DISCRETIONARY 

GRANTS

Education Needs to 

Improve Its Oversight 

of Grants Monitoring

Report to the Chairman, Committee on 

Health, Education, Labor, and Pensions, 

U.S. Senate

April 2017

GAO-17-266

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-266, a report to the 

Chairman, Committee on Health, Education, 

Labor, and Pensions, U.S. Senate

April 2017

DISCRETIONARY GRANTS

Education Needs to Improve Its Oversight of 

Grants Monitoring

What GAO Found

U.S. Department of Education (Education) grant staff did not consistently 

document in the official grant files key required monitoring activities, according to 

GAO’s review of a nongeneralizable sample of 75 discretionary grants. As a 

result, about $21 million in discretionary grant funds lacked correct 

documentation of grantee performance in the official grant files GAO reviewed. 

Specifically, compared to Education’s requirements for these files, almost all—69 

of 75—were incomplete in terms of certain key documents (i.e., grant award 

notifications, post-award conference records, and annual performance reports) 

that should have been contained in them (see figure). Further, the three principal 

offices GAO reviewed—the Offices of Postsecondary Education, Elementary and 

Secondary Education, and Innovation and Improvement—have not established 

detailed written procedures for the supervisory review of official grant files, 

contrary to federal internal control standards, which call for entities to provide 

reasonable assurance that internal control objectives, such as grant monitoring, 

are achieved and clearly documented. By developing and implementing detailed

supervisory review procedures for official grant files, Education would be better 

positioned to ensure the proper stewardship of its discretionary grants. 

Required Key Monitoring Documentation Found in the 75 Education Discretionary Official 

Grant Files Reviewed by GAO

Note: Number of documents expected is based on Education’s grant oversight policies.

Education spent about $700,000 to develop features within the Post-Award 

Monitoring (PAM) Module of its grants management system that allow staff to, for 

example, identify and share performance information to a central location, but it 

has not developed guidance on its effective use by grant staff working across 

programs and offices. Education described several ways staff share performance 

information, but according to a review of official grant files and interviews with 

Education officials, GAO found that staff rarely used PAM to disseminate 

information about grantee performance, such as notable results achieved in 

specific grant projects. Additionally, while Education officials said they offer staff 

training on PAM, they have not developed guidance to clarify use of features 

related to grantee performance. Federal internal control standards call for 

pertinent information, such as grantee performance information, to be identified, 

captured, and distributed in a form and time frame that permits people to perform 

their duties efficiently. Absent guidance on how to effectively use PAM Module 

features to share information about grantee performance, Education will likely not 

be able to achieve the full potential benefits of its grants management system. 

View GAO-17-266. For more information, 

contact Jacqueline M. Nowicki at (617) 788-

0580 or nowickij@gao.gov.

Why GAO Did This Study

In fiscal year 2015, Education awarded 

more than $4 billion to over 7,000 

grantees through some 80 

discretionary grant programs. Over the 

past decade, GAO and Education’s 

Inspector General identified various 

grants management and oversight 

challenges, including effectively 

monitoring grantee performance. GAO 

was asked to examine Education’s 

oversight of its discretionary grants. 

This report examines the extent to 

which Education: (1) consistently 

applied its discretionary grant 

monitoring policies, and (2) identified 

and shared across the department 

information about the performance of 

discretionary grantees. GAO reviewed 

the grant monitoring practices of three 

of Education’s seven principal offices, 

which together awarded more than 80 

percent of discretionary grant funds in 

fiscal year 2015, according to GAO’s 

review of Education data, the most 

recent data available. Additionally, 

GAO reviewed a randomly selected, 

nongeneralizable sample of 75 official

grant files; analyzed federal and 

Education grants policies and 

procedures; and interviewed Education 

grant officials and nine randomly 

selected grantees.

What GAO Recommends

GAO recommends Education establish 

and implement detailed written 

supervisory review procedures for 

official grant files and develop 

guidance for grant staff on using the 

PAM Module to share information. 

Education substantially agreed with 

both recommendations and described 

the procedures and training it will 

provide to implement them. 
Page i GAO-17-266 Education Discretionary Grants

Letter 1

Background 5

Official Grant Files for About $21 Million in Selected Discretionary 

Grants Lacked Complete Documentation of Grantee 

Performance, and Education Has No Written Grant File 

Supervisory Review Procedures 12

Education Created a Way to Identify and Share Grantee 

Performance Information Internally, but Has Not Developed 

Guidance to Help Ensure Its Effective Use by Grant Staff 17

Conclusions 21

Recommendations for Executive Action 22

Agency Comments and Our Evaluation 23

Appendix I Education’s Grant Staff Hiring Processes and Training 25

Appendix II Comments from the U.S. Department of Education 27

Appendix III GAO Contact and Staff Acknowledgments 30

Tables

Table 1: Education Discretionary Grant Obligations in Fiscal Year 

2015 8

Table 2: Use of the Post-Award Monitoring (PAM) Module by 

Education Grant Staff 19

Figures

Figure 1: Education Coordinating Structure (Including Offices 

Selected in GAO’s Review) 6

Figure 2: The Discretionary Grant Lifecycle 9

Figure 3: Key Post-Award Monitoring Activities for Education 

Multiyear Discretionary Grants 9

Figure 4: Education Post-Award Monitoring (PAM) Module Within 

Its G5 Grants Management System 18

Contents
Page ii GAO-17-266 Education Discretionary Grants

Abbreviations

Award Notice Grant Award Notification 

Education U.S. Department of Education 

G5 G5 grants management system 

Handbook Education’s Handbook for the Discretionary Grant

Process

OCFO Office of the Chief Financial Officer 

OESE Office of Elementary and Secondary Education 

OHR Office of Human Resources 

OIG Office of Inspector General 

OII Office of Innovation and Improvement 

OPE Office of Postsecondary Education 

PAM Module Post-Award Monitoring Module 

PDF portable document format 

RMS Risk Management Service

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

United States. The published product may be reproduced and distributed in its entirety 

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

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Page 1 GAO-17-266 Education Discretionary Grants

441 G St. N.W.

Washington, DC 20548

April 18, 2017

The Honorable Lamar Alexander

Chairman

Committee on Health, Education, Labor, and Pensions

United States Senate

Dear Mr. Chairman:

The U.S. Department of Education (Education) awards discretionary 

grants under a number of different statutory authorities for various 

purposes, such as to support projects to improve student achievement or 

to expand access to higher education for low-income and first generation 

students. In the last 10 years, the number and size of Education’s 

discretionary grant awards have increased considerably. In fiscal year 

2015, Education obligated more than $4 billion in awards for over 80 

discretionary grant programs and awarded more than 7,000 discretionary 

grants across the United States. As the number and size of Education’s 

grant awards have increased, GAO and Education’s Office of Inspector 

General (OIG) have reported on Education’s grants management and 

oversight challenges, including challenges related to effectively 

monitoring grantee performance, improving risk management, and 

sharing information about grantee performance across Education.1

In light of these challenges, you asked us to review Education’s oversight 

of its discretionary grant programs and grantees.

This report examines (1) the extent to which Education consistently 

applied its discretionary grants policies and procedures for monitoring 

grantees; and (2) the extent to which Education systematically identified 

and shared across the department information about the performance of 

discretionary grantees. In addition, we reviewed the ways in which 

Education hires and trains grant staff, which is included in appendix I.

 1

See, for example, GAO, Race to the Top: Education Could Better Support Grantees and 

Help Them Address Capacity Challenges, GAO-15-295 (Washington, D.C.: April 13, 

2015); Grant Monitoring: Department of Education Could Improve Its Processes with 

Greater Focus on Assessing Risks, Acquiring Financial Skills, and Sharing Information, 

GAO-10-57 (Washington, D.C.: Nov. 19, 2009); and Department of Education, Office of 

Inspector General, Education’s Process to Identify and Monitor High-Risk Grantees, EDOIG/I13K002 (Washington, D.C.: March 2012). 

Letter
Page 2 GAO-17-266 Education Discretionary Grants

To address these objectives, we reviewed three of Education’s seven 

principal offices that award discretionary grants—the Offices of 

Postsecondary Education (OPE), Elementary and Secondary Education 

(OESE), and Innovation and Improvement (OII). We selected these 

offices because they collectively awarded about 87 percent of Education’s 

discretionary grant funds awarded in fiscal year 2015—about $3.8 billion 

out of approximately $4.3 billion—according to our review of the most 

recently available Education data.2

We also reviewed relevant federal laws, regulations, policy, and guidance 

as well as agency documentation. 3 For instance, we reviewed 

Education’s Handbook for the Discretionary Grant Process (Handbook), 

which generally establishes the internal policies and procedures for 

discretionary grant management department-wide. 4 Additionally, we 

reviewed Education guidance on its grantee risk assessment process. 5

Further, to obtain information on how Education officials implemented 

discretionary grant monitoring policies and procedures in practice, hired 

and trained grant staff, and shared information about grantee 

 2

We reviewed Education data on discretionary grant awards made from fiscal years 2010 

through 2015, the most recent available at the time we did our work.

3

In December 2013, the Office of Management and Budget (OMB) consolidated several of 

its grants management circulars into a single document—the Uniform Administrative 

Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform 

Guidance). 78 Fed. Reg. 78,590 (Dec. 26, 2013) (codified as amended at 2 C.F.R. pt. 

200).These requirements apply broadly across the federal government to different types of 

grantees—including state, local, and tribal governments, institutions of higher education, 

and nonprofit organizations—and different types of grants. The Uniform Guidance is 

implemented through individual federal agency regulations, including Education 

regulations. See 79 Fed. Reg. 75,871 (Dec. 19, 2014) and 80 Fed. Reg. 67,261 (Nov. 2, 

2015). The Uniform Guidance requirements generally apply to new grant awards and 

certain continuation awards made on or after December 26, 2014. Grants made before 

that date, including some of those in the sample we reviewed, would be subject to the 

previous OMB circulars, as applicable.

4

According to Education officials, they revised their discretionary grant policies to comply 

with OMB’s Uniform Guidance and issued a new version of the Handbook in 2015. We 

reviewed the current version of Education’s Handbook as well as the prior version that 

was in effect from January 2009 through September 2015. For reporting purposes, unless 

otherwise indicated, we refer to the 2015 version of the Handbook. However, because our 

grant file review included grants that were awarded prior to the issuance of the 2015 

Handbook, we ensured that the monitoring requirements we reviewed were included in 

both versions.

5

U.S. Department of Education, Risk Management Service, ED Entity Risk Review 

Guidance, (Washington, D.C.: Dec. 2015).
Page 3 GAO-17-266 Education Discretionary Grants

performance across offices, we interviewed officials from our three 

selected principal offices, including program specialists who most directly 

interact with grantees. We also interviewed officials from Education’s Risk 

Management Service, Office of the Chief Financial Officer, and Office of 

Human Resources, who provide guidance and support to principal offices. 

We compared the information obtained through interviews to Education’s 

Handbook, and also reviewed federal internal control standards 6 and 

leading grants management practices, as appropriate. 7

To determine whether Education consistently applied its grants policies 

and procedures for monitoring discretionary grantees, we also reviewed a 

nongeneralizable sample of 75 official grant files. 8 To select our sample, 

we first reviewed data Education provided from its G5 grants 

management system (G5) about all discretionary grant awards made from 

fiscal years 2010 through 2015, the most recent data available at the time 

we conducted our review. The data included information specific to each 

grant award, such as the recipient name, amount awarded, and the award 

type. It also identified the Education office responsible for the award and if 

Education awarded the funds as a cooperative agreement. Cooperative 

agreements entail a substantial level of involvement between the 

awarding federal agency and the recipient, and comprise a minority of 

Education’s discretionary awards. 9 For these reasons, we excluded 

cooperative agreements from our review. Second, using the G5 data, we 

randomly selected grants from a pool of recipients that received new 

discretionary awards made in fiscal year 2012. Doing so allowed us to 

review up to 3 years of grant file monitoring documentation, where 

 6

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

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

7

See, for example, Domestic Working Group, Guide to Opportunities for Improving Grant 

Accountability (October 2005), available at https://www.ignet.gov/content/reportspublications.

8

The Handbook requires grant staff to maintain an official grant file for all discretionary 

grantees. Our review of these files focused specifically on the post-award phase of the 

grant lifecycle—when Education staff monitor grantees as they implement their projects—

rather than on the pre-award phase when Education competitively selects grantees. We 

focused our review primarily on monitoring documentation that discussed the terms and 

conditions of the award, and grantees’ progress in achieving the aims and objectives of 

their projects. We did not review Education’s fiscal oversight of grantee expenditures. 

9

Both cooperative agreements and grants provide funding to carry out approved federal 

activities, but a cooperative agreement involves substantial programmatic involvement 

between the federal agency and the recipient in carrying out the activity contemplated by 

the federal award. See 31 U.S.C. § 6305.
Page 4 GAO-17-266 Education Discretionary Grants

applicable. We reviewed a total of 75 official grant files—40 from OPE, 25 

from OESE, and 10 from OII—that totaled about $272 million in 

discretionary grant awards made by Education over the period of our 

review. 10 Our sample is nongeneralizable and the number of grants we 

reviewed from each office was in proportion to the total number of grant 

awards made by each office in fiscal year 2012.

As part of this effort, we also interviewed 9 of the 75 selected grantees to 

obtain their perspectives on Education’s monitoring of their grant projects. 

To do so, we randomly selected 3 grantees from each of the three 

principal offices in our review. We determined that the G5 data are 

sufficiently reliable for the purposes of this report by reviewing 

documentation about the G5 system and interviewing agency officials. 

While the results of our grant file review and grantee interviews are not 

generalizable, they provide insight into Education’s monitoring of 

discretionary grantees.

To review each grant file in our sample, using Education’s requirements 

in the Handbook for the organization and content of official grant files, we 

developed a data collection instrument to assess whether the files 

contained documentation that grant staff performed various grantee 

monitoring activities. 11 Where certain key monitoring documents should 

have been present for each and every grantee—for example, the 

performance reports grantees are required to submit at the end of each 

budget period12—we determined whether those documents were present 

in the official file. In other instances, Education requires in its Handbook

that grant staff document activities, such as regular telephone contacts, email correspondence, and site visits, as appropriate. In these instances, 

 10Our period of review of the selected official grant files generally spanned calendar years 

2012 through 2014. However, given the variability in when grant projects begin and end, 

our review extended into calendar year 2015 in some cases.

11In conducting the grant file review, we considered only those documents Education 

made available to us in response to our request to review the complete official grant files. 

We did not attempt to determine whether any of the records might exist elsewhere, as the 

purpose of this work was to assess the completeness of the official grant files, consistent 

with the requirements in Education’s Handbook.

12A “budget period” is the interval of time into which a grant project period is divided for 

budgetary purposes, usually 12 months. Unless otherwise indicated, in this report we use 

the grant terminology and definitions as described in the 2015 Handbook or Education’s 

non-technical guidance document summarizing its discretionary grant process. See 

Department of Education, Grantmaking at ED: Answers to Your Questions About the 

Discretionary Grants Process, Washington, D.C., August, 2015.
Page 5 GAO-17-266 Education Discretionary Grants

we confirmed, for example, the absence or presence of routine 

correspondence in the official files. Two analysts reviewed each file, with 

the second analyst verifying the first analyst’s review.

We conducted this performance audit from September 2015 to April 2017 

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 the 

evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

Education has seven principal offices that administer discretionary grants 

to entities that provide education or education-related services (see fig. 

1). These principal offices generally focus on specific areas of education, 

such as career, technical, and adult education; elementary and secondary 

education; or postsecondary education. Each principal office has 

individual program offices responsible for specific grant programs. 

Program offices have directors, supervisors, and program specialists 

(referred to in this report as grant staff) responsible for grant 

administration.

Department-wide offices—the Risk Management Service (RMS), Office of 

the Chief Financial Officer (OCFO), and Office of Human Resources 

(OHR)—provide support and guidance to the principal offices. RMS, in 

particular, is responsible for effectively communicating discretionary grant 

policies to principal offices and providing guidance to assist them in their 

efforts to adhere to those policies. Additionally, RMS offers training on 

discretionary grants to staff across the department. OCFO, among other 

things, resolves discretionary grant award findings resulting from single 

audit reports and offers training on financial aspects of grants 

Background

Department of Education
Page 6 GAO-17-266 Education Discretionary Grants

administration. 13 OHR works with principal offices to identify staffing 

needs and to post job positions, among other responsibilities.

Figure 1: Education Coordinating Structure (Including Offices Selected in GAO’s Review)

 13The Single Audit Act, as amended, and as implemented by OMB, generally requires 

each nonfederal entity that expends a total amount of federal awards equal to or in excess 

of a specified threshold in a fiscal year to have a single audit. From 2004 to 2014, the 

threshold was $500,000. The Uniform Guidance, effective for grantees on December 26, 

2014, increased the threshold to $750,000. Single audits evaluate the use of federal funds 

and help provide federal agencies with information to fulfill their oversight responsibility for 

the funds that they award to non-federal entities.
Page 7 GAO-17-266 Education Discretionary Grants

Discretionary grants refer to an award for which the awarding agency has 

discretion, or choice, in deciding which applicants receive funding. 14

Education generally awards these types of grants through a competitive 

process. 15 Grant project periods can vary in duration, ranging from less 

than a year to 5 years. 16 When Education funds grants with project 

periods longer than a year (referred to in this report as multiyear grants), 

it generally funds the grants in annual increments called budget periods, 

usually 12 months. With multiyear grants, grantees are generally eligible 

to receive funding beyond the initial budget period provided certain 

conditions are met; for example, Education must determine that a grantee 

has made substantial progress toward the project’s goals and objectives, 

and Congress must have appropriated sufficient funds, among other 

conditions. 17 Award amounts can vary widely. For example, in 2012 

Education awarded a grantee $27,315 to help subsidize fees for lowincome students registering for Advanced Placement and International 

Baccalaureate tests, and in the same year, Education awarded another 

grantee about $5 million to support professional development for teachers 

and school administrators. In fiscal year 2015, Education awarded about 

$4.3 billion in discretionary grants across its seven principal offices (see 

table 1).

 14Congress generally creates discretionary grant programs through authorizing statutes 

and provides funding for the programs through annual appropriations acts. Education may 

also establish program regulations that set forth how its programs are to be administered 

and may include criteria for the review of applications. In addition, Education’s 

discretionary grant programs are also governed by applicable Education Department 

General Administrative Regulations, and OMB’s Uniform Guidance (or OMB’s previous 

grants management circulars).

15Education also awards formula grants. Formula grants are grants that Education is 

directed by statute to make to grantees, and for which the amount is established by a 

formula based on criteria in the statute and program regulations. Formula grants were 

outside the scope of this review. 

16Under 34 C.F.R. § 75.250, Education may fund a project for up to 5 years unless a 

program statute or regulation provides for a longer project period.

1734 C.F.R. § 75.253. These awards for subsequent budget periods are called 

continuation awards. In some cases, Education may award funding for an entire project 

period (i.e., all budget periods in the grant) at the time the initial award is made, rather 

than in separate awards for each budget period. 

Education’s Discretionary 

Grants
Page 8 GAO-17-266 Education Discretionary Grants

Table 1: Education Discretionary Grant Obligations in Fiscal Year 2015

Principal office Total obligated amount 

(rounded to nearest dollar)

Office of Postsecondary Education 2,075,701,737

Office of Innovation and Improvement 935,830,862

Office of Elementary and Secondary Education 780,678,874

Institute of Education Sciences 237,414,981

Office of Special Education and Rehabilitative 

Services

220,437,318

Office of English Language Acquisition 46,178,402

Office of Career, Technical, and Adult Education 33,779,514

Total 4,330,021,687

Source: GAO analysis of U.S. Department of Education (Education) data.  | GAO-17-266

Note: The total obligated amounts shown in this table include new awards, continuation awards, and 

supplemental awards.

The lifecycle of a discretionary grant has three general phases: preaward, award, and post-award (see fig. 2).18 The Handbook establishes 

department-wide policies and procedures for each phase. For example, in 

the award phase, the Handbook describes policies for notifying grantees 

about their awards.

 18For the purposes of this report, we focused on the post-award phase of a grant’s 

lifecycle. The Education OIG and GAO have reviewed pre-award and award activities. 

See, for example, Department of Education, Office of Inspector General, The Office of 

Elementary and Secondary Education’s Process of Awarding Discretionary Grants, EDOIG/A03M0002 (Washington, D.C.: Aug. 12, 2013) and GAO, Education Grants: Promise 

Neighborhoods Promotes Collaboration but Needs National Evaluation Plan, GAO-14-432 

(Washington, D.C.: May 5, 2014).

Grant Lifecycle
Page 9 GAO-17-266 Education Discretionary Grants

Figure 2: The Discretionary Grant Lifecycle

During the post-award phase, the Handbook establishes specific 

monitoring activities Education grant staff should perform, and requires 

grant staff to document these activities in the official file they are to keep 

for each grantee, which may be paper-based or electronic (see fig. 3). For 

example, all grant files should include the following three key documents: 

grant award notifications, post-award conference records, and grantee 

performance reports. As we describe below, the purpose of these 

documents is to record information on various key monitoring activities.

Figure 3: Key Post-Award Monitoring Activities for Education Multiyear Discretionary Grants

• Grant award notification. According to the Handbook, Education’s 

grant staff are to send all discretionary grantees a grant award 

notification (referred to in this report as an award notice) that provides 

details about the grant, including the amount of the award; the binding 

terms and conditions of the grant, including statutory and regulatory 

Post-award: Grantee 

Monitoring Activities
Page 10 GAO-17-266 Education Discretionary Grants

requirements; and any specific conditions.19 For example, as a 

specific condition, a grantee may be required to seek reimbursements 

from Education for grant-related expenditures (referred to in the 

Handbook as “cost reimbursement”), or may be prohibited from 

proceeding with its project until Education receives satisfactory 

evidence of acceptable performance. If Education later assigns 

specific conditions, grant staff are to amend the award notice and 

resend it to the grantee, according to the Handbook. Additionally, the 

Handbook specifies that grant staff should save copies of award 

notices, as well as amended versions, if applicable, to include in the 

grantee’s official grant file.

• Post-award conference records. According to the Handbook, the postaward conference is the initial discussion between Education’s grant 

staff responsible for monitoring the grant and the grantee’s project 

director or other authorized representative. The Handbook specifies 

that this meeting should take place within 30 days of the award to 

establish a mutual understanding of the specific outcomes that are 

expected, and to clarify measures and targets for assessing the 

project’s progress and results, among other things. This meeting may 

take place in-person, via telephone or e-mail, or as part of a virtual or 

in-person conference. Following the discussion, grant staff are to 

document that a meeting occurred and should also save any related 

notes from the discussion to the official grant file, according to the 

Handbook.

• Calls, site visits, technical assistance to grantees (as needed).

According to the Handbook, certain day-to-day activities that occur or 

apply (as needed) to the particular circumstances of a grantee must 

be documented in the official grant file. These activities include, 

among other things, routine telephone or e-mail correspondence; 

reports from a site visit by Education staff; and, if relevant, contracts 

into which a grantee may have entered as a condition of receiving the 

grant (e.g., a contract for a rigorous post-grant evaluation of a pilot 

project). Grant staff can adjust the scope and frequency of these 

activities using their professional judgment, according to grant staff 

supervisors. When making these determinations, grant staff may 

consider various factors, such as the amount awarded; past grantee 

 19See 34 C.F.R. §§ 75.234-75.235. Education may assign specific conditions under 

certain circumstances, including those specified in 2 C.F.R. § 200.207, or if the agency 

determines specific conditions are necessary to protect the federal government’s interest; 

reduce the risk of noncompliance; or help ensure a grantee is successful in implementing 

its project, according to the Handbook. 
Page 11 GAO-17-266 Education Discretionary Grants

performance, if applicable; and any reported problems by the grantee 

or requests for specific assistance.

• Performance reports. Education requires discretionary grantees to 

submit reports that describe the specific activities they performed 

during a budget period.20 Education encourages grantees to use a 

standardized form to submit these reports. Using this form, grantees 

can describe work and activities completed, as well as progress made 

toward their project’s goals and objectives. Recipients of multiyear 

discretionary grants must generally submit these reports annually. 

According to the Handbook, grant staff are to review these reports—

along with other information on financial and project management 

activities—to determine, among other things, if the grantee has made 

substantial progress in reaching the project’s objectives and if 

continuing the project is in the best interest of the federal 

government.21 Additionally, grant staff must sign and date these 

reports to indicate their review and save them to the official grant file, 

according to the Handbook. 22

Discretionary grant recipients and grant staff are to use Education’s G5 

web-based grants management system to perform various activities 

throughout the grant lifecycle. For instance, grantees are to use G5 to 

withdraw funds from their grant accounts during the post-award phase, 

and can also use the system to submit required performance reports. G5 

is the grant staff’s primary tool for providing fiscal oversight of 

discretionary grantees, according to the Handbook. For instance, using 

G5, grant staff can monitor the rate at which grantees withdraw funds 

from their grant accounts to ensure their spending patterns are consistent 

with the project’s approved scope of work and project milestones. 

Education officials told us it added a Post-Award Monitoring (PAM) 

Module to G5 in 2013 that allows grant staff to enter information on the 

performance of the grantees they monitor to a central location, among 

other things.

 20See 2 C.F.R. § 200.328 and 34 C.F.R. § 75.720(a)(2). 

21As previously mentioned, continuation funding is to be awarded only if the requirements 

in 34 C.F.R. § 75.253 are met.

22The Handbook also allows grant staff to include a note to the official grant file indicating 

that they have reviewed and approved the required report instead of signing and dating 

the report itself. 

G5 Grants Management 

System
Page 12 GAO-17-266 Education Discretionary Grants

The sample of official grant files we reviewed did not consistently contain 

documentation of certain key required monitoring activities outlined in 

Education’s Handbook. Specifically, almost all—69 of the 75 grant files 

we reviewed—were incomplete; most were missing at least one award 

notice, post-award conference record, or grantee performance report, 

which are all key monitoring documents that should be included in the 

official files, according to the Handbook.23 Federal internal control 

standards call for the clear, prompt, and accurate documentation of 

internal control and all other significant events, including monitoring 

activities, and state that this documentation should be readily available for 

examination. 24

 23The monitoring documents we looked for during our grant file review included: (1) award 

notices, (2) post-award conference records, and (3) grantee performance reports. Based 

on discussions with Education staff about Handbook requirements and our review of the 

Handbook grant monitoring requirements and Education data, we determined that our 75 

selected grant files should contain: 175 award notices and 179 performance reports—

because many of the selected grant files were for multiyear grants and should contain 

multiple award notices and performance reports—and 75 post-award conference records, 

according to the Handbook. 

24GAO/AIMD-00-21.3.1

Official Grant Files for 

About $21 Million in 

Selected 

Discretionary Grants

Lacked Complete 

Documentation of 

Grantee 

Performance, and 

Education Has No 

Written Grant File 

Supervisory Review 

Procedures

Official Grant Files We 

Reviewed Did Not 

Consistently Contain Key 

Monitoring Documenation
Page 13 GAO-17-266 Education Discretionary Grants

More specifically, with respect to grantee performance reports, based on 

our analysis and the requirements outlined in the Handbook, the 75 

official grant files should have contained 179 performance reports. We 

found 121, which is 58 less than required by the Handbook. In these 58 

instances—associated with 54 of the 75 grant files we reviewed—about 

$21 million in discretionary grant awards lacked complete and correct 

documentation in the official grant file of the progress and results 

grantees achieved. 25 As a result, and contrary to federal internal control 

standards, we could not, using the official grant files Education provided 

to us, verify the existence of documentation that would demonstrate 

whether these grantees achieved the results for which they received grant 

funds or made adequate progress that would warrant receiving additional 

funds.26

In commenting on a draft of this report, Education reiterated its reliance 

on a variety of safeguards and monitoring procedures (discussed below) 

to ensure it provides additional funding only to grantees that achieve 

substantial progress with their grant funds and comply with applicable 

regulations. Education also stated that it conducted its own review and 

found all the appropriate performance reports, though some were found 

outside of the official grant files or in other Education systems, and the 

agency is therefore confident that no funds were at risk. We note that the 

focus of our file review was on Education’s application of the 

documentation requirements for official grant files included in its 

Handbook. Our analysis was not designed or intended to determine 

 25The approximately $21 million in discretionary grant awards that lacked complete and 

correct documentation is likely higher because two of our selected grants had received a 

single multiyear grant award, but performance reports covering one or more budget 

periods had not been included in the official grant file. Because the amount expended by 

these grantees may have varied by budget period, we could not determine specific 

amounts associated with the budget periods for which a performance report had not been 

included in the file. Therefore, we excluded the value of these two grants from the $21 

million calculation because we were not able to determine how much money was 

associated with the missing documentation.

26About $17.5 million of this approximately $21 million consists of initial and continuation 

awards for multiyear grants whose official grant files did not include the annual 

performance reports that describe the progress the grantees had achieved over the prior 

budget period and that inform Education’s decision about whether to continue funding the 

project. The remaining about $3 million consists of those grants whose files did not include 

the grantees’ final performance reports. These reports describe the results these grantees 

had achieved with the grant funds. For purposes of this calculation, we added the 

applicable award amounts for all grant files that were missing an annual or final 

performance report; we did not include the award amounts for grant files that were missing 

only an award notice or missing only a post-award conference record.
Page 14 GAO-17-266 Education Discretionary Grants

whether any discretionary grant funds are “at risk” or were awarded 

improperly. 

Additional required monitoring documentation—describing the terms and 

conditions of the grant, as well as general expectations of Education’s 

grant monitoring staff—were also often not included in the official grant 

files we reviewed. Specifically:

• Grant Award Notifications. Per Education’s Handbook, the 75 official 

grant files we reviewed should have contained 175 award notices, but 

we found 132, which was 43 less than required. Because award 

notices include the binding terms and conditions of the grant during 

each budget period, including statutory and regulatory requirements, 

as well as any specific conditions, they are important documents for 

grant staff to be familiar with and to easily reference as they monitor 

grantees to ensure they are in full compliance with the terms and 

conditions of the award.

• Post-award conference records. We found 27 of the 75 records that 

should have been contained in the official grant files we reviewed—48 

less than required by the Handbook. Education states in its publicly 

available guidance that these discussions are the first step in building 

a successful partnership between the department and the grantee to 

help ensure successful project outcomes.27 In the instances where we 

identified that grant staff did not document in the official grant file that 

these meetings occurred, we could not, therefore, verify whether grant 

staff and grantees established a mutual understanding of the specific 

outcomes Education expects from the grant projects, or clarified 

measures and targets it will use to assess the grantees’ progress and 

results.

Regarding day-to-day activities, such as telephone calls with and e-mail 

correspondence to or from grantees, we generally found evidence that 

these had been documented in the 75 official grant files we reviewed.

Grant staff supervisors we interviewed told us that missing documentation 

from the official grant files does not mean monitoring activities did not 

occur—or that grantees did not submit required documentation such as 

performance reports. Grant staff supervisors said that grant staffs’ heavy 

workload sometimes prevents them from saving grantee monitoring 

 27Department of Education, Grantmaking at ED: Answers to Your Questions About the 

Discretionary Grants Process, (Washington, D.C., August 2015). 
Page 15 GAO-17-266 Education Discretionary Grants

documentation to the official grant file in a timely manner. One supervisor 

noted specifically that grantees may send hard copies of their 

performance reports in April each year, but that these may not be saved 

to the official grant file until the following September because of 

competing demands. Additionally, during the time of our review, 

Education officials said they were enhancing G5 and that grant staff were 

in the process of transitioning from their previous systems. During this 

transition period, they said remnants of the old systems were used 

alongside the new system because creating electronic documents proved 

to be an onerous task, leading to the use of an official grant file and a 

working file. Going forward, Education stated that there is a need to 

consolidate to one official grant file within G5.

At the same time, grant staff supervisors said there are various 

safeguards in place that help prevent continuation awards from being 

made to grantees that do not demonstrate substantial progress. 

Specifically, they said grant staff cannot independently decide to make 

continuation awards. Instead, grant staff must prepare a Continuation 

Award Memo documenting that they have evaluated the project for 

substantial progress during the budget period against the project’s aims 

and objectives, and recommend whether Education should continue to 

fund that project.28 These officials said grant staff are to submit this memo 

to principal office management for review before a continuation award 

can be made.29 Education refers to these steps as the slate review 

process. 

Education officials said that these safeguards, as well as others—such as 

conducting grantee risk and performance reviews—help to ensure that no 

continuation funds are provided to grantees who fail to comply with grant 

requirements or who do not show substantial progress.

30 Nonetheless, 

 28The process of preparing Continuation Award Memos to document that grantees have 

adequately demonstrated substantial progress is not documented in the Handbook. 

29There is no Handbook requirement specifying that grant staff should include these 

memos in the official grant file.

30According to Education officials, some of these other safeguards include: (1) risk and 

performance reviews, using Education’s Entity Risk Review process and government-wide 

databases such as the System for Award Management and the Federal Awardee 

Performance and Integrity Information System; (2) automatic checks and notifications for 

risk issues in G5, including excessive drawdown and audit findings notifications; and (3) 

verification by Education staff authorized to obligate and award grant funds that the 

grantee has submitted required reports and has achieved substantial progress.
Page 16 GAO-17-266 Education Discretionary Grants

without monitoring documentation, such as grantee performance reports, 

and saving this documentation to the official grant file, Education cannot 

readily produce, and we were hence unable to verify, the evidence 

underpinning the grant staffs’ assessment of substantial progress, which 

informs the department’s continued funding of the projects.

Grant staff supervisors with whom we spoke said they periodically review 

official grant files to help ensure staff perform and document key 

monitoring activities, but we found little evidence within the official grant 

files we reviewed of this being done. Specifically, grant staff supervisors 

in our three selected offices said they review a random sample of official 

grant files twice per year—once at grant staff mid-point evaluations and 

once at their annual evaluations. The number of files they review varies 

depending on factors such as the number of staff they manage, the 

complexity of the grant programs in their portfolio, and the number of 

awards made as part of each grant program, according to grant staff 

supervisors. Additionally, they said they can also review individual official 

grant files at any point as needed. During our review of 75 official grant 

files, we found two documented instances that showed a grant staff 

supervisor reviewed a grant file for completeness in terms of ensuring all 

required documentation was included in the file.

Principal offices have not established written procedures with enough 

detail for grant staff supervisors to know how frequently to review official 

grant files nor what, specifically, the review should entail. Grant staff 

supervisors in our selected principal offices said they rely on the 

Handbook to guide them as they conduct these reviews, but beyond 

specifying that grant staff supervisors should routinely review official grant 

files, the Handbook—issued by RMS—contains few specifics on what 

these reviews should entail. For instance, it does not establish what 

portion of official grant files staff supervisors should review, how often 

these reviews should occur, and whether to document in the official grant 

file, G5, or anywhere else that the reviews occurred. Federal internal 

control standards state that entities should provide continuous 

supervision to provide reasonable assurance that internal control 

objectives are achieved, and that internal control activities and 

transactions be clearly documented. 31

 31GAO/AIMD-00-21.3.1.

Grant Staff Supervisors 

Did Not Routinely Review 

All Grant Files We 

Selected, and Principal 

Offices Have Not 

Established Written 

Procedures to Help 

Ensure They Do
Page 17 GAO-17-266 Education Discretionary Grants

Because the Handbook does not include detailed, written procedures for

how grant staff supervisors should review official grant files to ensure 

grant staff performs and documents required monitoring activities, 

supervisors may not have a clear understanding of what these reviews 

should entail, including the expected scope and frequency of review. 

Thoroughly reviewing official grant files is particularly important given our 

findings that key monitoring documents had not consistently been 

included in the 75 official grant files we reviewed. Without these 

monitoring records, Education may not be able to readily demonstrate the 

results that grantees achieved, or that grantees implemented their 

projects according to the terms and conditions of the award. Additionally, 

absent documented monitoring records, when monitoring responsibilities 

shift from one grant staff person to another—such as when employees 

retire, resign, or otherwise change positions—the new grant staff person 

may not have all the information required to continue effectively 

monitoring those grantees. Written procedures that detail requirements 

for the supervisory review of official grant files could enhance Education’s 

ability to hold grant staff supervisors accountable for ensuring their grant 

staff adhere to the monitoring and documentation requirements and help 

the department be better positioned to ensure proper stewardship of its 

federal discretionary grants.

Education developed features within G5 that allow grant staff to 

systematically maintain, organize, identify, and share information about 

grants and grantees in a central location. In 2013, Education spent about 

$700,000 to develop the G5 Post-Award Monitoring (PAM) Module, 

according to officials with whom we spoke. The system consists of eight 

features, or tabs, grant staff can choose to use when monitoring grantees 

(see fig. 4). Two of these features, the “Issues” and “Notable Results”

tabs, allow grant staff to identify and share across the department 

performance information about grantees they monitor, according to 

Education officials. This could include disseminating notable results and 

lessons learned from the grant projects they monitor or to alert other grant 

staff of potential performance issues.

Education Created a 

Way to Identify and 

Share Grantee 

Performance 

Information Internally, 

but Has Not 

Developed Guidance 

to Help Ensure Its

Effective Use by 

Grant Staff
Page 18 GAO-17-266 Education Discretionary Grants

Figure 4: Education Post-Award Monitoring (PAM) Module Within Its G5 Grants Management System

Based on our review of official grant files, staff consistently used some, 

but not all, of the voluntary PAM Module features when monitoring 

grantees. Specifically, in our review of 61 electronic grant files,32 we 

found grant staff consistently used four tabs, including the “Finances” and 

“Award Details” tabs, but they rarely used others, such as the 

“Objectives,” “Issues,” and “Notable Results” tabs (see table 2). 33 With the 

“Issues” tab in particular, grant staff noted performance issues in 7 of the 

61 electronic grant files we reviewed. In 4 of these 7 grant files, staff 

indicated that grantees had large available balances remaining at the end 

 32Of the 75 Education official grant files we reviewed, 61 were electronic and 14 were 

paper files. Education officials said grant staff do not generally use the PAM Module for 

paper-based files, and thus the 14 paper grant files were excluded from this analysis. 

33RMS officials said Education is currently evaluating the usefulness of the “Objectives”

tab given that the project objectives and performance measures associated with the grant 

are supposed to be already included elsewhere in the grant file.
Page 19 GAO-17-266 Education Discretionary Grants

of the budget period, which could indicate non-performance or financial 

mismanagement, according to the Handbook. The remaining 3 files cited 

other potential performance challenges, including noncompliance with 

specific conditions Education had imposed on a grantee, a decision to 

place a grantee on cost reimbursement, and frequent changes in key 

grant project personnel. 34 In none of the 61 electronic official grant files 

we reviewed did grant staff enter information in the PAM Module about 

notable results of specific grant projects they monitored.

Table 2: Use of the Post-Award Monitoring (PAM) Module by Education Grant Staff

PAM Module Tabs Office of Postsecondary 

Education (out of 40 electronic 

files)

Office of Elementary and 

Secondary Education (out of 

17 electronic files)

Office of Innovation and 

Improvement (out of 4 

electronic files)

Number of grant files that used each tab

Award Details 40 17 4

Recipient 40 17 4

Grant File 40 17 4

Issues 1 4 2

Objectives 0 0 0

Notable Results 0 0 0

Finances 40 17 4

Source: GAO analysis of 61 selected U.S. Department of Education (Education) official grant files. | GAO-17-266

Note: The PAM Module, part of Education’s G5 grants management system, has eight tabs in total. 

We did not review information contained in the “Unofficial Notes” tab as, according to Education 

officials, this is where grant staff can make informal notes or reminders and is not considered part of 

the official grant file.

Education does not require staff to use the PAM Module to share 

information about grantees, and noted that the PAM Module is one of 

several means available to its staff to capture and share grantee 

information.

35 Education officials stated that due to the lack of consistency 

 34Placing a grantee on cost reimbursement is a specific condition that requires the grantee 

to submit receipts for expenditures, so that Education releases payment only if it approves 

these costs, according to the Handbook.

35Education officials provided examples of ways in which information about grantees is 

shared across offices outside the PAM Module. For instance, within its G5 grants 

management system, though outside the PAM Module specifically, Education officials said 

they share information on grantee high-risk designations, suspended or debarred grants, 

and grants that were closed in non-compliance. Additionally, they said RMS provides all 

offices Entity Risk Review reports to share up-to-date information about continuing 

grantees and applicants.
Page 20 GAO-17-266 Education Discretionary Grants

in program statutes and regulations regarding grant administration, 

offices’ varying workloads and resources, and their differing rates of 

transition to electronic record-keeping, the PAM Module tabs are 

interpreted and implemented in ways that make sense for each office.

That said, RMS officials told us that the information grant staff enter in the 

“Issues” and “Notable Results” tabs could be useful to inform their 

grantee risk assessment process, but also said it is up to principal offices 

to clarify whether their staff should use these features as they monitor 

grantees.

One potential benefit of the PAM Module is that it allows RMS to collect 

data on grantee performance from a central location, according to RMS 

officials. Currently, they said grantee performance information is primarily 

contained in annual performance reports, which staff generally saves to 

individual grant files in a portable document format (PDF). As a result, 

RMS cannot easily access or aggregate the information to potentially 

identify wider performance issues or possible best practices, according to 

officials with whom we spoke. In particular, RMS officials said they would 

like to use grantee performance information to inform their Entity Risk 

Review process. Developed in 2010, Entity Risk Review is an analysis 

tool RMS officials use to provide program offices with information about 

the risks associated with continuing grantees and applicants. As part of 

this process, RMS consolidates information, such as details about past 

grantee performance, if applicable; financial information about the grantee 

organization; and relevant single audit findings to develop a risk profile for 

continuing grantees and applicants relative to three risk categories—

administrative, financial, and internal controls, which is then shared with 

principal and program offices, according to RMS officials. 36

However, RMS has not taken steps to help ensure that the information 

grant staff enters in the PAM Module about grantee performance will be 

useable. Specifically, since the PAM Module was implemented in 2013, 

RMS officials said grant staff have been inconsistently interpreting key 

terminology like “issues” and “notable results.” While RMS officials said 

they offer grant staff training on the PAM Module, due to competing 

priorities, they have not developed guidance to clarify what information 

 36For more information on Education’s Entity Risk Review process, see, for example, IBM 

Center for the Business of Government, Risk Management for Grants Administration: A 

Case Study of the Department of Education (Washington, D.C., 2015), and Department of 

Education, Office of Inspector General, The Department of Education’s Process to Identify 

and Monitor High-Risk Grantees ED-OIG/I13K0002 (Washington, D.C.: March 2012).
Page 21 GAO-17-266 Education Discretionary Grants

grant staff should enter into the PAM Module related to the “Issues” and 

“Notable Results” tabs, specifically, nor circumstances under which using 

the PAM Module might be an effective means to share information.

Federal internal control standards state that pertinent information should 

be identified, captured, and distributed in a form and time frame that 

permits people to perform their duties efficiently. 37 Without guidance to 

help grant staff enter consistent information about grantee performance 

across Education’s principal and program offices, RMS may not be able 

to realize the full potential of its grants management system.

Additionally, according to RMS officials, not all offices use the PAM 

Module because some program offices have not yet fully transitioned 

from paper-based to electronic grant files. RMS officials said Education is 

currently moving toward fully electronic grant administration, but it has not 

established a time frame for when it will complete this transition. Of the 

three principal offices we reviewed, OPE and OESE officials said they 

use electronic grant files, whereas OII officials said they still mainly use 

paper-based files, though they are transitioning to electronic. An OII grant 

staff member we interviewed noted that the PAM Module may be a good 

vehicle to share information about grantee performance, but also said OII 

staff were not familiar with it given their current reliance on paper files.

The Department of Education’s more than 80 discretionary grant 

programs are one of the foundational tools for achieving its mission of 

increasing student achievement. However, Education’s ability to 

adequately assess the results of its grant monitoring activities, 

demonstrate good stewardship of its limited resources, and show results 

grantees achieved—using its billions in discretionary grant funds—may 

be diminished when it does not routinely ensure that its grant staff review 

and document in the official grant files the results grantees achieve with 

federal funds. During our review of 75 official grant files, we could not 

locate documentation describing the results grantees had achieved with 

about $21 million in discretionary grant awards—about 8 percent of the 

award funds associated with our nongeneralizable sample of 75 files. 

When these documents are not included in the official grant files, 

Education cannot readily demonstrate—in the manner called for by 

federal internal control standards and its own Handbook—that grant funds 

were expended according to the terms and conditions of the award, 

 37GAO/AIMD-00-21.3.1.

Conclusions
Page 22 GAO-17-266 Education Discretionary Grants

including any specific conditions, or what grantees achieved with the 

funds. Absent detailed written procedures for the supervisory review of 

official grant files, these issues may persist. By describing in detail what it 

expects grant staff supervisors to do, Education would be better 

positioned to ensure proper and consistent stewardship of its 

discretionary grant funds. 

 

Education invested time and resources to develop features in G5 that 

allow grant staff to routinely identify and share information about grantee 

performance as part of their monitoring efforts. As Education continues to 

move toward agency-wide adoption of its electronic G5 grants 

administration system, using a centralized approach, such as G5’s PAM 

Module, to gather this information could provide Education opportunities 

to share information about grantee performance across programs and 

offices. If grant staff consistently noted performance issues in the PAM 

Module, such as whether a particular grantee was placed on cost 

reimbursement, RMS would have a central, easily accessible location 

from which to incorporate this information into its grantee risk assessment 

process. By doing so, all program offices would benefit by having the 

most current information on the risks associated with specific grantees 

before making new or continuation awards. This is particularly true given 

that some entities may receive discretionary grants from more than one of 

Education’s principal offices. However, RMS has not developed guidance 

on the types of information grant staff should enter into the PAM Module 

related to the “Issues” and “Notable Results” tabs, specifically, nor 

circumstances under which using the PAM Module might be an effective 

means to share information. Such guidance may better position 

Education to achieve the full potential benefits of its grants management 

system.

To enhance its oversight of discretionary grantee performance, the 

Secretary of Education should direct RMS to work with principal offices, 

as appropriate, to:

• Establish and implement detailed written supervisory review 

procedures for official grant files to provide reasonable assurance that 

grant staff perform and document key monitoring activities.

• Develop guidance for grant staff on using the PAM Module to share 

information on grantee performance. Such guidance could clarify 

expectations about when staff should use the “Issues” and “Notable 

Results” tabs while monitoring grantees once the transition to 

Recommendations for 

Executive Action
Page 23 GAO-17-266 Education Discretionary Grants

electronic grant files is complete, and clarify the types of information 

staff should enter about grantee performance.

We provided a draft of this report to Education for review and comment. 

Their written comments are reproduced in appendix II. In its comments, 

Education substantially agreed with both of our recommendations and 

provided additional technical comments and clarifications, which we have 

incorporated, as appropriate. Among other things, Education reported that 

it will (1) establish a standard operating procedure for grant file reviews, 

including a protocol for the review of these files to ensure that monitoring 

efforts are documented appropriately; and (2) reinforce through grant 

administration trainings the importance of sharing grantee performance 

information agency-wide, including in the PAM Module. 

In commenting on our finding about the extent to which grant staff 

consistently applied discretionary grant monitoring policies, Education 

focused much of its attention on the 58 performance reports we 

determined were missing from the official grant files we reviewed, and 

which were associated with about $21 million in discretionary grant 

awards. Education stated that in every case, it found the performance 

reports and acknowledged that, contrary to its policies, some were found 

outside of the official grant files, such as in other Education systems. 

Hence, Education stated that it believes no federal funds were at risk, in 

part because it was able to locate the documentation necessary for 

continuation awards. Because our review focused on the required 

contents of the official grant file, per Education’s requirements contained 

in its Handbook for the Discretionary Grant Process, we would not have 

found documentation Education kept elsewhere. We have clarified our 

report to note that our analyses pertain to the contents of the official grant 

files we reviewed, and we make no judgment as to whether federal funds 

were “at risk” or improperly awarded. Education also provided more 

details on the safeguards described in the draft report that are meant to 

ensure funding is only provided to grantees that have achieved 

substantial progress and have complied with applicable regulations; we 

included these details in the final report, as appropriate. 

In commenting on our finding about identifying and sharing grantee 

performance information agency-wide, Education agreed that sharing 

such information throughout a grant’s lifecycle would be beneficial and 

that a broader approach to such sharing would enhance steps it has 

taken. Education also stated that the report does not provide a complete 

assessment regarding system training and resources for staff use of the 

Agency Comments 

and Our Evaluation
Page 24 GAO-17-266 Education Discretionary Grants

PAM Module, and that its Office of the Chief Information Officer had 

developed, in consultation with RMS and others, a user guide for the 

PAM Module that provides multiple “guidance tips.” RMS officials also 

confirmed, as stated in our draft report, that they had not developed 

guidance clarifying how staff were to use the tabs we discuss—“Notable 

Results” and “Issues.” Though we were unable to obtain a copy of the 

user guide after several requests during the course of our review, we are 

pleased that Education reports that one exists. As stated in our report, 

establishing a common understanding of when to use these tabs and the 

kinds of information to enter in them could help to ensure that the 

information staff enter in the PAM Module about grantee performance will 

be usable by RMS or other Education offices. We also recognize that staff 

need flexibility to interpret grantee performance terminology within the 

context of the particular grant programs they oversee. Because the intent 

of the related recommendation on developing guidance is meant to 

increase Education’s ability to share and use grantee performance 

information, we have clarified the report language and recommendation 

accordingly. 

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to the 

appropriate congressional committees, the Secretary of Education, and 

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

charge on GAO’s web site at http://www.gao.gov.

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

contact me at (617) 788-0580 or nowickij@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found 

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

this report are listed in app. III.

Sincerely yours,

Jacqueline M. Nowicki

Director, Education, Workforce,

 and Income Security Issues
Appendix I: Education’s Grant Staff Hiring 

Processes and Training

Page 25 GAO-17-266 Education Discretionary Grants

As part of our review, we discussed Education’s processes for hiring and

training staff with Office of Human Resources (OHR) and principal office 

officials. Education last issued a hiring plan in 2009 that outlined specific 

hiring goals and related initiatives, including attracting more diverse 

candidates using special initiatives, as appropriate, such as the Office of 

Personnel Management’s Pathways Program, to hire entry level staff. The 

Pathways Program is a streamlined developmental program meant to 

encourage careers in federal service by offering meaningful training and 

career development for students and recent graduates.1 These programs 

can reduce the time it takes to recruit and hire staff, according to OHR 

officials. OHR officials said they are currently reviewing the effectiveness 

of Education’s strategy to recruit, hire, and retain staff—including grant 

staff—and plan to issue an updated hiring plan in late 2017. As part of 

this review, OHR officials said they will assess Education’s efforts to 

recruit diverse candidates, and review the job series that comprise the 

department’s grant workforce to ensure job descriptions match the duties 

currently being performed by staff in those roles.

Education’s current job series for grant staff identifies specific skills grant 

staff need to manage discretionary grants, and Education offers training 

aimed at helping staff perform these duties effectively. The skills needed 

to manage discretionary grants according to Education officials include, 

for example, (1) knowledge of education theories, principles, processes, 

and practices; (2) proficiency in application of fact-finding and 

investigative techniques; (3) analytical ability; (4) oral and written 

communication; (5) development of presentations and reports; and (6) 

knowledge of specific program and grant information. Education officials 

said they aim to hire staff with these skills and then train them on the 

specifics of grants management through mentoring and on-boarding 

programs, as well as on-the-job and optional training. 

Officials from our three selected principal offices said they all have 

established mentoring or on-boarding programs for new grant staff. In 

fiscal year 2012, Education began offering an optional foundational 

curriculum of grant management courses that, upon completion, lead to a 

grant management certificate, according to RMS officials. These officials 

 1

The Pathways Program, which began in 2010, has three components: 1) an Internship 

Program; 2) a Recent Graduate Program; and 3) the Presidential Management Fellows 

Program. For more information on the Pathways Program, see 

https://www.usajobs.gov/Help/working-in-government/unique-hiring-paths/students/.

Appendix I: Education’s Grant Staff Hiring 

Processes and Training
Appendix I: Education’s Grant Staff Hiring 

Processes and Training

Page 26 GAO-17-266 Education Discretionary Grants

said the curriculum consists of eight courses (delivered over 15 

nonconsecutive days) covering topics such as grants monitoring, financial 

principles, ethics, and administrative requirements, among other things. 

They said the program is offered each year to cohorts of about 35 grant 

staff from across the department, and that since its inception, 228 of the 

department’s roughly 656 grant staff members had completed it. Grant 

staff can also choose to take a variety of other training opportunities that 

are offered department-wide or by principal offices on topics such as cost 

analysis and budget review. 

According to RMS officials, only certain grant staff are required to receive 

grant specific training, which is delivered in the form of an annual briefing. 

Specifically, this briefing is intended for those employees holding a 

discretionary grant license from RMS, which allows them to obligate and 

award grant funds. RMS officials said the annual briefing is designed to 

provide license holders an update on legislative and regulatory 

developments that affect the agency’s grant administration policies. The 

briefing also offers license holders an opportunity to share best practices, 

common concerns, and recommendations on how to improve the grant 

process.
Appendix II: Comments from the U.S. 

Department of Education

Page 27 GAO-17-266 Education Discretionary Grants

Appendix II: Comments from the U.S. 

Department of Education
Appendix II: Comments from the U.S. 

Department of Education

Page 28 GAO-17-266 Education Discretionary Grants
Appendix II: Comments from the U.S. 

Department of Education

Page 29 GAO-17-266 Education Discretionary Grants
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 30 GAO-17-266 Education Discretionary Grants

Jacqueline M. Nowicki (617) 788-0580 or NowickiJ@gao.gov.

In addition to the contact named above, Bill MacBlane (Assistant 

Director), Justin Dunleavy (Analyst-In-Charge), Robin Marion, and Flavia 

Bleahu made key contributions to this report. Also contributing to this 

report were James Bennett, Deborah Bland, Mindy Bowman, Amber 

Yancey-Carroll, David Chrisinger, Sarah Cornetto, Aimee Elivert, Kelsey 

Kennedy, Amy Moran Lowe, Monica Savoy, and Amy Sweet.

Appendix III: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(100322)
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