ANTI-DRUG MEDIA

CAMPAIGN

ONDCP Met Most

Mandates, but

Evaluations of Impact

Are Inconclusive

United States General Accounting Office

GAO Report to Congressional Committees

July 2000

GAO/GGD/HEHS-00-153

United States General Accounting Office General Government Division

Washington, D.C. 20548

Page 1 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

B-281160

July 31, 2000

The Honorable Ben Nighthorse Campbell

Chairman

The Honorable Byron L. Dorgan

Ranking Minority Member

Subcommittee on Treasury

and General Government

Committee on Appropriations

United States Senate

The Honorable Jim Kolbe

Chairman

The Honorable Steny Hoyer

Ranking Minority Member

Subcommittee on Treasury, Postal Service,

and General Government

Committee on Appropriations

House of Representatives

The conference report and Senate Appropriations Committee Report for the Treasury and

General Government Appropriations Act for 1999 required us to review various aspects of the

Office of National Drug Control Policy’s (ONDCP) National Youth Anti-Drug Media

Campaign. In response to the legislative mandate and discussions with your Subcommittees,

this report discusses (1) whether ONDCP provided timely financial reports to Congress; how

funds for paid advertising were managed and disbursed; and whether ONDCP complied with

certain statutory requirements regarding the obligation of funds; (2) what ONDCP has done

to develop and implement guidelines for the Campaign in response to program requirements

set out in Public Law 105-61 and Public Law 105-277; and (3) whether the evaluation designs

for phases I, II, and III were appropriate; how well the phases I and II evaluations were

implemented; and how effective phases I and II of the Campaign were in influencing group

awareness of different types of paid anti-drug media messages and drug attitudes. This report

contains recommendations to the Director of ONDCP regarding the development and

implementation of certain Campaign guidelines.

We are sending copies of this report to the Chairmen and Ranking Minority Members of other

appropriate congressional committees; the Honorable Barry R. McCaffrey, Director of the

Office of National Drug Control Policy; the Honorable Jacob J. Lew, Director of the Office of

Management and Budget; and other interested parties. Copies will also be made available to

others upon request.
B-281160

Page 2 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

If you have any questions regarding this report, please call me at (202) 512-8816 or Daniel C.

Harris, Assistant Director, at (202) 512-8720. You may also reach us by E-mail at

stanar.ggd@gao.gov or harrisd.ggd@gao.gov. The major contributors to this report are listed

in appendix IV.

Richard M. Stana

Associate Director, Administration of

Justice Issues
Page 3 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign
Executive Summary

Page 4 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

The Office of National Drug Control Policy’s (ONDCP) National Youth

Anti-Drug Media Campaign, which was proposed as a nearly $1 billion

federal effort over 5 years, was developed in response to reported

increases in drug use among youth in the United States.1

The conference

report2

and the Senate Appropriations Report3for the Treasury and

General Government Appropriations Act of 1999 directed GAO to (1)

conduct a financial audit and review of the ONDCP Media Campaign, (2)

review ONDCP’s compliance with certain Campaign program requirements

that are listed in the public law, and (3) review certain aspects of the

results of phase I of the Campaign (of 3 phases). On the basis of

subsequent discussions with the Subcommittee on Treasury and General

Government, Senate Committee on Appropriations, and the Subcommittee

on Treasury, Postal Service, and General Government, House Committee

on Appropriations, GAO agreed to determine

• whether ONDCP provided timely financial reports to Congress as required

by Public Law 105-61 and Public Law 105-277; how funds for paid

advertising were managed and disbursed; and whether ONDCP complied

with certain statutory requirements regarding the obligation of funds;

• what ONDCP has done to develop and implement guidelines for the

Campaign in response to the program requirements set out in Public Law

105-61 and Public Law 105-277; and

• whether the evaluation designs for phases I, II, and III were appropriate;

how well the phases I and II evaluations were implemented; and how

effective phases I and II of the Campaign were in influencing group

awareness of different types of paid anti-drug media messages (ad

awareness)4

and drug attitudes.

ONDCP has complied with most statutory requirements regarding Media

Campaign funds and program guidelines, although ONDCP may not be able

to fully comply with certain congressional requirements that were enacted

after the initial legislation establishing the Campaign. Evaluations of the

first two phases of the Campaign remain inconclusive, due to various

evaluation survey design and implementation limitations. However,

various other indicators, such as the Department of Health and Human

Service’s Substance Abuse and Mental Health Service Administration’s

1

Public Law 105-61, 111 Stat. 1293, 1294 (1997).

2

H.R. Conf. Rep. No. 105-825, 1493, 1497 (1998).

3

S. Rep. No. 105-251, 58-59 (1998).

4

ONDCP, Testing the Anti-Drug Message in 12 Cities National Youth Drug Media Campaign: Phase I

(Report No. 2), p. 2-1, March 1999.

Purpose

Results in Brief
Executive Summary

Page 5 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

National Clearinghouse for Alcohol and Drug Information (NCADI) data

and focus group and community key informant input, support the

conclusion that the Campaign was having some positive effects during

phases I and II. The phase III evaluation design appears promising;

implementation of this phase began in 1999.

In response to statutory financial reporting requirements and certain

statutory spending restrictions, ONDCP generally provided timely financial

reports to the appropriate Committees and complied with selected

statutory spending restrictions imposed by Congress for fiscal years 1998

and 1999. In addition, GAO noted that although ONDCP used

administrative contract support from other federal agencies to assist with

the paid advertising contracts, it remained responsible for ensuring that

only valid Campaign expenses were paid. In doing so, ONDCP had

processes in place to monitor and approve all paid advertising

expenditures before paying vendors and reporting to Congress.

ONDCP’s success in meeting the congressionally mandated program

requirements was mixed. The match program, which was developed during

phase I of the Campaign to meet the congressional requirement that

ONDCP supplement existing public service announcements (PSA),

resulted in over 265,000 pro bono or “match” PSAs. However, due to the

need to meet the Campaign’s reach and frequency goals, ONDCP may not

be able to meet the current congressional direction that it obtain a pro

bono match as a part of each buy from every vendor. This requirement was

imposed after the development of the match program. Contractor officials

explained that some vendors were unwilling or financially unable to

provide a match. In some of these cases, it was necessary to make a

purchase without the match so that ONDCP could meet the Campaign’s

reach and frequency goals in that market. GAO is making a

recommendation in this report to help address this conflict.

According to ONDCP, its work with community anti-drug coalitions was

limited in the first two phases of the Campaign due to ONDCP’s need to

focus efforts on planning and executing the paid advertising Campaign.

However, ONDCP and contractors planned and/or initiated numerous

initiatives for phase III.

As of the date of GAO’s review, ONDCP had not developed a plan to secure

private sector contributions. ONDCP had anticipated having a plan in place

by October 2000 but, as of the date of GAO’s review, had fallen behind in

meeting the schedule necessary to complete work by that date. ONDCP

officials told GAO that they do not believe they will ever be able to attain
Executive Summary

Page 6 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

the highest level of the congressionally mandated levels of contributions,

which range from 40 to 100 percent of the annual Campaign appropriations

for fiscal years 1999 through 2002. GAO is making a recommendation in

this report to help clarify this matter.

ONDCP (1) developed policy and guidance prohibiting advertisements that

feature political figures or partisan political purposes and (2) established

an advertisement review process. However, ONDCP had no internal

controls requiring that the reviews be documented. GAO is making a

recommendation in this report to correct this situation.

The results of the phases I and II evaluations regarding the Campaign’s

impact on youth, teen, and parent ad awareness and drug attitudes were

inconclusive due to various design, implementation, and analytical

limitations. Site selection problems, unknown parent response rates, low

school response rates, and data analysis issues contributed to the

inconclusive youth, teen, and parent survey data. However, unweighted

findings from phases I and II, input from community sources, and data

from NCADI provided indications that the initial phases of the Campaign

had some positive effects. The 4-year, phase III evaluation began in 1999,

and its design appears promising, given its more comprehensive scope and

methodological sophistication. In addition, Ogilvy and Mather, the phase

III advertising contractor, is to examine the impact of each media element,

and NCADI is to continue to collect data through the end of calendar year

2000 on the volume of public contacts and reports distributed as

supplemental measures of Campaign awareness/exposure.

ONDCP officials reviewed a draft of this report and generally agreed with

its findings, conclusions, and recommendations.

In the Treasury and General Government Appropriations Act for 1998,

Congress required that ONDCP submit a campaign strategy for approval to

the Committees on Appropriations and the Senate Judiciary Committee

that included the following requirements:

• guidelines to ensure and certify that funds will supplement and not

supplant current anti-drug community-based coalitions and current pro

bono public service time donated by national and local broadcasting

networks;

• guidelines to ensure and certify that funds are not used for partisan

political purposes and that funded advertisements do not feature any

elected officials, persons seeking elected office, cabinet-level officials, or

Background
Executive Summary

Page 7 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

certain other federal officials, absent advance notice to the respective

congressional Committees;

• a detailed implementation plan is to be submitted to the Committees for

securing private sector contributions, including but not limited to in-kind

contributions;

• a detailed implementation plan is to be submitted to the Committees

stating the qualifications that are necessary for any organization, entity, or

individual to receive funding for or otherwise be provided broadcast media

time; and

• a system is to be developed to measure outcomes of success of the Media

Campaign.

The act further required that the Director of ONDCP report to Congress

quarterly on the obligation of funds, as well as specific parameters of the

Campaign, and report to Congress within 2 years on the effectiveness of

the Campaign. In addition, the act placed certain restrictions on the

obligation of Campaign funds.

In fiscal year 1999, Congress placed additional requirements in the

Campaign’s appropriations acts regarding financial reporting; obligation of

funds; public service time (requiring ONDCP to obtain a pro bono match as

a part of each buy from every vendor); private sector contributions

(requiring ONDCP to obtain contributions ranging from 40 to 100 percent

of the annual Campaign appropriations for fiscal years 1999 through 2002,

respectively); and other aspects of the Campaign. In fiscal year 2000,

Congress required that ONDCP not obligate 10 percent of available funds

until it submitted a plan for corporate sponsorship to the Appropriations

Committees.

In response to the previously mentioned requirements, ONDCP submitted

a Campaign strategy to the appropriate Committees in November 1997 and,

as requested by the Committees, provided additional information in early

1998. In addition, ONDCP officials provided Congress with oral reports

regarding spending during the early months of the Campaign and, in May

1998, began providing periodic written reports on Campaign obligations

and expenditures. These officials also provided impact evaluation reports

regarding Campaign effectiveness in August 1998, September 1998, March

1999, and June 1999.

The centerpiece of the Campaign is the paid advertising effort in which

Campaign funds are used to purchase media time and space for

advertisements that deliver anti-drug messages to the Campaign’s target

audiences. The initial reach and frequency goal for the paid advertising
Executive Summary

Page 8 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

component was to reach 90 percent of the target audiences with at least

four messages a week, across all types of media.5

The Campaign is being implemented in the following three phases:

• Phase I, a 12-city pilot focused on paid advertising with very limited

implementation of the other Campaign components, ran from January 1998

through July 1998.

• Phase II, a nationwide extension of the pilot to include all media types and

very limited implementation of the other Campaign components, ran from

July 1998 through December 1998.

• Phase III, a continuation of the nationwide advertising Campaign with

expanded implementation of the other Campaign components, is to run

from January 1999 through December 2002.

ONDCP uses advertising contractors to obtain the media planning,

purchasing, and other advertising expertise that is necessary to conduct

the paid advertising component of the Campaign. Paid advertising includes

national and local television, radio, and cable and newspaper, magazine,

and Internet advertisements, among others. During fiscal years 1998 and

1999, paid advertising accounted for approximately 84 percent of the total

Campaign expenditures that ONDCP reported to Congress.

ONDCP also relied on other federal agencies for administrative contract

support. However, ONDCP remained responsible for ensuring that the

contractors’ performance met the advertising objectives of the Campaign.

This responsibility included selecting contractors, ensuring that contracts

and related modifications were in accordance with ONDCP’s media plan,

and authorizing payment of the various media advertising costs.

In performing its review, GAO did not

• verify the accuracy of the financial reports provided to Congress or other

financial information provided;

• test ONDCP’s processes to oversee paid advertising spending to ensure

that the procedures were effective and properly implemented;

• review the documents supporting every Campaign obligation;

• review ONDCP’s compliance with other statutory spending requirements,

such as restrictions regarding the type of activities for which Campaign

funds may or may not be used;

5

“Reach and frequency goal” refers to communicating the message to a certain percentage of the target

audiences a certain number of times a week.
Executive Summary

Page 9 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

• verify the accuracy of the youth, teen, and parent survey response data

that were collected in phases I and II, or that of the NCADI and community

informant data obtained; and

• conduct a detailed assessment of ONDCP’s phases I and II qualitative

evaluations (e.g., focus groups and key informant interviews); instead,

GAO focused on the quantitative youth, teen, and parent evaluations since

these were ONDCP’s focus.

In response to statutory financial reporting requirements, ONDCP

generally provided timely financial reports to the Committees. ONDCP

provided oral reports during the early months of the Campaign and

provided its first written report, covering the first 8 months of the

Campaign, in May 1998. Since then, ONDCP provided timely written

financial status reports on a monthly basis, except in October, November,

and December, 1998, and October 1999 because of delays in closing the

accounting records for one fiscal year and opening records for the new

fiscal year. The reports provided cumulative obligations and expenditures.

Although not statutorily required to submit reports in fiscal year 2000,

ONDCP plans to do so. However, neither written nor oral reports have

been issued in fiscal year 2000 to date, due to delays associated with (1)

upgrading the Executive Office of the President’s financial accounting

system that maintains the accounting records and (2) ONDCP’s plans to

change the financial report’s format.

ONDCP had processes in place to monitor and approve all paid advertising

expenditures before paying vendors and reporting to Congress. ONDCP

uses advertising contractors to carry out the paid advertising portion of the

Campaign. These contracts accounted for about 84 percent of the total

Campaign expenditures as of September 30, 1999. ONDCP used contract

support agents to assist them with these contracts but remained

responsible for ensuring that only valid Campaign expenses were paid.

ONDCP complied with selected statutory spending restrictions that were

imposed by Congress for fiscal years 1998 and 1999. In fiscal year 1998,

ONDCP was not to obligate Campaign funds before submitting a Campaign

strategy for approval to the Appropriations Committees and the Senate

Judiciary Committee. Additionally, obligation of $17 million before

September 30, 1999, was restricted. ONDCP submitted a strategy to

Congress in November 1997 and by December 10, 1997, received approval

Principal Findings

ONDCP Generally Provided

Timely Financial Reports

and Obligated Funds

According to Selected

Statutory Restrictions
Executive Summary

Page 10 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

to begin obligating funds. On the basis of GAO’s review of contracts and

other obligating documents representing 91 percent of the 1998

appropriation available for obligation, the first obligation of the Campaign

was incurred on December 18, 1997. The Office of Management and

Budget did not apportion $17 million until after the end of fiscal year 1998

to ensure compliance with that restriction. In fiscal year 1999, ONDCP was

prohibited from obligating (1) funds before ONDCP had submitted a report

on the evaluation and results of phase I of the Campaign to the

Appropriations Committees and (2) more than 75 percent of Campaign

funds before submitting a report on phase II. GAO’s review of contracts

and other obligating documents, representing 94 percent of the 1999

appropriation, indicated that ONDCP complied with these restrictions.

ONDCP is required to hold back 10 percent of the fiscal year 2000

appropriation until ONDCP submits a corporate sponsorship plan to the

Appropriations Committees. ONDCP officials said that they would monitor

compliance with this restriction.

To meet the congressional requirement that ONDCP supplement existing

PSAs, ONDCP developed the match program. Under this program, ONDCP

requires its advertising contractors, when purchasing advertising time or

space, to obtain either an equivalent value of time and space or an

equivalent in-kind contribution, pro bono, for the PSAs of qualifying

organizations. This program resulted in over 265,000 free or match PSAs,

valued at approximately $148 million and benefiting 45 organizations as of

the time of GAO’s review. GAO’s review of advertising company

documentation indicated with 95-percent statistical confidence that

contractors were successful in achieving at least a 100-percent rate of

match-to-paid advertising value. However, due to the need to meet the

advertising Campaign’s reach and frequency goals, ONDCP may not be

able to meet the current congressional direction that it obtain a pro bono

match as a part of each buy from every vendor. This requirement was

imposed after the development of the match program. Contractor officials

explained that some vendors were unwilling or financially unable to

provide a match, or free airtime. In some of these cases, it was necessary

to make a purchase without the match so that ONDCP could meet the

Campaign’s reach and frequency goals in that market. According to the

contractors, for the time period covering June 29, 1998, to December 31,

1999, time and space were purchased from 2,991 media vendors. Of this

Compliance With Statutory

Program Requirements Was

Mixed
Executive Summary

Page 11 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

total, the contractors made purchases from 12 vendors who did not

provide a match.6

According to ONDCP, its work with community anti-drug coalitions was

somewhat limited in the first two phases of the Campaign, due to the need

to focus efforts on planning and executing the paid advertising Campaign.

During phases I and II, most of ONDCP’s time was directed at getting the

paid advertising out in the 12 pilot cities and then expanding the effort

nationally. According to ONDCP, phase III will provide the opportunity to

fully develop and implement work with community anti-drug coalitions.

ONDCP and nonadvertising contractors planned and/or instituted

numerous initiatives for phase III.

As of the date of GAO’s review, ONDCP had not developed a plan to secure

private sector contributions. According to ONDCP officials, a plan

developed by a contractor in 1998 was not implemented for several

reasons, including (1) legal difficulties with the contract, (2) the ONDCP

belief that it might be possible to develop a better plan, (3) the need to

plan and execute the paid advertising segment of the Campaign, and (4)

ONDCP staffing limitations. ONDCP anticipated having a plan in place by

October 2000 but, as of the date of GAO’s review, fell behind in meeting

the schedule necessary to complete work by that date. Even without a

plan, as of the date of GAO’s review, ONDCP reported contributions

valued at an estimated $71.7 million. Beginning in fiscal year 1999,

Congress directed ONDCP to develop a plan to secure contributions

equaling 40 to 100 percent of the Campaign’s annual appropriations for

fiscal years 1999 through 2002. Officials told GAO that even when a plan is

finalized, ONDCP might not be able to attain these congressionally

mandated levels of contributions. ONDCP plans to learn more about the

availability of private sector contributions as it goes through the process of

obtaining a contractor to implement a contributions plan.

ONDCP and the Partnership for a Drug-Free America (PDFA) developed

guidance prohibiting advertisements that feature political figures or

partisan political purposes and established an advertisement review

process. Advertising agencies must submit proposed advertisements to

PDFA’s Creative Review Committee (CRC), which is to review the

advertisements following a 29-step process. None of these steps address

the prohibition on political figures or partisan purposes. CRC

recommendations are to be documented in a creative status report. This

6

The overall match rate exceeded 100 percent because some media vendors provided a match in

excess of a dollar-for-dollar value.
Executive Summary

Page 12 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

report does not require documentation of review for political figures or

partisan content. The final review is to be made in ONDCP’s Office of

Legal Counsel. These reviews are not documented. The Comptroller

General’s Standards for Internal Control in the Federal Government

(GAO/AIMD-00-21.3.1) requires that all transactions and significant events

are to be clearly documented, and that the documentation is to be readily

available for examination.

Phases I and II principally focused on testing the impact of the Media

Campaign on youth, teen, and parent ad awareness at the local and

national levels, respectively. Ad awareness and other outcome results for

those phases of the Campaign were inconclusive for each of the three

groups, due to several design, implementation, and analytical limitations.

These limitations included site selection problems, unknown parent

response rates, low school response rates, ad awareness measurement

problems, and data weighting issues. Four of the 12 comparison sites

dropped out of the phase I study; of these 4 sites, 2 did not have

comparable replacements. School response rates for youth and teens in

phase II were less than 30 percent; comparison site school response rates

in phase I were less than 50 percent. Ad awareness was not based on

viewing all types of Campaign advertisements—but instead focused

exclusively on television advertisements.

Other data sources provided evidence that the Campaign had some

positive effects during phases I and II. NCADI demonstrated increased

public contacts and publication distribution during the Campaign, as

compared with the pre-Campaign period. Community sources credited the

Campaign with fostering several anti-drug activities and changes in their

localities. In addition, GAO’s examination of unweighted survey data for

phases I and II showed some positive gains on most ad awareness items. In

addition, the phases I and II data did not show any significant changes in

respondents’ drug attitudes.

The 4-year, phase III evaluation design appeared more promising than the

previous phases in being able to effectively assess the impact of the

Campaign. A comprehensive model of the relationship between media

exposure and drug attitudinal and behavioral change was being tested for

the first time in phase III. The respondent sampling design overcame some

of the limitations of phases I and II—including the use of household

surveys to increase response rates, rather than school and telephone

interviews. The phase III measurement of advertisement exposure is much

more inclusive than the measure of ad awareness in phases I and II

Phases I and II Evaluations

Were Inconclusive; Phase

III Evaluation Design

Appeared Promising
Executive Summary

Page 13 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

because the measurement includes both lagged7and historic trend

analyses, rather than just percentage change scores. In addition, Ogilvy

and Mather are to conduct an ongoing phase III assessment of the impact

of each media element relevant to cost, in order to maximize the

effectiveness of the Campaign. Finally, NCADI is to continue collecting

data on public contacts and publication distribution as supplemental

measures of ad awareness and exposure through the end of calendar year

2000.

To improve ONDCP’s compliance with the statutory program

requirements, GAO recommends that the Director of ONDCP ensure that

the appropriate ONDCP or contractor staff take the following actions:

• To determine the extent to which matches do not occur because of efforts

to achieve the Campaign’s reach and frequency goals, maintain

documentation of all purchases that do not result in a match, including

data on why the vendor did not provide a match and why the purchase was

made without a match. This information should be provided to Congress to

assist in its assessment of the viability of the current congressional

direction that ONDCP obtain a match from each and every seller of

advertising time and space, given the Campaign’s reach and frequency

goals.

• After adequate research and consultation with experts, provide

information to Congress detailing the anticipated dollar value of all

private- sector, nonmatch contributions to assist Congress in its

assessment of the viability of the private-sector contributions goals and the

dollar value that ONDCP can be expected to obtain from the private

sector.

• Develop internal controls, in accordance with the Comptroller General’s

standards, to ensure that the reviews of new advertisements for political

figures or partisan content are fully documented and available for

examination.

GAO provided a draft of this report to the Director of ONDCP for

comment. ONDCP provided written comments, which are discussed at the

end of chapters 2, 3, and 4. GAO also provided relevant sections of the

draft report to the Department of Defense’s Office of the Inspector General

and the Department of Health and Human Services’ Program Support

Center, National Institute on Drug Abuse, and Substance Abuse and Mental

Health Services Administration for a review of the facts pertaining to them.

These organizations, as well as ONDCP, provided technical or clarifying

7 “Lagged” analyses refer to the study of changes taking place over time, rather than concurrently.

Recommendations

Agency Comments and

GAO’s Evaluation
Executive Summary

Page 14 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

changes, which have been incorporated, as needed, in the appropriate

sections of this report.

Overall, ONDCP agreed with GAO’s findings, conclusions, and

recommendations. It stated that the report is balanced, with fair

assessments and recommendations. ONDCP also said that the draft report

could have given greater recognition to various factors that were out of

ONDCP’s control in implementing the Campaign.

In commenting on GAO’s findings and conclusions relating to the financial

aspects of the Campaign, ONDCP inferred that GAO conducted a financial

audit. It added that internal controls allowed ONDCP to monitor the

expenditures and control payments of outside contractors. GAO

emphasizes that it did not conduct a standard financial audit of the

Campaign’s fiscal operations or review the related internal controls. Also,

GAO did not conduct a contract management audit or review how the

internal controls were applied during the contract administration process.

ONDCP asked GAO to amend the draft report to reflect that ONDCP has

submitted to the Appropriations Committees a plan to secure corporate

sponsorship. GAO’s review of the document, which ONDCP provided with

its written comments, led GAO to conclude that it is a blueprint or strategy

for ONDCP’s acquiring a contractor to develop and implement the plan,

rather than the implementation plan itself.8 Therefore, the requirement to

submit to the Appropriations Committees and the Senate Judiciary

Committee an implementation plan for securing private sector

contributions has not yet been fulfilled.

Concerning the recommendation relating to the match program, ONDCP

provided GAO with a copy of a letter addressed to Ogilvy and Mather

instructing the contractor to maintain records of instances in which it is

unable to obtain a match (see app. III). Assuming this instruction is

followed by the contractor, GAO believes it addresses the first part of the

recommendation that ONDCP maintain documentation of all purchases

that do not result in a match. However, in instructing the contractor that

this information should be made available upon request, ONDCP did not

address the intent of the second part of the recommendation, that is, that

ONDCP proactively provide this information to the Congress. As a result,

GAO is retaining its recommendation.

8

The Fiscal Year 1998 Treasury and General Government Appropriations Act required ONDCP to

submit to the Appropriations Committees and the Senate Judiciary Committee a detailed

implementation plan for securing private sector contributions, including but not limited to in-kind

contributions.
Executive Summary

Page 15 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

In response to GAO’s recommendation that ONDCP formalize the review

of new advertisements for political figures or partisan content, ONDCP

stated that it would do so by requiring that the required legal reviews be

documented. Since this action has not yet been taken, GAO is retaining

this recommendation.
Page 16 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

Contents

Executive Summary 4

20

Media Campaign Appropriations and Statutory

Requirements

20

Campaign Strategy and Implementation 21

Campaign Structure 23

Objectives, Scope, and Methodology 28

Chapter 1

Introduction

34

As Mandated, ONDCP Generally Provided Timely,

Written Financial Reports to Congress Since May 1998

34

ONDCP Established Processes to Oversee Paid

Advertisement Spending

36

ONDCP Obligated Funds in Compliance With Selected

Statutory Spending Restrictions

39

Conclusions 41

Agency Comments and Our Evaluation 41

Chapter 2

ONDCP Generally

Provided Timely

Financial Reports and

Obligated Funds in

Accordance With

Selected Statutory

Restrictions

42

Match Program Developed to Meet Requirements

Regarding Existing PSAs and Qualifications of

Recipient Organizations

43

Campaign’s Efforts With Community Anti-Drug Coalitions

Have Increased Over Time

51

ONDCP Has Not Developed a Private Sector

Contributions Plan

57

Guidance and Procedures Regarding Political Figures and

Partisan Political Purposes Lacked Adequate Internal

Control

62

Conclusions 63

Recommendations 64

Agency Comments and Our Evaluation 64

Chapter 3

ONDCP’s Compliance

With Statutory

Program Requirements

Has Been Mixed
Contents

Page 17 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

67

ONDCP Has System for Evaluating the Campaign 67

Phases I and II Respondent Sampling Designs Were

Generally Appropriate, but Awareness Measure Had

Limitations

70

Phases I and II Implementation and Analytic Limitations

Compromised the Results

72

Some Positive Effects Were Associated With Phases I and

II

76

The Phase III Evaluation Design Appears More Promising

Than Previous Phases

78

Conclusions 80

Agency Comments and Our Evaluation 81

Chapter 4

ONDCP Phases I and II

Campaign Evaluations

Were Inconclusive;

Phase III Evaluation

Appears Promising

Appendix I: Experts Consulted 82

Appendix II: NCADI Public Contacts and Publication

Distribution

84

Appendix III: Comments From the Office of National

Drug Control Policy

86

Appendix IV: GAO Contacts and Staff Acknowledgments 91

Appendixes

Table 1.1: Campaign Phases 23

Table 1.2: Descriptions and Roles of Organizations

Involved in the Media Campaign

24

Table 3.1: Number of Matches, Dollar Values, and Dollar

Percentages, Hard and Soft, Through December 1999

44

Table 3.2: Partnership Activities as of March 2000 54

Table 3.3: Private Sector Cash, In-Kind, and Other

Contributions

60

Table 4.1: Methodology of the Impact Evaluations for

Phases I, II, and III of the National Youth Anti-Drug

Media Campaign

69

Table II.1: NCADI Public Contacts Pre-Campaign and

Phases I and II (Percentage Change From PreCampaign Period)

84

Table II.2: NCADI Publication Distribution Pre-Campaign

and Phases I and II

85

Tables

Figure 1.1: Total Media Campaign Expenditures, as of

September 30, 1999 Figures 26

Figure 2.1: Media Campaign Costs Associated With Paid

Advertising, as of September 30, 1999

37
Contents

Page 18 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

Abbreviations

AAF American Advertising Federation

CADCA Community Anti-Drug Coalitions of America

CiC Cable in the Classroom

CLSPY Community Longitudinal Survey of Parents and Youth

COR Contracting Officer's Representatives

CRC Creative Review Committee

DOD Department of Defense

EOP Executive Office of the President

FFA Future Farmers of America

HHS Department of Health and Human Services

JRAP Joint Recruiting and Advertising Program

MTF Monitoring the Future

NASADAD National Association of State Alcohol and Drug Abuse Directors

NCADI National Clearinghouse for Alcohol and Drug Information

NDPL National Drug Prevention League

NEA National Education Association

NHSDA National Household Survey on Drug Abuse

NIDA National Institute on Drug Abuse

NNN Newspaper National Network

NPN National Prevention Network

NSPY National Survey of Parents and Youth

OMB Office of Management and Budget

ONDCP Office of National Drug Control Policy

PAS Print Audit Service

PDFA Partnership for a Drug-Free America

PSA public service announcement

PSC Program Support Center (Health and Human Services)

PTSA Prevention Through Service Alliance

RFI Request for Information

RFP Request for Proposal

SAMHSA Substance Abuse and Mental Health Services Administration

SHRM Society for Human Resource Management

YSA Youth Service America
Page 19 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign
Chapter 1

Introduction

Page 20 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

The Office of National Drug Control Policy’s (ONDCP) National Youth

Anti-Drug Media Campaign, which was proposed as a nearly $1 billion

federal effort over 5 years, was developed in response to reported

increases in drug use among youth in the United States. The Media

Campaign’s goals are to (1) educate and enable youth to reject illegal

drugs, (2) prevent youth from initiating the use of drugs, and (3) convince

occasional users to stop using illegal drugs. The Campaign supports the

first goal of the 1999 National Drug Control Strategy, which is to educate

and enable America’s youth to reject illegal drugs as well as alcohol and

tobacco.1

In the Treasury and General Government Appropriations Act for 1998,

Congress authorized ONDCP to undertake a national Media Campaign to

reduce and prevent drug use among youth.2 The initial appropriation for

the Campaign was $195 million. An additional $185 million were

appropriated in the fiscal year 1999 Appropriations Act3 and in the fiscal

year 2000 Appropriations Act.4

As part of its fiscal year 1998 appropriation, Congress mandated that

ONDCP submit a Campaign strategy for approval to the Appropriations

Committees and the Senate Judiciary Committee. The Campaign strategy

was to include the following requirements:

• guidelines to ensure and certify that funds will supplement and not

supplant current anti-drug community-based coalitions;

• guidelines to ensure and certify that funds will supplement and not

supplant current pro bono public service time that is donated by national

and local broadcasting networks;

• guidelines to ensure and certify that the funds will not be used for partisan

political purposes;

• guidelines to ensure and certify that no media campaigns to be funded

pursuant to this Campaign shall feature any elected officials, persons

seeking elected office, cabinet-level officials, or other federal officials

employed pursuant to Schedule C of title 5, Code of Federal Regulations,

section 213, absent advance notice to the Appropriations Committees and

the Senate Judiciary Committee;

1

The National Drug Control Strategy, 1999, ONDCP.

2

Public Law 105-61, 111 Stat. 1293, 1294 (1997).

3

Public Law 105-277, 112 Stat. 2681-496 (1998).

4 Public Law 106-58, 113 Stat. 447, 448 (1999).

Media Campaign

Appropriations and

Statutory

Requirements
Chapter 1

Introduction

Page 21 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

• a detailed implementation plan to be submitted to the Appropriations

Committees and the Senate Judiciary Committee for securing private

sector contributions, including, but not limited to, in-kind contributions;

• a detailed implementation plan to be submitted to the Appropriations

Committees and the Senate Judiciary Committee of qualifications that are

necessary for any organization, entity, or individual to receive funding for

or otherwise be provided with broadcast media time; and

• a system to measure outcomes of success of the Campaign.

The act further required that the Director report to Congress quarterly on

the obligation of funds, as well as specific parameters of the Campaign,

and report to Congress within 2 years on the effectiveness of the Campaign

on the basis of measurable outcomes previously provided to Congress. In

addition, the act placed a restriction on the obligation of Campaign funds.

Subsequently, as discussed in chapters 2 and 3, in fiscal year 1999,

Congress placed additional requirements on ONDCP in the Campaign’s

appropriations acts regarding financial reporting, obligation of funds,

public service time, private sector contributions, and other aspects of the

Campaign. In fiscal year 2000, Congress required that ONDCP not obligate

10 percent of its available funds until ONDCP had submitted a plan for

corporate sponsorship to the Appropriations Committees.

In response to these requirements, ONDCP submitted a Campaign strategy

to the appropriate Committees in November 1997 and, as requested by the

Committees, provided additional information in early 1998. In addition,

ONDCP officials provided oral reports to Congress regarding spending

during the early months of the Campaign and began providing written

reports on Campaign obligations and expenditures in May 1998. They also

provided impact evaluation reports regarding Campaign effectiveness in

August 1998, September 1998, March 1999, and June 1999.

Initially, ONDCP and a contractor, Porter Novelli, developed a

communication strategy to establish the overall Campaign direction and to

guide the development of specific Campaign messages, materials, and

activities. According to the communication strategy, the focus of the

Campaign is to promote primary prevention—that is, to prevent drug

abuse before it starts. In general, the Campaign is intended to counteract

messages and images in the popular culture that glamorize, legitimize,

normalize, or otherwise condone drug use. Youth aged 9 to18 years,

primarily 11 to 13 year olds; parents and other primary caregivers; and

other adults who influence youth are targeted by the Campaign. Campaign

messages are to accurately depict drug use and its consequences,

Campaign Strategy and

Implementation
Chapter 1

Introduction

Page 22 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

encourage parents to discuss drug abuse with children, and foster other

message strategies as outlined in the communications strategy.

The centerpiece of the Campaign is the paid advertising effort in which

Campaign funds are to be used to purchase media time and space for

advertisements that deliver anti-drug messages to the Campaign’s target

audiences. The initial reach and frequency goal, which ONDCP established

for the paid advertising component, was to reach 90 percent of the target

audiences with at least four messages a week, across all media types.5

Advertisements are to be produced in 11 languages to communicate to

youth and adults of major ethnic groups, including Hispanics, Asian

Americans, and Pacific Islanders.

The Campaign has five other key components, as follows, that support the

advertising effort:

• interactive media,

• entertainment industry collaboration,

• public information/news media,

• partnerships/community participation, and

• corporate participation.

The Campaign is being implemented in three phases. Table 1.1 illustrates

the scope, time period, and focus for each phase.

5

“Reach and frequency goal” refers to communicating the message to a certain percentage of the target

audiences a certain number of times a week.
Chapter 1

Introduction

Page 23 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

Phase Scope Time period Focus

I 12-city pilot January-July,

1998

Paid advertising—local

television and radio. Very limited

implementation of the additional

five Campaign components.

II Nationwide, 102

media markets

July-December,

1998

Expansion of paid advertising to

include all media types. Very

limited implementation of the

additional five Campaign

components.

III Nationwide, 102

media markets

January 1999-

December 2002a

Continuation of paid advertising.

Expansion of the additional five

Campaign components.

a

There was a transition period of several months between phases II and III. As a result, the fully

integrated Campaign did not start until the summer of 1999.

Source: ONDCP.

ONDCP has overall responsibility for developing and implementing the

Media Campaign. However, as directed by the congressional conferees,6

ONDCP consults with media and drug experts, such as The Advertising

Council, Inc. (Ad Council), and the Partnership for a Drug-Free America

(PDFA). In addition, ONDCP has worked with other federal entities,

private businesses, nonprofit organizations, and trade associations to

obtain support for various aspects of the Campaign—from initial

Campaign design to evaluation.

Table 1.2 lists the organizations that support the Campaign and that are

discussed in this report. The table provides the organizations’ name, type,

work description, and role in the Campaign.

6 H.R. Conf. Rep. No. 105-284 at 67 (1997).

Table 1.1: Campaign Phases

Campaign Structure
Chapter 1

Introduction

Page 24 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

Organization Type Description and role in Media Campaign

The Advertising Council, Inc. Nonprofit organization Provides public service communications for nonprofit

organizations. Serves as the clearinghouse for the

organizations and public service announcements (PSAs)

submitted by nonprofit groups and government organizations for

consideration as part of the Campaign’s national-level media

match program. Also assists the Campaign in recruiting

volunteers for anti-drug coalitions and reviews production costs

for new Campaign advertisements.

The American Advertising

Federation

Trade association Professional advertising association of corporate advertisers,

agencies, media companies, suppliers, and academia.

Oversees all screening and approval of local organizations and

PSAs for participation in the local-level match program.

Bates Advertising USA, Inc. Private business Phases I and II paid advertising contractor. Efforts included (1)

media planning and purchasing of media time and space from

various media vendors and (2) oversight, negotiation, and

implementation of the Campaign’s media match program.

Community Anti-Drug Coalitions

of America

Nonprofit organization National organization of anti-drug coalitions that supports

community-based strategies for substance abuse prevention, to

promote drug-free communities. Assists the Campaign in

developing process evaluation measures to assess the impact

of the Campaign on community-based, anti-drug efforts and in

developing partnerships at the community level to enhance and

leverage Campaign messages. Also, inquiries generated from

Campaign advertisements in certain areas are referred to these

coalitions and their network of community resources. Assisted in

surveying its member coalitions to report impacts on community

organizations from phase I advertisements.

Cox and Associates, CPAs, P.C. Private business Accounting agency. Provides financial management support,

such as invoice processing and development of a Campaign

financial and program information tracking system.

CSR, Inc. Private business Policy research, training, and management services

organization. Campaign evaluation contractor for phases I and

II.

Department of Defense (DOD),

Defense Manpower Data Center

Joint Advertising and Market

Research Division

Federal agency Oversees DOD’s Joint Recruiting and Advertising Program,

which, along with its contracting office, the Defense Supply

Service, Washington, provided administrative contract support

for phase I paid advertising efforts by issuing a task order under

its existing contract with Bates Advertising USA, Inc.

Department of Health and

Human Services’ Program

Support Center

Federal agency Among other things, provides contracting support to other

federal agencies on a fee-for-service basis. Provides

administrative contract support for phases II and III paid and

nonpaid advertising efforts through advertising and awarding

Campaign contracts (e.g., Bates Advertising USA, Inc.; Ogilvy

and Mather; and Fleishman-Hillard, Inc.)

Department of Health and

Human Services’ Substance

Abuse and Mental Health Services

Administration (SAMHSA)

Federal agency Mission is to improve the quality and availability of prevention

and treatment and rehabilitation services for substance abuse

and mental health. Provided a qualitative analysis of the impact

of phase I and identified ways to amplify the impact of phase I

as the Campaign expands nationally.

Table 1.2: Descriptions and Roles of Organizations Involved in the Media Campaign
Chapter 1

Introduction

Page 25 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

Organization Type Description and role in Media Campaign

Fleishman-Hillard, Inc. Private business Phase III nonpaid advertising contractor. Assists with interactive

media, entertainment industry collaboration, public

information/news media, and partnerships.

National Association of State

Alcohol and Drug Abuse

Directors

Nonprofit organization National association to foster and support the development of

effective alcohol and other drug abuse prevention and treatment

programs throughout every state. Assists The American

Advertising Federation with its local media match activities, and,

through a hotline and clearinghouse, responds to inquiries

generated by Campaign advertisements.

National Clearinghouse for

Alcohol and Drug Information

Federal agency SAMHSA’s information service, which, upon request, provides

current information and materials concerning substance abuse.

Collecting public contact and publication distribution data for the

phases I, II, and III evaluations.

National Drug Prevention

League

Nonprofit organization An association of 30 national and major regional private sector

organizations for drug abuse prevention. Assisting ONDCP in

identifying the capacities and key points of contact for drug

prevention among civic and community organizations across the

country.

National Institute on Drug

Abuse

Federal agency Funds 85 percent of the world’s drug abuse research.

Conducting the phase III evaluation on behalf of ONDCP, to

ensure state-of-the-science methods and analytic procedures

and the integrity and independence of the results.

Ogilvy and Mather Private business Phase III paid advertising contractor. Efforts include (1) media

planning and purchasing of media time and space from various

media vendors and (2) oversight, negotiation, and

implementation of the Campaign’s media match program.

The Partnership for a Drug-Free

America

Nonprofit organization Coalition of professionals from the communications industry.

Oversees and implements the creation of all paid

advertisements used in the Campaign.

Porter Novelli Private business Strategic communications planning firm. Provided general

advertising and Campaign expertise and assisted ONDCP in

developing the overall communication strategy.

Westat Private business Research organization. Phase III Campaign evaluation

contractor.

Zenith Media Services, Inc. Private business Phases I and II subcontractor under Bates Advertising USA, Inc.

Purchased media time and space from all national and local

broadcast vendors, except purchases directed at specific ethnic

markets.

Source: ONDCP.

ONDCP uses advertising contractors to obtain the media planning,

purchasing, and other advertising expertise necessary to carry out its

statutory responsibilities for conducting the paid advertising component of

the Media Campaign. Media purchases include national and local

television, radio, and cable and newspaper, magazine, and Internet

advertisements, among others. As shown in figure 1.1, payments to the

advertising contractors for media planning and purchasing accounted for

approximately 84 percent of the total Campaign expenditures for the first 2

years of the Campaign that ONDCP reported to Congress.

ONDCP Uses Advertising

Contractors and Contract

Support Agents for Paid

Advertisements
Chapter 1

Introduction

Page 26 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

a

Includes expenditures for activities such as research, consulting, and clearinghouse services.

Source: GAO analysis of ONDCP Obligation and Expenditure Report to Congress, as of September

30, 1999.

From the Campaign’s inception, ONDCP relied on other federal agencies to

provide administrative contract support for the Campaign’s paid

advertising contracts. Administrative contract support included, among

other things, managing the contracting process through solicitation and

selection; awarding the contract; and overseeing the execution of the

contract, including reviewing vouchers against the contract’s limit.

Although ONDCP used administrative contract support from other

agencies, it remained responsible for ensuring that the contractors’

performance met the advertising objectives of the Campaign. This

responsibility included selecting the contractors, ensuring those contracts

and related modifications were in accordance with ONDCP’s media plan,

and authorizing payment of media advertising costs.

ONDCP officials told us that because of the potentially high demands of

the Campaign, ONDCP initially decided that neither ONDCP nor the

Executive Office of the President (EOP) had the capabilities necessary to

support the contracting efforts needed to undertake the Campaign’s paid

advertising efforts. In November 1997, ONDCP entered into an interagency

agreement with the Defense Manpower Data Center Joint Advertising and

Market Research Division, which handles the Department of Defense’s

(DOD) Joint Recruiting and Advertising Program (JRAP), to provide

Figure 1.1: Total Media Campaign

Expenditures, as of September 30, 1999
Chapter 1

Introduction

Page 27 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

administrative contract support services for the phase I paid advertising

efforts. JRAP’s contracting office, the Defense Supply Service, Washington,

had an existing contract with a large advertising agency, Bates Advertising

USA, Inc. (Bates), which could provide services for other federal agencies.

As a result, the Defense Supply Service, Washington, issued a task order

for the phase I paid advertising, with subsequent modifications, totaling

$23 million under its existing contract. ONDCP paid for the costs

associated with running the advertisements, but DOD did not charge

ONDCP for its efforts in administering the contract. Upon completion of

the phase I Campaign efforts, according to ONDCP officials, ONDCP did

not renew its agreement with JRAP because ONDCP always intended for

DOD’s existing contract to be used only as a temporary vehicle to quickly

initiate the Campaign.

In April 1998, ONDCP entered into an agency reimbursable work

agreement with the Department of Health and Human Services’ (HHS)

Program Support Center (PSC) to provide administrative contract support

for the phase II paid advertising efforts, including award of the contract to

an advertising agency. In May 1998, HHS issued a contract to Bates, the

same contractor that was used for phase I,7 for about $120 million, which

was subsequently modified to about $140 million for additional media

purchases.

In December 1998, the HHS agreement was amended to cover phase III

paid advertising efforts through December 1999. HHS issued a contract for

about $129 million in December 1998 to Ogilvy and Mather for phase III of

the Campaign.8

The phase III contract was issued for 1 year, with four 1-

year options to cover the entire Campaign. In January 2000, HHS and

ONDCP entered into another agreement to cover the first option year

under the contract, and HHS issued a contract modification for about $133

million to Ogilvy and Mather to extend the contract through January 3,

2001.

PSC provides administrative support services on a fee-for-service basis to

HHS components and other federal agencies. As of February 2000, ONDCP

7

According to ONDCP and HHS officials, a sole-source contract was issued to Bates, in part, to prevent

disruption in the advertising Campaign as it transitioned from a 12-city pilot program in phase I to a

national Campaign in phase II.

8

According to ONDCP and HHS, a full-and-open competition was conducted to select the phase III

contractor.
Chapter 1

Introduction

Page 28 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

had agreed to pay PSC about $604,000 for services supporting ONDCP

Campaign contracts.9

Although ONDCP used administrative contract support from other federal

agencies, it remained responsible for monitoring the contractors’ costs for

paid advertising. (See ch. 2 for more information regarding ONDCP’s

oversight of paid advertisement spending.)

The conference report10 and the Senate Appropriations Committee Report11

for the Treasury and General Government Appropriations Act for 1999

directed us to (1) conduct a financial audit and review of the ONDCP

National Youth Anti-Drug Media Campaign, (2) review ONDCP’s

compliance with certain program requirements listed in the public law, and

(3) review certain aspects of the phase I results. On the basis of

subsequent discussions with staff from the Subcommittee on Treasury and

General Government, Senate Committee on Appropriations, and the

Subcommittee on Treasury, Postal Service, and General Government,

House Committee on Appropriations, we agreed to determine the

following:

• whether ONDCP provided timely financial reports to Congress as required

by Public Law 105-61 and Public Law 105-277; how funds for paid

advertising were managed and disbursed; and whether ONDCP complied

with certain statutory requirements regarding the obligation of funds;

• what ONDCP has done to develop and implement guidelines for the

Campaign in response to the program requirements set out in Public Law

105-61 and Public Law 105-277; and

• whether the evaluation designs for phases I, II, and III were appropriate;

how well the phases I and II evaluations were implemented; and how

effective phases I and II of the Campaign were in influencing group

awareness of different types of paid anti-drug media messages (ad

awareness)12 and drug attitudes.

9

ONDCP agreed to pay PSC, in addition, about $156,000 for other contracts that supported its

advertising efforts (e.g., consulting) and about $412,000 for nonadvertising Campaign contracts. Thus,

the total PSC fees agreed to by ONDCP to support the Campaign, as of February 2000, were about

$1,172,000.

10 H.R. Conf. Rep. No. 105-825 1493, 1497 (1998).

11 S. Rep. No. 105-251, 58-59 (1998).

12 ONDCP, Testing the Anti-Drug Message in 12 Cities National Youth National Drug Media Campaign:

Phase I (Report No. 2), p. 2-1, March 1999.

Objectives, Scope, and

Methodology
Chapter 1

Introduction

Page 29 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

We did not conduct a financial audit of the Campaign’s fiscal operations or

review the related internal controls. Also, we did not conduct a contract

management audit, that is, we did not review the contract award process

or review how the internal controls were applied during the contract

administration process.

To review the timeliness of ONDCP’s financial reporting, we collected and

examined pertinent ONDCP and EOP documents, including the monthly

written reports on obligations and expenditures that were submitted to

Congress, and the fiscal years 1998, 1999, and 2000 Treasury and General

Government Appropriations Acts. We also interviewed ONDCP and EOP

officials, as agreed with the Subcommittee staffs. We did not, however,

verify the accuracy of the financial information reported.

To describe how funds for paid advertising were managed and disbursed,

we (1) gained an understanding of ONDCP’s use of contractors and

contract support agents for its paid advertising efforts and (2) examined

the paid advertising invoicing process from invoice preparation by the

contractor to final payment and expenditure reporting to Congress. We

collected and reviewed pertinent EOP, ONDCP, DOD, HHS, and contractor

documents, such as contracts, interagency agreements, invoices, and

supporting documentation (e.g., media vendor billings). In addition, we

also interviewed EOP, ONDCP, DOD, HHS, the contractors, and the

subcontractor officials. However, as agreed, we did not test ONDCP’s

processes to oversee paid advertisement spending to ensure that the

procedures were effective and properly implemented.

To review ONDCP’s compliance with selected statutory requirements

regarding the obligation of funds, we collected and analyzed certain

obligating documents, including all Campaign contracts and interagency

agreements entered into during fiscal years 1998 and 1999; other pertinent

ONDCP documents; and fiscal years 1998, 1999, and 2000 Treasury and

General Government Appropriations Acts. However, we did not review the

obligating documents supporting every Campaign obligation. For example,

we did not review the supporting documents for travel and printing

obligations. The obligating documents we reviewed represented about 91

and 94 percent of ONDCP’s fiscal years 1998 and 1999 appropriations,

respectively. We did not review ONDCP’s compliance with other statutory

spending requirements, such as restrictions regarding the type of activities

for which Campaign funds may and may not be used.

To review ONDCP’s development and implementation of guidelines to

meet the program requirements listed in Public Law 105-61, we
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Introduction

Page 30 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

interviewed officials at the following offices: ONDCP; Bates; Zenith Media

Services, Inc. (Zenith); Ogilvy and Mather; the Ad Council; The American

Advertising Federation; Fleishman-Hillard; and PDFA. We also collected

and analyzed pertinent documents from each of these offices.

In addition, regarding the “match” program, we verified the electronic data

provided by ONDCP’s phases I and II advertising contractors against their

actual supporting documentation. Bates was ONDCP’s advertising

contractor for phases I and II; Zenith was the subcontractor responsible

for the purchase of national and local television, radio, and cable

advertisements. Bates and Zenith reported achieving rates of at least 100-

percent match value to paid value, that were based on computerized data

on paid advertisements and the corresponding matches. In verifying the

accuracy of the electronic data provided by the contractors, we focused

primarily on the number and size of the errors in the databases. We

compared a sample of records from the electronic databases to their

supporting documentation, and defined an “error” as any instance when

we found a difference of more than $100 that would have inflated the

estimate of the percentage of dollars matched. Errors in the electronic

data would indicate that the match estimates were questionable; relatively

few discrepancies between database and supporting documentation would

indicate confidence in the match estimates.

Since the match program covered multiple media types and numerous

vendors, we selected all vendors in some media types and samples of

vendors in other media types, to reduce data collection time and cost. We

asked Bates and Zenith to provide lists of matches negotiated from each

media vendor, from the third quarter of 1998 through the first quarter of

1999. We selected all magazine, in-school, and cinema/arcade vendors; all

national television and radio vendors (which accounted for 73 percent of

the total dollars spent on television and radio advertising); and random

samples of 64 local television and radio vendors and 61 newspaper

vendors.

We developed a data collection instrument to compare data from the

contractors’ databases and their supporting documentation. We pretested

our data collection instrument, using information related to several

vendors, to ensure the reliability of our data collection.

For each vendor, we reviewed database information and the supporting

documentation for each paid advertisement and corresponding match.

From the contractors’ databases, we recorded the number and value of

paid advertisements and matches for each vendor. At the offices of Bates
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Introduction

Page 31 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

and Zenith, we used several types of supporting documentation, including

invoices, insertion orders, print requisition forms, rate cards, vendor

agreements, post buy reports, Print Audit Service (PAS) and Newspaper

National Network (NNN)13 reports, and brand/time schedules.

The results from the newspaper and the local television and radio vendors’

samples were weighted. The weighting enabled us to make estimates about

the total population error rates in the contractors’ databases for these

vendors. Additionally, since our sample contained vendors that accounted

for 73 percent of the total dollars spent on television and radio advertising,

we also were able to estimate, with adequate precision, the match

advertisement dollars as a percentage of paid advertisements for television

and radio.

The estimate for the error rate in Bates’ database was 3 percent, with a 95-

percent confidence interval of 1 to 7 percent; the estimated error rate in

Zenith’s database was 2 percent, with a 95-percent confidence interval of

less than 1 to 8 percent. This means, for example, that we are 95-percent

confident that at least 1 percent of Bates’ database records were in error,

but that no more than 7 percent of the records were in error. Similarly, we

are 95-percent confident that from less than 1 to 8 percent of Zenith’s

database records were in error.

The estimate for the match program for Bates was 102 percent, with a 95-

percent confidence interval of plus or minus 2 percent; the estimate of the

percentage match received by Zenith was 115 percent, plus or minus 10

percent. In other words, we are 95-percent confident that Bates received at

least a dollar-for-dollar of match-to-paid advertisement value. We are also

95-percent confident that Zenith received a match between 105 and 125

percent.

To determine how appropriate the impact evaluation designs were for

determining the effectiveness of phases I, II, and III of the Campaign, we

interviewed ONDCP officials and study representatives from the principal

evaluation organizations—CSR, Inc., (phases I and II) and the National

Institute on Drug Abuse (NIDA) (phase III). We obtained documentation

from each of these agencies describing the evaluation designs for each of

the three phases, and we submitted oral and/or written questions when we

identified concerns or limitations. We also obtained outside reviews from

13 PAS and NNN are services that, for advertising agencies, verify that newspaper advertisements have

been printed as agreed. The data they collect are entered into databases that produce reports sent to

the advertising agencies.
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experts on the methodological and statistical procedures used in the

Campaign (see app. I). The appropriateness of the evaluation designs was

based on principles of scientific research, input from outside experts, and

our own knowledge base built upon years of scientific research. We also

interviewed Ogilvy and Mather officials and obtained documentation

related to their phase III econometric study of media impact, to determine

the strengths and limitations of the design.

To determine how well the phases I and II evaluations were implemented,

we evaluated the phases I and II final reports that ONDCP submitted to

Congress, in addition to agency documents regarding specific aspects of

the evaluation implementation.14 We relied on our experience in designing

and assessing evaluation methodologies—that is, our experience with

generally accepted social science methodological standards and practices.

We discussed issues and concerns with ONDCP and CSR and

recommended changes to phase I drafts, some of which ONDCP

subsequently approved and adopted. We also received written reviews

from several outside experts on various aspects of the phases I and II

methodological and statistical procedures (see app. I).

To determine how effective phases I and II of the Campaign were in

influencing drug ad awareness and drug attitudes, we examined the

aggregate and site-specific baseline and follow-up survey data from the 12

target and 12 comparison sites of phase I (see table 4.1). We also examined

the baseline and follow-up survey data that were derived from ONDCP’s

phase II national effort. These data were principally derived from the

phases I and II reports to Congress. But, as questions and issues arose, we

were able to obtain additional statistical information and documentation

from either ONDCP or CSR. In addition, we examined data from the

National Clearinghouse for Alcohol and Drug Information (NCADI) to

determine the relationship between Campaign intervention and agency

contacts and requests for information. Beyond examining the individual

data sets, we considered various methodological and statistical issues as

they bear on the evaluation results, including site selection procedures,

response rates, ad awareness measurement, data weighting procedures,

and the representativeness and generalizability of the results.

We performed our work from September 1998 to May 2000 in accordance

with generally accepted government auditing standards. In June 2000, we

requested comments on a draft of this report from the Director of ONDCP.

14 Phase III implementation was only beginning at the time we completed our work.
Chapter 1

Introduction

Page 33 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

On July 3, 2000, we received written comments from ONDCP, which are

discussed at the end of chapters 2, 3, and 4 and reprinted in appendix III.

We also provided relevant sections of the draft report to DOD’s Office of

the Inspector General, HHS’ Program Support Center, NIDA, and the

Substance Abuse and Mental Health Services Administration for a review

of the facts pertaining to them. These organizations, as well as ONDCP,

provided technical or clarifying changes, which have been incorporated, as

needed, in the appropriate sections of this report.
Chapter 2

ONDCP Generally Provided Timely Financial

Reports and Obligated Funds in Accordance

With Selected Statutory Restrictions

Page 34 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

In response to statutory financial reporting requirements, ONDCP

provided oral reports to Congress regarding spending during the early

months of the Media Campaign. In May 1998, ONDCP provided its first

written financial report to Congress covering the first 8 months of the

Campaign. Since then, ONDCP has generally provided timely cumulative

written financial status reports on a monthly basis. ONDCP reported

spending approximately 84 percent of the total Campaign funds for fiscal

years 1998 and 1999 on paid advertising. ONDCP had processes in place to

monitor and approve all paid advertising expenditures before paying

vendors and reporting to Congress. In addition, our review showed that

ONDCP complied with selected spending restrictions imposed by

Congress.

The Treasury and General Government Appropriations Act of 19981

required the Director of ONDCP to report to Congress quarterly on the

obligation of funds of the Campaign. In December 1997, the Subcommittee

on Treasury and General Government, Senate Committee on

Appropriations, requested that ONDCP provide a monthly report of all

obligations and expenditures of funds associated with the Campaign.2

Subsequently, the Treasury and General Government Appropriations Act

of 19993

required ONDCP to report to Congress not only quarterly, but also

to provide monthly itemized reports of all obligations and expenditures

relating to the Campaign.4

Our review of fiscal year 1998 obligations5revealed that ONDCP made its

first significant financial obligation of the Campaign in December 1997 for

paid advertisements. Related disbursements began in March 1998. ONDCP

officials said that they communicated orally with the appropriate

Committees during the first two quarters of fiscal year 1998, including

discussions regarding the Campaign’s financial activities.

1 Public Law 105-61, 111 Stat. 1293, 1295 (1997).

2

A letter dated December 8, 1997, was sent to ONDCP from the Chairman of the Subcommittee on

Treasury and General Government, Senate Committee on Appropriations.

3

Public Law 105-277, 112 Stat. 2681-497 (1998).

4

Although the Treasury and General Government Appropriations Act for 2000 (P.L. 106-58) did not

contain a reporting requirement, the Senate report on the bill directed ONDCP to submit quarterly

reports on the obligation of funds (S. Rep. No. 106-87 at 54).

5

We reviewed obligating documents representing 91 percent of the fiscal year 1998 Campaign’s funds

that were available for obligation.

As Mandated, ONDCP

Generally Provided

Timely, Written

Financial Reports to

Congress Since May

1998
Chapter 2

ONDCP Generally Provided Timely Financial Reports and Obligated Funds in Accordance

With Selected Statutory Restrictions

Page 35 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

ONDCP provided its first written report to Congress in May 1998. The

report included obligations and disbursements for the first 8 months of the

Campaign (i.e., from Oct. 1997 to May 1998). According to ONDCP

officials, ONDCP previously provided oral reports rather than written

reports because (1) there were several administrative tasks to complete in

developing the new Campaign, including designing reporting procedures

and formats; (2) there were relatively few financial transactions during the

first several months of the Campaign; and (3) ONDCP officials believed

that their oral reports satisfied the intent of the act’s reporting

requirements.

Since May 1998, ONDCP generally provided written reports on a monthly

basis. The reports included cumulative obligations and expenditures from

the inception of the Campaign.6 According to ONDCP officials, ONDCP did

not provide written reports in October, November, and December, 1998,7

and October 19998 because of delays in closing the accounting records for

one fiscal year and opening records for the new fiscal year. Although

ONDCP is not statutorily required to provide financial reports to Congress

in fiscal year 2000, officials stated that they intend to continue to provide

financial reports. However, according to ONDCP officials, due to delays

associated with upgrading the EOP’s financial accounting system that

maintains the accounting records and ONDCP’s plans to change the report

format, no written or oral reports had been issued in fiscal year 2000 at the

time of our review. ONDCP plans to issue a report that includes

cumulative figures reflecting all activity to date as soon as these two issues

are resolved. According to ONDCP officials, the updated report format will

be more consistent with how the Campaign’s efforts are organized,

particularly for paid advertisements.

The fiscal years 1998 and 1999 ONDCP reports detailed the Campaign’s

operating budget, commitments, obligations, and expenditures by various

spending categories, such as program evaluation and paid advertisements.

The EOP’s Office of Administration maintains the official financial system

of record for the Campaign and, therefore, is responsible for preparing the

financial reports for ONDCP. However, ONDCP is responsible for ensuring

the accuracy of the financial reports. In doing so, ONDCP is to approve all

6

Each written monthly report includes total obligations and expenditures since the program started, as

of the date of the report or the end of the month before the date of the report, as noted.

7

The subsequent report provided in January 1999 included cumulative figures that reflected activity for

the months in which no reports were provided.

8

In November 1999, ONDCP provided a report on all obligations and expenditures as of September 30,

1999.
Chapter 2

ONDCP Generally Provided Timely Financial Reports and Obligated Funds in Accordance

With Selected Statutory Restrictions

Page 36 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

Campaign transactions, including all Campaign obligations and

expenditures, before their input into EOP’s financial management system.

We did not conduct a financial audit of the Campaign’s fiscal operations or

review the related internal controls to determine the accuracy of the

Campaign’s obligations and expenditures.

ONDCP uses advertising contractors to carry out its statutory

responsibilities for conducting the paid advertising portion of the

Campaign. These contractors provide the necessary media planning,

purchasing, and other advertising expertise. Paid advertising includes

costs associated with radio, television, newspaper, magazine, and Internet

advertisements, among others. These paid advertisements are considered

the most significant costs of the Campaign. According to ONDCP’s

financial reports to Congress, during the first 2 years of the Campaign,

these contracts accounted for approximately 84 percent of total Campaign

expenditures as of September 30, 1999.9 Although ONDCP used

administrative contract support from other federal agencies to assist them

with the advertising contracts, ONDCP remained responsible for ensuring

that only valid Campaign expenses were paid. ONDCP is to review all

invoices from paid advertisement contractors and recommend payment or

nonpayment to HHS. We did not conduct a contract management audit or

review how the internal controls were applied during the contract

administration process.

From its inception, ONDCP relied on other federal agencies to provide

administrative contract support for the Campaign’s paid advertising

contracts. Administrative contract support included, among other things,

overseeing the execution of the contract (e.g., reviewing invoices against

the contract’s limit).10 As shown in figure 2.1, the majority of ONDCP’s

expenditures under these advertising contracts were for purchasing time

and space for anti-drug advertisements from various media vendors,

including radio and television broadcasters, newspapers, magazines, and

Internet providers, among others. Expenditures under the advertising

contracts were also made for activities such as advertising production and

labor.

9

The remaining 16 percent of the Campaign expenditures included Campaign evaluation expenditures

and those for other activities, such as research, consulting, and clearinghouse services. (See fig. 1.1 in

ch. 1 of this report.)

10 For more information regarding these contract support agents and advertising contracts, see chapter

1.

ONDCP Established

Processes to Oversee

Paid Advertisement

Spending
Chapter 2

ONDCP Generally Provided Timely Financial Reports and Obligated Funds in Accordance

With Selected Statutory Restrictions

Page 37 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

a

Includes expenditures for activities such as advertising production and labor.

Source: ONDCP Obligation and Expenditure Report to Congress, as of September 30, 1999.

Although ONDCP used administrative contract support from other federal

agencies, it remained responsible for monitoring the contractors’ costs and

spending for the paid advertising efforts. Monitoring included attending

planning meetings with the contractors, obtaining periodic financial status

reports, and reviewing and approving all Campaign expenditures. In

August 1998, ONDCP hired a new staff member to oversee certain

contracting and financial activities of the Campaign, particularly the paid

advertising contracts. Among other duties, his responsibilities included (1)

working with the contract support personnel to ensure, for example, that

the contract modifications and audits were appropriate;11 (2) working with

the contractors to ensure proper billings; and (3) reviewing and approving

all paid advertising expenditures (i.e., contractor invoices) for cost

reasonableness, allowability, and support. Also, in August 1998, ONDCP

entered into a contract with an accounting firm12 to acquire additional

financial management support. The accounting firm is to review the

support for advertising invoices submitted by the contractors, such as

11 For the phase II contract with Bates and the phase III contract with Oglivy and Mather, these duties

included acting as the Contracting Officer’s Representative (COR) of record. For phase I, DOD

maintained COR responsibilities, but under its interagency agreement, ONDCP still approved all

invoices before payment and made recommendations to the COR regarding other issues related to the

Campaign task order.

12 Cox and Associates, CPAs, P.C.

Figure 2.1: Media Campaign Costs

Associated With Paid Advertising, as of

September 30, 1999
Chapter 2

ONDCP Generally Provided Timely Financial Reports and Obligated Funds in Accordance

With Selected Statutory Restrictions

Page 38 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

media vendor billings, and make recommendations to ONDCP regarding

payment approval.13

For each phase of the Campaign, ONDCP’s advertising contractors used a

private-sector, on-line accounting and account management system to

produce the invoices sent to ONDCP for the Campaign. The on-line system

supports various aspects of the Campaign, including planning, purchasing,

and billing, and is used as the basis for the contractors’ invoices that are

sent to ONDCP. According to advertising contractor officials, this

accounting and account management system is generally accepted by the

advertising industry and used by most large advertising firms in the United

States.

In addition to the invoice review support provided by the accounting firm,

in March 1999, HHS’ Program Support Center contracted, on behalf of

ONDCP, with the Ad Council to assist ONDCP in reviewing invoices for

producing new advertisements, among other tasks. Subsequently, ONDCP

adopted a review process for new advertisement production in which

ONDCP must approve all invoices on the basis of recommendations for

payment by the Ad Council and its subcontractor, which are to review

each new advertisement production invoice for cost reasonableness,

allowability, and support.

ONDCP officials are responsible for recommending the payment or

nonpayment of all invoices to HHS.14 After obtaining recommendations

regarding payment from the accounting firm and/or the Ad Council, an

ONDCP official is to review the completed work and, as necessary,

independently review the underlying support. For example, an ONDCP

official is to review all of the support provided for the contractor’s labor

and out-of-pocket15 billings. The ONDCP official also reviews the invoice

for cost reasonableness and allowability before recommending payment or

nonpayment. Once HHS approves payment, the invoices are to be paid,

and ultimately, paid advertising expenditures are to be reported to

Congress as part of ONDCP’s monthly cumulative financial reports.

13 As part of its review procedures, the accounting firm also is to verify the invoice totals, check for

duplicate billings on previous invoices, and verify that the dates of service coincide with the contract

effective dates, among other actions.

14 Per contractual requirements, all invoice payments are provisional until final payment is made under

the contract, since payments are subject to later audit. Thus, for example, until the contract is closed,

each payment is subject to possible adjustments if additional information indicates that the initial

payment was incorrect.

15 According to an ONDCP official, out-of-pocket costs include media production, tracking, and

evaluation.
Chapter 2

ONDCP Generally Provided Timely Financial Reports and Obligated Funds in Accordance

With Selected Statutory Restrictions

Page 39 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

To further assist ONDCP in tracking and categorizing detailed Campaign

expenditure information, among other data, ONDCP directed the

accounting firm to establish and implement a Campaign tracking system

that is based on requirements created by ONDCP. ONDCP remained

involved throughout the system’s development, testing, and

implementation, according to ONDCP officials, to ensure that the system

met ONDCP’s objectives. According to ONDCP and accounting firm

officials, the financial management application of the system includes data

on all paid advertising expenditures to date, for all three phases of the

Campaign. The system is capable of providing reports on paid

advertisement expenditures by numerous spending categories, including

the type of spending (e.g., media purchases, media production, and labor);

type of media purchased (e.g., radio, television, newspaper, magazine, and

the Internet); and geographic location of advertising placements, among

others. Accounting firm officials are to use the system to assist them with

their review of contractor invoices. As a result, the data in the system are

based on the advertising contractors’ Campaign invoices and supporting

documentation (e.g., media vendor billings). At the time of our review, the

system was being used to process paid advertising invoices.

Congress established statutory spending restrictions limiting ONDCP from

obligating Campaign funds until certain conditions were met. Our review

of supporting documentation and discussions with agency officials showed

that these funds were obligated in accordance with selected statutory

spending restrictions for fiscal years 1998 and 1999.16

The Treasury and General Government Appropriations Act of 1998

prohibited the obligation of Campaign funds before the ONDCP Director’s

submitting a Campaign strategy for approval to the Appropriations

Committees and the Senate Judiciary Committee. The act further

prohibited the obligation of $17 million before September 30, 1998. ONDCP

financial and contract management officials stated that they monitored the

obligation of Campaign funds to ensure compliance with these restrictions.

In November 1997, ONDCP submitted a Campaign strategy to the

Committees,17 and by December 10, 1997, ONDCP had received approval to

begin obligating Campaign funds. On the basis of the Campaign contracts

16 We did not review documentation supporting 100 percent of the appropriations for fiscal years 1998

and 1999. For fiscal year 1998, we reviewed documentation that represented 91 percent of the

appropriation available for obligation; for fiscal year 1999, we reviewed documentation that

represented 94 percent of the appropriation. Also, we did not review all statutory spending restrictions

(see Objectives, Scope, and Methodology section in ch. 1).

17 Subsequently, ONDCP submitted additional information to the Committees regarding its

development of certain guidelines related to this statutory provision.

ONDCP Obligated

Funds in Compliance

With Selected

Statutory Spending

Restrictions
Chapter 2

ONDCP Generally Provided Timely Financial Reports and Obligated Funds in Accordance

With Selected Statutory Restrictions

Page 40 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

and other obligating documents we reviewed, which represented 91

percent of the 1998 Campaign appropriation available for obligation,18 the

first obligation for $14 million was incurred on December 18, 1997,

following ONDCP’s submission to the required Committees and its

subsequent receipt of approval to begin obligations. Further, OMB did not

apportion $17 million of the Campaign’s appropriation to ONDCP for

obligation until after the end of fiscal year 1998 to ensure compliance with

the statutory provision.19

The Treasury and General Government Appropriations Act of 1999

required that (1) no Campaign funds be obligated before ONDCP’s

submitting a report on the evaluation and results of phase I of the

Campaign to the Appropriations Committees and (2) not more than 75

percent of the Campaign funds be obligated before submission of a report

on the evaluation and results of phase II. ONDCP financial and contract

management officials stated that they monitored the obligation of

Campaign funds to ensure compliance with these restrictions. ONDCP

submitted a phase I evaluation report to the Appropriations Committees

on October 1, 1998,20 and the phase II report on May 7, 1999. Our review of

Campaign contracts and other obligating documents, representing 94

percent of the 1999 Campaign appropriation, indicated that ONDCP

complied with these restrictions. On the basis of our analysis, ONDCP

incurred its first Campaign obligation on October 22, 1998, and, as of May

7, 1999, had incurred obligations representing about 74 percent of its fiscal

year 1999 appropriation.21

The Treasury and General Government Appropriations Act of 2000

required that 10 percent of Campaign funds not be available for obligation

before ONDCP’s submitting a corporate sponsorship plan to the

Appropriations Committees.22 As with previous statutory spending

restrictions, ONDCP contract and financial officials said that they would

monitor compliance with this restriction to ensure that obligations

18 We reviewed documents representing 91 percent of the $178 million available for obligation.

Although Congress appropriated $195 million for fiscal year 1998, $17 million was unavailable for

obligation until September 30, 1999.

19 Apportionment is the action by which OMB distributes amounts available for obligation in an

appropriation or fund account. The amounts apportioned limit the amount of obligations that may be

incurred.

20 ONDCP submitted a final phase I evaluation report in March 1999.

21 ONDCP’s Campaign had a remaining available balance of about $24 million from its fiscal year 1998

appropriations. Thus, fiscal year 1999 obligations were initially offset by this amount.

22 Public Law 106-58, 113 Stat. 447, 449 (1999).
Chapter 2

ONDCP Generally Provided Timely Financial Reports and Obligated Funds in Accordance

With Selected Statutory Restrictions

Page 41 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

occurred in accordance with the statutory requirements. ONDCP’s plan to

secure private sector contributions, including corporate sponsorship, is

still under development. (See ch. 3 of this report for details regarding the

status of ONDCP’s efforts.)

In response to statutory requirements, since May 1998, ONDCP generally

provided timely written financial status reports to Congress on cumulative

Media Campaign obligations and expenditures during fiscal years 1998 and

1999. ONDCP also established processes to approve and monitor paid

advertisement spending, which represented about 84 percent of the total

expenditures for fiscal years 1998 and 1999 reported by ONDCP. Further,

ONDCP complied with selected statutory spending restrictions limiting the

obligation of fiscal years 1998 and 1999 funds until certain conditions were

met.

In its written comments on a draft of this report, ONDCP indicated its

agreement with our findings and conclusions in this chapter and did not

raise any issues or concerns. ONDCP also stated that we could have placed

greater emphasis on ONDCP’s ability to meet statutory requirements given

the scope and complexity of the Campaign; the speed with which it was

implemented; and the multitude of contracting, legal, and other issues

involved.

In commenting on our findings and conclusions, ONDCP inferred that we

conducted a financial audit. ONDCP added that while it retained outside

administrative contract support, internal controls allowed it to monitor

expenditures and control payments. We want to emphasize that we did not

conduct a financial audit of the Campaign’s fiscal operations or review the

related internal controls. Also, we did not conduct a contract management

audit or review how the internal controls were applied during the contract

administration process. Rather, the scope of our work was restricted to (1)

reviewing the timeliness of ONDCP’s financial reporting, (2) determining

how funds for paid advertising were managed and disbursed, and (3)

reviewing ONDCP’s compliance with selected statutory requirements

regarding the obligation of funds.

Conclusions

Agency Comments and

Our Evaluation
Chapter 3

ONDCP’s Compliance With Statutory Program

Requirements Has Been Mixed

Page 42 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

ONDCP’s success in meeting the congressionally mandated program

requirements was mixed. The match program, which was developed early

on to meet the congressional requirement that ONDCP supplement

existing public service announcements (PSA), resulted in over 265,000 pro

bono or match PSAs, valued at approximately $148 million and benefiting

45 organizations as of the time of our review.1However, ONDCP may not

be able to fully meet the congressional direction that it obtain a pro bono

match as a part of each buy from every vendor. This requirement was

imposed after the development of the match program. ONDCP and the Ad

Council also developed guidelines to determine the organizations that

could receive the matches.

According to ONDCP, its work to supplement community anti-drug

coalitions was somewhat limited during the first two phases of the

Campaign due to ONDCP’s need to focus on planning and executing the

paid advertising Campaign. However, ONDCP and its contractors planned

and/or instituted numerous initiatives to work with coalitions for phase III.

ONDCP does not yet have the congressionally required private sector

contributions plan in place. It had anticipated having a plan in place by

October 2000, as of the date of our review, but had fallen behind in

meeting the schedule necessary to complete work by that date. ONDCP

officials said that, even when a plan is in place, ONDCP may not be able to

meet the congressionally mandated levels of contributions.

Finally, to meet congressional requirements, ONDCP and PDFA have (1)

developed a policy and guidance prohibiting advertisements that feature

political figures or partisan purposes and (2) established an advertisement

review process. However, ONDCP had no internal controls requiring that

the reviews be documented.

1 Phase I data are not included because matches were used solely for the Campaign during phase I.
Chapter 3

ONDCP’s Compliance With Statutory Program Requirements Has Been Mixed

Page 43 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

Congress directed ONDCP to develop guidelines to ensure that Campaign

funds supplement and not supplant current PSAs that are donated by

national and local broadcasting networks. ONDCP was also required to

develop a detailed plan regarding the qualifications necessary for an

organization, entity, or individual to receive this free broadcast time. To

comply with these requirements, ONDCP; its advertising contractors; the

Ad Council; and PDFA developed a match program during phase I of the

Campaign, including criteria for receipt of the match. In general, ONDCP

requires that every time the advertising contractors purchase time or

space, the media vendor must provide (1) an equivalent amount of free

public service time or space or (2) an equivalent in-kind contribution. The

program includes not only broadcast media—national and local television,

radio, and cable—but also newspapers, magazines, outdoor media (such as

billboards), the Internet, in-school media, and cinema/video arcades.

The ONDCP guidelines stating that advertising time or space will not be

purchased without the provision of matching (i.e., free) time or space are

reflected in negotiating directions that ONDCP gave its advertising

contractors.2

The contractors are to request, when negotiations for the

paid time or space occur, that the media vendors match ONDCP’s

purchase of time or space, dollar-for-dollar with nonpaid advertisements

or in-kind contributions of the same value. ONDCP’s advertising

contractors are also responsible for ensuring that the match time or space

has been provided. The media vendor is to be paid only after the paid

advertisement and its match have been broadcasted or printed.

Though individual media vendors decide how to meet the requirement,

ONDCP’s goal is that the majority of the matches must be in the form of

equivalent time or space, known as “hard matches.” For broadcast media,

the match might be 30 seconds of time given for a purchase of 30 seconds

of time, in a comparable time slot or location. For print media, a hard

match could be a free page of advertisement for a paid page.

In addition to hard matches, media vendors may provide “soft matches,”

which include complementary in-kind contributions, such as programming;

locally or nationally sponsored community anti-drug events; in-school

programs; radio interviews; and public affairs programming. A

programming soft match might be an anti-drug or alcohol message written

into a television show, thus adding to the total amount of available antidrug or alcohol messages.

2

Bates was the contractor for phases I and II, and Zenith was a subcontractor to Bates. Ogilvy and

Mather is the phase III contractor.

Match Program

Developed to Meet

Requirements

Regarding Existing

PSAs and

Qualifications of

Recipient

Organizations

Contractor Responsibilities

and Type, Valuation, and

Number of Matches
Chapter 3

ONDCP’s Compliance With Statutory Program Requirements Has Been Mixed

Page 44 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

ONDCP requires its advertising contractors to document the value of the

matches in conjunction with documentation verifying the paid time or

space. Hard matches are given the same value as the purchased time or

space. For example, 30 seconds provided as a match is valued the same as

the paid 30 seconds. According to ONDCP and contractor officials, the

valuation of soft matches was new to them and the industry and, as a

result, their valuation estimates were very conservative. For example,

programming (e.g., story lines and interviews) was valued using a formula

that is based on the requirements for a product advertiser to officially

sponsor a show. An advertiser officially sponsors a half-hour show when it

purchases three 30-second advertisements. As a result, if the theme of a

half-hour show was consistent with the Campaign’s strategy and

dominated the content of the program, the contractor was to allow credit

for three 30-second advertisements. Using a less conservative approach,

the contractor could have given credit for the full 30 minutes.

Because the valuation of soft matches and other nonmonetary

contributions to the Campaign is new to ONDCP and its contractors, and

to ensure use of the best system possible, ONDCP is in the process of

securing a contractor to assist in the development of a valuation system.

Table 3.1 shows the number of hard and soft matches obtained by ONDCP

contractors through December 1999, their dollar value, and the percentage

dollar distribution of the hard matches compared with the soft matches.

Hard matches Soft matches Percentage

Number Value Number Value

Total

dollars Hard value Soft value

Phase I

Bates and ZenithaNAb$19,000,000 NAb$297,600 $19,297,600 98% 2%

Phase II

Batesc 339,712 45,773,000 717 2,816,000 48,589,000 94 6

Zenithd154,679 83,190,049 NAb19,757,756 102,947,805 81 19

Phase III

Ogilvy and Matherc 137,985 34,620,960 NAb 4,721,040 39,342,000 88 12

Ogilvy and Matherd110,707 65,142,805 NAb15,127,437 80,270,242 81 19

Total 743,083 $247,726,814 717 $42,719,833 $290,446,647 85% 15%

a

All media types, both general and ethnic markets.

b

Contractor data were not available.

c

Newspapers, magazines, outdoor media, cinema/video arcades, in-school media, the Internet, and

ethnic market.

d

National and local general market television, radio, and cable.

Source: Contractor data.

Table 3.1: Number of Matches, Dollar Values, and Dollar Percentages, Hard and Soft, Through December 1999
Chapter 3

ONDCP’s Compliance With Statutory Program Requirements Has Been Mixed

Page 45 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

As shown in table 3.1, the total number of hard and soft matches is

understated because these data were not available from the contractor.

However, the values of hard and soft matches, as determined by the

contractor, are known. The number of hard matches acquired during phase

I was not available because, at that time, the contractor and subcontractor

did not count the individual hard matches. The value of hard matches does

include phase I since the contractor and subcontractor kept financial

records to ensure that they received a dollar-for-dollar match rate. The

total number of soft matches acquired during phases I, II, and III was not

available because the contractor and subcontractor did not count the

individual soft matches during phase I, the subcontractor did not count

these matches during phase II, and the contractor did not count them

during phase III. However, the value of soft matches does include all

phases since the contractors and subcontractor kept financial records to

ensure that they received a dollar-for-dollar match rate.

ONDCP and the Ad Council developed criteria to determine which

organizations and PSAs could qualify for receipt of the national television,

radio, and cable match time. The Ad Council serves as a clearinghouse at

the national level. Nonprofit organizations and government agencies are to

submit applications to the Ad Council on an ongoing basis for participation

in the match program. Television, radio, cable, and some Internet banner

advertisement matches are available for the use of qualifying

organizations. To qualify, organizations and their campaigns must meet the

following criteria:

• the campaign must be sponsored by a legally recognized, nonprofit

organization or government agency;

• nonprofit organizations should be in compliance with guidelines of the

Council of Better Business Bureaus’ Philanthropic Advisory Service or

those of the National Charities Information Bureau and must provide

ONDCP with proof of their tax-exempt status;

• PSAs created by the media are eligible only if cosponsored by a nonprofit

organization;

• messages must directly benefit the cause of a nonprofit or government

agency; and

• messages with commercial benefit or commercial advertiser identification

are not eligible.

Qualifications Necessary to

Receive Match Time or

Space
Chapter 3

ONDCP’s Compliance With Statutory Program Requirements Has Been Mixed

Page 46 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

Eligible messages include those that accomplish the following:

• educate and support the development of good parenting practices;

• encourage greater parental and caregiver involvement in a child’s

upbringing and promote effective drug prevention parenting strategies;

• foster high expectations and self-esteem for youth;

• discourage drug abuse, including underage tobacco and alcohol use; and

• emphasize the connection between drugs and crime and violence.

The messages must also be nondenominational, noncommercial, and

politically nonpartisan. They cannot be designed to influence specific

legislation or feature elected officials. Finally, the advertisements are to be

screened to ensure acceptable creative and technical quality.

The Ad Council processes the applications and then forwards them to the

Media Match Task Force for final decision. The task force consists of

representatives from ONDCP, the Ad Council, PDFA, HHS, the Department

of Justice, and the Department of Education. The task force reviews

applications on a quarterly basis and has met seven times to make the final

decisions and discuss the match program, including possible modifications

to the ongoing effort.

After the task force approves the organizations and advertisements,

ONDCP’s advertising contractor encodes the television and radio PSAs on

a master reel that is reproduced and distributed to the media vendors on a

quarterly basis. National broadcast media vendors then choose from

among the advertisements on the reel to satisfy their agreed-upon hard

match requirement and concentrate their efforts on issues, organizations,

and target audiences that best fit their public affairs priorities.

As of the time of our review, 45 organizations had received the broadcast

time provided through the match program, including America’s Promise,

Boys Town USA, the Center for Substance Abuse Treatment, Connect for

Kids, the Harvard Mentoring Project, Mothers Against Drunk Driving, and

the National 4-H Council.

The American Advertising Federation (AAF) performs the clearinghouse

function for local-level organizations that could use the local television,

radio, and cable matches. The guidelines are the same as those used by the

Ad Council. AAF reviews submissions through local review panels that

usually meet quarterly; AAF’s goal is to establish these panels in each of

the 102 media markets. As of the time of our review, panels had been

established in 74 markets. The review panels usually consist of three to six
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members that are drawn from the AAF advertising clubs and federations,

plus a representative of the National Association of State Alcohol and Drug

Abuse Directors (NASADAD). Members of NASADAD are included

because of their technical expertise in drug prevention messages. PSAs

approved by the review panels are forwarded to AAF, which then forwards

the PSAs to ONDCP’s advertising contractor. The contractor prepares the

reel to be provided to local broadcasters. AAF officials said that, as of the

end of 1999, review panels had approved 117 PSAs from 8 local markets.3

According to ONDCP and its contractors, the Campaign has exceeded its

goal of a dollar-for-dollar match. As of September 9, 1999, ONDCP’s

contractors reported an overall rate of match-to-paid value of 108 percent.

To test the accuracy of these reported data, we examined media vendor

documentation, including invoices; insertion orders; vendor agreements;

and brand/time schedules, in the offices of Bates and Zenith. (See pp. 30

and 31 of this report for details.) In comparing this documentation with

data reported by the contractors and ONDCP, we found very few errors.

Three percent of Bates’ and 2 percent of Zenith’s database records were in

error by at least $100.4 On the basis of our review and analysis, we can

estimate with 95-percent confidence that both contractors received at least

a 100-percent rate of match-to-paid value. Specifically, we estimate that

Zenith procured a match rate in a range of 105 to 125 percent and that

Bates procured a rate in the range of 100 to 104 percent.

By requiring ONDCP to supplement and not supplant current PSA levels,

Congress expressed concern that the Campaign’s advertisements should

not result in the loss of PSA opportunities for other organizations.

According to officials at the Ad Council, some available evidence suggests

that there has been a recent increase in overall broadcast PSA levels.

However, to the extent there has been an increase, there is no clear

quantitative evidence to attribute it to the match program.

Neither ONDCP nor the Ad Council had baseline data on levels of all PSA

activity before the Campaign. We were told that no organization tracks all

PSA activity, which would include the campaigns of local, regional, and

national nonprofit organizations and local and national governments. As a

3

Before AAF’s participation, PSAs approved for the national level were provided for use by local

television, radio, and cable. National broadcast PSAs are still used in markets where local PSAs are not

available.

4

The 95-percent confidence interval for the estimated error rate in the Bates database was 1 to 7

percent of records; the 95-percent confidence interval for the estimated error rate in the Zenith

database was from less than 1 to 8 percent.

Contractors Obtained at

Least a Dollar-for-Dollar

Match

Effect of the Match

Program on PSA Levels Was

Not Clear
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result, ONDCP and contractor officials were unable to provide clear

quantitative evidence that PSA levels had increased since the inception of

the Campaign.

ONDCP expressed the intent, through its match program guidelines, that

media vendors should not reduce support of Ad Council or other public

service campaigns to generate the match PSA; these contributions were to

be in addition to existing PSAs. We were told that at the time of

negotiations, the contractors’ buyers were to convey this information to

each media vendor from which they made a purchase. The vendors

provided assurances to the buyers that their existing support of PSAs

would not change.

Overall, Ad Council officials believed that broadcasts of its PSAs had

increased since the beginning of the Campaign.5

As of the date of our

review, the Ad Council managed about 30 active national public service

campaigns. Ad Council officials believed these campaigns represented

about 20 to 25 percent of all PSA activity. According to a Senior Vice

President of the Ad Council, Ad Council PSAs increased by 21 percent

from 1997 to 1998. Of this increase, about 9 percent could be attributed to

advertisements used by organizations that received match time; the

remaining 12 percent were Ad Council advertisements that were not a part

of the match program.

Ad Council officials also provided numerous letters from organizations

whose PSAs were aired through the match program. These organizations

all reported increased exposure of their PSAs, and many reported an

increase in calls to their hotline numbers.

Ad Council officials said that they were skeptical at first regarding the

match program component of the Campaign. They were not sure if the

program would work or if it would benefit organizations in need of free

broadcast time. However, from their experiences to date, these officials

expressed satisfaction with the program and the efforts of ONDCP and its

contractors to increase the overall level of PSAs. According to these

officials, ONDCP listened to their concerns and those of other

organizations and designed a fair program that is intended to assist them

and others with their PSA efforts. These officials were also pleased about

the placement of the PSAs in desirable times that its organizations had not

seen in years.

5 The figures provided by the Ad Council reflect activity from 1997 to 1998.
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Data compiled in the 1999 annual report produced by the American

Association of Advertising Agencies and the Association of National

Advertisers, Inc., have been cited by the Ad Council as evidence of an

increase in prime-time broadcast PSAs. 6

We reviewed the annual report

and found no clear pattern of an increase in broadcast PSAs across

programming times, networks, or broadcast media types. In response to

our questions, an Ad Council official stated that although the data

provided some evidence that network PSAs increased in November 1998,

the report does not provide a firm quantitative basis for determining

whether an increase had occurred or, if so, whether and how much the

increase was attributable to the Campaign.

In the fiscal year 1999 appropriation bill, Congress required that ONDCP

obtain a match up front as part of the media buy from each seller of

advertisement time and space. This specific language was not included in

the fiscal year 2000 appropriation bill, but support for this requirement was

reiterated in the conference report.7 In a few instances, however, ONDCP

and its advertising contractors have been unable to secure a match. In

most of these instances, the contractors stopped the negotiations and did

not make a media buy; in others, due to the advertising Campaign’s need to

meet its reach and frequency goals, a buy was made without the required

match.8

According to an official at Ogilvy and Mather, ONDCP and its advertising

contractors developed the Campaign’s reach and frequency goals. He

explained that, as in any advertising campaign, the goals are based on the

belief that this specific level of reach and frequency is necessary to achieve

the attitude and behavioral changes the Campaign is seeking to bring

about. He also said that if these goals are not met, the Campaign will be

unable to achieve its ultimate aims.

According to the contractors, time and space were purchased from 2,991

media vendors9

during the period covering June 29, 1998, to December 31,

1999. In 15 instances, vendors did not provide a match. In 3 of these 15

instances, after a buy was made for the Campaign, the vendor

6

‘98 Television Commercial Monitoring Report, American Association of Advertising Agencies and

Association of National Advertisers, Inc. (1999).

7

H.R. Conf. Rep. No. 105-825 at 74. (1999).

8

The overall match rate still exceeded 100 percent because some media vendors provided a match in

excess of dollar-for-dollar.

9

This number (2,991) includes overlap between vendors used by the phases I and II contractor and the

phase III contractor.

Need to Attain Campaign’s

Reach and Frequency Goals

Can Conflict With

Congressional Direction

Regarding the Match

Program
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reconsidered and provided a match. According to the contractors, in an

additional 193 instances, vendors were unwilling or unable to provide a

match; therefore, the contractors did not purchase from these vendors.

From our assessment of the information provided to us, we determined

that neither ONDCP nor its contractors maintained systematic records of

these instances.

ONDCP and contractor officials emphasized that their goal, in keeping

with ONDCP guidelines and the congressional direction, is to achieve a

dollar-for-dollar match in every instance. However, they explained that,

due to the need to achieve the Campaign’s reach and frequency goals, they

would likely continue to encounter instances in which a buy must be made

without the benefit of a match. For example, the officials explained that to

reach a particular segment of the target audience in a particular market, it

might be necessary to purchase airtime from a small radio station that is

unwilling or financially unable to provide it for free. Other vendors might

be unwilling to provide free time because, due to the strong economy, they

are able to sell all of their inventory. An official at Zenith emphasized that

attaining the match goal is important; however, if the reach and frequency

goals of the Campaign are to be met, ONDCP and its contractors need

flexibility in instances in which the vendor does not provide a match.

According to an official at Bates, they were occasionally unable to get a

full dollar-for-dollar match for certain media types. For example, there is a

very limited inventory of “out-of-home” advertising space, such as exterior

transit (panels on buses). As a result, Bates could not get a 100-percent

match for this form of media. However, because the medium represented

an important part of the media plan, Bates purchased the space needed to

meet the Campaign’s reach and frequency goals, even though the vendors

provided only about a 75-percent match.

Advertising contractors raised concerns about the future viability of the

match program and spoke of the following three barriers to the indefinite

continuation of the program, particularly if they are required to obtain a

match from every vendor:

• Media vendors have been influenced by the amount of funding available

for the purchase of time and space and, as a result, are more motivated to

provide the match. If ONDCP’s funding for the program decreased, and

smaller purchases were made, the vendors might balk at providing free

inventory.

• If campaigns relating to other issues (e.g., alcohol or tobacco) begin

requesting matches, the vendors might begin to be selective about their
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participation because they might not be able to participate in all

campaigns.

• The advertising market is in good shape now and stations are able to sell

most of their inventory. If this continues, or if the stations are able to sell

their entire inventory, the amount available for the match program could

potentially be reduced.

Congress directed ONDCP to develop guidelines to ensure that Campaign

funds supplement and not supplant current anti-drug community-based

coalitions.10 Guidelines were forwarded to Congress in November 1997.

However, according to ONDCP, because the primary focus of the first two

phases of the Campaign was on paid advertising, which is one of the six

Campaign “components,” less time was devoted to the other components,

including work with community anti-drug coalitions. 11 Most of ONDCP’s

time was directed at getting the paid advertising out in the 12 pilot cities

and then expanding the advertising effort nationally. According to the

Director of the Campaign, the advertising focus, along with the speed with

which the Campaign was rolled out, precluded a lot of work with

community groups in phases I and II of the Campaign. According to

ONDCP, phase III will provide the opportunity to fully develop and

implement the various nonadvertising aspects of the Campaign, including

partnerships with community anti-drug coalitions.

ONDCP officials said they made several efforts during phase I to work

with anti-drug coalitions or community groups. During phase I, the

Community Anti-Drug Coalitions of America (CADCA) prepared a tool kit

for ONDCP. This hands-on marketing guide for community coalitions

introduced the Campaign and explained how the local coalitions could use

the Campaign to further their own goals. A Campaign video was also

prepared for the launch in the 12 pilot cities, and ONDCP met with various

statewide groups to explain how the Campaign could benefit their efforts.

The Campaign’s director held one-on-one and conference telephone calls

with community groups and coalitions; ONDCP also held national

teleconferences with local elected officials. In choosing what groups or

organizations to contact, ONDCP used the databases maintained by

CADCA and NASADAD.

10 ONDCP describes community anti-drug coalitions as anti-drug groups that operate in communities

and span or include many and diverse institutions, such as prevention and treatment programs, police,

social services, businesses, and schools.

11 The Campaign components are as follows: paid advertising; interactive media; entertainment industry

outreach; public information; partnerships (national and community organizations and coalitions); and

corporate involvement, sponsorship, and participation.

Campaign’s Efforts

With Community AntiDrug Coalitions Have

Increased Over Time

Efforts in Phases I and II

Were Limited
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In addition, in phases I and II, ONDCP provided assistance to help local

coalitions capitalize on the increased visibility of drug issues within their

communities. According to an ONDCP official, ONDCP provided training

to the coalitions on how to get news coverage; improve public

understanding of the importance of prevention efforts; and generate a

range of collaborative anti-drug activities with businesses and schools and

community, civic, and other local organizations. ONDCP also coordinated

a Campaign launch satellite broadcast through CADCA and the National

Guard.

Throughout the Campaign, ONDCP attempted to “tag” local

advertisements, when appropriate, with the names and telephone numbers

of community anti-drug coalitions. However, during the first two phases of

the Campaign, ONDCP was not always able to tag advertisements, because

the Campaign used off-the-shelf PDFA advertisements that would have

required difficult and time-consuming modifications. According to an

ONDCP official, the local organizations whose telephone numbers were

featured in print advertisement tags provided very positive feedback

regarding the response they received from callers who had seen the

advertisements.

Formal ONDCP policy regarding the use of tags went into effect in

December 1999. To qualify, the organizations whose telephone numbers

are used must have the following:

• governmental or nonprofit status;

• a live voice or voice mail to answer calls with a capacity to return calls

within 24 hours;

• E-mail and Internet access;

• the capacity to refer calls to youth and adult treatment providers and

prevention programs specific to middle school youth and parents, as

requested; and

• the capacity to mail, fax, or E-mail materials without cost to the caller.

According to an ONDCP official, tags are to be placed on all parent

advertisements. Youth advertisements will feature tags selectively because

young people have been shown to be much less likely to call in response to

a tag. All local newspaper and some local billboard and local broadcast

advertisements during phase III of the Campaign will be tagged.
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ONDCP has increased its involvement with community anti-drug coalitions

in phase III of the Campaign. ONDCP entered into a contract with

Fleishman-Hillard, Inc., to implement four of the five nonadvertising

components of phase III—interactive, public information, entertainment

industry outreach, and partnerships. ONDCP’s efforts with community

anti-drug coalitions are a primary focus of Fleishman-Hillard’s work with

partnerships.

Fleishman-Hillard officials explained that there are three types of activities

that ONDCP undertakes with partners: (1) using the partners’ resources;

(2) using the partners’ communication networks to spread the Campaign’s

message; and (3) tailoring ONDCP programs to the organization’s mission,

to the extent that its mission overlaps that of the Campaign.

Fleishman-Hillard officials provided the following examples of these

activities:

• using the National Education Association’s school-oriented materials to

further the Campaign’s goals,

• using the YMCA’s resources and communication structures,

• assisting the YMCA with the curriculum of its after-school programs and

training its directors to work with or teach children the Campaign’s

message.

ONDCP and Fleishman-Hillard are now working with numerous

organizations, including national organizations such as the YMCA, to

strengthen anti-drug efforts at the local level. These organizations and

other partnerships with community groups are displayed in table 3.2. In

addition, Fleishman-Hillard has entered into discussions with many other

organizations in the 102 media markets.

Greater Emphasis on

Community Partnerships in

Phase III
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Organization/Community group Project Description of actions being taken

AmeriCorps Training program Proposal in development for a “training the trainers” program to

work with project leaders on substance abuse and the linking of

community service projects to drug prevention.

Boys and Girls Clubs of America In development In discussion to explore potential partnership opportunities.

Cable in the Classroom (CiC) Link with the National

Future Farmers of

America (FFA) program

The Campaign is working with CiC to share production expertise

and resources with FFA members as they develop submissions

for the Campaign PSA contest. ONDCP has also partnered with

CiC to produce a series of four short videos for teachers

demonstrating how to incorporate subjects like drug use and

violence into existing curricula on other subjects.

Community Anti-Drug Coalitions

of America (CADCA)

3-in-3 soccer program,

leadership forum

In partnership with CADCA, the Campaign launched a series of

interactive satellite programs on Campaign themes that were

down-linked to about 250 CADCA sites across the country. The

Campaign also participated in CADCA’s National Leadership

Forum in December 1999.

Community groups Campaign Update

Newsletter

The Campaign produces a stakeholder newsletter

approximately four times a year that highlights programs and

opportunities across the country.

Community groups Media tool kit for

community action

The Campaign developed materials for kits for national, state,

and local levels to help partners carry out training and

awareness-building activities to extend the Campaign’s impact.

Community groups Campaign brochure The Campaign produces a brochure that highlights all of the

components of the Campaign and its programs and

opportunities.

Community groups Broadcast E-mail The Campaign alerts stakeholders to time-sensitive

opportunities via a broadcast E-mail system. The database

currently has more than 45,000 entries.

ESPN and community groups X Games The Campaign partnered with ESPN, through a pro bono match

opportunity, to be a sponsor at the X Games in San Francisco;

11 local partner organizations were enrolled to participate.

Girl Scouts Various The Campaign is working with the Girl Scouts on the creation of

badge and patch programs for all levels of girl scouts.

Hepatitis Foundation

International and community

groups

Let’s Kick Hepatitis

Challenge!

The Campaign hosted an exhibit and provided Campaign

resource materials at this event in Atlanta in November 1999.

Following the event, the Campaign also provided additional

material for follow-up packets that were sent to all middle-school

students in the Atlanta area.

National Association of Partners

in Education

Conference presentation The Campaign made a conference presentation, “Student

Success: The Business of Partnerships,” in November 1999.

National Association of State

Alcohol and Drug Abuse

Directors (NASADAD)

Local match task forces The Campaign has engaged NASADAD and its affiliate, the

National Prevention Network (NPN) by including a NASADAD

member on each of the local match review panels; promoting

the Campaign to state and local NASADAD and NPN

constituents; establishing a mechanism for providing information

from ONDCP to NASADAD and NPN membership; and

establishing a mechanism for providing feedback from

NASADAD/NPN members to ONDCP.

National Council of La Raza In development In discussion to explore potential partnership opportunities.

Table 3.2: Partnership Activities as of March 2000
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Organization/Community group Project Description of actions being taken

National Drug Prevention League

(NDPL)

Media market mapping The Campaign has identified capacities of community-level,

drug prevention, and civic organizations in each local media

market working through the 25 largest members of NDPL and

their community affiliates.

National Education Association

(NEA)

Education program The Campaign is collaborating with NEA on such things as Web

resources, media literacy initiatives, and the integration of a

drug component for its parenting skills workshop program.

National Future Farmers of

America

Youth-to-youth education The Campaign has partnered with FFA to create a peer-to-peer

PSA contest for FFA’s 450,000 members. The contest was

launched in October 1999. The Campaign created a Web

resource area for FFA on Campaign themes.

The National Guard, Sun

Microsystems, Inc., Open Voice,

Forever Young Foundation,

CADCA

Straight Scoop News

Bureau

The October 1999 launch events included an on-line chat and

live videoconference. Viewer reach was over 5 million with

participation from, among others, 2,700 schools and 56 school

districts.

The New York Times Educator guide The Campaign is working with the paper’s Newspaper in

Education Program and released an updated educator’s tool,

“Anti-Drug Education With The New York Times,” in November

1999.

Prevention Through Service

Alliance (PTSA)

Civic alliance The Campaign is creating and packaging materials for and Web

resources with the civic organizations of PTSA, whose 47

umbrella members include Big Brothers Big Sisters of America,

National 4-H Council, Girl Scouts, 100 Black Men of America,

and dozens of other community organizations. ONDCP and

PDFA are also creating advertisements specifically tailored for

the magazines of 37 civic, fraternal, and service organizations.

A recognition program for these organizations supporting youth

activities is also being developed.

Society for Human Resource

Management (SHRM)

Outreach program Discussion groups were held with SHRM members to gather

information about working with the human resource community

to provide anti-drug information to parents through workplace

communication channels.

USA Today Family and education

program

The Campaign is working with the USA Today Family and

Education program, the National Association of Student

Assistance Professionals, and the National Middle School

Association on the production of a print insert on Campaign

themes.

Various Freevibe The Campaign developed this Web site for middle-school

children. The Web site has extensive drug information and links.

An on-line guide for teachers is also available.

YMCA of the USA Resources, training, and

after-school program

The Campaign is collaborating with the YMCA on the launch of

its “City Agenda,” which includes an after-school program for

middle-school students. Contributions include assisting with

curriculum development, training of YMCA center directors, and

creating Internet and Intranet resources for members and teen

staff on Campaign themes.

Youth Service America (YSA) Community fairs, Web

resource development

The Campaign is working with YSA to create 35 National Youth

Service Day programs around the country highlighting

volunteerism as a drug prevention intervention. Web resources

are in development to take advantage of YSA’s youth

volunteerism opportunities across the country.

Source: Fleishman-Hillard, Inc., and ONDCP.
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Fleishman-Hillard has also developed a Media Tool Kit for Community

Action. The kit will be given to community anti-drug coalitions and others

and will provide information about what the Campaign is and how these

groups can use it in their own programs.

According to ONDCP, the Ad Council is also playing an important role with

community groups during phase III. As a part of its contract with ONDCP,

the Ad Council is developing and assisting in the implementation of an

anti-drug coalition/drug prevention organization recruitment campaign.

Through this effort, ONDCP hopes to recruit adults to join anti-drug

organizations, including community coalitions. In partial fulfillment of this

task, the Ad Council established an Anti-Drug Coalition Task Force, which

held meetings with a broad range of coalitions to assist the Ad Council in

understanding the work of the coalitions, how they recruit, and the

barriers to participation in the work of these coalitions. In addition, six

focus groups met to discuss why some individuals decline to become

involved in anti-drug coalitions. Through these meetings, the Ad Council

learned that many adults (1) do not feel qualified to join an anti-drug

group, (2) are afraid of the stigma associated with being part of an antidrug group, and/or (3) have a negative opinion of anti-drug groups.

The Ad Council concluded that an educational awareness campaign would

be needed before a serious recruitment effort could be successful. In

response, the Ad Council developed a two-stage approach. The first stage,

to be carried out over 1 to 2 years, is to (1) focus on education and

awareness to change misconceptions about anti-drug coalitions and

present a positive face on anti-drug coalition activities and (2) involve a

series of print and possibly, outdoor, advertisements directed toward

adults. This campaign is to be launched in August 2000. The second stage

of this campaign will focus on recruitment, using various advertising

media.

Through the AAF and the local-level match program, ONDCP also assists

community anti-drug coalitions by providing free media time to those that

qualify for the match time (see pp. 46 and 47 of this report, for additional

details).

ONDCP staff also attended all regional meetings in 1999 of the Centers for

the Application of Prevention Technology, which is an organization that

brings together coalitions at the local level. ONDCP used these meetings to

bring members up to date on the Campaign and how it can be used as a

tool to their benefit. ONDCP staff also made presentations at the

bimonthly meetings of the National Drug Prevention League (NDPL) and
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obtained information about local-level chapters. NDPL is made up of

representatives from 30 groups that are involved in prevention. Through

NDPL, ONDCP is to identify in each market the capacities and points of

contact for prevention, civic and community organizations, and experts.

This information is to be used to create a media market map that will

establish a communications framework for Campaign initiatives and for

responding to time-sensitive media opportunities.

Congress directed ONDCP to develop a detailed implementation plan for

securing private sector contributions including, but not limited to, in-kind

contributions. In its November 1997 submission to Congress, ONDCP

stated its intention to finalize a detailed plan in January 1998. However, as

of the date of our review, ONDCP had not yet developed a detailed

implementation plan for securing private sector contributions and was

slipping on its current schedule to produce a plan by October 2000.

Nevertheless, even without a plan, as of March 2000, ONDCP reported

contributions valued at an estimated $71.7 million. According to ONDCP,

even when a plan is finalized, ONDCP may not be able to raise the required

amounts in private sector contributions.

A proposed corporate sponsorship/participation plan was developed in

1998 by Porter Novelli, which is a strategic communications planning firm

under contract with ONDCP for phases I and II of the Campaign. ONDCP

officials explained that this plan was not implemented for the following

reasons:

• Implementation of the plan was included in the contract with Porter

Novelli as an unpriced option. ONDCP wanted to exercise this option for

implementation in the fall of 1998. However, it realized that when

exercising an unpriced option, the contractor must be justified as a sole

source. It was not possible to justify Porter Novelli as a sole source for this

activity.

• The plan focused heavily on corporate sponsorship. 12 ONDCP believed that

other approaches, such as direct monetary contributions, might be more

12 Congress, in the initial Campaign legislation, required ONDCP to submit a plan to secure private

sector contributions. The Porter Novelli plan defined the following three types of contributions: (1)

corporate sponsorship, or rights fees paid by corporate brands in exchange for specific benefits and

promotional rights around the campaign and its target audiences; (2) corporate charitable

contributions, or donations of cash and/or in-kind services to the campaign; and (3) media or

promotional matches, or free or discounted time or space given as part of the match program (see pp.

43 to 51, of this report, for additional detail), or the requirement that corporate sponsors dedicate a

percentage of their own media and promotional vehicles to publicizing their participation in the

campaign. In subsequent legislation, Congress referred to corporate sponsorship. In this discussion of

private sector contributions, we refer to all types of contributions.

ONDCP Has Not

Developed a Private

Sector Contributions

Plan

ONDCP Was Unable to

Implement a 1998 Plan
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advantageous to the Campaign than a heavy focus on corporate

sponsorship, and ONDCP wanted time to “test the market.”

• The Campaign lacked a “brand,” which ONDCP officials explained is a

unifying idea that permeates every aspect of a media campaign and that

heightens recall of campaign messages. Both ONDCP and PDFA came to

believe it would be necessary to develop this unifying idea before

developing a contribution plan.13

• ONDCP decided that to make the most effective use of a contributions

plan, it would first need to have the full phase III Campaign in place

because resources generated from the private-sector contributions plan

could support the nonadvertising components of the Campaign, such as

partnerships.

• Other demands of the Campaign made it difficult to focus on the

contributions plan. The development and implementation of a media

campaign was new to ONDCP. The first two phases of the Campaign were

devoted primarily to planning and executing the paid advertising segment

of the Campaign. ONDCP also began the nonadvertising communication

activities in areas of public information, the Internet, entertainment

industry collaboration, and partnerships with nongovernmental

organizations.

• ONDCP staffing limitations also played a part. The few staff devoted to the

Campaign had many other responsibilities important to the Campaign in

the first two phases, such as working with the contractors on the paid

advertising campaign.

ONDCP hoped to have a detailed implementation plan for securing private

sector contributions in place in October 2000. Officials explained that as a

first step, ONDCP would issue a request for information (RFI), using this

mechanism because ONDCP has no in-house expertise regarding private

sector contributions. Private industry would be asked to identify specific

requirements that are necessary for formulating and executing a program

to develop and apply private resources to the Campaign. The information

acquired through the RFI process would be included in the statement of

work section of a request for proposal (RFP) that ONDCP would issue to

obtain a contractor’s assistance with the development and implementation

of a contributions plan. ONDCP estimated that it would take about 1 year

to implement a private-sector contributions plan once a contractor is

chosen.

ONDCP had planned to obtain a contractor according to the following

timetable:

13 The campaign launched its brand, “The Anti-Drug,” in September 1999.

Steps and Timetable for

Development of a

Contributions Plan Were

Behind Schedule
Chapter 3

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Page 59 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

• Issue the RFI in November 1999, with the closing date for responses in

January 2000.

• Issue the RFP in March 2000, after review of the RFI and meetings with

industry representatives for additional input into the RFP.

• Award a contract around October 2000.

However, as of the time of our review, the process had not begun; neither

the RFI nor the RFP had been issued.

ONDCP was also looking for a firm with expertise in both valuation and

advertising to advise ONDCP on how to value noncash contributions, such

as entertainment story lines and special events tailored to the needs of the

Campaign. ONDCP planned to either issue an RFP or use a firm from the

General Services Administration schedule. ONDCP did not meet its goal

for completing the selection process for this contract by the end of

calendar year 1999.

Even without a plan to secure private sector contributions, as of the time

of our review, ONDCP reported the contributions listed in table 3. 3.14

ONDCP and its contractors valued these contributions at a combined

estimate of over $71.7 million.

14 ONDCP has received both cash and various in-kind contributions but has not received corporate

sponsorship to date.

ONDCP Received

Contributions in the

Absence of a Plan
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Page 60 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

Contribution

Type/Source Description Value

Cash

United Parcel Service N/A $30,000

The Waitt Family Foundation N/A 100,000

Subtotal $130,000

In-Kind

ABC The creative development and production costs of six PSAs. $1,500,000a,b

ABC/Disney Free development and management of the “Freevibe” Web

site.

100,000a

America Online, Inc. Free development and management of a Web site for

parents, the development of Web sites for teens and middle

school children, and sponsorship of several Web chat

sessions on drugs.

1,000,000a

CBS The creative development and production costs of four PSAs. 1,200,000a,b

ESPN The creative development and production costs of seven

PSAs.

500,000a,b

Fox The creative development and production costs of five PSAs. 1,400,000a,b

NBC The creative development and production costs of seven

PSAs.

1,700,000a,b

PDFA Advertisements for use in the Campaign.c61,800,000a

Univision The creative development and production costs of two PSAs. 500,000a,b

WB Network The creative development and production costs of four PSAs. 1,200,000a,b

Subtotal $70,900,000

Other

CADCA Showed six national satellite downlink broadcasts to its

members on media Campaign message themes.

d

Current Miss America Contributed her time for personal appearances, PSAs, and

Internet chat sessions.

d

Major League Soccer Sponsored a “coachaton” anti-drug event, placed anti-drug

information on its programs, requested that its teams do

anti-drug events, and designated one of its players as a

national spokesman on the drug issue.

d

Miss Teen USA Pageant Designated youth anti-drug media Campaign as the

pageant’s official cause.

d

Reader’s Digest, the Ad Council, and

the DC Boys and Girls Club

Sponsored a youth PSA contest. d

Seventeen Major League Baseball teams

and 5 NFL teams

Ran PSAs during games. d

Several local school districts Sponsored a youth PSA construction media summit. d

Subtotal over $700,000

Total over $71,730,000

a

Valuation was determined by contractors using industry standards.

b

Does not include the value of the time donated by celebrities.

c

Does not include contributions from advertising firms for creative development, the full value of the

waiver of celebrity actors’ fees, and the full value of the waiver of music rights fees from owners of

copyrights.

d

ONDCP did not separately value these contributions; it estimated a combined value that exceeds

$700,000.

Table 3.3: Private Sector Cash, In-Kind, and Other Contributions
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Page 61 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

Source: ONDCP.

For fiscal year 1999, Congress added the requirement that ONDCP develop

a plan to secure contributions equaling 40 percent of the Campaign’s

appropriation for that fiscal year—60 percent in fiscal year 2000; 80

percent in fiscal year 2001; and 100 percent in fiscal year 2002. The

Campaign was appropriated $195 million in its fiscal year 1998

appropriation and $185 million in both its fiscal years 1999 and 2000

appropriations. For fiscal year 2000, Congress directed ONDCP to hold

back 10 percent of its appropriated funds until ONDCP submitted a

corporate sponsorship plan to the Appropriations Committees (see pp. 40

and 41 of this report). In addition, the Senate Appropriations Committee

specified that ONDCP should secure contributions equaling 80 percent of

the Campaign’s fiscal year 2000 appropriation, which was an increase of

the requirement established for fiscal year 1999.

ONDCP officials told us that even when a private-sector contributions plan

is developed and implemented, they do not believe they will be able to

attain the highest levels of the congressionally mandated levels of

contributions. ONDCP officials said they did not know at what level of

congressionally mandated contributions they would run into trouble. An

ONDCP official indicated that, on the basis of Porter Novelli’s 1998

proposed plan and its knowledge of corporate sponsorship and what the

market will generally “bear” in this area, ONDCP might be able to obtain

from $20 million to $30 million a year in financial or in-kind contributions,

including the value of corporate sponsorship, for a few years. ONDCP

plans to learn more about market limitations through the process of

developing the statement of work and awarding a contract for the

implementation of a contributions plan. ONDCP then plans to brief

Congress on what ONDCP might be able to accomplish in terms of total

annual contributions.

ONDCP May Be Unable to

Achieve Contributions

Goals
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Congress directed ONDCP to develop guidelines to ensure that Campaign

funds would not be used for partisan political purposes, and that no

Campaign efforts would feature elected officials; persons seeking elected

office; cabinet-level officials; or other federal officials employed pursuant

to Schedule C of title 5, Code of Federal Regulations, section 213,15 absent

advance notice to the Appropriations Committees and the Senate Judiciary

Committee. ONDCP and PDFA developed (1) policy and guidance

addressing this requirement and (2) a review process intended, in part, to

ensure that advertisements do not feature political figures or partisan

content. However, neither ONDCP nor PDFA has an internal control

requirement that these reviews be documented. As a result, ONDCP

cannot ensure that advertisements have been reviewed for the presence of

political figures and partisan content.

In its November 1997 submission to Congress, ONDCP stated that all

advertisements to be used in the Campaign would be carefully reviewed to

ensure that they did not feature political figures or partisan purposes. A

PDFA official explained that ONDCP and PDFA subsequently inserted the

following into PDFA’s production guidelines:

“Please note that under no circumstances whatsoever should anyone running for public

office, members of the Cabinet, elected officials, or any other political appointees to federal

office be featured in a PDFA PSA. Additionally, PDFA PSA’s cannot be used by anyone in

public office in his or her own political advertising campaign.”16

According to ONDCP and PDFA, advertising agencies must present their

concepts to PDFA’s Creative Review Committee (CRC). The CRC, which

consists of creative directors from major advertising agencies, can

approve, decline, or request revisions to creative work. In reviewing

agencies’ presentations, CRC is to follow a 29-step creative development

process. The 29 steps include activities such as soliciting agencies to do

the work on a pro bono basis, reviewing agency work, and notifying the

agency regarding any necessary changes that must be made. None of the

steps address the prohibition on political figures and partisan purposes.

Recommendations made by the CRC are to be recorded by PDFA staff and

kept on a creative status report. According to PDFA, if political

figures/partisan purposes were found, this would be captured in the

creative status report, but the report itself does not require that these

15 These are noncareer employees of the Senior Executive Service and, in some agencies, noncareer

GS-15s.

16 The production guidelines are instructions that detail advertisement production from start to finish

and are provided to each advertising agency that develops messages for the Campaign.

Guidance and

Procedures Regarding

Political Figures and

Partisan Political

Purposes Lacked

Adequate Internal

Control
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Page 63 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

reviews be documented. However, PDFA believes that the appearance of

political figures/partisan purposes would be curtailed by PDFA staff. PDFA

staff work closely with the advertising agency and PDFA management

believe its staff would inform the agency about content that violates the

production guidelines.

The final review is to be made at ONDCP. New advertisements would be

presented to the Office of Legal Counsel for review. Part of that review is

to ensure that the advertisements do not feature political figures or

partisan purposes. However, these reviews also are not documented.

The Comptroller General’s guidance on internal controls in the federal

government, Standards for Internal Control in the Federal Government

(GAO/AIMD-00-21.3.1), requires that all transactions and other significant

events are to be clearly documented, and that the documentation is to be

readily available for examination. The documentation should appear in

management directives, administrative policies, or operating manuals and

may be in paper or electronic form. All documentation and records should

be properly managed and maintained. The documentation of transactions

or other significant events should be complete and accurate and should

facilitate tracing the transaction or event and related information.

For various reasons, ONDCP’s progress and results in implementing the

various program requirements related to the Campaign have been mixed.

ONDCP fully complied with some requirements, is still in the process of

implementing others, and may not be able to fully comply with some

unless certain issues are resolved.

Although ONDCP’s contractors were successful in obtaining at least a

dollar-for-dollar match, they were not able to obtain a match from every

vendor. To reach the Campaign’s reach and frequency goals, it was

sometimes necessary for contractors to purchase time or space from a

vendor unwilling or financially unable to provide equivalent free time or

space. Until the conflict between the congressional direction and the

program goals is resolved, ONDCP may not be able to fully comply with

the congressional direction or achieve its reach and frequency goals.

Although ONDCP obtained some private sector contributions, it still did

not develop a detailed implementation plan to secure private sector

contributions. Moreover, ONDCP indicated that, even when a plan is

developed and implemented, it does not believe that it can raise annually

an amount close to its annual appropriation. Instead, it believes that it

might be possible to raise $20 to $30 million a year in financial or in-kind

Conclusions
Chapter 3

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Page 64 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

contributions, including the value of corporate sponsorship. Therefore,

until this issue of a feasible amount of private sector contributions is

resolved, it appears that ONDCP may not be able to meet the

congressional mandate.

ONDCP and PDFA have developed a policy and guidance to help ensure

that advertisements developed for the Campaign do not feature political

figures or partisan content. However, although they have established a

requirement and process to review advertisements for political content,

there is no internal control requirement that such reviews be documented

and readily available for examination. This is important because without

documentation, ONDCP cannot be certain that its policy and guidance are

being followed and, thus, whether it is in full compliance with Congress’

intent.

To improve ONDCP’s compliance with the statutory program

requirements, we recommend that the Director of ONDCP direct the

appropriate ONDCP or contractor staff to take the following actions:

• To determine the extent to which matches do not occur because of efforts

to achieve the Campaign’s reach and frequency goals, maintain

documentation of all purchases that do not result in a match, including

why the vendor did not provide a match and why the purchase was made

without a match. This information should be provided to Congress to

assist in its assessment of the viability of the current congressional

direction that ONDCP obtain a match from each seller of advertisement

time and space given the Campaign’s reach and frequency goals.

• After adequate research and consultation with experts, provide

information to Congress detailing the anticipated dollar value of all

private-sector, nonmatch contributions to assist Congress in its

assessment of the viability of the private-sector contributions goals and the

dollar value ONDCP can be expected to obtain from the private sector.

• Develop internal controls in accordance with the Comptroller General’s

standards to ensure that the reviews of new advertisements for political

figures or partisan content are fully documented and available for

examination.

In its written comments on a draft of this report, ONDCP generally agreed

with the findings, conclusions, and recommendations contained in this

chapter. However, ONDCP stated the belief that we had given “short shrift”

to its accomplishments regarding the match program. It was not our intent

to do so. In fact, we recognized that ONDCP and its contractors were able

to achieve a match-to-paid rate in excess of 100 percent. Our focus was on

Recommendations

Agency Comments and

Our Evaluation
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Page 65 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

the difficulty in obtaining a match in every instance and in developing a

recommendation to address this issue. ONDCP agreed with our

recommendation regarding the match program and provided, as

attachment A to its written comments (see app. III), a copy of a letter

addressed to Ogilvy and Mather instructing the contractor to maintain

records of instances in which it is unable to obtain a match. Assuming this

instruction is followed by the contractor, we believe it addresses the first

part of the recommendation, that ONDCP maintain documentation of all

purchases that do not result in a match. However, in instructing the

contractor that this information should be made available upon request,

ONDCP did not address the intent of the second part of the

recommendation, that is, that ONDCP proactively provide this information

to the Congress. As a result, we are retaining our recommendation.

ONDCP asked that we note that ONDCP’s involvement with anti-drug

coalitions was based on an incremental approach. We believe that the

report’s treatment of the issue of ONDCP’s involvement with anti-drug

coalitions already reflects such an approach to meeting the requirement to

work with the coalitions. Specifically, we noted that because ONDCP’s

primary focus in the first two phases of the Campaign was on paid

advertising, less time was devoted to the other Campaign components,

including work with community anti-drug coalitions, and that ONDCP has

increased its involvement with community anti-drug coalitions in phase III

of the Campaign.

ONDCP asked us to amend the draft report to reflect that it has submitted

a plan to secure corporate sponsorship to the Appropriations

Committees.17 ONDCP attached a copy of this plan to its comments. Our

review of the document led us to conclude that it is a blueprint or strategy

for ONDCP’s acquiring a contractor to develop and implement a plan,

rather than the implementation plan itself. In fact, as discussed on page 59,

neither the RFI nor the RFP have been issued. Therefore, the requirement

to submit a detailed implementation plan for securing private sector

contributions has not been fulfilled.

ONDCP also notes that, in addition to nearly $72 million in unsolicited

contributions, it has received another $334 million18 in value through the

17 The Fiscal Year 1998 Treasury and General Government Appropriations Act required ONDCP to

submit to the Appropriations Committees and the Senate Judiciary Committee a detailed

implementation plan for private sector contributions, including but not limited to in-kind contributions.

18 This figure differs from that in table 3.1 because it includes data developed by Ogilvy and Mather

subsequent to completion of our review.
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match program. However, as ONDCP also correctly mentions, Congress

has directed that the value of such match contributions not be counted as

private sector contributions.

Finally, in response to our recommendation, ONDCP stated that it would

formalize its existing process for reviewing advertisements for political

figures or partisan content to include documenting the required legal

review. Since this action has not yet been taken, we are retaining the

recommendation on this matter.
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Were Inconclusive; Phase III Evaluation

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As required by law, ONDCP established a system for evaluating the impact

of the National Youth Anti-Drug Media Campaign. The first two evaluation

phases have been completed; the third has recently begun. The results of

the phase I and II evaluations regarding the Campaign’s impact on youth,

teen, and parent ad awareness and drug attitudes were inconclusive

because of various design, implementation, and analysis limitations. There

were, however, other indications that the initial phases of the Campaign

had some positive effects. These derived from unweighted awareness data,

Campaign community informants, and information obtained from the

Substance Abuse and Mental Health Services Administration’s (SAMHSA)

NCADI. Although it is too early to gauge the success of phase III in

affecting drug attitudes, beliefs, and behaviors, the evaluation design

appears promising, given its comprehensive scope, methodological

sophistication, and use of lessons learned from previous phases.

In response to the legislative mandate discussed in chapter 1, ONDCP

established a three-phase impact evaluation system for measuring the

success of the Campaign. Other entities also developed research projects

to help inform Campaign managers. To date, ONDCP has issued final

evaluation reports to Congress on the success of phases I and II. Outcome

results on phase III are scheduled to be issued every 6 months, beginning

approximately in late summer 2000.

After a decade of decreasing drug use by teenagers, the Monitoring the

Future (MTF) survey of 8, 10, and 12 graders showed a rising rate of drug

use from 1992 to 1996 as well as a corresponding decrease in drug risk

perception.1

A major goal of The National Drug Control Strategy of 1997

was to “[e]ducate and enable America’s youth to reject illegal drugs as well

as alcohol and tobacco.” In pursuit of that goal, one objective was to

“[p]ursue a vigorous advertising and public communications program

dealing with the dangers of drug, alcohol, and tobacco use by youth.”

ONDCP has discussed the evaluation of the 5-year Campaign in two parts:

(1) as an “impact” evaluation (subdivided into three phases) and (2) as

other research projects, which have helped inform Campaign managers

throughout the process.

In phase I of the impact evaluation (Jan. to June, 1998), a 6-month pilot

study, ONDCP principally tested whether the infusion of a paid anti-drug

Campaign made a significant difference in youth, teen, and parent ad

1

The MTF survey is one of the nation’s principal sources of drug prevalence data on school age youth.

The University of Michigan has conducted the survey annually since 1975, with funding from NIDA.

ONDCP Has System

for Evaluating the

Campaign
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awareness. 2Twelve target sites received the paid advertisements over the

6-month period. These sites were compared with 12 comparison sites that

relied on available PSAs and other community sources for their anti-drug

information.

In the phase II impact evaluation (July 1998 to early 1999), which was

approximately 6 months in duration, ONDCP expanded the Campaign

evaluation from the 24 target and comparison sites to a national scale. Ad

awareness remained the principal focus of concern in the evaluation but,

as in phase I, other drug-related data also were collected.

Phase III comprises the full-scale national Campaign impact evaluation, to

be conducted over a 4-year period, starting in 1999. Awareness of and

exposure to media advertisements will continue to be explored, but the

principal focus will shift toward evaluating the degree to which changes in

drug attitudes, behaviors, and beliefs can be causally related or associated

with the Campaign. These other variables were not principally considered

in phases I and II since ONDCP believed that it would take another 1 to 2

years before changes in perceptions and attitudes could be detected and 2

to 3 years for drug use changes to be evident.

In addition to the impact evaluation, other research studies were

developed to help inform Campaign managers. These studies included (1)

the collection of local qualitative data from focus groups and key

informants, under contract with SAMHSA’s Center for Substance Abuse

Prevention; (2) public contact and publication distribution information

from NCADI; and (3) an assessment of the utility of the Campaign

elements, relative to cost, developed by Ogilvy and Mather.

The principal focus of our report was to review the ONDCP impact

evaluation, since it focused on the primary dependent variables—drug ad

awareness, attitudes, beliefs, perceptions, and drug use change—upon

which ONDCP drew its phases I and II conclusions and will draw its phase

III conclusions.

An overview of ONDCP’s impact evaluation design for each phase of the

Campaign is presented in table 4.1.

2

In phase I, quantitative survey data were also collected on drug attitudes, past use of drugs,

perceptions of drug risk, drug information sources, and parent-child communication about drugs. Also,

qualitative data were collected from focus groups and key informants (i.e., members of the community

who are knowledgeable or informed about the community’s drug-related problems and may play a role

in policy or program decisionmaking).
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Methodological issue Phase I Phase II Phase III

Geographic site selection 24 metropolitan areas:

12 target sites

12 comparison sites

National cross-sectional

sample

National cross-sectional sample,

four-site longitudinal sample, and

special analytic studies

Respondent selection Youth & teens: school survey

Parents: telephone survey

Focus groups, key informants,

and community organizations

Youth & teens: school survey

Parents: telephone survey

Focus groups, key informants

and community organizations

Youth & teens: household survey

Parents: household survey

Actual sample size Baseline:

School survey: 18,300

Telephone survey: 4,314

Follow-up:

School survey: 17,015

Telephone survey: 4,211

Baseline:

School survey: 22,534

Telephone survey: 4,209

Follow-up:

School survey: 23,414

Telephone survey: 4,256

Data are not yet collected

Principal analytic focus Ad awareness Ad awareness Ad exposure, drug use, attitudes,

and beliefs

Campaign evaluation period January 1998 to June 1998

(total of 6 months)

July 1998 to early 1999

(total of about 6 months)

Starting in 1999

(total of 4 years)

National sponsorship

agency

ONDCP ONDCP ONDCP/NIDA

Primary evaluation

contractor

CSR CSR Westat

Source: Documentation provided by ONDCP and NIDA.

As requested, we addressed the following methodological and analytic

questions related to the various phases of the Campaign:

• How appropriate were the evaluation designs for assessing the

effectiveness of phases I, II, and III?

• How successfully were these evaluation designs implemented?

• How effective were the first two phases of the Campaign in influencing

both drug ad awareness and attitude change?3

3

We limited our assessment of phase III to the design stage since data collection was just beginning at

the time our work was completed.

Table 4.1: Methodology of the Impact Evaluations for Phases I, II, and III of the National Youth Anti-Drug Media Campaign
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The phases I and II impact evaluation sampling designs for selecting youth,

teen, and parent participants in the respective local and national surveys

were generally appropriate on the basis of common scientific practice.

However, the ad awareness measure—the principal outcome variable of

both phases I and II—did not adequately measure the overall awareness

generated by the Campaign.

In the phases I and II impact evaluations, ONDCP sought to obtain youth

(grades 4 to 6), teen (grades 7 to 12), and parent participation in the local

and national surveys to study the impact of the Campaign on drug ad

awareness, attitudes, and other outcome variables. The sampling designs

used to select respondents from each of these three groups were generally

appropriate.4

A multistage sampling approach was used to conduct baseline and followup surveys of teens and youth in each phase. The phase I design involved

the selection of 12 target and 12 comparison sites,5

followed by the random

selection of schools and classrooms at the sites. The goal was to obtain

completed questionnaires from 24,000 students at baseline and 24,000 at

follow-up, equally divided by target and comparison sites. The phase II

design called for the random selection of counties nationwide, followed by

the random selection of schools and classrooms in these counties. The

goal was to obtain completed questionnaires from 21,000 students at

baseline and follow-up, equally divided between youth and teens. The

questionnaires were to be anonymously completed by students present on

the day of the survey in each phase.

The parent samples in the phases I and II telephone surveys were to be

selected independently from the student samples. The parent samples

were obtained by random digit dialing, a standard sampling technique used

in telephone surveys of the general population. Each household contacted

4

The term “generally appropriate” is used here to indicate that although the respondent sampling

design was largely positive, our outside reviewers did cite some limitations in the sampling design (e.g.,

student exclusion from private schools in phase I and a reduced precision of estimates attributable to

highly clustered student samples). This latter limitation can occur in surveys in which students are

sampled from clusters of schools.

5

The site selection criteria included the following characteristics: (1) geographic dispersion; (2)

population size and other demographic characteristics; (3) presentation, at least in some areas, of

emerging drug problems; (4) availability of community drug data; and (5) low drug PSA activity, to

minimize outside drug media influences.

Phases I and II

Respondent Sampling

Designs Were

Generally Appropriate,

but Awareness

Measure Had

Limitations

Respondent Sampling

Designs Were Generally

Appropriate
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was to be screened to determine if it contained a parent of a child 18 years

old or younger. Parents satisfying these criteria were requested to

participate in the survey.

Ad awareness was the major outcome variable in the phases I and II

evaluations. But the ad awareness measures established in the design stage

did not capture the full extent of either local or national awareness of the

Campaign. Nor did the Campaign appropriately measure teen and parent

awareness.

We identified several limitations that may have had an effect on ad

awareness measurement, including the following:

• Youth, teens, and parents were asked only about television advertisements

in the phases I and II survey forms; radio, newspaper, magazine, and

billboard media ad awareness items were not included in the survey

instruments. 6

• Teen and parent awareness responses were to be measured in a

conservative manner; that is, positive teen and parent awareness

responses were to be based on seeing an advertisement “often” in the past

few months rather than “ever” seeing the advertisement. Had the working

definition of awareness been broadened, Campaign awareness results

would have increased.

• “Aided recall”7

procedures were used to assess individuals’ awareness of

Campaign advertisements. Although aided recall procedures have been

used in other surveys, there is a risk that respondents could have indicated

awareness of a specific advertisement when, in fact, they were unfamiliar

with that advertisement.8 To counter this overreporting potential, follow6 In phase I of the Campaign, advertisements for youth and teens were presented on television and

radio; advertisements for parents were presented on television, radio, and newspapers. In phase II, the

use of magazines and the Internet were introduced. ONDCP recognized the need to ask about other

media in addition to television, yet indicated that at the time that the phases I and II surveys were

approved by the Office of Management and Budget, only television advertisements were available.

7 Aided recall procedures are used in surveys in an attempt to stimulate respondents’ memories. These

procedures provide the respondent with information or other memory cues to help the individual

complete the task, rather than leaving the individual to his/her own devices. In the Campaign, ONDCP

provided respondents with one- to four-sentence descriptions of the surveyed advertisements.

8

Seymour Sudman and Norman M. Bradburn, Response Effects in Surveys: A Review and Synthesis.

Aldine Publishing Company, Chicago, 1974, pp. 80-81. Seymour Sudman and Norman M. Bradburn,

Asking Questions: A Practical Guide to Questionnaire Design. Jossey-Bass Publishers, San Francisco,

1982, pp. 36-39.

Limitations Existed in the

Ad Awareness Measures
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up questions could have been asked (on at least a few items) to elicit a

more in-depth description of the advertisement or action sequence.9

• One or more false advertisements could have been provided in the survey

instrument as a measure of respondent veracity.10

We identified several limitations in ONDCP’s efforts to implement and

analyze the phases I and II youth, teen, and parent evaluations. These

limitations related to geographic site selection, unknown parent response

rates, high school nonresponse rates, and problems relating to data

analysis—with implications for the quantitative accuracy,

representativeness, and generalizability of the youth, teen, and parent

survey results.

The phase I survey design strategy called for obtaining a geographic

sample of comparable target and comparison sites to determine whether

the paid Campaign intervention made a difference in local ad awareness

and other outcome variables. However, several target and comparison

sites were not comparable at the implementation stage. As a result,

ONDCP could not determine how much of the ad awareness differences

found between these sites should be attributed to the campaign

intervention versus other outside factors.

To test the effects of the paid Campaign in phase I, ONDCP sought to

create comparable (or matched) target and comparison sites in an effort to

minimize the effects of outside factors. If the target sites exposed to the

paid media advertisements demonstrated more positive effects than

matched the comparison sites on ad awareness and other outcome

variables, ONDCP would have had greater assurance that at least some of

these positive effects may have been due to the Campaign. ONDCP

presented its matching strategy in the phase I final report. “Each site was

[to be] paired with a comparison site that had similar population

characteristics, to the extent possible, and was located in a relatively

9

The underreporting of ad awareness could have also taken place, given that respondents were only

provided with an one- to four-sentence description of the specific advertisements in the ONDCP survey

instruments. One of ONDCP’s consultants believed that the false positives generated by aided recall

were “probably more than offset by underreporting,” but we had no way to verify the underreporting or

overreporting. In addition, one of our outside expert reviewers judged the lack of unaided recall

procedures as “the biggest objection” to the survey instruments.

10 Because false advertisements were not provided in the survey instruments, ONDCP sought after-thefact to develop a surrogate measure of this phenomenon in response to our concern. In both phases I

and II, ONDCP noted that a limited number of teen advertisements had been included in the survey

instruments but ultimately not used either as PSAs or in the paid Campaign. Respondents

demonstrated low awareness of these advertisements both at baseline and follow-up, thereby

providing some degree of reporting veracity.

Phases I and II

Implementation and

Analytic Limitations

Compromised the

Results

Geographic Site Selection

Proved Problematic
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similar geographic area.” However, the initial pairing of target and

comparison sites did not always yield sites well matched on population

characteristics and geographic area, as intended by ONDCP. For example,

our outside reviewers and we noted that 9 of the 12 target sites had larger

populations than their matched comparison sites. In 1 illustration, the

median target site (Baltimore) had a population that was 275 percent the

size of its respective comparison site (Richmond)—that is, 2,383,172

versus 865,640. The crime rate per 100,000 per year in Baltimore was more

than double that of Richmond (1,335 v. 603), and the percentage of

children under 18 living below the poverty level in Baltimore was more

than twice that of Richmond (34 v. 14). In another illustration, Washington,

D.C.’s, population was more than 4 times larger than that of Birmingham,

AL, which was its comparison site (3,923,574 v. 907,810). Birmingham had

a crime rate that was150 percent higher than that of Washington (1,071 v.

716), an unemployment rate that was 165 percent higher than that of

Washington (6.1 v. 3.7), and a child poverty level that was 258 percent

higher than that of Washington (20.4 v. 7.9). In addition, Washington is

located in the South Atlantic census region, whereas Birmingham is

located in the East South Central region. 11 In all, 6 target-comparison site

matches demonstrated crime-rate variations that were greater than 350 per

100,000 per year. Four matches were not in the same geographic census

region.12

Further, as previously indicated, target and comparison sites were to be

matched on other design variables (i.e., areas of low drug public service

activity, areas of emerging drug problems, and areas of available

community drug data). However, ONDCP has not presented the data

indicating the success of the matches for these variables.

ONDCP also experienced problems gaining school survey data in 4 of the

12 comparison sites chosen. Since ONDCP did not have any other

comparison sites in reserve, when these four sites were dropped from the

study, four comparison sites already participating in the study had to be

11 In addition, ONDCP noted that “[i]t was very difficult to find an MSA [Metropolitan Statistical Area]

with characteristics similar to those of Atlanta....” Memphis was chosen as the Atlanta match.

However, there were several differences between these two sites: Memphis had about one-third the

population of Atlanta (981,747 v. 2,833,511), a different racial configuration (41 percent v. 25 percent

African American), a crime rate 155 percent higher than that of Atlanta (1,253 v. 807), and about twice

the percentage of children under 18 living below the poverty level (26.6 v. 13.9).

12 The following matches were not in the same geographic census region: Milwaukee (West North

Central census region) with Nashville (East South Central census region); Memphis (East South

Central) with Atlanta (South Atlantic); Tucson (Mountain) with Austin (West South Central); and

Washington with Birmingham.
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used as replacements. 13 Two of these four sites were not comparable to

the target sites.

Moreover, key informants participating in the Campaign pointed out that

other recent events in at least four target sites and one comparison site

might have influenced drug awareness results in these sites irrespective of

the Campaign.14

ONDCP reported adjusted response rates15 for the parent surveys in the

phases I and II final reports submitted to Congress. The phase I adjusted

response rates were reported to be 47 percent for the baseline survey and

46 percent for the follow-up survey. The phase II adjusted response rates

were reported to be 53 percent for the baseline survey and 52 percent for

the follow-up survey. We questioned the accuracy of these adjusted parent

response rates, given the high levels of reported initial refusals16 and the

methodology used to compute the adjusted rates.17 We also had concerns

about the generalizability of the parent data.18 ONDCP subsequently

13 ONDCP cited four reasons for its inability to recruit alternate sites: (1) a tight time schedule—the

design and implementation of the study had to be conducted in 3 months, (2) budget limitations, (3)

difficulty recruiting in additional cities and schools, and (4) insufficient notice that the four sites would

refuse participation—clarification was obtained in December; baseline data collection was to be

completed in January.

14 For example, key informants in the Baltimore area indicated that the Campaign may have only

“slightly” raised awareness of the drug problem in the community because “numerous” federal, state,

local, and private efforts have been ongoing to address drug use and trafficking; a “concurrent” media

campaign conducted by Assets for Colorado Youth “may have affected survey responses” in Denver, in

addition to the recent formation of institutionalized prevention programs within government; a key

informant in Atlanta attributed increased awareness of anti-drug television messages to a “major antidrug media campaign conducted in the Atlanta area in 1997” (just before the inception of the

Campaign); and site visits to San Diego and Memphis demonstrated that each of these sites had

ongoing anti-drug media campaigns in place before and during the Campaign.

15 Since there were large numbers of households that refused to participate in the parent survey

screening process, ONDCP could not determine exactly how many households contacted actually had

a member qualified for participation (i.e., had at least one parent with a child 18 years of age or

younger). ONDCP therefore adjusted the overall survey response rates in an attempt to take parent

qualification into consideration.

16 According to ONDCP, the term “initial refusals” refers to the actual number of households refusing to

participate in the parent survey screening processes of phases I and II. In phase I, ONDCP reported

14,812 initial refusals at baseline and 15,249 at follow-up; in phase II, ONDCP reported 10,966 initial

refusals at baseline and 11,116 at follow-up.

17 Because of the apparent high number of households that refused to provide information about parent

status, ONDCP’s estimates could have been biased.

18 Surveys with a high level of nonresponse could be affected by nonresponse bias and other statistical

problems, particularly at response rates lower than 50 percent. Office of Information and Regulatory

Affairs, Office of Management and Budget (OMB), The Paperwork Reduction Act of 1995:

Implementing Guidance for OMB Review of Agency Information Collection, June 2, 1999, pp. 73, 127-

129.

Unknown Parent Response

Rates; Low School

Response Rates
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provided revised response rate data, but we found inconsistencies in these

calculations as well. Consequently, the actual parent response rates for

phases I and II of the Campaign are unknown.

School response rates were low for both phases I and II. This was

particularly so in phase II, in which less than one-third of the originally

invited schools agreed to participate in ONDCP’s youth and teen surveys.

In phase II, 27 percent of the schools for youth agreed to participate at

baseline and follow-up; 29 percent of the schools for teens agreed to

participate at these two time periods.19 In phase I, the aggregate school

response rates in the comparison sites were 41 percent at baseline and 42

percent at follow-up.20

To obtain the planned quotas of completed questionnaires, ONDCP

selected additional schools to replace the originally selected schools that

did not participate. A total of 97 replacement schools participated in phase

I; 248 replacement schools participated in phase II. ONDCP’s contractor

was not able to provide a response rate for the replacement schools due to

the nonrandom method they used to select the replacements (i.e., due to

time pressures, they enlisted the participation of several schools at the

same time and selected the first one willing to participate). Because of the

quota procedure used, the low original school response rates and the

nonrandom method of selecting replacement schools, it is likely that

participating youth and teens were not representative of their respective

study populations.21 Thus, as with results of the parent surveys, the results

from the school surveys should not have been generalized beyond the

respondent samples.

ONDCP weighted the parent, youth, and teen results from the phases I and

II surveys using population parameters. However, since there was reason

19 In ONDCP’s request for revised survey instrument clearance from OMB, it was anticipated that at

least 80 percent of the schools contacted would participate in the phase II baseline study; 90 percent of

those were expected to cooperate at follow-up.

20 ONDCP provided the following two reasons to explain their “handicap” in the school recruitment

process: (1) “We were new to the field and had no record of cooperation with the schools, unlike the

MTF which has been in existence for more than 25 years, and (2) there are too many surveys

competing for scarce time in the classroom, including the MTF, the Youth Risk Behavior Survey, state

and local surveys, and several non-drug related surveys by Federal, State, and local governments.”

21 As noted by OMB, “The statistical laws that permit inference from a sample to a population assume

complete coverage, complete response, and random selection... ‘quota samples’ cannot produce

results that can be generalized to the universe of study. Likewise, samples drawn from a substantially

incomplete frame, or which suffer from significant nonresponse cannot support valid statistical

inferences.” Office of Information and Regulatory Affairs, OMB, The Paperwork Reduction Act of 1995:

Implementing Guidance for OMB Review of Agency Information Collection, June 2, 1999, p. 73.

Analysis Problems
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to believe that the samples of these respective groups may not have been

representative of their respective populations (due to unknown parent

response rates, high school nonresponse rate, and loss of the randomized

sample) unweighted data—that is, actual data that were obtained from the

respondents participating in the survey samples—should have been used.

In addition, tests were used to determine the statistical significance of

these survey results. However, statistical significance testing generally

requires that data be obtained from random samples. Youth and teen data

collection from replacement schools was implemented in a nonrandom

fashion. Therefore, use of statistical significance testing with these results

is questionable. At a minimum, ONDCP should have indicated that

statistical tests had been used even though the final samples were not

completely random. ONDCP should also have provided reasons, on the

basis of such factors as subject matter knowledge, experience, and

judgment, why it believed such tests were nevertheless justified.

The previously mentioned limitations notwithstanding, there were

indications from the unweighted survey results, community informants,

and information obtained from NCADI, that led us to believe the initial

phases of the Campaign had some positive effects.

First, unweighted data from the impact studies of phases I and II seemed

to indicate increased awareness of Campaign advertisements. Youth,

teens, and parents in target sites22 demonstrated positive gains on 25 of 26

unweighted ad awareness items during these phases of the Campaign.

Unweighted drug attitudinal data for the three groups showed both small

gains and losses.

Second, focus groups and Campaign community informants have reported

anecdotal information that describe positive community anti-drug

activities/changes taking place as a result of the Campaign.23 These

changes included the following:

22 We considered only target sites in the phase I analysis to obviate comparison site match concerns.

We also measured ad awareness in the same way that ONDCP measured this variable for youth, teens,

and parents.

23 Some of these findings were derived from the ONDCP phase I final report section on site-specific

results; other findings were derived from the Pacific Institute for Research and Evaluation, ONDCP

Media Campaign Surrogate Measures Project, report prepared under contract from the Center for

Substance Abuse Prevention, Substance Abuse and Mental Health Services Administration, June 25,

1998. We did not verify each observation made by community informants against source documents.

Some Positive Effects

Were Associated With

Phases I and II
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• In Washington, D.C., prevention program providers cited a 30-percent

increase in hotline telephone calls from individuals searching for

information on substance abuse prevention and treatment.

• In Sioux City, several local television and radio stations aired the campaign

advertisements as PSAs rather than as paid slots. The stations donated the

money saved from the paid advertisements to community prevention

programs.

• In Colorado, a $50,000 grant was allocated for conducting marijuana

education.

• In Houston, advertisements were aired on Channel 1 in the Houston

Independent School District.

• In San Diego, the Partnership for a Drug Free San Diego was asked to

provide the police force with substance abuse prevention materials for its

neighborhood policing effort.

Third, our comparison of the volume of NCADI’s public contacts24 and

publications distribution over three, 6-month periods25 showed that

clearinghouse activity increased substantially during the Campaign period.

For example, there was a 192-percent increase in telephone contacts and a

64-percent increase in faxes, E-mails, and mail contacts between the preCampaign and phase II periods. The number of hits per day on NCADI’s

PREVLINE Web site increased from 44,433 in the pre-Campaign period to

74,905 during phase I and 103,303 hits in phase II (an increase of 132.5

percent within a 1-year period.) In phase II, there were also distribution

increases on five of seven anti-drug publications, ranging between 122

percent and 249 percent compared with the pre-Campaign period (see app.

II). Although at least some of this increased activity could be due to factors

other than the Campaign, NCADI data lend support to the contention that

there is a positive relationship between increased Campaign awareness

and heightened clearinghouse activity.26

24 Public contacts comprise telephone calls, faxes, regular mail, E-mails, and Internet Web site hits.

25 Phases I and II were compared with a pre-Campaign period: the pre-Campaign period (July 1997 to

Dec. 1997), phase I (Jan. 1998 to June 1998), and phase II (July 1998 to Dec. 1998).

26 To illustrate, a Campaign advertisement for a marijuana publication appeared in Parade Magazine.

NCADI reported receiving 2,776 contacts the following day, resulting in the shipment of 5,299 copies,

approximately 3 times the number of publications shipped either the week before or after the

advertisement appeared. In addition, SAMHSA found that daily increases in the distribution of seven

publications were associated with Campaign activities announcing the ONDCP toll-free telephone

number. We did not seek to verify these data.
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The phase III evaluation design appears to be more promising than

previous phases in being able to provide a more comprehensive overall

assessment of the Campaign’s impact and effectiveness. This is because

the phase III design (1) seeks to examine a more extensive set of

evaluation objectives and variables, including drug use behaviors,

attitudes, knowledge, and belief patterns; (2) incorporates a theoretical

model of the relationship between these variables, to better understand the

process through which media exposure occurs and drug use and

attitudinal change take place; (3) employs a sampling design that builds

upon lessons learned from phases I and II, and allows for the collection of

both cross-sectional and longitudinal data; and (4) uses a more

comprehensive analytical strategy for demonstrating whether there is a

preponderance of evidence in support of the Campaign. Also, the

continued collection of NCADI data as a supplemental measure will help to

demonstrate whether public awareness of and exposure to anti-drug

messages are increasing or diminishing over time. In addition, an Ogilvy

and Mather study will seek to determine the impact of particular media

elements, with the aim of revising the Campaign while in progress to

maximize its effectiveness.

According to NIDA, the phase III evaluation will comprise the following

five major objectives, containing a greater number of intermediate and

outcome variables than was covered in the phases I and II evaluations:

• measure changes in drug-related knowledge, attitudes, beliefs, and

behavior in youth and their parents;

• assess the relationship between changes in drug-related knowledge,

attitudes, beliefs, and behavior and their association with self-reported

measures of media exposure, including the salience of message;

• assess the association between parents’ drug-related knowledge, attitudes,

beliefs, and behavior and those of their children;

• assess changes in the association between the parents’ drug-related

knowledge, attitudes, beliefs, and behavior and those of their children that

may be related to the Campaign; and

• assess the extent to which community-based drug prevention activities

change in response to the Campaign.

During phase III, the relationship between the Campaign and drug use

behavioral change—the key outcome variable—will be initially explored.

ONDCP officials had not examined this relationship in earlier phases of the

study because they said that it would take approximately 2 to 3 years for

the Campaign to have an impact on drug use change. Both phases I and II

were each only about 6 months in duration.

The Phase III

Evaluation Design

Appears More

Promising Than

Previous Phases

Phase III Objectives Are

More Extensive Than Those

for Phases I and II
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The ONDCP phase III evaluation of the Campaign is based primarily on

two studies, the National Survey of Parents and Youth (NSPY) and the

Community Longitudinal Survey of Parents and Youth (CLSPY). Both

studies use household surveys—rather than school and telephone

surveys—to maximize response rates. Both studies sample parents and

youth from the same households to study interaction effects that may be

taking place among family members. If these phase III design elements are

properly implemented, ONDCP should be able to provide Congress and the

public with more conclusive results regarding the impact of the Campaign

than were provided in phases I and II.

The NSPY was designed as a nationally representative, cross-sectional

survey of noninstitutionalized youth and parent (or caregiver)

respondents, living in all 50 states and Washington, D.C. As in phases I and

II, a multistage sampling approach is to be used in selecting respondents.

The NSPY household survey is to be administered once every 6 months,

over a period of 4 years. This time frame provides NIDA and its

contractors with the opportunity to continually measure changes in the

outcome variables over time. This was not feasible in phases I and II, in

which there was only a single follow-up to the baseline measure.

The CLSPY was designed as a longitudinal survey to better understand the

progressive and interactive dynamics taking place among youth, parents,

and communities in four sites, as a result of the Campaign. The CLSPY has

three principal aims: (1) to determine how knowledge, attitudes, and

beliefs among younger age groups relate to subsequent drug use behaviors

as teens; (2) to evaluate the impact of parent-child interactions on

subsequent outcome changes; and (3) to assess the impact of the

Campaign on communities and local organizations.

Participating CLSPY youth and parent respondents will be interviewed for

the first time at phase III baseline, and then subsequently interviewed once

a year for the next 3 years, to obtain the necessary follow-up data.

NIDA and its contractor/subcontractors realized that other outside factors

might be impinging on individuals simultaneously during phase III of the

Campaign. The phase III evaluators succeeded in designing a

comprehensive theoretical model and analytic strategy for determining the

impact of the Campaign on several drug intermediate and outcome

variables.

A few highlights of the types of analyses planned are illustrated below:

The Phase III Sample

Designs Build on Lessons

Learned From Phases I and

II

Comprehensive Analytical

Strategy Planned for

Determining the Impact of

Phase III
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• To assess whether the Campaign may be having a positive impact on

national drug use rates, historic trend data (from the MTF and the National

Household Survey On Drug Abuse surveys) will be evaluated to determine

whether drug use rates during the Campaign period have declined relative

to those in the pre-Campaign period.

• To assess whether changes in parents’ drug attitudes are having an

influence on their children, “lagged” analyses27 are to be conducted over

the 4-year, phase III time frame to determine when, and if, child attitudinal

scores change in accordance with their parents.

• To determine whether there is a concurrent or lagged relationship between

attitudinal modification and drug use change, current and longer-term

attitudinal data will be compared against drug use change scores.

• Special analytic studies are also to be designed to focus on the “indirect,

message-specific, outcome-specific, and risk-group-specific effects of the

Campaign.” More complex analyses, including logistic, multivariate,

structural equations, will be used to design and test various hypotheses.

Further, NCADI will continue to collect information on the volume and

types of public contacts received and publications distributed through the

end of calendar year 2000. As previously mentioned, the volume of public

contacts are to be measured in terms of telephone calls, faxes, regular

mail, E-mail contacts, and Web site hits, while publication distribution data

are to cover publications of general community interest. NCADI is also

continuing to collect user satisfaction data as part of its overall

performance monitoring and quality assurance tasks.

In addition, as part of the phase III evaluation, Ogilvy and Mather has

designed an econometric study to provide continuous, short-term feedback

to Campaign officials regarding the contribution of each media element to

the Campaign, relative to costs. If appropriately used, the study has the

potential to help ONDCP make media adjustments on an as needed basis,

thereby enhancing the potential media impact of the Campaign.

As required by law, ONDCP has established a system to evaluate the three

phases of the Campaign. However, due to various design, implementation,

and analytical concerns, the phases I and II youth, teen, and parent survey

evaluation data remain inconclusive. Potential limitations regarding

geographic site selection, nonresponse rates, and data representativeness

and generalizability may have compromised the results. But unweighted

findings from the phases I and II impact studies; input from focus groups,

key informants, and community organizations; and data derived from

27 “Lagged” analyses refers to the study of changes taking place over time, rather than concurrently.

Conclusions
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NCADI lead us to believe that the initial phases of the Campaign had some

positive effects.

The 4-year, phase III evaluation design appears to be more promising than

previous phases for several reasons. A theoretically based, better-designed

model has been developed. More comprehensive analytical strategies have

been enumerated for demonstrating the impact of the Campaign. Various

statistical procedures have been designed for analyzing both current and

long-term effects. Moreover, limitations of phases I and II may be

overcome in the phase III design strategy, thereby maximizing response

rates and permitting the study of family drug interaction patterns. Also,

NCADI plans to continue to collect data on the volume of public contacts

and reports distribution, a supplemental measure of campaign awareness

and exposure. In addition, Ogilvy and Mather plans to determine the

importance of each media element relevant to cost—on a rapid turnaround basis—to maximize the impact of the Campaign.

In its written comments on a draft of this report, ONDCP generally agreed

with our findings and conclusions relating to the evaluation of the

Campaign’s three phases, and did not raise any issues or concerns.

However, we need to clarify ONDCP’s paraphrasing of two of our findings

and conclusions. First, ONDCP stated that indications from NCADI and

focus groups “support that the Campaign has positive effects on changing

youth attitudes toward drug use.” As discussed in this chapter, we found

that information from NCADI and focus groups provided indications that

the Campaign may have had some positive effects on anti-drug awareness.

We did not find, however, that these sources provided indications of the

Campaign having positive effects specifically on youth attitudes toward

drug use.

Second, ONDCP stated that our report concludes that the phase III

evaluation “should yield superior data.” Although we concluded that phase

III appears to be more promising than previous phases because of its

design and analytical strategy, we did not specifically characterize the

quality of data it might yield.

Agency Comments and

Our Evaluation
Appendix I

Experts Consulted

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We consulted with the following experts in reviewing the (1)

appropriateness of the methodological, statistical, and design aspects of

ONDCP’s evaluations of phases I and II of the National Youth Anti-Drug

Media Campaign and (2) results of these evaluations.

Elaine Cardenas, MBA

Director of Marketing

The Gallup Organization

Dr. James Derzon

Research Scientist

Hamilton Fish National Institute on School and Community Violence

The George Washington University

Rosslyn, Virginia

Dr. John Finnegan, Jr.

Associate Dean for Educational Affairs

School of Public Health

University of Minnesota

Minneapolis, Minnesota

Peter Hannan, Senior Research Fellow

Division of Epidemiology

School of Public Health

University of Minnesota

Minneapolis, Minnesota

Dr. Leslie Kish, Professor Emeritus

Department of Sociology

Survey Research Center

Institute for Social Research

University of Michigan

Ann Arbor, Michigan

Dr. Philip Palmgreen

Department of Communication

University of Kentucky

Lexington, Kentucky
Appendix I

Experts Consulted

Page 83 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

Dr. John Pierce

Sam M. Walton Professor for Cancer Research

Associate Director for Cancer Prevention and Control

University of California, San Diego

La Jolla, California

Dr. Michael Slater

Departments of Journalism & Technical Communication/Psychology

Colorado State University

Fort Collins, Colorado

Dr. Roger Tourangeau

Senior Advisor

The Gallup Organization

Dr. Stephen Weber

Senior Vice President

Market Facts

McLean, Virginia
Appendix II

NCADI Public Contacts and Publication

Distribution

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We compared changes in the volume of NCADI’s public contacts and

publications distribution over three, 6-month periods to determine whether

clearinghouse activity increased during the local and national phases of

the Campaign. These periods and their time frames were as follows: (1) the

pre-Campaign period (July 1997 to Dec. 1997), (2) phase I (Jan. 1998 to

June 1998), and (3) phase II (July 1998 to Dec. 1998).

NCADI’s public contacts included telephone calls, faxes, E-mails, regular

mail, and Web site hits (see table II.1). Publication distribution was based

on a review of seven anti-drug publications that were directed toward

youth, teens, and their parents (see table II.2).

Campaign evaluation period

Total telephone

contacts

Total FAX/E-mail/

mail contacts

Average PREVLINE

Web site hits/day

Pre-Campaign

(July 1997 - Dec. 1997)

63,765 17,625 44,433

Phase I

(Jan. 1998 – June 1998)

70,337

(+10.3%)

21,482

(+21.9%)

74,905

(+68.6%)

Phase II

(July 1998 - Dec. 1998

186,251

(+192.1%)

28,929

(+64.1%)

103,303

(+132.5%)

Source: SAMHSA’s National Clearinghouse for Alcohol and Drug Information. Weekly Reports on

Impact of Office of National Drug Control Policy Youth Anti-Drug Media Campaign on NCADI

Operations, 1999; and unpublished Web site documentation.

Table II.1 indicates that the volume of public contacts with the

clearinghouse increased during both phases I and II of the Campaign. The

greater increases took place during phase II, as would be expected, given

that the scope of the Campaign had been enhanced from a local to a

national effort.

Regarding telephone contacts, there was a 10.3-percent increase at phase I

and a 192.1-percent increase at phase II, compared with the 6-month preCampaign period. Regarding total fax/E-mail/mail contacts, there was a

21.9-percent increase at phase I and a 64.1-percent increase at phase II,

compared with the same pre-Campaign period. On the PREVLINE Web site

(a service of SAMHSA’s Center for Substance Abuse Prevention, which is

operated through NCADI), there was a 68.6-percent increase at phase I and

a 132.5-percent increase at phase II.

Table II.1: NCADI Public Contacts Pre-Campaign and Phases I and II (Percentage Change From Pre-Campaign Period)
Appendix II

NCADI Public Contacts and Publication Distribution

Page 85 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

Campaign period and distribution (percentage change

from pre-Campaign period)

Publication

Pre-Campaign

(July 1997 to

Dec. 1997)

Phase I

(Jan. 1998 to

June 1998)

Phase II

(July 1998 to

Dec. 1998)

Keeping Youth Drug Free: A Guide for Parents, Grandparents,

Elders, Mentors and Other Caregivers

258,739 269,140

(+4.0%)

574,035

(+121.9%)

Tips for Teens About Inhalants 170,507 335,895

(+97.0%)

482,445

(+182.9%)

Marijuana, Facts Parents Need to Know 52,028 120,978

(+132.5%)

161,424

(+210.3%)

Marijuana, Facts for Teens Not available 112,058 99,383

Inhalant Abuse: Its Dangers Are Nothing to Sniff At (NIDA Research

Report Series)

20,397 15,905

(-22.0%)

17,616

(-13.6%)

Marijuana, Facts for Teens (Spanish version) 11,177 18,217

(+63.0%)

26,443

(+136.6%)

Marijuana, Facts Parents Need to Know (Spanish version) 7,231 18,039

(+149.5%)

25,212

(+248.7%)

Source: Unpublished documentation submitted by SAMHSA to GAO.

Table II.2 demonstrates publication distribution gains during the Campaign

period as well. Five of the seven publications showed increased

distributions at phase I relative to the pre-Campaign period and even

greater gains at the phase II stage of the Campaign.

In one instance—that is, regarding a publication entitled Marijuana, Facts

for Teens—percentage change distribution results could not be calculated

because the publication was not available in the pre-Campaign period.

In the single instance in which a distribution decrease was noted during

the Campaign period, relative to the pre-Campaign time frame, SAMHSA

indicated that this was due to a decreased inventory of the publication

entitled Inhalant Abuse: Its Dangers Are Nothing to Sniff At.

During phase I, the median publication distribution increase, compared

with the pre-Campaign period, was 80 percent. During phase II, the median

publication distribution increase was 159.8 percent. For the 6 publications,

for which there are data for all 3 time periods, 520,079 were distributed in

the pre-Campaign period; 778,174 in phase I; and 1,287,175 in phase II.

Table II.2: NCADI Publication Distribution Pre-Campaign and Phases I and II
Appendix III

Comments From the Office of National Drug

Control Policy

Page 86 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

Now on pp. 43-51.

Now on p. 34.

Now on p. 36.

Now on p. 39.
Appendix III

Comments From the Office of National Drug Control Policy

Page 87 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

Now on pp. 57-61.

Now on p. 51.
Appendix III

Comments From the Office of National Drug Control Policy

Page 88 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

Now on pp. 62-63.

Now on pp. 67-78.

Now on p. 76.
Appendix III

Comments From the Office of National Drug Control Policy

Page 89 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

We did not reproduce

attachment B.
Appendix III

Comments From the Office of National Drug Control Policy

Page 90 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign
Appendix IV

GAO Contacts and Staff Acknowledgments

Page 91 GAO/GGD/HEHS-00-153 Anti-Drug Media Campaign

Richard L. Stana (202) 512-8816

Daniel Harris (202) 512-8720

In addition to the persons named above, the following persons made key

contributions to this report: Doris Page, Jared Hermalin, Amy Lyon, Wendy

Ahmed, David Alexander, Louise DiBenedetto, Nancy Finley, Michael

Little, Sidney H. Schwartz, Rebecca Shea, and Keith Wandtke.

GAO Contacts

Acknowledgments
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