JUSTICE GRANT 

PROGRAMS

DOJ Should Do More 

to Reduce the Risk of 

Unnecessary 

Duplication and 

Enhance Program 

Assessment

Report to Congressional Committees

July 2012

GAO-12-517

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-517, a report to 

congressional committees

July 2012

JUSTICE GRANT PROGRAMS

DOJ Should Do More to Reduce the Risk of 

Unnecessary Duplication and Enhance Program 

Assessment

Why GAO Did This Study

Since fiscal year 2005, approximately 

$33 billion has been appropriated to 

DOJ for the administration of more 

than 200 federal financial assistance

solicitations, such as grants, that 

support criminal justice activities at the 

state and local levels. Pursuant to 

section 21 of Public Law 111-139, this 

report addresses the extent to which 

(1) overlap exists across DOJ grant 

programs and if it contributes to the

risk of unnecessary duplication in grant 

awards, (2) DOJ has taken steps to 

reduce overlap and the potential for

unnecessary duplication in its grants 

awards, and (3) DOJ uses monitoring 

and assessment to determine grant 

program effectiveness and uses the 

results to enhance its grant programs. 

GAO assessed DOJ’s fiscal year 2010 

announcements of grant award

funding; categorized them according to 

key justice areas to identify any 

overlap; and interviewed DOJ officials 

about their grant making practices, 

systems, and assessment methods. 

Further, GAO interviewed officials from 

11 states receiving DOJ grants, 

selected for the levels and types of 

funding received. Though not 

generalizable, the interviews provided 

their perspectives on funding. 

What GAO Recommends

GAO recommends, among other 

things, that the department assess its 

grant programs for overlap, ensure its 

comprehensive study of DOJ grant 

management systems also includes an 

analysis of steps necessary to 

harmonize business processes, and 

examine its mix of grant monitoring 

and program assessment activities. 

DOJ agreed with GAO’s

recommendations.

What GAO Found

The Department of Justice’s (DOJ) grant programs overlap across 10 justice 

areas contributing to the risk of unnecessarily duplicative grant awards for the 

same or similar purposes. For example, GAO reviewed all 253 grant award 

announcements that DOJ’s Office of Justice Programs (OJP), the Office on 

Violence Against Women (OVW), and the Community Oriented Policing Services 

(COPS) Office published on their websites for fiscal year 2010 and found overlap 

across the justice areas. For example, 56 of DOJ’s 253 grant solicitations—or 

more than 20 percent—were providing grant funds for victim assistance and 

related research. GAO also found instances where applicants used the same or 

similar language to apply for funding from these overlapping programs. In one 

example, a grant recipient applied for, and received, funding from both OJP’s 

Internet Crimes Against Children program and the COPS Office’s Child Sexual 

Predator Program to provide training for cyber crime investigations and establish 

an Internet safety program. In some instances, DOJ may deem it appropriate for 

distinct grant programs to serve one goal, or for one community or grantee to 

benefit from multiple streams of grant funding. However, DOJ generally lacks 

visibility over the extent to which its grant programs overlap and thus is not 

positioned to minimize the risk of potential, unnecessary duplication before 

making grant awards. 

DOJ has taken some actions that address overlap in its grant programs; for 

example, by requesting statutory authorization in some instances to consolidate 

programs that are similar. However, DOJ has not conducted an assessment of its 

grant programs to systematically identify and reduce overlap. Doing so would 

enable DOJ to identify program areas where overlap may be desirable and 

where a consolidation of programs may be more efficient. Further, OJP and 

OVW use a separate grants management system than the COPS Office uses, 

limiting their ability to share information on the funding they have awarded or are 

preparing to award to a recipient. According to COPS Office officials, its mission

and grant management processes are unique enough to necessitate a separate 

system. However, OJP officials told GAO that its system has been and can be 

modified with minimal investment to accommodate different grant processes.

DOJ has initiated a study to assess the feasibility, costs, and benefits of unifying 

the systems among other options. By ensuring that such a study accounts for the

effort necessary to harmonize departmental grant processes, DOJ could ensure 

that variations in such processes do not encumber system unification. 

DOJ’s Office of Audit, Assessment, and Management (OAAM) oversees

monitoring of grantees’ compliance and conducts grant program assessments to 

gauge program effectiveness. GAO found that OAAM’s program assessments 

yield richer information than its monitoring reports because they identify

improvement areas. OAAM officials believe additional assessments could be 

beneficial. They also said they lacked resources to conduct more, but had not 

conducted a feasibility analysis to confirm this. By OAAM examining its mix of 

monitoring and assessment activities, including the costs and benefits of current

resource allocations, it could better ensure continuous improvement in grant 

programs.

View GAO-12-517. For more information, 

contact David C.Maurer at (202) 512-9627 or 

maurerd@gao.gov.
Page i GAO-12-517 DOJ Grants Management

Letter 1 

Background 6

DOJ Grant Programs Overlap, Contributing to the Risk of 

Unnecessarily Duplicative Grant Awards for the Same or Similar 

Purposes 12

DOJ Has Taken Actions That Address Overlap in Grant Programs 

but Could Further Reduce the Risk of Unnecessary Duplication 

in Grant Funding 20

DOJ Could Benefit from Examining Its Programmatic Grant 

Monitoring and Assessment Functions and Considering 

Expansion of OAAM’s Authorities 36

Conclusions 47

Recommendations for Executive Action 49

Agency Comments and Our Evaluation 50

Appendix I Objectives, Scope, and Methodology 56

Appendix II DOJ Granting Agencies’ Organizational Structure 59

Appendix III Structure, Purpose, and Funding of DOJ Granting Agencies 60

Appendix IV Consolidated, Braided, and Blended Grant Program Solicitations 62

Appendix V Office of Audit Assessment and Management Structure 65

Appendix VI Comments from the Department of Justice 67

Appendix VII GAO Contact and Staff Acknowledgments 74

Contents
Page ii GAO-12-517 DOJ Grants Management

Tables 

Table 1: Types and Examples of Federal Financial Assistance 7

Table 2: Breakdown of Fiscal Year 2010 DOJ Grant Solicitations by 

Granting Agency and Justice Area 14

Table 3: Consolidation and Coordination of DOJ Grant Programs 

and Illustrative Examples 21

Table 4: Comparison of Programmatic Grant Monitoring and 

Program Assessment Activities 38

Table 5: Comparison of OVW and OAAM Measurement of Grant 

Program Effectiveness 45

Figures

Figure 1: DOJ Grant Funding Appropriated from Fiscal Years 2005 

through 2012 8

Figure 2: Grant Life Cycle of Federal Awarding Agency 9

Figure 3. DOJ Grant and Subgrant Award Information Flow to 

USASpending.gov 34

Figure 4: Consolidated Grant Programs 62

Figure 5: Braided Grant Programs 63

Figure 6: Blended Grant Programs 64
Page iii GAO-12-517 DOJ Grants Management

Abbreviations

BJA Bureau of Justice Assistance

BJS Bureau of Justice Statistics

CMS COPS Management System 

COPS Community Oriented Policing Services

CSPP Child Sexual Predator Program

CTAS Coordinated Tribal Assistance Solicitation

DHS Department of Homeland Security

DOJ Department of Justice

FEMA Federal Emergency Management Agency

FFATA Federal Funding Accountability and Transparency 

 Act 

FMIS 2 Financial Management Information System 2

GAT Grant Assessment Tool

GMS Grants Management System 

GSA General Services Administration

ICAC Internet Crimes Against Children

IG Inspector General

JAG Edward Byrne Memorial Justice Assistance Grant 

NIJ National Institute of Justice

OAAM Office of Audit, Assessment, and Management

OJJDP Office of Juvenile Justice and Delinquency 

 Prevention

OJP Office of Justice Programs

OMB Office of Management and Budget

OVC Office for Victims of Crime

OVW Office on Violence Against Women

PAD Program Assessment Division

SAA state administering agency

VAWA Violence Against Women Act

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Page 1 GAO-12-517 DOJ Grants Management

United States Government Accountability Office

Washington, DC 20548

July 12, 2012

Congressional Committees

Since fiscal year 2005, approximately $33 billion has been appropriated1

to support crime prevention, law enforcement, and crime victim services 

through more than 200 federal financial assistance programs that the 

U.S. Department of Justice (DOJ) manages.2 In fiscal year 2010, DOJ 

awarded nearly $3.6 billion in grants through its three granting agencies—

the Office of Justice Programs (OJP), the Office on Violence Against 

Women (OVW), and the Community Oriented Policing Services (COPS) 

Office. Many of the grant programs that OJP, OVW, and the COPS Office 

administer are, pursuant to their originating statutes, similar in scope, and 

grant applicants can apply for and receive grant awards from more than 

one program. Moreover, statutes may also require that grant recipients 

award a portion of their grants to subgrantees. Where statutes do not 

require subgranting, a grantee may voluntarily choose to award all or a 

portion of its funds to subgrantees.3

 

1

In addition to fiscal year funding from 2005 through 2012, this amount includes $4 billion 

appropriated in fiscal year 2009 through the American Recovery and Reinvestment Act of 

2009 (Recovery Act) (Pub. L. No. 111-5, 123 Stat. 115, 129-30), which includes $10 

million for salaries and expenses to manage, administer, and oversee the grant programs. 

This approximate amount does not reflect amounts, if any, that have been rescinded, 

reprogrammed, or transferred. 

These subgrantees may also apply 

directly to DOJ for funding through other grant programs for purposes that 

are the same or similar to the purpose for which they received the 

subgrant. The number of grant programs and recipients, and the billions 

of dollars in funds awarded annually, present administrative challenges 

for DOJ.

2

Federal financial assistance programs provide funding pursuant to statutory authorization 

through formula grants, discretionary grants, cooperative agreements, and other payment 

programs, but are all generally referred to as grants. Formula grant programs are 

noncompetitive awards based on a predetermined formula, typically established in statute. 

Discretionary grants are usually awarded on the basis of a competitive selection process. 

A cooperative agreement is a type of federal financial assistance similar to a grant except 

the federal government is more substantially involved with the grant. Payment programs 

typically take the form of reimbursements to state and local law enforcement entities for 

purchases such as body armor. 

3

COPS Office, however, prohibits grantees from subawarding any portion of COPS Office 

grants.

 
 

Page 2 GAO-12-517 DOJ Grants Management

We have identified management of programs that support state and local 

crime reduction efforts as a major performance and accountability 

challenge for DOJ.4 We previously reported on evaluations of grant 

programs to assist communities in addressing gang problems, and the 

quality of DOJ’s tool to measure grantees’ performances under Recovery 

Act funding for one of OJP’s largest grant programs.5 Moreover, the DOJ 

Inspector General (IG) has listed grant management as one of the top 10 

challenges for DOJ every year from 2000 through 2011 and has identified 

overlap in grant programs and duplicative oversight and monitoring 

services. Specifically, a 2003 IG audit found overlap in grant programs 

between OJP and the COPS Office, which it noted resulted from statutes 

that created multiple grant programs to fund similar justice areas.6 The IG 

audit also found that no formal communication procedures between OJP 

and the COPS Office existed to ensure that grantees did not receive 

funds for similar purposes from both granting agencies and made 

recommendations to address this coordination issue as discussed later in 

this report. In addition, DOJ’s Acting IG testified in June 2011 that certain 

monitoring and oversight performed by OVW and the COPS Office are 

duplicative of services that are available through OJP.7

As the United States experiences budgetary constraints, there is an everincreasing need to ensure that governmental resources—including those 

awarded through grants and subgrants—are appropriately targeted and 

that overlap and unnecessary duplication are mitigated. In February 2012, 

we reported that DOJ had not assessed its grant programs to identify 

 

4

GAO, Major Management Challenges and Program Risks: Department of Justice, 

GAO-03-105 (Washington, D.C:. Jan. 1, 2003).

5

GAO, Community Policing Grants: COPS Grants Were a Modest Contributor to Declines 

in Crime in the 1990s, GAO-06-104 (Washington, D.C.; Oct. 14, 2005); Combating Gangs: 

Better Coordination and Performance Measurement Would Help Clarify Roles of Federal 

Agencies and Strengthen Assessment of Efforts, GAO-09-708 (Washington, D.C.: July 24, 

2009); and Recovery Act: Department of Justice Could Better Assess Justice Assistance 

Grant Program Impact, GAO-11-87 (Washington, D.C.: Oct. 15, 2010). 

6

U.S. Department of Justice Office of the Inspector General, Audit Division, Streamlining 

of Administrative Activities and Federal Financial Assistance Functions in the Office of 

Justice Programs and the Office of Community Oriented Policing Services, Audit Report 

03-27 (Washington D.C.: Aug. 2003).

7

Hearing before the U.S. House of Representatives Committee on Oversight and 

Government Reform Subcommittee on Technology, Information Policy, Intergovernmental 

Relations and Procurement Reform concerning Improving Oversight and Accountability in 

Federal Grant Programs, June 23, 2011.
 

Page 3 GAO-12-517 DOJ Grants Management

overlap and that DOJ did not routinely coordinate grant awards to avoid 

unnecessary duplication.8

To examine overlap and potential duplication within DOJ—and in support 

of our ongoing efforts to explore duplication, overlap, and fragmentation 

governmentwide

This report provides further elaboration on the 

February 2012 report’s findings, as well as addresses DOJ’s ability to 

assess the results of its grant programs.

9

Using the framework established in our prior work addressing overlap and 

duplication, we use the following definitions for purposes of assessing 

DOJ’s grant programs:

—this report addresses the following three questions: 

(1) To what extent does overlap across DOJ grant programs exist and 

contribute to the risk of unnecessary duplication in grant awards? (2) To 

what extent has DOJ taken steps to reduce overlap in its grant programs 

and the potential for unnecessary duplication in grant awards? (3) To 

what extent does DOJ use grant monitoring and assessment to determine 

grant program effectiveness and use the results to enhance its grant 

programs?

10

• Overlap occurs when multiple granting agencies or grant programs 

have similar goals, engage in similar activities or strategies to achieve 

these goals, or target the same or similar beneficiaries. Overlap may 

result from statutory or other limitations beyond an agency’s control.

• Duplication occurs on multiple levels. It occurs when a single grantee 

uses grant funds from different federal sources to pay for the exact 

same expenditure. Duplication also occurs when two or more granting 

agencies or grant programs engage in the same or similar activities or 

provide funding to support the same or similar services to the same 

beneficiaries. Duplication thus stems from overlap. When granting 

 

8

GAO, 2012 Annual Report: Opportunities to Reduce Duplication, Overlap, and 

Fragmentation, Achieve Savings, and Enhance Revenue, GAO-12-342SP (Washington, 

D.C.: Feb. 28, 2012).

9

We conducted this work in support of our mandate to conduct routine investigations to 

identify programs, agencies, offices, and initiatives with duplicative goals and activities 

within departments and governmentwide, and report annually to Congress. See Pub. L. 

No. 111-139, § 21, 124 Stat. 8, 29-30 (2010) (31 U.S.C. § 712 Note). As such, we 

included portions of this report in our 2012 annual report. See GAO-12-342SP. 

10GAO-12-342SP. 
 

Page 4 GAO-12-517 DOJ Grants Management

agencies do not identify overlap, assess its impact, or coordinate their 

activities in acknowledgment of the overlap, there is a heightened risk 

of unnecessary duplication because one granting agency may not 

be knowledgeable of the ways in which its funding decision duplicates 

another’s. At times, federal funding is leveraged by design to achieve

a single purpose through multiple federal funding streams. These 

funding arrangements are not characterized as unnecessary 

duplication for purposes of this review so long as federal agencies are 

aware of them or have deliberately planned for grant programs to be 

complementary.

To determine potential areas of overlap across DOJ’s grant programs, we 

identified a total of 253 DOJ grant solicitations—announcements to 

applicants of funding opportunities—for fiscal year 2010 by reviewing the 

solicitation lists posted on the OJP, OVW, and COPS Office websites and 

confirming the accuracy of the information with DOJ officials. We 

established 10 categories of criminal justice areas and then sorted the 

solicitations into each category to determine whether these solicitations 

were announcing grant funding available for similar purposes. We 

developed these 10 categories after reviewing comparable justice areas 

identified within DOJ materials, such as a website it operates to discuss 

criminal justice research and strategic planning documents. After 

identifying solicitations with similar scopes, we reviewed a nonprobability 

sample of 26 successful grant applications that were awarded under 

similar solicitations to identify and assess specific examples of how the 

recipients planned to use funds from multiple programs in the same or 

similar manner and whether this creates the risk of unnecessary 

duplication in DOJ grant funding. The sample was selected based upon 

applicants receiving multiple grant awards from overlapping grant 

programs. The sample we reviewed is not generalizable to all DOJ grant 

programs because an ideal sample size based upon nearly 11,000 

funded grant applications was impractical to select, review, and analyze. 

However, the results from our sample illustrate the potential for 

unnecessary duplication.

To examine the extent to which DOJ has taken action to reduce or 

mitigate overlap and ensure that DOJ does not unnecessarily award 

funds from multiple grant programs to support similar purposes, we 

analyzed agency policies, procedures, and guidance, current as of 2012, 

on grant program design and award, such as the OJP Grant Manager’s 

Manual. In addition, we interviewed DOJ officials from OJP, OVW, and 

the COPS Office to discuss, among other topics, their grant program 

design and award processes and the extent to which they coordinate and 
 

Page 5 GAO-12-517 DOJ Grants Management

share information with one another. We also visited or conducted phone 

interviews with officials from 11 states to discuss the type and timeliness 

of information on grant awards and subawards that they provide to or 

receive from DOJ.11 We selected these states based on the amount of 

Edward Byrne Memorial Justice Assistance Grant (JAG) funding they 

receive and the existence of other recipients in their communities 

receiving DOJ discretionary grants for potentially similar purposes.12 The 

results of these contacts are not generalizable to all states, but provided 

insight into how DOJ grant funds were used locally and communication 

occurred between states and DOJ. We also compared agency grant 

design and award practices against Standards for Internal Control in the 

Federal Government and promising practices identified in the Domestic 

Working Group Grant Accountability Project’s Guide to Opportunities for 

Improving Grant Accountability.

13

To analyze the extent to which DOJ uses grant monitoring and 

assessment to determine program effectiveness and uses the results to 

enhance its grant programs, we analyzed DOJ documentation, such as 

assessments DOJ conducted of its programs and specific programmatic 

grant monitoring reports.14

 

11We selected California, Florida, New York, North Dakota, Pennsylvania, South Dakota, 

Rhode Island, Tennessee, Texas, Vermont, and Wyoming.

We also interviewed DOJ officials from the 

12DOJ established the JAG program following enactment of the Violence Against Women 

and Department of Justice Reauthorization Act of 2005, which merged the Edward Byrne 

Memorial State and Local Law Enforcement Assistance Program with the Local 

Government Law Enforcement Block Grants Program. See Pub. L. No. 109-162, § 1111, 

119 Stat. 2960, 3094-3102 (2006). The JAG program is the leading source of federal 

justice funding to state and local jurisdictions. JAG provides funding to support a range of 

program areas, including law enforcement; prosecution and courts; prevention and 

education; corrections and community corrections; drug treatment and enforcement; 

planning, evaluation, and technology improvement; and crime victim and witness 

initiatives. The program provides 60 percent of the JAG awards directly to the state 

agencies that administer JAG funds—known as state administering agencies (SAA)—and 

40 percent of the awards directly to local units of government. Local recipients of JAG 

funding can receive money either as a direct payment from the JAG program, as a passthrough from the SAA, or, in some cases, from both the program and the SAA.

13GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999); Domestic Working Group, Grant Accountability 

Project, Guide to Opportunities for Improving Grant Accountability (Washington, D.C.: 

October 2005).

14Programmatic monitoring is conducted by federal grant program staff and includes, 

among other requirements, a general review of grant compliance and grantee progress.
 

Page 6 GAO-12-517 DOJ Grants Management

granting agencies, including those tasked with assessment, as well as 

grantees responsible for measuring the effectiveness of grant programs 

for OVW.

We conducted this performance audit from May 2011 to July 2012 in 

accordance with generally accepted government auditing standards.15

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

sufficient, appropriate evidence to provide a reasonable basis for our 

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

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. Appendix I contains further 

information on our scope and methodology.

DOJ awards federal financial assistance to state and local governments, 

for-profit and nonprofit organizations, tribal jurisdictions, and educational 

institutions to help prevent crime, assist victims of crime, and promote 

innovative law enforcement efforts. Federal financial assistance can take 

the form of discretionary grants, formula grants, cooperative agreements, 

and payment programs, which all are generally referred to as grants. 

Grant programs are generally created by statute and funded through 

annual appropriations. As such, Congress has a central role in 

determining the scope and nature of federal financial assistance 

programs. In addition, the Office of Management and Budget (OMB) 

establishes general guidance which governs administration of all such 

federal financial assistance and DOJ has flexibility in how to administer 

assistance that is discretionary in nature.

In fiscal year 2010, DOJ provided direct grant funding to nearly 11,000 

grantees.16

 

15We reported some of our findings in February 2012. See 

Table 1 describes the various forms of federal financial 

assistance.

GAO-12-342SP. 

16Grant recipients awarded funds directly from OJP and OVW may in turn award them to 

subrecipients. The COPS Office Prohibits subawarding. In the case of the JAG State 

program, for example, grantees are required to pass through—or award through a 

subgrant—a predetermined portion of the funding to local communities. Direct grant 

funding includes all funding awarded by DOJ, including awards made to recipients from 

DOJ’s various payment programs. 

Background 
 

Page 7 GAO-12-517 DOJ Grants Management

Table 1: Types and Examples of Federal Financial Assistance 

Types of assistance Examples 

Discretionary grant: Applicants generally compete for funding 

that agencies award at their discretion. 

Enhanced Collaborative Model to Combat Human Trafficking funds 

sites that use a comprehensive approach to combating all forms of 

trafficking—sex trafficking and labor trafficking of foreign nationals 

and U.S. citizens (male and female, adults and minors). 

Formula grant: Recipients and award amounts are generally 

based on statutorily defined calculations that may incorporate 

a state’s population and violent crime rate. Formula grants are 

usually administered and managed by state administering 

agencies. States use part of their grant to pass through their 

funds to local subrecipients. These subrecipients may be 

nonprofit organizations or other units of government.

Formula grants can take the form of either block grants or 

categorical grants. Block grants are generally broad in scope 

and allow the states discretion in the use of the grant funds. 

Categorical grants are generally limited to more narrowly 

defined activities.

Edward Byrne Memorial JAG State Grant Program supports all 

components of the criminal justice system, from multijurisdictional 

drug and gang task forces to crime prevention and domestic violence 

programs, courts, corrections, treatment, and justice informationsharing initiatives. JAG-funded projects may address crime through 

the provision of services directly to individuals or communities and by 

improving the effectiveness and efficiency of criminal justice systems, 

processes, and procedures. 

Cooperative agreements: Typically awarded at DOJ’s 

discretion. According to OJP, a cooperative agreement is a 

legal instrument that permits DOJ to transfer money or 

something of value to accomplish a public purpose of support 

authorized by federal statute and used when substantial 

involvement of DOJ may be required in completion of the 

grantee’s activity.

Violence Against Women Act (VAWA) Measuring Effectiveness 

Initiative supports, among other things, the collection and 

documentation of performance information to measure the work of 

OVW grantees nationwide.

Payment programs: Provide recipients with funds for specific 

purposes. These are unique types of programs that provide 

funds for designated purposes and do not involve activities 

after the funding has been awarded. 

Southwest Border Prosecution Initiative reimburses state and local 

governments for their costs associated with the prosecution and 

pretrial detention of federally initiated criminal cases that are declined 

by U.S. Attorneys’ offices and referred to state and local jurisdictions 

for prosecution. 

Source: GAO analysis of DOJ information.

DOJ administers its grant programs through three granting agencies—

OJP, OVW, and the COPS Office. Appendix II illustrates this organization. 

OJP is the largest of DOJ’s granting agencies and in fiscal year 2011 had 

approximately $2.4 billion in funding for grants. Its mission to develop the 

nation’s capacity to prevent and control crime, administer justice, and 

assist crime victims is broader than that of OVW or the COPS Office. For 

example, OJP’s bureaus and offices administer grant programs that 

address victim assistance, technology and forensics, and juvenile justice, 

among other things. The COPS Office had approximately $495 million in 

funding for grants in fiscal year 2011, and its grant programs focus on 

advancing community policing. OVW had approximately $420 million for 

grant awards in fiscal year 2011. OVW administers grant programs 

related to domestic violence, dating violence, sexual assault, and stalking. 

Trends in amounts appropriated to these DOJ components since fiscal 

year 2005 for grant funding are illustrated in figure 1. For additional 
 

Page 8 GAO-12-517 DOJ Grants Management

information on the structure, purpose, and funding of DOJ granting 

agencies, see appendix III.

Figure 1: DOJ Grant Funding Appropriated from Fiscal Years 2005 through 2012 

Note: Funding levels in fiscal year 2009 include amounts appropriated through the American 

Recovery and Reinvestment Act of 2009. See Pub. L. No. 111-5, 123 Stat. 115, 129-30. These

amounts do not reflect any applicable rescinded, reprogrammed, or transferred funding.
 

Page 9 GAO-12-517 DOJ Grants Management

The grants that OJP, OVW, and the COPS Office award generally follow 

a similar life cycle, including pre-award, award, implementation, and 

closeout stages, which is shown in figure 2.17

Figure 2: Grant Life Cycle of Federal Awarding Agency

 

17GAO, Federal Grants: Improvements Needed in Oversight and Accountability 

Processes, GAO-11-773T (Washington, D.C.: June 23, 2011). 

The Grant Life Cycle
 

Page 10 GAO-12-517 DOJ Grants Management

In the pre-award phase for a competitive grant, the agency announces 

the grant opportunity with a grant solicitation, which notifies potential 

applicants of the grant’s purpose, the terms of the award, the amount 

available, and the eligibility criteria, among other information. During the 

pre-award phase, the agency also receives and reviews applications and 

makes award decisions based on requirements set by statute and the 

grantor agency, as appropriate. Once the agency makes the award, it 

must report the grant information to USAspending.gov.18

During the implementation stage, the agency is responsible for monitoring 

the grant. After the end date of a grant, the closeout process should 

ensure that each recipient has met all of the grant’s financial 

requirements, returned any unused funds, and provided final reports. OJP 

and OVW use a web-based system—the Grants Management System 

(GMS)—to manage this process, while the COPS Office uses a separate 

COPS Management System (CMS), which is a desktop application that 

communicates with a centralized database. In our June 2011 report on 

the grant life cycle, we noted that effective internal control systems are 

important at each stage in the process.19

OJP, OVW, and the COPS Office are responsible for monitoring their 

grants to ensure that the grants are being implemented as intended and 

that grantees are compliant with statutory or regulatory requirements as 

well as any applicable policy guidelines. The granting agencies conduct 

programmatic grant monitoring by collecting information through 

telephone calls to grantees, file reviews of the documents and reports that 

grantees submit, and on-site visits to monitor grantees’ activities at their 

locations. OJP’s Office of the Chief Financial Officer provides fiscal policy 

guidance and financial monitoring of grantees for the three agencies. 

 

18OMB established USASpending.gov in 2007 to comply with the Federal Funding 

Accountability and Transparency Act (FFATA) of 2006. See Pub. L. No. 109-282, § 2, 120 

Stat. 1186. FFATA required OMB to ensure the existence and operation of a single 

searchable website that includes for each federal award: (1) the name of the entity 

receiving the award, (2) the amount of the award, (3) information on the award including 

transaction type and funding agency, (4) the location of the entity receiving the award and 

the primary location of performance under the award, and (5) a unique identifier of the 

entity receiving the award; among other information. As of October 2010, 

USASpending.gov has been updated to include first-tier subaward data, such as 

subawards states may distribute using a DOJ grant that was awarded to the state.

19GAO-11-773T. 

Grant Monitoring and 

Assessment
 

Page 11 GAO-12-517 DOJ Grants Management

Financial monitoring generally consists of reviewing expenditures of 

grantees compared with their approved budgets and allowable grant 

expenditures, and reviewing compliance with grant requirements such as 

the submission of required grant reports.

In addition, pursuant to the Violence Against Women Act of 2000, the 

Attorney General reports biennially on the effectiveness of OVW grantee 

activities carried out with VAWA grant funds.20 To meet this requirement, 

OVW entered into a cooperative agreement with a university to develop 

and implement reporting tools to measure the effectiveness of projects 

and activities that OVW funds through its grants. In 2006, the Violence 

Against Women and Department of Justice Reauthorization Act of 2005, 

established an Office of Audit, Assessment, and Management (OAAM) 

within OJP and gave it statutory authority to provide additional oversight 

for OJP and the COPS Office programs, as well as any other DOJ grant 

program the Attorney General considers appropriate.21

Currently, OAAM oversees OJP and the COPS Office granting activities. 

According to OJP, among its other activities, OAAM has the following four 

main responsibilities (see app. V for more details):

DOJ’s Acting 

Associate Attorney General approved the organizational structure of 

OAAM in 2007, the same year the office became operational and was 

staffed. The office was not fully staffed until 2009, but OJP reports that as 

of May 2012, its staff level is 20 percent below the office’s authorized 

number of positions.

1. ensures financial grant compliance and auditing of OJP’s internal 

controls to prevent waste, fraud, and abuse;

 

20Specifically, the Violence Against Women Act of 2000 provided that the Attorney 

General or Secretary of Health and Human Services, as applicable, shall require grantees 

under any program authorized or reauthorized under the act to report on the effectiveness 

of the activities carried out with amounts made available for the program. See Pub. L. No. 

106-386, Div. B, § 1003(a), 114 Stat. 1464, 1491 (2000) (codified at 42 U.S.C. § 

3789p(a)). It further required the Attorney General or Secretary, as applicable, to report 

biennially to the Committees on the Judiciary of the Senate and House of Representatives 

on the grant programs described, including any information reported by grantees. See 42 

U.S.C. § 3789p(b).

21See Pub. L. No. 109-162, § 1158, 119 Stat. 2960, 3114-16 (2006) (codified as amended 

at 42 U.S.C. § 3712h).
 

Page 12 GAO-12-517 DOJ Grants Management

2. conducts program assessments of OJP and COPS Office grant 

programs;

3. oversees programmatic monitoring activities of OJP and COPS Office; 

and

4. serves as a central source for OJP grant management policy.

We reviewed all 253 of the fiscal year 2010 grant solicitations that OJP, 

OVW, and the COPS Office published on their respective websites and 

found overlap across 10 justice areas—as table 2 illustrates. These 

solicitations announced funding available to grantees for criminal and 

juvenile justice activities, including direct assistance for crime victims and 

the hiring of police officers. These solicitations also announced funding 

available for grantees to collect criminal justice data, conduct research, or 

provide related training and technical assistance.22

 

22The 253 solicitations that we reviewed in August 2011 represent those for new grant 

programs available in fiscal year 2010 that agency officials told us were archived on their 

websites. These solicitations are in addition to grant programs that DOJ continues to 

administer from prior fiscal years or more recently began administering. Because DOJ’s 

grant awards can last from 1 to 5 years, the total number of active DOJ grant programs 

can be higher than what is presented in table 2, which is a single year of grant program 

solicitations.

We developed these 

10 categories of justice areas after reviewing comparable justice areas 

identified within OJP’s CrimeSolutions.gov website, which OJP officials 

stated covers a variety of justice topics, including some topic areas that 

OVW and the COPS Office fund; OJP’s Fiscal Year 2010 Program Plan; 

and other materials from OVW and the COPS Office, such as justice 

DOJ Grant Programs 

Overlap, Contributing 

to the Risk of 

Unnecessarily 

Duplicative Grant 

Awards for the Same 

or Similar Purposes

DOJ’s Grant Solicitations 

Overlap across 10 Key 

Justice Areas
 

Page 13 GAO-12-517 DOJ Grants Management

program themes from their respective websites. Within the justice areas, 

a variety of activities—including research, direct service provision, or 

technical assistance—can be conducted. We examined the purpose 

areas of the 253 grant solicitations and then categorized them by justice 

area.

In conducting this analysis, we recognize that overlapping grant programs 

across common programmatic areas result in part from authorizing 

statutes, and that overlap itself may not be problematic. However, the 

existence of overlapping grant programs is an indication that agencies 

should increase their visibility of where their funds are going and 

coordinate to ensure that any resulting duplication in grant award funding 

is purposeful rather than unnecessary. Overlap and the associated risk of 

unnecessary duplication occur throughout the government, as we have 

reported previously, and are not isolated to DOJ.23

 

23

However, when 

coupled with consistent programmatic coordination, the risk of 

unnecessary duplication can be diminished.

GAO-12-342SP. 
 

Page 14 GAO-12-517 DOJ Grants Management

Table 2: Breakdown of Fiscal Year 2010 DOJ Grant Solicitations by Granting Agency and Justice Area

Justice Area

Component 

/ program 

office

Victim 

assistance

Technology 

and 

forensics

Juvenile 

justice

Enhancing 

policing 

Justice 

information 

sharing Courts

Community

crime 

prevention 

strategies

Mental 

illness, 

substance 

abuse, 

and crime

Corrections, 

recidivism, 

and reentry

Multipurpose Total a

COPS 0 1 0 2 0 0 3 1 0 0 7 

Joint 0 b 0 1 0 0 0 0 0 2 3 6 

OVW 15 0 0 0 0 1 0 0 0 1 17

OJPc

BJA 2 2 0 7 3 7 3 6 7 5 42

BJS 5 2 2 3 6 4 1 1 4 2 30

CCDO 0 d 0 0 0 0 0 2 0 0 0 2 

NIJ 3 36 0 4 0 1 4 0 5 8 61

OJJDP 8 0 30 7 1 8 4 0 0 3 61

OVC 23 0 0 0 0 0 0 0 0 0 23

SMART 0 0 0 0 2 0 0 0 2 0 4 

Total 

solicitations

56 41 33 23 12 21 17 8 20 22 253

Total award 

amount (in 

millions)

$872 

e

$325 $264 $386 $98 $77 $77 $53 $430 $810 $3,393f

Source: GAO analysis of DOJ information.

Notes: Solicitations in this table reflect those for direct assistance, such as funds DOJ provides for the 

hiring of police officers, as well as those for research, data collection, and technical assistance on the 

related justice areas.

a

Multipurpose solicitations were solicitations for grants that addressed more than one justice area 

within a single solicitation.

b

Joint refers to solicitations issued jointly by multiple program offices, components, or departments 

(e.g., DOJ and the Department of Health and Human Services, or DOJ’s Bureau of Justice 

Assistance and Office of Juvenile Justice and Delinquency Prevention).

c

OJP is composed of a number of smaller bureaus and offices. BJA is the Bureau of Justice 

Assistance; BJS is the Bureau of Justice Statistics; CCDO is the Community Capacity Development 

Office; NIJ is the National Institute of Justice; OJJDP is the Office of Juvenile Justice and

Delinquency Prevention; OVC is the Office for Victims of Crime; and SMART is the Sex Offender 

Sentencing, Monitoring, Apprehending, Registering, and Tracking Office.

d

Federal funding reductions in fiscal year 2011 included CCDO’s Weed and Seed Program. Without 

funding for this program, CCDO closed, and all remaining open, active CCDO grants were transferred 

to and are presently managed by BJA effective June 6, 2011.

e

Actual amount awarded to grantees in millions. Total award amounts will not sum because of 

rounding.

f

This amount excludes benefits paid through DOJ’s Public Safety Officers’ Benefits Program.
 

Page 15 GAO-12-517 DOJ Grants Management

As table 2 illustrates, we found overlap across the various DOJ grant 

programs. For example, 56 of DOJ’s 253 grant solicitations—or more 

than 20 percent—were providing grant funds available for activities 

related to victim assistance or to support the research and prevention of 

violence against women. Eighteen of these 56 programs were 

administered by offices other than OVW and OJP’s Office for Victims of 

Crime.24

There are some instances in which overlap occurs because of the statute 

that established programs. Further, we recognize that overlap among 

DOJ’s grant programs may be desirable because such overlap can 

enable DOJ’s granting agencies to leverage multiple funding streams to 

serve a single justice purpose. However, coordination across the 

administering granting agencies is critical for such leveraging to occur. In 

the section below, we discuss the ways in which overlapping grant 

programs increase the risk of unnecessarily duplicative grant awards for 

the same or similar purposes. In subsequent sections, we discuss the

steps DOJ has taken to enhance coordination and some ways in which 

DOJ’s efforts can be improved. 

In addition, more than 50 percent of all grant solicitations 

provided funding that could be used in support of the same three justice 

areas—victim assistance, technology and forensics, and juvenile justice—

indicating concentrated and overlapping efforts. The justice area with the 

least overlap was juvenile justice, with 30 of 33 grant programs 

administered by the Office of Juvenile Justice and Delinquency 

Prevention.

We found that in some instances, DOJ’s granting agencies awarded 

multiple grants to the same grantees for the same or similar purposes. 

Applicants can apply directly to DOJ for funding through a variety of grant 

programs that DOJ announces annually. Recipients of such grant awards 

are referred to as prime grantees. Since many of DOJ’s grant programs 

allow prime grantees to award subgrants, applicants also can apply 

directly to a prime grantee for award funding. As a result, prime grantees 

receiving money from DOJ through one funding stream also can be 

 

24OVW’s mission is to provide federal leadership in developing the nation’s capacity to 

reduce violence against women and administer justice for and strengthen services to 

victims of domestic violence, among others. OVC’s mission is to enhance the nation’s 

capacity to assist crime victims and to provide leadership in changing attitudes, policies, 

and practices to promote justice and healing for all victims of crime. 

In Some Instances, DOJ 

Awarded Grant Funding 

from Overlapping 

Programs to the Same 

Applicants for the Same or 

Similar Purposes
 

Page 16 GAO-12-517 DOJ Grants Management

subgrantees receiving money from a prime grantee through another 

funding stream. If an applicant, either as a prime grantee or as a 

subgrantee, receives multiple grant awards from overlapping programs, 

the risk of unnecessary duplication increases since the applicant may 

receive funding from more than one source for the same or similar 

purpose without DOJ being aware that this situation exists. Such 

duplication may be unnecessary if, for example, the total funding received 

exceeds the applicant’s need, or if neither granting agency was aware of 

the original funding decision.

After reviewing a sample of 26 grant applications from recipients who 

received funds from grant programs we identified as having similar 

purpose areas, we found instances where applicants used the same or 

similar language to apply for multiple streams of funding. For example, 

one grant recipient applied for funding to reduce child endangerment 

through cyber investigations from both the COPS Office’s Child Sexual 

Predator (CSPP) Program25

After we shared these examples with DOJ, DOJ officials followed up with 

the grant recipients involved and reported to us that the grantees were 

not using awarded funds for duplicative purposes—which DOJ defines as 

grantees using funds to pay for the exact same item. However, such 

follow-up for the purpose of assessing duplication is not a routine practice 

and OJP’s Internet Crimes Against Children 

(ICAC) program. In both of these applications, the applicant stated that it 

planned to use the grants to increase the number of investigations in the 

state, provide training for cyber crime investigations, serve as a forensic 

resource for the state, and establish an Internet safety program. Further, 

included in this applicant’s proposed budgets for both funding streams 

were plans to purchase equipment, such as forensic computers and the 

same specialized software to investigate Internet crimes against children. 

Another grant recipient from a different jurisdiction also applied for 

funding from OJP and the COPS Office programs to support the same 

types of investigations. In a third instance, an applicant received fiscal 

year 2010 grant funding for planned sexual assault victim services from 

both OJP’s Office for Victims of Crime and OVW. The applicant used 

similar language in both applications, noting that it intended to use the 

funding to support child victim services through its child advocacy center.

 

25DOJ’s fiscal year 2013 performance budget justification does not include a request for 

funding to continue this grant program.
 

Page 17 GAO-12-517 DOJ Grants Management

for DOJ. Further, DOJ’s narrow definition of duplication curtails it from 

assessing the use of funds for the same or a similar overall purpose on a 

grant project.

In fiscal year 2010, DOJ’s three granting agencies awarded nearly 11,000 

prime grant awards,26 but officials told us that they do not consider the 

flow of grant funds to subgrantees when making grant award decisions.27

Because DOJ does not have visibility of the flow of funds to these 

recipients, agency officials were not positioned to tell us what activities, or 

for what purposes, the subgrantees were spending their federal funds. 

Thus, to obtain more information, we surveyed JAG SAAs, who are 

responsible for managing the subgrants they make, to obtain information 

related to the purpose areas of their funding.28

In our survey, we asked the JAG SAAs if they or their subgrantees used 

grant funding in fiscal year 2010 for key justice areas such as funding sex 

offender registry notification systems; correctional officer salaries, and 

sexual assault services; purchasing bullet-resistant vests; and hiring 

police officers. DOJ supports all of these areas through JAG, as well as 

through targeted grant programs specifically addressing each of these 

topics. On the basis of survey responses, we found several instances 

where SAAs reported that JAG funds were used to support activities that 

could have been funded through other DOJ grants. For instance, 11 of 50 

responding SAAs, or 22 percent, reported that they or their subgrantees 

used JAG funding to support correctional officer salaries. Further, 23 of 

 

26This number includes all formula, discretionary, and payment program awards.

27The public website USASpending.gov is designed to make such information transparent.

28Survey of Indigent Defense Funding from Byrne Memorial Justice Assistance Grants, 

GAO (2012). This survey and the results are published in Indigent Defense: Surveys of 

Grant Recipients, Select Tribes, and Indigent Defense Providers GAO-12-661SP, May 

2012, an E-supplement to GAO-12-569, GAO-12-661SP (Washington, D.C. May 30, 

2012). The survey was conducted to support the GAO report: Indigent Defense: DOJ 

Could Increase Awareness of Eligible Funding and Better Determine the Extent to Which 

Funds Help Support This Purpose, GAO-12-569 (Washington, D.C.: May 9, 2012). 

“Indigent defense,” as we used the term in that report, refers to direct and indirect 

activities that help ensure indigent defendants are afforded counsel in criminal cases, and 

includes activities such as hiring additional public defenders, investigators, or other 

support staff; providing training for public defenders; and making technological 

improvements in defenders’ offices or systems. In fiscal year 2010, all SAA JAG 

recipients, except for U.S. territory SAAs, subawarded some of their awards. Thirty-two of 

the 50 state SAAs subawarded a majority of their JAG funding. More information on the 

survey is included in appendix I.
 

Page 18 GAO-12-517 DOJ Grants Management

the 50 SAAs, or nearly 50 percent, reported that they or their subgrantees 

used JAG funding to hire police officers, even though a separate DOJ 

program dedicates funding exclusively to hiring law enforcement 

personnel.29

The survey results indicate an increased risk of DOJ funding 

unnecessarily duplicative grant awards. If DOJ were aware that an 

applicant had received JAG funding through a subgrant to conduct 

community policing patrols, DOJ would be better positioned to decide 

whether that applicant should receive additional funding as a prime 

grantee from its community policing discretionary grant program. The 

results from our site visits confirmed this heightened risk. For example, in 

one state we visited, a county had received a JAG program subaward 

and used the funding for its officers to conduct community policing. The 

same county also received a COPS Office hiring grant and used the 

funding for an officer to conduct community policing.30

 

29Eight of the 50 responding SAAs, or about 16 percent, reported that they or their 

subgrantees used JAG funding to support sex offender registry and notification systems; 

11 out of the 50, or 22 percent, reported JAG funding was used to support sexual assault 

services; 15 out of the 50, or 30 percent, reported funding was used to support bulletresistant vest purchases. 

Additionally, the 

largest city in this county received a COPS Office hiring grant to conduct 

community policing. Because this city received the COPS Office funding 

to conduct community policing and grant-supported officers conducted 

patrols in geographical areas that overlapped with areas in the county 

already served by JAG-funded police officers, three DOJ grant awards 

were used to provide community policing to overlapping areas in the 

county. During the course of our audit work, COPS Office officials told us 

that community policing is not an activity but rather a philosophy for how 

policing should be conducted. As such, the officials consider multiple 

awards to the same communities to be complimentary. Since the COPS 

Office does not routinely consider the variety of federal funding that 

current and prospective grantees already use or may soon benefit from 

before making grant award decisions, they are not positioned to 

determine whether such funding arrangements are complementary. 

Further, officials from two additional counties in this state told us they 

30The COPS Office hiring grant awarded to this county was for fiscal year 2009. COPS 

Office hiring grants last up to 3 years, and the county used the grant in fiscal years 2010 

and 2011 as well. These grants support the hiring or the rehiring of career law 

enforcement officers to increase community policing and crime prevention strategies.
 

Page 19 GAO-12-517 DOJ Grants Management

received funding for drug court–assisted substance abuse treatment and 

mental health counseling through both a JAG program subaward and a 

grant directly from OJP’s Adult Drug Court Grant Program. Officials from 

one of these counties informed us that they received so much DOJ 

funding from the two grant programs that it exceeded the county’s need 

and they planned to return a portion to DOJ.31

The IG has previously identified the risk of OJP and the COPS Office 

funding duplicative grant awards. For example, in 2003, the IG identified 

duplication between the COPS Office Hiring Program and the Local Law 

Enforcement Block Grant Program, the predecessor to the JAG grant 

program. The IG reported that while the COPS Hiring Grant program is 

required to advance community policing, the Local Law Enforcement 

Block Grant Program grants are sometimes used for the same or similar 

purposes. According to the IG, in such cases the grants are duplicative.32

In 2010, the IG reported that it had identified potential overlap between 

the COPS Office Hiring Recovery Program and OJP’s JAG Formula 

Program and Edward Byrne Competitive Grant Program. As a result, the 

IG recommended that the COPS Office work with OJP to avoid 

duplication of future funding by coordinating closely on grantee selection 

decisions, as discussed later in this report.33

 

31According to DOJ officials, existing oversight mechanisms, such as programmatic and 

financial monitoring, as well as IG audits, help them ensure that grantees only expend 

federal financial assistance for allowable costs approved by DOJ in applicants’ budgets. 

32U.S. Department of Justice Office of the Inspector General, Audit Division, Streamlining 

of Administrative Activities and Federal Financial Assistance Functions in the Office of 

Justice Programs and the Office of Community Oriented Policing Services, Audit Report 

03-27 (Washington D.C.: Aug. 2003).

33U.S. Department of Justice Office of the Inspector General, Audit Division, A Review of 

the Selection Process for the COPS Hiring Recovery Program, Audit Report 10-25 

(Washington D.C.: May 2010).
 

Page 20 GAO-12-517 DOJ Grants Management

According to DOJ officials, the statutory creation of grant programs with 

similar purposes requires grant design coordination within and among 

DOJ’s granting agencies to limit the risk of unnecessary duplication from 

overlapping programs. The primary purpose of consolidation or 

coordination may not be to limit this risk, but officials reported that 

reducing the risk may be a secondary benefit. Officials from all three 

granting agencies stated that they meet with one another to coordinate 

the goals and objectives of their grant programs, especially joint grant 

programs that they believe are complementary. For example, the Bureau 

of Justice Assistance and the Office for Victims of Crime issued a joint 

solicitation for anti-human trafficking programs where each office issued 

separate awards based on coordinated proposals from collaborating 

police departments and community-based victim service organizations. 

Further, according to officials, DOJ recently launched the Coordinated 

Tribal Assistance Solicitation to provide a single application for most of 

DOJ’s tribal grant programs.

Consolidating two programs with similar purposes into one, with unified 

management, is the most comprehensive way to reduce overlap, 

according to DOJ officials. However, they stated that the statutory 

creation of grant programs with similar purposes can create 

administrative challenges because in many cases, DOJ must seek 

statutory authorization to discontinue or consolidate enacted programs 

that DOJ believes may be overlapping. Officials told us they have sought 

congressional action in a few instances for these purposes and will 

continue to do so, but because the process is complex, they have also 

taken administrative steps on an ad hoc basis to mitigate overlap of 

purpose areas as illustrated in table 3.

DOJ Has Taken 

Actions That Address 

Overlap in Grant 

Programs but Could 

Further Reduce the 

Risk of Unnecessary 

Duplication in Grant 

Funding 

DOJ Has Taken Some 

Action to Consolidate and 

Coordinate Similar Grant 

Programs
 

Page 21 GAO-12-517 DOJ Grants Management

Table 3: Consolidation and Coordination of DOJ Grant Programs and Illustrative Examples

Consolidation: Statutory authority is generally 

required to merge two or more existing grant 

programs. Once programs have been consolidated, a 

single DOJ office announces and manages the newly 

merged grant program.

• In accordance with DOJ’s fiscal year 2012 appropriations act, OVW will 

consolidate four existing youth victim-oriented grant programs into a 

single program.a

Coordination: Congressional action is not required, 

and officials explained two approaches they have 

taken to improve coordination. The first approach is 

“blending,” whereby DOJ coordinates grant 

management from within a single office while keeping 

funding streams from separate appropriations distinct. 

The second approach is “braiding,” whereby DOJ 

continues to manage the programs through separate 

offices and separate funding streams but issues a 

single grant announcement.

By creating one solicitation, an OVW official reported 

that the grant application process may be streamlined, and cost 

efficiencies related to reviewing applications may be achieved (see app.

IV for more details). 

• OJJDP coordinated 9 of its youth grant programs to create 1 grant 

program known as SafeFutures. The program assisted recipients and 

communities through a single program (see app. IV for more details).

• In fiscal year 2010, DOJ coordinated several of its tribal grant programs 

to create the Coordinated Tribal Assistance Solicitation (CTAS), which 

involves OJP’s, OVW’s, and the COPS Office’s tribal grant programs. 

The CTAS program combined 10 DOJ tribal grant program solicitations 

into 1 for purposes of streamlining the application and selection process, 

and OJP officials reported reducing the administrative burden on its 

applicants as a result. These programs continue to be managed by 

separate DOJ bureaus and offices (see app. IV for more details).

Source: GAO analysis of DOJ information.

a

See Pub. L. No. 112-55, Div. B, 125 Stat. 552, 612-13 (2011).

Officials stated that they meet with one another when they determine it is 

needed to coordinate the goals and objectives of their grant programs, 

especially those programs that they believe are complementary. In 

addition, an OJP official told us that in 2010 the office prioritized 

coordination as 1 of its 10 management goals and cited benefits that 

resulted from this focus, including reduced administrative costs, fewer 

grant solicitations, and a reduced number of competitive grant peer 

reviews. However, these officials told us that these coordination and 

consolidation efforts, as well as those illustrated in table 3, do not occur 

routinely.

Even with efforts to coordinate its programs, DOJ officials told us they 

have not conducted a formal assessment or study of their grant programs 

to determine if and to what extent they overlap and where opportunities 

exist to more consistently pursue consolidation or better coordinate grant 

programs. Further, we found that coordination among granting agencies 

occurred on an ad hoc basis and that without an assessment of its 

overlapping programs, DOJ was not well positioned to identify and 

describe areas of potential for unnecessary duplication across its grant 

programs.

DOJ Has Not Assessed Its 

Grant Programs to Identify 

and Reduce Overlap
 

Page 22 GAO-12-517 DOJ Grants Management

A senior OJP official told us that the department had not formally 

assessed or studied its grant programs to determine the extent of overlap 

because of the significant investment of time and staff resources that it 

would require. DOJ officials emphasized that since these programs were 

statutorily established as distinct programs, they are not certain that any 

attempt at harmonization—beyond what they have already done—would 

be viable. For example, they said that in some cases, statutes creating 

what may appear to be similar programs also create very different 

eligibility criteria for grant applicants. Thus, the officials stated, some 

programs may not be easily merged through administrative efforts such 

as announcing similar grant programs in a single solicitation. We agree 

that similar grant programs may have unique features that could render 

grant consolidation or coordination impractical, but DOJ has not taken the 

steps to catalogue all of its programs across each of the three granting 

agencies, and then determine which have the potential to be consolidated 

or coordinated and what barriers might exist to achieve such changes.

The IG continues to include DOJ’s grants management among its list of 

top challenges affecting the department, and in previous reports, has 

identified fragmentation and duplication among DOJ’s granting agencies 

as an area of concern. Further, developing agency procedures to avoid 

grant duplication is one of the promising practices that the federal 

Domestic Working Group Grant Accountability Project suggested in its 

Guide to Opportunities for Improving Grant Accountability.

34

 

34The Domestic Working Group is composed of 18 federal government inspectors 

general, other state and local audit organizations, and is chaired by the Comptroller 

General of the United States.

Given the 

specific knowledge of these grant programs’ statutory authorities, their 

histories of funding certain types of activities, and the nuances related to 

their administration, officials within OJP, OVW, and the COPS Office are 

uniquely positioned to assess their programs for overlap. Doing so could 

yield positive dividends for the granting agencies and the department over 

the longer term. Specifically, such assessments could include 

understanding the areas in which individual granting agencies may be 

awarding funds for the same or similar purposes, determining whether 

these grant programs appropriately channel the department’s resources 

across the justice areas it funds, and determining whether any existing 

overlap is desirable. By conducting an assessment of its grant programs 

of this kind, DOJ would be better positioned to take action, such as 

through consolidation and coordination of its programs, in a more 
 

Page 23 GAO-12-517 DOJ Grants Management

systematic way to limit overlap and mitigate the risk of unnecessary 

duplication.

OJP, OVW, and the COPS Office do not routinely share lists of current 

and potential awardees to consider both the current and planned 

dispersion and purposes of all DOJ grant funding before finalizing new 

award decisions. Not having routine coordination in the pre-award phase 

limits each of DOJ’s granting agencies’ visibility of the funds each 

respectively awards rather than to the overall flow of department dollars. 

Thus, in the instances where DOJ made multiple grant awards to 

applicants for the same or similar purposes, officials made these awards 

without always being aware of the potential for unnecessary duplication or 

whether funding from multiple streams was warranted. DOJ officials 

stated that their annual process to formulate budgets for grant 

administration, OJP’s annual planning process to develop solicitations, 

and the department’s overall grant oversight functions address the risks 

of unnecessary duplication in grant awards. However, these activities do 

not specifically relate to the pre-award phase when any potential for 

unnecessary duplication can best be avoided. DOJ officials also stated 

that they meet bi-monthly to discuss grantees on DOJ’s High Risk List to 

avoid funding grantees who in the past have demonstrated deficiencies in 

properly managing their federal awards.35

As a result of our work, OJP officials informed us that as of March 2012, 

they had begun to pilot solicitation language in two of its grant programs 

requiring grant applicants to disclose any pending applications submitted 

in the last 12 months for other federally funded assistance to support the 

However, the purpose of these 

discussions is not to prevent or reduce duplication. Developing agency 

policies and procedures to avoid unnecessary grant duplication in the 

awarding of funds is one of the promising practices that the federal 

Domestic Working Group Grant Accountability Project suggested in its 

Guide to Opportunities for Improving Grant Accountability.

 

35DOJ designates grantees as high risk based on a number of factors, including but not 

limited to, a history of unsatisfactory performance, financial instability, an inadequate 

financial management system, or nonconformance to terms and conditions of previous 

awards. Additional reporting requirements are imposed on high-risk recipients. OAAM’s 

Audit and Review Division coordinates the high-risk grantee list and works to either 

resolve the issues underlying the high-risk designation or to impose conditions on highrisk grantees to ensure appropriate stewardship of federal funds and enhance 

programmatic results.

DOJ’s Granting Agencies 

Do Not Have Policies and 

Procedures to Ensure 

Coordination to Limit the 

Risk of Unnecessary 

Duplication 
 

Page 24 GAO-12-517 DOJ Grants Management

same costs associated with the same projects outlined in applicants’ 

budgets. Additionally, officials stated they are currently developing a grant 

special condition for all fiscal year 2012 grant awards that would require 

grantees to report to OJP if they receive any funding for a specific project 

cost that is duplicative of the funding OJP provides.36

In addition, OVW officials stated that for fiscal year 2013, they intend to 

require those applying to four of its grant programs to identify in their 

grant applications all federal funding that they recently applied for or have 

received. By enhancing visibility over various sources of grant funding, 

OVW would be better positioned to avoid unnecessary duplication in 

awarding grants for these four programs. It could also provide OVW with 

opportunities to best leverage OVW funding in a manner that 

complements other funding streams the applicant already has available or 

may soon receive. For example, if an applicant reports to OVW that it 

already receives money through a non-OVW grant to provide counseling 

services to victims, OVW can ensure that OVW funds are available for 

OJP officials told us 

that if grantees report duplicative funding for a specific project cost, OJP 

staff will work with the grantees to ensure return of the OJP funds. We 

believe this requirement will improve OJP’s ability to limit the risks of 

duplicative funding for single items; however, OJP continues to take a 

more narrow view of the term “duplication.” OJP defines duplicative 

funding to include only instances where grantees are using federal money 

for the same exact item. In doing so, OJP excludes from its purview all 

federal funding that grant applicants have been awarded to carry out the 

same or similar activities within a proposed project. Thus, in making 

funding decisions without asking for information about and considering 

other sources of an applicant’s federal funding to carry out the same or 

similar activities, OJP may be awarding funds for proposed projects that 

are already partially or fully funded. It may also be doing so at the 

expense of other applicants who, in the absence of other funding sources, 

may demonstrate to OJP greater financial need for their proposals. 

Further, DOJ’s new approach—while an important step—relies solely on 

grantee reporting. By independently assessing its own lists of actual and 

prospective grantees prior to awarding funds, DOJ could have additional 

assurance that it is taking actions to mitigate the risk of unnecessary 

duplication.

 

36Special conditions set forth specific terms that grantees must meet, in addition to the 

general conditions associated with the grant, in order to receive funds.
 

Page 25 GAO-12-517 DOJ Grants Management

other project-related activities such as providing training to counselors 

who serve victims. However, beyond what OJP is piloting and what OVW 

has proposed for four of its programs, DOJ generally does not require 

grant applicants to identify other funding that they have received or any 

pending funding yet to be awarded, including funding received through a 

subgrant.37

OJP, OVW, and the COPS Office have not established policies and 

procedures requiring consistent coordination and information sharing 

among its granting agencies. Having such policies and procedures would 

provide guidance to DOJ granting agencies to help ensure they take 

action to mitigate the risks of unnecessary duplication before finalizing 

award decisions. By routinely coordinating to ensure the sharing of grant 

applications and potential grant awards among DOJ granting agencies 

prior to finalizing grant award decisions and documenting its methods for 

doing so, DOJ could also improve its oversight and better leverage 

information already at its disposal.

Further, while the COPS Office’s grants management system 

automatically includes information on other COPS Office funding a COPS 

Office applicant may already be receiving, it does not identify other DOJ 

grant funding or any other federal funding sources. As a result, DOJ’s 

three granting agencies could take additional steps to increase their 

visibility over what applicants may already be receiving before awarding 

new funds.

The IG recommended in August 2003 that OJP and the COPS Office 

establish procedures to coordinate to ensure that grantees do not receive 

funds for the same purpose from both agencies.38

 

37In fiscal year 2009, OVW required applicants from its OVW Recovery Act grant program 

to identify other sources of DOJ funding on their grant applications and as a grant special 

condition, required recipients to inform OVW if they receive any other DOJ funding during 

the term of the grant. This process was repeated for a different OVW grant program in 

fiscal year 2010. Additionally, OJP issued 2 grant program solicitations for fiscal year 2012 

requiring applicants to report all pending federal and state grant applications which 

propose to support the same project and the same costs in both applications. 

In response, OJP and 

the COPS Office signed a memorandum of understanding to establish 

procedures for avoiding duplication by coordinating grants and grant 

programs that were identified by the IG and grant programs where the 

38U.S. Department of Justice Office of the Inspector General, Audit Division, Streamlining 

of Administrative Activities and Federal Financial Assistance Functions in the Office of 

Justice Programs and the Office of Community Oriented Policing Services, Audit Report 

03-27 (Washington D.C.: Aug. 2003).
 

Page 26 GAO-12-517 DOJ Grants Management

potential for duplication exists. Further, the agencies committed to 

reviewing any new guidance affecting grants or grant programs where the 

potential for duplication exists. Specifically, for grants and grant programs 

identified as having potential for duplication, OJP and the COPS Office 

agreed to minimize potential duplicative grant awards in a manner 

consistent with statutory provisions, and include a grant award special 

condition requiring that grantees not use OJP and COPS Office grant 

funds to pay for the same expenses.39 During the course of our audit 

work, we asked COPS Office and OJP officials for examples of the type 

of coordination they have been engaging in since the IG’s 

recommendations. Officials provided evidence from fiscal year 2009, 

when they coordinated funding decisions with OJP prior to awarding 

grants for two similar grant programs funded under the Recovery Act.40

Officials from OJP and the COPS Office told us that state and local 

communities have expansive criminal justice needs and therefore they 

encourage applicants to seek out as much DOJ grant funding as possible, 

including from grant programs that may have similar objectives or allow 

However, in some cases, granting agencies continue to provide funding 

for the same or similar purposes without each being aware of the others’ 

actions. Further, we examined grant special conditions for the COPS 

Office CSP program and OJP’s ICAC grant program and neither agency 

included special conditions in the grant awards requiring grantees to 

identify and report duplication. However, the 2010 COPS Child Sexual 

Predator Program Grant Owner’s Manual did include a requirement that 

grantees inform the COPS Office if they receive other funding for the 

same cost or service already funded by the COPS Office while their grant 

is underway. The Grant Manager’s Manual used by OJP lists grant award 

special conditions, and except for the duplication condition that 

specifically applies to CTAS, there were no other grant duplication special 

conditions listed.

 

39The IG’s understanding of OJP and the COPS Office’s approach to addressing the IG’s 

recommendation, as stated in their response to the agencies’ review of the report, was 

that the agencies will develop procedures to ensure that duplicative awards are not made 

to the same grantee for similar purposes.

40The American Recovery and Reinvestment Act of 2009 (Recovery Act), Pub. L. No. 111-

5, 123 Stat 115, was enacted on February 17, 2009. See Pub. L. No. 111-5, 123 Stat. 

115. Purposes of the act include promoting economic recovery, providing investments 

needed to increase economic efficiency, and stabilizing state and local government 

budgets to minimize and avoid reductions in essential services. DOJ awarded grants 

under a variety of Recovery Act grant programs. 
 

Page 27 GAO-12-517 DOJ Grants Management

for similar activities. In some instances, DOJ may deem it appropriate for 

distinct grant programs to serve the same goal, or for one community or 

grantee to benefit from multiple streams of grant funding. For example, if 

DOJ granting officials are coordinating their activities across overlapping 

grant programs and are aware that a grantee is receiving funds from 

more than one DOJ program, making funding decisions of this kind may 

be warranted. However, DOJ’s granting agencies are not routinely 

engaging in such coordination. Unless DOJ improves granting agencies’ 

coordination, and considers information available on current, past, and 

prospective funding, it cannot know where all of its funding goes, how it is 

being or will be used, and whether it is awarding grant dollars in the most 

efficient way possible. Further, if the granting agencies are not aware of 

which recipients are receiving funds from multiple grants, they may be 

inadvertently awarding multiple grants that exceed the demonstrated 

need of a recipient or community at the expense of another applicant or 

community with similar demonstrated needs. In addition, they may be 

missing opportunities to award grants to recipients who may use funding 

in a complementary way, whereby funding may be leveraged by a 

grantee or a community to accomplish a single goal. With the exception of 

OVW’s plan to have four grant program recipients identify all federal 

funding they receive and OJP’s solicitation pilot and plan to have 

applicants identify duplicative cost items, DOJ does not have policies and 

procedures that require grant applicants to identify all sources of current 

or pending DOJ funding in their grant applications in a manner that 

provides DOJ a complete picture of DOJ grant project funding. If DOJ had 

(1) a coordinated approach to share applicants’ funding intentions, and 

(2) policies and procedures to share lists of applicants that each granting 

agency plans to fund, DOJ could improve its understanding in the preaward phase as to whether its funding would complement or 

unnecessarily duplicate other federal funding.

DOJ officials told us that the timeline for reviewing applications, making 

recommendations, and processing awards each year is compressed and 

that it would be difficult to build in the extra time and level of coordination 

required to complete an intradepartmental review for potentially 

unnecessary duplication of funding prior to making awards. The officials 

added that it would take even more time if granting agencies were to 

attempt a pre-award duplication review at the subgrantee level. Thus, 

officials told us that they rely upon post-award activities through grant 

monitoring, Single Grant Audits, and IG audits to determine if duplicative 

expenses have occurred after grants are under way. However, relying 

upon monitoring and external audits to identify duplication after it has 

occurred should not substitute for the mitigation of potential unnecessary 
 

Page 28 GAO-12-517 DOJ Grants Management

duplication in the pre-award phase. We acknowledge that the time 

necessary to complete annual grant awards makes such a review 

process more difficult; however, actions to make coordination more 

consistent and efficient as well as the leveraging of grant award 

information, including subgrants, could help overcome this challenge. 

Moreover, using tools such as existing grant data available on 

USASpending.gov, which we address later in this report, could aid DOJ in 

validating other grant funding that grant applicants report and allow for an 

expedient way to search for subgrant funding. In addition, DOJ could limit 

its pre-award coordination to those grant programs that DOJ identifies as 

overlapping with other DOJ grant programs. For certain grant programs, 

OJP and OVW have taken important first steps to require grant applicants 

to report other sources of funding, but expanding this requirement to all 

grant programs across all granting agencies, such that every applicant 

would report both past and prospective sources of DOJ grant funding, 

could provide broader coverage and help DOJ better mitigate the risk of 

unnecessary duplication.

While OJP and OVW use a single grants management system called 

GMS, the COPS Office uses a separate grants management system—

CMS—which limits the sharing of grant award information across the 

granting agencies.41

 

41There is a cross-DOJ system for financial management, the Financial Management 

Information System 2 (FMIS 2), that can be used to identify awards and grant 

disbursements, but it does not show the intended purpose of the grants or grant 

information related to grant activities grantees currently have under way. 

Specifically, OJP, OVW, and the COPS Office use 

GMS and CMS to track and manage awards throughout the grant life 

cycle. For example, agency grant staff in OJP, OVW, and the COPS 

Office use their grant management systems to review and approve 

applications and to plan and document grant monitoring activities. 

Grantees use the grant management systems to submit financial status 

reports that include summary information on grant expenditures and 

program income as well as progress or performance reports. DOJ has 

spent about $36 million from 2008 through 2010 to maintain and upgrade 

DOJ Uses Separate Grant 

Management Systems, a 

Fact That Limits Award 

Coordination 
 

Page 29 GAO-12-517 DOJ Grants Management

these two separate grants management systems, including about $8 

million for CMS and $28 million for GMS.42

DOJ’s continued use of two systems to manage grant programs impedes 

coordination because GMS and CMS are not linked with each other, and

the agencies’ access is limited to the grants management systems they 

utilize. OJP and OVW can access information through GMS about grants 

awarded by each other, but they cannot access CMS to see the grantees 

that have received COPS Office funds. As a result, these granting 

agencies cannot use these grants management systems to inform 

themselves of all of the funding DOJ has awarded or is preparing to 

award to a recipient and consider this information before making 

additional awards. According to an OJP official, over the long term, it 

would be helpful if GMS could connect to CMS. Pursuant to the statute 

establishing OAAM—the office overseeing programmatic grant monitoring 

and assessment across OJP and COPS Office programs—the Director of 

OAAM was required to establish and maintain a modern, automated 

system for managing all information relating to grants made under 

programs within its purview.43

Standards for Internal Control in the Federal Government highlights the 

importance of program managers having access to operational and 

financial data to determine whether they are meeting their goals for 

accountability and efficient use of resources. In addition, the Domestic 

Working Group Grant Accountability Project’s Guide to Opportunities for 

Improving Grant Accountability identified consolidating systems as a 

promising practice. Further, in 2010, the IG found that, as of 2009, OJP’s 

Office of the Chief Financial Officer, which has oversight over the COPS 

Office, did not have access to basic data in CMS needed for financial 

monitoring site visits and other financial compliance reviews. The IG 

recommended that the COPS Office improve coordination with OJP by 

providing OJP additional grants management documentation for oversight 

However, GMS and CMS remain distinct 

grant management systems in the department.

 

42These costs include software and hardware upgrade acquisitions and maintenance but 

do not include costs such as user training for each system. In the case of GMS costs, a 

portion of the costs was capitalized from 2008 through 2013. Had those costs not been 

capitalized, GMS costs would appear higher for this 3-year period. 

43See 42 U.S.C. § 3712h(g) (providing that the OAAM Director shall establish and 

maintain such a system in consultation with the chief information officer of the office).
 

Page 30 GAO-12-517 DOJ Grants Management

and monitoring, such as through remote access to CMS.44

DOJ contractors completed a gap analysis of CMS and GMS in 2006 to 

outline the differences—or gaps—between the two systems and propose 

solutions for reconciling them. At the time, the contractor found key gaps 

between the two systems related to business processes—in particular, 

programmatic grant monitoring, financial monitoring, and progressreporting capabilities. Thus, the contractor recommended either building a 

new single grants system or maintaining the status quo because in the 

analysis, business process differences between OJP and the COPS 

Office were reportedly obstacles that made using either one of the two 

grants systems for both agencies untenable. Since 2007, OJP has 

upgraded GMS, which has closed some of the system gaps that the 

contractor initially identified, but the two systems remain distinct and 

unlinked.

The IG 

concluded that oversight agencies should have direct, instant, and 

complete access to grant information, which is not provided using the 

current system, which relies on hard copies of documents. In response, 

COPS Office officials reported that they would provide OJP with real-time 

hard copy reports necessary to carry out oversight work and that CMS 

could be accessed only by employees using remote access to the COPS 

Office or through a COPS Office laptop.

According to COPS Office officials, CMS continues to better meet their 

needs than GMS could because CMS captures and stores data in such a 

way that it can be more easily queried than data in GMS and CMS 

uniquely aligns with COPS Office grant processes. This is helpful to the 

officials when the COPS Office is evaluating grant applications for its 

largest program, the COPS Hiring Program. Rather than evaluating 

qualitative grant project narratives through external peer review, the 

COPS Office considers quantitative data related to applicant fiscal 

distress, reported crime statistics, and community policing strategies 

when determining where to award COPS Hiring Program grants. Because 

COPS Hiring Program grant applicants use CMS to upload their data, 

COPS officials are positioned to use CMS for automated aggregation and 

analysis of applicant responses.

 

44U.S. Department of Justice Office of the Inspector General, Audit Division, A Review of 

the Selection Process for the COPS Hiring Recovery Program, Audit Report 10-25 

(Washington D.C.: May 2010).
 

Page 31 GAO-12-517 DOJ Grants Management

In contrast, OJP officials said that because of recent upgrades, GMS 

could be used or modified in order to query individual searchable 

elements. They also stated that variation in the information required by 

individual grant programs would not present an insurmountable barrier to 

unifying systems. In addition, GMS has served multiple agencies in the 

past and can be modified when circumstances warrant. For example, in 

2010 and 2011, COPS Office officials successfully used GMS for 

awarding purposes under CTAS. According to OJP officials, the initial 

coordination with the COPS Office for CTAS purposes required additional 

modifications to GMS, but these were not onerous or costly. The officials 

said that with relative ease, after the modifications, OJP, OVW, and 

COPS Office grant managers all accessed GMS to perform some of the 

phases of the CTAS grant process. For example, GMS supports the 

management of CTAS by storing all applications, managing peer review 

comments, and registering awards once decisions are final. Besides 

OVW’s use of GMS to award and manage its grants, the Department of 

Homeland Security’s (DHS) Federal Emergency Management Agency 

(FEMA) also uses GMS to award and manage grants, though it has future 

plans to use a DHS grants system.45

In June 2012, DOJ officials informed us they had engaged a contractor to 

assess whether a single grants management system, among a range of 

other options, can best serve DOJ’s granting agencies. They plan for the 

contractor to report back within 6 months of beginning the analysis and 

said that they envision the assessment including an evaluation of costs, 

benefits, and technical requirements, such as those needed to harmonize 

business processes. Engaging a contractor for this purpose is an 

important first step, and doing so could help DOJ make better investment 

decisions about the most efficient way to manage its grants systems, 

especially when it considers the costs and benefits of having fragmented 

grants systems. In the interim, however, DOJ could take a more 

immediate solution to foster information sharing across GMS and CMS by 

Further, OJP officials stated that 

GMS has a current storage capacity well in excess of what it currently 

uses. They also emphasized that OVW and FEMA have grant business 

processes that do not completely align with OJP’s, but with small 

investments, OJP has been able to adjust GMS to accommodate OVW 

and FEMA.

 

45Both OVW and FEMA pay OJP to use GMS through an interagency agreement, and the 

rates they have paid in the last 5 years have remained relatively stable. 
 

Page 32 GAO-12-517 DOJ Grants Management

providing system access to appropriate OJP, OVW, and COPS Office 

staff—for example, through common login names and passwords, just as 

department staff have done in limited instances such as the CTAS 

Program.

DOJ’s granting agencies are not submitting grant award information to 

USASpending.gov in a timely way. In accordance with the Federal 

Funding and Transparency Act of 2006 (FFATA), USASpending.gov was 

created to increase the transparency and accountability for federal 

funding awarded through contracts, loans, grants, and other awards.46

OMB issued guidance on reporting the receipt and use of federal funds. 

OMB also launched USASpending.gov in December 2007 to allow the 

public to view federal spending and engaged the General Services 

Administration (GSA) to build and maintain USASpending.gov, among 

other FFATA-related websites.47

OMB’s FFATA guidance requires agencies to submit grant award data by 

the 5th of each month. USASpending.gov contains validation software 

used to validate agency data submissions, and if data are rejected, 

agencies receive automated notification. OMB guidance then requires 

agencies to resubmit the corrected data to USASpending.gov within 5 

In August 2010, OMB established 

guidelines for agencies related to the requirement for prime grantees to 

report all subgrants over $25,000 in fiscal year 2011. The 

USASpending.gov website includes the subgrantees’ names, 

geographical locations of funded activities, specific subgrant amounts, 

and the funded purposes. A GSA official told us that the FFATA reporting 

infrastructure is the first time that comprehensive federal grant and 

subgrant information, including DOJ grant information, has been made 

widely available on a single website. Through the steps that granting 

agencies, as well as the grantees, take to supply this website’s content, 

the public and DOJ’s granting agencies can better track the flow of funds 

and identify communities receiving funds from multiple streams.

 

46See Pub. L. No. 109-282, 120 Stat. 1186 (2006).

47To support OMB efforts, GSA hired a vendor to maintain the FFATA reporting 

infrastructure including the FFATA Subaward Reporting System (FSRS.gov), a federal 

government website used by federal contractors and grantees to submit data such as 

subaward information to USASpending.gov, and the USASpending.gov websites. In 2010, 

USASpending.gov logged 1.8 million website visits.

DOJ Does Not Timely 

Submit Grant Data to 

USASpending.gov and Is 

Not Fully Leveraging the 

Website’s Subgrant Award 

Information before Making 

Grant Award Decisions
 

Page 33 GAO-12-517 DOJ Grants Management

working days of the rejection notification.48 OJP manages submissions to 

USASpending.gov for all of DOJ—that is for OJP, OVW, and the COPS 

Office—and an OJP official reported that DOJ submits grant award 

information to USASpending.gov twice per month. However, more than a 

quarter of the grant award information that DOJ submitted to 

USASpending.gov in fiscal year 2011 was rejected and resubmission took 

more than 80 days after the fiscal year ended.49

 

48Office of Management and Budget, Memorandum for the Heads of Departments and 

Agencies: Guidance on Data Submission under the Federal Funding Accountability and 

Transparency Act, M-09-19 (Washington, D.C.: June 1, 2009).

Figure 3 illustrates the 

flow of grant award information from both DOJ and grantees and some 

issues we identified related to DOJ’s fiscal year 2011 reporting.

49DOJ typically submits batches of grant award information, and each batch can contain 

hundreds of distinct grant awards. Under current OMB guidelines, if more than 10 percent 

of the awards in the batch contain errors, such as mistakes in the codes uniquely 

assigned to grantees, the entire batch of grant award information is rejected. Upon receipt 

of the batch returned, DOJ is then charged with reviewing the entire batch and correcting 

the identified errors before GSA will post it. 
 

Page 34 GAO-12-517 DOJ Grants Management

Figure 3. DOJ Grant and Subgrant Award Information Flow to USASpending.gov

Agency reporting of prime grant award information in USASpending.gov 

is a critical step in the FFATA reporting process because prime grantees 

cannot upload their subgrant award information until it occurs. For fiscal 

year 2011, DOJ submitted 4,346 distinct prime grant award records to 

USASpending.gov; however, GSA rejected 1,152 of these because of 

incomplete or inaccurate data associated with some of these grant files, 

and DOJ did not resubmit the records within 5 working days as required 
 

Page 35 GAO-12-517 DOJ Grants Management

under OMB guidance. Specifically, DOJ did not correct and resubmit the 

rejected records until December 22, 2011, which was after we raised this 

issue with DOJ and 83 days after the end of the fiscal year. Five out of 11 

DOJ prime grantees we interviewed who had awarded subgrants 

indicated that, after searching, they could not view their prime DOJ grant 

awards on FSRS.gov or USASpending.gov and indicated that DOJ had 

not uploaded the information to the websites. Further, another prime 

grantee among the 11 with whom we spoke indicated that it was unaware 

that subgrant reporting was a requirement. As a result, these prime 

grantees were unable to submit their subgrant award information and thus 

were unable to comply with OMB subgrant reporting requirements. DOJ 

has taken action to help ensure that prime grantees and DOJ grants staff 

are aware of FFATA reporting requirements. For example, OJP offered 

FFATA reporting training for all DOJ grants staff and grantees, and all 

three granting agencies required a special condition in grant awards that 

included FFATA reporting requirements. These steps may have informed 

grantees of their FFATA responsibilities, but DOJ’s untimely submission 

of grant award information to USASpending.gov led to prime grantees 

being unable to access their grant awards to submit their subgrant award 

information as required by OMB.

OJP officials stated that since 2007 they have been coordinating with 

OMB, other federal agencies, and contractors on issues related to 

reporting guidelines and other technical requirements related to subgrant 

reporting, but that it was not until August 2010 that OMB established 

guidelines for the collection and reporting of subgrant information. 

Nevertheless, OJP officials stated that the current allotment of 5 days for 

agencies to review and resubmit data that GSA originally rejected is an 

unreasonable time frame given the time-intensive nature of checking and 

correcting errors. Officials also noted that OJP would like to see GSA 

allow for the posting of individual records that pass system validation 

rather than waiting for entire blocks to be corrected at once before GSA 

will post award information to USASpending.gov. In addition, OJP officials 

indicated that the information prime grantees ultimately posted about their 

subgrantees was limited and in most cases very brief. As a result, the 

officials said they were not considering such information before making 

new awards.

We recognize that 5 days may not be adequate to correct errors in grant 

award information, but we also believe that timely submission of grant 

award information on USASpending.gov is key to transparency and the 

overall utility of the system for grant decision makers, the criminal justice

community, Congress, and taxpayers. By DOJ ensuring that it submits its 
 

Page 36 GAO-12-517 DOJ Grants Management

grant award information to USASpending.gov in as timely a manner as is 

possible, prime grantees’ abilities to report their subgrant activities would 

likely improve. As a result, DOJ could have greater visibility over which 

subgrantees were using its money and for what purposes before DOJ 

makes its grant award decisions. Further, even if DOJ does not believe 

that the information that prime grantees ultimately post about their 

subgrantees is ideally descriptive in every instance, the information could 

provide DOJ with important details—that it currently does not consider or 

otherwise have access to before finalizing award decisions—related to 

how subgrantees are using their funds.

The statute establishing OAAM tasked the OAAM Director with selecting 

and carrying out program assessments of not less than 10 percent of the 

aggregate amount of grant funding awarded annually by OJP, the COPS 

Office, and any other grant programs carried out by DOJ that the Attorney 

General considers appropriate.50

 

50See 42 U.S.C. § 3712h(b), (c).

OAAM officials told us that to meet the 

directive to conduct program assessments, and in recognition of its own 

resource constraints, OAAM relies on the programmatic grant monitoring 

that OJP’s and the COPS Office’s grant staff already conduct. To oversee 

and track these monitoring efforts, OAAM develops and implements 

standards and protocols, including a framework and methodology for 

DOJ Could Benefit 

from Examining Its 

Programmatic Grant 

Monitoring and 

Assessment Functions 

and Considering 

Expansion of OAAM’s 

Authorities 

OAAM Uses Programmatic 

Grant Monitoring and 

Program Assessment for 

Grant Oversight, but 

Program Assessments 

Yield Richer Information
 

Page 37 GAO-12-517 DOJ Grants Management

systematically identifying high-risk grantees.51 OAAM also tracks OJP’s 

and the COPS Office’s monitoring progress and compares it against an 

established annual monitoring plan. For example, in its fiscal year 2010 

annual report—the latest available—on both OJP and the COPS Office’s 

monitoring goals and activities, OAAM found that both offices exceeded 

their goals of monitoring 10 percent of total award funding. OJP 

monitored 1,447 grantees with awards totaling $3.05 billion, and the 

COPS Office monitored 185 grantees with awards totaling $234.74 

million. In addition to overseeing monitoring activities, OAAM also 

conducts program assessments of OJP and COPS Office grant 

programs. OAAM considers monitoring—and its oversight of it—as 

responsive to its originating statute’s intent, but it also recognizes that 

assessments have utility and serve a separate but important function in 

helping the office improve grant management. Table 4 illustrates the 

distinction between OJP’s and the COPS Office’s monitoring and OAAM’s 

assessment functions.

 

51DOJ designates grantees as high risk based on a number of factors, including but not 

limited to, a history of unsatisfactory performance, financial instability, an inadequate 

financial management system, or nonconformance to terms and conditions of previous 

awards. Additional reporting requirements are imposed on high-risk recipients. OAAM’s 

Audit and Review Division coordinates the high-risk grantee list and works to either 

resolve the issues underlying the high-risk designation or to impose conditions on highrisk grantees to ensure appropriate stewardship of federal funds and enhance 

programmatic results.
 

Page 38 GAO-12-517 DOJ Grants Management

Table 4: Comparison of Programmatic Grant Monitoring and Program Assessment Activities

OJP’s and the COPS Office’s programmatic grant monitoring OAAM’s grant program assessments

Who conducts:

• Grant staff in OJP’s program offices and COPS Office’s Grant 

Monitoring Division.

Scope:

• Focuses on individual grant recipients one at a time.

Characteristics:

• Checks that the grantee complies with the programmatic, 

administrative, and financial requirements.

• Advocates responsible stewardship of awarded funds.

• Verifies that grant implementation is consistent with the 

grantee’s stated plan, policy guidelines, and applicable DOJ 

rules and regulations.

• Observes and verifies project implementation for promising 

practices.

Results:

• Provides guidance to the grantee on DOJ policies and 

procedures, and programmatic, administrative, and financial 

reporting requirements.

• Works with the grantee to identify any problems and provide 

assistance to resolve them.

• Recommends appropriate and available training or technical 

assistance.

Who conducts:

• Analysts in OAAM.

Scope:

• Can focus on a whole or one aspect of a grant program.

Characteristics:

• Systematic review and evaluation of programs to gauge 

effectiveness, identify promising practices, and document 

impediments.

• Begins with research into a grant program’s issue area, 

origin, and original purpose, along with key program 

challenges and issues.

• Uses a variety of analytical approaches, depending on the 

goals of the assessment, to provide bureaus and program 

offices with information to improve their programs.

Results:

• May result in recommendations to grant-making offices and 

bureaus for improving their grant programs.

• When recommendations are made, OAAM staff work with 

program offices to implement recommendations.

Source: GAO analysis of DOJ information.

In general, both monitoring and assessment are important and 

complementary tools for grant oversight. Nevertheless, we found that 

OAAM’s program assessments yield richer information to enhance grant 

programs than either OJP’s or the COPS Office’s individual monitoring 

reports or the summary reports that OAAM’s Program Assessment 

Division (PAD) compiles because the program assessments are more 

analytical and broader in perspective. OAAM’s PAD Standard Operating 

Procedures define a program assessment as “a systematic review and 

evaluation of programs to gauge effectiveness, identify promising 

practices, document impediments, and when necessary, make 

recommendations for improvement.” OAAM reported to us that from 2008 

through mid-February, 2012, its staff had produced 28 products; however, 

when we reviewed the 28, we found that 7 met OAAM’s definition for a 
 

Page 39 GAO-12-517 DOJ Grants Management

program assessment.52

Of the 7 publications meeting OAAM’s definition for program 

assessments, 2 reviewed a single aspect of the grant cycle—program 

awarding—within a particular grant program rather than the grant 

program overall.

For example, in 2012, OAAM completed an 

assessment report on the COPS Office Methamphetamine Initiative. In 

2011, it completed one on BJA payment programs, and in 2010, it 

assessed the ICAC Training and Technical Assistance Program. The 

other 21 publications were user guides; summaries of monitoring reports, 

such as those described earlier; or Recovery Act risk indicator reports, 

which identify potentially high-risk grantees so that the program offices 

can work with those grantees to resolve issues and prevent potential 

problems. According to OJP, all of OAAM’s publications contribute to 

improving OJP’s grant programs and operations by strengthening internal 

controls, streamlining processes to be more efficient, or reporting on how 

well programs and policies are meeting their objectives.

53

 

52OAAM considered eight of its products to be program assessments. However, we 

eliminated one because it did not specifically look at a DOJ grant program.

Nevertheless, all 7 were based on a much more 

thorough review of the extent to which a grant program is meeting its 

intended purpose. Moreover, each recommended specific actions to 

address identified program deficiencies, and implementation of these 

recommendations has helped DOJ enhance its grant programs. For 

example, the 2010 ICAC assessment report contained 11 

recommendations related to the collection and use of performance 

measurement data, financial management, fair and open competition for 

awards, and improving grant management and oversight. In our review of 

the six monitoring reports that the ICAC grant manager completed for the 

ICAC program’s sole grantee, there was no mention of the same 

deficiencies. In particular, none of the six monitoring reports identified the 

unallowable costs, conflict of interest, or inadequate oversight and 

documentation of grant activity that the OAAM assessment report 

identified. Instead, the monitoring reports showed that the grantee was 

progressing as expected on implementation of the program, and was on 

schedule with no problems noted.

53In 2011, OAAM issued assessment reports for the Bureau of Justice Assistance 

Recovery Act Programs Combating Criminal Narcotics Activity Stemming from the 

Southern Border of the United States (CCNA program), and the Assistance to Rural Law 

Enforcement to Combat Crime and Drugs (RLE program).
 

Page 40 GAO-12-517 DOJ Grants Management

OAAM also assessed BJA’s payment programs, which otherwise are not 

subject to BJA grant monitoring. In the November 2011 report, OAAM 

assessed the processes that BJA used to verify the eligibility and 

accuracy of reimbursement requests submitted by grantees.54

Standards for Internal Control in the Federal Government calls for 

managers to compare actual performance with planned or expected 

results throughout the organization and analyze significant differences. 

These standards also identify that program managers need both 

operational and financial data to determine whether they are meeting their 

agencies’ strategic and annual performance plans and meeting their 

goals for accountability for effective and efficient use of resources. The 

programmatic grant monitoring reports that each of the granting agencies 

compile contribute to meeting these standards at the grantee level by 

tracking the progress and, when necessary, providing assistance to 

individual grant recipients. OAAM’s summaries of these reports then roll 

The 

assessment concluded that BJA is administering its payment programs

appropriately to verify the eligibility and accuracy of payments, but it also 

determined that additional internal controls were necessary and that 

procedures were not sufficient to identify duplicate payment requests from 

grantees. As a result of the assessment, OAAM made six 

recommendations to BJA, including implementing additional procedures 

to identify duplicate requests for payments of detention expenses. In 

particular, one of OAAM’s recommendations was that BJA implement a 

process to identify overlapping requests for reimbursement between two 

of the programs for expenses related to detention of criminal aliens. In 

response, BJA compared all of those programs’ applications for 

reimbursement for fiscal year 2011 to identify whether jurisdictions were 

requesting reimbursement for the detention of the same individuals over 

the same period of time. BJA’s review led to the removal of approximately 

$5.8 million in requests for reimbursement prior to generating the final 

reimbursement awards.

 

54This assessment included the following programs: the Bulletproof Vest Partnership 

Program, which assists state, local, and tribal law enforcement agencies with purchasing 

body armor for sworn personnel; the State Criminal Alien Assistance Program 

(SCAAP),which provides assistance to states and localities by reimbursing them for 

correctional officer salary costs associated with incarcerating undocumented criminal 

aliens; the Southwest Border Prosecution Initiative (SWBPI); and the Northern Border 

Prosecution Initiative (NBPI), which reimburses state, local, and tribal jurisdictions for 

prosecuting criminal cases declined by U.S. Attorneys’ offices and for pretrial detention 

expenses in states along the southern and northern borders, respectively.
 

Page 41 GAO-12-517 DOJ Grants Management

up the statistics and ensure the compliance monitoring occurs as 

required. However, OAAM’s program assessments are more 

comprehensive than both the individual grant monitoring reports and the 

summary reports OAAM prepares because their broader perspective 

allows for reporting on program successes, impediments, and potential 

areas for improvement. While monitoring 10 percent or more of the 

aggregate amount of grant funding awarded annually is important and 

beneficial to the grant management process, the 7 program assessment 

reports that OAAM has issued since 2008 have led to more than 50 

recommendations for the improvement of OJP and COPS Office grant 

programs.

According to OAAM officials, additional program assessments would be 

beneficial; however, they told us that OAAM does not have sufficient 

resources to conduct more. They said that conducting program 

assessments on 10 percent of the aggregate amount of grant funds 

awarded annually would not be possible given current resources, but they 

also noted that the department has not conducted a feasibility analysis 

that considers the costs and benefits of having OAAM conduct 

assessments on a larger number of grant programs. Further, OJP officials 

stated that since the establishment of OAAM, the administration has 

never requested, and the department has not received, the full amount 

authorized for appropriation under OAAM’s governing statute.55 DOJ 

officials did not explain the rationale for the administration’s budget 

proposals and officials did not report any plans to increase OAAM’s 

resources. As of December 2011, out of a total of 49 staff (26 federal staff 

authorized by DOJ and 23 contractors) spread across OAAM’s three 

divisions, OAAM had 8 staff (5 federal staff authorized by DOJ and 3 

contractors)—or less than 20 percent—in its PAD dedicated to performing 

program assessments in addition to overseeing OJP and COPS Office 

programmatic monitoring.56

 

55Pursuant to its authorizing statute, not more than 3 percent of all funding made available 

for programs under OAAM’s purview in a fiscal year shall be available to OAAM for, 

among other things, carrying out and coordinating program assessments. See 42 U.S.C. § 

3712h(a)(2).

OAAM also has 18 staff (10 federal staff 

56In a March 2011 report the IG reported that, as of May 2009, OAAM had filled all of its 

49 federal employee and contractor positions, but in May 2012, OJP reported that OAAM 

has undergone attrition and is currently 20 percent below its authorized staffing level. See 

U.S. Department of Justice, Office of the Inspector General, Audit Division, Audit of the 

Office of Justice Programs’ Monitoring and Oversight of Recovery Act and Non-Recovery 

Act Grants, Audit Report 11-19 (Washington D.C.: March 2011).
 

Page 42 GAO-12-517 DOJ Grants Management

authorized by DOJ and 8 contractors)—or more than 30 percent—

working in its Audit and Review Division to coordinate IG, GAO, and 

Single Grant Audit resolutions,57 and to conduct A-123 reviews—activities 

that are not specifically addressed in OAAM’s authorizing statute.58

Appendix V contains further discussion of the different activities of 

OAAM’s three divisions. Because DOJ considers its resources to be 

limited, it is important that OAAM’s resources be used as efficiently as 

possible to maximize the investment in grant programs. Thus, given the 

different roles that grant monitoring and program assessment play in 

assessing the overall effectiveness of grant programs, considering 

whether it employs an appropriate mix of monitoring and program 

assessments could aid DOJ in awarding grant funds in the most efficient 

and effective way possible.

 

57Pursuant to the Single Audit Act, as amended, each nonfederal entity that expends 

$500,000 or more in federal awards, including grants and other assistance, in a fiscal year 

must obtain an annual “Single Audit,” which includes an audit of the entity’s financial 

statements and a schedule of the expenditure of federal awards, as well as, among other 

things, a review of related internal controls. See 31 U.S.C. §§ 7501-07.

58OAAM annually reviews OJP’s critical business processes in the areas of financial 

management, information technology, and grant management and makes 

recommendations to enhance and strengthen internal controls as required by OMB 

Circular A-123, “Management’s Responsibility for Internal Control.” 
 

Page 43 GAO-12-517 DOJ Grants Management

Consistent with the 2000 reauthorization of the Violence Against Women 

Act, the Attorney General submits a biennial report to Congress on the 

effectiveness of VAWA-funded grant programs.59 OVW uses the VAWA 

Measuring Effectiveness Initiative, conducted under a noncompetitive 

cooperative agreement with a university to develop and implement 

reporting tools, as the primary way it meets statutory requirements to 

report on the effectiveness of VAWA-funded programs.60 Staff from the 

university also provide data collection training to grantees to ensure that 

they use the forms and database properly, and then use the information 

collected to summarize grantee performance in semiannual summary 

data reports. The results of this initiative are summary data reports that 

university staff compile from the semiannual or annual progress reports 

that grantees submit to OVW. OVW then uses these summaries to meet 

biennial reporting requirements for its discretionary grant programs under 

VAWA and, for example, the Services, Training, Officers, Prosecutors 

(STOP) Violence Against Women Formula Grant Program (STOP 

Program). 61

OVW’s biennial reports are composed of three main components:

The STOP Program promotes a coordinated, 

multidisciplinary approach to improving the criminal justice system’s 

response to violent crimes against women and increasing the availability 

of victim services.

• a literature review of research showing (where available) the 

effectiveness of grant-funded activities and (when such research is 

not available) information on promising or best practices in the field of 

victims services;

 

59Specifically, the Violence Against Women Act of 2000 provided that the Attorney 

General or Secretary of Health and Human Services, as applicable, shall require grantees 

under any program authorized or reauthorized under the act report on the effectiveness of 

the activities carried out with amounts made available for the program. See Pub. L. No. 

106-386, Div. B, § 1003(a), 114 Stat. 1464, 1491 (2000) (codified at 42 U.S.C. § 

3789p(a)). It further required the Attorney General or Secretary, as applicable, to report 

biennially to the Committees on the Judiciary of the Senate and House of Representatives 

on the grant programs described, including any information reported by grantees. See 42 

U.S.C. § 3789p(b).

60Information on which the Attorney General shall report related to the effectiveness of 

activities carried out with VAWA grant funds includes the number of persons served and, if 

applicable, the number of persons seeking services who could not be served.

61Prior to enactment of the Violence Against Women Act of 2005, VAWA required that the 

Attorney General report annually on the STOP Program.

Not Including OVW in 

OAAM’s Oversight Has 

Resulted in Inconsistent 

Assessment of the 

Effectiveness of DOJ Grant 

Programs 
 

Page 44 GAO-12-517 DOJ Grants Management

• a summary of performance measure data, such as the number of 

grant-funded staff, the number of people trained, and the number of 

victims/survivors seeking services that are served, partially served, 

and not served, as reported by the grantees to OVW through OJP’s 

GMS; and

• anecdotal evidence from grantees on the benefit of what they are able 

to do with grant funds.

The statute establishing OAAM did not give it oversight authority for OVW 

programs. Provisions in the authorizing statute, however, provide the 

Attorney General with discretion to expand OAAM’s scope beyond OJP 

and COPS Office programs, which the Attorney General has not 

undertaken. As a result, while OVW uses its data collection and analysis 

to report on grant program effectiveness, in accordance with the VAWA 

requirement, by providing information on activities carried out with grant 

funds and the number of persons served using those funds, it does not 

benefit from the monitoring oversight and grant program assessments 

that OAAM provides. Such assessments could provide OVW with more 

substantive information on its grant programs.

Table 5 contains a comparison of the analytical approaches that OVW 

uses when it reports to Congress on the effectiveness of its grant 

programs against those that OAAM uses in its program assessments. On 

the basis of a review of seven OVW reports and seven OAAM grant 

program assessment reports, we found that OVW’s reports contain less 

analysis than the OAAM reports do. Specifically, these OVW reports 

summarized performance measurement data rather than analyzed it. 

Further, these OVW reports did not address grant program operations 

and management. OAAM, in contrast, used more varied approaches to 

analyze grant programs, which provided information on both grant 

program performance and operations, identified areas for improvement, 

and resulted in specific recommendations to OJP’s bureaus and program 

offices, and the COPS Office.
 

Page 45 GAO-12-517 DOJ Grants Management

Table 5: Comparison of OVW and OAAM Measurement of Grant Program Effectiveness

Analytical approaches 

Number of OVW 

reports including 

approach 

Number of OAAM 

reports including 

approach 

Comparative analysis—seeks to identify the strengths and weaknesses of two or 

more comparable programs or processes 

0 1 

Compliance analysis—determines whether a program is being operated within 

the laws and regulations under which it is funded 

0 2 

Grant administrative requirements review—examines the extent to which 

grants comply with grant administrative requirements 

0 5 

Financial/grant expenditure review—reviews the financial history of a grant to 

ensure that grantees properly accounted for expenditures 

0 3 

Literature review—examines related research on the effectiveness of grantfunded programs or best practices in the field 7 1 

Output analysis—identifies the direct products or services delivered by a 

program 

7 2 

Performance measurement analysis—determines whether a grant program or 

its grantee has useful and appropriate performance data to measure program 

effectiveness 

0 3 

Process analysis—determines the extent to which a program is operating under 

its original intent or whether there are particular processes that could be improved 

0 7 

Trend analysis—examines historical results to attempt to identify patterns and 

trends in order to predict a future outcome 

0 2 

Source: GAO analysis of information from DOJ and the Measuring Effectiveness Initiative.

Unlike the OAAM analysts who conduct assessments of OJP and COPS 

Office grant programs, the university staff responsible for the Measuring 

Effectiveness Initiative do not have access to grant program financial data 

or OVW grant monitoring reports. Additionally, university staff involved in 

the initiative do not conduct site visits to validate the data provided by 

grant recipients and the work they perform. Instead, OVW staff in each 

program area review the results of the biennial reports and the 

semiannual summary data reports compiled from grantee progress 

reports to identify priority areas where there is an unmet need. The OVW 

reports contain sections on “remaining areas of need” identified by grant 

recipients. However, the areas of need that OVW identified are based on 

comments grant recipients provided on gaps in service, rather than being 

based on an independent assessment that OVW conducted on the overall 

grant programs. Moreover, unlike the grant program assessments that 

OAAM conducts, beyond identifying areas of need, the biennial reports do 

not result in concrete recommendations for improving OVW’s grant 

programs. OVW officials told us that for the upcoming 2012 biennial 

report, they plan to focus more attention to the discussion of remaining 

areas of need.
 

Page 46 GAO-12-517 DOJ Grants Management

According to OVW’s 2010 Biennial Report to Congress on the 

Effectiveness of Grant Programs Under the Violence Against Women Act,

demonstrating the effectiveness of services provided by agencies funded 

under OVW presents a challenge for those charged with meeting the 

reporting mandate of VAWA 2000. An OVW official told us that it is 

difficult to discern between output and outcomes when dealing with the 

grant programs in OVW and that it is difficult to measure outcomes with 

service grant programs.62

According to the federal Domestic Working Group Grant Accountability 

Project’s Guide to Opportunities for Improving Grant Accountability, 

agencies need a process for managing performance once grants are 

awarded, and the ability to assess grant results and use those results 

when awarding future grants. The Working Group identified engaging 

outside experts to assess program performance, inspecting projects after 

completion, and conducting evaluations to identify factors affecting results 

among its promising practices to improve program performance. These 

activities are not part of OVW’s current approach to program oversight.

For example, OVW might consider whether an 

abuse victim not only gets a protective order but also receives additional 

services. Additionally, according to OVW officials, it would be difficult to 

track how many victims received different types of services in multiple 

areas, because OVW service provider grantees only track the first 

instance in which a victim receives services and do not follow up on 

related services.

OVW conducts its grant program monitoring as well as IG audit follow-up. 

Additionally, OVW has a Grant Assessment Tool (GAT)—designed by the 

same company that produced the GAT for OJP.63

 

62Outputs are the direct products or services delivered by a program. Outcomes are the 

results of those products and services.

OAAM currently 

conducts Single Audit follow-ups; manages the high-risk grantee list; and 

oversees DOJ’s combined programmatic and financial monitoring plan, 

which is the combined monitoring list of all the sites that OJP, OVW, and 

the COPS Office plan to visit for the year. In a March 2011 audit, the IG 

found that OVW and the COPS Office perform certain monitoring and 

oversight services that are duplicative of the services available through 

OJP and recommended that DOJ standardize the oversight services 

63OVW’s Grant Assessment Tool is a database containing 18 standard elements to 

evaluate the level of risk associated with grantees in order to prioritize monitoring.
 

Page 47 GAO-12-517 DOJ Grants Management

provided to OVW and the COPS Office to eliminate such duplication and 

provide uniformity in oversight among DOJ granting agencies. OAAM 

provides certain administrative services that facilitate grant program 

management, but DOJ officials told us the reason OAAM does not have 

oversight over OVW is because the Attorney General has not extended 

OAAM’s purview. OJP officials told us that they have not been provided 

the scope of work that OVW oversight may encompass and, as such, 

OAAM has not conducted any analyses using a workforce model to 

determine the staffing levels, associated resources, and other possible 

impacts (i.e., costs and benefits) of having OVW under its purview on 

OAAM operations.

OVW officials expressed concern that OAAM staff would not have any 

expertise in violence against women issues. However, OAAM currently 

has oversight over specialized bureaus and offices such as the Office for 

Victims of Crime and the Office of Sex Offender Sentencing, Monitoring, 

Apprehending, Registering, and Tracking. Additionally, OVW officials 

stated that OAAM does not perform data collection and analysis activities, 

which are the primary activities of the Measuring Effectiveness Initiative. 

However, as a part of its assessments, OAAM has collected performance 

measures and conducted analysis. For example, in its assessment of the 

ICAC Training and Technical Assistance Program, OAAM collected and 

analyzed national performance metrics related to training. Given the 

nature of OAAM assessments, along with the other oversight services it 

provides to OJP and the COPS Office, the information resulting from 

OAAM assessments of OVW grant programs could better inform OVW 

about its grant programs and funding to assist with future program design 

and award decisions while also providing Congress with a more complete 

picture on the effectiveness of programs funded under VAWA. 

Accordingly, DOJ could benefit from assessing the feasibility, costs, and 

benefits of OAAM providing grant program assessments for OVW.

The statutory design of DOJ’s grant programs has contributed to overlap 

across a number of justice areas. We recognize that even when programs 

overlap, there may be meaningful differences in their eligibility criteria or 

objectives, or they may be providing similar types of services in different 

ways. We also recognize that a number of grant programs are formuladriven and therefore grantees’ eligibility is predetermined. However, 

because DOJ exercises independent judgment when making 

discretionary awards and therefore has full responsibility for how it 

conducts its pre-award reviews, it will be important for the department to 

maximize visibility over how grantees plan to spend the funds they 

Conclusions 
 

Page 48 GAO-12-517 DOJ Grants Management

receive from multiple funding streams. In some instances, DOJ may 

deem it appropriate for large numbers of distinct grant programs to serve 

one goal, or for the same communities to benefit from multiple streams of 

its grant funding. In these cases, duplication may be warranted. However, 

because we found routine coordination and consistent policies and 

procedures for sharing information across the granting agencies during 

DOJ’s pre-award phase limited, we do not believe DOJ knows with 

certainty if such duplication is always necessary.

DOJ’s three granting agencies have taken some steps to coordinate their 

grant-related activities and have sought congressional approval in some 

instances for grant program consolidation. Further, they have initiated 

other, limited actions to ensure that grantees report additional streams of 

funding. However, DOJ limits its view of duplication to instances where 

grant applicants apply for and receive multiple streams of funding, 

including DOJ funding, to support single costs associated with a single 

grant project. Using this definition, DOJ believes that any unnecessary 

duplication can be identified through monitoring grantees post-award. We 

take a broader view of duplication and consider it potentially unnecessary 

when DOJ is unaware that grantees have applied for and are receiving 

funding for potentially the very same or similar purposes. Therefore, we 

believe it is incumbent that DOJ take steps in the pre-award phase to 

make purposeful judgments about funding necessity before finalizing the 

awards. Doing so would help the department better mitigate this risk for 

potential, unnecessary duplication. Specifically, by conducting a broad 

examination of all DOJ grant programs to systematically identify justice 

areas for which funding overlaps, DOJ would have greater visibility over 

how its funding can be used and whether it is awarding grant dollars in 

the most efficient way possible. Further, developing and implementing 

policies and procedures to require granting agencies to routinely share 

and consider information each may have about past or prospective 

grantee funding could provide DOJ with more strategic visibility over its 

awarding decisions. In addition, requiring all grantees to report current or 

prospective federal funding sources when applying for DOJ grants could 

provide DOJ with more information to better target its limited financial 

resources before it finalizes new grant awards.

Additionally, by taking interim steps to expand access to the two distinct 

grant management systems—CMS and GMS—DOJ could better ensure 

that grant managers and decision makers can leverage all existing tools 

while a longer-term study to consider the feasibility, costs, and benefits of 

potential options for DOJ grant management systems is underway. Such 

options could include unifying the systems, creating a DOJ-wide system, 
 

Page 49 GAO-12-517 DOJ Grants Management

or using off-the-shelf software to bridge information gaps. Related, DOJ 

can have greater confidence that any variation in how the granting 

agencies are currently managing their portfolios does not hinder any 

potential unification by ensuring that its planned study include an 

assessment of the steps needed to harmonize DOJ grant processes. 

Further, with additional steps to ensure that DOJ is submitting grant 

award information to USASpending.gov in the most timely manner 

possible, the department could facilitate prime grantees’ uploading of 

information on subgrantees’ use of funds and therefore make the website 

a more useful resource to DOJ’s own grant decision makers. Finally, 

recognizing the value of OAAM’s role, assessing whether the office relies 

on an appropriate mix of programmatic grant monitoring and program 

assessment—as well as considering expansion of OAAM’s coverage to 

include OVW—could improve the overall operation of grant programs 

departmentwide.

To ensure that DOJ can identify overlapping grant programs to either 

consolidate or coordinate similar programs, mitigate the risk of 

unnecessary grant award duplication in its programs, and enhance DOJ’s 

ability to gauge grant program effectiveness, we recommend that the 

Attorney General take the following eight actions:

1. Conduct an assessment to better understand the extent to which the 

department’s grant programs overlap with one another and determine 

if grant programs may be consolidated to mitigate the risk of 

unnecessary duplication. To the extent that DOJ identifies any 

statutory obstacles to consolidating its grant programs, it should work 

with Congress to address them, as needed.

2. Coordinate within and among granting agencies on a consistent basis 

to review potential or recent grant awards from grant programs that 

DOJ identifies as overlapping, including subgrant awards reported by 

prime grant awardees, to the extent possible, before awarding grants. 

DOJ should also take steps to establish written policies and 

procedures to govern this coordination and help ensure that it occurs.

3. Require its grant applicants to report all federal grant funding, 

including all DOJ funding, that they are currently receiving or have 

recently applied for in their grant applications.

4. Provide appropriate OJP and COPS Office staff with access to both 

GMS and CMS and appropriate OVW staff with access to CMS.

Recommendations for 

Executive Action
 

Page 50 GAO-12-517 DOJ Grants Management

5. As part of DOJ’s evaluation of its grant management systems, DOJ 

should ensure that it assesses the feasibility, costs, and benefits of 

moving to a single grants management system, including the steps 

needed to harmonize DOJ grant processes, so that any variation in 

how the granting agencies manage their portfolios is not an 

encumbrance to potential system unification.

6. Ensure the most timely reporting possible of grant award information 

to USASpending.gov according to OMB guidelines, which would 

enable its grantees to comply with their reporting responsibilities 

according to the same guidelines.

7. Assess whether OAAM relies on an appropriate mix of programmatic 

grant monitoring and program assessment, and determine whether 

the office could support additional program assessments.

8. Assess the feasibility, costs, and benefits of OAAM providing 

assessments for OVW, in addition to OJP and the COPS Office. If 

DOJ determines that OAAM assessments of OVW grant programs 

would be more cost-effective and provide greater insight into the 

effectiveness of OVW grant programs than OVW’s current approach, 

then the Attorney General should extend OAAM’s oversight to include 

OVW.

We provided a draft of this report to DOJ for comment. DOJ provided 

written comments, which are reproduced in full in appendix VI, and 

concurred with all eight of the recommendations. DOJ also described 

actions it has underway or plans to take to address the recommendations.

• DOJ agreed with the first recommendation that it conduct an 

assessment to better understand the extent to which the department’s 

grant programs overlap with one another. DOJ stated it will explore 

options for carrying out such an assessment in an effort to reduce the 

risk associated with unnecessary or inappropriate program 

duplication. For example, DOJ stated it is considering tasking OAAM 

to conduct such an assessment. Since DOJ is developing options for 

how it will implement this recommendation, it is too soon to know what 

specific actions DOJ will take, when they will be completed, and 

whether they will fully address the intent of the recommendation.

• DOJ agreed with the second recommendation that it coordinate within 

and among granting agencies, to the extent possible, before awarding 

grants. DOJ stated that its grant-making agencies will continue to 

Agency Comments 

and Our Evaluation
 

Page 51 GAO-12-517 DOJ Grants Management

closely collaborate and share information prior to making grant 

awards. DOJ also stated it plans to use the results of the assessment 

referenced in the first recommendation to develop a targeted and 

strategic approach for reviewing grant applications during the preaward process. Since DOJ is considering how it will implement this 

recommendation, it is too soon to know what specific actions DOJ will 

take, when they will be completed, and whether they will fully address 

the intent of the recommendation.

• DOJ agreed with the third recommendation that DOJ require its grant 

applicants to report all federal grant funding, including all DOJ 

funding, that they are currently receiving or have recently applied for 

in their grant applications. DOJ stated it plans to use a risk-based 

approach to implement this recommendation, using the results from 

its assessment in response to the first recommendation. This is a 

positive step toward ensuring that DOJ has a more complete picture 

of an applicant’s access to other federal funding. However, since DOJ 

has not yet developed its approach, it is too soon to tell whether 

DOJ’s actions will address the intent of the recommendation.

• DOJ agreed with the fourth recommendation that DOJ provide 

appropriate OJP and COPS Office staff with access to both GMS and 

CMS and appropriate OVW staff with access to CMS. DOJ noted that 

OJP will provide read-only GMS access to COPS Office staff and that 

the COPS Office will provide reports to OJP and OVW from CMS, 

given the technological barriers to providing external system access.

These actions, when implemented, should address the intent of this 

recommendation.

• DOJ agreed with the fifth recommendation that as part of its 

evaluation of its grant management systems, DOJ should ensure it 

assesses the feasibility, costs, and benefits of moving to a single 

grants management system. DOJ stated that it had initiated such a

study and plans to complete it within the next six months. When 

effectively completed, this study, along with any actions taken to 

implement its findings, should address the intent of this 

recommendation.

• DOJ agreed with the sixth recommendation that DOJ ensure the most 

timely reporting possible of grant award information to 

USASpending.gov. DOJ committed to doing its best to ensure timely 

reporting, but did not provide specific actions or plans to address the 

intent of the recommendation.
 

Page 52 GAO-12-517 DOJ Grants Management

• DOJ agreed with the seventh recommendation that DOJ assess 

whether OAAM relies on an appropriate mix of programmatic grant 

monitoring and program assessment, and whether the office could 

support additional program assessments. DOJ stated that additional 

program assessments would be beneficial and contribute to the 

improvement of grant programs and operations. DOJ also stated it 

would explore ways to conduct more program assessments, but did 

not provide specific actions or plans to address the intent of the 

recommendation.

• DOJ agreed with the eighth recommendation that DOJ assess the 

feasibility, costs, and benefits of OAAM providing assessments for 

OVW, in addition to OJP and the COPS Office. DOJ stated that 

discussions have been initiated between OAAM and OVW related to 

this recommendation. This is a positive first step, but it is too soon to 

know whether the results of these discussions and any resulting 

potential future actions will address the intent of the recommendation. 

In addition, DOJ raised concerns about the methodology we used to 

identify overlap in DOJ’s fiscal year 2010 grant program solicitations 

across 10 broad justice themes. DOJ stated that our analysis of potential 

overlap between DOJ funding solicitations substantially overstated the 

number of programs that might be duplicative. DOJ commented that the 

table we used to show the overlap was an indication that DOJ was 

involved in “wasteful duplication.” Our analysis, as summarized in table 2 

of this report, demonstrates overlap in the justice areas that DOJ’s grant 

programs aim to support. Having several overlapping grant programs 

within individual justice areas requires greater visibility and pre-award 

coordination on the part of DOJ to diminish the risk of unnecessary 

duplication at the grant project level. As such, our analysis does not, on 

its own, indicate unnecessary duplication among DOJ grant programs, 

but instead identifies the potential risk of unnecessary duplication. 

Implementing the recommendations in this report that DOJ assess grant 

program overlap and coordinate grant award decisions will help DOJ 

identify areas of overlap and mitigate the risk of unnecessary duplication 

in grants. DOJ also considered the categories we developed for our 

analysis such as “community crime prevention strategies” as too broad 

and exclusive of specialized programs such as community policing. We 

developed our 10 broad justice areas based mainly on programmatic 

information contained on DOJ granting agency websites and other DOJ 

literature and believe they fairly demonstrate overlap among DOJ’s 

various grant programs. We recognize that the more detailed analysis we 
 

Page 53 GAO-12-517 DOJ Grants Management

recommended and DOJ agreed to undertake is necessary to determine 

the extent of any unnecessary duplication.

DOJ also commented that our sample size of grant applications was too 

small in number and was not generalizable. As discussed in this report, 

our sample size was not intended to be generalizable across the entire 

scope of DOJ grant program awards, but instead was meant to illustrate 

the potential for unnecessary duplication. DOJ further commented that 

their investigation of the examples of unnecessary duplication we 

provided proved that no duplication actually existed in the grant 

programs. DOJ conducted its review after we provided our examples and 

focused on how grantees were using the funds they had received. Our 

analysis of potential duplication focused on grant applications—how 

applicants proposed to spend federal grant dollars—and not on the 

verification of activities grantees carried out once DOJ funded them.

DOJ’s plans to improve pre-award coordination are positive steps and we 

believe that by doing so, DOJ will be better positioned to make better 

informed decisions about the financial needs of grantees and 

communities for their proposed projects.

Finally, DOJ expressed concern that the report implies that DOJ is not 

tracking subgrantees’ activities. Our analysis focused on pre-award 

coordination, not DOJ’s efforts to track subgrantee activities. As such, we 

recommended that DOJ use the subgrant award information it does have 

to help inform DOJ’s grant award decision making. We believe that 

subgrant award information could provide DOJ decision makers with a 

more complete financial picture of applicants and the projects they 

propose to be funded by DOJ. 

We are sending copies of this report to the Attorney General, selected 

congressional committees, and other interested parties. In addition, the 

report is available at no charge on the GAO website at 

http://www.gao.gov. 
 

Page 54 GAO-12-517 DOJ Grants Management

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

me at (202) 512-9627 or maurerd@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. Key contributors to this report are listed in 

appendix VII. 

David C. Maurer

Director, Homeland Security and Justice Issues
 

Page 55 GAO-12-517 DOJ Grants Management

List of Congressional Committees

The Honorable Patrick J. Leahy

Chairman

The Honorable Chuck Grassley

Ranking Member

Committee on the Judiciary

United States Senate

The Honorable Lamar Smith

Chairman

The Honorable John Conyers, Jr.

Ranking Member

Committee on the Judiciary

House of Representatives
Appendix I: Objectives, Scope, and 

Methodology

Page 56 GAO-12-517 DOJ Grants Management

This report answers the following questions: (1) To what extent does 

overlap across Department of Justice (DOJ) grant programs exist and 

contribute to the risk of unnecessary duplication in grant awards? (2) To 

what extent has DOJ taken steps to reduce overlap in its grant programs 

and the potential for unnecessary duplication in grant awards? (3) To 

what extent does DOJ use programmatic grant monitoring and 

assessment to determine grant program effectiveness and use the results 

to enhance its grant programs?

To examine the extent to which overlap across DOJ grant programs 

exists, we identified the total number of DOJ grant solicitations for fiscal 

year 2010. To do this, we reviewed the lists posted on the Office of 

Justice Programs (OJP), Office on Violence Against Women (OWV), and 

Community Oriented Policing Services (COPS) Office websites and 

confirmed the currency of the information with DOJ officials. To determine 

whether these solicitations were announcing grant funding available for 

similar or overlapping purposes, we first established 10 categories of 

criminal justice areas. We developed these 10 categories after reviewing 

comparable justice areas identified within OJP’s CrimeSolutions.gov 

website, which OJP officials stated includes themes addressed through 

OVW and COPS Office programs; OJP’s Fiscal Year 2010 Program Plan; 

and other materials from OVW and the COPS Office, such as justice 

program themes from their respective websites. Next, through analyst 

consensus, we sorted the grant solicitations according to the 10 justice 

categories. After identifying solicitations with similar scopes, we then 

reviewed 26 successful grant applications that were awarded under 

similar solicitations to identify and assess specific examples of how the 

recipients planned to use funds from multiple programs in the same or 

similar manner. The sample we reviewed is not generalizable to all DOJ 

grant programs because we did not review all of the more than 11,000 

grant applications that DOJ funded in fiscal year 2011, but it illustrates the 

potential for unnecessary duplication. To determine if DOJ could take 

more action to avoid program overlap that can lead to unnecessary 

duplication, we applied the Domestic Working Group Grant Accountability 

Project’s Guide to Opportunities for Improving Grant Accountability. 

To examine the extent to which DOJ has taken steps to reduce overlap in 

its grant programs and the potential for unnecessary duplication in grant 

awards, we reviewed agency policies, procedures, and guidance on grant 

program design and award, such as the COPS Office Program 

Development Team charter and template, and the OJP Grant Manager’s 

Manual. Further, we interviewed DOJ officials from the three granting 

agencies to obtain additional information on grant program design and 

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 57 GAO-12-517 DOJ Grants Management

award processes, and the extent to which the three agencies coordinate 

and share information. We also visited or conducted phone interviews 

with officials from 11 states, including the five largest and five smallest 

state recipients of Edward Byrne Memorial Justice Assistance Grant 

(JAG) funding. These officials represent the state administering agencies 

(SAA) responsible for distributing JAG and other DOJ formula block grant 

funds to subrecipients in California, Florida, New York, North Dakota, 

Pennsylvania, South Dakota, Rhode Island, Tennessee, Texas, Vermont, 

and Wyoming. These officials provided their views regarding the type and 

timeliness of information on grant awards and subawards they provide to 

and receive from DOJ. We selected these 11 states based on the amount

of JAG funding they receive and the existence of other recipients in their 

communities receiving DOJ discretionary grants for potentially similar 

purposes. The results of these contacts are not generalizable to all states, 

but provided insight into how DOJ grant funds are used locally and into 

the communication between states and DOJ. To determine if JAG 

recipients expended grant funds in fiscal year 2010 on sexual assault 

services, bullet and stab-resistant vests, sex offender registry and 

notification systems, Internet crime against children task forces, hiring 

police officers, and correctional officer salaries, we conducted a webbased survey of all recipients of DOJ JAG grant funding who received an 

award from fiscal years 2005 through 2010. The survey response rate 

related to SAAs was 89 percent, with 50 out of 56 SAAs answering the 

questionnaire. We compared agency grant design and award practices 

against Standards for Internal Control in the Federal Government and 

promising practices identified in the Domestic Working Group Grant 

Accountability Project’s Guide to Opportunities for Improving Grant 

Accountability. 

To analyze the extent to which DOJ uses programmatic grant monitoring 

and assessment to determine grant program effectiveness and uses the 

results to enhance its grant programs, we analyzed DOJ documentation, 

such as assessments DOJ conducted of its own programs and specific 

programmatic grant monitoring reports. We also interviewed DOJ officials 

from the granting agencies, including those tasked with assessment, as 

well as contractors responsible for assessing grant programs for OVW. 

This report focuses solely on the types of assessment conducted by DOJ 

granting agencies on its grant programs. Training and technical 

assistance provided by the department and its program offices and 

bureaus to grantees to support the evaluation of individual grant projects, 

such as the Bureau of Justice Assistance (BJA) Center for Program 

Evaluation and Performance Measurement, is not included in this report. 

Also excluded from this report are the outcome evaluations of the impact 
Appendix I: Objectives, Scope, and 

Methodology

Page 58 GAO-12-517 DOJ Grants Management

of grant programs such as those funded by the National Institute of 

Justice (NIJ).
Appendix II: DOJ Granting Agencies’ 

Organizational Structure

Page 59 GAO-12-517 DOJ Grants Management

Appendix II: DOJ Granting Agencies’ 

Organizational Structure
Appendix III: Structure, Purpose, and Funding 

of DOJ Granting Agencies

Page 60 GAO-12-517 DOJ Grants Management

OJP OVW COPS Office

Establishment and structure OJP, established by the Justice 

Assistance Act of 1984, is the 

primary grant-making arm of 

DOJ. A presidentially appointed 

Assistant Attorney General leads 

OJP. The Assistant Attorney 

General and all OJP bureau 

heads are presidentially 

appointed and confirmed by the 

Senate.

OJP Bureaus and Offices:

• Bureau of Justice Assistance

• Bureau of Justice Statistics

• National Institute of Justice

• Office of Juvenile Justice 

and Delinquency Prevention

• Office for Victims of Crime

• Office of Sex Offender 

Sentencing, Monitoring, 

Apprehending, Registering 

and Tracking

Following the enactment of the 

Violence Against Women Act of 

1994, the department established 

the Violence Against Women 

Office, which later became OVW 

under OJP. OVW now functions 

as a separate and distinct office 

within DOJ and is headed by a 

presidentially appointed, Senateconfirmed Director.

The Attorney General 

established the COPS Office 

in October 1994 to 

administer community 

policing grants authorized 

under the Violent Crime 

Control and Law 

Enforcement Act of 1994. 

The Attorney General 

appoints a Director to head 

the COPS Office.

Purpose OJP provides grants to various 

organizations, including state and 

local governments, universities, 

and private foundations, which 

are intended to develop the 

nation’s capacity to prevent and 

control crime, administer justice, 

and assist crime victims.

OVW administers financial and 

technical assistance to local, 

state, and tribal governments;

courts; nonprofit organizations; 

community-based organizations; 

secondary schools; institutions of 

higher education; and state and 

tribal coalitions. OVW provides 

grants for developing programs, 

policies, and practices aimed at 

ending domestic violence, dating 

violence, sexual assault, and 

stalking.

The COPS Office provides 

grants to and shares 

information with the state, 

local, territory, and tribal law 

enforcement agencies to 

advance community policing. 

Programs and funding From fiscal years 2005 to 2012, 

OJP received approximately $24 

billion for OJP grant programs.

In 2010, almost 3 billion was 

available to OJP to fund grants, 

and OJP issued 223 solicitations 

for grants.a According to OJP, it 

awarded nearly 5,000 grants in 

2010.

From fiscal years 2005 to 2012, 

OVW received approximately 

$3.4 billion for OVW grant 

programs.

In 2010, OVW received $418.5 

million for OVW grant programs, 

and OVW issued 19 solicitations 

for grants.

From fiscal years 2005 to 

2012, the COPS Office 

received approximately $5.3 

billion to fund COPS Office 

grant programs.

In 2010, the COPS Office 

received $791.6 million to 

fund COPS Office grants, 

and the COPS Office issued 

nine solicitations for grants. 

Source: GAO analysis of information from DOJ.

Note: Funding levels in fiscal year 2009 include amounts appropriated through the American 

Recovery and Reinvestment Act of 2009. See Pub. L. No. 111-5, 123 Stat. 115, 129-30.

Appendix III: Structure, Purpose, and 

Funding of DOJ Granting Agencies
Appendix III: Structure, Purpose, and Funding 

of DOJ Granting Agencies

Page 61 GAO-12-517 DOJ Grants Management

a

Solicitations are announcements of new grant funding available and explain areas for which funding 

can be used. These numbers reflect solicitations provided by each individual office and do not reflect 

any joint solicitations, which are those offered in tandem with other program offices, either within or 

external to DOJ (e.g., other DOJ components or federal agencies).
Appendix IV: Consolidated, Braided, and 

Blended Grant Program Solicitations

Page 62 GAO-12-517 DOJ Grants Management

According to DOJ officials, there are three ways in which DOJ grant 

programs can be merged or better coordinated—through consolidation, 

braiding, and blending. Figures 4,5, and 6 explain these mechanisms.

Figure 4: Consolidated Grant Programs

Appendix IV: Consolidated, Braided, and 

Blended Grant Program Solicitations
Appendix IV: Consolidated, Braided, and 

Blended Grant Program Solicitations

Page 63 GAO-12-517 DOJ Grants Management

Figure 5: Braided Grant Programs
Appendix IV: Consolidated, Braided, and 

Blended Grant Program Solicitations

Page 64 GAO-12-517 DOJ Grants Management

Figure 6: Blended Grant Programs
Appendix V: Office of Audit Assessment and 

Management Structure

Page 65 GAO-12-517 DOJ Grants Management

The three divisions within OAAM—the Audit and Review Division, the 

Program Assessment Division, and the Grants Management Division—

together carry out the following primary functions of OAAM for one or 

more of DOJ’s three granting agencies:

• coordinates audits, such as Single Audits that independent 

nongovernmental auditors conduct, as well as those that the Inspector 

General (IG) and GAO conduct,

1

• reviews internal control processes (A-123),

2

• manages DOJ’s High Risk Grantee Program, which applies criteria to 

identify grantees most at risk of fraud, waste, or abuse in use of their 

grant funds.

and

• oversees OJP and COPS Office programmatic monitoring, including 

development and implementation of standards and protocols, and

• assesses grant programs and initiatives of OJP and the COPS Office, 

as well as operational activities.

• serves as the primary resource for OJP grants management policies 

and procedures by producing authoritative guidance,

• develops and facilitates grants related training to staff and grantees,

 

1

Pursuant to the Single Audit Act, as amended, each nonfederal entity that expends 

$500,000 or more in federal awards, including grants and other assistance, in a fiscal year 

must obtain an annual “Single Audit,” which includes an audit of the entity’s financial 

statements and a schedule of the expenditure of federal awards, as well as, among other 

things, a review of related internal controls. See 31 U.S.C. §§ 7501-07.

2

Office of Audit, Assessment, and Management (OAAM) annually reviews OJP’s critical 

business processes in the areas of financial management, information technology, and 

grant management and makes recommendations to enhance and strengthen internal 

controls as required by OMB Circular A-123, “Management’s Responsibility for Internal 

Control.” 

Appendix V: Office of Audit Assessment and 

Management Structure

Audit and Review Division

Program Assessment 

Division

Grants Management 

Division
Appendix V: Office of Audit Assessment and 

Management Structure

Page 66 GAO-12-517 DOJ Grants Management

• manages Grants Management System (GMS) and other tools and 

systems, and

• facilitates OJP’s business process improvement efforts.
Appendix VI: Comments from the Department 

of Justice

Page 67 GAO-12-517 DOJ Grants Management

Appendix VI: Comments from the 

Department of Justice
Appendix VI: Comments from the Department 

of Justice

Page 68 GAO-12-517 DOJ Grants Management
Appendix VI: Comments from the Department 

of Justice

Page 69 GAO-12-517 DOJ Grants Management
Appendix VI: Comments from the Department 

of Justice

Page 70 GAO-12-517 DOJ Grants Management
Appendix VI: Comments from the Department 

of Justice

Page 71 GAO-12-517 DOJ Grants Management
Appendix VI: Comments from the Department 

of Justice

Page 72 GAO-12-517 DOJ Grants Management
Appendix VI: Comments from the Department 

of Justice

Page 73 GAO-12-517 DOJ Grants Management
Appendix VII: GAO Contact and Staff 

Acknowledgments

Page 74 GAO-12-517 DOJ Grants Management

David C. Maurer, (202) 512-9627 or maurerd@gao.gov

In addition to the contact named above, Joy Booth, Assistant Director, 

and Christian Montz, Analyst-in-Charge, managed this assignment. Julie 

E. Silvers, Marya Link, Caitlin Carlberg, and Michael Sweet made 

significant contributions to the work. Michele Fejfar assisted with design 

and methodology. Janet Temko and Tom Lombardi provided legal 

support. Lara Miklozek provided assistance in report preparation.

Appendix VII: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(440971)
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