RECOVERY ACT

Grant Implementation 

Experiences Offer 

Lessons for 

Accountability and 

Transparency 

Report to Congressional Requesters

January 2014

GAO-14-219

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-219, a report to 

congressional requesters

January 2014

RECOVERY ACT

Grant Implementation Experiences Offer Lessons for 

Accountability and Transparency

Why GAO Did This Study

In response to the recent serious 

recession, Congress enacted the 

Recovery Act to promote economic 

recovery, make investments, and 

minimize or avoid reductions in state 

and local government services. 

Approximately $219 billion was

distributed as grants for use in states

and localities, making grants a major 

component of the act. These grants

covered a broad range of areas 

including education, transportation,

energy, infrastructure, the 

environment, health care, and housing. 

GAO was asked to examine grant 

management lessons learned resulting 

from the Recovery Act. This report 

examines federal, state, and local 

experiences with implementing grants 

funded by the Recovery Act by 

identifying examples of good practices 

employed and challenges faced in 

meeting the act’s accountability and 

transparency requirements. GAO 

reviewed relevant documents including

OMB and Recovery Board guidance,

relevant literature, and previous reports 

by GAO, federal inspectors general, 

and others. GAO also interviewed 

officials from OMB, the Recovery 

Board, four federal agencies, three 

state governments, and two local 

governments, among others. This 

report also draws on GAO’s past bimonthly reviews of selected states’ and 

localities’ use of Recovery funds. 

What GAO Recommends

GAO is not making any 

recommendations in this report. We 

provided a draft of this report to 

relevant agencies for comment. They 

generally agreed with our findings and 

provided technical comments.

What GAO Found

Federal, state, and local officials responsible for implementing grants funded by 

the American Recovery and Reinvestment Act of 2009 (Recovery Act) as well as

the external oversight community reported lessons learned regarding both useful 

practices and challenges to ensuring accountability. Faced with aggressive 

timelines for distributing billions of dollars, they adopted a number of practices to 

foster accountability including (1) strong support by top leaders; (2) centrallysituated collaborative governance structures; (3) the use of networks and 

agreements to share information and work towards common goals; and (4)

adjustments to, and innovations in, usual approaches to conducting oversight 

such as the increased use of up-front risk assessments, the gathering of “real 

time” information, earlier communication of audit findings, and the use of 

advanced data analytics. For example, in 2009, the Recovery Accountability and 

Transparency Board (Recovery Board) established the Recovery Operations 

Center which used advanced data analysis techniques to identify potential fraud 

and errors before and after payments were made. The Recovery Act’s emphasis 

on accountability also presented challenges for several states and federal 

agencies. These included limited resources for oversight at the state and local 

levels, and the speed with which Recovery Act funds were distributed. One state 

addressed the challenge of limited resources by transferring funds from its 

central administration account to Recovery Act oversight. To facilitate the quick

distribution of funds, maintenance-of-effort provisions concerning transportation

projects (which prevented Recovery funds from being used for planned state 

projects) were rolled out before the Department of Transportation had time to 

issue sufficiently detailed definitions of what constituted “state funding.” To 

address this challenge, the department had to issue clarifying guidance to states 

seven times during the first year of the Recovery Act.

Federal, state, and local officials also developed practices and encountered 

challenges related to the transparency of Recovery Act funds. An example of one 

good practice that was required by the Recovery Act was the creation of the 

Recovery.gov website. This site, as well as similar portals created by states and 

localities, demonstrated several leading practices for effective government 

websites. These included (1) establishing a clear purpose, (2) using social 

networking tools to garner interest, (3) tailoring the website to meet audience 

needs, and (4) obtaining stakeholder input during design. Efforts to increase 

transparency also led to challenges for several states and federal agencies. For 

example, some recipients lacked knowledge or expertise in using the data 

systems needed to report grant spending, while others faced challenges with 

reporting the same data to multiple systems. Early GAO reviews also found 

several problems with job reporting data including discrepancies in how full time 

equivalents were recorded and the capacity of recipients to meet reporting 

deadlines. The Office of Management and Budget (OMB) addressed these 

challenges by issuing additional guidance and providing technical support. 

Finally, agencies receiving Recovery Act funds were required to submit 

performance plans that identified measures on a program-by-program basis. The 

level of detail and the specificity of outcomes in these plans varied greatly for the 

agencies GAO examined, making it difficult to determine the extent to which 

some were making progress toward their goals and demonstrating results. 

View GAO-14-219. For more information, 

contact Stanley J. Czerwinski at (202) 512-

6806 or czerwinskis@gao.gov.
Page i GAO-14-219 Grant Lessons from the Recovery Act

Letter 1

Background 4

Practices at Federal, State, and Local Levels Contributed to 

Improved Accountability of Recovery Act Grant Programs but 

Challenges Existed 13

The Recovery Act Resulted in Increased Transparency but Also 

Presented Challenges 34

Concluding Observations 52

Agency Comments 53

Appendix I Objectives, Scope, and Methodology 54

Appendix II GAO Contact and Staff Acknowledgments 58

Table

Table 1: Key Organizations and Their Primary Accountability and 

Oversight Responsibilities Regarding Implementation of 

the Recovery Act 11

Figures

Figure 1: Timeline of Selected Recovery Act Events 6

Figure 2: Overview of Recovery Act Spending by Program and 

Category, as of October 31, 2013 8

Figure 3. An Analyst Working in the Recovery Board’s Recovery 

Operations Center and a Sample Output of One of ROC’s 

Link Analysis Tools. 30

Figure 4: Screenshot of Recovery.gov User Identification Feature 37

Figure 5: Screenshot of Recovery.gov’s Recipient Projects Page 

for a Georgia ZIP Code, 30318 41

Figure 6: Screenshot of NYCStat Stimulus Tracker Mapping 

Feature 43

Contents
Page ii GAO-14-219 Grant Lessons from the Recovery Act

Abbreviations

ARRA American Recovery and Reinvestment Act of 2009

API Application Program Interface

BCN ARRA Big City Network

CBO Congressional Budget Office

DOE Department of Energy

HUD Department of Housing and Urban Development

DOT Department of Transportation

FHWA Federal Highway Administration

FTE Full-time Equivalent

GPRAMA GRPA Modernization Act of 2010

IG Inspector General

MASSPIRG Massachusetts Public Interest Research Group

NIAF National Intergovernmental Audit Forum

NRT National Review Team

OMB Office of Management and Budget

Recovery Board Recovery Accountability and Transparency Board

ROC Recovery Operations Center

SFSF State Fiscal Stabilization Fund

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

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Page 1 GAO-14-219 Grant Lessons from the Recovery Act

441 G St. N.W.

Washington, DC 20548

January 24, 2014

The Honorable Thomas R. Carper

Chairman

The Honorable Tom Coburn, M.D.

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Claire McCaskill

Chairman

Subcommittee on Financial and Contracting Oversight

Committee on Homeland Security and Governmental Affairs

United States Senate

In response to the recent serious recession, Congress enacted the 

American Recovery and Reinvestment Act of 2009 (Recovery Act) to, 

among other purposes, promote economic recovery, make investments, 

and minimize and avoid reductions in state and local government 

services.1

To better understand grant management lessons learned resulting from 

the Recovery Act, we focused on two key issues involving grant 

A significant component of the Recovery Act was grants for use 

in states and localities. As of the end of October 2013, the Department of 

the Treasury had awarded approximately $219 billion of Recovery Act 

funds in the form of grants. These grants covered a broad range of areas 

including education, transportation, infrastructure, energy, the 

environment, health care, and housing. The importance of spending 

Recovery Act funds quickly was highlighted by the President’s goal of 

spending 70 percent of the funds by September 30, 2010. You asked us 

to examine grant management lessons learned resulting from the 

Recovery Act and to provide examples of what worked well, as well as 

what challenges were experienced by federal, state, and local 

governments.

 1

Pub. L. No. 111-5, 123 Stat. 115.
Page 2 GAO-14-219 Grant Lessons from the Recovery Act

implementation—accountability2 and transparency3—where Congress 

and the administration placed unprecedented emphasis when they 

crafted the Recovery Act. Specifically, this report identifies and provides 

examples of good practices employed and the challenges faced in 

meeting the Recovery Act’s accountability and transparency requirements 

by select federal, state, and local agencies implementing grant programs 

funded by the Recovery Act. Additionally, in September 2013, we issued 

a related report examining federal efforts to increase the transparency of 

federal data and identifying lessons learned from operating existing data 

systems that could contribute to these efforts.4

To accomplish our objectives, we conducted a detailed literature review to 

identify relevant prior work by us and others regarding Recovery Act 

challenges and lessons learned.5

 2

The Recovery Act established multiple mechanisms to provide accountability including

those aimed at preventing fraud, waste, and abuse. According to the Office of 

Management and Budget’s (OMB) initial Recovery Act implementation guidance, meeting 

the Recovery Act’s accountability objectives included ensuring that funds were awarded 

and distributed in a prompt manner; benefits of these funds were reported in a timely 

manner; and projects funded avoided unnecessary delays and cost overruns. OMB further 

specified that a critical accountability objective is ensuring funds are used for authorized 

purposes and instances of fraud, waste, and abuse are mitigated. See OMB, Initial 

Implementing Guidance for the American Recovery and Reinvestment Act of 2009, OMB 

Memorandum M-09-10 (2009).

We then interviewed federal, state, and 

local officials involved in the implementation of the Recovery Act and 

obtained supporting documentation. The federal entities that we 

contacted with broad jurisdiction for the Recovery Act were the Recovery 

3

In 2009, the President and OMB issued memos stating that “transparency promotes 

accountability and provides information for citizens about what the Government is doing.”

Further, the Federal Funding Accountability and Transparency Act of 2006, as amended, 

requires information disclosure concerning entities receiving federal financial assistance 

through federal awards such as federal contracts, sub-contracts, grants, and sub-grants.

31 U.S.C. § 6101 note. Office of Management and Budget, Open Government Directive,

OMB Memorandum M-10-06 (2009); and Open Government Directive–Federal Spending 

Transparency and Subaward and Compensation Data Reporting (2010). 

4

GAO, Federal Data Transparency: Opportunities Remain to Incorporate Lessons 

Learned as Availability of Spending Data Increases, GAO-13-758 (Washington, D.C.: 

Sept. 12, 2013).

5

For additional information on GAO’s broad body of work related to the Recovery Act, see 

http://www.gao.gov/recovery/. External reports we reviewed include studies by the White 

House, Recovery Accountability and Transparency Board, federal Inspectors General,

IBM Center for the Business of Government, and George Mason University. See appendix 

I for additional information on studies reviewed.
Page 3 GAO-14-219 Grant Lessons from the Recovery Act

Implementation Office, the Office of Management and Budget (OMB), and 

the Recovery Accountability and Transparency Board (Recovery Board).6

The state and local governments we selected included California, 

Georgia, and Massachusetts, as well as New York, New York and 

Denver, Colorado. These three states are part of a core group of 16 

states and the District of Columbia that we selected for our series of 

bimonthly reviews of how Recovery Act funds were being used by 

recipients. The Recovery Act required that we conduct these bimonthly 

reviews of how these funds were used by selected states and localities. 

This report also fulfills this requirement in that we examined the use of 

Recovery Act funds in the previously mentioned states and cities. To 

obtain a broader state perspective, we interviewed officials from the state 

Recovery Act coordinators’ network, which included key state officials 

responsible for implementing the Recovery Act from several states. For 

additional context, we supplemented these interviews by meeting with 

officials from state and local advocacy organizations such as the National 

Association of State Auditors and Comptrollers; the National Association 

of State Budget Officers; and the National Association of Counties. We 

reviewed and synthesized the information provided by these officials, as 

We developed criteria to select a subset of four federal agencies, three 

state governments, and two local governments. We then contacted these 

entities in order to obtain a more in-depth understanding of their 

experiences with grant programs funded by the Recovery Act as well as 

to identify examples of challenges and good practices. Our selection 

criteria included factors such as the nature, type, and value of the grants 

handled by the organization; whether the grants involved were already 

well-established, greatly increased in size, or entirely new; and the extent 

to which the organizations were identified in our previous work or in the 

broader literature. The federal agencies we selected were the 

Departments of Education, Energy, Transportation, and Housing and 

Urban Development. We deemed Medicaid out of scope for the purposes 

of this review. Although it was the largest grant program funded by the 

Recovery Act, it is primarily an entitlement and is subject to specific rules 

that are not typical of program grants.

 6

The Recovery Implementation Office, with a staff of not more than eight full-time 

equivalents, was created by Vice President Biden to oversee the high-level management 

dimensions of the Recovery Act. The Recovery Accountability and Transparency Board 

was created by the Recovery Act to carry out a wide range of accountability and 

transparency functions. See table 1 for more specifics. 
Page 4 GAO-14-219 Grant Lessons from the Recovery Act

well as previously issued work regarding challenges and good practices 

that relate to our two key themes, and we developed descriptive 

examples. We also reviewed and applied criteria established by 

HowTo.gov, a source of guidance and leading practices for government 

websites, to Recovery.gov and state and local Recovery websites. A full 

description of our objectives, scope, and methodology is provided in 

appendix I.

We conducted this performance audit from December 2012 to January 

2014 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

The stated purposes of the Recovery Act are to:

• preserve and create jobs and promote economic recovery;

• assist those most impacted by the recession;

• provide investments needed to increase economic efficiency by 

spurring technological advances in science and health;

• invest in transportation, environmental protection, and other 

infrastructure that will provide long-term economic benefits; and

• stabilize state and local government budgets, in order to minimize and 

avoid reductions in essential services and counterproductive state and 

local tax increases.7

While many Recovery Act projects focused on immediately jumpstarting 

the economy, some projects—such as those involving investments in 

technology, infrastructure, and the environment—are expected to 

contribute to economic growth for many years. The Recovery Act 

established the Recovery Accountability and Transparency Board 

(Recovery Board) to provide additional monitoring and oversight. The 

board was originally scheduled to terminate operations by September 30, 

 7

Recovery Act, § 3(a), 123 Stat. at 116. 

Background
Page 5 GAO-14-219 Grant Lessons from the Recovery Act

2013,8 but its mission has been extended until September 30, 2015, to 

provide oversight and monitoring of assistance provided in response to 

Hurricane Sandy, which hit the northeast in October 2012.9

 8

The authority of the Recovery Board was expanded by the Consolidated Appropriations 

Act, 2011, under which the Recovery Accountability and Transparency Board was 

appropriated $28.35 million, to carry out title XV of the Recovery Act and to “develop and 

test information technology resources and oversight mechanisms to enhance 

transparency of and detect and remediate waste, fraud, and abuse in federal spending.”

Pub. L. No. 112-74, 125 Stat. 786, 920 (2011).

The timeline 

in figure 1 displays selected events related to the Recovery Act and its 

requirements.

9

Disaster Relief Appropriations Act, 2013, Pub. L. No. 113-2, § 904(d), 127 Stat. 4, 18.
Page 6 GAO-14-219 Grant Lessons from the Recovery Act

Figure 1: Timeline of Selected Recovery Act Events
Page 7 GAO-14-219 Grant Lessons from the Recovery Act

The Congressional Budget Office (CBO) initially estimated the cost of the 

Recovery Act to be approximately $787 billion; however, CBO’s most 

recent estimate projects that the Recovery Act will cost approximately 

$830 billion over the 2009-2019 time period.10 As of October 31, 2013, 

the federal government provided a total of approximately $812 billion 

related to Recovery Act activities. This includes funding to 28 federal 

agencies that were distributed to states, localities, and other entities; 

individuals through a combination of tax benefits and cuts; entitlements; 

and loans, contracts, and grants. See figure 2 for an overview of 

Recovery Act spending by category and program. Although Medicaid was 

the single largest Recovery Act grant program, we did not include it in our 

review because it is primarily an entitlement program and subject to 

specific rules that are not typical of program grants.11 Accordingly, we 

included the Recovery Act funds directed to Medicaid in the entitlement 

category, rather than the grant category, in figure 2. Emphasizing the 

importance of spending Recovery Act funds quickly, the President 

established a goal that by September 30, 2010, 70 percent of Recovery 

Act funding should be spent (that is, both obligated and outlayed).12

 10Congressional Budget Office, Estimated Impact of the American Recovery and 

Reinvestment Act on Employment and Economic Output from October 2012 Through 

December 2012, (Washington, D.C.: Feb. 21, 2013). In January 2010, CBO estimated that 

the cost of the Recovery Act would be larger than originally estimated. Among the factors 

contributing to the higher estimates were higher than anticipated use of entitlement 

programs such as unemployment insurance and nutritional assistance, as well as higher 

than anticipated use of the Build America Bonds program.

Therefore, agencies had approximately 19 months to spend almost threequarters of their Recovery funds.

11Medicaid is a joint federal-state program that finances health care for certain categories 

of low-income individuals, including children, families, persons with disabilities, and 

persons who are elderly.

12An “obligation” is the definite commitment that creates a legal liability of the government 

for the payment of goods and services ordered or received, or a legal duty on the part of 

the United States that could mature into a legal liability by virtue of actions on the part of 

the other party beyond the control of the United States. An “outlay” is the issuance of 

checks, disbursement of cash, or electronic transfer of funds made to liquidate a federal 

obligation. See GAO, A Glossary of Terms Used in the Federal Budget Process, 

GAO-05-734SP, (Washington, D.C.: Sept. 2005). Spending by the federal government 

(i.e., funds obligated and outlayed) can represent just the first steps of using the funds. 

For instance, the Department of Education makes grants to state educational agencies. 

After the federal government has outlayed the funds to the state educational agencies, 

they may, in turn, make grants to local educational agencies, which would then, in turn, 

spend the money on salaries, school facilities, or other items.

Recovery Act Funding
Page 8 GAO-14-219 Grant Lessons from the Recovery Act

Figure 2: Overview of Recovery Act Spending by Program and Category, as of October 31, 2013

a

Does not include Medicaid which is instead reflected in the entitlement category in the first pie chart 

above.
Page 9 GAO-14-219 Grant Lessons from the Recovery Act

Grants have played a key role in providing Recovery Act funds to 

recipients, with approximately $219 billion being awarded for use in states 

and localities through a wide variety of federal grant programs. With the 

intent of disbursing funds quickly to create and retain jobs and stabilize 

state and local budgets, a large majority of Recovery Act grant funding 

went to states and localities within 3 years of the law’s enactment. 

Recipients reported receiving approximately 88 percent of their grant 

awards by the end of the 2nd quarter of calendar year 2013. State and 

local spending was as follows:

• Fiscal year 2009: spending totaled approximately $53 billion in actual 

outlays.

• Fiscal year 2010: spending was at its highest level with approximately 

$112 billion in actual outlays.

• Fiscal year 2011: spending decreased from its peak, with 

approximately $69 billion in actual outlays.

The 28 federal agencies that received Recovery funds developed specific 

plans for spending the money.13

Recovery Act grants provided to states and localities covered a broad 

range of areas such as transportation, energy, and housing. Education 

programs were the largest recipients of Recovery Act grant awards. Of 

the education programs funded in the Recovery Act, the largest in terms 

of funding was the newly created State Fiscal Stabilization Fund (SFSF) 

program, which provided assistance to state governments to stabilize 

their budgets by minimizing budgetary cuts in education and other 

essential government services, such as public safety. The Recovery Act 

The agencies then awarded grants and 

contracts to state governments or, in some cases, directly to schools, 

hospitals, or other entities. OMB guidance directed these federal 

agencies to file weekly financial reports detailing how the money was 

being distributed. Recipients of the funds, in turn, were required by the 

Recovery Act to file quarterly reports on how they were spending the 

Recovery Act funds that they received.

 13Some programs administered by these agencies followed a different procedure. For 

example, some of the Recovery Act funds provided to the Department of Transportation 

were distributed to states and localities through the statutory formulas and rules governing 

existing programs. The states and localities retained responsibility for selecting projects, 

which were required to meet additional requirements specified in the Act.

Grant Programs Funded 

by the Recovery Act
Page 10 GAO-14-219 Grant Lessons from the Recovery Act

appropriated $53.6 billion for the SFSF program.14 As figure 2 (above) 

shows, grants represent over one-quarter of Recovery Act funding. Out of 

that category, funding received in the program areas of education, 

transportation, and energy and environment amount to approximately 

$137 billion, or 70 percent, of Recovery Act grant spending to date.

The Recovery Act called for a large amount of federal funds to be spent 

(that is, obligated and outlayed) in a short period of time—approximately 

19 months—by the end of September 30, 2010. To assure the public that 

their tax dollars were being spent efficiently and effectively, the Recovery 

Act placed increased emphasis on accountability and transparency 

through enhanced reporting, auditing, and evaluation requirements for 

users of Recovery Act funds. The Recovery Act delineated some of these 

increased accountability and transparency responsibilities to existing 

organizations and entities as well as newly-created ones. See table 1 for 

details regarding the primary accountability and oversight responsibilities 

of key organizations involved in implementing the Recovery Act.

 14Under the Recovery Act, the Department of Education’s SFSF Grant authorized three 

programs—SFSF State Grants, State Incentive Grants, and an Innovation Fund. Of the 

$53.6 billion appropriated for SFSF, the Department used $48.6 billion for the State 

Grants, $4.35 million for Race to the Top Grants (authorized under the State Incentive 

Grants), and $650,000 for the Investing in Innovation program (authorized under the 

Innovation Fund). Recovery Act, div. A, §§ 14001–14012, 123 Stat. at 279–286. 

Recovery Act Oversight 

and Accountability 

Responsibilities of Key 

Participants
Page 11 GAO-14-219 Grant Lessons from the Recovery Act

Table 1: Key Organizations and Their Primary Accountability and Oversight Responsibilities Regarding Implementation of the 

Recovery Act

Key organizations and entities Primary accountability and oversight responsibilities

Federal government

Congressional Budget Office • Provide periodic estimates on the Recovery Act’s effect on employment. 

(Recovery Act, div. A, § 1512(e), 123 Stat. at 288)

Council of Economic Advisers • Prepare periodic reports on employment and economic impacts of Recovery Act 

spending. (Recovery Act, div. A, § 1513, 123 Stat. at 288)

Federal agencies • Report how they are distributing the funds on a weekly basis. (Office of 

Management and Budget Guidance, OMB Memorandum M-09-10)

• Use a separate accounting identifier for Recovery Act funded projects. (Office of 

Management and Budget Guidance, OMB Memorandum M-09-10)

• Make publicly available recipient reports within 30 days of the end of each 

quarter. (Recovery Act, div. A, § 1512(d), 123 Stat. at 288)15

Government Accountability Office • Conduct bimonthly reviews and prepare reports of such reviews of selected 

states’ and localities’ use of Recovery Act funds. (Recovery Act, div A, § 901(a), 

123 Stat. at 191)

• Comment on quarterly recipient reports on the number of jobs created or 

preserved. (Recovery Act, div. A, § 1512(e), 123 Stat. at 288)

• Review areas such as trade adjustment assistance, new education incentive 

grants, and efforts to increase small business lending. (Recovery Act, div. B, 

§ 1894, 123 Stat. at 423, Recovery Act, div. A, § 14009, 123 Stat. at. 285 and 

Recovery Act, div. A, § 507, Stat. at 158 )

Inspectors general • Audit the programs, grants, and projects funded under the Recovery Act, both 

within their particular agency or department and collectively address concerns 

raised by the public. (Recovery Act, div. A, § 1514, 123 Stat. 289)

• Serve on Recovery Act Board. (Recovery Act, div. A, § 1522(b), 123 Stat. at 

290)16

• Conduct whistleblower reprisal investigations. (Recovery Act, div. A, 123 § 1553, 

Stat. 297)

 15Although the law gave responsibility to agencies to make recipient reports available, 

recipients actually submitted information to a single website operated by the Recovery 

Board. Data were then provided to agencies for review and recipients were requested to 

make any needed corrections. The Recovery Board then made the data available on its 

website, Recovery.gov.

16The Recovery Accountability and Transparency Board is comprised of a chairperson 

appointed by the President and inspectors general from the Departments of Agriculture, 

Commerce, Education, Energy, Health and Human Services, Homeland Security, Justice, 

Transportation, and Treasury, and any other inspector general designated by the 

President from any agency that expends or obligates Recovery Act funds. 
Page 12 GAO-14-219 Grant Lessons from the Recovery Act

Key organizations and entities Primary accountability and oversight responsibilities

Office of Management and Budget (OMB) • Coordinate with federal agencies on recipient reporting guidance. (Recovery Act, 

div. A, § 1512(g), 123 Stat. at 288)

• Coordinate with the Council of Economic Advisers on their reports. (Recovery 

Act, div. A, § 1513(a), 123 Stat. at 288)

Recovery Accountability and Transparency 

Board (Recovery Board)

• Review whether use of Recovery Act funds met applicable standards and 

specified purposes. (Recovery Act, div. A, § 1523(a)(2)(A), 123 Stat at 290)

• Identify fraud, waste and mismanagement related to the use of Recovery Act 

funds and refer to federal Inspector General. (Recovery Act, div. A, § 1523(a)(1) 

and (a)(2)(C), 123 Stat at 290)

• Review whether there are sufficient and qualified contract and grant personnel 

overseeing Recovery Act funds. (Recovery Act, div. A, § 1523(a)(2)(D), 123 Stat 

at 290)

• Submit quarterly and annual reports to the President and Congress, as well as 

“flash reports” on potential problems that require immediate attention. (Recovery 

Act, div. A, § 1523(b)(1), (b)(2) and (b)(3), 123 Stat at 291)

• Make recommendations to federal agencies on measures to prevent fraud, 

waste, and mismanagement of Recovery Act funds. (Recovery Act, div. A, 

§ 1523(c)(1), 123 Stat at 291)

• Establish and maintain the Recovery.gov website. (Recovery Act, div. A, 

§ 1526(a), 123 Stat at 293)

Recovery Implementation Office • Support key administration officials and coordinate Recovery Act efforts at OMB.

• Facilitate interagency coordination.

• Complement oversight work led by the Recovery Board.

Recovery Independent Advisory Panel • Provide recommendations to the Recovery Board to identify and prevent fraud, 

waste and abuse in Recovery Act programs. (Recovery Act, div. A, § 1542, 123 

Stat at 295)

State government

Governors • Within 45 days of enactment of the Act, certify that the state will request and use 

funds provided by the Recovery Act and that the funds will be used to create 

jobs and promote economic growth. (Recovery Act, div. A, § 1607(a), 123 Stat at 

303)

State auditors • Work with the Recovery Board in coordinating oversight activities. (Recovery 

Act, div. A, § 1528, 123 Stat at 294)

State government agencies • Report on the amount of funds received on a quarterly basis. (Recovery Act, 

div. A, § 1512 (c)(1), 123 Stat at 287)

• Report on their use of funds on a quarterly basis. (Recovery Act, div. A, 

§ 1512(c)(2), 123 Stat at 287)

• Report on an estimate of the number of jobs created and the number of jobs 

retained on the quarterly basis. (Recovery Act, div. A, § 1512(c)(3 )(D), 123 Stat 

at 287)

• Use a separate accounting identifier for Recovery Act funded projects. (Office of 

Management and Budget Guidance, OMB Memorandum M-09-10)
Page 13 GAO-14-219 Grant Lessons from the Recovery Act

Key organizations and entities Primary accountability and oversight responsibilities

Local government and others

Recipients’ of Recovery Act funds (local 

governments, universities and other research 

institutions, non-profit organizations, and 

private companies)

• Report quarterly on Recovery Act funds including on (1) the amount of funds 

received, (2) the amount of funds expended or obligated to projects and 

activities, (3) a detailed list of all projects and activities for which funds were 

expended or obligated, including a name, description, and evaluation of 

completion status for each project or activity, and (4) an estimate of the number 

of jobs created and the number of jobs retained by each project or activity. 

(Recovery Act, div. A § 1512(c), 123 Stat at 287-288)

Source: GAO analysis of Recovery Act and OMB/White House memoranda.

Under the Recovery Act, accountability for timely and effective 

implementation of the law was a shared responsibility that included 

agencies involved in directly implementing the law as well as the external 

oversight community. On the operational side, among the practices that 

facilitated accountability were (1) strong support by top leaders, (2) 

centrally-situated collaborative governance structures, and (3) the regular 

and systematic use of data to support management reviews.

Practices at Federal, 

State, and Local 

Levels Contributed

to Improved

Accountability

of Recovery Act

Grant Programs but 

Challenges Existed

Strong Support by Top 

Leaders, a Collaborative 

Approach, and Systematic 

Use of Data Were Key to 

Managing Recovery Act 

Implementation
Page 14 GAO-14-219 Grant Lessons from the Recovery Act

We have previously reported on the importance of having the active 

support of top leadership when undertaking large and complex 

activities.17

In each of these roles he had direct access to, and support from, the 

highest levels of government. The former head of the Recovery 

Implementation Office stated this was key to his ability to ensure 

cooperation and coordination with other federal departments during the 

Recovery Act. For example, he told us that senior government leaders 

knew that his office had the authority of the President and Vice President 

behind it, and if they did not do what was requested, they would have to 

explain their reasoning to senior White House officials. This awareness of 

the Recovery Implementation Office’s line of authority helped to ensure 

that federal officials coordinated and cooperated with the office. In turn, 

the involvement and engagement of top leaders at individual federal 

agencies was facilitated by OMB guidance that required each agency to 

identify a senior accountable official—generally at the deputy secretary or 

This was the case in the implementation of the Recovery Act 

where, at the federal level, the President and Vice President made clear 

that effective Recovery Act implementation was a high priority for them. 

The President assigned overall management responsibility for the 

Recovery Act to the Vice President and appointed a former OMB deputy 

director to head the newly-created Recovery Implementation Office with 

direct reporting responsibilities to both him and the Vice President. The 

former head of the Recovery Implementation Office told us that his 

position gave him access to top leadership in the administration. This 

official said he participated in daily morning staff meetings with the White 

House senior staff, briefing them on any issues related to the Recovery 

Act. He briefed the President directly approximately once a month. In 

addition, he typically met with the Vice President’s staff on a daily basis 

after the President’s staff meeting. He also met with the Vice President 

directly every 1 to 2 weeks. Finally, he frequently interacted with the head 

of OMB and sometimes also sat in on his staff meetings.

 17GAO, Managing for Results: Key Considerations for Implementing Interagency 

Collaborative Mechanisms, GAO-12-1022 (Washington, D.C.: Sept. 27, 2012); 

Streamlining Government: Key Practices from Select Efficiency Initiatives Should be 

Shared Government wide, GAO-11-908 (Washington, D.C.: Sept. 30, 2011); Gulf Coast 

Rebuilding: Preliminary Observations on Progress to Date and Challenges for the Future, 

GAO-07-574T (Washington, D.C.: Apr. 12, 2007); and Catastrophic Disasters: Enhanced 

Leadership, Capabilities, and Accountability Controls Will Improve the Effectiveness of the 

Nation’s Preparedness, Response, and Recovery System, GAO-06-618 (Washington, 

D.C.: Sept. 6, 2006).

Strong Support by 

Top Leaders
Page 15 GAO-14-219 Grant Lessons from the Recovery Act

subcabinet level—to be responsible for Recovery planning, 

implementation, and performance activities within the agency.18

At the state level, several governors demonstrated top leadership support 

by establishing specific positions, offices, or both that were responsible 

for state Recovery efforts. For example, the Governor of Massachusetts 

created the Massachusetts Recovery and Reinvestment Office as a 

temporary program management office for the specific task of overseeing 

Recovery activities. The former director of the office stated that he 

reported directly to, and drew his authority from, the Governor. The 

Governor also elevated the office to the rank of a senior level office. This 

action increased the office’s visibility and gave it a seat at the Governor’s 

weekly cabinet meetings, where its director would regularly report on the 

status of Recovery Act projects. In addition, no state Recovery Act 

program could be approved without the director’s consent. The former 

director told us that the success of the office was attributable to the direct 

line of authority it had with the Governor of Massachusetts. In fiscal year 

2012, Massachusetts’ Office of Commonwealth Performance, 

Accountability, and Transparency was created, in part, as a direct result 

of the Recovery Act.

These 

senior agency leaders were regularly involved with overseeing and 

reporting on Recovery Act efforts.

19

Collaboration played a key role in ensuring timely implementation of, and 

accountability for, Recovery Act grant programs. Because the success of 

the Recovery Act relied on many programs being implemented quickly at 

the federal, state, and local levels, cooperation and collaboration among 

these groups was essential. While centrally-situated federal entities such 

as the Recovery Implementation Office, OMB, and the Recovery Board 

set the tone, issued guidance, and provided ongoing oversight, many

implementation decisions were left to state and local partners directly

engaged in managing Recovery Act programs. For example, agencies 

and grantees were given freedom to publish notices of funding availability 

According to Massachusetts’ state officials, this 

office is the state’s attempt to take lessons from the state’s experience 

with the Massachusetts Recovery and Reinvestment Office and apply 

them post Recovery Act.

 18OMB, Initial Implementing Guidance for the American Recovery and Reinvestment Act 

of 2009, OMB Memorandum M-09-10 (2009).

19Mass. Gen. Laws ch. 7, § 4A(e).

Centrally-Situated 

Collaborative Governance 

Structures
Page 16 GAO-14-219 Grant Lessons from the Recovery Act

and to run competitions in a manner consistent with their individual 

statutes, regulations, and agency practices. On the other hand, there was 

also centralization of oversight as demonstrated by the direct involvement 

of high-level officials such as the Vice President, cabinet secretaries, and 

senior accountable officials in federal agencies receiving Recovery Act 

funding, as well as centrally-placed policy and oversight organizations 

such as OMB and the Recovery Board. This combination of a centralized 

and decentralized approach to managing the implementation of the 

Recovery Act represented a new method of managing grant oversight, 

one which simultaneously recognized the importance of collaboration 

while increasing the role of the center.20

Officials in the Recovery Implementation Office employed a collaborative, 

facilitative approach, while also leveraging the authority of the Vice 

President to facilitate the participation of stakeholders. The office 

functioned as a convener and problem-solver that engaged with a wide 

range of federal, state and local partners. This approach was embodied in 

the objectives identified by the Vice President when the office was 

established. These objectives included the expectation that office staff 

respond to requests and questions within 24 hours, cut across 

bureaucratic silos by reaching out to a variety of partners, and always be 

accessible. Toward this end, the office adopted the role of an “outcome 

broker,” working closely with partners across organizational silos at all 

levels of government in order to foster implementation of the Recovery 

Act and achieve results.

21

 20For a detailed discussion of this and related issues see, Posner, Paul L., et. al.,

Implementation of the Recovery Act: Networks Under Stress, George Mason University, 

Centers on the Public Service, (February 2013). 

Another role of the Recovery Implementation 

Office was to closely monitor Recovery Act spending. One way it did so 

was to monitor grants to ensure that they were consistent with the 

objectives identified by the Vice President. A second way the office 

monitored spending was to review weekly financial reports on agency 

obligations and expenditures for programs receiving Recovery Act funds 

and to meet with the agencies on a regular basis.

21For more information on the concept of an “outcome broker”, please see Frank 

DiGiammarino, Can Government Work Like Open Table? Innovation in the Collaborative 

Era (2012), accessed January 22, 2014, 

http://www.scribd.com/doc/115361546/Can-Government-Work-Like-OpenTable.
Page 17 GAO-14-219 Grant Lessons from the Recovery Act

OMB sought to facilitate effective implementation of the Recovery Act by 

working to establish and strengthen relationships with state and local 

governments that would ultimately implement the programs on the 

ground. This was done in two ways: (1) by soliciting feedback from state 

and local partners when formulating and revising rules and policies 

governing the implementation of Recovery Act programs and (2) by 

developing its capacity to respond to questions from the many states and 

localities that would be implementing those rules and policies. A senior 

OMB official directly involved in this work told us the office had to move 

out of its traditional role as mainly a policy-making organization to adopt a 

more interactive and service-oriented approach. Under this approach, key 

activities involved engaging with and obtaining feedback from states and 

localities as well as providing technical support to these groups so that 

they could meet the Recovery Act’s numerous reporting requirements.

For example, to obtain feedback from state and local partners when 

developing key Recovery Act policies, OMB became actively involved in 

weekly conference calls that included a diverse group of federal, state, 

and local organizations. Starting in the spring of 2009, regular participants 

in these calls included OMB; GAO; the National Association of State 

Auditors, Comptrollers and Treasurers; the National Governors’ 

Association; the National Association of State Budget Officers; the 

Recovery Board; the National Association of Counties; the National 

Association of State Chief Information Officers; and the National 

Association of State Purchasing Officers. These weekly calls were 

scheduled after several of these organizations wrote to OMB and GAO to 

express their strong interest in coordinating on reporting and compliance 

aspects of the Recovery Act. An important outcome of this regular 

information exchange was to make OMB aware of the need to clarify 

certain reporting requirements. The Recovery Act required federal 

agencies to make information publicly available on the estimate of the 

number of jobs created and number of jobs retained as a result of 

activities funded by the act. Our previous Recovery Act work in the states 

raised the issue that some local officials needed clarification regarding 

definitions when reporting on job data. The local partners participating in 

these calls were able to corroborate what we reported and provide OMB 

with specific information about what additional guidance was needed. To 

obtain information to further guide refinements to the Recovery 

implementation process, at the end of 2009, OMB officials said they (1) 

interviewed and surveyed numerous stakeholders including governors 

and state and local recipients, and (2) worked with GAO to identify best 

practices. Based on these efforts, OMB subsequently revised its 
Page 18 GAO-14-219 Grant Lessons from the Recovery Act

guidance, which focused on lessons learned around enhancing recipient 

reporting and compliance.22

To improve technical support provided to state and local governments 

implementing the Recovery Act, OMB worked with the Recovery Board to 

establish an assistance center based on an “incident command” model.23

Under the Recovery Act, some agencies used new data-driven 

approaches to inform how they managed programs, and some of those 

new approaches become institutionalized at the agencies post-Recovery. 

While the Government Performance and Results Act (GPRA)

Modernization Act of 2010 (GPRAMA) laid out requirements for datadriven quarterly performance reviews, several Recovery Act efforts aided 

agencies in implementing those requirements.

One OMB official likened this approach to an extension of a traditional 

response model used during natural disasters, where the country’s 

economic condition during the Great Recession was the “incident” and 

the Recovery Act was the intervention to be rolled out through many 

partners. To help implement this approach, OMB worked with officials 

from the Department of Agriculture who offered the services of one of 

their national emergency management teams to help set up and 

coordinate this effort. Given the large number of state and local 

governments that needed to be supported, OMB requested that each 

agency with grant programs receiving Recovery Act funds contribute 

personnel to support the center. According to OMB officials, from 

September to mid-December of 2009, the center responded to 

approximately 35,000 questions from states and localities.

24

 22OMB, Updated Guidance on the American Recovery and Reinvestment Act – Data 

Quality, Non-Reporting Recipients, and Reporting of Job Estimates, OMB 

Memorandum10-08 (2009).

For example, in February 

2013 we found that the Department of Energy (DOE) built on its Recovery 

23An example of an incident command system can be found within the Department of 

Homeland Security’s (DHS) National Incident Management System, which is intended to 

provide a consistent framework for incident management at all jurisdictional levels 

regardless of cause, size, or complexity of the situation. It also defines the roles and 

responsibilities of federal, state, and local governments during an emergency event.

DHS’s system has an incident command system component designed to coordinate the 

communications, personnel, and procedures of different agencies and levels of 

government within a common organizational structure during an emergency.

24Pub. L. No. 111-352, 124 Stat. 3866. GPRAMA updated the Government Performance 

and Results Act of 1993 (GPRA). Pub. L. No. 103-62, 107 Stat. 285.

Regular and Systematic 

Use of Data to Support 

Management Reviews
Page 19 GAO-14-219 Grant Lessons from the Recovery Act

Act-related performance reviews and established quarterly performance 

reviews, called business quarterly reviews, in 2011.25

As part of the Department of Housing and Urban Development’s (HUD)

implementation of the Recovery Act, the agency piloted a new approach

to data management and accountability called HUDStat. HUD’s Recovery 

Act team collected data about the status of projects and progress towards 

financial goals. Armed with this information, HUD leaders could identify 

and neutralize spending delays across the agency’s 80 field and regional 

offices. In some cases, a senior HUD official would make a phone call to 

a mayor or a governor to stress the need to spend funds quickly. In other 

cases, staff would refocus on regions where progress was slow and 

would work with grantees to move more quickly to promote economic 

growth. After the Recovery Act, and in accordance with GPRAMA 

requirements, HUD continued to use HUDStat to share data and 

resources across the agency.

Another control 

DOE implemented for large dollar projects was a “Stage-Gate” process, 

which did not allow the funds to be disbursed all at one time. It required 

the recipient to meet certain metrics before receiving additional funding at 

certain levels. DOE Office of Inspector General (OIG) officials believed 

this Stage-Gate approach was an effective internal control tool. PostRecovery, DOE has institutionalized both the business quarterly reviews 

and Stage-Gate processes.

The Recovery Act contained increased accountability requirements in the 

areas of reporting, audits, and evaluations to help ensure that tax dollars 

were being spent efficiently and effectively. At the same time, the act 

provided aggressive timelines—approximately 19 months—for the 

distribution of funds. The combination of these two factors placed high 

expectations on federal, state, and local governments and led to 

increased coordination both vertically across levels of government and 

horizontally within the same level of government to share information and 

work towards common goals.

 25GAO, Managing for Results: Data-Driven Performance Reviews Show Promise But 

Agencies Should Explore How to Involve Other Relevant Agencies, GAO-13-228

(Washington, D.C.: Feb. 27, 2103).

Heightened Accountability 

Requirements and 

Aggressive 

Implementation Timelines 

Led to Increased 

Coordination and 

Information Sharing
Page 20 GAO-14-219 Grant Lessons from the Recovery Act

Organizations involved in overseeing and implementing grants funded by 

the Recovery Act made use of both new and established networks to 

share information. Shortly after the Recovery Act was signed into law, our 

then Acting Comptroller General and the Chair of the Council of the 

Inspectors General on Integrity and Efficiency hosted a coordination 

meeting with the OIGs or their representatives from 17 federal agencies 

to discuss an approach to coordination and information sharing going 

forward. We also worked with state and local auditors and their 

associations to facilitate regular conference calls to discuss Recovery Act 

issues with a broad community of interested parties. Participants included 

the Association of Government Accountants; the Association of Local 

Government Auditors; the National Association of State Auditors, 

Comptrollers, and Treasurers; the Recovery Board; and federal OIGs.

Another active venue for information sharing was the National 

Intergovernmental Audit Forum (NIAF). The NIAF, led during this period 

by our then Acting Comptroller General, is an association that has existed 

for over three decades as a means for federal, state, and local audit 

executives to discuss issues of common interest and enhance 

accountability. NIAF’s May 2009 meeting brought together these 

executives and others including OMB, to update them on the Recovery 

Act and provide another opportunity to discuss emerging issues and 

challenges. In addition, several Intergovernmental Audit Forum meetings 

were scheduled at the regional level across the country and sought to do 

the same. This regional coordination and information sharing directly 

contributed to our Recovery Act work in the states. For example, our 

western regional director made a presentation at the Pacific Northwest 

Audit Forum regarding our efforts to coordinate with state and local 

officials in conducting Recovery Act oversight. In conjunction with that 

forum and at other related forums, she regularly met with the principals of 

state and local audit entities to coordinate oversight of Recovery Act 

spending.

Officials from New York City also played a role in creating networks to 

share information. Believing that large cities were probably facing similar 

issues and challenges, Recovery officials in New York City established 

the American Recovery and Reinvestment Act Big City Network (BCN) to 

serve as a peer exchange group and facilitate information sharing among 

large municipalities across the country. The group was composed of over 

20 large cities with geographical diversity, such as Los Angeles, 

Philadelphia, Phoenix, and Seattle, that received a significant amount of 

federal stimulus funding. The former head of the BCN told us that the 

organization held frequent teleconferences and used this collaboration to 

Networks Provided a 

Mechanism to Share 

Information
Page 21 GAO-14-219 Grant Lessons from the Recovery Act

elevate issues unique to large cities with OMB, the White House’s 

Recovery Implementation Office, and the Recovery Board. For example, 

BCN informally surveyed its members in January 2010 concerning each 

grant and associated funds they received. From this survey, BCN officials 

assembled a list of cross-jurisdictional issues reflecting the perspectives 

and experiences of large cities and shared them with the White House, 

OMB, and the Recovery Board. Likewise, OMB, the Recovery 

Implementation Office, and the Recovery Board used BCN as a vehicle 

for getting information out to its partners on the ground.

Similarly, at the state level, a network was established where state 

Recovery Act coordinators shared information and lessons learned on a 

weekly basis. This state-level network also discussed ongoing Recovery 

Act policy and operational issues with the White House, OMB, and the 

Recovery Board to ensure successful implementation. Federal officials 

joined the state calls on a regular basis. Both BCN and the state network 

proved to be especially helpful in fostering intergovernmental 

communications. For example, the former head of the BCN stated that in 

response to a Senate Committee request in 2012, New York City 

leveraged both BCN and the state Recovery Act coordinators’ network to 

inform the current discussion on the Digital Accountability and 

Transparency Act, proposed legislation which seeks to improve grant 

transparency through increased reporting.26

Under the tight time frames set for implementation of the Recovery Act, 

federal agencies needed to work together to accomplish their goals. For 

example, HUD and DOE shared a goal of weatherizing low-income 

households through long-term energy efficiency improvements. To get the 

projects under way as quickly as possible, they worked together to ensure 

that homeowners met income standards. Before Recovery Act 

implementation, both DOE and HUD conducted their own independent 

income verifications. In May of 2009, DOE and HUD entered into a 

memorandum of understanding that eliminated the need for separate 

DOE income verification for people whose incomes had already been 

verified by HUD. According to DOE officials, this collaboration helped 

Cities and states mobilized 

quickly and came together on key consensus principles for Congress’

consideration.

 26Digital Accountability and Transparency Act of 2013, H.R. 2061, 113th Cong. (2013); 

Digital Accountability and Transparency Act of 2013, S. 994, 113th Cong. (2013).

Organizations Worked 

Together in New Ways to 

Achieve Common Goals
Page 22 GAO-14-219 Grant Lessons from the Recovery Act

projects move faster, reduced the cost and administrative burden of 

duplicative verifications, and helped DOE weatherize numerous homes 

under the Recovery Act through 2013. DOE officials reported that 

between fiscal years 2010 and 2013, the joint effort helped weatherize 

approximately 1.7 million housing units, the majority of which were lowincome. This policy of sharing low-income verifications for weatherizing 

homes has continued post-Recovery Act.

At the state level, Massachusetts is an example where officials developed 

new ways of working together to achieve Recovery Act goals. For 

example, Massachusetts state officials established the Stimulus

Oversight and Prevention (STOP) Fraud Task Force in 2009 to fulfill the 

Recovery Act’s goal of preventing fraud, waste, and abuse of Recovery 

Act funds. This task force included the state OIG’s office, the Attorney 

General’s office, and the State Auditor. Over the next 2 years, the group 

met bimonthly to discuss fraud prevention and collaborated with several 

federal agencies including the Department of Justice, the Federal Bureau 

of Investigation, and HUD. The group also brought in federal OIGs

including DOE and Education, the state Comptroller’s office, and the

Massachusetts Recovery and Reinvestment Office to discuss our report 

findings and OMB guidance. According to officials from the 

Massachusetts Attorney General’s office, the task force improved 

communication and furthered efforts to avoid overlap.

Faced with the short time frames and accelerated roll out of Recovery Act 

funds, both the oversight community and agencies adjusted their 

oversight approach and innovated to foster accountability for Recovery 

Act funds at the federal and state agency levels. These organizations 

became more engaged in up-front analysis and monitoring of programs 

under the Recovery Act and their reviews were often issued before 

money was spent. These practices included (1) assessing and planning 

for risks up front; (2) reviewing programs before and while they were 

being funded rather than waiting until after programs were implemented; 

(3) communicating findings quickly through informal processes as 

opposed to regular full reports; and (4) using advanced data analytics.

At the federal level, several agency OIGs conducted up-front risk planning 

to proactively prepare for the influx of Recovery Act funds. For example, 

the Department of Transportation’s (DOT) OIG instituted a three-phase 

risk assessment process for DOT programs that received Recovery Act 

funds. The OIG first identified existing program risks based on past 

reports; it next assessed what the department was doing to address those 

The Recovery Act 

Prompted Adjustments 

and Innovations in 

Oversight to Foster 

Accountability

Increased Use of Up-Front 

Risk Assessments and 

Planning
Page 23 GAO-14-219 Grant Lessons from the Recovery Act

risks; and it then conducted the audit work. DOT’s OIG is continuing to

use this three-phase scan approach for its work on Hurricane Sandy.

At the Department of Education, when the OIG realized that Education’s 

discretionary grant budget would increase from a typical allotment of $60 

billion annually to over $100 billion under the Recovery Act, officials put 

aside their initial work plan and developed a new one which focused on 

the Recovery Act. Toward this end, the OIG conducted up-front risk 

assessments by looking at its prior work to identify persistent 

implementation issues going back to fiscal year 2003. The OIG then 

issued a 2009 capping report that summarized these issues. This report 

and additional risk assessments on Recovery Act-specific issues guided 

the OIG's internal control audits that focused on the use of funds, cash 

management, subrecipient monitoring, and data quality for Recovery Act 

education programs. 

Shortly after the Recovery Act was signed, DOE’s OIG reviewed the 

challenges the agency would need to address to effectively manage the 

unprecedented level of funding and to meet the goals of the Recovery 

Act. The resulting report was based on a body of work by the OIG to 

improve operations and management practices.27

At HUD, regional offices conducted front-end risk assessments of 

programs that would be receiving Recovery Act funds. The HUD OIG

considered these risk assessments when preparing its work plan and 

carrying out audits. The office also conducted capacity reviews for 

programs that field offices had identified as having known issues. The 

purpose of these capacity reviews was to enable the office to actively 

The OIG identified 

specific risks that they discovered during past reviews and investigations. 

The OIG also suggested actions that should be considered during 

Recovery Act planning and program execution to help reduce the 

likelihood that these historical problems would recur. Further, the OIG 

described the department’s initial efforts to identify risks and to develop 

strategies to satisfy the Recovery Act’s goals and objectives. In addition, 

the report outlined the OIG’s planned oversight approach which adopted 

a risk-based strategy that included, among other things, early evaluations 

of internal controls and assessments of performance outcomes.

 27Special Report on The American Recovery and Reinvestment Act at the Department of 

Energy (OAS-RA-09-01, March 2009). 
Page 24 GAO-14-219 Grant Lessons from the Recovery Act

address and work to resolve known issues before Recovery Act funds 

were distributed to programs.

At the state level, audit organizations also adjusted their usual 

approaches when planning and conducting reviews of grant programs 

that received Recovery Act funds. Several state auditors conducted extra 

audit work of state programs up front in an effort to identify risks and 

inform their work moving forward. For example, the Office of the 

California State Auditor conducted “readiness reviews” that highlighted 

known vulnerabilities in programs receiving Recovery Act money. The 

office used the information coming out of these reviews to identify specific 

issues to focus on in future work as well as to inform the oversight 

committees of the state legislature and other state officials involved in 

Recovery Act oversight and implementation. As a result of one such 

review that focused on DOE’s Weatherization Assistance Program, the 

State Auditor was able to identify key implementation issues that needed 

attention at a joint meeting of state and federal officials organized by the 

Governor’s Recovery Act Task Force. The readiness review identified 

specific areas where the program needed to improve and informed the 

frequency with which state auditors would go back to program officials to 

check on progress. According to the California state auditor, among the 

benefits of this approach was the feedback it provided to state agencies 

on their level of readiness as well as the detailed information given to 

both the state legislature and the Governor’s Recovery Act Task Force on 

the agency’s progress. The use of readiness reviews has continued postRecovery Act. Most recently, the office employed the approach in 2013 as 

it prepared to audit the implementation of the Affordable Care Act in 

California.

The Recovery Act’s short time frames prompted the oversight community 

to carry out some of its reviews in “real time” as Recovery funds were 

being rolled out, as opposed to the traditional approach of reviewing a 

program after implementation. Under this approach, members of the 

oversight community looked for ways to inform program officials of 

challenges and needed improvements much earlier in the process. For 

example, as described previously in table 1, the Recovery Act specified 

several roles for us, including conducting bimonthly reviews of selected 

states’ and localities’ use of funds made available under the Act. We 

subsequently selected a core group of 16 states and the District of 

Columbia to follow over the next few years to provide an ongoing 

longitudinal analysis of the use of funds provided in conjunction with the 

Recovery Act. The Recovery Act also assigned us a range of 

responsibilities to help promote accountability and transparency. Some 

Increased use of “Real Time”

Information
Page 25 GAO-14-219 Grant Lessons from the Recovery Act

were recurring requirements such as providing bimonthly reviews of the 

use of funds made available under various provisions of the Recovery Act 

by selected states and localities and reviews of quarterly reports on job 

creation and job retention as reported by Recovery Act fund recipients. 

Other requirements included targeted studies in several areas such as 

small business lending, education, and trade adjustment assistance. In 

total, we issued approximately 125 reports on, or related to, the Recovery 

Act resulting in more than 65 documented accomplishments.

The interest in obtaining “real time” feedback concerning Recovery Act 

implementation was not limited to the oversight community. For example, 

DOT’s Federal Highway Administration (FHWA) established National 

Review Teams (NRT) within 3 months of the Recovery Act’s passage to 

help assist its division offices attain the greater level of accountability and 

transparency called for under the Recovery Act. As we previously 

reported, the NRTs were composed of FHWA staff—separated from the 

rest of FHWA—to act as a neutral third party to conduct oversight.28

• a consistent, comparative perspective on the oversight regularly 

conducted by division offices, and the collection of information at the 

national level on both best practices and recurring trouble spots 

across FHWA division offices;

The 

mission of the NRTs was to conduct quick reviews of FHWA programs 

and assess processes and compliance with federal requirements in six 

key risk areas: (1) preliminary plans, specifications, and estimates; (2) 

contract administration; (3) quality assurance of construction materials; 

(4) local public agencies; (5) disadvantaged business enterprises; and (6) 

eligibility for payments. As a review progressed, the NRT discussed 

findings with division office and state transportation staff. According to 

FHWA officials, independent reviews had several benefits:

• additional “boots on the ground” for project-level oversight and 

increased awareness of federal oversight activity among states, 

Metropolitan Planning Organizations, and other transportation 

organizations receiving Recovery Act funds; and

• an independent outside voice to examine Recovery Act projects and 

point out problems, keeping the partnering relationship between the 

division offices and the state DOTs intact.

 28GAO, Highway Infrastructure: Federal-State Partnership Produces Benefits and Poses 

Oversight Risks, GAO-12-474 (Washington, D.C.: Apr. 26, 2012).
Page 26 GAO-14-219 Grant Lessons from the Recovery Act

Division offices and state officials with whom we spoke responded 

positively to the NRT reviews. The NRT was viewed as a success for 

FHWA and it has since added independent reviews based largely on the 

NRT model to provide independent corporate level review of projects and 

programs in addition to providing other support services.

The rapid pace at which Recovery Act funds were being distributed also 

prompted audit organizations to communicate their findings earlier in the 

audit process. For example, DOT’s OIG issued periodic advisories within 

the agency rather than waiting until an audit was completed to share its 

findings. According to OIG staff, these advisories informed the 

department of issues or concerns shortly after they were discovered, 

thereby permitting program staff to take corrective action much more 

quickly.

In our first report on our bimonthly reviews of the use of Recovery Act 

funds by selected states and localities, we determined that the Single 

Audit process needed adjustment to provide the necessary level of focus 

and accountability over Recovery Act funds in a timelier manner than the 

current schedule.29 Subsequently, we recommended that the director of 

OMB adjust the Single Audit process to provide for review of the design of 

internal controls during 2009 over programs to receive Recovery Act 

funding, before significant expenditures in 2010. In response, in October 

2009 OMB implemented the Single Audit Internal Control Project—a 

collaborative effort between 16 volunteer states receiving Recovery Act 

funds, their auditors, and the federal government—to achieve more timely 

communication of internal control deficiencies for higher-risk Recovery 

Act programs.30

 29GAO, Recovery Act: As Initial Implementation Unfolds in States and Localities, 

Continued Attention to Accountability Issues is Essential, 

The project encouraged auditors to identify and 

communicate significant deficiencies and material weaknesses in internal 

controls over compliance for selected major Recovery Act programs 3 

months sooner than the 9-month time frame required under statute. The 

project allowed program management officials at an audited agency to 

GAO-09-580 (Washington, D.C.: 

Apr. 23, 2009).

30GAO, Recovery Act: States’ and Localities’ Use of Funds and Actions Needed to 

Address Implementation Challenges and Bolster Accountability, GAO-10-604

(Washington, D.C.: May 26, 2010); and Recovery Act: One Year Later, States’ and 

Localities’ Use of Funds and Opportunities to Strengthen Accountability, GAO-10-437

(Washington, D.C.: Mar. 3, 2010).

Earlier Communication of 

Audit Findings
Page 27 GAO-14-219 Grant Lessons from the Recovery Act

expedite corrective action and help mitigate the risk of improper Recovery 

Act expenditures. In May 2010, we reported that the project met some of 

its objectives and was helpful in identifying critical areas where further 

OMB actions were needed to improve the Single Audit process over 

Recovery Act funding.31

Auditors at the local level also communicated their findings early. For 

example, the Denver City Auditor’s Office adopted new practices to 

provide more timely information on Recovery Act programs to the Mayor 

and other key officials, particularly on issues affecting compliance with 

Recovery Act reporting requirements. Using a tiered notification process, 

the auditor’s office would initially notify the appropriate city department 

informally through e-mail or a similar means of potential issues they were 

finding during an on-going audit. The auditor’s office would revisit the 

issues later and, if the office determined the issue had not been 

addressed, it would then formally communicate any substantive issue on 

a real-time basis through an “audit alert.” These alerts were typically brief 

documents and went to the affected departments as well as directly to the 

Mayor’s work group that oversaw the city’s Recovery Act implementation. 

If appropriate action was still not forthcoming, the city auditor might issue 

a public alert or maybe a full public audit report. According to a senior city 

audit official, the alerts were beneficial because the city auditor did not 

have to conduct a full audit to communicate risks and findings to decision 

makers, allowing them to more quickly address problems. The city auditor 

issued its first audit alert in October 2009 and subsequently issued 

another one in February 2010 when problems from the first one had not 

been addressed. After the second alert, the city administration corrected 

the identified problems.

To further increase accountability under the Recovery Act, the Recovery 

Board utilized innovative data analytics in carrying out its oversight 

responsibilities. Data analytics is a term typically used to describe a 

variety of techniques that can be used to analyze and interpret data to, 

among other things, help identify and reduce fraud, waste, and abuse. 

Specifically, predictive analytic technologies can be used to identify 

potential fraud and errors before payments are made, while other

techniques, such as data-mining and data-matching of multiple 

databases, can identify fraud or improper payments that have already 

 31GAO-10-604.

Use of Advanced 

Data Analytics
Page 28 GAO-14-219 Grant Lessons from the Recovery Act

been awarded, thus assisting agencies in recovering these dollars.32

According to Recovery Board staff, the results of these approaches 

provided the OIG community and other oversight authorities with 

information they could use to focus limited resources on cities, regions, 

and high-risk government programs where historical data and current 

trends suggested the likelihood of future risk. ROC analysts would crossreference lists of grant recipients or sub-recipients against a variety of 

databases to look for risk indicators such as criminal convictions, 

lawsuits, tax liens, bankruptcies, risky financial deals, or 

suspension/debarment proceedings.

In 

October 2009, the Recovery Board established an innovative center to 

analyze the use of Recovery Act funds by employing data analytics (see 

figure 3). The Recovery Operations Center (ROC) served as a centralized 

location for analyzing Recovery Act funds and their recipients through the 

use of such predictive analytic technologies.

One tool used to do this is link analysis, which assists the analyst in 

making connections by visually representing investigative findings. Link 

analysis charts visually depict how individuals and companies are 

connected, what awards an entity has received, and how these actors 

may be linked to any derogatory information obtained from the databases 

described above . Such tools, when combined with enhanced Geographic 

Information System capabilities, enable ROC analysts to conduct 

geospatial analysis by displaying data from multiple datasets on maps to 

help them make linkages and discover potential problems.

For example, the ROC helped a federal agency investigate possible 

contract fraud related to over-billing on multiple contracts. ROC analysts 

found 99 recipient awards made to a single company totaling over $12 

million. In another example, the ROC helped to investigate allegations of 

false claims and major fraud against the United States. ROC analysts 

found officers of one company were also executives of more than 15 

other companies, many of which were located at the same address, and 

collectively received millions in Recovery Act funds.

 32GAO, Highlights of a Forum: Data Analytics for Oversight and Law Enforcement, 

GAO-13-680SP (Washington, D.C.: July 2013).
Page 29 GAO-14-219 Grant Lessons from the Recovery Act

More recently, the ROC has been used to track funds and help reduce 

fraud, waste, and abuse related to the tens of billions of dollars that have 

been awarded to states and communities to assist in their recovery after 

Hurricane Sandy hit in October 2012. Recovery Board staff have sought 

to leverage the expertise they have developed in analyzing financial 

spending and identifying potential fraud and high-risk indicators based on 

their experience with the Recovery Act.
Page 30 GAO-14-219 Grant Lessons from the Recovery Act

Figure 3. An Analyst Working in the Recovery Board’s Recovery Operations Center and a Sample Output of One of ROC’s 

Link Analysis Tools.
Page 31 GAO-14-219 Grant Lessons from the Recovery Act

To assure the public that their tax dollars were being spent efficiently and 

effectively, the Recovery Act called for increased oversight and 

accountability of those funds by oversight and program entities at the 

federal, state, and local levels. This increased emphasis on oversight and 

accountability presented challenges for those entities stemming from (1) a 

lack of financial resources to conduct oversight at the state and local 

levels, (2) human capital issues, and (3) the accelerated roll out of 

Recovery Act funds.

Officials with whom we spoke in several states expressed concerns that 

the Recovery Act did not provide funding to state oversight entities, 

although it placed additional federal requirements on them to provide 

proper accounting and to ensure transparency. Federal agency OIG

offices received a significant amount to conduct oversight of Recovery Act 

funds—ranging anywhere from $1 million to $48.25 million distributed to 

more than 28 agencies. In contrast, states and localities relied on their 

existing budgets and human capital resources (and, in some cases, 

supplemented by a small percentage of administrative funds) to carry out

their additional oversight activities.

Due to fiscal constraints, states reported significant declines in the 

number of management and oversight staff—limiting states’ ability to 

ensure proper implementation and management of Recovery Act funds. 

With oversight capacity already strained in many states, the situation was 

further exacerbated by increased workloads resulting from 

implementation of new or expanded grant programs funded by the 

Recovery Act. For example, Massachusetts officials explained that the

state oversight community faced budget cuts of about 10 percent. 

According to officials from the OIG and the State Auditor’s office, their 

budgets are almost entirely composed of salaries, and any cuts in funding 

resulted in fewer staff available to conduct oversight. As a result of the 

cuts, the Inspector General stated that his department did not have the 

resources to conduct any additional oversight related to Recovery Act 

funds. Further, the Massachusetts State Auditor described how his 

department had to furlough staff for 6 days in fiscal year 2009. In 

recognition of this situation and reflective of the state’s desire to pursue 

fraud in the Recovery Act program, for state fiscal years 2009 through 

2012, the Massachusetts Recovery and Reinvestment Office allocated 

funds from the state’s central administration account to the Attorney 

General, State Auditor, and OIG offices to ensure that oversight would 

take place.

The Recovery Act’s 

Accountability 

Requirements Also 

Presented Oversight 

Challenges

Limited Resources to Conduct 

Oversight at the State and 

Local Levels
Page 32 GAO-14-219 Grant Lessons from the Recovery Act

The California State Auditor also cited the lack of federal funding for state 

and local oversight as a challenge to ensuring accountability in the 

implementation of the Recovery Act. In a 2009 testimony to the California 

state budget committee, the State Auditor said that her office would need 

to conduct an additional 14 audits based on an initial analysis of the 

estimated stimulus funds that California would receive. Furthermore, the 

programs that the office was auditing at the time received additional 

funds, which potentially increased the workload and cost to audit those 

programs as well. Finally, new requirements created by the Recovery Act 

for existing programs also impacted the State Audit Office’s efforts. The 

California State Auditor noted that given the additional responsibilities her 

office faced due to the influx of stimulus funds, any budget cuts would 

adversely affect the office’s ability to conduct audits.

In another example, Colorado’s state auditor reported that state oversight 

capacity was limited during Recovery Act implementation, noting that the 

Department of Health Care Policy and Financing had three controllers in 

4 years and the state legislature’s Joint Budget Committee cut field audit 

staff for the Department of Human Services in half. In addition, the 

Colorado DOT’s deputy controller position was vacant, as was the 

Department of Personnel & Administration’s internal auditor position. 

Colorado officials noted that these actions were, in part, due to 

administrative cuts during a past economic downturn in an attempt to 

maintain program delivery levels.

The President’s goal for quickly spending Recovery Act funds created a 

large spike in spending for a number of programs in the 28 agencies 

receiving Recovery Act funds. The act also created a number of new

programs—requiring agencies to move quickly. As a result, under the 

Recovery Act’s accelerated rollout requirements, some federal agencies 

and states faced oversight challenges.

For example, DOT and states faced numerous challenges in 

implementing the Recovery Act’s maintenance-of-effort oversight 

mechanism due to the accelerated rollout of funds. The Recovery Act 

contains maintenance of effort provisions designed to prevent recipients, 

such as state DOTs, public housing agencies, and private companies, 

from substituting planned spending for a given program with Recovery 

Act funds. That is, the provisions ensured that the increased federal 

spending would supplement rather than replace state, local, or private 

Accelerated Rollout of 

Recovery Act Programs 

Presented Oversight 

Challenges
Page 33 GAO-14-219 Grant Lessons from the Recovery Act

spending.33 The maintenance-of-effort provision for DOT in the Recovery 

Act required the governor of each state to certify that the state would 

maintain its planned level of transportation spending from February 17, 

2009, through September 30, 2010.34

At DOE, the department initially encountered some challenges with fully 

developing a management and accountability infrastructure because of 

the large amount of Recovery Act funding it received in a short period of 

time. According to an official in the DOE OIG’s office, this was especially 

Twenty-one states did not meet 

their certified planned spending levels, and a January 2011 preliminary 

DOT report found that some of these states were unclear on what 

constituted “state funding”. DOT also found some of the states were 

unclear about how well DOT guidance on calculating planned 

expenditures would work in the many different contexts in which it would 

have to operate. As a result, many problems came to light only after DOT 

had issued initial guidance and states had submitted their first 

certifications. DOT issued guidance seven times during the first year after 

the act was signed to clarify how states were to calculate their planned or 

actual expenditures for their maintenance-of-effort certifications. Further, 

many states did not have an existing means to identify planned 

transportation expenditures for a specific period, and their financial and 

accounting systems did not capture that data. Therefore, according to 

DOT and some state officials, a more narrowly focused requirement 

applying only to programs administered by state DOTs or to programs 

that typically receive state funding could have helped address the 

maintenance-of-effort challenges. DOT and state officials told us that 

while the maintenance-of-effort requirement can be useful for ensuring 

continued investment in transportation, allowing more flexibility for 

differences in states and programs, and adjustments for unexpected 

changes to states’ economic conditions, should be considered for future 

provisions.

 33GAO, Recovery Act: Funding Used for Transportation Infrastructure Projects, but Some 

Requirements Proved Challenging, GAO-11-600 (Washington, D.C.: June 29, 2011) and 

Recovery Act: Planned Efforts and Challenges in Evaluating Compliance with 

Maintenance of Effort and Similar Provisions, GAO-10-247 (Washington, D.C.: Nov. 30, 

2009).

34Recovery Act, div. A, § 1201(a), 123 Stat. at 212.
Page 34 GAO-14-219 Grant Lessons from the Recovery Act

true with the new Energy Efficiency Conservation Block Grant program.35

This official told us that some states and localities also did not have the 

infrastructure in place (including the necessary training) to manage the 

large amount of additional federal funding. Further, DOE required 

recipients’ weatherization plans to address how the respective state’s 

current and expanded workforce (employees and contractors) would be 

trained. In May 2010, according to DOE, the agency was in the process of 

developing national standards for weatherization certification and 

accreditation. DOE estimated that developing the standards would take 

about 2 years—a time frame that did not match the accelerated timing of 

the Recovery Act’s funds’ distribution. Several years after the Recovery 

Act was implemented, DOE reported that it had completed certain 

milestones toward developing national standards for weatherization, 

training, certification, and accreditation, but was still working to finalize 

other elements such as its national certification program.

In an April 2009 memorandum, OMB directed agencies to follow leading 

practices for federal website development and management, such as 

those listed on HowTo.gov, a website managed by the Federal Web 

Managers Council and the General Services Administration.36

 35Although the Energy Efficiency Conservation Block Grant was authorized in 2007 by the 

Energy Independence and Security Act of 2007, it was not funded (and the monies could 

not be spent) until the Recovery Act was enacted in 2009 and therefore is considered a 

new program.

HowTo.gov 

makes available a list of the “Top 10 Best Practices” for federal websites 

as a resource to improve how agencies communicate and interact with 

36See http://www.howto.gov/about-us, accessed December 12, 2013.

The Recovery Act 

Resulted in Increased 

Transparency but 

Also Presented 

Challenges

Recovery Act 

Transparency Websites 

Embody Several 

Leading Practices
Page 35 GAO-14-219 Grant Lessons from the Recovery Act

customers and provide services.37

Consistent with leading practices for the development of federal websites 

on HowTo.gov, Recovery.gov and selected state Recovery websites

clearly identify for the user the purposes of the site and the ways it can be 

used to accomplish tasks efficiently. According to HowTo.gov, this is 

important because people often visit government websites with a specific 

task in mind, and if it is not easy to find the information quickly that they 

need to complete that task, they will leave the site. Recovery.gov contains 

an entire page that outlines what users can do on the site, including how 

to use the raw data available through the website; report waste, fraud, 

and abuse; or find job and grant opportunities. Further, Recovery.gov has 

a “Get Started” page with an overview of the information on the site 

including Recovery Act goals, the Recovery Board’s mission, what 

information is not available on the website, and what users can do on the 

website.

Recovery.gov, as well as selected 

state and city Recovery websites, demonstrated several of these leading 

practices including establishing a clear purpose of the website, using 

social networking tools to garner interest in the website, tailoring websites 

to meet audience needs, and obtaining stakeholder input when designing

the website. In addition, we found that some websites enabled placebased performance reporting.

Similarly, Massachusetts’ Recovery website has tabs on its homepage 

that link to information on how to use the website to track Recovery Act 

jobs, spending, vendors, and the impact of Recovery Act dollars in the 

state.38

Another leading practice for federal websites includes the use of social 

networking tools. According to Howto.gov, social media is transforming 

how government engages with citizens, allowing agencies to share 

information and deliver services more quickly and effectively than ever 

before. Recovery.gov and selected state and local Recovery websites 

use social networking tools to garner interest in their websites. These 

For example, the “track jobs” page informs users how they can 

track jobs created and retained in their community and provides a user 

guide to assist them in their query.

 37GAO, Managing for Results: Leading Practices Should Guide the Continued 

Development of Performance.gov, GAO-13-517 (Washington, D.C.: June 6, 2013).

38See http://www.mass.gov/recovery/, accessed December 12, 2013.

Establish a Clear Purpose

of the Website

Use Social Networking Tools to 

Garner Interest in the Website
Page 36 GAO-14-219 Grant Lessons from the Recovery Act

websites integrated Web 2.0 technologies to help people share and use 

the information they provide. For example, to develop web-based 

communities of interest, Recovery.gov has a dedicated social media web 

page that has links to Recovery’s presence on various social-networking 

tools such as Facebook, Twitter, YouTube, and Flickr.39 Recovery.gov’s 

social media page enables users to (1) download a Recovery application 

for iPhones and for iPads with a mapping feature showing how Recovery 

Act funds were being spent, (2) sign up for a Recovery.gov month-inreview email, and (3) sign up to receive Recovery RSS web feeds.40

New York City also made use of social networking to communicate 

information regarding Recovery Act implementation through the use of a

Tumblr blog.

Finally, Recovery.gov also has a blog, written by Recovery Board staff, 

with a stated purpose to further a dialogue on transparency and 

accountability in government, as well as to provide a forum for thoughts, 

comments, and suggestions from the public.

41 City officials used this blog to communicate stories and 

examples to its residents about how it was using Recovery Act funds and 

the impact of those investments.42

 39Facebook is a social networking website that allows registered users to create profiles, 

upload photos and video, and send messages. Twitter is a social networking 

City officials said the blog allowed 

them to get behind full-time equivalent numbers and dollar expenditures 

so that people could better understand how the Recovery Act was helping 

them tackle problems where they work and live. For example, the blog 

described one project that had no net increase in jobs but still made a 

valuable difference for the city because Recovery Act funds were used to 

repair 300,000 potholes and move to zero diesel fuel emissions for city 

vehicles.

microblogging service that allows members to broadcast short posts called tweets. Twitter 

members can broadcast tweets and follow other users’ tweets on multiple platforms and 

devices. YouTube is a video-sharing website that allows members to store and share

video content. Flickr is an image hosting and video hosting website that allows users to 

share and embed photographs.

40A feed is a regularly updated summary of new content that also links to the content. The 

RSS feed allows Recovery.gov to publish frequently updated information by syndicating 

content automatically. 

41Tumblr is a microblogging platform and social networking website which allows users to 

post multimedia and other content to a short-form blog.

42See http://nycarra.tumblr.com/, accessed December 12, 2013.
Page 37 GAO-14-219 Grant Lessons from the Recovery Act

Organizing a website according to the needs of its audience is also a key 

leading practice for federal websites since an agency’s goal is to build the 

right website for the people who need it and serve them effectively by 

learning as much as possible about the website’s customers and what 

they do. Recovery.gov has dedicated pages for different audiences that 

compile and organize relevant resources according to their needs and 

interests. On its home page, Recovery.gov has a tab which provides links 

to pages designed with specific users in mind such as citizens, the press, 

and grant recipients. There are also links to pages on neighborhood 

Recovery Act projects, information on the Recovery Board, and other 

information users are looking for. For example, grant recipients have a 

dedicated page that provides resources such as reporting timelines, user 

guides, a service/help desk, recipient reporting information, and a 

recipient awards map. (See figure 4.)

Figure 4: Screenshot of Recovery.gov User Identification Feature

Note: The link to the above web page is 

http://www.recovery.gov/arra/Pages/audience_landing.aspx

Tailor Website to Meet 

Audience Needs
Page 38 GAO-14-219 Grant Lessons from the Recovery Act

On Recovery.gov’s “Developer Center” web page, users can access data 

reported by recipients of Recovery awards through the Recovery 

application program interface (API) and the Mapping API.

43 Users can 

also find widgets providing data summaries by state, county, 

congressional district, or ZIP code as reported by recipients.44

The state of Massachusetts also tailored its Recovery Act website to meet 

its audience’s needs. Prior to its implementation of the Recovery Act’s 

transparency provisions, Massachusetts had little experience with 

electronic reporting and disclosure of federal contracts, grants, and loans. 

The MassRecovery website provided weekly citizen updates and 

testimonials of how spending has benefited lives. The Citizens’ Update 

web page provides a summary of where the state’s Recovery Act dollars 

are going, where jobs are being created and retained, and information on 

beneficiaries of funds received. In December 2009, MASSPIRG, an 

independent consumer research group, issued a brief pointing to the 

strengths of the Massachusetts Recovery website including the ability of 

the Citizens’ Update web page to show money spent and jobs created 

and retained in easy-to-read pie charts and tables; a summary of funds 

distributed through the state; and an interactive state map of Recovery 

Act spending. Further, in January 2010, Good Jobs First, a national policy 

resource center, reviewed and evaluated states’ Recovery Act websites. 

The organization ranked Massachusetts’ Recovery website on its top 10 

list citing such beneficial features as the site’s comprehensive search 

engine, data download capability, and information on five key Recovery 

Act project elements—description, dollar amount, recipient name, status, 

and the text of the award.

The web 

page also has a tool for users to build customized charts and graphs 

displaying information such as funds awarded and received by state, 

agencies by number of awards, and spending categories by funds 

awarded.

 43An API specifies how some software components should interact with each other. APIs 

make it easier for software to interact with an outside program like a database or computer 

service such as a display control.

44A widget is an application that allows a website to perform a function, ranging from 

displaying a simple clock to pulling data from multiple sources for display. Recovery.gov 

provides widgets that let users display state-level recipient data or search the 

Recovery.gov databases from their own websites.
Page 39 GAO-14-219 Grant Lessons from the Recovery Act

Leading website practices also recommend that developers obtain 

stakeholder input when designing federal websites by engaging potential 

users through focus groups and other outreach; regularly conducting 

usability tests to gather insight into navigation, the organization of 

content, and the ease with which different types of users can complete 

specific tasks; and collecting and analyzing performance, customer 

satisfaction, and other metrics. According to leading website practices, 

these efforts are important for collecting and analyzing information about 

audiences, their needs, and how they are using, or want to use, the 

website.

The developers of Recovery.gov followed this leading practice by using 

input from user forums, focus groups, and usability testing with interested 

citizens to collect feedback and recommendations, which then inform the 

development of the website from its initial stages. For example, teaming 

with OMB and the National Academy of Public Administration, the 

developers of Recovery.gov hosted a week-long electronic town hall 

meeting at the end of April 2009 entitled “Recovery Dialogue on 

Information Technology Solutions.” Over 500 citizens, information 

technology specialists, and website development experts registered for 

the event and submitted numerous ideas. Recovery.gov adopted some of 

the ideas right away and included others in the re-launched version of the 

website in September 2009. These changes included a standardized 

reporting system for recipients, a greater use of maps, and a feedback 

section for users. Additionally, in October 2009, Recovery.gov developers 

conducted remote usability testing with 72 users, where the developers 

received suggested changes, some of which they later implemented.

Further, in 2012, significant changes were made to Recovery.gov based 

on user feedback on the website. These changes included creating a 

recipient and agency data page, agency profiles, and a new Recipient 

Projects Map with a series of dropdown menus and checkboxes that 

enable users to filter data so they can see it in a targeted fashion (for 

example, by state, agency, or category).

For websites covering numerous projects at various locations, a placebased geographic information system can be a useful tool. According to 

the White House’s Digital Government Strategy, the federal government 

needs to be customer-centric when designing digital service platforms 

such as websites. In other words, agencies need to be responsive to 

customers’ needs by making it easy to find and share electronic 

information and accomplish important tasks. From the beginning, 

recipient reported data on Recovery.gov was geo-coded in a way that 

made it possible for users to find awards and track the progress of 

Obtain Stakeholder Input 

When Designing the Website

Enable Place-Based 

Performance Reporting
Page 40 GAO-14-219 Grant Lessons from the Recovery Act

projects on a block-by-block basis. The presentation of information on 

Recovery.gov and on many state websites generally targeted individual 

citizens who were not experts in data analysis. The format and content of 

data prioritized mapping capabilities and invited people to enter their ZIP 

code and locate projects in their immediate area. For example, figure 5 

shows the map a user sees if ZIP code 30318 in Georgia is entered into 

this web page. From this map, the user can click on any of the dots that 

represent Recovery projects to find out information such as the project 

recipient name, award amount, project description, number of jobs 

created, and completion status. Additional information available to users 

includes the amount of funds received by recipients as well as the overall

distribution of grants by funding categories for that area.
Page 41 GAO-14-219 Grant Lessons from the Recovery Act

Figure 5: Screenshot of Recovery.gov’s Recipient Projects Page for a Georgia 

ZIP Code, 30318

Note: The link to access Recovery.gov’s recipient projects page can be found at

http://www.recovery.gov/arra/Transparency/RecoveryData/Pages/RecipientReportedData

Map.aspx

States and localities also utilized mapping features on their Recovery 

websites. For example, in New York City, Recovery officials launched a 
Page 42 GAO-14-219 Grant Lessons from the Recovery Act

Recovery Act website, the NYCStat Stimulus Tracker, as an interactive, 

comprehensive reporting tool. The federal government’s website, 

Recovery.gov, served as the design inspiration and, according to a senior 

city official, Stimulus Tracker was one of the first publicly-accessible 

websites to report Recovery Act data for a local jurisdiction. City 

Recovery officials were able to develop and launch New York City’s 

stimulus website more quickly than other locations—approximately 6 

weeks from start to completion—because they were able to leverage a 

previously implemented information technology platform to support 

citywide performance reporting. Stimulus Tracker allowed the public to 

explore several levels deeper than what was at Recovery.gov, which 

reported at the funding award level. For example, Stimulus Tracker broke 

down each award into several projects, each of which had its own 

dashboard page that displayed information such as (1) the status of the 

project, (2) the percentage of total funds spent, (3) start date and 

spending deadlines, and (4) the number of jobs created or retained.

Visitors to the site could drill into a record of every payment made with 

stimulus funds through the additional feature “Payment Tracker” and 

every contract to carry out stimulus-funded work through “Contract 

Tracker.”

Stimulus Tracker also offered an interactive map for site visitors who were 

interested in knowing how stimulus dollars were allocated geographically 

and where specific projects were located. This information was layered on 

top of the city’s existing online map portal. It included such items as the 

locations of schools, libraries, hospitals, and subways, as well as online 

property, building, statistics, and census information. As New York City’s 

existing online map portal could already be navigated either by entering a 

specific address or simply using zoom and scroll tools, city Recovery Act 

officials were able to build on this application and include a city mapping 

tool for Recovery Act funds where the public could find any project with a 

discrete location. See figure 6 for a screen shot of New York City’s 

mapping tool depicting the city’s Recovery Act projects.
Page 43 GAO-14-219 Grant Lessons from the Recovery Act

Figure 6: Screenshot of NYCStat Stimulus Tracker Mapping Feature

Note: The link to the NYC Stimulus Tracker webpage is 

http://maps.nyc.gov/doitt/nycitymap/?featuretypes=STIMULUS
Page 44 GAO-14-219 Grant Lessons from the Recovery Act

The Recovery Act requires recipients to report on their use of funding and

agencies that provide those funds to make the reports publicly available.45

The Recovery Act’s recipient reporting requirements apply only to 

nonfederal recipients of funding, including all entities other than 

individuals receiving Recovery Act funds directly from the federal 

government such as state and local governments, private companies, 

educational institutions, nonprofits, and other private organizations. As 

required by section 1512(c) of the Recovery Act, recipients were to 

submit quarterly reports that included the total amount of Recovery Act 

funds received, the amount of funds expended or obligated to projects or 

activities, and a detailed list of those projects or activities.46 For each 

project or activity, the detailed list was to include the project’s name, 

description, and an evaluation of its completion status. Also, the recipient 

reports were to include detailed information on any subcontracts or 

subgrants as required by the Federal Funding Accountability and 

Transparency Act of 2006.47

With the Recovery Act’s enhanced reporting requirements on spending, 

agencies and recipients faced several challenges. Many agencies and 

state and local partners were limited in their capacity to meet the 

enhanced reporting requirements due to a lack of knowledge and 

For example, recipient reports are required 

to also include details on sub-awards and other payments.

 45When measuring the implementation of Recovery Act, both the amount and speed of 

grant funding can be thought of as output measures. These measures typically describe 

an activity or effort including a description of the characteristics (e.g., amount or 

timeliness) established as standards for the activity (in this case grant funding). In 

contrast, outcome measures provide an assessment of results compared to the intended 

purpose to be achieved.

46These reports were submitted to FederalReporting.gov, the central governmentwide 

data collection system for federal agencies and recipients of federal awards using 

Recovery Act funds. 

4731 U.S.C. § 6101 note.

Recovery Act Performance 

Was Mostly Measured 

by Outputs Rather 

than Outcomes, and 

Challenges with Both 

Existed

Recipients and Agencies Were 

Required to Report Amount 

and Speed of Funding but 

Faced Challenges in Doing So
Page 45 GAO-14-219 Grant Lessons from the Recovery Act

expertise. Others struggled with the burden of double reporting when they 

had to report to federal systems tracking Recovery dollars as well as to 

agency systems because, in some cases, agencies required more data to 

manage their programs. Finally, some had trouble reporting data for 

certain projects within the operational limitations of place-based data 

mapping systems.

Capacity to meet reporting requirements. Many state and local 

partners were limited in their capacity to meet spending reporting 

requirements because they lacked knowledge and expertise. Using a 

centralized mechanism like FederalReporting.gov to capture recipient 

reporting information was a new process that recipients and agencies had 

to learn. We have previously reported on the questions raised by state 

officials regarding the reporting capacities of some local organizations, 

particularly small rural entities, boards, or commissions, and private 

entities not used to doing business with the federal government.48

Officials at several agencies suggested that if FederalReporting.gov had 

allowed certain key award and identifying data fields to be pre-populated 

each quarter, it would have likely resulted in fewer data errors for 

agencies to address and eased the reporting burden on recipients. In our 

September 2013 report and testimony on federal data transparency, we 

concluded that the transparency envisioned under the Recovery Act for 

tracking spending was unprecedented for the federal government, 

requiring the development of a system that could track billions of dollars 

disbursed to thousands of recipients. Such a system needed to be 

operational quickly to enable posting of spending information rapidly for a 

variety of programs. However, because agency systems did not collect 

spending data in a consistent manner, the most expedient approach for 

In 

addition, some state officials said that the Recovery Act’s requirement 

that recipients report on the use of funds within 10 days after a quarter 

ends was a challenge because some sub-recipients were unable to send 

them the needed data on time.

 48GAO, Recovery Act: As Initial Implementation Unfolds in States and Localities, 

Continued Attention to Accountability Issues is Essential, GAO-09-580 (Washington, D.C.: 

Apr. 23, 2009).
Page 46 GAO-14-219 Grant Lessons from the Recovery Act

Recovery Act reporting was to collect data directly from fund recipients.49

Recipients had the additional burden of having to provide this information 

and when the data had to be entered manually, it could impact the 

accuracy of the data.50 Thus, in September 2013 we recommended that 

the director of OMB, in collaboration with members of the Government 

Accountability and Transparency Board, develop a plan to implement 

comprehensive transparency reform, including a long-term timeline and 

requirements for data standards, such as establishing a uniform award 

identification system across the federal government.51

Earlier this year, the Recovery Board noted that agencies and OIGs also 

experienced difficulties adapting to the more frequent reporting (every 

quarter) and more detailed reporting (e.g., jobs created or individual 

project activities) required of most government grant recipients.52

 49GAO, Federal Data Transparency: Opportunities Remain to Incorporate Recovery Act 

Lessons Learned, 

Agency 

officials acknowledged spending considerable staff hours training 

recipients, providing technical assistance to them, verifying and validating 

their data, and following up with them when issues arose. Despite efforts 

to streamline and enhance existing review protocols, agencies still 

needed skilled people to review and process applications for awards. 

Although agencies and OIGs credited outreach to recipients for reducing 

noncompliance with reporting requirements, the amount of staffing 

resources it took to conduct that outreach was significant.

GAO-13-871T (Washington, D.C.: Sept. 18, 2013); Federal Data 

Transparency: Opportunities Remain to Incorporate Lessons Learned as Availability of 

Spending Data Increases, GAO-13-758 (Washington, D.C.: Sept. 12, 2013); and 

GAO-13-680SP.

50After the first few quarters of Recovery Act reporting, the system stabilized so recipients 

generally only needed to update a few data fields each cycle.

51OMB staff agreed that the Government Accountability and Transparency Board’s early 

plan provides an initial strategy and added that multiple initiatives are under way. One of 

these initiatives is the administration’s fiscal year 2014 budget proposal that would 

operationalize comprehensive transparency through the transfer of USAspending.gov 

from the General Services Administration to the Department of the Treasury.

52This report was issued by the Department of Interior’s OIG on behalf of the Recovery 

Board and included input from sixteen agencies and their OIGs. For more, see U. S. 

Department of Interior, Office of the Inspector General, Lessons Learned from the 

Recovery Act: An Agency and OIG Retrospective, Report No. RO-SP-MOI-0008-2012 

(Washington, D.C.: May 2013).
Page 47 GAO-14-219 Grant Lessons from the Recovery Act

Double reporting. We have previously noted that recipients of Recovery 

Act funds were required to report similar information to both agency 

reporting systems and FederalReporting.gov.53

At DOT, officials preferred using the agency’s own data because it was

more detailed and was reported monthly—more frequently than the 

Recovery.gov data. In a focus group involving state transportation 

officials, several echoed the redundancy of reporting systems. These 

officials indicated that having to report to three systems—the internal 

state system, DOT’s system, and FederalReporting.gov—increased their 

agencies’ burden. As we reported in our previously mentioned September 

2013 report and testimony on federal data transparency efforts, the lack 

of consistent data and standards and commonality in how data elements 

are defined places undue burden on federal fund recipients. This can 

result in them having to report the same information multiple times via 

disparate reporting platforms.

Several federal agency 

and state government officials we spoke with also mentioned that 

reporting to FederalReporting.gov resulted in double reporting for their 

agency and grantees as several of them deemed their existing internal 

systems superior and therefore would end up reporting to both. For 

example, at HUD, program offices were unable to abandon their 

established reporting systems because the agency’s systems collected 

data necessary to support HUD’s grants management and oversight 

processes. HUD officials told us that requiring grantees to report using

two systems resulted in double reporting of data and proved burdensome 

to recipients and to HUD staff who spent many hours correcting 

inaccurate entries.

54

Difficulty of using place-based GIS data for some types of projects.

While Recovery.gov enabled users to locate Recovery Act projects on a 

block-by-block basis, some of the Recovery Act data did not lend itself to 

To address this issue, as OMB developed 

procedures for reporting on the use of federal funds, it directed recipients 

of covered funds to use a series of standardized data elements. Further, 

rather than report to multiple government entities, each with its own 

disparate reporting requirements, all recipients of Recovery Act funds 

were required to centrally report into the Recovery Board’s inbound 

reporting website, FederalReporting.gov.

 53See GAO-12-913T.

54GAO-13-871T and GAO-13-758.
Page 48 GAO-14-219 Grant Lessons from the Recovery Act

the geospatial reporting presentation format on the website. For example, 

according to Recovery Board officials, the website only allowed one 

location to be reported per project even though some projects spanned 

multiple locations. Therefore, if a DOT highway project crossed multiple 

ZIP codes, only one location of performance could be reported. Further, 

certain locations were difficult to map such as rural roads, post office 

boxes, county level data, and consultant contractors who worked out of 

their homes.

The other major performance measure required under the Recovery Act 

focused on the estimate of the number of jobs created or number of jobs 

retained as a result of funding provided by the act. In addition to the 

previously described reporting on funds spent and activities, recipients 

were required in their quarterly reports to estimate the number of jobs 

created or retained by that project or activity.55 OMB issued clarifying 

guidance for recipient reporting in June 2009 and recipients began 

reporting on jobs starting in October 2009.56 Among other things, the 

guidance clarified that recipients of Recovery Act funds were to report 

only on jobs directly created or retained by Recovery Act-funded projects, 

activities, and contracts. Recipients were not expected to report on the 

employment impact on materials suppliers (“indirect” jobs) or on the local 

community. Recipients had 10 days after the end of each calendar 

quarter to report. OMB’s guidance also provided additional instruction on 

calculating the number of jobs created or retained by Recovery Act

funding on a full-time equivalent (FTE) basis.57

Recipients faced several challenges meeting these requirements. They 

had difficulty accurately defining FTEs, as various recipients interpreted 

and applied the FTE guidance from OMB differently. Further, many 

recipients struggled to meet reporting deadlines as they had little time to 

 55Recovery Act, div. A, § 1512(c)(3)(D), 123 Stat. at 288. 

56These reporting requirements applied only to nonfederal recipients of funding, including 

all entities receiving Recovery Act funds directly from the federal government such as 

state and local governments, private companies, educational institutions, nonprofits, and 

other private organizations.

57Office of Management and Budget, Implementing Guidance for the Reports on Use of 

Funds Pursuant to the American Recovery and Reinvestment Act of 2009, OMB 

Memorandum M-09-21 (2009).

Recipients Were Required to 

Report Outcome Measure of 

Jobs Created and Retained but 

Faced Some Challenges
Page 49 GAO-14-219 Grant Lessons from the Recovery Act

gather, analyze, and pass on information to the federal government at the 

end of each fiscal quarter.

Definitional challenges and discrepancies in reporting FTEs. Under 

OMB guidance, jobs created or retained were to be expressed as FTEs. 

In our November 2009 report we found that recipients reported data 

inconsistently even though OMB and federal agencies provided 

significant guidance and training.58

Capacity of recipients to meet deadlines. The requirement to regularly 

report on jobs created and retained further strained the capacity of some 

recipients. Recipients only had 10 days after the end of each fiscal 

quarter to determine this information and pass it on to the federal 

Specifically, we found that while FTE 

calculations should allow for different types of jobs—part time, full time or 

temporary—to be aggregated, differing interpretations of the FTE 

guidance compromised the recipients’ ability to aggregate the data. For 

example, in California, two higher education systems calculated FTEs 

differently. One chose to use a 2-month period as the basis for the FTE 

performance period. The other chose to use a year as the basis. The 

result was almost a three-to-one difference in the number of FTEs 

reported for each university system in the first reporting period. Although 

the Department of Education provided alternative methods for calculating 

an FTE, in neither case did the guidance explicitly state the period of 

performance of the FTE. We recommended that OMB clarify the definition 

of FTE jobs and encourage federal agencies to provide or improve 

program-specific guidance for recipients. Further, we recommended that 

OMB be more explicit that jobs created or retained are to be reported as 

hours worked and paid for by the Recovery Act. In general, OMB and 

agencies acted upon our recipient reporting-related recommendations 

and later reporting periods indicated significant improvements in FTE 

calculations. OMB’s guidance changed the original formula and 

consequently, agencies had to rush to educate recipients about the 

changes. Agencies spent extra time and resources that quarter reviewing 

and validating recipient data to reduce errors. In some cases, agencies 

communicated daily with recipients via phone or e-mail to ensure their 

report submissions were accurate.

 58GAO, Recovery Act: Recipient Reported Jobs Data Provide Some Insight into Use of 

Recovery Act Funding, but Data Quality and Reporting Issues Need Attention, 

GAO-10-223 (Washington, D.C.: Nov. 19, 2009). 
Page 50 GAO-14-219 Grant Lessons from the Recovery Act

government.59

The administration required agencies receiving Recovery Act funds to 

submit performance plans that identified additional measures on a 

program-by-program basis. Consistent with existing GPRA requirements 

for agencies to set outcome-oriented performance goals and measures, 

OMB’s initial Recovery Act implementation guidance required federal 

agencies to ensure that program goals were achieved. OMB required 

agencies to measure specific program outcomes, supported by 

corresponding quantifiable output measures, and improved results on 

broader economic indicators.

Some state education officials told us that deadlines for 

reporting should have been extended by 1 to 2 weeks so they were not 

rushing to input data. One of these officials said she was directed by 

other state officials to put in “the best data you have, even if it’s not 

correct...and go back and correct it later.” City officials also reported 

concerns with the quick turn-around time for reporting. For example, one 

city official stated that, in order to meet reporting deadlines, it was 

necessary had to enter data manually, which created additional work. The 

Recovery Board accepted these post-correction actions as it extended 

the quality assurance period to provide more time for agencies to review 

reports and recipients to make corrections in FederalReporting.gov. As a 

result, recipients could change their reports up to about 2 weeks before 

the start of the next reporting period.

60

 59According to a senior Recovery Board official, in an effort to accommodate weekends 

and holidays, the Recovery Board regularly allowed recipients 14 days to submit their data 

to FederalReporting.gov. 

In responding to this requirement, 

agencies typically resorted to existing measures in their grant programs’

performance plans. This information is reported by agency and by 

program within each agency, as opposed to government-wide. While 

Recovery.gov provided a template for facilitating the reporting of this 

information, the level of detail and specificity of outcomes varied greatly 

for some of the agencies we reviewed, making it difficult to determine the 

extent to which some were making progress toward their goals and 

demonstrating results.

60See OMB Memorandum M-09-10 (2009). This information was to be provided by all 

agencies receiving Recovery Act funds, covering each grant program using these funds, 

in the agencies’ “Recovery Program Plans” submitted to OMB. Initially due on May 1, 

2009, the plans were to be updated by the agencies as needed and were to be published 

on Recovery.gov as well as agency websites. These plans included information on each 

Recovery Act program’s objectives, activities, delivery schedule, accountability plan, 

monitoring plan, and program performance measures. 

Program Specific Performance 

Measures Varied by Program 

and Agency with Some 

Focusing More on Outputs 

than Outcomes
Page 51 GAO-14-219 Grant Lessons from the Recovery Act

For example, Education’s performance plan described the agency’s 

accountability mechanisms, the type and scope of project activities, and 

specific program performance measures. With the exception of the 

number of jobs created or retained, Education’s plan stated the agency 

was primarily using existing established agency performance measures 

that applied to both Recovery and non-Recovery funds. For example to 

measure the success of one type of education grant fund (specifically, 

Title I of the Elementary and Secondary Education Act of 1965, as 

amended) which the Recovery Act made available to local educational

agencies, Education used existing agency performance measures, such 

as the percentage of economically disadvantaged students in grades 3 to 

8 scoring at the proficient or advanced levels on state reading and 

mathematics assessments.

On the other hand, DOT filled out the templates to report on its 12 

programs, and its performance measures were generally less specific and 

outcome oriented. For example, DOT’s Capital Assistance for High Speed 

Rail Corridors and Intercity Passenger Rail Service performance plan 

metrics included whether interim guidance was published within time 

frames, the number of applicants received for the program, and the 

number of grants awarded for the program. Further, as we previously 

reported, DOT released a series of performance plans in May 2009 to 

measure the impact of Recovery Act transportation programs, but these 

plans generally did not contain an extensive discussion of the specific 

goals and measures to assess the impact of Recovery Act projects.61

 61GAO, Recovery Act: States’ and Localities’ Use of Funds and Actions Needed to 

Address Implementation Challenges and Bolster Accountability, 

For 

example, while the plan for the highway program contained a section on 

anticipated results, three of its five measures were the percent of funds 

obligated and expended and the number of projects under construction. 

The fourth measure was the percentage of vehicle miles traveled on 

pavement on the National Highway System rated in good condition, but 

the plan said that goals for improvement with Recovery Act funds were 

yet to be determined. The fifth goal was number of miles of roadway 

improved, and DOT’s plan reported that even with the addition of 

Recovery Act funds, the new target would remain the same as previously 

planned. As a result, we recommended in May 2010 that DOT ensure that 

the results of these projects were assessed and a determination made 

GAO-10-604

(Washington, D.C.: May 26, 2010). 
Page 52 GAO-14-219 Grant Lessons from the Recovery Act

about whether these investments produced long-term benefits. DOT did 

not implement our recommendation.

Created in response to the recent serious recession, the Recovery Act 

represents a significant financial investment in improving the economy.

Grant programs were a key mechanism for distributing this support. By 

increasing accountability and transparency requirements while at the 

same time setting aggressive timelines for the distribution of funds, the 

Recovery Act created high expectations as well as uncertainty and risk for 

federal, state, and local governments responsible for implementing the 

law.

Faced with these challenges, some of these organizations looked beyond 

their usual way of doing business and adjusted their usual practices to 

help ensure the accountability and transparency of Recovery Act 

funds. The oversight community adopted a faster and more flexible 

approach to how they conducted and reported on their audits and reviews 

so that their findings could inform programs of needed corrections before 

all Recovery funds were expended. They leveraged technology by using 

advanced data analytics to reduce fraud and to create easily accessible 

Internet resources that greatly improved the public’s access to, and ability 

to make use of, data about grants funded by the Recovery Act. These 

and other experiences, as well as the challenges identified in this report, 

provide potentially valuable lessons for the future. Underlying many of 

these lessons is the importance of increased coordination and 

collaboration, both vertically—transcending federal, state, and local levels 

of government—and horizontally—across organizational silos within the 

federal community—to share information and work towards common 

goals.

One question that remains unresolved is the extent to which good 

practices developed in response to the Recovery Act’s special challenges 

and conditions can ultimately be incorporated in everyday practice for 

managing and overseeing grants. Some of the practices we found, such 

as the use of the Recovery Operations Center and state readiness 

reviews, have been able to make this transition. Others, such as some of 

the information sharing networks established during the Recovery Act, 

have had more difficulty in doing so. Proposals under consideration by 

Congress and the administration to extend Recovery Act requirements for 

Concluding 

Observations
Page 53 GAO-14-219 Grant Lessons from the Recovery Act

spending transparency to all federal grants suggest that this has been the 

case for tracking dollars.62 Still to be seen is whether it will be possible to 

provide this type of government-wide transparency to other measures of 

performance, such as grant outcomes.

We provided a draft of this report to the Secretaries of the Departments of 

Education, Energy, Housing and Urban Development, and 

Transportation; and to the Director of the Office of Management and 

Budget. We also provided drafts of the examples included in this report to 

cognizant officials from the relevant state and local agencies to verify 

accuracy and completeness, and we made technical changes and 

clarifications where appropriate. The agencies generally agreed with our 

findings and provided technical comments which were incorporated in the 

report.

We are sending copies of this report to other interested congressional 

committees; the Secretaries of the Departments of Education, Health and 

Human Services, Housing and Urban Development, and Transportation;

and the Director of the Office of Management and Budget. In addition, the 

report will be available on our web site at http://www.gao.gov.

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

contact me at (202) 512-6806 or by email at czerwinskis@gao.gov. 

Contact points for our Offices of Congressional Relations and Public 

Affairs may be found on the last page of this report. Key contributors to 

this report are listed in appendix I.

Stanley J. Czerwinski

Director, Strategic Issues

 62Digital Accountability and Transparency Act of 2013, H.R. 2061, 113th Cong. (2013); 

Digital Accountability and Transparency Act of 2013, S. 994, 113th Cong. (2013).

Agency Comments
Appendix I: Objectives, Scope, and 

Methodology

Page 54 GAO-14-219 Grant Lessons from the Recovery Act

To better understand grant management lessons resulting from the 

American Recovery and Reinvestment Act of 2009 (Recovery Act), we 

focused on two key issues involving grant implementation during the 

Recovery Act: accountability and transparency. Specifically, this report 

identifies and provides examples of good practices employed and the 

challenges faced by select federal, state, and local agencies 

implementing grant programs funded by the Recovery Act, in the areas of 

accountability and transparency.

To obtain a broad view of lessons learned during the implementation of 

grants funded by the Recovery Act, we conducted a detailed literature 

review of relevant reports describing lessons learned from implementing 

grants funded by the Recovery Act from GAO; federal and state 

inspectors general; federal agencies; state and local governments; 

accountability boards; state and local government advocacy 

organizations; think tanks; and academia.1

 1

External reports reviewed include Khademian, Anne and Sang Choi, Virginia’s 

Implementation of the American Recovery and Reinvestment Act: Forging a New 

Intergovernmental Partnership, IBM Center for the Business of Government (2011); 

DeSeve, G. Edward, Managing Recovery: An Insider’s View, IBM Center for the Business 

of Government (2011); Posner, Paul L., et. al., Implementation of the Recovery Act: 

Networks Under Stress, George Mason University, Centers on the Public Service, 

(February 2013); U.S. Department of the Interior, Office of Inspector General, Lessons 

Learned from the Recovery Act: An Agency and OIG Retrospective, RO-SP-MOI-0008-

2012 (Washington, D.C.: May 2013); White House, A New Way of Doing Business: How 

the Recovery Act is Leading the Way to 21st Century Government, (February 2012); 

Rojas, Francisca M., Recovery Act Transparency: Learning from States’ Experience, IBM 

Center for the Business of Government (2012); Callahan, Richard, Sandra O. Archibald, 

Kay A. Sterner, and H. Brinton Milward, Key Actions That Contribute to Successful 

Program Implementation: Lessons from the Recovery Act, IBM Center for the Business of 

Government (2012); U.S. Department of Energy, Office of Inspector General ,Office of 

Audits and Inspections, Lessons Learned/Best Practices during the Department of 

Energy’s Implementation of the American Recovery and Reinvestment Act of 2009, OASRA-12-03 (Washington, D.C.: January 2012); and, U.S. Department of Housing and Urban 

Development, Office of Inspector General, American Recovery and Reinvestment Act 

Lessons Learned Initiative, Memorandum No.: 2013-IE-0801, (October 18, 2012).

We developed selection 

criteria to identify relevant federal agencies and state and local 

governments to obtain their views related to the implementation of grant 

programs funded by the Recovery Act. We then selected four federal 

agencies, three states, and two localities based on the extent to which 

they had information related to our focus areas of accountability and 

transparency; information from our colleagues, subject matter experts, 

and academics; and citations in the literature. To capture a diverse mix of 

Recovery Act grants and identify potential good practices and challenges, 

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 55 GAO-14-219 Grant Lessons from the Recovery Act

we selected a variety of grants—some that had their funding structures 

already well established, others that had their funding greatly increased 

as a result of the Recovery Act, as well as new programs.2

To obtain illustrative examples of the good practices employed and the 

challenges faced during the implementation of grants funded by the 

Recovery Act related to accountability and transparency, we conducted 

interviews with a wide range of officials and experts. We interviewed 

cognizant officials and obtained supporting documentation from 

government-wide oversight entities at the federal level including the 

Recovery Implementation Office, Office of Management and Budget, and 

the Recovery Accountability and Transparency Board. In addition, we 

interviewed and obtained supporting documentation from select federal 

agency officials from the Departments of Education; Energy; Housing and 

Urban Development; and Transportation; and their respective inspectors 

general. At the state level, we interviewed and obtained supporting 

documentation from agency and audit officials from the states of 

California, Georgia, and Massachusetts. To get a broader state 

perspective, we also interviewed officials from the state Recovery Act 

coordinators’ network, which included key state officials involved in 

implementing the Recovery Act from several states.

Although 

Medicaid was the largest grant program funded by the Recovery Act, we 

deemed it out of scope for the purposes of this review since it is primarily 

an entitlement and subject to specific rules that are not typical of program

grants. Further, Medicare and unemployment insurance were not 

included in the recipient reports we examined.

3

We also interviewed officials from leading state and local advocacy 

organizations that were involved in Recovery Act implementation such as 

the National Association of State Auditors and Comptrollers, the National 

At the local level, we 

interviewed officials from Denver, Colorado and New York, New York.

 2

The specific grants we focused on were: DOE, Energy Efficiency and Conservation Block 

Grant and the Weatherization Assistance Program; at DOT, Transportation Investment 

Generating Economic Recovery (TIGER) grants and the Federal Aid Highway Program; at 

HUD, Community Development Block Grants and the Tax Credit Assistance Program; at 

Education, Race to the Top grants, and the State Fiscal Stabilization Fund. 

3

The states represented in the state Recovery Act coordinators’ network meeting were 

Arizona, Arkansas, Delaware, Florida, Maryland, Massachusetts, Michigan, Minnesota, 

Missouri, Nebraska, Nevada, Oregon, Rhode Island, Tennessee, Texas, Utah, and 

Wisconsin. 
Appendix I: Objectives, Scope, and 

Methodology

Page 56 GAO-14-219 Grant Lessons from the Recovery Act

Association of State Budget Officers, and the National Association of 

Counties. We obtained additional information on lessons learned related 

to the Recovery Act from officials representing the Government 

Accountability and Transparency Board, Sunlight Foundation, Council of 

Government Relations, National Council of Non-profits, Center for 

Effective Government, the Federal Demonstration Project, and National 

Association of State Chief Information Officers. In addition, we conducted 

seven focus groups representing a range of federal fund recipients.4

Lastly, we reviewed and synthesized information provided in previously 

issued reports related to the Recovery Act that included the following 

sources: our previous work; inspectors general from the Departments of 

Education, Energy, Housing and Urban Development, and 

Transportation; the Recovery Accountability and Transparency Board; the 

White House; and various non-governmental sources including the IBM 

Center for The Business of Government. In addition, we reviewed and 

applied criteria established by HowTo.gov, a source of guidance and 

leading practices for government websites, to Recovery.gov and state 

and local Recovery websites. The scope of our work did not include 

independent evaluation or verification of the effectiveness of the 

examples we identified. We also did not attempt to assess the prevalence 

of the practices or challenges we cite either within or across levels of 

government. Therefore, entities other than those cited for a particular 

practice may or may not have employed the same or similar practice, and 

it is not possible to generalize how prevalent the practices and challenges 

may be across all Recovery Act grants.

Focus groups included: (1) state comptrollers; (2) state education and 

transportation officials; and (3) local government officials from both large 

and small municipalities. Each focus group had between four and eight 

participants who were recruited from randomized member lists provided 

by the recipient associations we interviewed.

We conducted this performance audit from December 2012 through 

January 2014, 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 

 4

Results from nongeneralizable samples cannot be used to make inferences about a 

population.
Appendix I: Objectives, Scope, and 

Methodology

Page 57 GAO-14-219 Grant Lessons from the Recovery Act

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives.
Appendix II: GAO Contact and Staff 

Acknowledgments

Page 58 GAO-14-219 Grant Lessons from the Recovery Act

Stanley J. Czerwinski, Director (202) 512-6806 or czerwinskis@gao.gov

In addition to the contact named above, Peter Del Toro, Assistant 

Director; Mark Abraham; and Jyoti Gupta made significant contributions 

to this report. Also contributing to this report were Tom Beall, Robert 

Gebhart, Jacob Henderson, Donna Miller, Robert Robinson, Beverly 

Ross, and Andrew J. Stephens.

Appendix II: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(451014)
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