The Honorable Bob Schaffer,

House of Representatives

United States General Accounting Office

GAO

October 2001 JUVENILE JUSTICE

Better Documentation

of Discretionary Grant

Monitoring Is Needed

GAO-02-65
Page i GAO-02-65 Better Grant Monitoring Needed

Letter 1

Results in Brief 2

Background 5

Scope and Methodology 5

Discretionary Grant Monitoring Process 7

Grant Files Contained Limited Documentation That Monitoring

Occurred 11

OJJDP Does Not Systematically Determine Staff Compliance With

Its Monitoring Requirements 18

Conclusions 19

Recommendations for Executive Action 19

Agency Comments and Our Evaluation 20

Appendix I OJJDP’s Discretionary Grant Award Process 22

Program Plan Is to Describe Goals and Priorities 25

Program Announcements and Application Kits Are to Solicit

Applicants for Programs 25

Peer Review Panels Are to Help Determine Which Grant

Applications Are Funded 25

Final Decision to Award Discretionary Grants 26

Appendix II Comments From the Department of Justice 28

GAO Comment 36

Appendix III GAO Contacts and Staff Acknowledgments 37

GAO Contacts 37

Acknowledgments 37

Figures

Figure 1: Key Steps in OJJDP’s Process for Planning and

Announcing Grants 23

Figure 2: Overview of OJJDP Grant Application and Review

Process 24

Abbreviations

OIG Office of the Inspector General

OJJDP Office of Juvenile Justice and Delinquency Prevention

OJP Office of Justice Programs

Contents
Page 1 GAO-02-65 Better Grant Monitoring Needed

October 10, 2001

The Honorable Bob Schaffer

House of Representatives

Dear Mr. Schaffer:

The Office of Juvenile Justice and Delinquency Prevention (OJJDP) was

established to help states and communities prevent and control juvenile

delinquency and improve their juvenile justice systems.1

 OJJDP provides

funding to states, territories, localities, and private organizations through

block grants2

 and discretionary funding.3 Between September 1996 and

September 2000, the number of active OJJDP discretionary grants has

more than tripled, from 240 to 790, and the related funding for active

grants almost doubled from $286 million to $555 million.

Monitoring these grant activities is a key management tool to help ensure

that funds are being properly spent. In May 1996, we testified that the

official grant files for discretionary grants generally contained plans for

agency monitoring, but little evidence that it occurred.4

Your original request asked about various aspects of OJJDP’s grant

management. We will be responding to that request with two reports. This,

the first, addresses how well OJJDP monitors its grants to ensure that

grantees properly implement the programs that the grants support. The

second report will discuss OJJDP grantee reporting requirements, the

 1

The Juvenile Justice and Delinquency Prevention Act of 1974, P.L. 93-415, as amended, 42

U.S.C. 5601, et seq. It is one of five components of the Department of Justice’s Office of

Justice Programs (OJP); the other four components are the National Institute of Justice,

Bureau of Justice Statistics, Bureau of Justice Assistance, and Office for Victims of Crime.

2

Block grants are awarded to the states to provide assistance to state and local units of

government for programs in accordance with legislative requirements.

3

Discretionary grants are awarded to states, units of local government, or private

organizations at the discretion of the awarding agency. Most discretionary awards are

competitive in nature in that there are limited funds available and a large number of

potential recipients.

4

Testimony before the Subcommittee on Youth Violence, Committee on the Judiciary, U.S.

Senate, Juvenile Justice: Selected Issues Relating to OJJDP’s Reauthorization

(GAO/T-GGD-96-103, May 8, 1996).

United States General Accounting Office

Washington, DC 20548
Page 2 GAO-02-65 Better Grant Monitoring Needed

number of juveniles OJJDP programs have directly served, and our

analysis of the program impact evaluations OJJDP has funded of its

programs.

Specifically, we reviewed and are reporting on the (1) OJJDP grant

monitoring process, (2) extent to which OJJDP documented its

discretionary grant5

 monitoring activities, and (3) process it uses to

oversee those activities. In appendix I, we describe OJJDP’s award process

for discretionary grants.

To address these areas, we met with officials from OJJDP and OJP

concerning discretionary grant monitoring activities, including OJJDP’s

activities to oversee its monitoring. We reviewed OJP and OJJDP’s grant

monitoring requirements and selected and reviewed a representative

sample of OJJDP demonstration discretionary grants that were active in all

of fiscal years 1999 and/or 2000. We did this to determine whether OJJDP

officials were adhering to the agency’s discretionary grant monitoring

requirements and how the results of its monitoring efforts were

documented in its grant files. We also made a similar review of a

representative sample of OJJDP training and technical assistance grants.6

To determine OJJDP’s oversight role of its discretionary grant monitoring

activities, we reviewed information such as performance work plans. We

also discussed with OJJDP officials the steps it has taken to improve

previously reported monitoring problems.

Our analysis did not address the quality of how OJJDP monitored its

grantees. For example, we reviewed documentation to determine whether

OJJDP made required site visits, but we could not review the quality of the

site visit contact.

OJJDP has specific program monitoring and documentation requirements

for its discretionary grants. These monitoring requirements include such

activities by the grant manager as making quarterly telephone calls, on and

off-site grant monitoring visits, and reviewing interim and final products.

In addition, all discretionary grantees are required to submit categorical

 5

Includes cooperative agreements.

6

For both discretionary and training and technical assistance grants, we express our

confidence in the precision of our sample results as a 95-percent confidence interval.

Unless otherwise noted, all percentage estimates have confidence intervals plus or minus

10 percentage points or less.

Results in Brief
Page 3 GAO-02-65 Better Grant Monitoring Needed

assistance progress reports that summarize project activities and quarterly

financial status reports for review by grant managers. OJJDP also requires

certain documentation at the time of grant closeouts. At the time of our

review, OJJDP was reviewing its monitoring practices, including how to

improve its grant records.

Our review of OJJDP’s official grant files and grant managers’ files for the

most recent award for a representative sample of grants active in all of

fiscal years 1999 and/or 2000, showed that OJJDP was not consistently

documenting its grant monitoring activities. Our current observations are

similar to those we reported in May 1996 about the agency’s lack of

documentation of its monitoring activities.

• The grant managers’ monitoring plans for the most recent awards for 79 of

89 demonstration grants and 34 of 45 training and technical assistance

grants had specific requirements for telephone contacts (e.g., monthly or

quarterly). There was no documentation showing that the requirement for

telephone contacts was met in 96 percent of the demonstration grants and

in any of the training and technical assistance grants.

• The grant managers’ monitoring plans for the most recent awards for 66

demonstration grants and 20 training and technical assistance grants had

specific requirements for on-site visits. There was no documentation

showing that the requirement for site visits was met in 88 percent7

 of the

demonstration grants and 90 percent8

 of the training and technical

assistance grants.

• Progress and financial reports filed by the grantee are required for the

entire grant period. In 56 percent of the 89 demonstration grant files and

80 percent9

 of the 45 training and technical assistance grants files

reviewed, the progress reports did not cover the entire grant period. In 65

percent of the 89 demonstration grant files and 60 percent10 of the 45

training and technical assistance grant files reviewed, the financial status

reports did not cover the entire grant period.

 7

The estimated range is between 77 and 95 percent.

8

The estimated range is between 68 and 99 percent.

9

The estimated range is between 69 and 88 percent.

10The estimated range is between 48 and 71 percent.
Page 4 GAO-02-65 Better Grant Monitoring Needed

OJJDP does not systematically monitor grant managers’ compliance with

its monitoring requirements or guidance, or assess the effectiveness of

OJJDP grant monitoring practices. According to OJJDP officials, one

method of overseeing compliance with the monitoring requirements is

their review of performance work plans. However, these plans referred,

for example, to monitoring grants to ensure that the projects meet their

goals and milestones, with no clear expectations regarding monitoring

requirements, such as site visits or telephone monitoring, or regarding

documentation of these contacts and reviews of grantees progress and

financial reports.

We are making recommendations regarding OJJDP’s need to improve its

documentation of discretionary grant monitoring activities.

The Acting Assistant Attorney General provided us with written comments

on a draft of this report by letter dated September 19, 2001. In general, she

agreed with our findings and recommendations. However, she stated that

we had not adequately considered the fact that the associated cost of

monitoring has not been commensurate with OJJDP’s available budgetary

resources. She also commented that we had not adequately considered

OJJDP’s recent efforts in a major OJP-wide effort to improve grant

monitoring practices and establish uniform policies.

While we are encouraged by OJJDP’s stated dedication to improving its

grant monitoring practices, we believe the results of our review are

sufficient to conclude that OJJDP’s discretionary grant monitoring is not

effective. We do recognize in the report, the rapid growth in discretionary

grants over the past 5 years. However, we believe that monitoring is a

critical management control that allows OJJDP to know that federal

dollars have been appropriately spent. This conclusion is supported by the

Department of Justice’s Office of the Inspector General (OIG). In a

December 2000, report to the Congress,11 the Inspector General cited grant

management as one of the 10 most serious management challenges facing

Justice. The Inspector General stated that Justice’s multi-billion dollar

grant programs are a high risk for fraud given the amount of money

involved and the tens of thousands of grantees. Among other things, the

Inspector General said that past OIG reviews have determined that many

grantees did not submit the required program monitoring and financial

reports and that program officials’ on-site monitoring reviews did not

consistently address all grant conditions. The full text of the Acting

 11Management Challenges in the Department of Justice (Dec. 1, 2000).
Page 5 GAO-02-65 Better Grant Monitoring Needed

Assistant Attorney General’s comments and our evaluation of them are

presented in appendix II and elsewhere in this report, as appropriate.

OJJDP, within the U.S. Department of Justice, is the primary federal

agency responsible for the prevention and control of juvenile delinquency

in the United States. This includes preventing, treating and controlling

youth gang activity and violence through sponsored research, evaluation,

and demonstrating new approaches for communities across the country.

The initiatives are carried out by seven components within OJJDP:

Research and Program Development Division, Training and Technical

Assistance Division, Special Emphasis Division, State Relations and

Assistance Division, Information Dissemination Unit, Concentration of

Federal Efforts Program, and Child Protection Division. OJJDP annual

appropriations have more than tripled from $162 million in fiscal year

1996, with 71 authorized staff positions, to $568 million in fiscal year 2000,

with 87 authorized staff positions.

In 1996, we reviewed the operations of OJJDP. We found that official grant

files for discretionary grants generally contained monitoring plans, but

little evidence that monitoring occurred. We reported that none of the

grant files had documentation of telephone contacts, site visits, or product

reviews. Also, no quarterly program and financial reports were included in

11 of the 78 files for which projects had been ongoing for at least 2

quarters at the time of our review, and one or more reports were missing

from another 61 files. In addition, only 6 of the 78 files had program and

financial reports for all quarters of work completed.

In commenting on our testimony, the OJJDP Deputy Administrator said

that the heavy workload of OJJDP staff may have resulted in a lack of

monitoring records and that, as a result of the our 1996 review, OJJDP

would take the steps necessary to improve records.

To address the first objective, to report on OJJDP’s grant monitoring

process, we reviewed applicable federal laws and regulations as well as

OJP and OJJDP policies and procedures. We also interviewed staff in

OJJDP and OJP’s Office of the Comptroller.

To accomplish the second objective, to report on OJJDP’s documentation

of its discretionary grant monitoring activities, we reviewed probability

samples of official grant files and grant managers’ files using a data

collection instrument to record whether required monitoring activity

occurred—that is, that the progress reports, financial reports, and other

Background

Scope and

Methodology
Page 6 GAO-02-65 Better Grant Monitoring Needed

required documents were included in the files. For each grant, we also

reviewed the most recent award covering 12 months to examine specific

monitoring requirements and activities, such as telephone calls and site

visits. Specifically, we reviewed a random sample of 89 of 545 OJJDP

demonstration discretionary grants, and 45 of 83 training and technical

assistance discretionary grants that were active in all of fiscal years 1999

and/or 2000. The results of these samples are representative of the

populations from which they were drawn. We express our confidence in

the precision of our sample results as a 95-percent confidence interval.

Unless otherwise noted, all percentage estimates have confidence

intervals plus or minus 10 percentage points or less.

To determine the timeliness of grantee progress reports and financial

status reports, we reviewed all such reports for OJJDP demonstration and

training and technical assistance discretionary grants from the initiation of

the grant through the date of our review.

For our review, we provided a list of the selected grants to OJJDP and

OJP’s Comptroller. Because we did not always receive the grant files in the

order requested, we reviewed them out of order. When files were missing

or lost, we substituted replacement files. After our review was complete,

some of the missing files were located. We did not review the missing files

but used the substitute files that were a part of our random sample. Four

grant files were not found in time to be included in our review.12 In

addition, when only one of the two files (the official grant file or the grant

managers’ file) was available, we used the available file to complete the

data collection instrument. We have no reason to believe that the

substitution of files affected the validity of our sample because they were a

part of our random sample.

To determine whether OJJDP grant closeout procedures were

implemented in accordance with OJP policy, we reviewed grant files in

our sample whose project periods expired before August 31, 2000. For our

review, we focused on required closeout documentation, such as final

progress or performance reports, final financial status reports, grant

 12In commenting on a draft of this report, the Acting Assistant Attorney General stated

reasons for the four official grant files not being accessible during our review. She said one

file was not provided due to an incorrect grant number on our list provided to the

Comptroller’s Control Desk when the official grant files were requested. However, the

incorrect grant number was contained in the list of grants that OJJDP provided to us. One

of the remaining grant files had been sent to storage. OJP staff had checked out a third, and

the last was missing. This last file is being reconstructed according to the Acting Assistant

Attorney General.
Page 7 GAO-02-65 Better Grant Monitoring Needed

checklist, and closeout notification and grant adjustment notice. Our

results should not be projected to the universe of cases in our sample.

To address the third audit objective, to report on the processes OJJDP

uses to oversee monitoring activities, we examined OJJDP’s monitoring

and oversight of its grant managers’ compliance with applicable laws,

regulations, and procedures for monitoring. We obtained information from

OJJDP officials at headquarters and obtained data related to these

activities, such as performance work plans. To determine the requirements

in the performance work plans, OJJDP officials gave us a plan that they

considered to be representative.

Our work was done between March 2001 and September 2001 in

accordance with generally accepted government auditing standards.

After OJJDP awards discretionary grants, OJP policies require OJJDP to

monitor the grants and related activities and document the monitoring

results in the grant managers’ program files and OJP’s Office of the

Comptroller official grant files. The monitoring is to ensure

• compliance with relevant statutes, regulations, policies, and guidelines;

• responsible oversight of awarded funds;

• implementation of required programs, goals, objectives, tasks, products,

time lines, and schedules;

• identification of issues and problems that may impede grant

implementation; and

• adjustments required by the grantee as approved by OJJDP.13

One of the OJJDP grant managers’ main responsibilities is project

monitoring. Each grant manager prepares a monitoring plan as part of a

grant manager’s memorandum recommending initial or continuation

funding. The level of monitoring required is based upon the stated

monitoring plan in the grant manager’s memorandum. The memorandum

includes

• an overview of the project;

• a detailed description of what type of activities the grantee plans on

implementing;

 13OJP, OJP Handbook: Policies and Procedures for the Administration of OJP Grants

(OJP HB 4500.2C, Feb. 1992), p. 93.

Discretionary Grant

Monitoring Process
Page 8 GAO-02-65 Better Grant Monitoring Needed

• a discussion of past monitoring activities and assessments, if the grant is a

multiyear grant that is awarded yearly;

• an identification of monitoring activities to be performed for the current

project period; and

• a discussion of the financial justification for the grant funds and of the

cost-effectiveness evaluation of the application.

Another part of the monitoring plan may list specific activities or

milestones to be monitored by the grant manager.

The 1991 OJJDP Monitoring Desk Book contains specific monitoring

procedures that grant managers used for monitoring OJJDP’s discretionary

grants. Monitoring activities documented included site visit reports and

quarterly monitoring telephone calls as well as other significant telephone

calls.

Also, according to the OJP 1992 Handbook, all discretionary grantees are

required to submit categorical assistance progress reports that summarize

project activities and quarterly financial status reports for review by grant

managers. The OJP Handbook also stated that when all of the grant funds

are spent, all grant activities are completed, and all grantee and grant

managers’ administrative requirements, including all paperwork and

review of grant files, are completed, the grant managers have to close out

the grant. (See app. I for a detailed discussion of the grant award

processes.)

The OJP Comptroller’s Control Desk is to maintain the official grant files

and is responsible for tracking the receipt of all grant documents. The

Control Desk receives the progress reports, files the original in the official

grant file, and forwards a copy to the cognizant program office. The grant

manager is responsible for the timely acceptance, review, and analysis of

progress reports.

The Comptroller’s Monitoring Division performs an in-house review of

various program and financial documents contained in the official grant

files. The Office of the Comptroller also performs risk-based on-site

financial reviews of grantee organizations to monitor administrative and

financial capability. The Comptroller applies risk-based criteria to a

universe of grants to develop a sample for each fiscal year monitoring

plan. The risk-based criteria include the dollar amount of the grant, new

grantees, new grant programs, and programs with known problems. The

Comptroller excludes from its sample any grantee organizations that were

subject to its other on-site financial monitoring or to audit by the Office of

the Inspector General during the last 2 years. According to OJP officials,
Page 9 GAO-02-65 Better Grant Monitoring Needed

the purpose of the reviews is to provide as much of a comprehensive

financial review as possible without going on site. 14 Our review of the

results of the Comptroller’s in-house financial reviews of the grants in our

sample disclosed that they identified a number of problems similar to our

own observations. These included missing program and financial

documents and program and financial monitoring not always being

documented in a timely manner.15

In commenting on a draft of this report, the Acting Assistant Attorney

General stated that there was no mention of delinquent documentation of

financial monitoring during our review, nor was there any evidence cited

in our draft report to support the contention that financial monitoring was

not documented in a timely manner. However, contrary to the Acting

Assistant Attorney General comment, our review found that there was no

documentation that financial reports were generally reviewed and that

many of the reports were not submitted in a timely manner. Specifically,

we found one case where no progress or financial reports had been

submitted during the life of a grant, and it was not discovered until almost

a full year after the award date (see p. 15).

In 1991, OJJDP issued a Monitoring Desk Book, which incorporated

material from OJP’s 1987 Handbook, including a formula for determining

the monitoring level requirements for the grant. According to OJJDP

officials, this formula is applied to determine how often a grantee will be

visited and officially contacted for monitoring purposes. This formula

applies a weight to issues such as program priority (i.e., how important is

the grant within the context of the OJJDP’s goals and objectives), size of

grant, grantee’s need for assistance, and anticipated difficulties in

implementing the approach. The grant manager assigns a weight or “score”

to each of these criteria, which are added together for a total score. This

 14In October 2000, the Comptroller eliminated its review of progress reports because

Comptroller officials believed that it was a duplication of efforts between the program

offices and the Comptroller’s Office, and it wanted to streamline closure of outstanding

reviews.

15The Monitoring Division made 939 in-house financial reviews in fiscal year 1999, of which

one OJJDP demonstration grant and five training and technical assistance grants were

included in our review. In fiscal year 2000, the division made 1,248 financial reviews, of

which three OJJDP demonstration grants and one training and technical assistance grant

were included in our review. As of August 2001, the financial reviews included eight OJJDP

demonstration grants and three training and technical assistance grants that were included

in our review.

Outdated Monitoring

Policies and Procedures

Were Being Used
Page 10 GAO-02-65 Better Grant Monitoring Needed

score assigns the grant to a category that defines the specific number of

on-site and off-site visits and the frequency of monitoring calls.

In February 1992, OJP revised its 1987 Handbook and eliminated the score

requirement to determine the monitoring level of a project. However,

OJJDP grant managers still use the instructions to determine the

monitoring level of a project. We found in our file reviews that 72 of the 89

demonstration grant files and 14 of the 45 training and technical assistance

grant files had a score or level indicating monitoring requirements. Using

the obsolete monitoring requirement to establish grant manager’s grant

monitoring responsibilities may not result in the most efficient use of their

time or in the needed monitoring to ensure grantee compliance, as pointed

out by the Deputy Administrator in May 1996. He said that site visits did

not occur because they are expensive and time-consuming. He added that

OJJDP might need to revise some procedures, noting that a site visit once

every 2 years and some interim telephone monitoring may be more

appropriate than annual visits. Current OJP policy provides flexibility to

determine monitoring needs (e.g., site visits as appropriate) consistent

with resource availability as compared with a monitoring level that is

associated with a specific monitoring requirement that may not be

achievable with existing resources.

Since April 2001, OJJDP has been engaged in a review of its monitoring

practices.16 According to OJJDP officials, this includes a thorough review

of its monitoring practices, including improvement of its grant records.

OJJDP indicated that a Working Group on Monitoring was created and

charged with reviewing its revised OJP Handbook: Policies and

Procedures for the Administration of OJP Grants to identify new and

modified policies and assess the need for training; to review OJJDP’s own

policies and procedures to ensure compliance with those in the revised

OJP Handbook; and to determine whether there is a continued need for

the OJJDP Monitoring Desk Book (1991), and if so, how it should be

updated. In addition, OJJDP recently embarked on an overhaul of its grant

closeout practices to improve its monitoring records. In spring 2000, it

launched a grant closeout effort jointly with the Office of the Comptroller

that is intended to significantly reduce the backlog of grants requiring

closeout. As part of this activity, grant files were reviewed, and relevant

documentation was collected.

 16As of August 2001, OJJDP’s efforts were ongoing.

OJJDP Current Activities
Page 11 GAO-02-65 Better Grant Monitoring Needed

OJJDP requires its grant managers to document their monitoring of

discretionary grants. This documentation is to include the development

and retention of a grant manager’s memorandum for each grant containing

a plan to follow for monitoring the project. In addition, progress reports

documenting progress achieved in relation to project milestones are

required from all grantees. Required documentation also is to include

quarterly financial reports from grantees. In addition, OJJDP requires

certain documentation at the time of grant closeouts.

While the grant files generally contained monitoring plans,17 OJJDP grant

managers were not consistently documenting their monitoring efforts

according to the monitoring plans. The grant files generally did not contain

documentation showing required telephone contacts and site visits.18

Further, progress and financial reports did not cover the entire grant

period over half of the time. For those grants in our sample that were

closed, most did not contain documentation showing compliance with

closeout procedures. We identified some of these same documentationrelated problems in May 1996.

We compared the proposed monitoring activities in the grant manager’s

monitoring plan for 89 of 545 OJJDP demonstration discretionary grant

files and 45 of 83 OJJDP training and technical assistance discretionary

grant files to actual monitoring documentation. Our comparisons of the

proposed to actual documented monitoring revealed that OJJDP grant

managers were not consistently following the monitoring plan.

• Telephone Contacts. The grant managers’ monitoring plans for the most

recent awards for 79 demonstration grants and 34 training and technical

assistance grants had specific requirements for telephone contacts (e.g.,

monthly or quarterly). There was no documentation showing that the

requirement for telephone contacts was met in 96 percent of the

demonstration grants and in any of the training and technical assistance

grants. Documentation was present that showed that some, but not all, of

the required telephone contacts had been made for 49 percent19 of the

 17While required for every award, our review of each grant’s most recent award showed

that 1 of the 89 demonstration grant files and 3 of the 45 technical assistance grant files

were missing the monitoring plan.

18The absence of documentation in the grant file does not necessarily mean that monitoring

did not occur.

19The estimated range is between 38 and 61 percent.

Grant Files Contained

Limited

Documentation That

Monitoring Occurred
Page 12 GAO-02-65 Better Grant Monitoring Needed

demonstration grants and 41 percent20 of the training and technical

assistance grants.

• Site Visits. The grant managers’ monitoring plans for the most recent

awards for 66 demonstration grants and 20 training and technical

assistance grants had a specified number of on-site visits to be made.

There was no documentation showing that the requirement for site visits

was met in 88 percent21 of the demonstration grants and 90 percent22 of the

training and technical assistance grants. Documentation was present that

showed that some, but not all, of the required on-site visits had been made

for 6 percent of the demonstration grants and 10 percent23 of the training

and technical assistance grants. When site visits are made to grantees, a

written site visit report is to be prepared. Of the awards that had any

evidence of site visits, such as memos or e-mails referring to the visit, 7 out

of the 12 demonstration grants and 2 out of the 4 training and technical

assistance grants had any of the OJP-required, written site visit reports.

In commenting on a draft of this report, the Acting Assistant Attorney

General informed us that most grant managers prepare site visit reports

after an on-site review, as their travel vouchers are not forwarded for

payment unless the reports are attached. She noted that the grant

managers do not routinely forward copies of the reports to the official

grant and program files. She said that a copy of the reports is filed in the

grant manager’s travel folders that we did not review. However, according

to the OJP Handbook, the original site visit report is to be placed in the

official grant file. While the grant managers’ travel folders may contain site

visit reports, the official grant files kept by the OJP Comptroller’s Control

Desk are the official record of the history and activity of the grant. As

such, we reviewed the official grant files as well as the grant managers’

files for required grant documents and not the travel voucher folders.

In another comment to a draft of this report, the Acting Assistant Attorney

General told us that monitoring plans that call for on-site visits by grant

managers are contingent upon staffing capacity and administrative

resources and not requirements. Our review indicated that, contrary to the

 20The estimated range is between 25 and 59 percent.

21The estimated range is between 77 and 95 percent.

22The estimated range is between 68 and 99 percent.

23The estimated range is between 1 and 32 percent.
Page 13 GAO-02-65 Better Grant Monitoring Needed

Acting Assistant Attorney General’s comment, certain specific program

monitoring requirements are included in the OJP Handbook, such as

creating monitoring plans and writing site visit reports within 10 days of a

site visit. To be useful, monitoring plans should be feasible. If they are not

feasible, then they will not be helpful guidance for monitoring. While it is

entirely reasonable to expect that some planned site visits will not take

place (for a variety of reasons), the proportion of site visits specified to

occur that were not documented seems to indicate that either they

occurred but were not documented or monitoring plans for site visits were

infeasible.

• Progress and Financial Reports. According to the OJP Handbook,24

recipients of discretionary grants are required to submit initial and then

semiannual categorical assistance progress reports documenting progress

achieved in relation to project milestones. Before December 31, 1995,

progress reports were due every quarter. Since March 1, 1996, progress

reports have been due every 6 months. This report must be submitted

within 30 days after the end of the reporting period for the life of the

award. A final report, which provides a summary of progress toward

achieving the goals and objectives of the award, significant results, and

any products developed under the award, is due 90 days25 after the end

date of the award.

We found that in 56 percent of the 89 demonstration grant files and 80

percent26 of the 45 training and technical assistance grant files reviewed,

the progress reports did not cover the entire grant period. In addition, 7

percent of the demonstration grants files and 4 percent of the training and

technical assistance grants had no progress reports.

We also found that 56 percent of the progress reports submitted for

demonstration grants were filed on time; for the other 44 percent, the

number of days late ranged from 1 to 545, with 62 percent of the reports

 24In January 2001, OJP released a revised Grant Management Policies and Procedures

Manual to update and codify OJP’s current policies regarding its business practices.

According to OJP officials, this document superceded and canceled OJP HB 4500.2C,

Policies and Procedures for the Administration of OJP Grants, dated February 19, 1992.

The revised policies and procedures were not applicable during the period of our review.

25The OJP Grant Management Policies and Procedures Manual dated January 2001,

changed the final progress report due date from 90 days to 120 days. The revised policies

and procedures were not applicable during the period of our review.

26The estimated range is between 69 and 88 percent.
Page 14 GAO-02-65 Better Grant Monitoring Needed

for demonstration grants being late up to 30 days and 24 percent between

31 and 90 days.27 We found that 42 percent of the training and technical

assistance grant reports were filed on time; for the other 58 percent, the

number of days late ranged from 1 to 297, with 76 percent being late up to

30 days and 15 percent between 31 and 90 days.

According to the OJP Handbook, all discretionary grantees are required to

submit quarterly financial status reports to OJP’s Office of the Comptroller

Control Desk, which maintains the official grant files. Copies are

disseminated to the appropriate financial analysts and cognizant grant

managers. These quarterly reports are required for all active grants, even if

there has been no financial activity during the reporting period. According

to OJP officials, reports are considered delinquent, for payment purposes,

if not received 45 days after the end of each calendar quarter. The final

financial status report is due 90 days28 after the end of the grant period or

extension. Future awards and fund drawdowns may be withheld if the

progress and financial status reports are delinquent.

We found that in 65 percent of the 89 demonstration grant files and 60

percent29 of the 45 training and technical assistance grant files reviewed,

the financial status reports did not cover the entire grant period. We also

found that 67 percent of the financial status reports submitted for

demonstration grants were filed on time; for the other 33 percent, the

number of days late ranged from 1 to 367, with 54 percent of the reports

for demonstration grants being late up to 30 days and 34 percent between

31 and 90 days.30 We found that 70 percent of the training and technical

 27We reviewed all 321 demonstration grant progress reports and 252 training and technical

assistance grant progress reports in the files from the initiation of the grant through the

date of our review for grants that were active in all of fiscal years 1999 and/or 2000. We

excluded 13 progress reports for demonstration grants and 16 reports for training and

technical assistance grants because of data-related problems, such as missing submission

dates.

28The OJP Grant Management Policies and Procedures Manual dated January 2001,

changed the final financial status report due date from 90 days to 120 days. The revised

policies and procedures were not applicable during the period of our review.

29The estimated range is between 48 and 71 percent.

30We reviewed all 615 demonstration financial status reports and 603 training and technical

assistance financial status reports in the files from the initiation of the grant through the

date of our review for grants that were active in all of fiscal years 1999 and/or 2000. We

excluded 18 financial status reports for demonstration grants and 6 reports for training and

technical assistance grants because of data-related problems, such as missing submission

dates.
Page 15 GAO-02-65 Better Grant Monitoring Needed

assistance grant reports were filed on time; for the other 30 percent, the

number of days late ranged from 1 to 353, with 72 percent being late up to

30 days, and 19 percent between 31 and 90 days.

Further, our review found no documentation in the files that OJJDP grant

managers regularly reviewed these reports, as required by OJP. Without

such reviews, OJJDP does not have assurances that the grants are being

properly administered. For example, one grant we reviewed had no

documentation of required semiannual categorical assistance progress

reports or quarterly financial reports in the file for the entire life of the

award. The project and budget periods ran from October 1, 1999, to

September 30, 2000. A $300,000 grant was awarded on March 7, 2000 (6

months after the start of the budget period). The grantee was required to

submit an initial and then semiannual categorical assistance progress

reports documenting progress achieved in relation to project milestones,

starting June 30, 2000, and every 6 months thereafter. The grantee was also

required to submit a quarterly financial status report within 45 days after

the quarter ended, starting May 15, 2000, and every quarter thereafter.

Although no progress or financial reports had been submitted during the

life of the grant period, OJJDP did not discover this until almost a full year

from the award date. Nevertheless, OJJDP extended the grant period for

an additional year to allow the grantee to spend the funds for the project,

which it had not drawn down during the grant period. Missing progress

reports and quarterly financial reports increase the risk that OJJDP might

not be able to identify and rectify grantee’s program and financial

problems in a timely manner.

In commenting on a draft of this report, the Acting Assistant Attorney

General acknowledged this lack of documentation, but did not agree that

it meant that OJJDP had not been monitoring grants to ensure they were

being properly implemented. From our perspective, this lack of

documentation suggests to us that OJJDP does not know the extent to

which grant managers were carrying out their monitoring responsibilities

to ensure that grants were being properly implemented.

Despite the lack of evidence that grant managers were adhering to the

established monitoring plans, we did find that some grant monitoring was

occurring. For example, the files contained evidence that communication

occurred between grantees and the grant managers in the form of reports,

faxes, letters, and oral and e-mail communication on specific issues,

problems, or requests for information. However, much of the

communication between grantees and grant managers was not

documented according to OJJDP requirements.
Page 16 GAO-02-65 Better Grant Monitoring Needed

• Closeout Procedures. The OJP grant closeout process calls for an

accounting of programmatic accomplishments in relation to planned

activities; an inventory of all required financial, programmatic, and audit

reports; and an accounting of all federal funds. According to the OJP

Handbook, the grant manager is to complete an assessment report and

other closure requirements within 180 days after the end date of the award

or any approved extension. These requirements include a closeout

checklist, overall assessment of grant performance, final progress reports,

final financial status reports, and closeout notification and grant

adjustment notice.

Our assessment of the closeout process did not include enough cases to

ensure that it is representative of all grant closeouts.31 However, our

limited review showed that some grant files did not contain required

closeout materials.

At the time of our review, the following documents were missing from the

files:

• The required case checklists were not prepared for two of the eight

demonstration grants that expired and required closeout. Similarly,

neither of the two training and technical assistance grants had the

required case checklists.

• An overall assessment of grant performance was not prepared for two

of the eight demonstration grants. Neither of the two training and

technical assistance grants had this assessment.

• Final progress reports were missing from three of the eight

demonstration grant files. Neither of the two training and technical

assistance grants had final progress reports in the files.

• The final financial status report was missing from one of the eight

demonstration grant files. Neither of the two training and technical

assistance grants had a final financial status report in the files. And

there was no documentation that grant managers had reviewed any of

the reports or other official documents that were filed.

 31Because of the small number of closeout cases in our sample of active grants in all of

fiscal years 1999 and/or 2000, we have no assurances that the eight demonstration and two

training assistance grants would be representative of all closed out grants.
Page 17 GAO-02-65 Better Grant Monitoring Needed

• A closeout notification and grant adjustment notice to deobligate funds

or advise the grantee to retain records for 3 years was not prepared for

three of the eight expired demonstration grants. Similarly, neither of

the two training and technical assistance grants had a closeout

notification and grant adjustment notice.

In commenting on a draft of this report, the Acting Assistant Attorney

General noted the programmatic and fiscal closure process might not have

been completed for those grants until after our review. In our review of

closeout procedures, we waited at least the required 180 days before

reviewing the grant files to allow sufficient time for OJJDP to complete the

grant closeout process. However, the files we reviewed did not contain the

required closeout documents.

The Comptroller General’s internal control standards32 require that all

transactions and other significant events be clearly documented and that

the documentation be readily available for examination. Appropriate

documentation is an internal control activity to help ensure that

management’s directives are carried out. Without such documentation,

OJJDP has no assurance that grants are meeting their goals and funds are

being used properly.

In commenting on a draft of this report, the Acting Assistant Attorney

General also said that almost 50 percent of the 89 Special Emphasis

Division grants that we reviewed were awarded in fiscal years 1998 and

1999 under the Drug-Free Communities Support Program. Because of the

time needed to recruit, hire, and train new program staff, OJJDP handled

217 Drug-Free Communities Support Program grants in those 2 years with

less than adequate (i.e., two) staff. According to the Acting Assistant

Attorney General, caseloads of this size make proper documentation a

difficult goal to achieve.

 32Standards for Internal Control in the Federal Government (GAO/AIMD-00-21.3.1, Nov.

1999).
Page 18 GAO-02-65 Better Grant Monitoring Needed

OJJDP does not systematically monitor grant managers’ compliance with

its monitoring requirements or guidance nor does it assess the

effectiveness of OJJDP grant monitoring practices. When we asked OJJDP

officials about any oversight of OJJDP grant managers to determine the

adequacy of their monitoring of OJJDP discretionary grants, they told us

oversight takes several forms. They pointed out that the OJP Handbook

requires staff performance to be carefully scrutinized against the

performance work plans (i.e., the critical performance elements and

standards pertaining to monitoring responsibilities). They said that OJJDP

supervisory managers are to address the following questions to determine

how well each grant manager with monitoring responsibilities is

performing: (1) how informed is the grant manager about his or her

project; (2) what specific oversight and review activities are being

conducted; and (3) how are grantee performance issues, if any, being

resolved?

Our review of the performance work plan OJJDP considered to be

representative found that it tended to contain information that made it

difficult to precisely understand the nature of the monitoring to be

conducted. The performance work plan, for example, referred to

monitoring grants to ensure that projects meet their goals and milestones,

with no clear expectations regarding monitoring requirements, such as site

visits or telephone monitoring, and documentation of these contacts and

reviews of grantees’ progress and financial reports.

In addition, according to OJJDP officials, they do not have an officewide

management information system that tracks monitoring activities specific

to each grant and links these to grant monitoring staff.33 However, OJJDP

officials said they take several actions to ensure that staff are adequately

performing their monitoring responsibilities. They said the grant

manager’s memorandum is carefully scrutinized to determine that the

proper information regarding grant goals, objectives, tasks, program

activities, and products are included. Division directors are to review

requests for site visits on a quarterly or semiannual basis as part of their

development of travel budgets. Site visit reports are reviewed at the time

or within a reasonable period of submission of travel reimbursement

requests. Finally, division directors are routinely consulted regarding

corrective action on grants.

 33OJP’s Office of the Comptroller has developed an automated tracking system that flags

missing and late progress and financial reports. This information is available to OJJDP

grant managers. However, OJJDP does not have a system for tracking telephone contacts,

site visits, review of progress and financial reports, or other reporting requirements.

OJJDP Does Not

Systematically

Determine Staff

Compliance With Its

Monitoring

Requirements
Page 19 GAO-02-65 Better Grant Monitoring Needed

In our May 1996 work, we reported that OJJDP’s files for discretionary

grants generally contained monitoring plans but little documentation that

monitoring occurred. OJJDP said that a heavy workload might have

resulted in a lack of monitoring records, but that it would take the steps

necessary to improve records. OJJDP has made limited progress in

addressing the monitoring problems we identified in 1996.

Our review showed that monitoring activities continue to be insufficiently

documented, and because of this, neither OJJDP nor we can determine the

level of monitoring being performed by grant managers as required by

OJP, OJJDP, and the Comptroller General’s internal control standards.

OJJDP also cannot rely on supervisory oversight of its grant managers to

ensure that monitoring is being performed as required. The use of staff

performance work plans seems problematic as a means of reviewing

monitoring activities because the requirements are written in such general

terms. Grant managers’ performance work plans do not include clear

expectations and accountability for monitoring called for in grant

managers’ monitoring plans as well as follow-up requirements to notify

and assist grantees who consistently submit late or no progress or

financial reports. Further, the approval of grant managers’ memorandums

or preapproval of site visits does not ensure that required monitoring is

taking place, and none of these oversight activities is designed to ensure

that proper documentation of monitoring activity is taking place.

Current activities to review monitoring policies and practices and to

complete documentation for closed grants could result in positive

changes. However, these activities are too new to be evaluated in relation

to their potential for improving grant monitoring or its documentation.

The current review of monitoring policies and practices affords an

opportunity for OJJDP to assess monitoring in light of our recent findings.

To facilitate and improve the management of program grant monitoring,

we recommend that the Attorney General direct OJJDP, as part of its

ongoing review of monitoring policies and practices, to determine whether

the monitoring documentation problems that we identified were an

indication of grant monitoring requirements not being met or of a failure

to document activities in the official grant files that did, in fact, take place.

If monitoring requirements are not being met, we recommend that the

Attorney General direct OJJDP to determine why this is so and to consider

those reasons as it develops solutions for improving compliance with the

requirements.

Conclusions

Recommendations for

Executive Action
Page 20 GAO-02-65 Better Grant Monitoring Needed

If it is determined that required monitoring is taking place but is not being

documented, we recommend that the Attorney General direct OJJDP to

develop and enforce clear expectations regarding monitoring

requirements. This policy should, among other things, require supervisory

review to ensure that monitoring activities are being carried out and

documented as prescribed. Further, grant managers’ performance work

plans should include clear expectations and accountability for monitoring

called for in grant managers’ monitoring plans as well as follow-up

requirements to notify and assist grantees who consistently submit late or

no progress or financial reports.

We provided a copy of this report to the Attorney General for review and

comment. In a September 19, 2001, letter, the Acting Assistant Attorney

General commented on a draft of this report. Her comments are

summarized below and are presented in their entirety in appendix II.

The Acting Assistant Attorney General said that overall, the report

provides useful information in highlighting management and monitoring

activities in need of improvement. Senior staff within OJJDP have been

directed to address each of the issues identified in the draft report to focus

on adjusting the nature and types of monitoring activities pursuant to

these types of grants, thus ensuring that every active grant receives a

programmatic assessment. OJJDP will also be considering ways to

improve and streamline grant management monitoring activities to ensure

that program monitoring efforts are documented and useful, including the

development of a management information system and the use of private

contractors to assist in some of these review functions.

The Acting Assistant Attorney General also said that the draft report could

have gone further in acknowledging the impact of OJJDP’s enormous

growth of the past 5 years on its ability to monitor recipients. We

recognized that the number of active OJJDP discretionary grants has more

than tripled over the past 5 years. However, it is OJJDP’s responsibility to

initiate action, such as to request additional funding to meet its monitoring

responsibilities or revise its monitoring efforts to comport with its

available resources. In commenting on our May 1996 testimony, the OJJDP

Deputy Administrator recognized that OJJDP’s heavy workload might have

resulted in a lack of monitoring records, but that he would take steps

necessary to improve records. However, our current review disclosed that

similar monitoring problems persist.

Further, the Acting Assistant Attorney General said that we did not

acknowledge OJJDP’s efforts in a major OJP-wide effort to improve grant

Agency Comments

and Our Evaluation
Page 21 GAO-02-65 Better Grant Monitoring Needed

monitoring practices and establish uniform policies. We recognized some

of the efforts to review its monitoring practices, such as revising the OJP

Handbook: Policies and Procedures for the Administration of OJP

Grants and its recent embarking on an overhaul of its grant closeout

practices to improve its monitoring records. Such efforts, we believe,

should help address the monitoring problems we identified.

The Acting Assistant Attorney General concurred with our

recommendation that grant managers’ performance work plans include

clear expectations and accountability for monitoring. She said

performance work plans put into effect after February 2001 for grant

managers in OJJDP’s Special Emphasis Division more clearly reflect

monitoring responsibilities and provide for better supervisory controls.

Further, she noted that OJJDP’s Special Emphasis Division has put into

place a new process designating one staff member with responsibility for

file “audits” to help ensure that files are in order and that documentation

of monitoring is in place.

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

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

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

and Ranking Members of the Senate Judiciary Committee; Senate

Subcommittee on Youth Violence; House Committee on Education and the

Workforce; House Subcommittee on Early Childhood, Youth and Families;

Attorney General; and Director, Office of Management and Budget. We will

also make copies available to others upon request.

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

or James M. Blume at (202) 512-8777. Key contributors to this report are

acknowledged in appendix III.

Sincerely yours,

Laurie E. Ekstrand

Director, Justice Issues
Appendix I: OJJDP’s Discretionary Grant

Award Process

Page 22 GAO-02-65 Better Grant Monitoring Needed

Each year, OJJDP publishes a proposed program plan seeking public

comment about proposed discretionary funding opportunities for activities

covered under parts C and D (all national programs and gang-related

activities) of the Juvenile Justice and Delinquency Prevention Act. The

proposed plan is published in the Federal Register. Program

announcements and solicitations for discretionary funding opportunities

are published as they become available. The announcements and

solicitations provide details about specific funding opportunities,

including eligibility requirements and deadlines. These include funding

opportunities for tribal youth and drug-free communities as well as

funding opportunities associated with parts C and D. Once discretionary

grant applications are submitted, OJJDP said that its contractor1

 conducts

an initial review to eliminate any applications that do not comply with the

specified grant instructions. After ineligible grant applications are

eliminated, OJJDP has a peer review panel, which consists of three or

more outside experts who evaluate and rank OJJDP’s grant applications.

After the peer review panel has ranked the applications, OJJDP’s grant

managers2

 do an in-depth review of applications and make formal

recommendations regarding the funding of individual grants to the OJJDP

Administrator.

As shown in figure 1, the key parts of OJJDP’s process for planning and

announcing discretionary grants are issuance of a program plan, issuance

of discretionary program announcements, and distribution of application

kits.

 1

OJJDP’s current contractor is the Juvenile Justice Research Center at Aspen Systems.

2

OJJDP’s grant managers are OJJDP officials with responsibility for overseeing and

monitoring grants.

Appendix I: OJJDP’s Discretionary Grant

Award Process
Appendix I: OJJDP’s Discretionary Grant

Award Process

Page 23 GAO-02-65 Better Grant Monitoring Needed

Figure 1: Key Steps in OJJDP’s Process for Planning and Announcing Grants

Source: GAO analysis of OJJDP documents and interviews with OJJDP staff.

As shown in figure 2, according to OJJDP officials, the key parts of the

grant application and review process include initial screening of an

application by the OJJDP contractor, peer review of applications, and the

final selection of applications for funding by the OJJDP Administrator or

Assistant Attorney General.

Step 1 Step 2

OJJDP program plan

Development Revision

OJJDP program 

announcement

Development

Federal Register

publishes proposed 

program plan

Federal Register

publishes program

announcement

notice

Contractor mails out 

application kits for discretionary grants

Applicant applies

for discretionary

Final program

plan issued

Public has 45-day

comment period

grant
Appendix I: OJJDP’s Discretionary Grant

Award Process

Page 24 GAO-02-65 Better Grant Monitoring Needed

Figure 2: Overview of OJJDP Grant Application and Review Process

a

Some program managers will do initial screening only for specific programs.

b

Quality control checks are done by program managers before the peer review.

Source: GAO analysis of OJJDP documents and interviews with OJJDP staff.

Contractor

does initial

 screening of grant

 applicationsa

Peer review panel 

evaluates application

and makes funding

 recommendationsb Does

application

meet

 requirements?

OJJDP

Administrator makes

 tentative selection of

 application for funding

OJJDP

Administrator

approves grant

 awards for research,

evaluation, statistics

and other grants, 

as delegated by 

the Assistant 

Attorney General

OJP Comptroller

 conducts financial

 review

Applications are no

longer processed

Juvenile Justice

Research Center

at Aspen Sytems

receives the

 applications

Program 

managers review

recommendations of

 peer review panelists

 and make 

formal funding 

recommendations 

to OJJDP

Administrator

Assistant Attorney

 General, OJP, 

approves grants 

in accordance 

with the guidance 

outlined in the current 

appropriations law; 

e.g., training and

 technical assistance 

and demonstration

Yes

No
Appendix I: OJJDP’s Discretionary Grant

Award Process

Page 25 GAO-02-65 Better Grant Monitoring Needed

OJJDP’s proposed program plan describes OJJDP’s goals and priorities

and the particular program activities it plans to carry out during the fiscal

year under parts C and D of Title II of the OJJDP Act. OJJDP publicly

announces its proposed program plan in the Federal Register. After a 45-

day comment period, OJJDP is to publish a final plan3

 that is to take into

consideration comments received during the comment period.

According to an official, the OJJDP program plan is generally drafted by

the Administrator and senior managers and based on (1) congressional

and departmental priorities, (2) their knowledge and expertise, and (3)

input during the course of the year from a variety of sources. These

sources include program reviews by OJJDP staff and comments from

practitioners in the field, officials from Justice and OJP bureaus and

offices, and other federal agencies.

Following publication of the final program plan, OJJDP is to publish in the

Federal Register a notice of discretionary grant programs and to announce

the availability of an application kit for grants. The notice is to include the

availability of funds, criteria for selection of grant applicants, procedures

applicable to the submission and review of application for submission and

review of applications for assistance, and information on how to obtain an

application kit.

Upon receipt of discretionary grant applications, the OJJDP contractor

does an initial review of each application, using an application review

checklist. The objective of this initial review is to determine whether

applications are complete and eligible for federal funding.

OJJDP contracts out the administrative arrangements (e.g., arranging

panels and notifying reviewers) for the peer review of its discretionary

grant applications. The contractor maintains a list of qualified consultants

from which peer reviewers were selected by OJJDP. An OJJDP official

estimated that there were 73 peer review panels in fiscal year 2000 for its

22 grant programs. The grant managers identify the particular expertise

they want the peer reviewer to have. The contractor generates a list of

potential reviewers with their resumes, background information, and other

helpful information. The grant managers recommend peer reviewers on

 3

The plan is to be published before December 31 each fiscal year.

Program Plan Is to

Describe Goals and

Priorities

Program

Announcements and

Application Kits Are

to Solicit Applicants

for Programs

Peer Review Panels

Are to Help

Determine Which

Grant Applications

Are Funded
Appendix I: OJJDP’s Discretionary Grant

Award Process

Page 26 GAO-02-65 Better Grant Monitoring Needed

the basis of the contractor’s list and give the list to the Deputy

Administrator for approval.4

 After the Deputy Administrator approves the

list, it is sent to the Administrator. Once the Administrator selects the peer

reviewers, the contractor makes arrangements with the individuals

selected and manages the peer review process.

According to an OJJDP official, consultants performing the peer reviews

are reimbursed at a flat rate of $150 a day. OJJDP guidance requires that

the grant managers use the following criteria to help achieve balance on

the peer review panel.

• Each reviewer should have expertise in or complementary to the subject

area under review.

• Where possible, the peer review panel should be composed of a mix of

researchers, practitioners, and academicians.

• Special attention should be paid to obtaining qualified representation from

women and minority groups.

OJJDP’s peer review process is advisory and is to supplement and assist

OJJDP’s consideration of applications. However, an OJJDP official noted

that, in practice, results of the peer review panels’ consideration of

application were almost always accepted.

After completion of the peer review panels, OJJDP’s grant managers do an

in-depth review of the peer review panels’ ranked list. The OJJDP grant

managers make recommendations concerning applications to receive

funding in a memorandum to the Administrator, and the Administrator is

to make tentative grant selections. The OJJDP Administrator makes final

awards for research and evaluation grants, while final awards for all

training and technical assistance and demonstration grants are made by

the Assistant Attorney General. After the applications are approved, OJP’s

Office of the Comptroller does a financial review of these applications to

determine whether the applicant has the necessary resources and integrity

 4

The Juvenile Justice and Delinquency Prevention Act of 1974, as amended, requires OJJDP

to have formal peer review process for discretionary grant awards (National Programs). 42

U.S.C. 5601, 5665a (d). However, OJJDP chooses to require all the competitive

discretionary grant applications to be involved in its peer review. Noncompetitive grants,

earmarks, and uniquely qualified grants do not go through a formal peer review process.

OJJDP usually has a maximum of three grants that are uniquely qualified, which are

reviewed and approved by the Administrator.

Final Decision to

Award Discretionary

Grants
Appendix I: OJJDP’s Discretionary Grant

Award Process

Page 27 GAO-02-65 Better Grant Monitoring Needed

to account for and administer federal funds properly and whether budget

and cost data in the application were allowable, effective, and reasonable.
Appendix II: Comments From the Department

of Justice

Page 28 GAO-02-65 Better Grant Monitoring Needed

Appendix II: Comments From the

Department of Justice

Note: GAO comments

supplementing those in

the report text appear at

the end of this appendix.
Appendix II: Comments From the Department

of Justice

Page 29 GAO-02-65 Better Grant Monitoring Needed

See footnote 12.

See comment 1.
Appendix II: Comments From the Department

of Justice

Page 30 GAO-02-65 Better Grant Monitoring Needed

Now last paragraph.

Now on p. 8.
Appendix II: Comments From the Department

of Justice

Page 31 GAO-02-65 Better Grant Monitoring Needed

Now on p. 9, footnote 14.

Now on p. 9.
Appendix II: Comments From the Department

of Justice

Page 32 GAO-02-65 Better Grant Monitoring Needed

Now on p. 14.

See pp. 12-13.

See p. 17.

Now on p. 11.
Appendix II: Comments From the Department

of Justice

Page 33 GAO-02-65 Better Grant Monitoring Needed

Now on p. 16, 1st bullet.

Now on p. 16, 4th bullet.

Now on p. 15.

See p. 14, footnote 28.
Appendix II: Comments From the Department

of Justice

Page 34 GAO-02-65 Better Grant Monitoring Needed

Now on p. 20.

See p. 12.

Now on pp. 19-20.

Now on p. 17.
Appendix II: Comments From the Department

of Justice

Page 35 GAO-02-65 Better Grant Monitoring Needed
Appendix II: Comments From the Department

of Justice

Page 36 GAO-02-65 Better Grant Monitoring Needed

The following are GAO’s comments on the Department of Justice’s

September 19, 2001, letter.

1. According to the OJP Handbook: Policies and Procedures for the

Administration of OJP Grants (Feb. 1992), official grant files kept by

the Office of the Comptroller Control Desk are to contain documents

relating to each grantee, including progress and financial reports and

site visit reports. In addition, for documentation to be readily available

for examination, as required by the Comptroller General’s internal

control standards, keeping them in the official grant file seems

appropriate.

GAO Comment
Page 37 GAO-02-65 Better Grant Monitoring Needed

Laurie E. Ekstrand (202) 512-8777

James M. Blume (202) 512-8777

In addition to those named above, R. Rochelle Burns, Jill Roth, Michele

Fejfar, Sidney H. Schwartz, Michele J. Tong, Jerome T. Sandau, and Ann H.

Finley made key contributions to this report.

Appendix III: GAO Contacts and Staff

Acknowledgments

GAO Contacts

Acknowledgments

(440026)
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