Office of the Inspector General

U.S. Department of Justice

OVERSIGHT ★ INTEGRITY ★ GUIDANCE

Audit of the Office of Community 

Oriented Policing Services Hiring 

Program Grants Awarded to the 

Arlington Police Department, 

Arlington, Texas

REDACTED FOR PUBLIC RELEASE

REDACTED FOR PUBLIC RELEASE

REDACTED FOR PUBLIC RELEASE

Redactions were made to the full version of this report for privacy reasons. The redactions are contained in 

Appendix 4, the grantee’s response and Appendix 5, the granting agency’s response, and are of individuals’ 

names.

Audit Division 20-070 June 2020
i

Executive Summary

Audit of the Office of Community Oriented Policing Services Hiring Program 

Grants Awarded to the Arlington Police Department, Arlington, Texas

Objectives

The Office of Community Oriented Policing Services

(COPS Office) awarded the Arlington Police Department 

(APD) three grants totaling $11.2 million in project costs 

that included $5.6 million in federal funds for the COPS 

Hiring Program (CHP) and $5.6 million in local funds. 

The objectives of this audit were to determine whether 

costs claimed under the grants were allowable, 

supported, and in accordance with applicable laws, 

regulations, guidelines, and terms and conditions of the 

award; and to determine whether the grantee 

demonstrated adequate progress towards achieving 

program goals and objectives.

Results in Brief

As a result of our audit, we concluded that the APD

demonstrated adequate progress toward achieving the 

grants’ stated community policing goals, except that the 

APD did not provide documentation of activity with what 

it considered its three most important partners under 

Grant Number 2017-UL-WX-0015. Additionally, we did

not identify significant concerns regarding the APD’s 

required match and application statistics. However, we 

identified noncompliance with essential award conditions 

related to performance reports, officer type, use of 

funds, and financial accounting. Specifically, the APD 

charged unallowable salaries for ineligible officers to the 

grants, charged unallowable salaries and fringe benefits 

over the approved amounts in the Financial Clearance 

Memorandums (FCM), and did not accurately account for 

grant expenditures by cost category. Further, we 

determined that procedures related to progress reports, 

budget management and control, drawdowns, and 

federal financial reporting could be improved. As a 

result of these deficiencies, we identified $878,341 in 

unallowable total project costs, and the APD paid back 

the federal share to the DOJ before the issuance of this

final report.

Recommendations

Our report contains 13 recommendations to the COPS 

Office. We requested a response to our draft audit 

report from the COPS Office and the APD, which can be 

found in Appendices 5 and 4, respectively. Our analysis 

of those responses is included in Appendix 6.

Audit Results

The purpose of the three COPS Office CHP grants we 

reviewed was to hire new, additional career law 

enforcement officers in an effort to increase the 

agency’s community policing capacity and crime 

prevention efforts. The project period for the grants 

was from September 2015 through October 2020. The 

APD drew down a cumulative amount of $4,104,142 for

all of the grants we reviewed as of September 2019.

Program Goals and Accomplishments – We found 

that the APD demonstrated adequate achievement of 

the grant’s stated community policing goals under Grant 

Number 2015-UL-WX-0026. Additionally, the APD

demonstrated adequate progress towards achieving the 

grants’ stated community policing goals under Grant 

Numbers 2016-UL-WX-0011 and 2017-UL-WX-0015, 

except that the APD did not document activity with what 

it considered its three most important partners under 

Grant Number 2017-UL-WX-0015.

Grant Expenditures – We found that the APD charged 

unallowable salaries and fringe benefits related to 

44 officers that filled 35 positions throughout the grant 

periods that did not adhere to any CHP hiring category. 

After bringing this issue to APD officials’ attention, the 

APD identified officers that were eligible under the 

grants. However, we identified $856,520 in remaining 

unallowable costs associated with the ineligible officers. 

Additionally, we identified $21,821 in unallowable 

salaries and associated fringe benefits under Grant 

Number 2015-UL-WX-0026, as these costs exceeded the 

allowable rates in the FCM.

Budget Management and Control – We found that 

the APD did not accurately account for grant 

expenditures by cost category, and that the APD 

charged costs in excess of approved rates in the FCM.

Drawdowns – We found that the APD was overdrawn 

on Grant Number 2016-UL-WX-0011 as a result of 

charging the unallowable salaries of ineligible officers to 

the award.
AUDIT OF THE OFFICE OF COMMUNITY ORIENTED

POLICING SERVICES HIRING PROGRAM GRANTS

AWARDED TO THE ARLINGTON POLICE DEPARTMENT,

ARLINGTON, TEXAS

TABLE OF CONTENTS

INTRODUCTION .......................................................................................... 1

The Grantee ...................................................................................... 1

OIG Audit Approach ............................................................................ 2

AUDIT RESULTS.......................................................................................... 3

Program Performance and Accomplishments ........................................... 3

Program Goals and Objectives ..................................................... 3

Required Progress Reports .......................................................... 4

Retention Plan Requirement ........................................................ 5

Grant Financial Management ................................................................ 6

Grant Expenditures............................................................................. 7

Officer Type.............................................................................. 8

Personnel and Fringe Costs ....................................................... 11

Matching Costs........................................................................ 13

Budget Management and Control ........................................................ 13

Non-Supplanting Requirement ................................................... 16

Drawdowns ..................................................................................... 17

Federal Financial Reports ................................................................... 19

Application Statistics ......................................................................... 19

CONCLUSION AND RECOMMENDATIONS....................................................... 21

APPENDIX 1: OBJECTIVES, SCOPE, AND METHODOLOGY ................................ 23

APPENDIX 2: SCHEDULE OF DOLLAR-RELATED FINDINGS............................... 26

APPENDIX 3: ADDITIONAL TABLES AND FIGURES ......................................... 27
APPENDIX 4: ARLINGTON POLICE DEPARTMENT RESPONSE TO THE DRAFT AUDIT 

REPORT .......................................................................................... 30

APPENDIX 5: OFFICE OF COMMUNITY ORIENTED POLICING SERVICES RESPONSE 

TO THE DRAFT AUDIT REPORT............................................................ 37

APPENDIX 6: OFFICE OF THE INSPECTOR GENERAL ANALYSIS AND SUMMARY OF 

ACTIONS NECESSARY TO CLOSE THE REPORT ...................................... 48
1

AUDIT OF THE OFFICE OF COMMUNITY ORIENTED

POLICING SERVICES HIRING PROGRAM GRANTS

AWARDED TO THE ARLINGTON POLICE DEPARTMENT, 

ARLINGTON, TEXAS

INTRODUCTION

The U.S. Department of Justice (DOJ) Office of the Inspector General (OIG) 

completed an audit of three grants awarded by the Office of Community Oriented 

Policing Services (COPS Office), under the COPS Hiring Program (CHP) to the 

Arlington Police Department (APD) in Arlington, Texas, totaling over $11.2 million in 

project costs that included over $5.6 million in federal funds, as shown in Table 1.

Table 1

COPS Office Hiring Program Grants Awarded to the APD

Award Number Award 

Date

Project 

Period 

Start Date

Project 

Period 

End Date

Federal 

Share

Applicant 

Share

Total 

Project 

Costs

2015-UL-WX-0026 10/01/2015 09/01/2015 12/03/2018 $1,875,000 $1,734,938 $3,609,938

2016-UL-WX-0011 10/01/2016 09/01/2016 09/30/2020 1,875,000 1,798,606 3,673,606

2017-UL-WX-0015 11/01/2017 11/01/2017 10/31/2020 1,875,000 2,045,629 3,920,629

Total: $5,625,000 $5,579,173 $11,204,173

Source: COPS Office

Funding through CHP grants supports local law enforcement agencies’ ability

to hire, rehire, or both career law enforcement officers in an effort to increase the

agency’s community policing capacity and crime prevention efforts. The COPS 

Office defines community policing as a philosophy that promotes organizational 

strategies that support the systematic use of partnerships and problem solving 

techniques to proactively address the immediate conditions that give rise to public 

safety issues such as crime, social disorder, and fear of crime.

Additionally, CHP grants provide up to 75 percent of the approved entry-level 

salaries and fringe benefits of full-time officers for a 36-month grant period with a 

minimum 25 percent local cash match requirement and a maximum federal share of 

$125,000 per officer position. CHP grant funding may be used to hire new officers, 

rehire officers who have been laid off, or avoid the scheduled lay off of officers on a 

specific future date as a result of local budget reductions. For the APD, CHP grant 

funding supported the hiring of 15 new, additional officer positions under each

grant, totaling 45 positions. Additionally, each position was to be retained 

12 months following the conclusion of DOJ grant funding with local funds.

The Grantee

The APD serves the City of Arlington, Texas which is located between Dallas 

and Fort Worth, Texas in Tarrant County. The city is about 100 square miles, has 

more than 380,000 residents, and over 680 sworn law enforcement officers as of 
2

September 2019. An important component of policing at APD is its efforts to 

maintain a law enforcement agency whose personnel reasonably represent the 

diversity of the community. Additionally, the APD’s mission is to build trust in the 

community through transparent actions and positive engagement and to leverage 

technology, geographic policing, and employee development to increase legitimacy 

and reduce crime. Further, the APD was selected by the COPS Office as 1 of 15 law 

enforcement agencies to lead a national initiative, the Task Force on 21st Century 

Policing. In 2014, President Obama created this initiative to identify best practices 

and offer recommendations on how policing in America can promote effective crime 

reduction while building trust and promoting officer wellness and safety.

Grant Administration

Through the course of the audit, we identified 61 officers that filled the

45 awarded CHP positions throughout the 3 grant periods. Of these 61 officers, we 

found that 44 officers were not eligible under any CHP hiring category and should 

have been locally funded. We discuss this issue in more detail in multiple sections 

of the audit report, including Required Performance Reports, Retention Plan 

Requirement, Officer Type, Personnel and Fringe Costs, and Drawdowns.

OIG Audit Approach

The objectives of this audit were to determine whether costs claimed under 

the grants were allowable, supported, and in accordance with applicable laws, 

regulations, guidelines, and terms and conditions of the grants; and to determine 

whether the grantee demonstrated adequate progress towards achieving program 

goals and objectives. To accomplish these objectives, we assessed performance in 

the following areas of grant management: program performance, financial 

management, expenditures, budget management and control, drawdowns, and 

federal financial reports, application statistics, and the retention plan.

We tested compliance with what we consider to be the most important 

conditions of the grants. The DOJ Grants Financial Guide; the 2015, 2016, and 

2017 CHP Award Owner’s Manuals (Award Owner’s Manual); and the award 

documents contain the primary criteria we applied during the audit.1

The results of our analysis are discussed in detail later in this report. 

Appendix 1 contains additional information on this audit’s objectives, scope, and 

methodology. The Schedule of Dollar-Related Findings appears in Appendix 2, and 

additional tables and figures related to findings in the audit report appear in 

Appendix 3.

1 The DOJ Grants Financial Guide serves as the primary reference manual to assist Office of 

Justice Programs, Office on Violence Against Women, and COPS Office award recipients in fulfilling 

their fiduciary responsibility to safeguard grant funds and ensure funds are used for the purposes for 

which they were awarded.
3

AUDIT RESULTS

Program Performance and Accomplishments

We reviewed required performance reports, grant applications, grant 

documentation, and interviewed APD officials to determine whether the APD 

demonstrated adequate progress towards achieving the program goals and 

objectives. We also reviewed quarterly progress reports to determine if the 

required reports were accurate. Finally, we assessed the APD’s retention plan 

under Grant Number 2015-UL-WX-0026.

Program Goals and Objectives

The program goals and objectives of CHP grants are intrinsically tied to 

community policing. In the grant applications, the primary goals of the community 

policing plan are selected in response to the grantee’s defined focus area. 

According to the Award Owner's Manual, the grant recipient is required to 

implement the community policing plan it set forth in the CHP award application, 

which includes the following elements of community policing: (1) problem solving, 

(2) community partnerships and support, and (3) organizational transformation. 

For the ended award, Grant Number 2015-UL-WX-0026, we verified that all 

community policing goals were achieved. For the on-going awards, Grant Numbers 

2016-UL-WX-0011 and 2017-UL-WX-0015, we verified progress towards achieving 

the community policing goals.

The focus area for Grant Number 2015-UL-WX-0026 was to build trust, 

specifically to reduce citizen distrust of police actions and motives through 

increased police involvement in positive, non-enforcement activities with citizens. 

The three primary goals related to this focus area were to: (1) increase public trust 

in the agency, (2) improve the response to the focus area, and (3) improve citizen 

perceptions of the focus area. Additionally, the APD detailed the three most 

important external organizations that it would initiate or enhance a partnership with 

to develop responses to the focus area. In all, the APD stated that it would initiate 

or enhance a total of 40 partnerships.

For Grant Number 2015-UL-WX-0026, we found no indications that the APD

did not adequately achieve the stated community policing goals of the grant.

The focus area for Grant Number 2016-UL-WX-0011 was to build trust 

through impartial policing. Specifically, the APD planned to reduce public 

perception of biased enforcement through enhanced supervision that emphasized 

procedural justice principles. At the APD, these principles include: (1) treating 

people with respect, (2) listening to what they have to say, (3) making fair 

decisions, and (4) explaining all actions. The APD’s three primary goals in response 

to their focus area were to: (1) increase public trust in the agency; (2) improve the 

response to the focus area; and (3) improve citizen perceptions of the focus area. 

Additionally, the APD detailed the three most important external organizations that 

it would initiate or enhance a partnership with to develop responses to the focus 
4

area. In all, the APD stated that it would initiate or enhance a total of 

41 partnerships.

For Grant Number 2016-UL-WX-0011, we found no indications that the APD 

was not adequately achieving the stated community policing goals of the grant.

The focus area for Grant Number 2017-UL-WX-0015 was on violent crime 

problems, specifically gun violence. The three primary goals in response to the 

focus area were to reduce the: (1) number of incidents, (2) seriousness of the 

incidents or the amount of harm, and (3) the number of offenders and repeat 

offenders. Additionally, the APD detailed the three most important external 

organizations that it would initiate or enhance a partnership with to develop 

responses to the focus area. In all, the APD stated that it would initiate or enhance 

a total of 10 partnerships.

For Grant Number 2017-UL-WX-0015, APD provided its list of active 

partnerships as of December 2019. We found that this list did not include three 

external organizations identified in the grant application as being the most 

important. We requested documentation regarding activity with these three 

external organizations or partnerships. However, the APD did not provide any 

documentation illustrating activity with these three partnerships. As the APD did 

not document any activity with these three partnerships that it identified as most 

important, we determined that it was not adhering to its community policing plan 

set forth in the CHP award application. Therefore, we recommend the COPS Office 

coordinate with the APD to ensure it initiates or enhances the partnerships as 

identified in the CHP grant application under Grant Number 2017-UL-WX-0015.

Required Progress Reports

Progress reports are used to track the agency’s progress towards 

implementing community policing strategies and collecting data to gauge the 

effectiveness of increasing the agency’s community policing capacity through COPS 

Office funding. As a result, the DOJ Grants Financial Guide requires that the 

funding recipient should ensure that valid and auditable source documentation is 

available to support all data collected for each performance measure specified in 

the program solicitation or award.

In order to verify the information contained in the progress reports, we 

selected a judgmental sample of 10 performance measures from the 2 most recent 

quarterly progress reports submitted for each grant for a total sample size of 30. 

We then traced the items to supporting documentation maintained by the APD.

Overall, we found that 13 of the 30 performance measures we sampled did 

not match the supporting documentation. Of these 13 performance measures, 

9 were inaccurate as the APD was tracking the positions of ineligible officers instead 

of the eligible new hires, 3 were due to inaccuracies in reporting crime data, and 

1 was due to not documenting partnership activity with community partners it 

identified as most important in the CHP grant application.
5

Based on our interviews with APD officials and our review of the APD's grant 

management policies and procedures, we determined that these policies and 

procedures could be improved. Specifically, according to a City of Arlington, Texas, 

grant compliance guide; the department must monitor its activities under federal 

awards to assure compliance with applicable federal requirements and that 

performance measures are being achieved. However, the guide does not require 

the departments to maintain documentation of grant program progress.

Therefore, we recommend that the COPS Office coordinate with the APD to 

develop and implement policies and procedures to ensure the APD reports accurate 

accomplishments in its progress reports and maintains documentation of grant 

program progress.

Retention Plan Requirement

According to the Award Owner’s Manual, the recipient is required to retain 

the officer positions awarded under the CHP grant and not the specific officers hired 

to fill the grant positions. If a position funded by the CHP grant becomes vacant 

during the retention period, the agency is required to take active and timely steps 

consistent with the agency’s hiring policies and procedures to fill the position with a 

new officer to complete the remainder of the 12-month retention period. 

Additionally, if a position becomes vacant during the grant or retention period, the 

agency must maintain records of the employment dates of any new officers hired to 

fill the position. Furthermore, at the conclusion of federal funding, agencies that 

fail to retain the sworn officer positions awarded under the CHP grant may be 

ineligible to receive future CHP grants for a period of 1 to 3 years.

According to the former Grant Coordinator, the APD must receive approval 

from the City of Arlington, Texas, before applying for CHP grants to ensure that 

local funding is budgeted to meet any retention requirements of the grants. In its 

grant applications, the APD indicated that it would use general funds to retain the 

15 additional officer positions awarded under each grant for a minimum of 

12 months at the conclusion of federal funding.

We then tested retention activity under Grant Number 2015-UL-WX-0026, 

which, according to the APD, had entered the 12-month retention period in 

December 2018.2 Therefore, the APD planned to complete the 12-month retention 

period in December 2019. However, we identified five CHP positions that were not 

backfilled with new hires as required, but were filled with seven locally-funded 

officers that were transferred to the grant. As such, these officers would not qualify 

as new-hires under the requirements of the CHP grants, and they would not count 

toward the APD meeting its retention requirements under Grant Number 

2015-UL-WX-0026.

We discussed these officers with APD and were provided an additional ledger

of eligible new hires for these five CHP officer positions. Based on our review, we 

2 As Grant Numbers 2016-UL-WX-0011 and 2017-UL-WX-0015 had not yet entered their 

retention periods, we did not examine retention period activities for these two grants.
6

determined that these officers were eligible under the grant. However, in order to 

meet retention requirements, all 15 positions would need to be retained after 

December 2019. Specifically, 10 positions would need to be filled through January 

2020, 3 positions through April 2020, and 2 positions through May 2020. Overall, 

as of September 2019, the APD was on track to meet the retention requirement.

Because of the issues identified above, we determined that the APD’s method 

of tracking officer retention could be improved. Therefore, we recommend the 

COPS Office coordinate with the APD to update its policies and procedures to ensure 

that, when a CHP position becomes vacant during the grant or retention period, the 

APD tracks new officers hired on or after the date the CHP positions were vacated in 

order to meet retention requirements.

Grant Financial Management

According to the DOJ Grants Financial Guide and the Award Owner's Manual, 

the grant recipient is required to establish and maintain adequate accounting 

systems and financial records to accurately account for funds awarded and 

disbursed to them. These records must include both federal funds and any local 

funds contributed to the project. Additionally, as required by the Uniform 

Administrative Requirements, Cost Principles, and Audit Requirements for Federal 

Awards; the grant recipient’s accounting system should be designed to provide 

reasonable assurance regarding the achievement of the following objectives for 

federal awards: (1) transactions are executed in compliance with all applicable 

federal statutes, regulations, and the award terms and conditions; and 

(2) transactions are properly recorded and accounted for in order to prepare 

reliable financial statements and federal reports.

To assess the APD’s financial management of the grants covered by this 

audit, we conducted interviews with financial staff, examined policy and procedures, 

and inspected grant documents to determine whether the APD adequately 

safeguards the grant funds we audited. We also performed testing in the areas that 

were relevant for the management of this grant, as discussed throughout this 

report. Finally, we reviewed the City of Arlington, Texas Single Audit Reports for 

fiscal years (FY) 2015 through 2018 to identify internal control weaknesses and 

significant non-compliance issues related to federal awards. We did not find 

significant deficiencies or material weaknesses in the Single Audit Reports related to 

grant administration.3

However, our review of grant expenditures identified significant weaknesses 

in the APD’s award financial management and adherence to base grant 

requirements. Specifically, we found that the APD did not adhere to allowable CHP 

hiring categories; did not adhere to the allowable amounts and rates of salaries and 

fringe as defined in the Financial Clearance Memorandum (FCM); did not use 

available controls to monitor costs in the general ledger; had excess drawdowns as 

APD tracked sergeants under Grant Number 2016-UL-WX-0011 instead of new, 

3 The APD is incorporated under the City of Arlington, Texas in the relevant Single Audit 

Reports.
7

additional officers; and did not accurately report required Federal Financial Reports

(FFRs).

Based on our review, we concluded that grant financial management related 

to officer type, use of award funds, budget management and control, drawdowns, 

and federal financial reports could be improved. We make additional 

recommendations in the other sections of this report to remedy these deficiencies.

Grant Expenditures

For Grant Numbers 2015-UL-WX-0026, 2016-UL-WX-0011, and 

2017-UL-WX-0015, the APD’s approved budgets included entry-level salaries and 

fringe benefits such as Medicare, health insurance, retirement, Worker’s 

Compensation, shift differential, and disability insurance. The APD was also

required to expend a minimum of 25 percent in local funds up to the full matching 

amount as defined in the FCM. Specifically, the planned local match was 

$1,734,938 for Grant Number 2015-UL-WX-0026, $1,798,606 for Grant Number 

2016-UL-WX-0011, and $2,045,629 for Grant Number 2017-UL-WX-0015. As the 

required match was a percentage of total project costs, we did not separately test 

matching transactions.

To determine whether costs charged to the awards were allowable, 

supported, and properly allocated in compliance with award requirements, we 

verified the officer types and tested a sample of transactions. Specifically, we 

judgmentally sampled five non-consecutive pay periods for each award. However, 

during the course of the audit, we found that the APD charged unallowable salaries 

and fringe benefits of sergeants and detectives to Grant Numbers 

2016-UL-WX-0011 and 2017-UL-WX-0015, respectively. After we informed the 

APD, APD officials identified new, additional officers that fulfilled the grant award 

requirements. Therefore, we sampled the salaries and fringe benefits of these 

positions as identified by the APD. Additionally, we found that the general ledgers

did not identify officers under the grants, and did not properly account for cost 

categories, which is further discussed under Budget Management and Control. 

Thus, we incorporated the payroll ledgers into our analysis of personnel and fringe 

costs.

Table 2

Sample of Grant Expenditures as of September 22, 2019

Award Number Payroll Ledger

Expenses(a)

Total Payroll

Dollars Sampled

Percent of

Dollars Sampled

2015-UL-WX-0026 $3,778,983 $258,292 6.8%

2016-UL-WX-0011 $3,708,607 $287,182 7.7%

2017-UL-WX-0015 $1,552,317 $259,885 16.7%

Total: $9,039,907 $805,359 8.9%

(a) We sampled payroll of new hires under Grant Numbers 2016-UL-WX-0011 and 

2017-UL-WX-0015.

Source: APD
8

We reviewed documentation, accounting records, and performed verification 

testing related to grant expenditures. Based on this testing, we identified $878,341

in unallowable costs related to personnel and associated fringe. The following 

sections describe the results of that testing.

Officer Type

According to the Award Owner's Manual, grant recipients are required to use 

CHP award funds for the specific hiring categories awarded. These full-time hiring 

categories are limited to: (1) new, additional officer positions; (2) the rehire of 

officers who were laid off; and (3) the rehire of officers scheduled to be laid off. 

Additionally, the Award Owner’s Manual stated that the positions must be in

addition to the recipient’s current funded level of sworn officer positions and that

the hire or rehire date must be on or after the official award start date as it appears 

on the recipient's award document. Further, if a position becomes vacant during 

the grant or retention period, the grant recipient must maintain records of the 

employment of any new officers hired to fill the position.

In each of the grant applications, the APD requested 15 new, additional 

officer positions and no other hiring categories were requested. Additionally, we did 

not identify any grant modifications to request a change in hiring category. 

Further, APD officials stated that there had been no layoffs of sworn officers 

between October 2014 and October 2019, and we did not identify any reductions in 

the total law enforcement operating budget through FY 2020. Therefore, the 

categories to rehire officers who were laid off and to rehire officers scheduled to be 

laid off were not applicable to the APD. The only CHP hiring category allowed under 

the grants was new, additional officer positions.

For Grant Number 2015-UL-WX-0026, we found that all initial officers hired 

met the condition of being a new, additional officer. However, as attrition occurred, 

seven officers in five positions did not meet the condition of being a new hire as

they were initially hired in locally-funded positions and were later transferred to the 

2015 CHP grant. On average, these officers were hired into locally funded positions 

7 months before they were transferred to the grant. Because the rehire categories 

were not applicable to the APD, we determined that these officers were not eligible 

under any CHP hiring category, indicating that the APD replaced local funds with 

federal funds. As a result, three positions were not filled with eligible officers that 

were hired after the position was vacated, and two positions were not filled with 

eligible officers for several months. Therefore, the APD incurred $562,358 in 

unallowable salaries and fringe for these ineligible officers.

According to City of Arlington, Texas policy, the APD was required to obtain 

approval from the Deputy City Manager (Finance Department) for significant 

deviations from the original grant concept. Additionally, before the grant 

applications were submitted to the granting agency, the department was required 

to prepare and submit staff reports for city council approval. For Grant Numbers 

2016-UL-WX-0011 and 2017-UL-WX-0015, the approved staff reports and grant 

applications indicated that the sergeants and detectives would perform the 
9

community policing activities, and the entry-level police officers would financially 

impact the awards.4

However, we found that Grant Number 2016-UL-WX-0011 was used to

partially fund the promotions of sergeants, and Grant Number 2017-UL-WX-0015 

was used to partially fund the promotions of detectives. Then an equal number of 

locally-funded entry-level officers were hired. Additionally, we found that all 

37 sergeants and detectives in the 30 positions under the grants were not hired on 

or after the award start date. On average, the APD hired the officers 12 years 

before the grants started. Therefore, the sergeants and detectives were not new, 

additional officers and, as the rehire categories were not applicable to the APD, 

these sergeants and detectives were not eligible under any CHP hiring category.

APD officials stated that they were meeting the requirements of the new-hire 

category as the APD consistently hired new officers and was meeting the 

non-supplanting requirement. Additionally, APD officials stated that they were 

advised by the COPS Office to put the new hire backfills in the general fund and to 

put the community policing officers, the sergeants and detectives, under the CHP

grants. However, the APD could not provide documentation of this advice from the 

COPS Office, and such advice would directly contradict CHP requirements. This 

error resulted in $5,193,441 of unallowable salaries and fringe benefits related to 

ineligible veteran officers under the two grants, specifically $3,619,215 under Grant 

Number 2016-UL-WX-0011 and $1,574,226 under Grant Number 

2017-UL-WX-0015 as of September 22, 2019.

Overall, we identified $5,755,799 in unallowable salaries and fringe for the 

3 grants related to 44 ineligible officers in 35 positions, as the APD replaced local 

funds that would, in the absence of federal aid, be made available for the award 

purposes as shown in Table 3.

Table 3

Summary of Ineligible Officers under the CHP Grants

Award Number

Officer

Positions

Awarded

Positions with

Ineligible

Officers

Number of

Ineligible

Officers

Unallowable Costs of

Ineligible Officers

2015-UL-WX-0026 15 5 7 $562,358

2016-UL-WX-0011 15 15 21 $3,619,215

2017-UL-WX-0015 15 15 16 $1,574,226

Total: 45 35 44 $5,755,799

Source: APD

After we notified APD officials, APD provided payroll ledgers of new hires who 

met the requirements of the CHP hiring categories, as these officers were hired 

after the award start date or after vacancies were created. As we did not identify 

4 According to the Award Owner’s Manual, the specific officers funded or an equal number of 

redeployed veteran officers must be used to initiate or enhance community policing activities. 

Additionally, these officers must implement the grant recipient’s approved community policing plan

described in the grant application.
10

indications of supplanting under the Non-Supplanting Requirement section, we 

performed testing on these eligible officers. This included 5 officers in 5 positions 

under Grant Number 2015-UL-WX-0026 and 15 officers in each of the 15 positions

under Grant Numbers 2016-UL-WX-0011 and 2017-UL-WX-0015.

We compared the new-hire payroll ledger information to the allowable cost 

categories of salaries and fringe as identified in the FCMs to compute allowable 

costs by cost category for each newly hired officer in each pay period.5 Since these 

costs would replace the unallowable costs we previously identified, we then 

compared the allowable costs for eligible officers to the unallowable costs for 

ineligible officers. We found that the allowable costs provided by the APD were less 

than the unallowable costs for ineligible officers charged to the awards and,

therefore, resulted in remaining unallowable costs, as shown in Table 4. For further 

details of our comparison by cost category, see Appendix 4.

Table 4

Unallowable Costs Regarding Officer Eligibility as of September 22, 20196

Award Number Costs of

Ineligible Officers

Costs of

Eligible Officers(a)

Remaining

Unallowable Costs

(Ineligible less Eligible Costs)

2015-UL-WX-0026 $562,358 $365,888 $196,469

2016-UL-WX-0011 $3,619,215 $3,145,814 $492,358

2017-UL-WX-0015 $1,574,226 $1,407,995 $167,693

Total: $5,755,799 $4,919,697 $856,520

(a) When comparing allowable costs by category to the unallowable costs by category, we identified

more allowable costs than what the APD charged to the awards including: $18,957 in compensatory 

time and worker’s comp under Grant Number 2016-UL-WX-0011, and $1,462 in worker’s comp and 

Medicare under Grant Number 2017-UL-WX-0015. We did not include these additional costs in the 

computation of remaining unallowable costs.

Source: APD

Overall, we identified $856,520 in remaining unallowable costs for the 

salaries and fringe of ineligible officers. The unallowable costs identified include 

both the federal share and local share. Therefore, we recommend the COPS Office 

remedy the federal portion of the $856,520 in unallowable costs for the remaining 

salaries and fringe of ineligible officers; specifically $196,469 under Grant Number 

5 Regarding eligible officers, the APD’s reconciliation of allowable salaries and fringe under 

Grant Number 2016-UL-WX-0011 totaled $3,186,941, and for Grant Number 2017-UL-WX-0015 

totaled $1,417,487 as of September 30, 2019. However, the APD did not provide a detailed 

breakdown of costs by cost category, employee, or pay period. Thus, the OIG relied on its 

reconciliation of allowable salaries and fringe for eligible officers under the grants through 

September 22, 2019.

6 Differences in the totals of this table are due to rounding. The sum of individual numbers 

prior to rounding may differ from the sum of the individual numbers after rounding.
11

2015-UL-WX-0026, $492,358 under Grant Number 2016-UL-WX-0011, and 

$167,693 under Grant Number 2017-UL-WX-0015.7 

Subsequent to the issuance of the draft report, the COPS Office and APD 

coordinated and the COPS Office determined the federal portion of the total project 

costs related to the remaining unallowable salaries and fringe benefits of ineligible 

officers charged to the grants. For Grant Number 2015-UL-WX-0026 the federal 

share was $102,164 that represents the 52 percent federal share that was charged 

to the grant. For Grant Number 2016-UL-WX-0011, the net federal share was

$234,035 that represents $251,103 or the 51 percent federal share that was 

charged to the grant less an offset of $17,068 in funds not drawn down as of 

May 3, 2020. Lastly for Grant Number 2017-UL-WX-0015, the net federal share 

was $0 that represents $80,493 or the 48 percent federal share that was charged 

to the grant less an offset of $227,413 in funds not drawn down as of May 3, 2020. 

As such the aggregate amount that was reimbursed to the DOJ for this 

recommendation was $336,199. Additionally, the COPS Office provided evidence 

that APD repaid these funds to the DOJ. As a result, we consider these unallowable 

costs totaling $856,520 to be remedied.

Additionally, we recommend the COPS Office coordinate with the APD to 

develop and implement policies and procedures to ensure officers charged to the 

awards are allowable under the CHP hiring categories.

Personnel and Fringe Costs

According to the Award Owner’s Manual, the grant recipient may only be 

reimbursed for the approved cost categories that are documented within the FCM, 

up to the amounts specified in the FCM. Additionally, the grant recipient may not 

use CHP funds for any costs that are not identified as allowable in the FCM. 

Furthermore, any additional costs above the approved entry-level salaries and 

fringe benefits are the responsibility of the grantee agency.

For Grant Number 2015-UL-WX-0026, we found that the personnel and 

fringe costs charged to the grants were supported, computed correctly, and 

properly authorized. However, from our judgmental sample, we identified $21,821

in unallowable salaries and associated fringe benefits that were in excess of the 

approved entry-level rates in the FCM and should have not been allocated to Grant 

Number 2015-UL-WX-0026, for either the federal or local share. Therefore, we 

recommend the COPS Office remedy the federal portion of the $21,821 in 

unallowable salaries and fringe benefits that were in excess of the approved 

entry-level rate in the FCM.7 Additionally, we recommend the COPS Office 

coordinate with the APD to review salary and fringe benefits charged to Grant 

7 The OIG did not assign the federal and local shares to the unallowable costs as the 

allocations may fluctuate during the award periods. Additionally, we did not identify any issues with 

the APD meeting the 25 percent minimum match requirement. See Matching Costs for further details. 

Further, prior to the issuance of this final report, the COPS Office determined the federal portion of the 

unallowable total project costs, and the APD repaid these funds to the DOJ. As such, these actions are 

sufficient to remedy the unallowable cost, as explained in the following paragraphs. 
12

Number 2015-UL-WX-0026 to ensure they are in accordance with the approved 

FCM.

Subsequent to the issuance of the draft report, the COPS Office and APD 

coordinated and the COPS Office determined the federal portion of the total project 

costs related to unallowable salaries and fringe benefits in excess of the approved 

entry-level rate in the FCM. For Grant Number 2015-UL-WX-0026, this was

$11,346 that represents the 52 percent federal share that was charged to the 

grant. Additionally, the COPS Office provided evidence that APD repaid these funds 

to the DOJ. As a result, we consider these unallowable costs of $21,821 to be 

remedied.

Further, we reviewed APD's policies and procedures regarding the allocation 

of time and effort to the grants. According to a City of Arlington, Texas grant 

compliance guide, the City's financial management systems, including records 

documenting compliance with Federal Statutes, regulations, and the terms and 

conditions of the federal award, must be sufficient to permit the: (1) preparation of 

reports required by general and program-specific terms and conditions, and 

(2) tracing of funds to a level of expenditures adequate to establish that such funds 

have been used according to the federal statutes, regulations, and the terms and 

conditions of the federal award.

For Grant Number 2015-UL-WX-0026, the APD provided documentation 

evidencing that unallowable salary and fringe benefit categories were removed from 

the general ledger on a monthly basis. Additionally, the APD removed the 

unallowable associated fringe benefits. However, we found that the new-hire 

payroll charged to the grant project was consistently higher than approved in the 

FCM, and the monthly adjustments did not review salary rates. Therefore, we 

determined that the APD was not reviewing officer salary according to the amounts 

approved in the FCM to prevent the allocation of costs above the approved 

entry-level salaries and fringe benefits to the grant. As such, we determined that 

the APD's policies and procedures could be improved. We recommend the COPS 

Office coordinate with the APD to enhance policies and procedures to review costs 

charged to DOJ grants, ensuring costs are allowable and in accordance with award 

terms and conditions.

As stated under Officer Type, we found that the entirety of personnel and 

fringe benefits costs recorded in the APD’s accounting system under Grant Numbers 

2016-UL-WX-0011 and 2017-UL-WX-0015 were related to ineligible officers. After 

we notified APD officials, APD provided payroll ledgers of new hires who met the 

requirements of the CHP hiring categories. Therefore, we tested a sample of 

personnel and fringe benefit costs for these new, additional officers. Although we 

found that the entry-level rates for the new, additional officers and employee 

insurance were consistently over the approved rates in the FCM, and we identified 

salary and fringe benefit categories that were not in the approved FCM, we did not 

question these costs as they were captured in our analysis under Officer Type. 

Additionally, we found that the personnel and fringe benefits costs of the new, 

additional officers were supported.
13

Matching Costs

Matching Costs are the non-federal recipient’s share of the total project costs

and, for CHP grants, must be paid with state, local, or other non-COPS Office funds 

and may not be from any funds previously budgeted for law enforcement purposes. 

According to the Award Owner's Manual, the CHP grants will cover up to 75 percent 

of the approved entry level salary and fringe benefits of each CHP position over the 

36 month grant period with a minimum 25 percent local cash match requirement 

and a maximum federal share of $125,000 per officer position. Through our 

testing, we found that the APD met and exceeded the local match requirement of 

25 percent for all three CHP grants. However, as previously discussed, portions of 

the local match were related to ineligible officers whose salary and fringe benefits 

were charged to the grants. We discuss this in more detail above in Officer Type.

Budget Management and Control

According to the DOJ Grants Financial Guide, the recipient is responsible for 

establishing and maintaining an adequate accounting system, which includes the 

ability to compare actual expenditures or outlays with budgeted amounts for each 

award. Additionally, the grant recipient must submit a formal budget modification if 

the reallocation of funding between budget categories exceeds or is expected to 

exceed 10 percent of the total award amount. Additionally, according to the Award 

Owner's Manual, the grant recipient should have financial internal controls in place 

to monitor the use of CHP funding to ensure that its use is consistent with grant 

terms and conditions.

Similar to the Uniform Administrative Requirements, Cost Principles, and 

Audit Requirements for Federal Awards; City of Arlington, Texas guidance indicated 

that the departments are responsible for administering grant funded programs, and 

that the departments’ financial management system must: (1) permit the tracing 

of funds to a level of expenditures adequate to establish that funds have been used 

according to federal statutes, regulations, and terms and conditions of the award; 

and (2) provide comparison of expenditures with budget amounts for each federal 

award.

We found that the APD’s general ledgers did not accurately record account 

category balances. For instance, salaries from operations were significantly 

overstated while fringe benefit accounts generally had large negative balances. 

Table 5 illustrates this deficiency in the general ledgers.
14

Table 5

Summary of General Ledger Account Balances as of September 22, 20198

Account Grant Number

2015-UL-WX-0026

Grant Number

2016-UL-WX-0011

Grant Number

2017-UL-WX-0015

Salaries

Operations $3,784,352 $4,162,945 $1,786,069

Compensatory Time (23,001) (42,673) (15,234)

Overtime (71,341) (66,315) (45,831)

Education Incentive (46,261) (52,670) (22,419)

Other Salaries(a) (16,862) (150) (18,253)

Fringe Benefits

Worker’s Comp (8,775) (19,939) (5,064)

Employee Retirement (24,270) (221,241) (69,443)

Employee Insurance 561 (5,220) (127)

Medicare (2,383) (20,287) (5,429)

Other Fringe Benefits(b) (3,642) (115,235) (30,042)

Total: $3,588,377 $3,619,215 $1,574,226

(a) Other salaries includes reversals for terminal pay, officer training, and investigator pay.

(b) Other fringe benefits includes reversals for Thrift plan, shift differential, disability insurance, 

longevity/stability pay, petition, and phone allowance.

Source: APD’s general ledger

As presented, the general ledgers were only useful for aggregate grant costs. 

The account totals did not correspond to actual costs for any cost category. We 

found that the APD documented the actual cost categories in separate worksheets 

by month and quarter. We reviewed numerous detailed monthly and quarterly 

reports maintained by the former Grant Coordinator, used to identify and remove 

unallowable cost categories or to reduce the amounts of sergeant and detective 

salaries and fringe benefits allocated to the grants. However, this cost category 

information was not documented cumulatively, and the APD did not compare or 

review the cumulative actual and budgeted expenditures by cost category.

Regarding the general ledger, we found that the accounting system allowed 

for budget categories to be listed in detail. However, the APD did not use this

feature to compare actual and budgeted expenditures by cost category in order to

verify that the APD was only reimbursed for approved cost categories and amounts 

specified in the FCM. Therefore, we recommend the COPS Office coordinate with 

the APD to ensure its accounting system accurately accounts for the actual and 

budgeted expenditures by cost category for DOJ grants.

According to the Award Owner’s Manual, the grant recipient may only be 

reimbursed for the approved cost categories that are documented within the FCM 

8 We categorized the accounts according to the approved FCMs for each grant as applicable. 

Additionally, we identified adjustments to worker’s comp and petition that were improperly 

categorized as salaries-operations and classified them under the appropriate account above. Note 

that differences in the totals of this table are due to rounding. The sum of individual numbers prior to 

rounding may differ from the sum of the individual numbers after rounding.
15

up to the amounts specified in the FCM. Additionally, any additional costs above 

the approved entry-level salaries and fringe benefits are the responsibility of the 

recipient agency.

Due to the limitations of the general ledgers, we reconciled the grant general 

ledgers against the original payroll ledgers that included ineligible officers to 

determine actual costs by cost category for each grant. We then compared these 

cost categories from the general ledgers to the approved cost categories in the FCM 

to determine whether the APD charged costs to the awards in excess of the FCMs. 

We identified several instances where the APD was over the amount specified in the 

approved FCM and included costs that were not identified as allowable in the 

approved FCM.

Table 6

Costs over the Approved FCMs as of September 22, 20199

Account Grant Number

2015-UL-WX-0026

Grant Number

2016-UL-WX-0011

Grant Number

2017-UL-WX-0015

Salaries

Operations $91,396 $0 $0

Overtime 0 1,030 5,218

Education Incentive 0 746 762

Investigator Pay 0 0 346

Fringe Benefits

Employee Retirement 20,680 18,757 0

Employee Insurance 6,767 0 0

Medicare 255 0 0

Other Fringe Costs

Shift Differential 0 51,976 0

Longevity/Stability Pay 0 114 89

Petition 61 1,441 227

Total: $119,159 $74,063 $6,642

Source: COPS Office and the APD

In all we identified $199,864 in salaries and fringe benefits that were over 

the amounts specified or were not in the approved FCMs, which would be the 

responsibility of the recipient agency. Ultimately, APD replaced the salaries and 

fringe benefits of ineligible officers with allowable new hires, therefore we did not 

question these costs. However, through our review of the APD’s budget 

management, we determined that the APD’s review of cumulative grant 

expenditures could be improved. Therefore, we recommend the COPS Office 

coordinate with the APD to develop and implement policies and procedures to 

periodically review cumulative actual and budgeted grant expenditures by cost 

category to ensure compliance with the approved FCM.

9 The table includes the unallowable salaries and fringe benefits of sergeants and detectives 

under Grant Numbers 2016-UL-WX-0011 and 2017-UL-WX-0015. Also, differences in the totals of this 

table are due to rounding. The sum of individual numbers prior to rounding may differ from the sum 

of the individual numbers after rounding.
16

Non-Supplanting Requirement

The three CHP grants had non-supplanting requirements. The special 

conditions state that grant recipients must use CHP funds to supplement, and not 

supplant state or local funds that are already committed or otherwise would have 

been committed for award purposes during the award period. Additionally, the 

Award Owner’s Manual requires that grant recipients receiving CHP grant funds to 

hire a new officer position, including filling an existing officer vacancy that is no 

longer funded in the recipient’s local budget, must hire the additional position on or 

after the official grant award start date, above its current budgeted (funded) level 

of sworn officer positions. In addition, grant recipients receiving CHP funds to 

rehire an officer laid off as a result of state or local budget reductions, must rehire 

the officer on or after the official grant award start date. Further, grant recipients

receiving CHP grant funds to rehire an officer who was, at the time of grant 

application, scheduled to be laid off on a specific future date as a result of state or

local budget reductions, must continue to fund the officer with its own funds 

through the grant award start date until the date of the scheduled layoff.

We assessed the APD’s on-board officer strength to determine if it increased 

its sworn officer strength by the number of officer positions funded with the three 

CHP grants. The APD reported 631 officers in its 2015 CHP Application, which we 

used as the baseline figure to compute the target officer level. Figure 1 compares 

the target officer level to the actual officer level at the APD from September 2015, 

the start date for Grant Number 2015-UL-WX-0026, through September 2019.
17

Figure 1

Target Officer Level vs. Actual Officer Level

From September 2015 through September 2019

(a) The target officer level includes a baseline of 631 sworn officers plus any dedicated COPS Office 

funded officer positions in the period. This target officer level also accounts for the COPS Office 

retention requirement that ensures the increased officer staffing level continues with local funds for a 

minimum of 12 months after federal funding ends. For Grant Number 2015-UL-WX-0026, the

retention period began in December 2018. Additionally, the target officer level has been reduced by 

5 percent to account for vacancy rates.

Source: COPS Office and the APD

While we found that the APD did not meet the condition to use CHP grant 

funds to hire new officers for 35 officer positions under the three CHP grants, our 

analysis shows that APD met or exceeded the target officer level for FY 2016

through 2019.10 As a result, we did not identify any indications of supplanting 

under the three CHP grants awarded to the APD.

Drawdowns

According to the DOJ Grants Financial Guide and the Award Owner’s Manual, 

an adequate accounting system should be established to maintain documentation to 

support all receipts of federal funds. If, at the end of the grant award, recipients 

have drawn down funds in excess of federal expenditures, unused funds must be 

10 APD’s fiscal year is the same as the City of Arlington, Texas and goes from October 1 

through September 30.

580

600

620

640

660

680

700

Sep-2015

Nov-2015

Jan-2016

Mar-2016

May-2016

Jul-2016

Sep-2016

Nov-2016

Jan-2017

Mar-2017

May-2017

Jul-2017

Sep-2017

Nov-2017

Jan-2018

Mar-2018

May-2018

Jul-2018

Sep-2018

Nov-2018

Jan-2019

Mar-2019

May-2019

Jul-2019

Sep-2019

Number of Officers

Months

Actual Officer Level Target Officer Level (a)
18

returned to the awarding agency. According to APD officials, drawdowns are done 

quarterly and the accounting aide is responsible for calculating quarterly 

expenditures and the reimbursement and matching percentages. While this was 

discussed verbally, we did not receive any written procedures that addressed 

internal controls related to drawing down funds. Further, the Award Owner's 

Manual states that the grant recipient should ensure that it has financial internal 

controls in place to monitor the use of CHP funding and ensure that its use is 

consistent with the grant terms and conditions. Good practices in this area include 

written accounting practices and an accounting system that tracks all drawdowns 

and grant expenditures. Due to the lack of written procedures at the APD, we 

recommend the COPS office coordinate with the APD to develop written procedures 

that address internal controls related to drawing down funds.

To assess whether the APD managed grant receipts in accordance with 

federal requirements, we compared the total amount reimbursed to the total 

expenditures in the accounting records. As of September 2019, the APD had drawn 

down a total of $4,104,142. Based on the original accounting records provided by 

the APD that included ineligible officers, we found the APD’s process for requesting 

drawdowns did not result in excess cash on hand.

However, as discussed previously, after identifying that the APD filled 

30 officer positions under Grant Numbers 2016-UL-WX-0011 and 

2017-UL-WX-0015 with ineligible officers, we requested that APD identify and 

reconcile grant expenditures with newly hired officers that would have met the 

award conditions. After receiving the reconciliation, we compared the APD’s 

updated expenditures to the total amount reimbursed. Table 7 below details the 

results of our comparison.

Table 7

Total Drawdowns Compared to Expenditures as of September 201911

Award Number

Federal

Award 

Amount

Total 

Drawdowns

Original Federal 

Expenditures

provided in

October 2019

APD’s Revised

Federal 

Expenditures

provided in

December 2019

Drawdowns Less

Revised Federal 

Expenditures

2015-UL-WX-0026 $1,875,000 $1,863,803 $1,863,803 $1,863,803 $0

2016-UL-WX-0011 $1,875,000 $1,660,678 $1,832,064 $1,650,219 $10,460

2017-UL-WX-0015 $1,875,000 $579,660 $778,181 $810,217 $(230,556)

TOTAL $5,625,000 $4,104,142 $4,474,048 $4,324,238 $(220,097)

Source: COPS Office and the APD

For Grant Number 2016-UL-WX-0011, we found that drawdowns exceeded 

expenditures by $10,460 as of September 2019. This occurred because the 

updated federal expenditures for new hires that met the award conditions were less 

than the total drawdowns that were requested for ineligible officers. Therefore, we 

11 Differences in the totals of this table are due to rounding. The sum of individual numbers 

prior to rounding may differ from the sum of the individual numbers after rounding.
19

recommend the COPS Office coordinate with the APD to compute drawdowns 

according to the eligible officers under Grant Number 2016-UL-WX-0011.

Federal Financial Reports

According to the Award Owner’s Manual, the quarterly FFR reflects the actual 

cumulative federal expenditures incurred during the funding period and the 

remaining unobligated balance of federal funds. Additionally, grant recipients are 

required to report the amount of local match contributed on the quarterly FFR. To 

determine whether the APD submitted accurate FFRs, we compared the four most 

recent reports to the APD’s accounting records for each grant.12 For 4 of the 12 

FFRs we reviewed, the FFRs did not match APD’s accounting records, as shown in 

Table 8.

Table 8

FFR Accuracy of Cumulative Expenses13

Period

End

Date

Federal 

Expenses 

in FFR

Federal 

Expenses 

in GL

Expenses 

in FFR

less GL

Local 

Expenses 

in FFR

Local 

Expenses 

in GL

Expenses 

in FFR

less GL

Total 

Difference

Grant Number 2016-UL-WX-0011

12/31/2018 $1,292,823 $1,319,454 $(26,631) $1,240,138 $1,265,683 $(25,546) $(52,176)

06/30/2019 $1,660,678 $1,689,667 $(28,989) $1,593,002 $1,620,809 $(27,808) $(56,796)

Grant Number 2017-UL-WX-0015

12/31/2018 $253,251 $275,480 $(22,229) $276,341 $300,597 $(24,256) $(46,485)

06/30/2019 $579,660 $605,661 $(26,000) $632,511 $660,882 $(28,371) $(54,371)

Source: COPS Office and the APD

Specifically, for quarter ending December 31, 2018, the APD indicated on 

monthly reports that costs for pay period ending December 30, 2018 would be 

claimed in the next quarter. Also, for quarter ending June 30, 2019, the APD 

indicated on monthly reports that costs for pay period ending June 30, 2019 would 

be claimed in the next quarter. As a result, salaries and fringe benefits incurred in 

the reporting period were inaccurately claimed in a subsequent quarter.

Therefore, the APD was not accurately reporting expenses incurred, and we 

determined that the APD's financial reporting could be improved. We recommend

the COPS Office coordinate with the APD to update its federal financial reporting 

procedures to ensure expenditures are reported accurately.

Application Statistics

According to guidance in the CHP grant applications, the APD was required to 

certify the accuracy of the responses in the grant applications. To determine 

whether the APD submitted accurate grant applications, we judgmentally sampled 

40 quantifiable application statistics from Grant Numbers 2015-UL-WX-0026 and 

12 The FFRs did not identify any program income for any grant.

13 Differences in the totals of this table are due to rounding. The sum of individual numbers 

prior to rounding may differ from the sum of the individual numbers after rounding.
20

2016-UL-WX-0011 and 39 quantifiable application statistics from Grant Number 

2017-UL-WX-0015 for a total of 119 statistics. We then compared the application 

statistics to external documentation.

Through our review, we determined the applications were complete. 

However, we found that 3 of the 119 application statistics we tested did not

materially match external documentation. Because the inaccuracies were not 

pervasive, we do not offer a recommendation.
21

CONCLUSION AND RECOMMENDATIONS

As a result of our audit testing, we concluded that the APD demonstrated 

adequate achievement of the grant’s stated community policing goals under Grant 

Number 2015-UL-WX-0026 and demonstrated adequate progress towards achieving 

the grants’ stated community policing goals under Grant Numbers 2016-UL-WX-0011

and 2017-UL-WX-0015, except that the APD did not provide documentation of

activity with what it considered its three most important external organizations or 

partners under Grant Number 2017-UL-WX-0015. Additionally, we did not identify 

significant issues regarding the APD’s required match and application statistics. 

However, we found that the APD did not comply with essential award conditions 

related officer type, use of funds, and financial accounting. Further, we determined 

that the APD’s procedures regarding progress reports, retention, budget 

management and control, drawdowns, and financial reporting could be improved. 

As a result of these deficiencies, we identified $878,341 in unallowable costs, and 

we provide 13 recommendations to the COPS Office to address these deficiencies.

We recommend that the COPS Office:

1. Coordinate with the APD to ensure it initiates or enhances the partnerships 

as identified in the CHP grant application for Grant Number 

2017-UL-WX-0015.

2. Coordinate with the APD to develop and implement policies and procedures 

to ensure the APD reports accurate accomplishments in its progress reports

and maintains documentation of grant program progress.

3. Coordinate with the APD to update its policies and procedures to ensure that, 

when a CHP position becomes vacant during the grant or retention period, 

the APD tracks new officers hired on or after the date the CHP positions were 

vacated in order to meet retention requirements.

4. Remedy the federal portion of the $856,520 in unallowable costs for the 

remaining salaries and fringe of ineligible officers, specifically:

a. $196,469 under Grant Number 2015-UL-WX-0026,

b. $492,358 under Grant Number 2016-UL-WX-0011, and

c. $167,693 under Grant Number 2017-UL-WX-0015.14

5. Coordinate with the APD to develop and implement policies and procedures 

regarding allowable CHP hiring categories.

6. Remedy the federal portion of the $21,821 in unallowable salaries and fringe 

benefits that were in excess of the approved entry-level rate in the FCM

under Grant Number 2015-UL-WX-0026.14

14 As discussed previously, the COPS Office determined the federal portion of the unallowable 

total project costs, and the APD returned the federal portion to the DOJ.
22

7. Coordinate with the APD to review salary and fringe benefits charged to 

Grant Number 2015-UL-WX-0026 to ensure they are in accordance with the 

approved FCM.

8. Coordinate with the APD to enhance policies and procedures to review costs 

charged to DOJ grants, ensuring costs are allowable and in accordance with 

award terms and conditions.

9. Coordinate with the APD to ensure its accounting system accurately accounts 

for the actual and budgeted expenditures by cost category for DOJ grants.

10. Coordinate with the APD to develop and implement policies and procedures 

to periodically review cumulative actual and budgeted grant expenditures by 

cost category to ensure compliance with the approved FCM.

11. Coordinate with the APD to develop written procedures that address internal 

controls related to drawing down funds.

12. Coordinate with the APD to compute drawdowns according to the eligible 

officers under Grant Number 2016-UL-WX-0011.

13. Coordinate with the APD to update its federal financial reporting procedures

to ensure expenditures are reported accurately.
23

APPENDIX 1

OBJECTIVES, SCOPE, AND METHODOLOGY

Objectives

The objectives of this audit were to determine whether costs claimed under 

the grants were allowable, supported, and in accordance with applicable laws, 

regulations, guidelines, and terms and conditions of the awards; and to determine 

whether the grantee demonstrated adequate progress towards achieving the 

program goals and objectives. To accomplish these objectives, we assessed

performance in the following areas of grant management: program performance,

financial management, expenditures, budget management and control, drawdowns, 

federal financial reports, application statistics, and retention plan.

Scope and Methodology

We conducted this performance audit 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.

This was an audit of Office of Community Oriented Policing Services (COPS 

Office) grants awarded to the Arlington Police Department (APD) under the COPS 

Office Hiring Program, specifically $1,875,000 in federal funds and required local 

cash match of $1,734,938 under Grant Number 2015-UL-WX-0026, $1,875,000 in 

federal funds and required local cash match of $1,798,606 under Grant Number 

2016-UL-WX-0011, and $1,875,000 in federal funds and required local cash match 

of $2,045,629 under Grant Number 2017-UL-WX-0015.15 As of September 5, 

2019, the APD had drawn down $4,104,142 of the total grant funds awarded. Our 

audit concentrated on, but was not limited to September 1, 2015, the award start 

date for Grant Number 2015-UL-WX-0026, through March 3, 2020, the last day of 

our audit work. Grant Number 2015-UL-WX-0026 was closed out on April 8, 2019, 

and $11,197 was deobligated from the federal share.

To accomplish our objectives, we tested compliance with what we consider to 

be the most important conditions of the APD’s activities related to the audited 

grants. We performed sample-based audit testing for grant expenditures including 

payroll and fringe benefit charges, financial reports, and progress reports. In this 

effort, we employed a judgmental sampling design to obtain broad exposure to 

numerous facets of the grants reviewed. This non-statistical sample design did not 

allow projection of the test results to the universe from which the samples were 

selected. The DOJ Grants Financial Guide; the 2015, 2016, and 2017 CHP Award 

15 According to the award documents, the total estimated local share of the three CHP grants 

was $5,579,173. However, the required minimum local share was significantly less at 25 percent, or 

$1,875,000 for all three CHP grants.
24

Owner’s Manuals; and the award documents contain the primary criteria we applied 

during the audit.

During our audit, we obtained information from the COPS Office, the COPS 

Office’s NexGen System as well as the APD’s accounting system specific to the 

management of DOJ funds during the audit period. We did not test the reliability of 

those systems as a whole, therefore any findings identified involving information 

from those systems were verified with documentation from other sources.

Internal Controls

In this audit, we performed testing of internal controls significant within the 

context of our audit objectives. We did not evaluate the internal controls of the 

APD to provide assurance on its internal control structure as a whole. APD 

management is responsible for the establishment and maintenance of internal 

controls in accordance with Uniform Administrative Requirements, Cost Principles, 

and Audit Requirements for Federal Awards, 2 C.F.R. §200. Because we do not 

express an opinion on the APD’s internal control structure as a whole, we offer this 

statement solely for the information and use of the APD and COPS Office.16

In planning and performing our audit, we identified the following internal 

control components and underlying internal control principles as significant to the 

audit objectives:

We assessed the operating effectiveness of these internal controls and 

identified deficiencies that we believe could affect the APD’s ability to effectively 

operate, correctly state financial and performance information, and ensure 

compliance with laws and regulations. The internal control deficiencies we found 

are discussed in the Audit Results section of this report. However, because our 

review was limited to these internal control components and underlying principles, 

16 This restriction is not intended to limit the distribution of this report, which is a matter of 

public record.

Internal Control Components & Principles Significant to the Audit Objectives

Control Activity Principles

Management should design control activities to achieve objectives and 

respond to risks.

Management should design the entity’s information system and related 

control activities to achieve objectives and respond to risks.

Management should implement control activities through policies.

Information & Communication Principles

Management should use quality information to achieve the entity’s 

objectives.
25

it may not have disclosed all internal control deficiencies that may have existed at 

the time of this audit.
26

APPENDIX 2

SCHEDULE OF DOLLAR-RELATED FINDINGS

Description Amount Page

Questioned Costs17

Remaining unallowable personnel and fringe for ineligible 

officers

Grant Number 2015-UL-WX-0026 $196,469 10

Grant Number 2016-UL-WX-0011 492,358 10

Grant Number 2017-UL-WX-0015 167,693 10

Personnel and fringe over the FCM rates, 

Grant Number 2015-UL-WX-0026 21,821 11

Total Unallowable Costs $878,341

Less Remedied Costs18 ($878,341)

Net Questioned Costs $0

17 Questioned Costs are expenditures that do not comply with legal, regulatory, or 

contractual requirements; are not supported by adequate documentation at the time of the audit; or 

are unnecessary or unreasonable. Questioned costs may be remedied by offset, waiver, recovery of 

funds, the provision of supporting documentation, or contract ratification, where appropriate.

18 Prior to the issuance of this final report, the COPS Office determined the federal portion of 

the unallowable total project costs, and the APD returned the federal portion to the DOJ.
27

APPENDIX 3

ADDITIONAL TABLES AND FIGURES

Table 1

Reconciled General Ledger Account Balances as of September 22, 201919

Account Grant Number

2015-UL-WX-0026

Grant Number

2016-UL-WX-0011

Grant Number

2017-UL-WX-0015

Salaries

Operations $2,655,406 $2,600,286 $1,129,442

Compensatory Time 0 2,237 1,118

Overtime 0 1,030 5,218

Education Incentive 0 746 762

Investigator Pay 0 0 346

Fringe Benefits

Worker’s Comp 29,691 23,906 7,140

Employee Retirement 421,180 426,547 183,155

Employee Insurance 352,367 349,727 153,705

Medicare 37,433 34,989 15,392

Other Fringe Costs

Thrift Plan 45,460 69,699 30,463

Shift Differential 40,961 102,976 44,763

Disability Inc Plan 5,819 5,519 2,407

Longevity/Stability Pay 0 114 89

Petition 61 1,441 227

Total: $3,588,377 $3,619,215 $1,574,226

Source: APD’s General and Payroll Ledgers

19 Differences in the totals of this table are due to rounding. The sum of individual numbers 

prior to rounding may differ from the sum of the individual numbers after rounding. This table 

includes the unallowable salaries and fringe of sergeants and detectives under Grant Numbers 

2016-UL-WX-0011 and 2017-UL-WX-0015. Additionally, we identified adjustments to worker’s comp 

and petition under Grant Number 2015-UL-WX-0026 that were improperly categorized as salariesoperations and classified them under the appropriate account above.
28

Table 2

Unallowable Costs Regarding Officer Eligibility under

Grant Number 2015-UL-WX-002620

Account Costs for

Ineligible Officers

Costs for

Eligible Officers

Remaining

Unallowable Costs

Salaries

Operations $416,488 $294,969 $121,519

Fringe Benefits

Worker’s Comp 5,320 3,816 1,505

Employee Retirement 66,204 45,905 20,299

Employee Insurance 55,896 14,143 41,753

Medicare 5,763 4,277 1,486

Other Fringe Costs

Thrift Plan 6,080 1,968 4,111

Shift Differential 5,711 131 5,580

Disability Inc Plan 896 678 218

Total: $562,358 $365,888 $196,469

Source: APD’s General and Payroll Ledgers

Table 3

Unallowable Costs Regarding Officer Eligibility under

Grant Number 2016-UL-WX-0011 as of September 22, 201921

Account Costs for

Ineligible Officers

Costs for

Eligible Officers

Remaining

Unallowable Costs

Salaries

Operations $2,600,286 $2,370,403 $229,882

Compensatory Time 2,237 17,667 0

Overtime 1,030 0 1,030

Education Incentive 746 0 746

Fringe Benefits

Worker’s Comp 23,906 27,433 0

Employee Retirement 426,547 363,464 63,082

Employee Insurance 349,727 287,724 62,003

Medicare 34,989 34,627 362

Other Fringe Costs

Thrift Plan 69,699 38,065 31,634

Shift Differential 102,976 1,177 101,799

Disability Inc Plan 5,519 5,253 266

Longevity/Stability Pay 114 0 114

Petition 1,441 0 1,441

Total: $3,619,215 $3,145,814 $492,358

Source: APD’s General and Payroll Ledgers

20 Differences in the totals of this table are due to rounding.

21 Differences in the totals of this table are due to rounding. We identified additional 

allowable costs including $15,430 in compensatory time and $3,527 in worker’s comp under Grant 

Number 2016-UL-WX-0011.
29

Table 4

Unallowable Costs Regarding Officer Eligibility under

Grant Number 2017-UL-WX-0015 as of September 22, 201922

Account Costs for

Ineligible Officers

Costs for

Eligible Officers

Remaining

Unallowable Costs

Salaries

Operations $1,129,442 $1,063,976 $65,466

Compensatory Time 1,118 1,084 33

Overtime 5,218 0 5,218

Education Incentive 762 0 762

Investigator Pay 346 0 346

Fringe Benefits

Worker’s Comp 7,140 8,550 0

Employee Retirement 183,155 167,932 15,222

Employee Insurance 153,705 125,404 28,301

Medicare 15,392 15,443 0

Other Fringe Costs

Thrift Plan 30,463 17,292 13,172

Shift Differential 44,763 6,005 38,758

Disability Inc Plan 2,407 2,309 99

Longevity/Stability Pay 89 0 89

Petition 227 0 227

Total: $1,574,226 $1,407,995 $167,693

Source: APD’s General and Payroll Ledgers

22 Differences in the totals of this table are due to rounding. We identified additional 

allowable costs including $1,410 in worker’s comp and $52 in Medicare under Grant Number 

2017-UL-WX-0015.
30

APPENDIX 4

ARLINGTON POLICE DEPARTMENT 

RESPONSE TO THE DRAFT AUDIT REPORT23

23 Attachments referenced in the grantee’s response were not included in this final report.
31
32
33
34
35
36
37

APPENDIX 5

OFFICE OF COMMUNITY ORIENTED POLICING SERVICES 

RESPONSE TO THE DRAFT AUDIT REPORT
38
39
40
41
42
43
44
45
46
47
48

APPENDIX 6

OFFICE OF THE INSPECTOR GENERAL ANALYSIS AND

SUMMARY OF ACTIONS NECESSARY TO CLOSE THE REPORT

The OIG provided a draft of this audit report to the Arlington Police 

Department (APD) and the Office of Community Oriented Policing Services (COPS 

Office) for review and official comment. The APD’s response is incorporated in 

Appendix 4, and the COPS Office’s response is incorporated in Appendix 5 of this 

final report. In response to our draft report, the COPS Office concurred with our 

recommendations and, as a result, the status of the audit report is resolved. In its 

response, the APD generally concurred with our recommendations. Based on the 

responses, Recommendations 1 through 8, and 10 through 13 are closed.

Recommendation 9 remains resolved. The following provides the OIG analysis of 

the responses and summary of actions necessary to close the report.

Recommendations for the COPS Office:

1. Coordinate with the APD to ensure it initiates or enhances the 

partnerships as identified in the CHP grant application for Grant 

Number 2017-UL-WX-0015.

Closed. The COPS Office concurred with our recommendation and stated 

that the APD provided copies of memoranda addressing the APD Business 

Resource Manager that outlined community policing efforts with the 

partnerships identified in the CHP grant application for Grant Number 

2017-UL-WX-0015. Based on these memoranda, the COPS Office requested

closure of the recommendation.

The APD concurred with our recommendation and stated in its response that 

it continually initiates and enhances its community policing partnerships as 

part of its overall community policing strategy. Regarding the additional 

documentation needed to support the progress reports for these specific 

partnerships in the recommendation, the APD collaborated with reporting 

offices to obtain four summary documents that described participation with 

the community partnerships. Additionally, APD stated that future progress 

reporting will include specific references to partnerships to ensure compliance 

with the grant guidelines. Further, APD noted that it had been highlighted by 

the COPS Office in the documentary “Arlington, Texas: A Community 

Policing Story.” The APD has initiated numerous community policing 

programs that have been successful and received recognition.

These partnerships were reviewed as part of the OIG’s audit testing for goals 

and objectives and progress report verification under Grant Number 

2017-UL-WX-0015. As stated in the report, the partnerships were not listed 

on APD’s list of active partnerships, and the APD did not provide any 

documentation illustrating activity with these three partnerships during the 

audit. In response to the draft report, the APD provided four informational 
49

memoranda that summarized interaction with these partnerships from 2017 

through present. Then after the APD’s official response to the draft report, 

the APD provided additional documentation that supported these memoranda 

specifically in the quarter of our progress report testing, January through 

March 2019.

We reviewed the documentation and determined that it adequately 

addressed the recommendation. Therefore, this recommendation is closed.

2. Coordinate with the APD to develop and implement policies and 

procedures to ensure the APD reports accurate accomplishments in 

its progress reports and maintains documentation of grant program 

progress.

Closed. The COPS Office concurred with our recommendation and stated 

that the APD provided a copy of the APD Grants Management SOP Manual, 

effective May 2020. The COPS Office stated that it relied on Sections 102.02, 

102.03, and 301.00 of the revised SOP and requested closure of the 

recommendation.

The APD concurred with our recommendation and stated that the APD Grants 

Management SOP Manual has been implemented and outlines requirements 

related to reporting and monitoring progress and documentation. 

Additionally, the APD stated that it operates under the City of Arlington Grant 

Compliance Guide, effective September 2015 and described additional 

policies. Further, the APD stated that it will continue to review all established 

guidelines with staff to promote grant knowledge.

We reviewed Sections 102.02, 102.03, and 301.00 of the updated APD 

Grants Management SOP Manual and determined that they adequately 

addressed the recommendation. Therefore, this recommendation is closed.

3. Coordinate with the APD to update its policies and procedures to 

ensure that, when a CHP position becomes vacant during the grant or 

retention period, the APD tracks new officers hired on or after the 

date the CHP positions were vacated in order to meet retention 

requirements.

Closed. The COPS Office concurred with our recommendation and stated 

that the APD provided a copy of the APD Grants Management SOP Manual, 

effective May 2020. The COPS Office stated that it relied on Section 

201.00(H5) of the revised SOP and requested closure of the 

recommendation.

The APD concurred with our recommendation and stated that the APD Grants 

Management SOP Manual has been implemented and outlines necessary 

requirements related to CHP grant positions to ensure retention requirements 

are met. Additionally, the APD stated that it is training staff and developing 
50

a spreadsheet to track allowable hires in compliance with grant 

requirements.

We reviewed Section 201.00(H5) of the updated APD Grants Management 

SOP Manual and determined that it adequately addressed the 

recommendation. Therefore, this recommendation is closed.

4. Remedy the federal portion of the $856,520 in unallowable costs for 

the remaining salaries and fringe of ineligible officers, specifically:

a. $196,469 under Grant Number 2015-UL-WX-0026,

b. $492,358 under Grant Number 2016-UL-WX-0011, and

c. $167,693 under Grant Number 2017-UL-WX-0015.

Closed. The COPS Office concurred with this recommendation. Of the total 

project costs that were questioned, the COPS Office determined the

allocation to the federal share. This included $102,164 under Grant Number 

2015-UL-WX-0026 that represents the 52 percent federal share that was 

charged to this grant; $234,035 under Grant Number 2016-UL-WX-0011 that 

represents the 51 percent federal share that was charged to this grant less 

an offset of funds not drawn down as of May 3, 2020; and no federal funds

under Grant Number 2017-UL-WX-0015 that represents the $80,493 or 

48 percent federal share that was charged to the grant less an offset of 

$227,413 in funds not drawn down as of May 3, 2020. As such the 

aggregate amount that was reimbursed to the DOJ for this recommendation 

was $336,199. The COPS Office provided evidence that APD repaid these 

funds to the DOJ. Based on the repayment, the COPS Office requested 

closure of the recommendation.

The APD concurred with this recommendation and stated in its response that 

it would remedy the federal portion and repay these expenses to the DOJ. 

Additionally, the APD accepted the aggregate remedy amount offered by the 

COPS Office grant monitor and acknowledged that these funds would be 

reprogrammed back to Grant Numbers 2016-UL-WX-0011 and 

2017-UL-WX-0015 for future drawdown of allowable costs. Subsequent to 

providing its formal response, the APD repaid the funds to the DOJ.

We reviewed the documentation and determined that it adequately 

addressed the recommendation. Therefore, this recommendation is closed.
51

5. Coordinate with the APD to develop and implement policies and 

procedures regarding allowable CHP hiring categories.

Closed. The COPS Office concurred with our recommendation and stated 

that the APD provided a copy of the APD Grants Management SOP Manual, 

effective May 2020. The COPS Office stated that it relied on Section 

201.00(H5) of the revised SOP and requested closure of the 

recommendation.

The APD concurred with our recommendation and stated that the APD Grants 

Management SOP Manual have been implemented and outline necessary 

requirements related to CHP grant positions and hiring categories to ensure 

compliance. Additionally, the APD stated that it is training staff to strengthen 

knowledge and understanding of allowable hire practice through a review of 

grant award agency guidelines, City of Arlington grant guidelines, and grant 

SOP guidelines.

We reviewed Section 201.00(H5) of the updated APD Grants Management 

SOP Manual and determined that it adequately addressed the

recommendation. Therefore, this recommendation is closed.

6. Remedy the federal portion of the $21,821 in unallowable salaries 

and fringe benefits that were in excess of the approved entry-level 

rate in the FCM under Grant Number 2015-UL-WX-0026.

Closed. The COPS Office concurred with this recommendation. Of the total 

project costs that were questioned, the COPS Office determined the 

allocation to the federal share as $11,346 under Grant Number 

2015-UL-WX-0026, which represents the 52 percent federal share that was 

charged to the grant. The COPS Office provided evidence that APD repaid 

these funds to the DOJ. Based on the repayment, the COPS Office requested 

closure of the recommendation.

The APD concurred with this recommendation and stated in its response that

unallowable salaries and fringe benefits were charged to Grant Number 

2015-UL-WX-0026 in excess of the approved entry-level rate established in 

the FCM. The APD also stated that it was prepared to remedy the federal 

portion and would repay these expenses to the DOJ. Additionally, the APD 

stated that the APD Grants Management SOP Manual, effective May 2020, 

and City of Arlington Grant Compliance Guide, effective September 2015, 

outline procedures and internal controls to ensure adherence to the FCM. 

Further, the APD is training employees to ensure drawdowns are only based 

on allowable charges as identified in the FCM. Subsequent to providing its 

formal response, the APD repaid the funds to the DOJ.

We reviewed the documentation and determined that it adequately 

addressed the recommendation. Therefore, this recommendation is closed.
52

7. Coordinate with the APD to review salary and fringe benefits charged 

to Grant Number 2015-UL-WX-0026 to ensure they are in accordance 

with the approved FCM.

Closed. The COPS Office concurred with our recommendation and stated 

that it is in agreement with the unallowable costs violation under Grant 

Number 2015-UL-WX-0026, but that the APD maintained 15 newly-hired 

officers on the grant and have since met the retention requirement. 

Additionally, the COPS Office stated that the APD Grants Management SOP 

Manual, effective May 2020, and the City of Arlington Grant Compliance 

Guide, effective September 2015 outline procedures for adherence to the 

FCM and federal grant requirements. Based on these actions, the COPS 

Office requested closure of the recommendation.

The APD concurred with our recommendation and stated that the APD Grants 

Management SOP Manual and the City of Arlington Grant Compliance Guide 

outline procedures for adherence to the FCM and federal grant requirements. 

Additionally, APD stated that it is training staff on adhering to federal grant 

requirements.

We reviewed the documentation and determined that it adequately 

addressed the recommendation. Therefore, this recommendation is closed.

8. Coordinate with the APD to enhance policies and procedures to 

review costs charged to DOJ grants, ensuring costs are allowable and 

in accordance with award terms and conditions.

Closed. The COPS Office concurred with our recommendation and stated 

that the APD provided it a copy of the APD Grants Management SOP Manual, 

effective May 2020, and the City of Arlington Grant Compliance Guide, 

effective September 2015. Additionally, the COPS Office stated that the APD 

is training staff that the FCM approved funding amounts are the baseline for 

allowable costs and all other costs exceeding the baseline are the 

responsibility of the grantee. The COPS Office stated that it relied on Section 

102.03(7a) of the revised SOP and Section 200.309 of the City of Arlington 

Grant Compliance Guide, and it requested closure of the recommendation.

The APD concurred with our recommendation and stated that the APD Grants 

Management SOP Manual and City of Arlington Grant Compliance Guide 

outline procedures and internal controls to ensure adherence to the FCM and 

federal grant requirements. Additionally, APD stated that it is training staff 

that the FCM approved funding amounts are the baseline for allowable costs 

and all other costs exceeding the baseline are the responsibility of the 

grantee.

We reviewed Section 102.03(7a) of the revised APD Grants Management SOP 

and Section 200.309 of the City of Arlington Grant Compliance Guide and 

determined that they adequately addressed the recommendation. Therefore, 

this recommendation is closed.
53

9. Coordinate with the APD to ensure its accounting system accurately 

accounts for the actual and budgeted expenditures by cost category 

for DOJ grants.

Resolved. The COPS Office concurred with our recommendation and stated 

in its response that the APD will use existing accounting system features to 

manage accounting for actual and budgeted expenditures and for tracking 

allowable and unallowable expenses. The COPS Office stated that APD Fiscal 

Services staff are reviewing accounting system tools and features to enhance 

tracking and monitoring capabilities. Additionally, the COPS Office stated 

that the APD Grants Management SOP Manual Appendix A: Grant 

Management Guidelines II (C) addresses the recommendation. Based on the 

planned actions, the COPS Office requested closure of the recommendation.

The APD concurred with the recommendation and stated that it will use 

existing accounting system features to manage accounting accuracy, 

specifically for actual and budgeted expenditures and for tracking allowable 

and unallowable expenses. Fiscal Services staff are reviewing accounting 

system tools and features to enhance tracking and monitoring capabilities. 

Additionally, Fiscal Services staff confirmed the OIG finding that use of 

available accounting system budget categories will assist in tracking costs 

and have implemented the recommendation. Further, the APD stated that 

the APD Grants Management SOP Manual and City of Arlington Grant 

Compliance Guide outline procedures for adherence to internal controls and 

financial reporting requirements.

We reviewed the APD Grants Management SOP Manual Appendix A: Grant 

Management Guidelines II (C) and determined that it was adequate but does 

not fully address the recommendation. We were not provided documentation

that the APD’s general ledgers under the three grants accurately record 

account category balances for salaries and fringe benefits for both actual and 

budgeted expenditures. Additionally, the general ledgers should account for 

the unallowable grant expenditures identified in Recommendations 4 and 6.

This recommendation can be closed when we receive documentation that the 

COPS Office coordinated with the APD to ensure its accounting system

accurately accounts for the actual and budgeted expenditures by cost 

category for DOJ grants.

10. Coordinate with the APD to develop and implement policies and 

procedures to periodically review cumulative actual and budgeted 

grant expenditures by cost category to ensure compliance with the 

approved FCM.

Closed. The COPS Office concurred with our recommendation and stated 

that the APD provided a copy of the APD Grants Management SOP Manual, 

effective May 2020. The COPS Office stated that it relied on Section 

201.00(H5) of the revised SOP and requested closure of the 

recommendation.
54

The APD concurred with our recommendation and stated that the APD Grants 

Management SOP Manual and City of Arlington Grant Compliance Guide 

outline procedures for adherence to the FCM and grant federal requirements. 

Further, the Fiscal Services staff are preparing a training to review the FCM 

baseline costs as compared to actual drawdowns to enhance the monitoring 

and tracking of allowable cost category expenditures to permit a greater 

understanding of cumulative grant expenditures.

We reviewed Section 201.00(H5) of the updated APD Grants Management 

SOP Manual and determined that it adequately addressed the 

recommendation. Therefore, this recommendation is closed.

11. Coordinate with the APD to develop written procedures that address 

internal controls related to drawing down funds.

Closed. The COPS Office concurred with our recommendation and stated 

that the APD provided a copy of the City of Arlington Grant Compliance 

Guide. The COPS Office stated that it relied on Section 200.430(5a) of the 

guide and requested closure of the recommendation.

The APD concurred with our recommendation and stated that the APD Grants 

Management SOP Manual and City of Arlington Grant Compliance Guide 

outline procedures for grants management including policies and internal 

review procedures for drawing down funds. Additionally, it stated that the 

APD adheres to the City of Arlington Grant Compliance Guide for 

compensation of personnel and fringe benefits. Further, it stated that 

internal processes are being strengthened through additional training on the 

use of the FCM and using the accounting system budget categories.

We found the City of Arlington Grant Compliance Guide Section 200.430(5a), 

did not address internal controls related to drawdowns. Consequently, we 

reviewed the updated APD Grants Management SOP Manual Sections 102.03 

(A7) and (B3), and 201.00(H) and determined that they adequately 

addressed the recommendation. Therefore, this recommendation is closed.

12. Coordinate with the APD to compute drawdowns according to the 

eligible officers under Grant Number 2016-UL-WX-0011.

Closed. The COPS Office concurred with our recommendation. It stated that 

the APD agreed with the drawdowns to date and that the costs cited by the 

OIG are consistent with what was identified as unallowable and allowable. 

Further the APD maintains that following the OIG’s review of their financial 

expenditures as of September 2019, all subsequent drawdowns were for 

allowable salary and fringe benefits for the officers assigned to the grant. 

Additionally, the APD provided the salaries and fringe benefits expenditures 

to assess the allowability of grant expenditures. Based upon review of their 

outlays, an offset of funds was initiated as referenced under 

Recommendation 4. Based on the actions described, the COPS Office 

requested closure of the recommendation.
55

The APD concurred with our recommendation and stated that the APD Grants 

Management SOP Manual, effective May 2020, and City of Arlington Grant

Compliance Guide, effective September 2015, outline procedures for grants 

management including policies and internal review procedures to ensure 

compliance with the FCM and federal grant requirements, specifically related 

to computing drawdowns for eligible officers. Further, APD stated that staff 

training on using FCM baseline costs and tracking eligible officers’ costs has 

been implemented.

We reviewed the documentation and determined that it adequately 

addressed the recommendation. Therefore, this recommendation is closed.

13. Coordinate with the APD to update its federal financial reporting 

procedures to ensure expenditures are reported accurately.

Closed. The COPS Office concurred with our recommendation and stated 

that the APD provided it a copy of the APD Grants Management SOP Manual, 

effective May 2020, and the City of Arlington Grant Compliance Guide,

effective September 2015. Additionally, the COPS Office stated that the APD 

affirmed that grant staff are currently being trained on reporting grant 

requirements and that they are only to account for the expenditures in the 

quarter expended. Further, the APD Fiscal Service staff with grant 

management staff will review FFR and APD financial reporting records to 

ensure accuracy prior to reporting. The COPS Office stated that it relied on 

Section 201.00(H4) of the updated SOP and requested closure of the 

recommendation.

The APD concurred with our recommendation and stated that the APD Grants 

Management SOP Manual and City of Arlington Grant Compliance Guide 

outline procedures to ensure compliance with the FCM and financial reporting 

requirements. Additionally, APD stated that grant staff are retraining on 

reporting and grant requirements to only report expenditures in the quarter 

the expenditures occurred. 

We reviewed Section 201.00(H4) of the updated APD Grants Management 

SOP Manual and determined that it adequately addressed the 

recommendation. Therefore, this recommendation is closed.
U.S. DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL

950 Pennsylvania Avenue, NW

Washington, DC 20530-0001 

Also at Oversight.gov

The Department of Justice Office of the Inspector General (DOJ OIG) is a 

statutorily created independent entity whose mission is to detect and deter 

waste, fraud, abuse, and misconduct in the Department of Justice, and to 

promote economy and efficiency in the Department’s operations.

To report allegations of waste, fraud, abuse, or misconduct regarding DOJ 

programs, employees, contractors, grants, or contracts please visit or call the

DOJ OIG Hotline at oig.justice.gov/hotline or (800) 869-4499.

Website Twitter YouTube

oig.justice.gov @JusticeOIG JusticeOIG

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