State Department: Implementation of Grants Policies Needs Better Oversight
Published: 2014-07-21T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Grants are key tools that State uses to conduct foreign assistance. In fiscal year 2012, State obligated over $1.6 billion worldwide for around 14,000 grants to individuals and organizations for a variety of purposes, such as fostering cultural exchange and facilitating refugee resettlement. However, recent GAO and Inspectors General reports have identified challenges with State's management of these funds. This report examines (1) the policies and guidance that State has established to administer and oversee grants, and (2) the extent to which the implementation of those policies and guidance provides reasonable assurance that funds are being used as intended. GAO analyzed State's policies and guidance, and interviewed cognizant grants officials at 14 bureaus headquartered in Washington, D.C., and three overseas missions (Afghanistan, Cambodia, and Turkey). GAO also conducted file reviews for a sample of 61 grants totaling approximately $172 million. Selection criteria included total dollar value of grants in a country, geographic diversity, and balance among bureaus.
section_title: What GAO Found
paragraphs: The Department of State (State) has established policies and guidance that provide a supportive environment for managing grants and cooperative agreements (grants). In addition, State provides its grants officials mandatory training on these policies and guidance, and routinely identifies and shares best practices. State's policies are based on federal regulations, reflect internal control standards, and cover topics such as risk assessment and monitoring procedures. State's policies also delineate specific internal control activities that grants officials are required to both implement and document in the grant files as a way of promoting accountability (see fig.).
GAO found that inconsistent implementation of policies and guidance weakens State's assurance that grant funds are used as intended.
Inadequate risk analysis . In most of the files GAO reviewed, grants officials did not fully identify, assess, and mitigate risks, as required. For example, officials conducted a risk identification process for 45 of the 61 grants that GAO reviewed. While grants officials identified risk in 28 of those 45 grants, they mitigated risks in only 11.
Poor documentation . Grants officials generally did not adhere to State policies and procedures relating to documenting internal control activities. For example, 32 of the 61 files reviewed did not contain the required monitoring plan. Considerable turnover among grants officials makes documenting internal control activities particularly important. State's periodic management reviews of selected bureaus' and overseas missions' grant operations have also found that key documentation was frequently missing or incomplete and made recommendations to address the problem. However, State has not consistently followed up to ensure the implementation of these recommendations, as internal control standards require.
State does not have processes for ensuring compliance with risk analysis and documentation requirements. Without the proper implementation of its internal control policies for grants management, State cannot be certain that its oversight is adequate or that it is using its limited oversight resources effectively.
section_title: What GAO Recommends
paragraphs: GAO recommends that the Secretary of State develop processes for ensuring that (1) bureaus and missions conduct appropriate risk assessments and (2) grants officials complete required documentation. GAO also recommends that the Secretary of State (3) follow up systematically on recommendations from State's internal reviews of its grants management. State concurred with GAO's recommendations.

section_title: Letter
paragraphs: Grants and cooperative agreements are key tools that the U.S.  Department of State (State) uses to conduct foreign assistance. State  uses them to award assistance to individuals and organizations for a  variety of purposes, such as fostering educational and cultural exchanges  with citizens of other countries, facilitating refugee resettlement, and  developing U.S. allies’ law enforcement capacity. In fiscal year 2012,  State obligated over $1.6 billion for approximately 14,000 grants and  cooperative agreements worldwide.
State’s Office of the Inspector General and the Special Inspector General  for Afghanistan Reconstruction recently reported that State faced  challenges overseeing its grants and ensuring that funds were being used  as intended. In particular, they found deficiencies in certain internal  control activities as well as financial reporting. We have also identified  challenges and lessons learned for grants management across the  federal government in a body of work spanning several decades.
You asked us to review issues related to State’s management and  oversight of grants and cooperative agreements. This report examines (1)  the policies and guidance that State has established to administer and  oversee grants and cooperative agreements, and (2) the extent to which  the implementation of those policies and guidance provides reasonable  assurance that funds are being used as intended.
To address these objectives, we analyzed federal regulations and State’s  policies and guidance. We interviewed State officials from the Office of  the Procurement Executive (A/OPE); the Office of the Deputy Chief  Financial Officer, and various functional and regional bureaus and offices  headquartered in Washington, D.C.; and three overseas missions to  determine how State both designs and implements department-wide  internal control policies on grants performance and financial  management. To further determine how State implements these policies,  we selected three case study countries—Afghanistan, Cambodia, and  Turkey—based on criteria that included total dollar value of grants in a  country, geographic diversity, and balance among the bureaus involved in  managing the awards. For these countries we examined a  nongeneralizable sample of 48 grants and cooperative agreements by  award size and bureau that had obligations in fiscal year 2012. In  addition, we used the same criteria to draw another nongeneralizable  sample of 13 grants managed in Washington, D.C. Overall, the 61 grants  we reviewed ranged in value from just over $25,000 to $28,000,000, and  totaled approximately $172 million. Collectively, the grants in our  samples were managed by 3 posts and 14 of the 27 grant-making  bureaus and offices in State, and included grants by 6 of the top 10  bureaus and posts in terms of total dollar amount obligated for federal  financial assistance in fiscal year 2012. We developed a data collection  instrument that we used to conduct file reviews for the 61 grants. Our file  review assessed grants officials’ implementation of a selection of State’s  required internal control activities for grants management, including risk  assessment, monitoring of recipients, and documentation of key activities.  We also conducted interviews with cognizant grants officials for each of  the grants to learn how they implemented grants management policies.  To identify any internal control deficiency patterns or trends, we analyzed  and compared the data we collected from our file reviews and interviews,  and also compared them to the findings from State’s internal inspections  of grant-making operations.
We conducted this performance audit from May 2013 to July 2014 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe the  evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives. A more detailed description of  our scope and methodology can be found in appendix I.
subsections: section_title: Background
subsections: section_title: State Grants Management: Definitions and Key Roles and Responsibilities
paragraphs: Grants and cooperative agreements are assistance instruments used to  transfer money, property, or services to accomplish a public purpose. The  difference between the two instruments relates to the amount of  involvement between the agency and the recipient during performance:  when substantial involvement is not anticipated, State uses a grant;  otherwise, it uses a cooperative agreement. For the purposes of this  report, the term “grants” refers to both grants and cooperative  agreements.
State’s grants vary greatly by size and recipient—from grants of less than  $100 to help cover an individual’s travel expenses, to multi-million dollar  grants to, for example, international nongovernmental organizations for  democracy-building programs. A/OPE sets department-wide policies  related to grants management, and individual bureaus may also develop  their own specific policies to supplement those from A/OPE. Managing a  grant involves a variety of State officials, often from multiple bureaus and  posts. The principal grants officials include the following:
The grants officer (GO), who is ultimately responsible for overseeing  the grant.
The grants officer representative (GOR), who often has program  implementation expertise and assists the GO in overseeing a grant.
The program officer, who, if the GO is from a different bureau, may  provide programmatic expertise, primarily during the preaward phase.  For example, a program officer may design the grant announcement  and assist in selecting recipients. In some cases, the program officer  may be designated as the GOR once the grant is awarded to a  recipient.
The budget officer, who is responsible for ensuring that the  appropriated funds are drawn down correctly.
Some GOs and GORs also reported using a grants management  specialist or other staff, such as interns, to help them manage certain  aspects of their portfolios.
The various grants officials involved in the management of a grant may  be from different bureaus as well as different locations. Twenty-seven  bureaus and offices within State, including the U.S. Mission to the United  Nations, have grant-making authority or grant oversight responsibilities.  Posts, including embassies and consulates overseas, may also make  grants. Ten bureaus and posts accounted for the majority of federal  assistance obligations that State made in fiscal year 2012 (see table 1).  For those GOs located in Washington, D.C., the GOR is usually located in  the principal place of performance, which may be at State headquarters in  Washington, D.C.—for cultural exchange programs, for example—or  overseas. Eighteen of the 27 bureaus with grant-making authority have  their own GOs. Those that do not have GOs or whose GOs do not have a  high enough grant-making authority rely on the Office of Acquisitions  Management to fulfill the GO role. This office provides a full range of  grant management services, including planning, negotiations, cost and  price analysis, and administration. In those instances, the bureau  requesting the grant then generally provides the GOR, program officer, or  both to supply program-specific expertise. As of May 2014, there were  571 GOs worldwide, with 503 of them based overseas. Most GOs at  posts are Foreign Service Officers with multiple other duties. In addition,  Foreign Service Officers usually rotate to another post within 1-3 years,  per State’s normal operating procedures. This considerable turnover rate  means that a single grant may have multiple GOs over its life cycle.
State’s grants generally follow a life cycle that consists of four phases— preaward, award, postaward, and closeout. In the preaward phase, grants  officials develop the program idea, evaluate proposals, and select a  recipient. The GO then negotiates the costs of the grant with the recipient  and drafts the award document during the award phase. In the postaward  phase, grants officials monitor the recipient’s progress and disburse  payments as appropriate. Finally, in the closeout phase, grants officials  assess final programmatic and financial reports and determine any final  payments or reimbursements that are necessary.
section_title: Internal Control Standards Applicable to State Grants Management
paragraphs: As we have noted in prior reports, effective oversight and internal control  are important when awarding and managing federal grants to provide  reasonable assurance to federal managers and taxpayers that grants are  awarded properly, recipients are eligible, and federal grant funds are used  as intended and in accordance with applicable laws and regulations.  The Standards for Internal Control in the Federal Government (the federal  standards) sets forth the standards that provide the overall framework for  establishing and maintaining internal control and for identifying and  addressing major performance and management challenges and areas at  greatest risk of fraud, waste, abuse, and mismanagement.
Control environment: Management and employees should establish  and maintain an environment that sets a positive and supportive  attitude toward internal control and conscientious management. A  positive control environment is the foundation for all other standards.
Risk assessment: Internal control should provide for an assessment of  the risks the agency faces from both external and internal sources.  Risk assessment is the identification and analysis of relevant risks  associated with achieving the agency’s objectives and forming a basis  for determining how risks should be managed.
Control activities: Internal control activities help ensure that  management’s directives are carried out. Control activities are the  policies, procedures, techniques, and mechanisms that enforce  management’s directives. They help ensure that actions are taken to  address risks, and they are integral to the stewardship of government  resources and achieving effective results.  Information and communications: Information should be recorded and  communicated to management in a form and within a time frame that  enables management to carry out its internal control and other  responsibilities.
Monitoring: Internal control monitoring should assess the quality of  performance over time and ensure that any issues are promptly  resolved.
section_title: State Has Established Policies and Guidance That Provide a Supportive Environment for Administering and Overseeing Grants State’s Policies Incorporate Federal Regulations
paragraphs: State has established a core set of policies and guidance incorporating  federal regulations for administering and overseeing grants. A/OPE has  established policies and training to further assist grants officials as they  implement the department’s policies and to reduce wasteful spending in  government. A/OPE has taken steps to improve its policies, revising  many of them since their issuance. State has provided these policies, as  well as training and other support, to staff to encourage effective grant  management throughout the life cycle of a grant.
State’s grant management policies incorporate requirements established  in federal regulations and guidance, which are codified in the Code of  Federal Regulations (CFR). These regulations are based on Office of  Management and Budget (OMB) circulars on grants and cooperative  agreements with nongovernmental organizations and institutions of higher  education as well as with state and local governments. OMB circulars  provide guidance to grants officials for implementing rules regarding  allowable costs, program purposes, and financial management  procedures. In addition, the authorities for specific assistance programs  may provide requirements for associated grants. OMB guidance and  regulations contained in the CFR inform State’s policies for grants  management. State collects and articulates the department’s policies in  the Foreign Affairs Manual and its associated handbooks. This manual  assigns A/OPE the authority to prescribe acquisition and assistance  policies, regulations and procedures for State. State officials told us that  A/OPE also works closely with the Office of the Deputy Chief Financial  Officer to develop policies related to the financial management of grants.
Since 1992, A/OPE has issued 59 grants policy directives to provide  additional guidance specific to State’s staff explaining how they should  conduct grants management in accordance with federal regulations.  A/OPE has issued or revised more than half of these policies since 2008,  creating at least two of them in response to concerns from its Inspector  General and us about State’s internal controls for grants management.
subsections: section_title: State’s Policies and Guidance Establish Internal Controls throughout the Grant Life Cycle
paragraphs: State’s policies and guidance help establish a control environment  framework for grants management. Two of the directives related to risk  assessment, for example, directly cite the federal standards, which call on  federal agencies to identify risks as part of a positive internal control  environment. State’s policies also provide guidance for implementing key  internal control activities throughout the life cycle of a grant, such as  approval of the monitoring plan or review of quarterly or annual reports  (see fig. 1).
State’s control environment also includes a variety of additional guidance,  including mandatory training, “best practices” dissemination, and online  resources.
Training: State offers its staff several grants management courses,  covering such topics as monitoring and evaluation, cost principles,  and ethics. GOs must take at least 24 hours of grants management  training, and GORs must take both an introduction and a monitoring  course to obtain certification. Both must update their training with at  least 16 hours of courses every 3 years. Some courses are also  available online, and A/OPE has worked with several bureaus to hold  training focused on their specific needs. In addition, A/OPE  occasionally offers regional or post training in the field, depending on  resources, and has recently begun holding webinars to train and  answer questions from grants officials overseas.
Best practices dissemination: According to State officials, A/OPE  began holding quarterly meetings in 2004 for grants officials  throughout the department to both raise issues and share best  practices. More recently, A/OPE has begun to offer a 2-day course  twice a year in lieu of the quarterly meetings. The course offers an  update on trends and regulation changes as well as a refresher on  grants administration and policy.
Online resources: Finally, State has a number of Intranet resources  available for grants officials. Beyond distance learning courses,  A/OPE also has sample templates for a variety of grant  documentation, including a preaward survey, financial management  survey, risk assessment tool, and several types of monitoring reports.  An A/OPE official told us A/OPE is currently updating the Federal  Assistance Policy Manual, which will provide additional guidance for  the entire grant life cycle. Furthermore, bureaus and posts are  allowed to design guidance appropriate to the varying circumstances  surrounding their grants. For example, three of the bureaus and two of  the posts in our sample have developed their own risk assessment  checklists.
State guidance also directs grants officials to document key internal  control activities throughout the life cycle of a grant, including the use of  funds, the recipient’s progress, and the grants officials’ assessment of  that progress. State has several policies either dedicated to  documentation or requiring documentation. For example, one policy  describes the roles and responsibilities for both the GOs and the GORs,  listing what information they must document as well as where and at what  phase in the grant life cycle they should document it. For certain internal  control activities, State has created additional policies with detailed  documentation and reporting requirements. The policies cover topics  such as competition versus sole source decisions, risk identification and  assessment processes, and developing monitoring plans. These policies  also include sample templates outlining various approaches to  documenting these activities. Under State guidance, bureaus and posts  may tailor these policies to their specific needs. Given the considerable  turnover rate of GOs who are Foreign Service Officers, as well as the fact  that grants management is not often their primary task, a strong internal  controls environment is essential for accountability.
section_title: Inconsistent Implementation of State Policies and Guidance Weakens Assurance That Grant Funds Are Used as Intended
paragraphs: State has not consistently implemented the risk analysis and  documentation of internal controls required by grants management  policies and guidance, a fact that weakens assurance that grant funds are  used as intended. In particular, grants officials have not adhered  consistently to State’s policies about identifying, assessing, and mitigating  risks associated with the grants we reviewed. Furthermore, grants  officials do not always document the implementation of key internal  controls activities as required. State has established procedures for  assessing grants officials’ implementation of its internal controls. In  conducting these reviews, A/OPE found insufficient documentation in the  grant files at all 10 of the bureaus and posts that were also in our review  and recommended solutions, but did not systematically follow up to  ensure that the bureaus and posts had implemented them.
subsections: section_title: Grants Officials Often Did Not Conduct Required Risk Analysis
paragraphs: Grants officials responsible for the files in our sample often did not adhere  to State’s policies on risk assessment. Federal standards define risk  assessment as “the identification and analysis of relevant risks associated  with achieving the  objectives.” A risk analysis helps ensure that  grants officials undertake the necessary control activities and use  oversight resources appropriately. State’s policy on risk management  further elaborates that risk assessment should begin in the preaward  phase and continue throughout the grant life cycle. Furthermore, it states  that a risk management plan must include identification, assessment, and  monitoring and mitigation of risk. In most of the files we reviewed,  however, we did not find evidence that grants officials had fulfilled these  requirements, as described below.
Risk identification: State’s policies require grants officials to carry out  a comprehensive review of potential recipients to identify risks. Risk  factors could include a lack of stable financial infrastructure or  experience in managing a U.S. government grant, past performance  problems, an unusual or difficult environment, responsibility for a large  amount of funds, and concern the organization might be involved in  terrorist activities. Of the 61 grant files we reviewed, 45 showed that  grants officials had at least partially undertaken a risk identification  process. However, 33 of these were missing key elements of a risk  identification process, such as a review of the recipient’s financial  systems and internal controls.
Risk assessment: State policy requires grants officials to exercise a  greater level of oversight for high-risk versus low-risk grants; however,  we found in our file reviews that grants officials often did not assess  identified risks to determine the grants’ risk level. Of the 45 grants that  underwent a risk identification process, 28 had risks identified.  However, only 15 of those 28 grants that identified risks also included  at least a partial assessment of risks, such as a preaward checklist at  one post that included some questions about prior federal grant  management experience and other past performance issues. In  addition, while State has established a variety of guidance on risk  assessment, the wording of the guidance is not consistent in certain  aspects, such as assessment of external risk factors. For example,  while one of the grants policy directives lists Transparency  International’s Corruption Perception Index as a risk assessment  resource, none of A/OPE’s sample risk assessment templates  mention the index or corruption in general. In another example, we  found that a grant to support civil society had received a “low-risk”  determination, based on calculations from a risk assessment  checklist, although grants officials remarked in the notes section of the  checklist that corruption was rampant in that country. Since corruption  was not an element of the checklist itself, it did not factor into the  overall risk-level determination—nor was it reflected anywhere else in  the grant file documentation.
Risk mitigation: State policies require grants officials to document how  they will mitigate, or address, identified risks, including by preparing  and implementing a monitoring plan. Of the 15 grants that showed  both identification and assessment of risks, 11 showed at least partial  mitigation of those risks (see fig. 2). Of the remaining 4 grants that  showed no risk mitigation, 1 included an audit report identifying  significant financial management risks, such as noncompliance with  allowable costs, on the part of the grant recipient. The grants  officials, however, did not reflect these risks in a risk mitigation or  monitoring plan. In two other grant files we reviewed, grants officials  identified allegations of prior financial mismanagement, but awarded  the grant without addressing how the risk would be mitigated.  Furthermore, State’s various risk-related guidance does not clearly  emphasize the importance of linking risk assessment to monitoring.  Federal standards state that risk analysis generally includes deciding  how to manage the risk and what actions should be taken. Of the five  sample monitoring templates that A/OPE has developed, however,  three do not mention risk. Grants officials who use these templates,  therefore, may not make the link between monitoring and risk. For  example, of the 13 grants from two bureaus in our sample that had  developed their own risk assessment checklists based on A/OPE’s  templates, we found that 7 did not reflect risks identified in a  monitoring plan. Moreover, of the 23 grants in our sample overall that  had assessed risks and had a monitoring plan, only 10 reflected the  risks in the plan.
Without identifying and assessing risks, it may be difficult for State to  determine whether there are any observable impediments to the  recipient’s effective management of State funds that would need to be  mitigated. Determining which grants warrant greater oversight and which  require less helps managers ensure the appropriate allocation of  resources for safeguarding grant funds.
section_title: Grants Officials Often Did Not Document Control Activities
paragraphs: Grants officials in the sample of grants we reviewed generally did not  adhere to State policies and procedures relating to documenting control  activities. Federal standards call for the clear, prompt, and accurate  documentation of internal control and all other significant events,  including risk assessments and monitoring activities, and state that this  documentation should be readily available for examination. State  guidance directs grants officials to document key internal control activities  throughout the life cycle of a grant, including the use of funds, the  recipient’s progress, and the grants officials’ assessment of that progress  (see fig. 3). To support officials as they implement this guidance, State  has created multiple systems for organizing, retaining, and sharing  information about grants, whether the files are in electronic or hard copy  form. Documenting grant management activities is particularly important  because of grants officials’ considerable turnover rate, which can leave  newly assigned grants officials dependent on files to determine what  control activities are required and which have been conducted.
However, the grant files we reviewed did not consistently document key  grant activities as required, to demonstrate that internal controls had been  implemented. In many of the files we reviewed, required documents were  missing from the official file or incomplete, as described below.
Internal control checklist: State requires each grant file to contain a  checklist, which grants officials are supposed to use to document the  completion of many internal control activities throughout the grant’s  life cycle. These activities include vetting recipients, identifying the  amount of funds and project duration, identifying key contacts at State  and the recipient organization, and tracking receipt of information from  the recipient about progress made and costs incurred. State’s training  further emphasizes the importance of keeping all sections of this  checklist current to assist managers in monitoring grants and ensure  that they fulfill the U.S. government’s obligation to grant recipients.  However, 17 out of the 61 files we reviewed did not contain this  checklist, and only about 11 percent (5 out of 44) of the forms that did  exist were completely filled out.
Grant award justification: State requires grant files to contain a  justification for awarding any grants without a full and open  competition. However, for the 24 grants in our sample that were  sole-sourced, 7 did not contain this justification.
Monitoring plans: State policies require grants officials to prepare a  monitoring plan to measure the recipient’s progress toward achieving  the grant’s goals and objectives and ensure that the recipient  complies with the grant agreement. The grants officials must use the  plan to indicate the type and frequency of monitoring they will conduct  given the risks involved and the resources available for these  activities. However, about half of the files we reviewed (32 of the 61)  did not contain a monitoring plan. Furthermore, some of the 29 plans  that were documented did not address key aspects of monitoring the  terms and conditions of the grant agreement, such as risk analysis  and evaluation. For example, 3 of the 29 documented plans we  reviewed did not describe how the GO planned to monitor progress  toward the grant’s specific goals and objectives.
Monitoring activities conducted: While most of the files contained  evidence of some monitoring activities, such as e-mail communication  with recipients, this monitoring did not completely adhere to State’s  guidance. Of the 29 documented monitoring plans, the evidence  showed that grants officials had fully executed 8 of them and partially  executed an additional 10. For example, some of the partially  executed plans indicated that the grants officials were to conduct site  visits and review recipient reports, but the grant files showed that the  grants officials had closed the grants without documenting any  evidence of these planned monitoring activities. Regardless of  whether grants had monitoring plans, we found that only 16 of the 61  files contained evidence that the grants officials had completed the  required review of all the recipient’s financial and programmatic  reports to monitor for key information—including verifying timely  progress toward the goals, as well as identifying and addressing any  delays or inappropriate expenditures. Another 24 of the 61 files  contained evidence that grants officials had done partial reviews of  these reports. These reviews, as well as reviews of the final recipient  reports, are required to close an award, but we found four awards that  GOs had closed without evidence that they had reviewed the  recipient’s final reports. On more than one occasion, State had  difficulty providing required internal control documentation to us, either  because a grants official was on leave or had moved on to another  post. For example, we identified incomplete documentation in some  award files at one post, including missing final financial and  programmatic reports. Three months after our site visit, the GO still  could not produce the documents, because the grants management  specialist whose computer’s hard drive contained the documents was  on extended leave. Two other GOs we interviewed said the files they  inherited did not contain required documents, such as the approval  forms from bureau headquarters for awards exceeding $25,000.
Without documentation such as the internal control checklist, the grant  award justification, monitoring plans, and monitoring reports, State cannot  provide adequate oversight to ensure grant funds are being used as  intended. Without the required checklist, for example, managers cannot  readily ensure that the required documentation supporting the  management of each grant is present and complete. State also cannot  determine whether the GO’s decision not to award a grant through open  competition was justifiable according to State’s guidance unless the GO  documents that decision. Furthermore, while grants officials told us they  do conduct monitoring, absent adequate monitoring plans and reports, it  is difficult for managers to determine whether grants officials are  effectively allocating resources or conducting monitoring, or that a grant  accomplished its intended goals.
section_title: Grants Officials Cited Several Reasons for Nonadherence to Risk Analysis and Documentation Requirements, and State Does Not Have Processes for Ensuring Compliance
paragraphs: GOs and GORs we interviewed cited a variety of reasons for not  conducting the required risk analysis and documentation, including a  misunderstanding of State policies and guidance, a heavy workload, and  a lack of staff expertise. For example, several of these grants officials told  us they did not do a risk analysis either because the recipient was well  known or they knew intuitively that the risk level was low—particularly if  the grant was relatively small or funded a short-term project such as a 2- day photography exhibit. State policies, however, do not preclude well- known organizations from risk analysis. Moreover, we found an example  where the GO assumed the grant was low-risk without doing a full risk  analysis, even though it was the first time that State had awarded a grant  to the recipient. The grant files contained evidence that as the grant  progressed, the recipient had a variety of performance issues, including  trying to use the grant funds for activities other than what was intended.  The amount of time and resources dedicated to an appropriate risk  analysis may vary for lower dollar value grants, well-known recipients, or  other factors; nonetheless, according to an A/OPE official, a risk analysis  is still required in these circumstances. State, however, does not have a  process in place for ensuring that grants officials conduct a risk analysis.
According to State officials and the files we reviewed, multiple  responsibilities and large portfolios limited the oversight they conducted to  ensure that required documentation was in place. Grants officials  reported having high numbers of grants to manage and multiple  responsibilities beyond managing grants. At bureaus with GOs based in  Washington, D.C., workloads tended to be higher, according to an A/OPE  official. This official reported that the average number of grant  transactions undertaken by these domestic GOs in fiscal year 2013 was  46, and two Washington, D.C.-based GOs we interviewed reported  having portfolios of 110 and 200 active grants, respectively. At two posts  we visited, the GOs were responsible for managing portfolios of about 56  to 66 grants in fiscal year 2012, in addition to their primary responsibilities  as public affairs officers for the embassies. Both GOs reported relying on  GORs and others to complete the award documentation. They reported  conducting occasional spot checks of the files compiled by the GORs. At  both posts, however, we found that each grant file in our sample  managed by these GOs was missing required internal control documents.  Furthermore, we brought oversight issues to the attention of the GOs of  which they had previously been unaware, such as unexpended funds  from a closed-out grant.
Some grants officials told us that State’s systems for documenting key  management activities are not easy to use. A/OPE officials told us they  are working to improve the main electronic management systems used by  grants officials (the Grants Database Management System and the State  Assistance Management System), but the accuracy of some information  will still depend on the person inputting it, and State does not have a  process for ensuring that all of the required documentation is included.  Three grants officials we interviewed reported that interns and grant  assistants update the paper and electronic files and that the grants  officials do not check their work. In addition, some grants officials told us  that while official files might be missing required documentation, the  information was stored elsewhere and could be retrieved upon request.  While some grants officials eventually produced the requested  information, others did not. Some grants officials told us that they kept  information about recipient performance on their computer’s hard drive, a  fact that may limit other grants officials’ access to this information.  Furthermore, the official files did not indicate where this information could  be found.
section_title: State Has Assessed Implementation of Internal Controls at Bureaus and Posts, but Has Not Followed Up on Most Recommendations for Improvement
paragraphs: State has assessed the implementation of internal controls at several  bureaus and posts and has recommended improvements; however, it has  not followed up to ensure the implementation of its recommendations.  According to the federal standards, successful monitoring should include  policies and procedures for regularly assessing the effectiveness of the  internal controls in place and for ensuring that the findings of audits and  other reviews are promptly resolved. In 2008, A/OPE issued a policy to  systematically review grants management at posts and bureaus. The   policy stated that the number and extent of the reviews conducted each  year would be dependent on A/OPE’s available resources. monitoring should assess the quality  of performance over time and ensure  that any issues are promptly  resolved.
A/OPE has assessed compliance with grant management policies at  some bureaus in Washington, D.C., and overseas posts and found some  deficiencies in grants officials’ implementation of those policies. In 2008,  State created a Grants Management Review (GMR) program with  guidelines and a checklist for reviews. The bureaus and posts are to be  selected for review based on weaknesses identified by the Inspector  General, dollar amount and volume of grants processed, informal risk  assessments, public visibility of the grants, and bureau or post requests  to be reviewed. In addition to the GMRs and other reviews of grant- making bureaus headquartered in Washington, D.C., A/OPE has  conducted less formal reviews at grant-making posts overseas,  combining file reviews with training. These reviews—called Grants  Review Evaluation and Assistance Trainings (GREAT)—are initiated in  response to requests for training or when A/OPE becomes aware of  challenges faced at certain posts, including considerable turnover.  According to officials, A/OPE tries to select posts for review if they are  located at or near destinations where A/OPE staff have other reasons to  travel, so as to conserve resources. A/OPE officials said their method for  conducting GREATs was similar to that used for GMRs, but less in-depth.  As a result, unlike the formal GMRs—which State officials said can take 2  to 3 months to conduct—these informal GREATs take 2 to 3 days and  result in shorter reports. Between 2001 and February 2014, A/OPE  completed 13 GMRs and other reviews at 12 bureaus and offices  headquartered in Washington, D.C., and 42 GREATs at 37 posts around  the world.
These assessments of grants officials’ implementation of grants  management policy at bureaus and posts have found insufficient  documentation, among other deficiencies, and recommended solutions.  Specifically, 52 of the 55 reviews found insufficient documentation in  grant files, affecting 47 bureaus and posts. Ten of the bureaus and posts  where A/OPE had conducted GMRs, GREATs, and other reviews were  included in our review samples. At all 10 bureaus and posts, State found  challenges with documentation similar to those we identified. For  example, in 5 of the 10 bureaus and posts, A/OPE found that grants  officials did not consistently document monitoring reports or site visit  reports, and in one case the post had no monitoring plans in its award  files. A/OPE found insufficient documentation in the other 4 bureaus as  well, such as incomplete internal control checklists or inadequate  documentation of sole source justification. One bureau in Washington,  D.C., kept its monitoring reports on an electronic shared drive, but the  award files did not indicate where to find the reports. A/OPE has made  many recommendations to bureaus and posts aimed at correcting the  deficiencies it identified. These recommendations have included the  establishment of standard operating procedures and more effective use of  electronic systems for documentation, among others.
However, State has not systematically followed up to ensure the  implementation of these recommendations. State’s system for tracking  compliance with its grants management policies has yielded  recommendations for improvement at 48 of the 49 bureaus and posts it  has reviewed, but State has conducted follow-up with only 6 of those 48  bureaus and posts to ensure that these recommendations were  implemented. State’s policy for GMRs outlines how State will select and  conduct a review, but does not provide a procedure for ensuring that  corrective action has been taken and no further management action is  needed. However, A/OPE officials report that they have limited staff, with  currently only one individual leading both the GMR and GREAT reviews.  In addition, they report having a limited travel budget for conducting  follow-up reviews. A senior A/OPE official said it is necessary to be  vigilant about regularly sending messages regarding important grant- related tasks, particularly when there is considerable turnover among  personnel at posts. Because State does not track or report on the  implementation of recommendations, State cannot determine whether its  grants management reviews and training are achieving their purpose of  strengthening the management and oversight of assistance agreements.
section_title: Conclusions
paragraphs: Given the relatively large amount of funding for grants and the  widespread use of these instruments to achieve foreign policy goals, it is  important for State to ensure that grant funds are used as intended. State  has made progress toward establishing the internal controls it needs to  gain this assurance. For example, State has outlined its expectations for  grants management in detailed policies and guidance that should be clear  for all grants officials. In particular, the requirements to conduct a risk  analysis and document the implementation of required control activities  conform to the federal standards for internal control. However, we found  that most of the grant files we reviewed did not contain evidence of an  appropriate risk analysis or were missing other required internal control  documentation, and State has not developed processes for ensuring that  grants officials implement these requirements. Therefore, State’s  assurance that grant funds are used as intended is weakened.  Recommendations made in State’s internal reviews of grant-making  practices reinforce expectations concerning documentation. However,  State management does not systematically follow up to ensure that  grants officials throughout the department consistently implement these  required control activities or act upon recommendations made. As a  result, State cannot be certain that its oversight of grants management is  adequate or that it is using its limited oversight resources effectively.
section_title: Recommendations for Executive Action
paragraphs: To help ensure that State’s grants officials fully implement grants  management policies and internal controls that are in place, and that  grant funds are used as intended, we recommend that the Secretary of  State take the following two actions:  Develop processes to help ensure that bureaus and missions conduct appropriate risk assessments, and grants officials complete required documentation for all grants. Such a  process could include systematic inspections of grant files, with the  results shared among A/OPE, the appropriate bureaus and missions,  and the grants officials themselves, so as to promote accountability.
In addition, we recommend that the Secretary of State take the following  action:  follow up systematically on recommendations from State’s internal  reviews of its grants management.
section_title: Agency Comments
paragraphs: We provided a draft of this report to State for its review and comment.  State provided written comments, which we have reprinted in appendix III,  as well as technical comments, which we incorporated, as appropriate.
State provided additional information about its efforts to establish policies  and guidance to provide a supportive environment for administering and  overseeing grants. In particular, State noted that, in addition to the  policies and guidance described in our report, the department has  implemented processes regarding grant-making authority and certification  for grants officials and has cooperated with the Office of Management  and Budget on governmentwide foreign assistance management issues.
State concurred with our recommendations to develop processes for  ensuring that bureaus and missions conduct appropriate risk  assessments and that grants officials complete required documentation.  Specifically, State indicated that it will modify risk assessment guidance to  include suggestions from our report, provide additional training focused  on risk assessment, and specifically evaluate compliance with risk  assessment requirements in State’s own assessments of internal controls  at bureaus and posts. State also indicated that it will increase the  emphasis on file documentation and expand the extent of file reviews  during these assessments at bureaus and posts to help ensure that  grants officials complete required documentation for all grants. In  addition, State concurred with our recommendation to follow up  systematically on recommendations from State’s internal reviews of its  grants management. Specifically, it said that it will require formal  responses to recommendations from its grant management assessments  at bureaus and posts, to include recommendation implementation status  updates.
We are sending copies of this report to the appropriate congressional  committee and the Secretary of State. In addition, the report is available  at no charge on GAO’s website at http://www.gao.gov.
If you or your staff have any questions about this report, please contact  me at (202) 512-3149 or GootnickD@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. GAO staff who made major contributions to  this report are listed in appendix IV.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: Our objectives were to examine (1) the policies and guidance that the  Department of State (State) has established to administer and oversee  grants and cooperative agreements, and (2) the extent to which the  implementation of those policies and guidance provides reasonable  assurance that funds are being used as intended.
To define grants and cooperative agreements (grants) and to describe the  roles and responsibilities of those involved in managing State’s grants  and the key activities grants officials must conduct during each phase, we  reviewed State’s grants policy directives (GPD) and State’s required  grants officials training, and interviewed State officials. To describe the  internal control standards applicable to State grants management, we  reviewed the Standards for Internal Control in the Federal Government  (the federal standards).
To describe the policies and guidance that State has established to  administer and oversee grants, we reviewed federal regulations, Office of  Management and Budget (OMB) circulars, and State’s GPDs, as well as  training and other resources the department provides its grants officials.  We collected and analyzed all 54 active GPDs issued by State’s Office of  the Procurement Executive (A/OPE). We reviewed State Department  training regarding State’s incorporation of federal regulations into its  grants policies and interviewed A/OPE officials regarding this topic. We  interviewed officials from A/OPE and the Office of the Deputy Chief  Financial Officer, who set department-wide policies on grant performance  and financial management, and bureau and post officials regarding any  additional policies and guidance they provide that is specific to the  programs they manage. To describe the extent to which State’s GPDs  establish internal controls throughout the phases of a grant’s life cycle, we  compared the key activities the grants officials must conduct at each  phase, as well as the additional training and guidance A/OPE provides to  grants officials, with the federal standards and with federal regulations for  grants management.
To assess the extent to which State’s policies and guidance provide  reasonable assurance that funds are being used as intended, we  assessed State’s policies and guidance for grants management against  the implementation of those policies, as well as reviewing State’s own  process for conducting internal assessments of the implementation of  those policies. We interviewed State officials from A/OPE, the Office of  the Deputy Chief Financial Officer, and various functional and regional  bureaus and offices headquartered in Washington, D.C., and three  overseas missions to determine how State both designs and implements  department-wide internal control policies on grants performance and  financial management.
To further determine how State implements these policies, we selected  three case study countries —Afghanistan, Cambodia, and Turkey—  based on criteria that included total dollar value of grants in a country,  geographic diversity, and balance among the bureaus involved in  managing the awards. For these countries we examined a  nongeneralizable sample of 48 grants by award size and bureau that had  obligations in fiscal year 2012. In addition, we used the same criteria to  draw another nongeneralizable sample of 13 grants managed in the  United States, Washington, D.C. Overall, the 61 grants we reviewed  ranged in value from just over $25,000 to $28,000,000, and totaled  approximately $172 million. To arrive at these 61 grants, we included all  grants over $25,000 with obligations in fiscal year 2012 in Cambodia and  Turkey, which had 15 and 21 such grants respectively, and selected 20  such grants managed in the other two countries, for a total of 76 files. We  excluded grants where multiple places of performance were listed and  selected only those grants where our four countries were listed as the  only place of performance. However, once we began conducting  interviews regarding these grants, we discovered that some of the grants  had been mislabeled in State’s Grants Database Management System.  Specifically, 2 were managed in countries other than the ones listed in the  database; another grant was listed in the database as being managed in  Cambodia alone, but was in fact managed from Washington, D.C., and  implemented worldwide; and a fourth grant was a duplicate of a grant  already in our sample. Correcting for these errors and adjustments, our  sample was reduced to 72 grants. Three bureaus each managed 10 or  more of these, accounting for 39 of the 72 grants. We determined that we  had obtained sufficient coverage of grants from the three bureaus in  question by reviewing 28 of their 39 grants. This determination further  reduced our overall sample size from 72 to 61 grants. The final sample of  61 grants we conducted file reviews for included 19 in Afghanistan, 10 in  Cambodia, 19 in Turkey, and 13 in the United States.
Collectively, the grants in our samples were managed by 3 posts and 14  bureaus of the 27 grant-making bureaus and offices in State. Our sample  included grants by 6 of the top 10 bureaus and posts in terms of State’s  total federal financial assistance obligations in fiscal year 2012. Our  sample was nongeneralizable and did not allow us to determine whether  there were any statistically significant differences by factors such as  bureau or award size. In this report, we presented the overall results of  the data on internal control activities for all 61 grants that we selected for  data collection instrument review. During our analysis, we also looked for  any overall patterns or differences by bureau and award size in terms of  dollar value, but did not note any. We identified examples of concerns  about controls that we reported on, such as incomplete documentation  and absence of a risk assessment, in awards with high and low dollar  values across the bureaus in our sample. To examine how grants  officials implemented grants management policies, we conducted file  reviews for 61 grants using a data collection instrument and interviews  regarding those 61 grants using a standard set of questions. We  developed the data collection instrument to assess grants officials’  implementation of a selection of State’s required internal control activities  for grants management, including risk assessment, monitoring of  recipients, and documentation of key activities. To identify these required  internal control activities, we analyzed federal regulations and State  policies and guidance related to management of grants across their life  cycle and compared them against the federal standards. The data  collection instrument asked a series of questions about critical elements  of these internal control activities. During our reviews, we examined the  files that State provided for each grant to determine whether they  contained sufficient evidence to indicate whether the control activities had  been performed. Our file review guidance indicated that while State policy  requires the complete official file to be located in at least one place,  analysts completing the reviews were directed to contact grants officials  responsible for the files to request missing information where possible.  Comments sections in the data collection instrument allowed the  reviewers to document these requests and other notes they had about  each question in the file. Two analysts reviewed each file, with the second  analyst verifying the first analyst’s review. The focus of our analysis was  the degree to which the grants officials had performed the required  control activities for the grants in our sample. As noted above, we also  considered whether there were any patterns or differences by award size  in dollars or by bureau, but did not find any. In addition, the interview  questions asked grants officials to identify training and guidance they  found helpful, as well as any challenges they encountered as they  implemented these policies. We pretested both the data collection  instrument and interview questions in Kabul, and tested revised versions  in Washington, D.C. Our file review and interview questions covered each  phase of the grant life cycle, from preaward to closeout. We then  compared the file review results for control activities against responses  collected using the standard interview questions to provide a more  complete picture of how the grants officials implemented the policies and  identify reasons these officials cited for instances of noncompliance, as  well as any State policies and guidance they found helpful.
We conducted interviews using the standard set of questions with at least  one grants officer (GO) for each of the 61 grants in our sample, ultimately  interviewing more than 50 GOs and grants officer representatives (GOR),  as well as some program officers. To identify any internal control  deficiency patterns or trends, we analyzed and compared the data we  collected from our file reviews and interviews and also compared them to  the findings from State’s internal inspections of grant-making operations.
To describe State’s assessment of grants officials’ implementation of its  internal controls, we reviewed State’s guidance for conducting these  reviews, interviewed A/OPE officials regarding the review process, and  reviewed 55 assessment reports A/OPE issued between 2001 and  February 2014. These 55 included the assessment reports A/OPE  conducted in 12 grant-making bureaus, including 10 Grants Management  Reviews and 3 other reviews, and reports from the 42 Grants Review  Evaluation and Assistance Trainings A/OPE conducted at 37 posts  around the world. Of the 55 assessment reports, 10 covered 10 of the 17  bureaus and posts included in our review. We analyzed those 10 reports  to identify any findings related to the federal standards. We also  reviewed all 55 reports to identify any instances where A/OPE either  made recommendations and then returned to the bureaus and posts to  follow up, or documented receiving recommendation implementation  progress reports from those bureaus and posts.
We conducted this performance audit from May 2013 to July 2014 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe the  evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
section_title: Appendix II: Internal Control Standards as Designed and Implemented in State’s Grants Management
paragraphs: We analyzed State’s grants policy directives (GPD) as well as its own  grants management reviews, and we conducted file reviews for 61 grants  in our sample to help determine both the policies State established for  internal controls in grants management as well as how grants officials  implemented those policies. To conduct the file reviews, we developed a  data collection instrument that focused on basic documentation, decisions  about competitive selections, risk management approach, monitoring  approach, and closeout activities. For a full description of the  methodology for the file reviews, see appendix I.
The following tables reflect our overall analysis of State’s policies and  management reviews as well as selected results from our file reviews that  correspond to the five internal control standards of control environment,  risk assessment, control activities, information and communication, and  monitoring. We analyzed A/OPE’s GPDs against each internal control  standard to describe the control environment (see table 2). For risk  assessment, control activities, and information and communications, we  selected results from our 61 file reviews using a data collection instrument  we developed to analyze these three internal control standards in  particular (see tables 3-8). Finally, for monitoring, we analyzed A/OPE’s  findings from its internal reviews assessing the implementation of the  internal control activities at eight bureaus and two posts included in our  sample (see table 9). We selected these results because they add  additional detail to the information summarized in the report.
subsections: section_title: Control Environment
paragraphs: As shown in Table 2, we analyzed all 54 of A/OPE’s active GPDs against  each internal control standard to help describe the control environment.
section_title: Risk Assessment: Risk Management Approach
paragraphs: To determine the extent to which overall risk management was conducted  for each grant, each file reviewer first answered a series of questions in  our data collection instrument about key elements of risk management,  including the risk identification process, review of financial and systems  controls, consideration of external risks, risk identification, risk  assessment, and risk mitigation. On the basis of the responses to those  questions, the reviewers made a final determination on overall risk  management (see table 3).
section_title: Control Activities: Monitoring Approach and Closeout
paragraphs: To determine the extent to which overall monitoring (see table 4) and  closeout activities (see table 5) were conducted for each grant, each file  reviewer first answered a series of questions in our data collection  instrument about key elements of monitoring and closeout, including  whether there was a monitoring plan, and if so, whether it reflected risks,  whether monitoring mechanisms were described in the plan, whether the  plan had been executed, and whether monitoring had been carried out in  the absence of a plan. On the basis of the responses to those questions,  the reviewers made a final determination about overall monitoring.
section_title: Information and Communications
paragraphs: The data collection instrument we used to conduct the 61 file reviews also  contained questions related to information and communications. For  example, it contained questions and statements to verify whether required  documentation was present and if so, whether it was complete. The  documentation we looked for included the required internal control  checklist, or DS-4012 (see table 6); overall documentation of competitive  selection decisions (see table 7); and the required justification for  awarding any grants without a full and open competition (sole-sourcing)  (see table 8). To determine the extent to which overall competitive  selection decisions were justified for each grant, each file reviewer first  answered a series of questions about key elements of that justification,  including—but not limited to—whether the award was sole-sourced, and if  so, whether the decision to sole-source was justified in writing. On the  basis of the responses to those and other questions, the reviewers made  a final determination about the overall documentation of justification of  competitive selection decisions (see table 7).
section_title: Monitoring
paragraphs: A/OPE has assessed compliance with grant management policies at  some bureaus in Washington, D.C., and overseas posts using its Grants  Management Reviews (GMR) and Grants Review Evaluation and  Assistance Trainings (GREAT) and other reviews. The 55 reviews State  conducted between 2001 and February 2014 found some deficiencies in  grants officials’ implementation of State’s grant management policies.  Eight of the bureaus and two of the posts where State conducted there  reviews were included in our sample of grants. We analyzed those 10  reports to identify any findings related to the federal standards   (see table 9).
section_title: Appendix III: Agency Comments
section_title: Appendix IV: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, James B. Michels (Assistant  Director), Judith Williams, Katherine Forsyth, Jacob Beier, Debbie Chung,  Oliver Culley, Martin De Alteriis, Jon Fremont, Farhanaz Kermalli, Anne  McDonough-Hughes, Kimberly McGatlin, Shakira O’Neil, and Justin  Fisher made key contributions to this report. Etana Finkler, Ernie  Jackson, Julia Jebo Grant, and Cristina Ruggiero provided technical  assistance.
section_title: Related GAO Products
paragraphs: Grant Workforce: Agency Training Practices Should Inform Future  Government-wide Efforts. GAO-13-591. Washington, D.C.: June 28,  2013.
Cuba Democracy Assistance: USAID’s Program Is Improved, but State  Could Better Monitor Its Implementing Partners. GAO-13-285.  Washington, D.C.: January 25, 2013.
Grants to State and Local Governments: An Overview of Federal Funding  Levels and Selected Challenges. GAO-12-1016. Washington, D.C.:  September 25, 2012.
Grants Management: Action Needed to Improve the Timeliness of Grant  Closeouts by Federal Agencies. GAO-12-360. Washington, D.C.: April 16,  2012.
Improper Payments: Remaining Challenges and Strategies for  Government-wide Reduction Efforts. GAO-12-573T. Washington, D.C.:  March 28, 2012.  2012 Annual Report: Opportunities to Reduce Duplication, Overlap and  Fragmentation, Achieve Savings, and Enhance Revenue.  GAO-12-342SP. Washington, D.C.: February 28, 2012.
Federal Grants: Improvements Needed in Oversight and Accountability  Processes. GAO-11-773T. Washington, D.C.: June 23, 2011.
Grants.gov: Additional Action Needed to Address Persistent Governance  and Funding Challenges. GAO-11-478. Washington, D.C.: May 6, 2011.
Government Performance: GPRA Modernization Act Provides  Opportunities to Help Address Fiscal, Performance, and Management  Challenges. GAO-11-466T. Washington, D.C.: March 16, 2011.
Iraq and Afghanistan: DOD, State, and USAID Face Continued  Challenges in Tracking Contracts, Assistance Instruments, and  Associated Personnel. GAO-11-1. Washington, D.C.: October 1, 2010.
Contingency Contracting: Improvements Needed in Management of  Contractors Supporting Contract and Grant Administration in Iraq and  Afghanistan, GAO-10-357. Washington, D.C.: April 12, 2010.
Iraq and Afghanistan: Agencies Face Challenges in Tracking Contracts,  Grants, Cooperative Agreements, and Associated Personnel.  GAO-10-509T. Washington, D.C.: March 23, 2010.
Electronic Government: Implementation of the Federal Funding  Accountability and Transparency Act of 2006. GAO-10-365. Washington,  D.C.: March 12, 2010.
Grants Management: Grants.gov Has Systemic Weaknesses That  Require Attention. GAO-09-589. Washington, D.C.: July 15, 2009.
Single Audit: Opportunities Exist to Improve the Single Audit Process and  Oversight. GAO-09-307R. Washington, D.C.: March 13, 2009.
Grants Management: Attention Needed to Address Undisbursed  Balances in Expired Grant Accounts. GAO-08-432. Washington, D.C.:  August 29, 2008.
Department of State: Human Capital Strategy Does Not Recognize  Foreign Assistance Responsibilities. GAO-07-1153. Washington, D.C:  September 28, 2007.
Foreign Assistance: U.S. Democracy Assistance for Cuba Needs Better  Management and Oversight. GAO-07-147. Washington, D.C.: November  15, 2006.
Grants Management: Enhancing Performance Accountability Provisions  Could Lead to Better Results. GAO-06-1046. Washington, D.C.:  September 29, 2006.
Grants Management: Grantees’ Concerns with Efforts to Streamline and  Simplify Processes. GAO-06-566. Washington, D.C.: July 28, 2006.
Auditing and Financial Management: Standards for Internal Control in the  Federal Government. GAO/AIMD-00-21.3.1. Washington, D.C.:  November 1, 1999.