Department of Health and Human Services

OFFICE OF

INSPECTOR GENERAL

SAMHSA’S 

ADMINISTRATION OF GRANTS

 

Daniel R. Levinson 

Inspector General

February 2012

OEI-07-10-00220 
 

EXECUTIVE SUMMARY: SAMHSA’S ADMINISTRATION OF GRANTS

OEI-07-10-00220 

WHY WE DID THIS STUDY 

In 2009, the period of our review, the Substance Abuse and Mental Health Services 

Administration (SAMHSA) administered 2,281 discretionary grants, which ranged from 

approximately $17,000 to $7 million for a total of $906.8 million. This study is part of a 

body of work by the Office of Inspector General (OIG) on grants administration to ensure 

the appropriate stewardship of Federal funds. OIG has not previously evaluated 

SAMHSA’s grants administration.

HOW WE DID THIS STUDY

Using SAMHSA grantee data, we selected a sample of 130 discretionary grants. We 

reviewed the files for these grants to determine the extent to which SAMHSA maintains 

grant files in accordance with Federal requirements. We then surveyed SAMHSA staff 

and the grantee project directors to describe SAMHSA’s interactions with grantees.

WHAT WE FOUND

SAMHSA maintains grant files in accordance with Federal requirements. We were able 

to follow the grant “paper trail” and identify required documents; however, a few grant 

files were missing initial applications, continuation applications, and Financial Status 

Reports. Most SAMHSA staff and grantee project directors reported positive interactions 

with one another; however, some SAMHSA staff and grantee project directors identified 

obstacles to communication. 

WHAT WE CONCLUDE

Given the overall completeness and quality of the grant files and the low incidence of 

identified problems, we are not making formal recommendations to SAMHSA. Still, we 

encourage SAMHSA to strive to obtain and maintain all required documents. Also, 

SAMHSA may want to use information from this report to improve interactions between 

SAMHSA staff and the grantee project directors. SAMHSA concurred with our report as 

written and provided no further comments. 
TABLE OF CONTENTS

Objectives ....................................................................................................1 

Background ..................................................................................................1 

Methodology ................................................................................................4 

Findings........................................................................................................8 

Almost all SAMHSA grant files were maintained in 

accordance with Federal requirements .............................................8 

Most SAMHSA staff and grantee project directors reported 

positive interactions; however, some SAMHSA staff and grantee 

project directors identified obstacles to communication ...............10 

Conclusion .................................................................................................13 

Agency Comments and Office of Inspector General Response .................13 

Appendixes ................................................................................................14 

A: Point Estimates and Confidence Intervals for Selected

Statistics .........................................................................................14 

B: Additional Grantee Requirements Found in Notices of 

Grant Awards .................................................................................15 

C: Examples of Agency-Grantee Communication Found 

in Sampled Grant Files...................................................................16 

D: Agency Comments ...................................................................17 

Acknowledgments......................................................................................18 
 

OEI-07-10-00220 SAMHSA’s Administration of Grants 1

OBJECTIVES 

1. To determine the extent to which the Substance Abuse and Mental 

Health Services Administration (SAMHSA) maintains grant files in 

accordance with Federal requirements, and 

2. To describe SAMHSA’s interactions with grantees.

BACKGROUND

SAMHSA was established in 1992 to target substance abuse and mental 

health services to the people most in need of such services. In calendar 

year 2009, the period of this review, SAMHSA administered 

2,281 discretionary grants, which ranged from approximately $17,000 to 

$7 million for a total of $906.8 million.1

 In fiscal year (FY) 2011, 

SAMHSA awarded grants totaling $3.1 billion, including both 

discretionary and block grants. SAMHSA grants typically last 3 to 

5 years.2

SAMHSA Grant Administrative Requirements

SAMHSA conveys administrative requirements governing grants through 

documents such as grant applications, Notices of Grant Awards, 

continuation applications, and Financial Status Reports.3

Applications. According to the GPD, an application is “a request for 

financial support of a project, program or activity submitted to HHS on 

specified forms and in accordance with instructions provided by the HHS 

awarding office.”4

1 We did not include mandatory block grants or mandatory formula grants in this study. Discretionary grants 

are those for which the Operating Division may exercise judgment (“discretion”) in determining the recipient 

and the amount of the award. Block grants, which have minimal Federal administrative requirements or 

restrictions, typically give States substantial discretion over the type of activities that the grants support. 

Formula grants use a formula to determine the amount provided; to obtain a formula grant, a State must provide 

a plan/application indicating how it plans to use this amount. HHS Grants Policy Statement (GPS), I-3. HHS 

Grants Policy Directive (GPD) 1.02. 

 Potential grantees, such as State agencies, tribal 

2 SAMHSA Fiscal Year 2011 Justification of Estimates for Appropriations Committees. 3

 Three regulations provide uniform administrative requirements for HHS grants: 45 CFR pt. 74 applies to 

institutions of higher education, hospitals, other nonprofit organizations, and commercial organizations; 

45 CFR pt. 92 applies to State, local, and tribal governments; and 45 CFR pt. 96 applies to block grants (which 

our sample did not include). Additionally, HHS GPDs, the Grants Policy Statement, and the awarding agency 

Grants Administration Manual (AAGAM) establish further requirements for HHS grant programs. The GPDs 

direct Department staff regarding HHS’s policies, standards, and procedures. The AAGAM implements the 

GPDs. The GPS also provides grantees with up-to-date policy guidance and information on HHS and its 

discretionary grant process. The GPS is generally made binding on grantees through the grant terms and 

conditions.

4 HHS GPD 1.02. January 1, 2007. 
 

OEI-07-10-00220 SAMHSA’s Administration of Grants 2

organizations, and local organizations, submit grant applications to request 

funding to operate programs that further the mission of SAMHSA. 

Notice of Grant Award. SAMHSA issues each grantee a Notice of Grant 

Award that describes the terms and conditions of its grant. SAMHSA uses 

Notices of Grant Award throughout the grant period to inform grantees of 

changes in the grant amounts awarded and/or additional conditions placed 

on the grants, such as a requirement to submit additional reports. 

Continuation Applications. On an annual basis, SAMHSA grantees must 

submit continuation applications to indicate progress made on their 

projects and to request further grant funds. Each continuation application 

should compare accomplishments to the grantee goals and milestones 

established for the budget period. The continuation application should 

also include, if applicable, an explanation of the reasons the grantee did 

not meet the goals and/or milestones. Federal regulation requires grantees 

to submit continuation applications before the next budget period begins.5 

To improve SAMHSA’s workflow, SAMHSA requires grantees to submit 

continuation applications earlier than Federal regulations require. 

Financial Status Reports. Financial Status Reports document the financial 

status of the award. Financial Status Reports must be submitted 90 days 

after the annual budget period ends, and a final Financial Status Report 

must be submitted 90 days after the project period ends.6

SAMHSA’s Responsibilities

To fulfill its role with regard to the stewardship of Federal funds, 

SAMHSA grants management and program staff assess grantee 

performance by reviewing grant file documents, such as continuation 

applications, Financial Status Reports, and related documents.7 

Grant File Documentation. The GPD requires grant-awarding agencies to 

create and maintain grant files.8 A third-party reviewer should be able to 

follow the paper trail for the grant from the grant application through the 

5 HHS GPS, pp. i-17.34, and Supplementary Instructions for the Continuation Application Process, 

HHS-5161-1 (revised August 2007).

6 45 CFR §§ 74.52(a) and 92.41(b). SAMHSA uses the project period system of funding for discretionary 

grants it awards. Under this system, projects are programmatically approved for support in their entirety, but 

are funded in annual increments called budget periods. The total project period consists of the initial 

competitive segment and the budget periods for the grant. In the Federal Financial Report Instructions issued 

by SAMHSA, project periods are also referred to as “grant periods.” Accessed at 

http://www.samhsa.gov/dtac/CCPtoolkit/pdf/FFR-425_instructions.pdf on October 31, 2011. The Federal 

Financial Report (FFR, or Standard Form 425) replaced the Financial Status Report beginning in FY 2011. The 

due dates remain the same.

7 HHS GPD 3.06. 

8 Ibid.
 

OEI-07-10-00220 SAMHSA’s Administration of Grants 3

grant’s closeout, including decisions made and actions taken in between. 

An official file must be created for each grant and must contain the 

following documentation, as applicable: 

• signed copies of applications and all documentation related to review 

and approval of the applications, 

• all Notices of Grant Awards,

• postaward correspondence, 

• site visit reports,

• records of telephone calls and postaward technical assistance provided, 

• documentation related to enforcement actions,9

• required continuation applications and Financial Status Reports, 

• evidence of awarding agency review and acceptance of continuation 

applications and Financial Status Reports, and 

• closeout documentation.10

High-Risk Grantees. SAMHSA may designate a grantee as high risk if the 

grantee has a history of poor performance, poor business practices, 

financial instability, or inadequate management systems.11 SAMHSA may 

make this designation at the time of the award or after awarding the grant. 

Federal regulations list the special award conditions that may be imposed 

on high-risk grantees, but the regulations do not specify which special 

award conditions must be imposed.12

SAMHSA Interaction With Grantees

 SAMHSA uses the Notice of Grant 

Award to indicate what, if any, special conditions are placed on the 

grantee. Grantees must comply with the conditions to resolve their 

high-risk designation. Some grantees may resolve issues quickly, thus 

ending their high-risk designation, while others may require considerably 

longer periods. 

SAMHSA Grants Management Specialists (GMS) and Project Officers

(PO) are the primary individuals who interact with grantees—typically,

with the grantee project directors. Interactions can focus on grants 

9 SAMHSA may impose enforcement actions on grants awarded to grantees to ensure compliance with Federal 

rules and regulations. 45 CFR §§ 74.62(a) and 92.43(a).

10 Official files must also contain a review of any deviations from the approved grant and prior approval 

requests. GPD 3.06. A deviation includes any activity disapproved or restricted as a condition of the award. 

We did not include identification of deviations in our grant file review.

11 45 CFR §§ 74.14 and 92.12. 

12 45 CFR §§ 92.12 and 74.14. 
 

OEI-07-10-00220 SAMHSA’s Administration of Grants 4

monitoring or providing technical assistance. HHS grants policy creates a 

responsibility for SAMHSA to provide consultation and technical 

assistance to grantees, although no Federal requirements exist regarding 

frequency or types of interactions.13 

GMSs’ Interactions. GMSs ensure that Federal financial and 

programmatic interests are protected by assessing grantees’ financial 

performance and business management capabilities. The type of oversight 

activity required varies according to the type of award and whether the 

grantee has been designated as high risk.14 GMSs are responsible for 

reviewing requests for reimbursement, as necessary; maintaining 

documentation of corrective actions, if any, taken by the recipient; and 

monitoring documentation of assistance to the recipient in resolution of 

any identified deficiencies.15 GMSs are responsible for monitoring report 

due dates and following up on delinquent reports.16 GMSs’ activities

include working with the POs, other SAMHSA officials, and the grantees 

to develop, as necessary, corrective action plans; monitor improvement; 

and arrange appropriate technical assistance.

POs’ Interactions

METHODOLOGY

. POs monitor the conduct and progress of grants. 

POs collaborate with grantees in the planning and implementation of the 

grant and in evaluation activities. POs interactions with grantees might 

include answering questions about specific policies, advising grantees on 

programmatic issues, providing technical assistance, and requesting 

clarification of any required documents as necessary.

Data Collection and Analysis

Our methodology included two principal elements: (1) reviews of grant 

files and (2) surveys of the GMSs, POs, and grantee project directors 

responsible for administering sampled grants. Of the 2,281 discretionary 

grants funded by SAMHSA in 2009, we selected a stratified random 

sample of 130 grants. We then reviewed the complete grant files for each 

sampled grant to determine the extent to which SAMHSA maintained 

grant files in accordance with Federal requirements. Additionally, we 

13 GPD 3.06, AAGAM 3.06.106. HHS GPS, p. I-5, January 1, 2007. 

14 The terms and conditions of the award reflect the type of award and whether the grantee has been designated 

high risk. SAMHSA Grants: Standard Terms and Conditions of Award. Accessed at http://www.samhsa.gov

on October 18, 2010.

15 AAGAM § 2.01.101-7C. 

16 HHS GPD 3.06. Accessed at http://dhhs.gov/asfr/ogapa/aboutog/ogpoe/gpdhome.html on August 25, 2011.
 

OEI-07-10-00220 SAMHSA’s Administration of Grants 5

surveyed the GMSs, POs, and grantee project directors associated with the 

sampled grants to describe SAMHSA’s interactions with grantees.

Scope

This evaluation reviewed a sample of SAMHSA discretionary grants 

funded during 2009. We did not seek to determine the appropriateness of 

SAMHSA’s awarding of the grants or the appropriateness of SAMHSA’s 

designation of high-risk grantees. We also did not seek to determine the 

accuracy of the information in required reports or appropriateness of 

grantee expenditures, nor did we seek to independently validate survey 

responses. 

Sample Selection

We requested from SAMHSA a list of grants that received funding in 

2009. From this list, we selected a stratified random sample of 130 of the 

2,281 SAMHSA discretionary grants as shown in Table 1. Stratum 1 

contained 2,157 grants awarded to grantees that SAMHSA never 

designated as high risk, and Stratum 2 contained 124 grants awarded to 

grantees that SAMHSA designated prior to December 31, 2009, as high 

risk. We selected a stratified random sample of 100 grants from 

Stratum 1 and 30 grants from Stratum 2. We chose to stratify based on the 

designation of risk status in an effort to determine whether differing 

reporting requirements affected the contents of grant files and levels of 

interaction with SAMHSA. We found that grant file documentation was 

substantial for both grantee strata, and we were unable to identify specific 

differences between the two strata with regard to the amount and type of 

documented communication in the grant files.

Table 1: SAMHSA Grant Population and Sample Size for 2009

Strata Definition Population 

Size Sample Size

1. Grants to Grantees Not Designated as High Risk 2,157 100

2. Grants to Grantees Designated as High Risk 124 30

 Total 2,281 130

Source: SAMHSA grant information, 2011. 

We projected the results of our grant file reviews to the universe of 

2,281 grants awarded in 2009. 

Grant File Reviews

We reviewed the official grant files for all of the 130 grants in our sample 

to determine whether SAMHSA maintained them in accordance with 

Federal requirements. Specifically, we sought to determine the extent to 

which the grant files enabled a third party to follow the paper trail for 

SAMHSA grants. We reviewed these files to determine whether 
 

OEI-07-10-00220 SAMHSA’s Administration of Grants 6

SAMHSA ensured that grantees submitted required documents and 

whether grantees complied with any special award requirements. We also 

reviewed grant files for evidence that SAMHSA reviewed and approved 

submitted documents and for evidence of interactions between SAMHSA 

and grantees. For each grant file we reviewed, we completed a review 

form in which we indicated which documents we found in the file. 

To determine the level and type of interactions between SAMHSA and 

grantees as documented in the grant files, we reviewed letters, emails, 

telephone logs, and notes that SAMHSA staff made regarding the grants. 

Required Reports. We reviewed the grant files to determine whether 

required Notices of Grant Award were included. When these notices were 

present, we reviewed them for the amount or change in the amount of the 

grant awards and any additional conditions imposed upon grantees. 

We also reviewed the grant files to determine whether required 

continuation applications: 

• were in the grant files and had been submitted timely;

• compared accomplishments with grantee goals and milestones 

established for the budget period; and 

• explained why grantee goals and milestones were not met, if 

applicable.

Finally, we determined whether required Financial Status Reports were in 

the grant files and had been received within 90 days after the close of the 

budget period. For continuation applications and Financial Status Reports, 

we reviewed correspondence in the grant files to determine whether 

SAMHSA staff followed up with grantees on late reports. 

To determine the extent to which SAMHSA actively monitored grants, we 

reviewed the grant files for evidence that SAMHSA reviewed required 

reports. We considered evidence of review to be signatures on required 

reports, emails regarding reports in the grant files, and/or records of 

telephone calls with grantees related to required reports.

Because none of the sampled grantees had closed out their grants, we did 

not review the grant files for closeout documentation. 

GMS and PO Surveys

We surveyed the 18 GMSs and 75 POs assigned to the 130 sampled 

grants. We received responses from all 18 GMSs and, with the assistance 

of SAMHSA officials and after repeated attempts, 66 POs assigned to 
 

OEI-07-10-00220 SAMHSA’s Administration of Grants 7

97 grants.17 We asked GMSs and POs questions about their experiences 

collecting grant file documents and about their interactions with grantees. 

We asked specifically about grantees’ responsiveness, timeliness, and the 

completeness of their responses. We asked GMSs and POs whether any 

additional or different interactions would be helpful. We also asked GMSs 

and POs about their experiences monitoring and interacting with high-risk 

grantees. We received from SAMHSA the names and contact information 

for the GMS and PO assigned to each of the grants in 2009. However, 

because SAMHSA regularly reassigns staff to different grants, sometimes 

more than one GMS and/or PO was assigned to the same grant. For this 

reason, we did not project the result of our surveys to SAMHSA staff. 

Grantee Surveys 

For each of 130 of the sampled grants, we asked SAMHSA to identify the 

corresponding project director and provide his or her contact information 

during the grant project period.18 We then asked 127 of those grantee 

project directors to complete an online survey. We asked questions about 

their interactions with GMSs and POs, and asked whether any additional 

or different interactions would have been helpful. We also asked project 

directors about their experiences submitting required documents. For 

grantees designated as high risk, we asked the project directors about their 

efforts to comply with the additional award conditions placed on their 

grants and their interactions with SAMHSA concerning their high-risk 

designations. We received responses from 121 of the 127 project 

directors.

Using similar survey questions, we compared the responses from 

SAMHSA staff with those from grantee project directors to verify the 

frequency and types of their interactions with one another. To further 

describe the frequency and types of interactions, we compared letters, 

emails, and notes from telephone calls in the grant files to the survey 

responses from SAMHSA staff and grantee project directors. 

Standards

This study was conducted in accordance with the Quality Standards for 

Inspection and Evaluation issued by the Council of the Inspectors General 

on Integrity and Efficiency.

17 SAMHSA staff indicated that the nonresponding POs were out of the office during our survey period 

because of medical issues, work-related issues (such as site visits), or retirement.

18 We did not email electronic surveys to 3 of the project directors of the 130 grants in our sample. In one of 

these instances, we were unable to contact the one project director because of an ongoing OIG investigation, but 

we reviewed the official grant file and surveyed the assigned GMS and PO. In another case, we attempted to 

contact the identified project director, but the grant period had ended in September 2010 and the grant was no 

longer operational. In the third instance, we were unable to identify the grantee’s correct contact information. 
 

OEI-07-10-00220 SAMHSA’s Administration of Grants 8

FINDINGS

Almost all SAMHSA grant files were maintained in 

accordance with Federal requirements 

The GPD requires grant-awarding agencies to create and maintain an 

official file for each grant, containing certain documentation, as 

applicable.19

Grant files contained most, but not all, required documents

 As third-party reviewers, we were able to follow the grant 

paper trail for all grants. We easily identified sections of the grant files 

containing grant applications, Notices of Grant Awards, continuation 

applications, Financial Status Reports, and correspondence between 

SAMHSA and grantees. We also found evidence that clearly 

demonstrated that SAMHSA staff reviewed and approved 

grantee-submitted documents and took action to obtain missing 

documents. 

Most grant files contained required documents, but a few were missing 

initial applications, continuation applications, or Financial Status Reports. 

Table 2 summarizes the information we found in the files for the sampled 

grants. Appendix A presents the point intervals and confidence intervals 

for all population estimates. 

Table 2: Contents of Grant Files

Required Document

Projected 

Percentage of 

Grant Files*

Application 98

Notice(s) of Grant Award 100

Continuation application 98 

Financial Status Report 97 

Source: OIG review of sample grant files, 2011.

* Projection is based on 130 reviewed grant files.

Applications. Ninety-eight percent of grant files contained applications. 

Two grant files in our sample that were missing applications had 

originated with the Department of Justice (DOJ) and been transferred to 

SAMHSA. SAMHSA staff reported that DOJ retained the applications for 

these grants; however, we did not verify this statement. We noted that 

SAMHSA did not maintain copies of the applications. 

19 HHS GPD § 3.06. Accessed at http://dhhs.gov/asfr/ogapa/aboutog/ogpoe/gpdhome.html on 

August 25, 2011.
 

OEI-07-10-00220 SAMHSA’s Administration of Grants 9

Notices of Grant Awards. All of the sampled grant files contained at least 

one Notice of Grant Award for 2009.20 In addition to reviewing grant files 

to see whether they contained Notices of Grant Awards, we reviewed the 

content of the notices. This latter review indicated that SAMHSA staff 

identified deficiencies in the operation of some grants, imposed corrective 

actions, and followed up on them. Eighty-two percent of grants contained 

Notices of Grant Awards that placed special award conditions (e.g., 

revised budget, financial management review) on the grantees. Because of 

the large amount of documented communication in the grant files, we 

were unable to determine whether each corrective action was actively 

monitored. However, we found that 110 grant files contained Notices of 

Grant Awards that placed special award conditions on grantees, which we 

considered to be evidence that SAMHSA was actively monitoring grants. 

For a complete list of the special award conditions that SAMHSA placed 

on grantees, see Appendix B.

Continuation Applications

We specifically reviewed grant files for the timeliness of continuation 

applications submitted in 2009. All of the continuation applications were 

timely based on the Federal regulation. 

. Ninety-eight percent of the grant files 

contained continuation applications. All continuation applications we 

reviewed compared accomplishments with the programs’ goals and 

milestones.

Financial Status Reports. Approximately 4 percent of grant files were 

missing Financial Status Reports. We were unable to determine why the 

files did not include these reports. In the grant files that contained 

Financial Status Reports, 70 percent of the reports had been submitted 

timely. We were unable to determine whether the remaining 30 percent 

had been submitted timely because some grants had multiple reports 

submitted in the same time period and we were unable to identify the 

original submitted report. 

Postaward Correspondence. SAMHSA’s grant files include a separate 

section for postaward correspondence. We reviewed files for postaward 

correspondence, such as letters, documentation of email exchanges 

between SAMHSA and grantees, and notes related to telephone calls. 

Postaward correspondence included communication between SAMHSA 

and grantees regarding topics such as budgets, late reports, changes in 

20 Notices of Grant Awards can be revised because of changes in the grant amount, imposition of additional 

requirements on a grantee, or designation of a grantee being designated as high risk. Consequently, we 

expected to find multiple notices in some grant files.
 

OEI-07-10-00220 SAMHSA’s Administration of Grants 10

grantee personnel, upcoming closeouts of grants, and site visits. For a list 

of the types of postaward correspondence we found, see Appendix C.

Most SAMHSA staff and grantee project directors

reported positive interactions; however, some 

SAMHSA staff and grantee project directors identified 

obstacles to communication

SAMHSA and grantee project directors reported positive interactions; 

however, both groups reported opportunities for improvement. Obstacles

such as lack of staff availability, technical assistance, and quality of 

response were some of the specific areas identified as needing 

improvement. 

SAMHSA staff and grantee project directors reported positive 

interactions and helpful technical assistance

Interactions

Table 3: GMS/PO Perceptions of Interactions With Grantees

. SAMHSA staff and grantee project directors reported 

positive interactions with one another. GMSs and POs reported that 

grantees responded timely and completely to requests. Table 3 shows how 

GMSs and POs rated their interactions with grantees. 

Statement Number of GMSs/POs in Agreement

GMSs (n=18) POs (n=66)

Grantee is responsive 17 64

Grantee responses are timely 15 61

Grantee responses are complete 12 63

Grantee communicates well 17 61

Turnover among grantee staff has caused problems 3 5 

Source: OIG review of sampled grant files, 2011.

Most grantee project directors reported that their GMSs and POs 

responded timely and completely to requests. Table 4 shows how grantee 

project directors rated their interactions with GMSs and POs. 

Table 4: Grantee Project Directors’ Perceptions of Interactions

With GMSs and POs

Statement Number of Grantee Project 

Directors in Agreement (n=120)

Regarding GMSs Regarding POs 

GMS/PO is responsive 92 110

GMS/PO responses are timely 81 97

GMS/PO responses are complete 87 97

GMS/PO responses occur at appropriate frequency 84 93

GMS/PO turnover has caused problems 30 17

Source: OIG review of sampled grant files, 2011.
 

OEI-07-10-00220 SAMHSA’s Administration of Grants 11

Technical Assistance

SAMHSA staff and grantee project directors reported some 

obstacles

. Of the grantee project directors responding to our 

survey, 96 percent reported that the technical assistance they received 

from SAMHSA staff was helpful. The most common issues for which

project directors reported requesting technical assistance were what the 

required documents should contain, what the reporting requirements were, 

and when prior approval was needed. 

SAMHSA staff and grantee project directors identified obstacles to 

interaction and suggested improvements in technical assistance to grantees

and quality of response between SAMHSA staff and grantees. 

Three of eighteen GMSs reported experiencing obstacles to interactions 

with grantees—specifically, lack of grantee skill and technology 

limitations. Of the 66 POs responding to our survey, 9 reported 

experiencing obstacles to interactions with grantees; the most commonly 

reported obstacle was availability of grantees. 

Eighteen percent of grantee project directors responding to our survey 

reported obstacles to interactions with their GMSs. The most common 

obstacles reported were late responses, nonresponse, and GMSs’ lack of 

knowledge. Other obstacles included GMS turnover, inconsistent 

information, and GMSs’ workloads. Fifteen percent of sampled grantee 

project directors who responded to our survey reported obstacles to 

communicating with their POs. The most commonly reported obstacles

were availability and workload. 

Technical Assistance. Thirteen percent of grantee project directors who

responded to the survey stated that more technical assistance would be 

helpful. They suggested that receiving more technical assistance shortly 

after issuance of the Notice of Grant Award on basic subjects, such as 

grant administration and required reporting, would have better prepared 

them as grantees.

Perceived Attitudes of SAMHSA Staff. Ten of the one hundred twenty 

grantee project directors who responded to our survey reported that they 

perceived their GMSs and/or POs had negative attitudes towards grantees. 

One project director suggested “that the [grants management] staff provide 

objective support to the grantees without judgment and conviction. It 

seems that the [grants management] department is very critical of 

programs and it’s obvious in the way they speak to the project staff.” 

Perceived Quality of Response. Six of the one hundred twenty grantee 

project directors who responded to our survey reported that they perceived 

their GMSs and/or POs as lacking a commitment to quality. These project 
 

OEI-07-10-00220 SAMHSA’s Administration of Grants 12

directors described SAMHSA staff as performing only to minimum 

requirements. One project director reported that when asked questions, 

SAMHSA staff provided only short answers. The project director also 

indicated that SAMHSA could be more open and engaged with grantees to 

help better manage their grants. 
 

OEI-07-10-00220 SAMHSA’s Administration of Grants 13

CONCLUSION

SAMHSA maintains grant files in accordance with Federal requirements, 

and most SAMHSA staff and grantee project directors reported positive 

interactions with one another. However, a few grant files did not contain 

all required documents, and a few SAMHSA staff and the grantee project 

directors identified concerns with their interactions and/or suggested

improvements. Given the overall completeness and quality of the grant 

files and the low incidence of identified problems, we are not making 

formal recommendations to SAMHSA. Still, we encourage SAMHSA to 

strive to obtain and maintain all required documents. Also, SAMHSA 

may want to consider information from this report to improve interactions 

between SAMHSA staff and grantee project directors. 

AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 

RESPONSE 

SAMHSA concurred with our report as written and provided no further 

comments. We did not make any changes to the report as a result of the 

agency comments. For the full text of SAMHSA’s comments, see 

Appendix D. 
 

OEI-07-10-00220 SAMHSA’s Administration of Grants 14

APPENDIX A

Table A: Point Estimates and Confidence Intervals for Selected Statistics

Table A: Point Estimates and Confidence Intervals for Selected Statistics

Grant File Document Sample 

Size (n)

Point 

Estimate

95-Percent Confidence 

Interval

Applications in grant files 130 98.5 94.5–99.8

Notice(s) of Grant Awards in grant files 130 100.0 95.4–100.0

Notice(s) of Grant Awards with special award conditions 130 81.8 73.5–88.0

Continuation applications in grant files 95 97. 9 92.6–99.7

Continuation applications received on time 95 100.0 96.2–100.0

Financial Status Report in grant files 94 96.4 89.7–98.8

Financial Status Report missing from grant files 94 3.6 1.2–10.3

Financial Status Report received on time (and in grant files) 89 70.5 59.3–79.6

Financial Status Report 

timeliness

in grant files, but we were unable to determine 89 29.6 20.3–40.7

Grantee project directors reporting helpful technical assistance 107 96.2 89.7–98.7

Grantee project directors reporting 

Grants Management Specialists 

obstacles to interactions with 113 17.9 11.5–26.7

Grantee project 

Project Officers 

directors reporting obstacles to interactions with 119 14.7 9.0–23.1

Grantee project directors reporting that 

would be helpful

more technical assistance 119 12.6 7.4–20.7

Source: Office of Inspector General review of sampled grant files, 2011.
 

OEI-07-10-00220 SAMHSA’s Administration of Grants 15

APPENDIX B

Table B: Additional Grantee Requirements Found in Notices of Grant 

Awards

Table B: Examples of Additional Grantee Requirements Identified in Notices of Grant Awards

Requirements Imposed on Grantees Total*

Revised budgets 32

Grantee Financial Management Review 27

Change in personnel 20

Revised documents 10

Participant protection procedures 8 

Budget justifications 7 

Required missing reports (i.e., Financial Status Reports, continuation applications) and forms 7 

Indirect Cost Rate Agreement 6 

Required technical assistance 5 

Government Performance Results Act compliance procedures 5 

Prior approval of purchases 4 

Clinical Laboratory Improvement Amendments certification 4 

Response to other concerns 4 

Signed tribal resolutions 3 

Clarifying information 3 

Limitation on grantee activities or expenditures 2 

* Notices of Grant Awards often included multiple additional requirements; therefore, these will not add to the 110 Notices of Grant Awards 

found in the grant files. Because we were unable to identify all additional requirements, we are not projecting the results of this analysis.

Source: Office of Inspector General review of sampled grant files, 2011.
 

OEI-07-10-00220 SAMHSA’s Administration of Grants 16

APPENDIX C

Table C: Examples of Agency-Grantee Communication Found in Sampled 

Grant Files

Table C: Examples of Topics of Communication Between Substance Abuse and Mental Health Services 

Administration Staff and Sampled Grantees

Subject Matter Total*

Budget 40

Carryover 29

Late Financial Status Reports/other late reports 24

Key personnel 22

Closeout 15

Indirect Cost Rate Agreements 15

Continuation applications 15

Forms/reports 14

No-cost extensions 12

Site visit 12

Allowable cost 12

Participant protection 6 

Application process 6 

Financial reviews 5 

Excluded Parties List System** checks 5 

Supporting documentation 5 

Special conditions/enforcement actions (corrective action plans) 4 

Cost allocations 3 

Due dates 2 

Memorandums of Understanding between States and counties 2 

Federal match rate/cost sharing 2 

Rent/real estate 2 

Technical assistance 2 

Tribal resolutions 1 

Needs assessments 1 

Interest expense 1 

Programmatic questions 1 

Extensions to file 1 

Office of Inspector General requests for investigations 1 

* Correspondence found in grant files often included multiple topics; therefore, these will not add to 130 sampled grant files. 

** The Excluded Parties List System identifies those parties excluded throughout the U.S. Government from receiving Federal contracts or 

certain subcontracts and from certain types of Federal financial and nonfinancial assistance and benefits.

Source: Office of Inspector General review of sampled grant files, 2011.
APPENDIX D 

Agency Comments 

~ ~SAMiiSA 1 Chok. CIIo"Y Road' Rockville, MO 20867 

www.aamhsa.~ • ' -877-SAMHSA-1 (1 ,·871-728-4727) 

JAN 4 2012 

TO: Daniel R. Levinson, Inspector General 

Office of Inspector General (OIG) 

FROM: Administrator 

SUBJECT: OlG Drafl Report: SAMHSA 's Administration qfGrants, OEI-07-JO00220 

The Substance Abuse and Mental Health Services Administration has reviewed the above 

subject document and concurs with the document as written. 

Thank you for the opportunity to comment. 

ParK€la lJyd~:ro. 

Behavioral Health Is Essential To Health • Prevention Works • Treatment is Effective • People Recover 

OEI-07 -10-00220 SAMHSA's Administration of Grants 17 
OEI-07-10-00220 SAMHSA’s Administration of Grants 18

ACKNOWLEDGMENTS

This report was prepared under the direction of Brian T. Pattison, Regional 

Inspector General for Evaluation and Inspections in the Kansas City 

regional office; Deborah K. Walden, Deputy Regional Inspector General; 

and Brian T. Whitley, Deputy Regional Inspector General. 

Michael Barrett served as the project leader for this study. Other principal 

Office of Evaluation and Inspections staff from the Kansas City regional 

office who contributed to the report include Tricia Fields, Rae Hutchison, 

and Michala Walker; central office staff who contributed include 

Heather Barton and Kevin Farber.
Office of Inspector General

http://oig.hhs.gov

The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, as amended, is 

to protect the integrity of the Department of Health and Human Services (HHS) programs, as well as the 

health and welfare of beneficiaries served by those programs. This statutory mission is carried out through 

a nationwide network of audits, investigations, and inspections conducted by the following operating

components:

Office of Audit Services

The Office of Audit Services (OAS) provides auditing services for HHS, either by conducting audits with 

its own audit resources or by overseeing audit work done by others. Audits examine the performance of 

HHS programs and/or its grantees and contractors in carrying out their respective responsibilities and are 

intended to provide independent assessments of HHS programs and operations. These assessments help 

reduce waste, abuse, and mismanagement and promote economy and efficiency throughout HHS.

Office of Evaluation and Inspections

The Office of Evaluation and Inspections (OEI) conducts national evaluations to provide HHS, Congress, 

and the public with timely, useful, and reliable information on significant issues. These evaluations focus 

on preventing fraud, waste, or abuse and promoting economy, efficiency, and effectiveness of 

departmental programs. To promote impact, OEI reports also present practical recommendations for 

improving program operations. 

Office of Investigations

The Office of Investigations (OI) conducts criminal, civil, and administrative investigations of fraud and 

misconduct related to HHS programs, operations, and beneficiaries. With investigators working in all 

50 States and the District of Columbia, OI utilizes its resources by actively coordinating with the 

Department of Justice and other Federal, State, and local law enforcement authorities. The investigative 

efforts of OI often lead to criminal convictions, administrative sanctions, and/or civil monetary penalties.

Office of Counsel to the Inspector General

The Office of Counsel to the Inspector General (OCIG) provides general legal services to OIG, rendering 

advice and opinions on HHS programs and operations and providing all legal support for OIG’s internal 

operations. OCIG represents OIG in all civil and administrative fraud and abuse cases involving HHS 

programs, including False Claims Act, program exclusion, and civil monetary penalty cases. In 

connection with these cases, OCIG also negotiates and monitors corporate integrity agreements. OCIG 

renders advisory opinions, issues compliance program guidance, publishes fraud alerts, and provides other 

guidance to the health care industry concerning the anti-kickback statute and other OIG enforcement 

authorities.