Overview of the Threat-Based 

Resource Model and Funding Amounts by 

State and Territory

Table 8: Fiscal Year 2015 Threat-Based Resource Model Threat Percentages by State or Territory Program

Program Percentage Program Percentage

California 13.17% New Mexico 0.97%

Texas 12.98% Mississippi 0.94%

Florida 5.54% Colorado 0.93%

Arizona 5.02% Nevada 0.92%

New York 4.33% Iowa 0.91%

Illinois 3.20% Arkansas 0.88%

Puerto Rico 2.71% Wisconsin 0.87%

Tennessee 2.46% Minnesota 0.87%

Georgia 2.26% Vermont 0.75%

Missouri 2.18% District of Columbia 0.74%

Ohio 2.14% Nebraska 0.73%

Pennsylvania 2.12% Connecticut 0.70%

Kentucky 2.07% Delaware 0.70%

North Carolina 1.94% Guam 0.70%

New Jersey 1.90% Hawaii 0.70%

Michigan 1.82% Idaho 0.70%

Indiana 1.53% Maine 0.70%

Virginia 1.49% Montana 0.70%

Washington 1.43% New Hampshire 0.70%

Maryland 1.42% North Dakota 0.70%

Louisiana 1.36% Rhode Island 0.70%

Massachusetts 1.26% South Dakota 0.70%

Oklahoma 1.17% U.S. Virgin Islands 0.70%

South Carolina 1.15% Utah 0.70%

Alabama 1.12% West Virginia 0.70%

Kansas 1.11% Wyoming 0.70%

Oregon 1.05% Alaskaa 0.00%

Source: National Guard counterdrug program data. I GAO-16-133

a

Alaska has not participated in counterdrug program since fiscal year 2014.

The amount of funding each state receives depends on that state’s 

distribution percentage and available funds for the state plans project. 

Table 9 details the funding distributed to each state and territory in fiscal 

years 2014 and 2015.

Page 32 GAO-16-133 Drug Control
Appendix VI: Overview of the Threat-Based 

Resource Model and Funding Amounts by 

State and Territory

Table 9: State Plans’ Funding by State and Territories, Fiscal Years 2014 and 2015

Fiscal Year

State or Territory 2014 2015

Alabama $2,110,367 $2,130,546

Alaska 0 0

Arizona 1,786,639 6,643,038

Arkansas 14,116,892 1,783,881

California 23,308,294 22,639,065

Colorado 1,247,416 1,403,185

Connecticut 1,205,451 1,311,015

Delaware 938,827 998,640

District of Columbia 1,131,791 1,166,180

Florida 6,320,926 6,347,694

Georgia 3,889,948 3,312,889

Guam 563,306 632,498

Hawaii 1,140,145 790,244

Idaho 702,119 602,127

Illinois 3,135,672 2,951,287

Indiana 3,886,980 4,207,991

Iowa 1,591,581 1,514,021

Kansas 1,178,746 884,441

Kentucky 8,034,316 5,289,403

Louisiana 2,396,025 1,291,725

Maine 1,008,600 799,520

Maryland 2,763,234 2,304,829

Massachusetts 1,383,039 1,065,624

Michigan 1,947,976 2,013,786

Minnesota 1,312,450 1,387,742

Mississippi 1,865,560 2,242,773

Missouri 2,382,271 2,992,862

Montana 936,077 754,400

Nebraska 1,010,916 771,621

Nevada 1,478,681 1,262,081

New Hampshire 660,572 650,535

New Jersey 2,443,663 2,123,567

New Mexico 3,683,913 2,524,656

New York 6,531,500 7,163,473

Page 33 GAO-16-133 Drug Control
Appendix VI: Overview of the Threat-Based 

Resource Model and Funding Amounts by 

State and Territory

Fiscal Year

North Carolina 2,064,791 1,996,380

North Dakota 911,218 793,178

Ohio 2,443,352 2,468,261

Oklahoma 1,497,793 1,777,016

Oregon 1,668,232 2,089,292

Pennsylvania 2,914,034 2,868,961

Puerto Rico 3,468,617 4,563,715

Rhode Island 750,104 944,095

South Carolina 1,819,307 1,387,388

South Dakota 1,591,833 896,192

Tennessee 3,595,708 3,837,808

Texas 18,096,454 17,478,733

U.S. Virgin Islands 1,256,055 841,297

Utah 1,875,157 2,104,681

Vermont 708,446 718,257

Virginia 1,667,424 1,433,987

Washington 2,126,321 1,843,313

West Virginia 2,998,851 2,310,368

Wisconsin 1,367,539 1,144,083

Wyoming 577,971 596,005

Total $161,493,100 $146,050,349

Source: National Guard counterdrug program data. I GAO-16-133

Page 34 GAO-16-133 Drug Control
Appendix VII: Comments from the Department of Appendix VII: Comments from the Defense

Department of Defense

DOD’s comments refer to 

GAO report number, 

GAO-15-533. Given that 

GAO is issuing its final 

report in fiscal year 2016, 

it has changed the report 

number to GAO-16-133.

Page 35 GAO-16-133 Drug Control
Appendix VII: Comments from the Department of 

Defense

Page 36 GAO-16-133 Drug Control
Appendix VII: Comments from the Department of 

Defense

Page 37 GAO-16-133 Drug Control
Appendix VII: Comments from the Department of 

Defense

Page 38 GAO-16-133 Drug Control
Appendix VI: Overview of the Threat-Based 

Resource Model and Funding Amounts by 

State and Territory

John H. Pendleton, (202) 512-3489 or pendletonj@gao.gov

In addition to the contact named above, Rich Geiger (Assistant Director), 

Tom Jessor, Linda S. Keefer, Susan C. Langley, Amie Steele Lesser, 

Felicia M. Lopez, Tobin J. McMurdie, Carol D. Petersen, Richard 

Powelson, Caitlin N. Rice, Michael D. Silver, Sabrina C. Streagle, and 

Cheryl A. Weissman made key contributions to this report. 

Appendix VIII: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

Page 39 GAO-16-133 Drug Control
Appendix VI: Overview of the Threat-Based 

Resource Model and Funding Amounts by 

State and Territory

Budget Issues: Effects of Budget Uncertainty From Continuing 

Resolutions on Agency Operations. GAO-13-464T. Washington D.C.: 

March 13, 2013.

Drug Control: Initial Review of the National Strategy and Drug Abuse 

Prevention and Treatment Programs. GAO-12-744R. Washington D.C.: 

July 6, 2012.

Office of National Drug Control Policy: Agencies View the Budget Process 

as Useful for Identifying Priorities, but Challenges Exist. GAO-11-261R. 

Washington D.C.: May 2, 2011.

Drug Control: DOD Needs to Improve Its Performance Measurement 

System to Better Manage and Oversee Its Counternarcotics Activities.

GAO-10-835. Washington D.C.: July 21, 2010.

Preliminary Observations on the Department of Defense’s 

Counternarcotics Performance Measurement System. GAO-10-594R. 

Washington D.C.: April 30, 2010.

Continuing Resolutions: Uncertainty Limited Management Options and 

Increased Workload in Selected Agencies. GAO-09-879. Washington 

D.C.: September 24, 2009.

Related GAO Products

(351961) Page 40 GAO-16-133 Drug Control
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