Audit Division 20-043 March 2020

Office of the Inspector General

U.S. Department of Justice

OVERSIGHT ★ INTEGRITY ★ GUIDANCE

Review of the Office of Justice 

Programs’ Corrective Actions to 

Address Dollar-Related Audit 

Recommendations
i 

Executive Summary

Review of the Office of Justice Programs’ Corrective Actions to Address 

Dollar-Related Audit Recommendations

Objective

Our objective was to assess and summarize the corrective 

actions implemented by the Office of Justice Programs

(OJP) to address Department of Justice (DOJ) Office of 

the Inspector General (OIG) dollar-related 

recommendations in its grant audit reports closed during 

fiscal years (FY) 2015 through 2017.

Review Results

The OIG closed 61 audit reports of OJP grant recipients 

from FYs 2015-2017, of which 49 reports had 

approximately $45.5 million in dollar-related 

recommendations. Roughly 43 percent ($19.7 million) of 

these costs involved “Compromised” costs, which were 

not collected because of a court judgment, settlement, or 

legal agreement. The next largest category was

“Adjusted Supported” ($8 million) costs, which were not 

adequately supported at the time of the OIG audit, but 

were later supported by subsequent documentation 

provided to OJP by a grant recipient. The third highest 

category was “Adjusted Approved” ($7.1 million) costs 

the OIG had determined were unallowable questioned 

costs at the time of the audit but were retroactively 

approved by OJP. While OJP employed a credible audit 

follow-up process to address the dollar-related 

recommendations, there are areas where OJP could 

strengthen its audit resolution processes related to 

accepting supporting documentation from grantees for

previously unsupported costs, and granting retroactive 

approvals on expenditures not in compliance with grant 

terms.

Recommendations

As a result of our review, we made three 

recommendations to OJP to periodically assess its 

decisions on OIG Dollar-Related Recommendations and 

determine enhancements to its financial enforcement and 

grant management practices. We requested a response 

to our draft report from OJP, and its response is 

appended to this final report in Appendix 3. Our analysis 

of the response is included in Appendix 4.

Background

OJP and other DOJ components must establish internal 

audit follow-up and resolution systems to ensure that OIG 

audit findings and recommendations are adequately and 

timely resolved. DOJ and federal guidance require DOJ 

components to respond to audit findings and 

recommendations in writing. This response should 

include OJP’s completed or planned course of action in 

response to audit findings and recommendations, 

justification for such action, and timeframes for final 

resolution. Through this review, the OIG assessed and 

summarized the corrective actions implemented by OJP to 

address OIG dollar-related recommendations for grant 

audit reports closed in FYs 2015 through 2017.

Accepting Supporting Documentation from Grantees 

for Previously Unsupported Costs – We found no 

evidence that OJP’s follow-up and resolution system 

accepted support to remedy previously unsupported costs 

without adequate and sufficient justification and 

documentation. For 24 of the 49 reports with dollarrelated recommendations, the grant recipient provided 

supporting documents after the OIG audit report was 

issued. One report took 16 years to close and the 

23 remaining reports took an average of 3.3 years to close. 

A number of factors can affect the timeliness of a grant 

recipient producing support that is adequate to address an 

OIG recommendation. However, delays, particularly those 

lasting years, impose a burden on both OJP and OIG staff 

in monitoring a grant recipient’s progress implementing 

corrective actions and increase risks regarding the validity 

and reliability of the supporting documentation.

Granting Retroactive Approvals – For 27 of the 49

reports with dollar-related recommendations, OJP granted 

retroactive approvals totaling approximately $7.1 million 

of the $45.5 million in combined questioned costs. 

Although we found no evidence that OJP granted 

retroactive approvals without adequate documentation, 

the frequency of these retroactive approvals raises 

concerns that grant recipients face no penalty for their 

non-compliance with grant rules. In our view, this 

situation may increase the risk that grant recipients will

use grant funds for unallowable or questionable expenses 

rather than obtaining OJP’s prior approval.
REVIEW OF THE OFFICE OF JUSTICE PROGRAMS’

CORRECTIVE ACTIONS TO ADDRESS DOLLAR-RELATED AUDIT 

RECOMMENDATIONS

TABLE OF CONTENTS

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

Purpose and Scope of the OIG’s Review .................................................. 1

The Grant Audit Process ....................................................................... 2

Dollar-Related Recommendations.................................................. 2

Grant Audit Follow-up.................................................................. 3

RESULTS ..................................................................................................... 6

OIG Dollar-Related Recommendations .................................................... 6

OJP Corrective Actions.......................................................................... 7

OJP’s Follow-up Efforts to Address OIG Dollar-Related 

Recommendations Involving Unallowable or Unsupported Questioned 

Costs ........................................................................................ 9

OJP Approved Previously-Unsupported Questioned Costs .................. 9

OJP Retroactively Approved Unallowable Questioned Costs ............. 13

CONCLUSION AND RECOMMENDATIONS........................................................ 16

APPENDIX 1: OBJECTIVE, SCOPE, AND METHODOLOGY .................................. 17

APPENDIX 2: THE OIG’S, OJP’S, AND GRANT RECIPIENT’S ROLES DURING KEY 

AUDIT PHASES.................................................................................. 18

APPENDIX 3: OFFICE OF JUSTICE PROGRAMS’ RESPONSE TO THE DRAFT 

REPORT............................................................................................ 19

APPENDIX 4: OFFICE OF THE INSPECTOR GENERAL ANALYSIS AND SUMMARY OF 

ACTIONS NECESSARY TO CLOSE THE REPORT ....................................... 22
1

REVIEW OF THE OFFICE OF JUSTICE PROGRAMS’

CORRECTIVE ACTIONS TO ADDRESS DOLLAR-RELATED AUDIT 

RECOMMENDATIONS

INTRODUCTION

Department of Justice (DOJ) components are required to establish audit follow-up 

and resolution systems to ensure that corrective actions for Office of the Inspector 

General (OIG) audit recommendations are adequately and timely completed.1 Audit

follow-up, which is the tracking of recommendations from issuance of a final audit 

report to the closing of the recommendations made in that report, is an integral part 

of good management.2 The Office of Management and Budget (OMB) instructs federal 

agencies to maintain accurate records of the status of audit reports or 

recommendations through the entire process of resolution and corrective action.3

The OIG is a statutorily created independent entity whose mission is to detect 

and deter waste, fraud, abuse, and misconduct in DOJ programs and personnel, and 

to promote economy and efficiency in those programs. The Audit Division of the OIG 

conducts performance audits of DOJ programs and operations and oversees annual 

audits of over $35 billion in DOJ expenditures. In fiscal year (FY) 2018, the OIG 

issued 69 DOJ audit reports identifying over $31.6 million in questioned costs and 

$10.9 million in funds to be put to better use, together totaling approximately $42.5

million in dollar-related recommendations.4 Over half of those dollar-related 

recommendations were issued to the Office of Justice Programs (OJP) through OIG 

audits of grant recipients external to the DOJ.

Purpose and Scope of the OIG’s Review

Audit follow-up systems provide for periodic analysis of audit recommendations, 

resolution, and corrective action to determine trends and system-wide problems and 

to recommend solutions. OJP leadership has stated that it seeks to review and 

leverage the results of all audits to strengthen and improve its grant management; 

monitoring; and oversight policies, procedures, and processes.5 We performed this 

 1 DOJ Order 2900.6A, Audit Follow-up and Resolution

2 OMB Circular A-50, Audit Follow-up

3 Ibid

4 As discussed later in this report, the Inspector General Act of 1978, as amended, defines 

questioned costs and funds to be put to better use.

5 In July 2016, OJP’s former Principal Deputy Assistant Attorney General (Principal Deputy AAG) 

appeared before a U.S. House of Representatives subcommittee on government operations. In her 

written statement for the hearing, the former Principal Deputy AAG stated that OJP closely reviews and 

leverages the results of all audits to determine ways to strengthen its grant monitoring, including 

improving policies and procedures, grant management training, and oversight processes. Beth McGarry, 

former Principal Deputy Assistant Attorney General of Office of Justice Programs, before the Committee 

on Oversight and Government Reform Subcommittee on Government Operations, U.S. House of 

Representatives, concerning “Examining Mismanagement in OJP Grantmaking” (July 14, 2016).
2

review to assess and summarize the corrective actions implemented by the Office of 

Justice Programs (OJP) to address OIG dollar-related audit recommendations. We 

analyzed 61 grant audit reports issued to OJP that were closed during FYs 2015 

through 2017 that identified dollar-related recommendations totaling approximately 

$45.5 million.6 Our methodology is described in greater detail in Appendix 1.

The Grant Audit Process7

When the OIG selects an external grant recipient for an audit, we engage that 

recipient and perform site work on location to thoroughly review different aspects of 

the grant program’s implementation. Throughout the audit, the grant recipient and 

OJP are kept apprised of its progress and given multiple opportunities to address 

potential deficiencies and provide documentation to support questionable expenses. 

Once the audit nears its conclusion, the OIG holds an audit closeout meeting with the 

grant recipient and OJP to discuss the audit “findings” or deficiencies, as well as the 

recommendations. After the closeout meeting, the OIG issues a draft audit report 

with recommendations addressed to OJP for action.

The OIG requests written responses from both OJP and the grant recipient 

indicating whether they agree or disagree with the recommendations and to identify 

any corrective action to address the audit findings. The OIG then finalizes the audit 

report with OJP’s and the grant recipient’s written comments attached. This final 

audit report also includes OIG’s analysis of OJP and the grant recipient’s proposed or 

completed actions and further steps that must be taken, if any. The OIG then issues 

the final audit report and identifies its status as either:

• Closed, if there were no recommendations or if all of the recommendations 

were adequately addressed by the date we issue the audit report;

• Resolved, if OJP agrees with all of the recommendations and the OIG agrees 

with OJP’s corrective action plan for addressing the recommendations; or

• Unresolved, if OJP does not agree with one or more of the recommendations or 

the OIG does not agree with OJP’s corrective action plan.

Dollar-Related Recommendations

The audit recommendations in a final audit report consist either of management 

improvement recommendations that address internal control and performance 

findings, or dollar-related recommendations, which require DOJ to remedy an 

identified amount of funds associated with a deficiency. Dollar-related 

recommendations are either Questioned Costs that do not comply with legal, 

regulatory, or contractual requirements at the time of the audit; or Funds to be Put to 

Better Use, which are funds that could be used more efficiently if the audit 

recommendation is implemented. Pursuant to the definitions in the Inspector General 

 6 Our review included cooperative agreements and it excluded Single Audit Reports.

7 A detailed explanation of the OIG’s grant audit process can be found on the OIG’s website at 

https://oig.justice.gov/about/grant-audits.htm.
3

Act of 1978 (IG Act), the OIG categorizes dollar-related recommendations in the 

following categories:

• Unallowable Questioned Costs as used throughout this report means costs that 

are questioned due to an alleged violation of a provision of law, regulation, 

contract, grant, cooperative agreement, or other agreement or document 

governing the expenditure of funds.8 5 USC App 5 § 5(f)(1)(A) (2015).

• Unsupported Questioned Costs means costs that were not supported by 

adequate documentation at the time of the audit. Id. § 5(f)(1)(B).

• Unreasonable Questioned Costs means costs that were unnecessary. Id. § 

5(f)(1)(C).

• Funds to be put to Better Use means that the funds could be used more 

efficiently if management implements the recommendation, such as reductions 

in outlays; deobligation of funds from programs or operations; withdrawal of 

interest subsidy costs on loans or loan guarantees, insurance, or bonds; costs 

not incurred by implementing recommended improvements related to the 

operations of the establishment, a contractor or grantee; avoidance of 

unnecessary expenditures noted in preaward reviews of contract or grant

agreements; or any other savings which are specifically identified. Id. § 

5(f)(4).

Grant Audit Follow-up

Once the final report is issued, the OIG will follow up with OJP on its corrective 

actions until the OIG determines sufficient action has been taken to close all of the 

audit recommendations in the report. During this follow-up process, the OIG 

corresponds with OJP on its implementation of the recommendations, and OJP 

corresponds directly with the grant recipient, if necessary. This correspondence 

continues between the OIG and OJP until the OIG determines that all necessary 

actions have been completed. When OJP has completed the actions it determines are 

needed to address the recommendations, OJP notifies the OIG and requests closure of

the recommendations. The OIG then independently assesses documentation for those 

corrective actions and determines whether they are sufficient to close the audit 

recommendations. For example, when a grant recipient provides additional materials 

to OJP in support of questioned costs or when OJP grants a retroactive approval for a 

questioned unallowable expenditure, the OIG reviews OJP’s justification and 

supporting documentation to determine if the actions are sufficient to remedy the 

costs. OJP considers many of these unallowable questioned costs to be previously 

unauthorized. Once the OIG has determined that the actions were appropriate, the 

OIG notifies OJP that the audit is closed.

 8 OJP officials told us that many costs classified as unallowable by the OIG are viewed by OJP as 

unauthorized, which OJP may subsequently authorize, subject to additional justification and support by 

the grantee. According to OJP, per the DOJ Grants Financial Guide and the Code of Federal Regulations, 

“unallowable” costs include specifically defined items of costs such as land acquisition, lobbying, 

fundraising, entertainment costs, fines and penalties, and alcoholic beverages. OJP officials also told us

that unallowable costs also include, “any costs considered inappropriate by your awarding agency.”
4

The majority of our FY 2018 reports of OJP grant recipients with questioned 

costs were issued in a “resolved” status because we agreed with the corrective actions 

that OJP management proposed in its response to the draft report. The OIG does not 

accept corrective actions that it believes contradict existing laws or policies, are 

wasteful, or are otherwise insufficient. In the instance that the OIG does not accept 

the proposed actions, the OIG considers the recommendation “unresolved” and

explains the disagreement via official correspondence to OJP, as well as to the Office 

of the Deputy Attorney General and the Office of the Associate Attorney General, as 

necessary. If the OIG and OJP do not come to an agreement on the actions necessary 

to address the recommendations, according to DOJ policy the matter may be referred 

to the Department’s Audit Resolution Committee for a final decision. However, since 

the OIG’s creation, this has not occurred in OJP and has occurred just once with a 

different DOJ component.

Remedies for Dollar-Related Recommendations

To close dollar-related recommendations, specifically Questioned Costs and 

Funds to be Put to Better Use, the OIG expects documentation from OJP that it has 

remedied the costs that were associated with the deficiency identified in the audit. 

Those recommendations are remedied by OJP implementing one or more of the 

following types of corrective action remedies, which the OIG generally accepts based 

on guidance in the IG Act, 31 C.F.R. Parts 901-903, and OMB Circulars.9

• Adjusted Approved – This category includes costs that OJP management has 

retroactively approved. This remedy is generally applied by OJP to costs that 

were determined by the OIG to be unallowable at the time of the audit.

• Adjusted Supported – This category includes costs that were not adequately 

supported at the time of the OIG audit, but that OJP subsequently determined 

were “supported” as a result of the grant recipient providing adequate

documentation evidencing that the costs were appropriate.

• Compromised – Costs that were questioned by the OIG’s audit, but that OJP will 

not seek to collect due to a court judgment, settlement, or other appropriate 

legal agreements.

• Offsets – Costs that OJP management decides to offset against future federal 

funds to be provided to the grant recipient.

• Recovered (or Returned) – Costs that OJP has actually recovered. This also 

includes amounts that were repaid to the government as a result of 

settlements, court decisions, judgments, and other agreements.

• Saved – Funds that OJP management did not spend or apply to a different use 

because of the OIG’s audit recommendation, such as deobligating funds that 

were recommended to be put to better use.

• Waived – Costs that OJP management has forgiven, including costs terminated 

or suspended in accordance with federal regulations.

 9 DOJ Order 2900.6A, Audit Follow-up and Resolution and OMB Circular A-50, Audit Follow-up
5

• Write Offs of Delinquent Debt – Dollar-related recommendations, or portions 

thereof, that are also considered delinquent debt based on adequate 

documentation that the cost was written off in accordance with OMB Circular 

A-129.10

• Other – Used to categorize any other corrective action remedies taken by OJP 

to address OIG dollar-related recommendations.

Pursuant to the above authorities, OJP’s resolution actions must be consistent 

with governing laws and regulations and include, as appropriate, the written 

justification and legal basis for any decisions not to seek recovery of monies due to 

the federal government.

 10 OMB Circular A-129, Policies for Federal Credit Programs and Non-Tax Receivables, prescribes 

policies and procedures for justifying, designing, and managing federal credit programs and for collecting 

non-tax receivables. The circular sets principles for designing credit programs, including the preparation 

and review of legislation and regulations; budgeting for subsidy costs and administrative expenses of 

credit programs, and minimalizing unintended costs to the government; and improving the efficiency and 

effectiveness of federal credit programs.
6

RESULTS

We identified 61 audit reports of OJP grant programs closed during FYs 2015 

through 2017, 49 of which had dollar-related recommendations totaling approximately

$45.5 million that have since been closed. We found that $4.6 million of $45.5 million 

in questioned costs were “Recovered” or “Returned”, while a significant portion were 

“Adjusted Approved” because they were remedied by OJP-issued retroactive approvals 

($7.1 million), or “Adjusted Supported” because the grant recipient provided 

supporting records to OJP after issuance of the OIG audit report ($8 million).11 We 

believe the frequency of OJP’s acceptance of support documentation, sometimes years 

after an expenditure, and its routine use of retroactive approvals collectively increase 

the risk of unauthorized grant expenditures.

OIG Dollar-Related Recommendations

The majority of OIG audits of OJP grant recipients within our review scope resulted

in dollar-related recommendations. Of the 61 such audit reports closed in FYs 2015-

2017, 49 (80 percent) included Questioned Costs and Funds to be Put to Better Use 

totaling approximately $45.5 million. Table 1 includes the dollar-related 

recommendations according to the different types that the OIG tracks pursuant to the 

definitions in the IG Act.

 11 Amounts were rounded.
7

Table 1

Dollar-Related Recommendations for OIG Audits of OJP Grants

Description

Year that OIG Closed Audit Report

FY 2015 FY 2016 FY 2017 Total

Total Reports 23 19 19 61

Reports with Dollar-Related 

Recommendations 17 17 15 49

Funds to be put to Better Use $435,889 $3,943,879 $374,112 $4,753,880

Net Questioned Costs $7,124,468 $26,590,718 $7,029,682 $40,744,868

TOTAL DOLLAR-RELATED 

RECOMMENDATIONS $7,560,357 $30,534,597 $7,403,794 $45,498,748

Note: The Single Audit Act of 1984, as amended, provides for recipients of federal funding above a 

certain threshold to receive an annual audit of their financial statements and federal expenditures. The 

OIG reviews single audit reports to determine whether they contain audit findings related to DOJ funds 

and meet federal requirements and generally accepted government-auditing standards. The OIG then 

monitors these audits through the resolution and closure process. Because they do not reflect OIG audit 

work, we did not include these reports in this review’s scope.

Source: OIG analysis of FYs 2015 through 2017 audit resolution data.

More than half of the Dollar-Related Recommendations shown in Table 1 

resulted from the OIG audit of Big Brothers Big Sisters of America (BBBSA), which 

identified $19.5 million in Questioned Costs and $3.8 million in Funds to be Put to 

Better Use.12 That audit found that BBBSA could not adequately support any of the 

expenditures it made for the grant-funded programs because grant funds were 

commingled within BBBSA’s general fund account, making it impossible to identify 

how grant funds were used.

OJP Corrective Actions

After OIG final audit reports are issued, it is important for OJP to timely work 

with grant recipients to remedy Dollar-Related Recommendations. The primary 

responsibility for the follow-up and closure of the recommendations is managed by 

OJP’s Office of Audit, Assessment, and Management (OAAM), which coordinates with 

other OJP program offices as appropriate.13 For the 49 reports with Net Questioned 

Costs Recommendations, we analyzed the corrective action remedies that OJP took to 

bring the grant recipient into compliance. Table 2 contains the results of that analysis.

 12 U.S. Department of Justice (DOJ) Office of the Inspector General (OIG), Audit of the Office of 

Juvenile Justice and Delinquency Prevention Grants Awarded to Big Brothers Big Sisters of America, 

Audit Report Number GR-70-13-006 (June 2013), https://oig.justice.gov/reports/2013/g7013006.pdf

(accessed August 14, 2019), 7.

13 According to OJP, its intent for its projects and programs that are supported by OJP grant 

funds is to further its goals to provide innovative leadership to federal, state, local, and tribal justice 

systems, by disseminating state-of-the art knowledge and practices across America, and providing 

grants for the implementation of crime fighting strategies. OJP officials told us that their approach on

how best to remedy issues and questioned costs identified in OIG grant audit reports considers the 

programmatic impact that such an approach could have on the success of the grant recipients projects 

and programs. OJP officials said that they routinely convene multi-office meetings to continuously 

assess any risks and impacts posed until the closure of grant audit reports with significant issues and 

questioned costs.
8

Table 2

OJP Remedies for OIG Net Questioned

Cost Recommendations

Corrective Action

Year that OIG Closed Audit Report

FY 2015 FY 2016 FY 2017 Remedy Total

Compromised $0 $19,606,565 $0 $19,606,565

Adjusted Supported $1,962,473 $2,485,081 $3,511,400 $7,958,954

Adjusted Approved $4,410,674 $737,480 $1,912,909 $7,061,063

Saved $435,889 $3,943,879 $374,112 $4,753,880

Recovered/Returned $766,986 $2,865,600 $898,609 $4,531,195

Written Off $0 $0 $1,258,362 $1,258,362

Other $0 $1,072,775 $0 $1,072,775

Waived $0 $0 $36,978 $36,978

Less Duplicate Questioned

Costsa

($15,665) ($176,783) ($588,576) ($781,024)

Total $7,560,357 $30,534,597 $7,403,794 $45,498,748

a This category consists of costs representing more than one remedy category, costs resolved by an 

agreement reached between OIG and OJP during audit resolution, or costs for which no other 

category applies.

Source: OIG analysis of FYs 2015 through 2017 audit resolution data

Roughly 43 percent of the costs in Table 2 ($19.7 million) were

“Compromised” and those costs almost entirely involved the OIG findings from the 

BBBSA audit. Specifically, the compromise was the result of a court settlement 

agreement that the DOJ reached after OJP worked with BBBSA to hire forensic 

accountants to re-create its accounting records. Additionally, as a result of the 

settlement agreement, BBBSA was required to repay $1.6 million. The next largest 

category of costs was “Adjusted Supported” (almost $8 million), which represents

costs that were unsupported at the time of the audit, but for which OJP worked with 

the grantee to obtain missing documentation and OJP thereafter determined that the 

costs were supported. “Adjusted Approved” costs (almost $7.1 million) were those 

costs that were not approved at the time of our audit, but which OJP retroactively 

approved.

The next categories of costs – “Saved” ($4.8 million) and 

“Recovered/Returned” ($4.6 million) – represent those costs for which OJP enforced 

grant rules to recover the funds. Within the scope of this review, the audit with the 

highest “Saved” costs was the aforementioned BBBSA audit, where $3.8 million in 

unspent grant funds were either repurposed or deobligated. This audit also had the 

highest Recovered/Returned” costs due to the $1.6 million settlement that was

repaid.

Finally, costs that were “Written Off” (almost $1.3 million) and “Waived”

($36,978) are those costs for which OJP used its authority to waive grant 

requirements or determined that it would not pursue collecting the funds. In 

connection with the OIG’s audit findings concerning Education Advancement Alliance, 

OJP wrote-off almost $1.3 million after the Executive Director was found guilty of a 

federal racketeering conspiracy, the organization dissolved, and OJP determined it 
9

was unlikely that any funds would be remaining for recovery.14 The “Waived” dollarrelated recommendation was in connection with the OIG’s audit of grants to the 

Oglala Sioux Tribe.15

OJP’s Follow-up Efforts to Address OIG Dollar-Related Recommendations Involving 

Unallowable or Unsupported Questioned Costs

OJP has a process to follow-up and close recommendations after OIG final 

audit reports are issued, which must adhere to laws, regulations, and other 

requirements. Our analysis found that the two largest categories of remedies for 

dollar-related recommendations are those associated with OJP’s efforts to address 

OIG findings to bring grantees into compliance with grant rules and requirements. 

However, OJP’s post-audit approval of grantees’ noncompliant activities can

undermine general grantee compliance with grant program rules. In our view, to 

most effectively safeguard billions of dollars in grant funds, OJP should ensure that 

grant recipients comply with grant rules for the duration of the award period in order 

to avoid OJP having to work with the grant recipients to become compliant after an 

OIG audit reveals deficiencies.16 The following sections in this report analyze these 

risks in more detail.

OJP Approved Previously-Unsupported Questioned Costs

Grant recipients are required by OJP grant rules and federal regulation to 

maintain adequate support for grant costs. Grant rules also require these support 

records to be retained in the event of a federal examination or audit.17 In our view, 

compliance with these rules requires contemporaneous record-keeping by grant 

recipients and a grant recipient’s immediate production of these records upon request 

during an audit. When the OIG audits a grant and determines that the grantee’s 

records do not support a grant-related expenditure, the OIG issues a 

recommendation for OJP to remedy the unsupported questioned costs. After 

issuance of the final audit report, OJP usually works with the grant recipient to 

determine whether the grantee can obtain sufficient documentation to support the 

expenditure and thereby address the OIG’s audit recommendations. If OJP receives 

additional supporting documentation from the recipient and determines it is sufficient 

to support the costs, OJP provides a written memorandum to the OIG explaining its 

decision and providing the OIG with the documentation. The OIG reviews the 

 14 DOJ OIG, Audit of the OJP Grant Administered by the Educational Advancement Alliance, Inc., 

Philadelphia, Pennsylvania, Audit Report GR-70-13-005 (May 2013), 

https://oig.justice.gov/reports/2013/g7013005.pdf (accessed August 14, 2019).

15 DOJ OIG, Audit of the OJP Grants to the Oglala Sioux Tribe, Pine Ridge, South Dakota, Audit 

Report GR-60-05-004 (February 2005), https://oig.justice.gov/grants/g6005004.htm (accessed 

August 14, 2019). The basis for the waiver was U.S. Department of the Interior and DOJ legal opinions 

authorizing the expenditure of grant funds questioned.

16 OJP officials told us that they agreed with this statement and use various mechanisms to 

mitigate risks that grant funds are utilized for inappropriate purposes, including: pre-award risk 

determinations, in-depth financial and programmatic monitoring, grants financial management training 

(both on-line and live trainings are available to OJP grant recipients), and program office-sponsored 

training and conferences.

17 DOJ, Grants Financial Guide, December 2017
10

documentation to independently determine whether it supports the questioned costs. 

If the OIG does not agree with OJP’s decision, the OIG provides an explanation via 

correspondence to OJP and further information or action is requested.

In this review, we found no evidence that OJP’s follow-up and resolution 

system accepted support to remedy previously unsupported costs without adequate 

and sufficient justification and documentation. However, we noted that in 24 of the 

49 audit reports with Dollar-Related Recommendations, grant recipients provided OJP 

with previously unavailable supporting documentation to remedy unsupported 

questioned costs after the issuance of the final audit report; in many instances years 

later. Figure 1 shows the number of years that each of the 24 reports remained 

open.

Figure 1

Number of Years to Close Reports Involving a Grant Recipient Providing 

Previously Unavailable Supporting Documentation

Source: OIG analysis of OJP records

As reflected in Figure 1, 23 of the 24 reports took more than 1 year to close. 

Of these 23 reports, 8 reports were closed between 1 and 2 years, and another 8 

reports were closed between 2 and 4 years. Four reports were closed between 4 and 

7 years, and 3 reports took more than 7 years to close. Collectively, these 24 

reports took an average of 3.8 years to close. After removing the audit open the 

longest (16 years), which was an OJP cooperative agreement awarded to the 

Criminal Justice Institute, Incorporated (CJI), the remaining 23 audits took an 

average of 3.3 years to close.18

 18 DOJ OIG, Audit of OJP’s FY 1997 Corrections Technical Assistance Program to the Criminal 

Justice Institute, Inc., Audit Report GR-70-99-012 (September 1999),

https://oig.justice.gov/grants/g7099012.htm (accessed December 16, 2019).

0.00

2.00

4.00

6.00

8.00

10.00

12.00

14.00

16.00

18.00

0 5 10 15 20 25 30

Years

Reports

Reports
11

The CJI audit questioned $167,200 in total costs, of which $129,440 was 

unsupported. OJP agreed with the recommendations throughout the period it took to 

close the recommendations. During the 16-year closure period, the auditee indicated

that documentation supporting the questioned expenditures was lost, but the auditee 

did not supply appropriate secondary documentation, such as copies of invoices or 

statements, to support the expenditures in an expeditious manner. In one of the 

auditee’s responses, the auditee provided the same voluminous insufficient 

documentation provided during the audit, which was burdensome to OJP and OIG 

resources to review again. Ultimately, the auditee provided adequate documentation 

to address $129,200 of the questioned costs and provided repayment of about 

$38,000 to close the audit’s last two recommendations and the audit overall.

We recognize that a number of factors can affect the timeliness of a report’s 

resolution and closure, including offsite record storage, available resources, and the 

workload of grant recipient staff.19 However, during an OIG audit, OIG auditors 

provide grant recipients ample time and opportunities to produce supporting 

documentation that grant recipients should readily have available. The lengthy 

periods of time necessary to provide documentation that should be available 

contemporaneous with the expense increases the risks related to the validity and 

reliability of the documentation. The fact that many recipients can take well over a 

year to produce sufficient support is a concerning fact that we believe OJP should 

consider for its grant oversight practices. Moreover, as previously discussed, the 

largest amount of Questioned Costs during this time period was the OIG’s audit of 

BBBSA, which included $19.5 million in Dollar-Related Recommendations, of which 

$17.9 million in costs were compromised. We determined the costs were 

unsupported because BBBSA commingled grant funds with its general fund account, 

thereby making it impossible to distinguish allowable grant-related costs with 

unallowable costs.

These deficiencies were revealed in the OIG’s audit despite the fact that a prior

Single Audit of BBBSA performed before the OIG’s audit had resulted in relatively 

 

The average number of years to close the 49 reports with dollar-related recommendations was 

2.5 years.

19 As an example, OJP officials told us that in instances where there are large volumes of 

questioned transactions or amounts, grantees may make incremental progress in addressing the 

questioned costs, and it may take an extended period for them to satisfactorily support or justify all of 

the questioned costs. OJP officials also said that other factors can increase the length of time an audit 

report remains open including: (1) grantees that were subject to both audit and investigation by the 

OIG, which sometimes results in the temporary suspension of audit follow-up actions; (2) reports where 

all (or substantially all) of the grant-related costs were questioned because of broader issues such as 

when a grantee did not have a single audit report completed; (3) grantees that did not adequately 

monitor sub-recipients; and (4) grantees that commingled funds.
12

clean reports that did not identify the significant mismanagement of the grants.20 

After the OIG’s audit, BBBSA hired outside forensic accountants to recreate its 

accounting records, which took almost 3 years of working with OJP to get its records 

into an acceptable condition. Ultimately, a court settlement was reached for BBBSA 

to repay $1.6 million and relinquish $103,331 of the grant through deobligation, after 

which the audit was closed. Significant OIG, OJP, BBBSA, and DOJ resources were 

used in bringing BBBSA into compliance, which could have been avoided if OJP had 

ensured that BBBSA remained in compliance with grant requirements the entire time 

it was implementing its grant programs.

While CJI and BBBSA are two significant examples, the implications of the 

deficiencies identified in these audits are not unlike those uncovered in OIG audits

that lead to corrective actions to address grantees’ non-compliance with grant rules. 

As an initial matter, the inability to timely locate supporting documentation results in

significant after-the-fact attention by OIG, OJP, and grant recipient officials’ that 

would be unnecessary if grant recipients were contemporaneously complying with 

grant rules. The inability of grant recipients to properly document their expenditures, 

and the resulting devotion of time and effort required to address the non-compliance,

is a continual cycle of mismanagement that burdens limited resources and is an 

inefficient method of managing grant programs.

We are concerned that OJP, by routinely allowing grantees to remedy 

questioned costs years after an audit report has been issued increases the risk of 

federal funds being inappropriately used.

In its grant administration, OJP employs several tools to enhance its 

monitoring and oversight of grantees it identifies as having a higher risk of improper 

grants management, such as applying special conditions, increasing the level of 

 20 The OIG performed a Quality Control Review of BBBSA’s 2011 Single Audit and concluded 

that the auditor did not adequately perform multiple audit steps and procedures, and supervision was 

not sufficient to identify the errors and omissions in the audit work and documentation. As a result, the 

OIG concluded that the Single Audit auditor was not in compliance with government audit standards for 

reporting, evidence, and supervision.

According to OJP, the Single Audit Act intends for federal agencies to rely on the single audit in 

carrying out their administrative responsibilities for determining compliance with the requirements of 

federal awards by non-federal entities. OJP adds that consistent with the intent of the Single Audit Act, 

the single audit is a key part of OJP’s framework of grant oversight. OJP states that it would be impossible

for it to separately conduct its own in-depth audits of non-federal entities. Rather, OJP states that it 

relies heavily upon single audits to identify deficiencies, such as those identified in the BBBSA audit.

DOJ OIG, Quality Control Review of the PricewaterhouseCoopers LLP Fiscal Year 2011 Single 

Audit of Big Brothers Big Sisters of America, Audit Report GR-50-15-006 (July 2015), 

https://oig.justice.gov/reports/2015/g5015006.pdf (accessed August 14, 2019).
13

monitoring, and imposing a grantee with a “high-risk designation.”21 We recommend 

that OJP periodically evaluate the timeliness and circumstances of grantees producing 

supporting documentation to remedy questioned costs and implement rules and 

proactive measures to better ensure grantees maintain proper and contemporaneous 

support for grant expenditures. Such actions could further mitigate the risk of 

unauthorized grant expenditures and ensure that federal funds are not misused or 

abused. We also recommend that OJP establish and communicate to each grant 

recipient time limits for providing requested supporting documentation depending on 

the complexity of the audit findings.

OJP Retroactively Approved Unallowable Questioned Costs

When grantees apply for grants, they agree to abide by certain terms and 

conditions and often have a budget to which they must adhere. Those terms include 

conditions such as revising certain items in the OJP-approved grant budget before 

incurring costs for the grant, adhering to the agreed-upon project scope and budget, 

abiding by certain salary restrictions, and obtaining approval for key personnel 

working on the grant. To allowably deviate from those terms, recipients are required 

to submit a Grant Adjustment Notice (GAN) for OJP’s review and obtain OJP’s prior 

approval before deviating from the grant terms. When an OIG audit identifies that a 

grantee did not abide by such terms and did not obtain OJP’s prior approval, the OIG 

generally issues a recommendation for OJP to remedy Unallowable Questioned Costs 

that did not conform to the terms of the grant agreement.

To remedy those costs that the OIG has questioned, OJP sometimes issues 

retroactive approvals to support those deviations and costs, thereby bringing grant 

recipients into compliance. DOJ and OMB audit follow-up and resolution guidance 

allows OJP to retroactively approve costs if doing so is consistent with law, 

regulation, and administration policy. When OJP issues a retroactive approval, the 

OIG determines whether the retroactive approval violates a law, regulation, policy, or 

whether it results in ineffective, inefficient, or wasteful grant administration. The role 

of the OIG is not, however, to second-guess a discretionary judgment by OJP 

management that is authorized by OJP and DOJ guidance. If the OIG determines 

that the retroactive approval violates a law, regulation, policy, or would result in 

inefficient, or wasteful grant administration, the OIG does not agree to close the 

 

21 The DOJ’s high-risk designation policy was formally approved on January 6, 2012, and was 

adopted by DOJ’s three primary grant-making components: OJP, the Office of Community Oriented 

Policing Services, and the Office on Violence Against Women. The intended purpose of high-risk 

designations are to provide DOJ with a means of continuing to fund criminal justice programs while 

maintaining proper stewardship of federal funds and mitigating risk in the administration of grant 

programs.

The high-risk designation subjects the grant recipient to greater OJP managing, monitoring, and 

additional restrictions on any current and new grant awards. High-risk designations can result from a 

variety of conditions, including, but not limited to: (1) when a grant recipient has had audit report 

recommendations open for more than 1 year, and has not submitted documentation adequate to close 

the recommendation; or (2) when a recipient has not provided a corrective action plan within 105 days 

of transmission of the audit report to the grant recipient.
14

recommendation and explains its reasons via correspondence to OJP and requests 

further information or action. However, if the approval conforms to legal and other

relevant requirements, the OIG will generally close the applicable recommendations.

During this review, we found no evidence that OJP granted retroactive 

approvals without adequate documentation. Additionally, we found that in 27 of 49

reports, OJP retroactively approved questioned costs totaling approximately $6.7

million. For example, in our audit of the OJP’s National Institute of Justice

Cooperative Agreements with AKELA, Incorporated in Santa Barbara, California, we 

found that the grant recipient did not obtain a financial and compliance audit for FY 

2007 or on a bi-annual basis as required by the grant; therefore, we questioned the 

full $1.9 million in awards as unallowable.22 OJP granted a retroactive approval for 

the unallowable questioned costs because the grant recipient completed its financial 

and compliance audit for a subsequent period (FY 2009), a significant amount of time 

had elapsed since the prescribed audit period of FY 2007, and the grant recipient no 

longer had active awards with OJP.23

OAAM officials told us OJP’s program offices are primarily responsible for 

reviewing grant recipient requests for retroactive approval and that certain requests, 

such as retroactive budget modifications greater than 10 percent, must involve a 

review from OJP’s Office of the Chief Financial Officer. The officials also explained 

that OJP’s Office of the General Counsel could become involved in a retroactive 

approval request in special circumstances, such as a conflict-of-interest issue or 

when it becomes necessary to obtain a legal interpretation.

From our review of the audit follow-up and resolution materials and interviews 

with OAAM officials regarding OJP’s practices for providing retroactive approvals, we 

believe OJP employed a credible audit follow-up and resolution process to address 

the audit findings for the 49 reports containing dollar-related recommendations we 

reviewed for this report. After our issuance of final audit reports, OJP worked with 

grant recipients to remedy dollar-related recommendations, required grant recipients 

to justify any proposed remedial corrective actions, and provided justification and 

support materials to the OIG as the basis for closing recommendations. We also 

recognize that OJP already commits resources toward several ongoing grant 

oversight activities. In June 2017, the then Acting Assistant Attorney General of OJP 

appeared before a congressional hearing on grant oversight and commented 

regarding OJP’s efforts to improve its internal controls and risk management tools 

and strengthen its oversight and monitoring activities. In a written statement for the 

hearing, he commented on OJP’s multipronged approach that includes pre-award risk 

analysis before grant awards are made, routine review of grant recipient financial and 

 22 DOJ OIG, Audit of the OJP National Institute of Justice Cooperative Agreements with AKELA, 

Incorporated Santa Barbara, California, Audit Report GR-90-13-002 (January 2013), 

https://oig.justice.gov/reports/2013/g9013002.pdf (accessed August 14, 2019).

23 The grant recipient’s FY 2009 audit was issued as an unqualified opinion but noted 

deficiencies with the grant recipient’s internal controls.
15

programmatic reporting, training and technical assistance, and targeted outreach to 

high-risk or at-risk grantees.24

However, it would be impossible to determine whether OJP would have 

approved these questioned costs had grantees requested approval before expending 

the funds for otherwise unallowable purposes. Further, in our view, the frequency of 

OJP’s retroactive approvals raises concerns that grant recipients may perceive that 

there are few if any consequences for not following grant rules. This creates a risk 

that grant recipients, rather than risk an OJP denial by seeking OJP’s approval before 

making a questionable or unallowable purchase, will instead proceed with the 

purchase in the belief that it is highly likely that OJP will retroactively approve it. We 

therefore recommend that OJP evaluate these risks and determine enhancements to 

its enforcement practices for unallowable questioned costs identified in audits and 

reviews. Further, we recommend that OJP evaluate the risks posed by the proportion 

of unallowable questioned costs OJP retroactively approves, determine enhancements 

to its enforcement practices for unallowable questioned costs identified in audits and 

reviews, and periodically review grant terms for which OJP routinely approves 

deviations through Grant Adjustment Notices and retroactive approvals and identify 

strategies that better ensure grant recipients are spending grant funds for allowable 

purposes.

 24 Alan Hanson, then Acting Assistant Attorney General of Office of Justice Programs, before the 

Subcommittee on Crime, Terrorism, Homeland Security, and Investigations Committee on the Judiciary, 

U.S. House of Representatives, concerning “Department of Justice Grants Oversight” (June 8, 2017),

https://www.govinfo.gov/content/pkg/CHRG-115hhrg27070/pdf/CHRG-115hhrg27070.pdf, 8.
16

CONCLUSION AND RECOMMENDATIONS

We identified 61 audit reports of OJP grant programs closed during FYs 2015 

through 2017, of which 49 reports had dollar-related recommendations totaling 

approximately $45.5 million. Part of effective grant management is employing 

procedures and controls that best ensure grant recipients comply with the grant rules 

to which they agree when they accept the awards. However, our analysis of OJP’s 

actions to remedy OIG dollar-related recommendations often involved OJP accepting 

supporting documentation not available to the OIG during its audits or issuing 

grantees retroactive approvals after the OIG determined OJP grant recipients were 

out of compliance.

Given the importance of enforcing grant rules to ensure effective 

implementation of grant programs funded with billions of federal funds, we further 

analyzed OJP accepting supporting documentation and granting retroactive 

approvals. A significant portion of the questioned costs ($14.7 million or 32 percent

of all questioned costs) in those audits were remedied by OJP accepting supporting 

documentation after the OIG audit report was issued, and these reports took up to 

16 years to close. We believe the frequency of accepting dated supporting

documentation and granting retroactive approvals collectively increases the risk of 

unauthorized grant expenditures. Further, these practices potentially make it more 

likely that grant recipients will use grant funds for unallowable or questionable 

purchases, with the expectation that the questionable use will be retroactively 

approved.

We recommend that OJP:

1. Periodically evaluate the timeliness and circumstances of grantees producing 

supporting documentation to remedy questioned costs and implement 

guidance or policy and proactive measures to better ensure grantees maintain 

proper and contemporaneous support for grant expenditures.

2. Establish and communicate to each grant recipient time limits for providing

requested supporting documentation depending on the complexity of the audit 

findings.

3. Evaluate the risks posed by the proportion of unallowable questioned costs OJP 

retroactively approves, determine enhancements to its enforcement practices 

for unallowable questioned costs identified in audits and reviews, and 

periodically review grant terms for which OJP routinely approves deviations 

through Grant Adjustment Notices and retroactive approvals and identify 

strategies that better ensure grant recipients are spending grant funds for 

allowable purposes.
17

APPENDIX 1

OBJECTIVE, SCOPE, AND METHODOLOGY

Objective

The objective of this review was to assess and summarize the corrective 

actions implemented by the Office of Justice Programs (OJP) to address Department 

of Justice Office of the Inspector General (OIG) dollar-related recommendations of 

grant reports closed during fiscal years (FY) 2015 through 2017. To accomplish this 

objective we obtained and analyzed OIG and OJP follow-up resolution correspondence 

used to close the reports within our universe. We also analyzed data contained 

within the OIG’s Project and Resolution Tracking database and reviewed each audit 

report. We interviewed officials within OJP’s Office of Audit, Assessment, and 

Management responsible for managing OJP’s audit follow-up and resolution activities 

and have incorporated their comments within the report.

Scope and Methodology

We obtained from OJP data on corrective action remedies it implemented to 

address recommendations of reports closed in FY 2015 and provided by the former 

Principal Deputy Assistant Attorney General to Congress in July 2016. We performed 

an analysis of the recommendations and compared our results to OJP’s results. We 

also analyzed corrective action remedies OJP implemented for FYs 2016 and 2017. 

We identified 61 reports closed during the 3-year review period. We performed 

additional testing on retroactively approved and supported costs. Our universe 

included cooperative agreements, but excluded single audit reports. We also 

assessed and discussed in this report OIG audit reports of OJP grant recipients issued 

outside the FYs 2015-2017 review period.
18

APPENDIX 2

THE OIG’S, OJP’S, AND GRANT RECIPIENT’S

ROLES DURING KEY AUDIT PHASES

Initiation The OIG notifies OJP and the grant recipient of the forthcoming audit and prepares for 

fieldwork. The OIG also collects and analyzes OJP grant information and requests that the grant 

recipient provide certain grant documentation in advance of the audit. The OIG informs the 

grant recipient of the audit purpose, scope, and objectives.

Fieldwork The OIG performs detailed verification procedures in accordance with generally accepted 

government auditing standards.a

Exit Conference The OIG informs OJP and the grant recipient of the preliminary audit findings, obtains the 

grant recipient’s comments on the findings, and informs the grant recipient of the forthcoming 

reporting and resolution process. 

Draft Report The OIG issues a draft report of its preliminary audit findings, recommendations, and 

conclusions to OJP and the grant recipient, including any identified questioned costs and funds 

to be put to better use. The OIG also requests a written response from OJP and the grant 

recipient regarding agreement or disagreement with the recommendations and planned 

corrective actions to address our findings.

Final Report The OIG issues its final audit report that includes an analysis of OJP’s and the grant recipient’s 

responses containing proposed or completed actions and steps that both entities must take to 

close the recommendations. In the final report, dollar-related recommendations are adjusted, 

if necessary, and finalized. The final audit report notes the status of each recommendation. 

Recommendations are “resolved” when the OIG determines that OJP concurred with the 

recommendation. Recommendations are “unresolved” when the OIG determines that OJP did 

not concur with the recommendation. Recommendations are “closed” when the OIG 

determines that OJP concurred with the recommendation and provided documentation of the 

appropriate corrective action.

Resolution and 

Follow-up

OJP communicates with the audited grantee regarding the audit findings and corrective actions 

planned and completed. The Uniform Administrative Requirements, Cost Principals, and Audit 

Requirements for Federal Awards requires OJP to make a management decision that states 

whether the audit finding is sustained, the reasons for the decision, and the expected auditee 

action to repay disallowed costs, make financial adjustments, or take other action.b OJP then 

issues correspondence to the OIG reporting on its management decision and any corrective 

actions by the grant recipient and providing documentation for completed actions. Through 

this correspondence, OJP notifies the OIG when its staff believes the completed corrective 

actions are sufficient to resolve or close the recommendations. When the OIG concurs with 

the management decision, which typically occurs, it determines if the actions are sufficient to 

resolve or close the audit recommendations. The OIG objects to OJP management decision 

when it determines that the decision is contrary to law or policy or results in inefficiency or 

waste.

Closure The OIG issues correspondence to OJP closing individual recommendations based on its 

determination that the grant recipient’s corrective actions are appropriate, reasonable, and do 

not violate law, regulation, or administrative policy. When all recommendations in a report are 

closed, the OIG closes corrective action on the report as a whole.

a The generally accepted government auditing standards, commonly referred to as the “Yellow Book,” are 

issued by the U.S. Government Accountability Office. The standards apply to both financial and 

performance audits and provide a framework for conducting high-quality audits with competence, integrity, 

objectivity, and independence.

b 2 C.F.R. § 200.521 (2018). Prior to issuing the management decision, OJP may request additional 

information or documentation from the auditee, including a request for auditor assurance related to the 

documentation, as a way of mitigating disallowed costs.

Source: OIG
19

APPENDIX 3

OFFICE OF JUSTICE PROGRAMS’

RESPONSE TO THE DRAFT REPORT
20
21
22

APPENDIX 4

OFFICE OF THE INSPECTOR GENERAL ANALYSIS AND

SUMMARY OF ACTIONS NECESSARY TO CLOSE THE REPORT

The Office of the Inspector General (OIG) provided a draft of this report to the 

Office of Justice Programs (OJP). OJP’s response is incorporated in Appendix 3 of this 

final report. In response to our report, OJP agreed with all of our recommendations 

and discussed the actions it will implement in response to our findings. The following 

provides the OIG’s analysis of the response and summary of actions necessary to 

close the report.

Recommendations for OJP:

1. Periodically evaluate the timeliness and circumstances of grantees 

producing supporting documentation to remedy questioned costs and 

implement guidance or policy and proactive measures to better ensure 

grantees maintain proper and contemporaneous support for grant 

expenditures.

Resolved. OJP agreed with our recommendation and stated that the Office of 

Audit, Assessment, and Management (OAAM) will develop written policies and 

procedures for periodically analyzing grant audit findings and sharing the 

results with OJP offices. OJP also stated that it will use the results of this 

periodic analysis to inform Department of Justice (DOJ) grants financial 

management guidance for grant recipients and training offered by OJP’s Office 

of the Chief Financial Officer, as well as to enhance OJP programmatic and 

financial monitoring efforts.

This recommendation can be closed when we receive documentation of OJP’s

written policies and procedures for periodically analyzing grant audit findings 

and to ensure grantees maintain proper and contemporaneous support for 

grant expenditures.

2. Establish and communicate to each grant recipient time limits for 

providing requested supporting documentation depending on the 

complexity of the audit findings.

Resolved. OJP agreed with our recommendation and stated that OAAM will 

develop and implement written policies and procedures to ensure that OJP 

documents a corrective action plan approach, including an estimated timeline 

for fully addressing all corrective actions, upon initial review and analysis of 

each grantee audit report. OJP also stated that OAAM will coordinate the 

timeliness, which will vary depending on the complexity of the audit findings, 

with the grantee at the beginning of the audit follow-up process. OJP stated 

that the timelines will be documented and monitored in its audit follow-up 

correspondence.
23

This recommendation can be closed when we receive documentation of 

established time limits OJP communicated to grant recipients for providing 

requested supporting documentation depending on the complexity of the audit

findings.

3. Evaluate the risks posed by the proportion of unallowable questioned 

costs OJP retroactively approves, determine enhancements to its 

enforcement practices for unallowable questioned costs identified in 

audits and reviews, and periodically review grant terms for which OJP 

routinely approves deviations through Grant Adjustment Notices and 

retroactive approvals and identify strategies that better ensure grant 

recipients are spending grant funds for allowable purposes.

Resolved. OJP agreed with our recommendation and stated that OAAM will 

conduct an assessment of the circumstances under which OJP has retroactively 

approved costs in the past. OJP also stated that based on the results of the 

assessment, OJP will: (1) implement changes to current processes or 

practices to reduce the need for retroactive approvals, and (2) develop and 

implement guidance for circumstances when OJP will consider requests for 

retroactive approval.

This recommendation can be closed when we receive: (1) documentation of 

OJP’s assessment of the circumstances under which OJP retroactively approved 

costs in the past, (2) OJP’s developed and implemented changes to current 

processes or practices to reduce the need for retroactive approvals, and (3)

OJP’s guidance for circumstances when OJP will consider requests for 

retroactive approval.
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.

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oig.justice.gov @JusticeOIG JusticeOIG