Recovery Act: Head Start Grantees Expand Services, but More Consistent Communication Could Improve Accountability and Decisions about Spending
Published: 2010-12-15T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: This report responds to two mandates for GAO under the American Recovery and Reinvestment Act of 2009 (Recovery Act). First, it is the latest report on the uses of and accountability for Recovery Act funds in selected states and localities. Second, it comments on recipients' reports of the jobs created and retained. The Recovery Act provided $2.1 billion for Head Start and Early Head Start, primarily to expand services. GAO addressed four questions: (1) How have Head Start and Early Head Start grantees used Recovery Act funds, including for expanding enrollment? (2) What challenges have grantees encountered in spending Recovery Act funds? (3) How has the Office of Head Start (OHS) monitored the use of Recovery Act funds? (4) How has the quality of jobs data reported by Recovery Act recipients, particularly Head Start grantees, changed over time? In this report, GAO also updates the status of open recommendations from previous bimonthly and recipient reporting reviews. To address these questions, GAO interviewed grantees, analyzed federal agency and recipient reported data, and interviewed officials.
section_title: What GAO Found
paragraphs: Grantees reported using Recovery Act funds to expand enrollment and staff in a variety of ways, but new enrollment was lower than anticipated and reported enrollment numbers may not always be reliable. Grantees received funds to increase enrollment from about 890,100 to an additional 60,600; reported enrollment increased by 55,100 by the end of September 2010. Grantees GAO interviewed used different definitions of "enrollment," which OHS does not verify, introducing some unreliability in reporting. Grantees nationwide reported adding significant numbers of staff, but the portion of teachers who met recently increased standards slightly declined. Grantees experienced challenges in spending first-year Recovery Act funds, including delays in receiving grants and preparing facilities for expanded services, and received mixed messages about what to do with unobligated funds. By the end of the first year of Recovery Act funding, expansion grantees had expended at least 60 percent of their awards. Also, more than half of the grantees GAO interviewed said they were unclear about the policy regarding unobligated first-year funds. Because OHS did not clearly communicate its policy to regional offices, grantees adopted varied spending practices that may not always have directed expansion funds toward programs' highest, current priorities. OHS has engaged a contractor to conduct the large volume of monitoring visits required 1 year after expanded operations begin, but has not always incorporated some risk indicators in planning reviews. OHS has also been conducting other monitoring efforts, including mandatory 1-year visits for Early Head Start expansion grantees. These 1-year reviews include additional coverage of grantee governance and financial management. In response to prior GAO findings of fraudulent enrollment and attendance and enrollment discrepancies among some Head Start grantees, all monitoring visits to new grantees will be implemented as "surprise" visits. A few grantees awarded expansion funds had been earlier identified as high risk by their regional offices, and the HHS Inspector General identified several financial management deficiencies among four of the expansion grantees it reviewed. However, information on identified risks was not always available to OHS reviewers. OHS plans to scope and staff its 1-year reviews of Recovery Act grantees based primarily on their prior experience with Head Start and Early Head Start and whether the grantees have recently received a triennial review. GAO's analysis of the data reported by recipients in Recovery.gov, including jobs funded, shows results similar to previous reporting periods. For example, GAO continued to see a small number of reports for which data issues could prevent linking related reports across quarters. Analysis of Head Start recipient data showed that an earlier concern with calculating full-time equivalent jobs is being addressed. Further, in response to September 2010 Office of Management and Budget guidance on transparency of narrative descriptions, OHS reported that additional agency reviews resulted in recipients clarifying their reports.
section_title: What GAO Recommends
paragraphs: GAO recommends OHS verify the definition of enrollment, clearly communicate it to grantees along with policies for extending the use of Recovery Act funds, and incorporate known risks into review planning. HHS generally agreed with GAO's recommendations.

section_title: Letter
paragraphs: In the 22 months since the American Recovery and Reinvestment Act of  2009 (Recovery Act) was enacted, the Department of the Treasury has  paid out approximately $181.9 billion in Recovery Act funds for use in  states and localities to promote economic recovery. These funds have  been used to support and preserve services in a wide range of areas  including health, education, transportation, and child development. In  particular, the Recovery Act provided $2.1 billion for Head Start and Early  Head Start, primarily to expand the program from about 890,100 to about  an additional 60,600 children and families. Since its inception, the  program has provided comprehensive early childhood development  services intended to promote the school readiness of low-income children.
The Recovery Act requires that GAO conduct bimonthly reviews of how  Recovery Act funds are being used and whether they are achieving their  stated purposes to preserve and create jobs, as well as assist those most  affected by the recession. The Recovery Act also requires GAO to  comment and report quarterly on estimates of job creation and retention  as reported by recipients.
In this report, the eighth in a series responding to the act’s mandate, we  update and add new information on the use of Recovery Act funds by the  Head Start program, and on the quality of recipient job reports.  Specifically, we examined (1) how Head Start and Early Head Start  grantees used Recovery Act funds, including for expanding enrollment; (2)  what challenges grantees have encountered in spending Recovery Act  funds; (3) how the Office of Head Start (OHS) has monitored the use of  Recovery Act funds; and (4) how the quality of jobs data reported by  Recovery Act recipients, particularly Head Start grantees, has changed  over time. To address these questions, we analyzed grant awards, agency  data, and relevant federal laws and regulations, as well as federal agency  guidance. We spoke with relevant program officials at the Department of  Health and Human Services’ (HHS) OHS and an OHS contractor. We  conducted interviews with 16 grantees in 11 states, 4 of which were among  the 16 states on which GAO has reported in previous bimonthly reviews.  We followed up with 9 grantees that we have previously reported on in  these 4 states, while the remaining 7 we selected by analyzing HHS  expenditure data to identify grantees with low drawdown rates as of July  2010. These 16 grantee interviews are not generalizable to the  approximately 1,600 Head Start and Early Head Start grantees nationwide  in fiscal year 2009. In addition, we assessed recipient reports nationwide  for the quarter ending September 30, 2010, as well as those of Head Start  grantees for completeness and reliability. We also analyzed Head Start  grantees’ reported “full-time equivalent” jobs data across time.
Our oversight of programs funded by the Recovery Act has resulted in  more than 80 related products (see Related GAO Products at the end of  this report) with numerous recommendations. This report updates agency  actions in response to recommendations from previous bimonthly and  recipient reporting reviews that have not been fully implemented (open  recommendations) in appendix III, including our prior recommendations  regarding the use of Recovery Act funds for Head Start.
We conducted this performance audit from August 2010 to December 2010  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 that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
subsections: section_title: Total Recovery Act Outlays to States and Localities
paragraphs: Actual federal outlays to states and localities for all programs under the  Recovery Act, including Head Start, totaled approximately $181.9 billion  through November 26, 2010. Of that amount, about 9.5 percent—$17.3  billion—has been paid out since the start of federal fiscal year 2011 on  October 1, 2010. Figure 1 shows the estimated federal outlays (in billions  of dollars) to states and localities for Recovery Act programs for fiscal   for fiscal  years 2009 through 2016.  years 2009 through 2016.
To facilitate accountability over the use of Recovery Act funds, the act  requires that nonfederal recipients of Recovery Act funds—including  those with grants, contracts, or loans—submit quarterly reports that are to  include a list of each project or activity for which Recovery Act funds were  expended or obligated and information concerning the amount and use of  funds and jobs created or retained by these projects and activities, among  other information. The latest of these recipient reports covered the  projects and activities as of the Recovery Act’s passage through the  quarter ending September 30, 2010.
section_title: The Head Start Program
paragraphs: Established in 1965, Head Start provides for services to young, low-income  children and their families. It promotes pre-school aged children’s  development and school readiness by enhancing their cognitive, social,  and emotional development through providing a range of individualized  services. The Early Head Start program, begun in 1994, focuses on serving  children from birth to age 3 and pregnant women. Both Head Start and  Early Head Start are overseen by OHS, within the Administration for  Children and Families (ACF) at HHS. OHS awards grants directly to public  and private nonprofit and for-profit agencies. Grants policy is established  by ACF and HHS.
section_title: Head Start Funds under the Recovery Act
paragraphs: Under the Recovery Act, OHS received $2.1 billion for Head Start and  Early Head Start. Of that amount, OHS designated about $1.5 billion to  expand the number of children and pregnant women served. The Recovery  Act required OHS to obligate all funds—mostly by awarding funds to  grantees—by September 30, 2010. To serve additional children and  families with Recovery Act funds, OHS awarded Head Start expansion  grants generally for a period of 2 years. Consistent with the Recovery  Act, OHS designated a portion of these funds for training and technical  assistance to the expansion grantees. In addition to expanding services,  the Head Start Act directs a portion of Recovery Act funds to be allocated  to increase salaries, improve program quality, develop state advisory  councils, and monitor grantees, as shown in table 1. About $600 million  was dedicated to these purposes.
As of September 30, 2010, OHS had awarded about 99 percent of the $1.5  billion in Recovery Act funds designated for expanding Head Start and  Early Head Start, primarily for staffing. OHS awarded $744 million for the  first year of the expansion grant period, or fiscal year 2010. As shown in  figure 2, after staffing, the second largest budget category to which funds  were dedicated was “other” costs, which can be used for activities such as  insurance, food, and administrative costs. Funds from the third largest  budget category, “contractual,” may be used to engage entities such as  start-up planning consultants, agencies to which grantees delegate funds  to operate Head Start or Early Head Start programs, or food service  providers.
As we reported in May 2010, OHS had awarded most expansion funds  within a year of the law’s enactment, but had not met its goal of awarding  Early Head Start expansion grants by the end of September 2009. Instead,  the first Early Head Start awards were made in November 2009, and the  last one was made in July 2010. OHS officials explained that several  factors slowed the process of making Early Head Start awards, such as the  high volume of applications. The prolonged award-making process  contributed to a low drawdown (expenditure) rate. It also put pressure on  grantees because OHS shortened the period designated for start-up in  some cases.
Like typical Head Start and Early Head Start grants, expansion grantees  receive funding 1 year at a time partly to ensure that grantees expend  funds prudently. Consistent with its general practice, OHS awarded the  first year of Recovery Act funds between September 2009 and July 2010 for  expenditures by September 29, 2010. Near the end of the same fiscal  year, OHS awarded the balance of all funds for the final, second fiscal year  of the expansion grants.
In the event that a grantee cannot use all its funds within a single, annual  “budget period,” Head Start has provisions for generally using such funds  in the following year.
First, to allow for an orderly transition between budget periods, all Head  Start grantees can expend obligated funds in a subsequent budget period  without additional OHS approval if the funds were obligated for  expenditure by the end of the year for which they were awarded.  Obligated funds must be expended within 90 days of the close of the  budget period. For Recovery Act grants, this means that grantees generally  have until December 29, 2010, to expend funds obligated before  September 29, 2010.
Second, to use unobligated funds in a future budget period, grantees must  receive approval from an OHS regional office to “carry over” unobligated  funds. HHS and OHS policy states that grantees must apply in advance and  in writing, and must name specific items for which the funds will be used  in the next budget period. For first-year Recovery Act grants, requests are  due 90 days after the close of the fiscal year, which ends September 29,  2010.
Third, for grants that are not being renewed, OHS can approve a grantees’  request for an extension of time to complete a project, called a “no-cost  extension.” Grantees must also apply in advance for a no-cost extension,  which cannot be used if the primary purpose of the extension is to permit  the use of unobligated funds. If no extension is approved and the grantee  does not receive further Head Start grants (potentially allowing the  grantee to use the Recovery Act funds to start another project with a  longer time frame), unused Recovery Act funds will be returned to the U.S.  Treasury.
In addition, oversight of spending is a key internal control. As described in  GAO’s internal control standards, managers need current information on  expenditures to detect problems and proactively manage risks associated  with unusual expenditure patterns, such as overly rapid or slow  expenditures. Slow expenditures would present special challenges to  meeting the Recovery Act’s goals of assisting persons affected by the  recession and infusing funds into the slowing economy.
section_title: Monitoring and Oversight of Head Start Grantees
paragraphs: OHS uses various strategies to monitor Head Start grantees for adherence  to program standards as specified by the Head Start Act. These strategies  include comprehensive reviews conducted every 3 years. The Head Start  Performance Standards cover many activities designed to protect and  teach children, promote health, and responsibly manage federal funds. The  central OHS office provides guidance to grantees and monitors them  through centralized data systems. Staff in OHS regional offices directly  monitor grantees by following up on any concerns that are raised, such as  low enrollment, and by coordinating with contractors on the  administration of triennial reviews. OHS is also required to review any  newly funded grantee—such as the Early Head Start grantees that received  funds for the first time under the Recovery Act—immediately after the  completion of the first year it carries out a Head Start program.
The 2007 reauthorization of the Head Start Act also increased credential  requirements for some teachers. In particular, Early Head Start center- based teachers are required to have a Child Development Associate  credential and to have been trained (or have equivalent coursework) in  early childhood development by the end of September 2010.
In 2008, we made recommendations to enhance the use of risk  management strategies in management of Head Start. In its response,  HHS cited in part a more comprehensive risk assessment that was  developed and implemented in two regions. This and other activities, it  reported, evolved into a programwide risk management process that  officials stated was on track for national implementation in early 2008.  Through this process, officials noted that OHS would better identify risks,  challenges, and opportunities that Head Start programs might be  experiencing.
A central component of OHS’s risk management process is the Risk  Management Meeting. The goals of the meetings are to recognize grantee  strengths, identify areas of performance that need improvement, and use  this information to collaborate in producing a comprehensive action plan  that addresses those areas in need of support and improvement. While all  grantees are to have at least one Risk Management Meeting each year,  additional Risk Management Meetings might be held to gauge progress in  meeting goals or sustaining improvements, or when a grantee was  determined to have deficiencies or a significant number of  noncompliances.
section_title: Recent Accountability Community Findings
paragraphs: We and a federal inspector general have documented specific risks  through recent reviews and investigations of Head Start and its grantees.  In a September 2010 report, we found that in 8 of 13 instances, staff at  Head Start centers fraudulently misrepresented information to register  children who did not meet the income-eligibility requirements. The  undercover tests found that seven Head Start employees lied about  applicants’ employment status or misrepresented their earnings, leaving  these programs at risk that over-income children might be enrolled while  other eligible children are put on wait lists. These grantees had received  small amounts of Recovery Act funds for cost-of-living adjustments and  quality improvement. Additionally, five of them had received expansion  funds. We also examined attendance records for two other grantees that  were the subject of FraudNet reports and found that attendance was  substantially different from reported enrollment in both cases.
In mid 2009, HHS’s Office of the Inspector General (OIG) conducted  recipient capability audits of 83 Recovery Act applicants that had not  previously managed a Head Start or Early Head Start program. These  reviews focused on three aspects of program management: financial  viability; adequacy of management systems to account for funds; and  ability to operate a Head Start program according to federal regulations.  Following the reviews, some applicants were excluded from consideration  for a Recovery Act expansion grant. The OIG has also reviewed selected  Head Start grantees for program management issues and is nearing  completion of a series of health and safety audits of selected Head Start  grantees.
section_title: Grantees Report Expanding Program Options, Staff, and Enrollment, but Enrollment Figures May Be Unreliable
subsections: section_title: Grantees Expanded Program Options and Staff to Serve More Children and Families, Although Teachers Hired Did Not Always Meet Qualification Requirements
paragraphs: Head Start and Early Head Start grantees received $744 million in first- year Recovery Act funding to expand services from about 890,100 to about  an additional 60,600 children and families, often by initiating home-based  services. Most Early Head Start expansion grantees we interviewed  received funding for a combination of center-based and home-based  program options. Under the home-based program option, children and  families receive visits from Early Head Start staff in their homes, and meet  periodically for socialization activities. In 2009, before Recovery Act funds  were awarded, Early Head Start grantees provided home-based programs  for about 42 percent of the children and families they served, compared  with about 47 percent after Recovery Act funds were awarded, in 2010.
Many of the Early Head Start grantees we interviewed increased their  enrollment in home-based services to compensate for facilities delays to  serve the expanded enrollment for which they were funded. Of the 13  Early Head Start expansion grantees with whom we spoke about program  options, 8 initially planned to offer more center-based services than home- based. Among the 13 grantees, there were a total of 684 center-based slots  and 487 home-based ones. However, as a result of delays in receiving  awards, licensing concerns, difficulties in preparing facilities, and other  challenges, 7 grantees reported that they changed their expansion plans,  resulting in more home-based slots (667) than center-based ones (520)  among the 13 grantees.
Five grantees converted some of their center-based slots to home-based  slots. Four of these five changes were temporary—while grantees waited  for centers to be constructed, renovated, or licensed—but one change will  remain throughout the duration of the 2-year grant. In moving some of its  center-based slots to home-based ones, officials of one grantee in Illinois  told us that they had received approval from their regional office to enroll  16 more children and families than they had initially planned.
In addition to beginning home-based programs and constructing and  renovating facilities for center-based programs, grantees used Recovery  Act funds to support their expansion of services. Facilities and other  program features are tracked in OHS’s annual Program Information Report  (PIR) survey of grantees. Table 2 shows the growth in selected program  features from 2009, before the awarding of Recovery Act funds, through  August 2010, after the funds were awarded. For example, grantees  reported adding 15,571 full- or part-time staff, including classroom  teachers and home-based visitors. While a portion of these changes may be  attributable to changes in the use of regular grant funds, much of the  change is likely due to the addition of Recovery Act expansion funds  between 2009 and 2010.
Consistent with the Recovery Act’s goal to preserve and create jobs, as  grantees expanded services, they reported using Recovery Act funding for  the equivalent of about 10,000 full-time positions, also called “full-time  equivalents” (FTE), such as for teachers, from July through September  2010, as shown in figure 3. The number of FTEs being lower than the  number of total staff grantees reported adding (see table 2) may be due to  several factors, such as some of the newly hired staff working part-time,  which counts for one staff position but only for a fraction of an FTE;  differences in the reporting periods covered; and the fact that some  grantees reporting staffing levels did not receive Recovery Act expansion  grants. FTE data provide insight into the use and impact of the Recovery  Act funds, but recipient reports cover only direct jobs funded by the  Recovery Act. They do not include the employment impact on suppliers  (indirect jobs) or on the local community (induced jobs).
Due to various start-up challenges, there was only a gradual growth in  FTEs, as reported by grantees. For the quarter October through December  2009, only about one-third of grantees reported funding some portion of an  FTE with Recovery Act expansion funds. However, by the quarter of July  through September 2010, about 92 percent of grantees reported funding at  least a partial FTE, as shown in figure 4. As the number of grantees  reporting FTEs increased, the mean number of FTEs reported increased as  well—from 1.4 in the October though December 2009 quarter, to 11.8 in  the July through September 2010 quarter, also shown in figure 4.
As grantees added classroom teachers and home-based visitors from 2009  to 2010, as shown in table 2, the proportion of teachers meeting new, more  stringent qualification requirements fell slightly. The percentage of  classroom teachers meeting the new Early Head Start qualification  requirements, which went into effect September 30, 2010, dropped from 88  to 84 percent from 2009 to 2010. OHS officials told us some grantees  experienced challenges hiring staff with the required qualifications. In  addition, the proportion of Early Head Start classroom teachers and home- based visitors without credentials rose from 2009 to 2010. Classroom  teachers without credentials increased from 12 to 16 percent. While home- based visitors are not required to meet any qualification requirements, the  percentage of home-based visitors without credentials increased from 18  to 23 percent. Grantees in focus groups we conducted cited finding and  developing staff as a significant challenge.
section_title: Enrollment Increases Were Smaller than Expected, and Some Numbers Reported by Grantees Were Not Necessarily Reliable
paragraphs: Reported enrollment of children and families in Head Start services also  increased under the Recovery Act, though less than OHS anticipated. As  we previously reported, by the end of the first year of the 2-year grant  (fiscal year 2010), OHS planned to have used Recovery Act funding to  provide for enrollment of an additional 55,000 pregnant women, infants,  and toddlers under Early Head Start and an additional 14,100 children and  families under Head Start, for a total of 69,100 new enrollees. However,  OHS funded about 60,600 new Early Head Start and Head Start slots.  Because grantees were not able to enroll and provide services to the  numbers of children for whom OHS had provided funding as rapidly as  expected, by the end of September 2010, reported enrollment for both  programs totaled about 55,100, as shown in figure 5. This slow and gradual  growth in enrollment meant that grantees enrolled fewer children and  families for fewer months than OHS had planned.
Officials from 14 Early Head Start expansion grantees we interviewed  reported the following reasons:    Delays in receiving expansion grant awards. As we reported in May  2010, OHS did not meet its initial goal to award the Early Head Start  expansion grants by the end of fiscal year 2009. Awarding of Early Head  Start expansion grants began in November 2009 and continued through  July 2010. The prolonged award-making process resulted in a shortened  start-up period for some grantees, and seven grantees we spoke with cited  this as a cause for their delay in enrolling children and families.
Grntee using Recovery Act expion  fnd to renovte or contrct new fcilitie  for their center-based progrust  follow regtion deigned to protect the  federl interet. For exmple, grntee re  required to record  Notice of Federl  Interet when grnt-fnded contrction,  prchase, or mjor renovtion egin with  repect to cility. Althogh the title to   newly quired or renovted fcility my  vet with the grntee involved, such  fcilitiey not e mortgged, used as  collterl, old or otherwie trferred to  nother prty withot the written  permission of HHS. If fnding for Erly  HeSrt i not pproprited t Recovery  Act level eyond fil yer 2011, OHS  offici told us they will work with  individual grntee to find lternte w to  use the new fcilitie. For exmple, OHSsugget tht grntee move HeSrt children to new contrction from  rentl propertie or less suitable  grntee-owned fcilitie.
Delays in leasing, constructing, and renovating facilities. Six  grantees to whom we spoke experienced difficulties and delays in  securing leases, or constructing or renovating facilities in which to  provide Early Head Start services, which caused enrollment delays.
Delays in licensing facilities. Four expansion grantees we interviewed  cited delays in receiving inspections or approval for state child care  licenses for their centers as a cause for delays in enrollment.
Apart from challenges in expanding enrollment, differences in grantees’  interpretation of OHS’s enrollment policies suggest that reported  enrollment figures may not always be reliable. We discovered differences  in how grantees interpreted “enrollment” for purposes of the end-of-month  enrollment report. Five of the nine expansion grantees we interviewed  about enrollment reported children as “enrolled” when all paperwork was  complete, which is consistent with the Head Start definition of  enrollment. For example, one of these five grantees reported children on  its monthly enrollment report after the family completed forms  documenting health information, income eligibility, and residency. On the  other hand, four out of the nine expansion grantees we interviewed about  enrollment reported children as enrolled only when they had begun  receiving regular services, which is more consistent with the definition of  enrollment used in Head Start’s annual PIR instructions.
Grantees use different interpretations of enrollment for two reasons. First,  “enrollment” is defined differently in different sources, as shown in table 3.
Second, during routine on-site monitoring visits, OHS does not verify that  grantees are consistently defining enrollment for purposes of monthly  reporting. Instead, OHS checks that grantees’ records of enrollment,  however defined, are consistent with their end-of-month reports to OHS.  The monitoring protocol does not require that reviewers verify the  definition of enrollment that grantees employ in recordkeeping or monthly  reporting. Having a consistent measure of enrollment, a key performance  indicator for Head Start and Early Head Start, is crucial to helping OHS  oversee the programs and to providing transparency to outside entities.
Because OHS has not established a consistent definition for enrollment  reporting and does not verify during routine monitoring how grantees are  reporting enrollment, the grantee-reported enrollment numbers may be an  unreliable measure of grantee performance. For example, our prior work  compared two grantees’ enrollment information submitted through the  PIR with information obtained from daily attendance records we received  directly from grantees. Based on our review of this information, we  determined that for both grantees, average attendance at Head Start  centers was considerably lower than the reported enrollment at the  centers. In response to this report, HHS reported that it had taken action  to incorporate a comparison of enrollment and attendance in its reviews,  and stated that they were substantially different in only a small number of  cases. However, neither the updated monitoring protocol nor the  Recovery Act monitoring protocol contains changes designed to more  carefully reconcile enrollment and attendance figures.
section_title: Following Low Expenditure Rates in the First Year, Mixed Messages from OHS about Spending Policy Led to Varied Spending Practices
subsections: section_title: Delays, Facilities Issues, and Other Challenges Slowed Expenditure Rates
paragraphs: By the end of the first year of Recovery Act funding, expansion grantees  had expended at least 60 percent of awards, and about 1 month later,  grantees had expended about 70 percent (see figure 6), using a  conservative estimate, which is explained below. In contrast to expansion  grantees, grantees nationwide drew down at least 86 percent of Recovery  Act cost-of-living adjustment (COLA) and quality improvement (QI) funds  by the beginning of November. For expansion grantees, drawdown rates  among individual grantees varied considerably. About 14 percent of  grantees had drawn down 50 percent or less of their expansion awards,  while 62 percent of grantees had drawn down more than 75 percent of  their awards by the beginning of November. Grantees have until December  29, 2010, to expend all obligated funds for the first budget year of the  grant. However, of the 14 Early Head Start expansion grantees we  interviewed, 7 reported that they could not expend all first-year funds and  would request approval to “carry over” funds into the next year. Of these  seven, six were able to calculate the amount they would request to carry  over. The total was about $2 million, or 21 percent of their total first-year  awards.  “Drawdown” estimates can significantly underestimate individual grantees’  actual expenditures, therefore the data offer a conservative estimate of  grantees’ total expenditures nationwide. Drawdown data come from HHS’s  Payment Management System (PMS), from which grantees withdraw  funds to operate Head Start programs. Grantees generally must expend  withdrawn funds within a few days. Alternatively, grantees occasionally  use their own funds for some Head Start expenses and later withdraw  funds from PMS. For example, a representative of one American Indian  tribe we interviewed explained that the Head Start program used the  tribe’s general funds to pay for its staff’s COLAs under the Recovery Act,  and would withdraw the funds from PMS at a later time to reimburse the  tribe for its expenses. Because of practices such as these, the drawdown  rate is generally considered a conservative estimate of grantees’ actual  expenditures.
OHS officials we interviewed lacked ready access to current, aggregated  drawdown data or to normative data on drawdown rates at specific times  (or among types of grantees) that might be used to assess grantees’  current expenditures. Instead, central office officials referred to reports  that would be submitted by grantees or knowledge of specific grantees  among regional office staff. Current and historical drawdown information  are kept by a different office within HHS and are not routinely aggregated  or reported to OHS, even though current data are accessible.
Grantee expenditure patterns generally reflected when they had received  awards. Head Start grantees drew down more total first-year award funds  by the beginning of November 2010 (at least 82 percent) than Early Head  Start grantees (at least 70 percent), who received awards later. Further,  Early Head Start grantees that received expansion awards earlier drew  down more first-year award funds than those that received later Early  Head Start awards. Early Head Start grantees that received awards in  November 2009 averaged a drawdown rate of at least 83 percent, while  those who received awards in February 2010 averaged a drawdown rate of  at least 70 percent.
Different types of grantees drew down funds at different rates, as shown in  table 4. Some of the Early Head Start expansion funds went to programs  that serve two specific populations: American Indian and Alaska Native  programs enrolling children and families from federally recognized tribes  or native Alaskan children and families, and Migrant and Seasonal Head  Start programs enrolling children of migrant farm workers. Drawdown for  grantees serving American Indian and Alaska Native communities was at  least 48 percent by the beginning of November 2010, as shown in table 4.  OHS officials attribute this slow rate to the fact that some tribes advance  tribal funds to pay for services and are reimbursed retroactively.
Grantees themselves attribute low drawdown rates to delays in receiving  grants, difficulties in preparing facilities, and other challenges, as  discussed above. Five of the seven grantees we interviewed that did not  expect to obligate all first-year funds cited the delay in receiving first-year  grant awards from OHS as a challenge in expending first-year Recovery  Act expansion funds. As shown in figure 7, OHS began making Head Start  awards more than 6 months after the Recovery Act was enacted, and Early  Head Start awards were granted even later.
Among grantees attributing delays to the preparation of facilities, one  grantee cited the unanticipated need for time to commission and complete  architectural drawings of the planned facility. This grantee and another  that was constructing new facilities experienced difficulty completing the  paperwork to obtain approval from OHS to proceed with construction.  Grantees are not permitted to award a contract for construction or major  renovation without approval from an OHS official.
section_title: Due to Mixed Messages from OHS, Grantees Adopted Varied Spending Practices
paragraphs: The OHS central office told us that standard policy for permitting grantees  to request approval to carry over funds into the second year of the grant  will apply to Recovery Act expansion grantees—although a regional OHS  official reported that the OHS central office indicated that requests may  receive “additional flexibility”—and grantees we interviewed often  expressed confusion about whether or not OHS would permit them to  carry over funds. Of the officials at 13 grantees that commented on the  guidance they received, 9 stated that guidance on the carryover policy was  unclear. In particular, officials at seven grantees did not expect to obligate  all first-year funds by the end of the fiscal year, and five of these were  unclear about the carryover policy.
Given the unique nature of the Recovery Act’s one-time, 2-year funding,  grantees were unclear as to whether or not HHS’s typical carryover policy  would apply. For typical, ongoing grants, the carryover policy is explained  in HHS’s Grants Policy Statement, which states that grantees may request  to carry over unobligated funds in the next year of their grant. HHS sets  the policy for all grantees, while regional offices typically evaluate and  approve grantees’ requests for carryover. However, regional offices did not  consistently communicate a clear policy for Recovery Act funds. For  example, in June 2010, the head of one region publicly urged grantees to  expend all first-year funds within the fiscal year because the official was  uncertain about whether or not carryover would be permitted. According  to a grantee in another region, OHS staff told officials that it was likely  that the grantee would be able to carry over unobligated funds for use in  the following year. Officials at one grantee told us that the regional office  changed its guidance on carryover. Specifically, the grantee reported that  in June 2010, they received verbal assurances that they would be able to  carry over funds into the next fiscal year. According to these officials,  nearly 3 months later, the grantee was told that carryover would not be  permitted. Grantee officials representing two different regions told us that  OHS regional office contacts refused to state the carryover policy “in  writing.” One senior official from an OHS regional office confirmed that  this was the office’s practice. An OHS official representing a different  regional office stated that the office had not sent any e-mails or provided  any written guidance on carryover to grantees as of September 2010.
Regional offices conveyed inconsistent messages to grantees because the  OHS central office did not communicate its carryover policy clearly or  early to regional offices. Officials at the OHS central office explained to us  that the policy for carryover had not changed for Recovery Act grants.  Further, the officials told us that if grantees had unexpended funds at the  end of fiscal year 2011, OHS could approve grantees’ request to extend the  time period, or the funds would be returned to the U.S. Treasury.  Nevertheless, a senior official at one regional office indicated that they  were waiting for information about carryover from the central office. A  representative told us in July 2010 that the region was expecting guidance  from the central office, which was not received until mid-September— about 2 weeks before the close of the fiscal year—and came verbally, not  in written form. At that time, the regional official reported that Recovery  Act carryover requests would be permitted in a manner consistent with  normal policy, with the possibility of some additional flexibility to approve  grantee requests.
Head Start grantees need clear information about how and when they are  expected to obligate and expend federal funds so that they can plan to use  funds responsibly to achieve program goals. Under normal Head Start  policies, grantees are expected to have obligated all funds for that year  within the annual budget period or to apply in writing to carry over  unobligated funds to the next year. Grantees have access to information  on carryover and the consequences of failing to adhere to the deadlines, as  both are explained on an OHS Web site. As a result, grantees can plan  accordingly.
Grantees’ uncertainty about whether to “use or lose” Recovery Act grant  funds contributed to varied spending practices that may not always have  targeted expansion funds toward meeting programs’ highest current  priorities. Two grantees we interviewed made advanced purchases of  diapers, supplies, or other items that representatives either said were not  needed until the next fiscal year or for which the grantee did not originally  plan. Others among the 14 expansion grantees we contacted expended  funds on large items that they did not originally plan to purchase. For  example, one grantee told us they changed plans in order to purchase four  buses, a van, and staff training in the closing months of the fiscal year. On  the advice of the regional office, one grantee purchased a minivan to  transport home-based participants to health appointments and regularly  scheduled socialization activities. One grantee planned to construct a  playground to be used as an “outdoor learning environment” at a cost of  about $295,000. Another planned to use funds to construct a socialization  room for home-based Early Head Start participants on the same site as the  grantee’s other Head Start program, at a cost of about $43,000. Finally, 7 of  the 14 expansion grantees we spoke to planned to apply to OHS for  permission to carry over remaining unobligated funds into the second year.
section_title: OHS Hired a Contractor to Both Prepare for and Conduct On-Site Reviews, but Has Not Incorporated Some Risk Indicators in Planning for Reviews
subsections: section_title: OHS Has Contracted to Help Prepare for and Conduct On-Site Reviews
paragraphs: As required by the Head Start Act, OHS plans to conduct “1-year”  monitoring visits to 626 Early Head Start expansion grantees by expanding  its use of an existing contractor. HHS contracted with Danya International  (Danya) both for planning and carrying out reviews—for a total of $21  million. Since 1999, Danya has supported OHS reviews of Head Start  grantees by providing logistic and information technology support, and  recruiting and training reviewers. However, because the addition of new  grantees has been relatively rare, in any given year, OHS, together with  Danya, typically complete only a handful of first-year visits for new  programs.
In 2010, OHS openly competed a monitoring contract but received only  one bid, from its existing monitoring contractor, which had completed  initial planning for reviews of Recovery Act grantees under a  noncompetitive modification of its existing contract. OHS had awarded  Danya a noncompetitive contract modification in September 2009 for close  to $7 million to provide support for first-year monitoring visits to Recovery  Act Early Head Start expansion grantees. Under this contract as modified,  Danya was to develop a plan to integrate the Recovery Act expansion  grantee visits into the national monitoring schedule, plan to expand  recruitment of Early Head Start reviewers, and begin to develop  information technology support for handling the increased volume of  grantee reviews. HHS contracting officers justified the decision not to  compete the contract modification, stating that there was insufficient time  for another company to plan for monitoring Recovery Act expansion  grantees. OHS also estimated that awarding the contract to a contractor  other than Danya would cost $11 million in duplication of effort.  Subsequently, however, in accordance with the Recovery Act, HHS  officials competed their entire monitoring contract in January 2010 to  implement the monitoring visits that Danya had planned, as well as non- Recovery Act visits, worth $38 million each year. As the only company to  bid for the contract, Danya was awarded the contract for both Recovery  Act and non-Recovery Act monitoring on April 28, 2010. The Recovery Act  portion of this contract totaled $14 million dollars, of which Danya had  billed for close to $2.1 million as of September 2010.
Under Danya’s initial Recovery Act planning contract, OHS postponed  indefinitely a centralized data management system for all grantees after  paying more than $250,000 in Recovery Act funding for the project. The  data system, called the Knowledge Management Repository, was meant to  consolidate different OHS data systems into one system. For example, the  Knowledge Management Repository would have compiled grantee review  data and evidence, and information about reviewers’ expertise. In  February 2010, however, this project was postponed indefinitely.  According to OHS officials, they decided to postpone the project,  determining that this function should be implemented internally. They  stated the work completed by Danya will be used in a future data  management system. Although OHS officials told us that a working group  on monitoring information technology systems began meeting in October  2010, officials indicated that the envisioned data system will not be  completed within the Recovery Act grant period or available for  monitoring the Recovery Act expansion grantees.
section_title: OHS Has Prepared for On- Site Reviews but Has Not Incorporated Some Risk Indicators
paragraphs: In coordination with the contractor, OHS plans to complete on-site visits  by April 30, 2011, or by the end of grantees’ first year of operation,  whichever comes first. The Head Start Act requires that HHS conduct “a  review of each newly designated Head Start agency immediately after the  completion of the first year such an agency carries out a Head Start  program.” OHS considers the end of the grantees’ first year of operation  to be the end of 1 year of serving children and families. Recovery Act  monitoring visits will be in addition to regularly scheduled monitoring  visits, as shown in figure 8. OHS starts each monitoring season at the  beginning of the fiscal year, which is in October of each year. OHS visited  63 Recovery Act Early Head Start expansion grantees by October 31, 2010,  although it had planned to visit 67 by that date.
HHS’s Office of Inspector General (OIG) identified some financial  management risks among grantees, including a few that received Recovery  Act expansion grants. Among 24 grantees that OHS identified as high risk  that were reviewed by the OIG, five received Recovery Act expansion  funds in fall 2010 (three for Early Head Start, one for both Early Head Start  and Head Start and one for Head Start). According to OHS officials, the  OHS central and regional offices identified high risk grantees in their  regions and referred them to the OIG for review. The OIG began to audit  the grantees in July and August 2009. OHS later awarded five of the 24  grantees Recovery Act funding to expand their Early Head Start or Head  Start programs. OHS stated that no expansion funds were awarded to  grantees that were identified for health and safety performance violations,  although at least one of the grantees that received an unfavorable health  and safety review from the OIG received an expansion grant. OHS  officials explained that in making funding decisions, OHS looked at the  grantees’ reviews and spoke with staff in the regional offices to determine  if the grantees should receive expansion grants. In conducting these  reviews, the OIG identified several financial management deficiencies  among four expansion grantees for which reports had been issued,  including: uncertainties about continued financial viability; non- competitive agreements that advantaged the grantee; overcharging the  Head Start program for administrative costs or charging it for unallowable  or unsupported costs; and a weak system and internal controls related to  accounting, personnel, procurement and property management. Two of  the five expansion grantees that received financial management reviews  from the OIG were on Danya’s Recovery Act schedule to receive a  monitoring visit this year.
OHS plans to scope and staff its 1-year reviews of Recovery Act grantees  primarily according to their prior experience with Head Start and Early  Head Start and whether the grantees have recently received a triennial  review. New Early Head Start grantees will receive a full monitoring visit  using the triennial monitoring review protocol. Recovery Act expansion  grantees that have already received a triennial monitoring visit in years  just prior to receiving their expansion funds will be given a more limited 1- year review of Recovery Act operations. The remainder of the expansion  grantees will receive the triennial review for which they are scheduled in  2011, as shown in table 5. The 213 grantees that received Head Start  expansion funds but no funding for Early Head Start expansion will  receive their usual triennial review if they are scheduled to be reviewed  this year; if they are not on this year’s triennial schedule, they will not be  reviewed this year.
Both the full 1-year monitoring review and the triennial review cover all  aspects of the Head Start Monitoring Protocol, while targeted reviews will  focus on Early Head Start and Recovery Act issues. For the 1-year reviews  of Recovery Act grantees, OHS added questions to the Monitoring Protocol  to enhance coverage of topics such as grantee governance and financial  management, staffing, training and technical assistance funding, and  education services. Other questions are directed at grantees implementing  new programs. For example, one new question asks reviewers, “Has the  grantee drawn down an appropriate amount of funds, given where it is in  the start-up process?” Targeted reviews for established grantees that have  recently received a triennial review will cover matters related to Recovery  Act spending and Early Head Start expansion. In these visits, reviewers do  not ask grantees about some requirements, like partnering with parents or  transportation services.
HHS and contractor officials have stated that all monitoring visits to new  grantees will be implemented as “surprise” visits in response to GAO  findings of fraudulent enrollment and attendance and enrollment  discrepancies among some Head Start grantees as reported in May 2010.  Typically, the OHS monitoring contractor notified grantees of their  scheduled review date 30 days prior to the visit. According to the  contractor, this date is chosen from among multiple weeks selected by  grantees.
To prepare for monitoring visits to first-year expansion grantees, Danya  gathered documentation and data on grantees and ensured support  systems were equipped to receive Recovery Act grantee data. Danya  gathered documentation and data on grantees to prepare for monitoring  visits, such as grantee start-up proposals and information entered into the  Head Start Enterprise System, a user-restricted Web-based database that  includes PIR data and results of monitoring meetings with grantees. Danya  has also adapted its data systems to track Recovery Act-funded grantee  review activities.
In addition, Danya recruited and trained reviewers to conduct visits to  expansion grantees. As of October 20, 2010, Danya had recruited over 270  new reviewers for the first-year monitoring visits to expansion grantees.  The contractor stated that it recruited reviewers with fiscal, health, and  early childhood development expertise. For the Early Head Start  expansion visits, Danya reported recruiting reviewers who have specific  expertise in infant and toddler development, expectant families, and infant  mental health. Danya trained reviewers by October 20, 2010, through both  in-person and self-certified Web-based training. In addition, Danya trained  both OHS officials and nonfederal reviewers who received extra training  by September 23, 2010, to serve as review team leaders. Team leaders will  organize and implement the review and oversee the preparation of  preliminary reports. Danya officials stated that they will also conduct  quarterly booster and follow-up training.
OHS pl to monitor SAC fnd throgh  1-month report, as well as quarterly  progrm progress report nd minte to  submitted to OHS. The OHS centrl  office has assted grntee y providing  rerce on ccessing mtching fnd,  reponding to individuaqution, hoting   weinr, working with the NtionGovernor Assocition, nd reminding  grntee of recipient reporting dedline.  In ddition, OHS pl to honnual  meeting for te to re quired  knowledge on SAC, rting in April 2011.  OHS offici ted tht they hope to  crete cohort of te working on imilr  inititive with their SAC fnding. Grntee  noted, in prticr, tht the OHS SAC  repreenttive was helpfnd reponive.
In addition to preparing for first-year visits to expansion grantees, OHS has  been conducting other one-time and ongoing monitoring activities, as  shown in table 6. These efforts include initial on-site visits and reviewing  grantee reports. Additionally, regional office staffers have been holding  risk management meetings with expansion grantees to identify challenges  and to monitor their progress. While it was OHS’s policy that all grantees  receive regular risk management meetings, we found that at one of the two  regional offices we contacted, risk management meetings were not  consistently implemented or documented. For example, a regional office  did not document whether or not any risk management meetings were  conducted for one grantee that did not plan to open a Recovery Act- funded facility to children and families until September 2011. As a result, it  is not clear that grantees in that region have been receiving the same level  of review as other grantees or that regional offices are consistently  implementing OHS’s policy or providing such information for  consideration in staffing review teams.
section_title: Oversight of Recipient Reporting Data Quality Continues for the Fifth Round of Reporting
paragraphs: To meet our mandate to comment on recipient reports, we have continued  monitoring recipient reported data, including data on jobs funded. This  time we focused our review on the Head Start data in addition to the  national data. Analyzing these data can help in improving the accuracy and  completeness of the Recovery.gov data and in planning analyses of  recipient reports. Overall, this round’s results were similar to those we  observed in previous rounds. While data quality is improving, some issues  remain. According to Recovery.gov as of October 30, 2010, recipients  reported on over 200,000 awards indicating that the Recovery Act funded  approximately 671,607 jobs during the quarter beginning July 1, 2010, and  ending September 30, 2010. This included over 2,400 prime reports  associated with Head Start grantees. As reported by the Recovery  Accountability and Transparency Board, job calculations are based on the  number of hours worked in a quarter and funded under the Recovery  Act—expressed in FTEs.
subsections: section_title: Analysis of Fifth Round Recipient Reporting Data Shows Data Quality Is Relatively Stable
paragraphs: Using the fifth reporting period data, we continued our monitoring of  errors or potential problems by repeating many of the analyses and edit  checks reported in our earlier reports. We reviewed 77,711 prime recipient  report records from Recovery.gov for this fifth round, an increase of 3,462  or about 4.6 percent from round four. For our analyses, in addition to the  fifth round of recipient report data, we also used the previous four rounds  of data as posted on Recovery.gov as of October 30, 2010.
In examining recipient reports, we looked for progress in addressing  several key limitations found in our prior reports. In prior rounds we have  reviewed data logic and consistency and reviewed unusual or atypical  data. Data logic and consistency provide information on whether the data  are believable, given program guidelines and objectives; unusual or  atypical data values indicate potential inaccuracies. As with previous  quarterly report rounds, these reviews included (1) the ability to link  reports for the same project across quarters and (2) concerns in the data  logic and consistency, such as reports marked final that show a significant  portion of the award amount not spent. We continued to see results similar  to those of past reviews. For example, we continued to find a small  number of reports for which there were potential linkage issues across  quarters. This may impact the ability to track project funding and FTEs  over quarters. We also continued to see a small number of reports marked  final for which there appeared to be some discrepancies, such as reports  marked final but for which project status was marked as less than 50  percent completed.
As part of our review of data logic and consistency, we found some  inconsistencies in the Head Start data’s agency review flag field that were  similar to inconsistencies we found in our previous reviews. Our analysis  suggests that this field may not correctly reflect the extent of the agency’s  review process. Prime recipient report records include a review flag on  whether or not the federal agency reviewed the record during the data  quality review time frames. As we have noted in past reports, our analyses  of this agency review field, in conjunction with other fields and our  discussions with agency officials, have indicated potential problems and  inconsistencies. It appears that this continues to be the case with Head  Start reports, only 17 percent of which were marked as having been  reviewed by the agency. However, agency officials stated that all reports  were reviewed. Another data field on the recipient report shows whether  or not a correction was initiated; analysis of that field indicates it is likely  that additional agency reviews took place. A correction could be initiated  by either the prime recipient or the reviewing agency. Thirty percent of the  reports had the correction flag set to ‘yes’ even though the review flags  suggested that neither the agency nor prime recipient had reviewed those  reports. Officials noted that they continued to experience difficulties in  marking reports as reviewed. Agency officials indicated that they would  continue to update these flags during the continuous review process.
As part of our additional analysis, we found that a previously identified  concern with FTE calculations for Head Start reports is being addressed.  Agency officials stated that following the December 2009 Office of  Management and Budget (OMB) memorandum clarifying the FTE  definition, all grants associated with COLA/QI were reviewed with respect  to the reporting of FTEs. Agency officials reviewed these grants and  communicated to recipients that the cost-of-living increases were not to  count toward the FTE totals. We reviewed the FTEs reported to determine  if Head Start recipients were no longer reporting cost-of-living increases as  FTEs. In examining the impact on the FTE figures before and after this  clarification guidance was issued, we observed a significant drop in the  number of COLA/QI FTEs reported in all reporting periods following the  updated guidance. We further observed that for the fifth round of  reporting, over 60 percent of these COLA/QI recipient reports showed no  FTE value. For the remaining reports showing FTEs, we looked to see if,  in the 20 reports with the greatest number of FTEs, the fields describing  the award, project, and job creation explained their FTE counts. In almost  all cases, one of these narrative fields accounted for activities that would  be expected to produce FTEs—hiring staff, expanding existing staff hours,  or hiring other types of workers to improve facilities, in accordance with  Head Start quality improvement guidance. Agency officials noted that they  continue to monitor these grants to ensure that cost-of-living increases are  not being reported among the FTEs.
section_title: Head Start Agency Review of Recipient Data Included Updated OMB Guidance Requirements
paragraphs: OMB’s guidance requires federal agencies to work with their recipients to  ensure that the data they report are comprehensive and accurate. The  agencies must make limited reviews of recipients’ data to identify material  omissions and significant reporting errors and to notify the recipients of  any need to make appropriate and timely changes. However, as OMB  stated in its guidance, the federal agencies’ comments and suggestions for  report changes do not preclude the prime recipients’ ultimate  responsibility for the data they report.
On September 24, 2010, OMB issued updated guidance to federal agencies  and recipients that included guidance on, among other topics, improving  the transparency of narrative descriptions in recipient reporting. In  particular, this memorandum stated that unclear or overly general award  descriptions constitute material omissions. Further, the memorandum  described standards of completeness for the “Award Description” and  “Quarterly Activities/Project Description for Prime and Sub-recipients”  fields. OMB noted that these two fields together must provide, at  minimum, clear and complete information on the award’s purpose, scope  and nature of activities, outcomes, and status of activities. Per the  memorandum, federal agencies are to direct recipients to update or  correct these fields in instances in which incomplete award descriptions  would mislead the public or fail to provide sufficient information to  discern the award’s purpose and activities.
In response to this memorandum, HHS issued guidance to ACF and its  operating divisions on reviewing these data fields as it reviews recipient  reports. HHS provides broad guidance on the types of data quality reviews  its operating divisions should perform, and ACF works with OHS to review  Head Start recipients’ reports. This review used a series of reports that  contain data from FederalReporting.gov and the ACF grants management  systems to identify potential issues with data submitted by recipients.  This process entails automated data reviews that cover all reports  submitted, generating a list of reports from which ACF programs can  target their review of recipient reported data. The automated reviews  include, for example, award number matching and reviews of  expenditures, project status, and reported FTEs.
In response to the new HHS guidance, ACF and OHS have incorporated  these additional reviews into their procedures. Agency officials informed  recipients of the enhanced requirements for updating award and project  descriptions. Further, when officials reviewed records in early October in  which recipients had brief descriptions in the data fields, they found that  about 600 Head Start recipients potentially needed updating. In early  November, agency officials stated that this review had led to more than  450 of the 600 recipients updating their records. Agency officials noted  that many of the recipients had used the “copy forward” feature for several  rounds but had not updated these two fields in recent rounds. The officials  stated that they will update or modify their review process as further  guidance is released.
section_title: Conclusions
paragraphs: The Recovery Act expansion grants made it possible for some 60,000  additional children and families, particularly those with low incomes, to  receive up to 2 years of Head Start and Early Head Start services that will  help ensure school readiness. The expansion grants also created or  retained a number of jobs during the country’s economic slowdown. Still,  even as the Recovery Act directed an infusion of funds into the economy,  it also increased the importance of accountability for their use. In light of  the Recovery Act’s pledge of unprecedented transparency and  accountability for federal grants, the ability of OHS to measure the results  of expanded Head Start funding is critical. While grantee recipient  reporting figures indicate that staffing levels have increased with Recovery  Act funds, data on the number of children and families enrolled in Head  Start and Early Head Start are less clear. OHS’s plan to require that  reviewers compare attendance with enrollment reports offers some  clarification, but until OHS clearly communicates a consistent definition  for “enrollment,” the cumulative enrollment reports will continue to mean  different things for different grantees. Without better measures of  enrollment or service delivery, it will remain difficult for OHS to assess  whether its actions are extending Head Start and Early Head Start to as  many eligible children and families as possible.
The rapid addition of funds to Head Start and Early Head Start increased  the potential significance of efforts to reduce risks of misuse or abuse of  funds and enhance the effectiveness of sponsored programs and projects.  The fact that Early Head Start grants arrived later than expected—further  accelerating expenditures—increased the risk of ineffective choices on the  part of grantees. The absence of clearly communicated guidance on  whether they could carry funds from one year to the next and the lack of  consistent monitoring of their spending plans likely left grantees feeling  pressured to spend funds on near-term priorities in the belief that  application to longer-term but potentially more important issues would not  be possible. As a result, some children may have received significantly  different levels or a lesser quality of service than their program managers  might have otherwise planned or provided. Unless this confusion is  remedied, OHS may miss opportunities to foster the best outcomes with  Recovery Act expansion funds.
Without consistently sharing the results of risk management meetings,  risks are more likely to be overlooked and a central OHS strategy for  managing risk—including risks in management of new funds—does not  achieve its full potential. In addition, failure to incorporate known  information regarding financial management and other risks in planning  Recovery Act reviews may make these reviews less effective in holding  grantees accountable for the funds received and ascertaining their  progress in addressing known problems.
section_title: Recommendations for Executive Action
paragraphs: We recommend that the Director of the Office of Head Start take the  following three actions:    To help ensure that grantees report consistent enrollment figures, better  communicate a consistent definition of “enrollment” to grantees for  monthly and yearly reporting and begin verifying grantees’ definition of  “enrollment” during triennial reviews.
To provide grantees consistent information on how and when they will be  expected to obligate and expend federal funds, clearly communicate its  policy to grantees for carrying over or extending the use of Recovery Act  funds from one fiscal year into the next.
To better consider known risks in scoping and staffing required reviews of  Recovery Act grantees, direct OHS regional offices to consistently perform  and document Risk Management Meetings and incorporate known risks,  including financial management risks, into the process for staffing and  conducting reviews.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of the report to the Department of Health and Human  Services and the Office of Management and Budget for review and  comment. OMB did not provide comments. HHS’s comments are  reproduced in appendix II. HHS agreed with GAO's recommendations and  provided additional detail on steps it had initiated or planned to  implement. With respect to our recommendation that OHS direct regional  offices to consistently perform and document Risk Management Meetings,  HHS reports it is reviewing the Risk Management Meeting process to  ensure it is consistently performed and documented in its centralized data  system and that it has taken related steps, such as requiring the Grant  Officer to identify known or suspected risks prior to an on-site review.  HHS also indicates that it will issue explicit guidance on enrollment  terminology for grantees and monitoring teams, as well as provide  guidance and make other efforts to effectively communicate the  mechanisms in place for grantees to meet the requirements for obligation  and expenditure of funds. In addition, in connection with our observation  regarding OHS managers’ access to aggregated drawdown data, HHS  commented that it is pursuing plans to obtain monthly reports of this  nature for OHS and regional program managers. HHS also provided  technical comments, which we incorporated as appropriate.
We are sending copies of this report to the Secretary of Health and Human  Services, the Director of the Office of Management and Budget,  appropriate congressional committees, and other interested parties. The  report is also available at no charge on the GAO Web site at  http://www.gao.gov.
If you or your staffs have any questions about this report, please contact  Cornelia Ashby at (202) 512-7215 or ashbyc@gao.gov or Yvonne Jones at  (202) 512-6878 or jonesy@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: We took a number of steps to address our objectives, which were to  determine (1) how Head Start and Early Head Start grantees have used  American Recovery and Reinvestment Act of 2009 (Recovery Act) funds,  including expanding enrollment; (2) what challenges grantees have  encountered in spending Recovery Act funds; (3) how the Office of Head  Start (OHS) has monitored the use of Recovery Act funds; and (4) how the  quality of jobs data reported by Recovery Act recipients, particularly Head  Start grantees, has changed over time.
To determine how Head Start and Early Head Start grantees have used  Recovery Act funds to expand enrollment, we reviewed relevant federal  laws and regulations, met with agency officials, visited and spoke with  Head Start and Early Head Start grantees, and analyzed OHS-provided data  on awards, expenditures, programs, and enrollment. We conducted follow- up interviews with nine grantees that we visited previously in nine  localities in four states for a previous report on the Recovery Act. For  these interviews, we used an interview protocol that focused on progress  made in providing services, spending Recovery Act funds, plans for  carryover, and reporting on Recovery.gov. Additionally, we spoke with  seven grantees in seven other states that we identified by analyzing  Department of Health and Human Services’ (HHS) expenditure data to  identify grantees with drawdown rates below 5 percent as of July 16, 2010.  For these interviews, we used an interview protocol that addressed use of  Recovery Act funds, reasons for low spending rates, carryover guidance,  and regional office interaction. Table 7 lists the characteristics of grantees  that we spoke to, as well as the type of interview they received. None of  the grantees we interviewed were among the small portion new to the  Head Start program; however, eight of them were implementing Early  Head Start for the first time.
Interviews and site visits with grantees supplemented information  gathered from seven GAO focus groups with expansion grantees, on which  we reported in May 2010. Sixty-one individuals participated in focus  groups, representing a variety of programs, including existing Head Start  and Early Head Start grantees and grantees entirely new to the Head Start  and Early Head Start programs. For most focus groups, we recruited  participants from those attending Head Start-related conferences. The  focus groups discussed challenges faced in implementing their expansion  grants, among other topics. Despite the representation across types of  grantees and operating regions, information from site visits and the results  of interviews and focus groups are not generalizable to all expansion  grantees under the Recovery Act.
To describe how State Advisory Council grantees were planning to expend  their funds, we interviewed state officials in six states: three states that  received grants and three states that chose not to apply for these funds.
Additionally, we analyzed several databases used by OHS to understand  grantees’ characteristics and the features of the grant awards. We assessed  data reliability for all computer-processed data we used, including  reviewing documentation of processes supporting the databases,  conducting logic tests for key variables, and assessing data for out-of- range values.
We analyzed OHS-provided Financial Assistance Award data from the  Grants Administration Tracking and Evaluation System database to  determine total funds awarded by year, distribution of grantees’ awards  across budget categories, and how many children and families each  grantee was funded to serve.
We used HHS-provided grantee expenditure data taken from the Payment  Management System (PMS) to determine progress in Head Start and Early  Head Start grantees’ Recovery Act total drawdowns, as well as to identify  grantees with low drawdown rates for further GAO follow-up. OHS  officials cautioned us that PMS rates of expenditure are conservative, as  grantees occasionally spend their own funds on Head Start programming  and are reimbursed later through the PMS system.
We analyzed 2 years of Program Information Report (PIR) data on  enrollment, staffing levels, and other variables. The PIR is administered  through the Head Start Enterprise System, a user-restricted, Web-based  database. PIR is an annual survey administered to all Head Start and Early  Head Start grantees. We performed logic checks on all variables used in  the report. We also analyzed previous GAO reports and an external report  that found that some PIR variables were unreliable. None of these reports  used 2009 or 2010 data. We tested these variables for 2009 and 2010 and  found them to be sufficiently reliable for our purposes of reporting  aggregated figures.
We analyzed all end-of-month enrollment data for Recovery Act grantees.  Like the PIR, the end-of-month data collection instrument is administered  through the Head Start Enterprise System. OHS populates the funded  enrollment variable, and grantees are required to submit reported  enrollment each month, including an explanation for enrollment that falls  below a grantee’s funded enrollment. We did not validate individual  grantees’ enrollment reports by comparing them to actual enrollment  records. We found instances in which grantees’ funded enrollment was  attributed incorrectly or in which grantees’ total funded enrollment was  incorrect. These issues represented an error rate of less than 1 percent of  total funded enrollment. Although we have continuing concerns about  quality controls for the monthly enrollment data, we determined that data  used for our report are sufficiently reliable for our purposes of reporting  total reported and funded enrollment for all grantees.
To describe challenges grantees have encountered in spending their  Recovery Act funds, we reviewed relevant federal laws and regulations  and met with agency officials from both the OHS central offices and  regional offices. In addition, we analyzed drawdown data from HHS’s PMS  system. As described above, we also interviewed seven Early Head Start  grantees in seven states that we identified using PMS data. Among all  grantees with drawdown rates below 5 percent as of July 16, 2010, we  randomly selected seven grantees to contact. We used a standard protocol  to ask these grantees’ officials about how they have been using funds, their  challenges in spending funds, and why their drawdown rates were so low  at such a late time in the year.
To assess how OHS has monitored Recovery Act funds, we reviewed  relevant federal laws and regulations, interviewed agency officials,  analyzed contracts and contractor invoices, and reviewed other agency  documentation such as monitoring protocols. We met with the OHS  contracting officer and the OHS contractor to discuss the award process  and monitoring support. We also met with officials from the HHS Office of  the Inspector General to better understand their role in the expansion  grant-making process and in monitoring grantees.
The recipient reporting section of this report responds to the Recovery  Act’s mandate that we comment on the estimates of jobs created or  retained by direct recipients of Recovery Act funds. For our review of the  fifth submission of recipient reports, covering the period from July 1, 2010,  through September 30, 2010, we built on findings from our four prior  reviews of the reports, covering the period from February 2009 through  June 30, 2010. We performed edit checks and basic analyses on the fifth  submission of recipient report data that became publicly available at  Recovery.gov on October 30, 2010. To understand how the quality of jobs  data reported by Recovery Act recipients, particularly Head Start grantees,  has changed over time, we compared the five quarters of recipient  reporting data that were publicly available at Recovery.gov on October 30,  2010. We performed edit checks and other analyses on the Head Start  subset of recipient reports, which included matching OHS-provided data  (Financial Assistance Awards from the Grants Administration Tracking  and Evaluation System database) and HHS-provided data (grantee  expenditures from PMS) on grantees with recipient reports. We also  reviewed documentation and interviewed federal agency officials from  HHS, who have responsibility for ensuring a reasonable degree of quality  across their programs’ recipient reports. Due to the limited number of  recipients reviewed and the judgmental nature of the selection, GAO’s full- time equivalent findings are limited to those Head Start programs and time  periods examined and are not generalizable to any other program’s FTE  reporting..
To update the status of open recommendations from previous bimonthly  and recipient reporting reviews, we obtained information from agency  officials on actions taken in response to the recommendations.
We conducted this performance audit from August 2010 to December 2010  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 that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
section_title: Appendix II: Comments from the Department of Health and Human Services
section_title: Appendix III: Status of Prior Open Recommendations and Matters for Congressional Consideration
paragraphs: In this appendix, we update the status of agencies’ efforts to implement  the 28 open recommendations, 1 newly implemented recommendation,  and 1 newly closed recommendation from our previous bimonthly and  recipient reporting reviews. Agency responses to our new  recommendations are included in the program section of this report.  Recommendations that were listed as implemented or closed in a prior  report are not repeated here. Lastly, we address the status of our Matters  for Congressional Consideration.
subsections: section_title: Department of Energy
subsections: section_title: Open Recommendations
paragraphs: Given the concerns we have raised about whether program requirements  were being met, we recommend that the Department of Energy (DOE), in  conjunction with both state and local weatherization agencies, develop  and clarify weatherization program guidance that    establishes best practices for how income eligibility should be determined  and documented and issues specific guidance that does not allow the self- certification of income by applicants to be the sole method of  documenting income eligibility.    clarifies the specific methodology for calculating the average cost per  home weatherized to ensure that the maximum average cost limit is  applied as intended.    accelerates current DOE efforts to develop national standards for  weatherization training, certification, and accreditation, which is currently  expected to take 2 years to complete.    develops a best practice guide for key internal controls that should be  present at the local weatherization agency level to ensure compliance with  key program requirements.    sets time frames for development and implementation of state monitoring  programs.  revisits the various methodologies used in determining the weatherization  work that should be performed based on the consideration of cost- effectiveness and develops standard methodologies that ensure that  priority is given to the most cost-effective weatherization work. To  validate any methodologies created, this effort should include the  development of standards for accurately measuring the long-term energy  savings resulting from weatherization work conducted.    considers and addresses how the weatherization program guidance is  impacted by the introduction of increased amounts of multifamily units.
In addition, given that state and local agencies have felt pressure to meet a  large increase in production targets while effectively meeting program  requirements and have experienced some confusion over production  targets, funding obligations, and associated consequences for not meeting  production and funding goals, we recommended that DOE clarify its  production targets, funding deadlines, and associated consequences while  providing a balanced emphasis on the importance of meeting program  requirements.
DOE generally concurred with all of the recommendations. DOE provided  updates for each individual recommendation explaining what it has done  thus far and what it will do to satisfy the recommendations. For example,  for the first recommendation listed above—that DOE should establish best  practices for how income eligibility should be determined and not allow  the self-certification of income by applicants to be the sole method of  documenting income eligibility—DOE explained that it is revising a  Program Notice to strengthen these provisions. DOE reminded grantees  and subgrantees that proof of eligibility should be clearly documented, and  that self-certification should only be relied upon when all other methods  for documenting income eligibility have been exhausted. Evidence of all  other attempts to prove eligibility must be included in the client file.
section_title: Environmental Protection Agency
subsections: section_title: Open Recommendation
paragraphs: We recommend that the Environmental Protection Agency (EPA)  Administrator work with the states to implement specific oversight  procedures to monitor and ensure subrecipients’ compliance with the  provisions of the Recovery Act-funded Clean Water and Drinking Water  State Revolving Fund (SRF) program.
In response to our recommendation, EPA provided additional guidance to  the states regarding their oversight responsibilities, with an emphasis on  enhancing site specific monitoring and inspections. Specifically, in June  2010, the agency developed and issued an oversight plan outline for  Recovery Act projects that provides guidance on the frequency, content,  and documentation related to regional reviews of state Recovery Act  programs and regional and state reviews of specific Recovery Act projects.  For example, EPA’s guidance states that regions and states should be  reviewing the items included on the EPA “State ARRA Inspection  Checklist” or use a state equivalent that covers the same topics. The plan  also describes EPA headquarters role in ongoing Recovery Act oversight  and plans for additional webcasts. EPA also reiterated that contractors are  available to provide training and to assist with file reviews and site  inspections. We are undertaking further review of the states’ use of  Recovery Act funds for the Clean and Drinking Water programs. As part of  that work, we will consider EPA’s and the states’ oversight of Recovery  Act funds and, more specifically, progress in implementing EPA’s  guidance.
section_title: Department of Health and Human Services: Office of Head Start
subsections: section_title: Open Recommendation
paragraphs: To facilitate understanding of whether regional decisions regarding  waivers of the program’s matching requirement are consistent with  Recovery Act grantees’ needs across regions, the Director of OHS should  regularly review waivers of the nonfederal matching requirement and  associated justifications.
OHS has not conducted a review of waivers of the nonfederal matching  requirement, but OHS officials stated that the variation is largely due to  differences in regions’ policy in timing: some regional offices grant waivers  at the same time that the grant is made official, whereas other regions  grant waivers later. OHS officials stated that although the OHS central  office has not regularly reviewed grantees’ justifications for waiver  applications for regional variability in the past, they are looking into  tracking this data in their web-based system consistently across regions.  The process of tracking waivers is not yet complete.
section_title: Open Recommendation
paragraphs: To oversee the extent to which grantees are meeting the program goal of  providing services to children and families and to better track the  initiation of services under the Recovery Act, the Director of OHS should  collect data on the extent to which children and pregnant women actually  receive services from Head Start and Early Head Start grantees.
HHS disagreed with our recommendation. OHS officials stated that  attendance data are adequately examined in triennial or yearly on-site  reviews and in periodic risk management meetings. Because these reviews  and meetings do not collect or report data on service provision, we  continue to believe that tracking services to children and families is an  important measure of the work undertaken by Head Start and Early Head  Start service providers.
section_title: Newly Implemented Recommendation
paragraphs: To provide grantees with appropriate guidelines on their use of Head Start  and Early Head Start grant funds, and enable OHS to monitor the use of  these funds, the Director of OHS should direct regional office staff to stop  allocating all grant funds to the “other” budget category, and immediately  revise all financial assistance awards (FAA) in which all funds were  allocated to the “other” category.
Since our May report, OHS revised all FAAs that had designated all of a  grantee’s awarded funds to the “other” budget category rather than more  specific budget categories, such as “supplies” or “equipment.” Further,  OHS did not issue any FAAs that designated all funds to “other.”
section_title: Department of Housing and Urban Development
subsections: section_title: Open Recommendation
paragraphs: Because the absence of third-party investors reduces the amount of overall  scrutiny Tax Credit Assistance Program (TCAP) projects would receive  and the Department of Housing and Urban Development (HUD) is  currently not aware of how many projects lacked third-party investors,  HUD should develop a risk-based plan for its role in overseeing TCAP  projects that recognizes the level of oversight provided by others.
HUD responded to our recommendation by saying it will identify projects  that are not funded by the HOME Investment Partnerships Program  (HOME) funds and projects that have a nominal tax credit award. HUD  said it will make these identifications after projects are complete and  develop a monitoring plan tailored to these projects. HUD currently has  not taken any action on this recommendation because it is too early in the  process to be able to identify projects that lack third-party investors. The  agency will take action once they able to collect the necessary information  from the project owners and the state housing finance agencies.
section_title: Department of Labor
subsections: section_title: Open Recommendations
paragraphs: To enhance the Department of Labor’s (Labor) ability to manage its  Recovery Act and regular Workforce Investment Act (WIA) formula grants  and to build on its efforts to improve the accuracy and consistency of  financial reporting, we recommend that the Secretary of Labor take the  following actions:    To determine the extent and nature of reporting inconsistencies across the  states and better target technical assistance, conduct a one-time  assessment of financial reports that examines whether each state’s  reported data on obligations meet Labor’s requirements.
To enhance state accountability and to facilitate their progress in making  reporting improvements, routinely review states’ reporting on obligations  during regular state comprehensive reviews.
Labor agreed with both of our recommendations and has begun to take  some actions to implement them. To determine the extent of reporting  inconsistencies, Labor awarded a contract in September 2010 to perform  an assessment of state financial reports to determine if the data reported  are accurate and reflect Labor’s guidance on reporting of obligations and  expenditures. Labor plans to begin interviewing states in mid-December  and will issue a report after the interviews are completed and analyzed. To  enhance states’ accountability and facilitate their progress in making  improvements in reporting, Labor has drafted guidance on the definitions  of key financial terms such as obligations and expects to issue this  guidance in December 2010. After the guidance is issued, Labor plans to  conduct a system wide webinar on this topic.
section_title: Open Recommendations
paragraphs: Our September 2009 bimonthly report identified a need for additional  federal guidance in two areas—measuring the work readiness of youth  and defining green jobs—and we made the following two  recommendations to the Secretary of Labor:    To enhance the usefulness of data on work readiness outcomes, provide  additional guidance on how to measure work readiness of youth, with a  goal of improving the comparability and rigor of the measure.
To better support state and local efforts to provide youth with  employment and training in green jobs, provide additional guidance about  the nature of these jobs and the strategies that could be used to prepare  youth for careers in green industries.
Labor agreed with both of our recommendations and has begun to take  some actions to implement them. With regard to the work readiness  measure for WIA Youth summer employment activities, Labor issued  guidance on May 13, 2010 for the WIA Youth Program that builds on the  experiences and lessons learned during implementation of Recovery Act- funded youth activities in 2009. In this guidance, Labor broadly identified  some additional requirements for measuring work readiness of youth.  Further guidance was provided on August 19, 2010, that described the  methodology for implementing the work readiness indicator and provided  an optional work readiness tool for the WIA Youth Program. The guidance  clarifies the Employment and Training Administration’s (ETA) changes to  the definition of work readiness, now basing it on the employer’s worksite  evaluation and making this evaluation the required means to measure  work readiness.
Regarding our recommendation on the green jobs, Labor told us that the  Bureau of Labor Statistics (BLS) has developed a definition of green jobs.  The definition was developed through a review of a wide range of studies,  including several surveys conducted by state workforce agencies and  work conducted internationally. BLS also consulted with a variety of  stakeholders, including federal agencies, state labor market information  offices, and industry (business and labor) groups. BLS published its  proposed definition in the March 16, 2010, Federal Register and solicited  comments. The final definition was published in the Federal Register on  September 21, 2010. In addition, Labor is hosting a Green Jobs Community  of Practice, an online virtual community available to all grantees of the  Recovery Act-funded green jobs training grants, as well as members of the  workforce system and the general public. This will serve as Labor’s  primary venue for sharing information and updates on trends and  practices in green jobs training. The Department has also begun an  implementation study of these green jobs training grants to capture best  practices and lessons learned. Study results will be made available through  a Training and Employment Guidance Letter by summer 2011.
section_title: Executive Office of the President: Office of Management and Budget
subsections: section_title: Open Recommendation
paragraphs: To leverage Single Audits as an effective oversight tool for Recovery Act  programs, we recommended that the Director of the Office of Management  and Budget (OMB)  1. provide more direct focus on Recovery Act programs through the  Single Audit to help ensure that smaller programs with higher risk  have audit coverage in the area of internal controls and compliance;  2. take additional efforts to provide more timely reporting on internal  controls for Recovery Act programs for 2010 and beyond;  3. evaluate options for providing relief related to audit requirements for  low-risk programs to balance new audit responsibilities associated  with the Recovery Act;  4. issue Single Audit guidance in a timely manner so that auditors can  efficiently plan their audit work;  5. issue the OMB Circular No. A-133 Compliance Supplement no later  than March 31 of each year;  6. explore alternatives to help ensure that federal awarding agencies  provide their management decisions on the corrective action plans in  a timely manner; and  7. shorten the time frames required for issuing management decisions  by federal agencies to grant recipients.  1.  To provide more direct focus on Recovery Act programs to help  ensure that smaller programs with higher risk have audit coverage in  the area of internal controls and compliance through the Single Audit,  OMB updated its Single Audit guidance in the OMB Circular A-133,  Audits of States, Local Government, and Non-Profit Organizations  Compliance Supplement in July 2010. This compliance supplement  requires auditors to consider all federal programs with expenditures  of Recovery Act awards to be considered programs with higher risks  when performing standard risk-based tests to select programs to be  audited. The compliance supplement also clarified information to  assist auditors in determining the appropriate risk levels for programs  with Recovery Act expenditures. This is the second year that OMB  has included guidance in the compliance supplement to address some  of the higher risks inherent in Recovery Act programs. The most  significant of these risks are associated with new programs that may  not have the internal controls and accounting systems in place to help  ensure that funds are distributed and used in accordance with  program regulations and objectives. OMB and the federal cognizant  agency for audit have conducted several training and outreach  activities for the audit community regarding the importance of the  new audit requirements for Recovery Act programs.
Since most of the funding for Recovery Act programs will be  expended in 2010 and beyond, we continue to believe that it is  essential that OMB provide direction in Single Audit guidance so that  some smaller programs with higher risk would not be automatically  excluded from receiving audit coverage based upon the requirements  in the Single Audit Act. In recent discussions with OMB officials, we  communicated our concern that future Single Audit guidance provide  instruction that helps to ensure that smaller programs with higher  risk have audit coverage in the area of internal controls and  compliance. OMB officials agreed and stated that they plan to  continue including similar language in the Compliance Supplement  and performing outreach trainings throughout the duration of the  Recovery Act.  2.  To address the recommendation for taking additional efforts to  encourage more timely reporting on internal controls for Recovery  Act programs for 2010 and beyond, OMB commenced a second  voluntary Single Audit Internal Control Project (project) in August  2010 for states that received Recovery Act funds in fiscal year 2010.  Similar to the prior project (which did not get started until October  2009), one of the project’s goals is to achieve more timely  communication of internal control deficiencies for higher-risk  Recovery Act programs so that corrective action can be taken more  quickly. Specifically, the project encourages participating auditors of  states that received Recovery Act funds to identify and communicate  deficiencies in internal control to management 3 months sooner than  the 9-month time frame currently required under OMB Circular No. A- 133. The project also requires that management provide, 2 months  earlier than required under statute, plans for correcting internal  control deficiencies to the cognizant agency for audit for immediate  distribution to the appropriate federal agencies. The federal agency  is then to have provided its concerns relating to management’s plan  of corrective actions in a written decision as promptly as possible and  no later than 90 days after the corrective action plan is received by  the cognizant agency for audit. According to OMB officials, 13 states  had volunteered to participate in the project as of November 15, 2010.  Each participating state is to select a minimum of four Recovery Act  programs for inclusion in the project and at the completion of the  2010 project, OMB plans to assess the project’s results.
We assessed the results of the first OMB Single Audit Internal Control  Project for fiscal year 2009 and found that it was helpful in  communicating internal control deficiencies earlier than required  under statute. We reported that 16 states participated in the first  project and that the states selected at least two Recovery programs  for the project. We also reported that the project’s dependence on  voluntary participation limited its scope and coverage and that  voluntary participation may also bias the project’s results by  excluding from analysis states or auditors with practices that cannot  accommodate the project’s requirement for early reporting of control  deficiencies. Overall, we concluded that although the project’s  coverage could have been more comprehensive, the analysis of the  project’s results provided meaningful information to OMB for better  oversight of the Recovery Act programs selected and information for  making future improvements to the Single Audit guidance. We believe  that OMB needs to continue taking steps to encourage timelier  reporting on internal controls through Single Audits for Recovery Act  programs.  3.  OMB officials have stated that they are aware of the increase in  workload for state auditors who perform Single Audits due to the  additional funding to Recovery Act program and corresponding  increase in programs being subject to audit requirements. OMB  officials stated that they solicited suggestions from state auditors to  gain further insights to develop measures for providing audit relief.  However, OMB has not yet identified viable alternatives that would  provide relief to all state auditors. For state auditors that are  participating in the second OMB Single Audit Internal Control  project, OMB has provided some audit relief. Specifically, OMB  modified the requirements under Circular No. A-133 to reduce the  number of low-risk programs that must be included in some project  participants’ assessment requirements for smaller programs for  Single Audits for fiscal years 2010 and 2011. As expenditures of  Recovery Act funds are expected to continue through 2016, it is  important that OMB look for opportunities and implement various  options for providing audit relief in future years.  4, 5.  With regard to issuing Single Audit Guidance in a timely manner, and  specifically the OMB Circular A-133 Compliance Supplement, OMB  officials have stated that they intend to issue the fiscal year 2011  compliance supplement by March 31, 2011. The team of federal  officials who assisted in the development of the OMB Circular A-133  Compliance Supplement met in August 2010—a few weeks earlier  than in prior years—for its annual kick off meeting. At that meeting,  the team set a goal of issuing the 2011 compliance supplement by  March 31, 2011, and discussed revised production schedules and  deadlines needed to accommodate the earlier issuance date. We will  continue to monitor OMB’s progress to achieve this objective.
6, 7.
In October 2010, OMB officials stated that they have discussed  alternatives for helping to ensure that federal awarding agencies  provide their management decisions on the corrective action plans in  a timely manner, including possibly shortening the time frames  required for issuing management decisions by federal agencies to  grant recipients. However, OMB officials have yet to decide on the  course of action that they will pursue to implement our related  recommendations. OMB officials acknowledged that the results of the  2009 OMB Single Audit Internal Control Project confirmed that this  issue continues to be a challenge. They stated that they have met  individually with several federal awarding agencies that were late in  providing their management decisions in the 2009 project to discuss  the measures that the agencies will take to improve the timeliness of  their management decisions.
In March 2010, OMB issued guidance under memo M-10-14, item 7,  (http://www.whitehouse.gov/sites/default/files/omb/assets/memoranda_20 10/m10-14.pdf) that called for federal awarding agencies to review reports  prepared by the Federal Audit Clearinghouse regarding Single Audit  findings and submit summaries of the highest-risk audit findings by major  Recovery Act programs by September 30, 2010, as well as other relevant  information on the federal awarding agency’s actions regarding these  areas. OMB officials have stated that they plan to use this information to  identify trends that may require clarification or additional guidance in the  compliance supplement. OMB officials also stated that they are working  with the Recovery Act Accountability and Transparency Board to develop  metrics for determining how federal awarding agencies are to use  information available in the Single Audit. As of November 2010, according  to OMB officials, the project is in the planning phase and the specific  metrics are still being considered. OMB anticipates that the metrics may  be available in January 2011 and that the metrics could be applied at the  agency level, by program, to allow for analysis of Single Audit findings and  other measures to be determined. One goal of the metrics project is to  increase the effectiveness and timeliness of federal awarding agencies’  actions to resolve Single Audit findings. We will monitor the progress of  these efforts to determine the extent that it improves the timeliness of  federal agencies’ actions to resolve audit findings so that risks to Recovery  Act funds are reduced and internal controls in Recovery Act programs are  strengthened.
section_title: Newly Closed Recommendation
paragraphs: Because performance reporting is broader than the jobs reporting required  by section 1512, the Director of OMB should also work with federal  agencies—perhaps through the Senior Management Councils—to clarify  what new or existing program performance measures—in addition to jobs  created and retained—that recipients should collect and report in order to  demonstrate the impact of Recovery Act funding.
It was an objective of the Recovery Act to use existing measures to allow  the public to see the performance impact of the Act’s investments. Some  federal agencies have issued or plan to issue additional guidance on what  other programs or impact measures are required for evaluating the impact  of Recovery Act funding. Some state program officials said that they use  existing program performance measures developed by federal agencies to  track the performance impact of Recovery Act funding, while other states  have developed their own measures. With the passage of time, we have  concluded that the intent of this recommendation is being addressed by  individual federal agencies, as well as being addressed by local program  officials.
section_title: Department of Transportation
subsections: section_title: Open Recommendations
paragraphs: To ensure that Congress and the public have accurate information on the  extent to which the goals of the Recovery Act are being met, we  recommend that the Secretary of Transportation direct the Federal  Highway Administration (FHWA) to take the following two actions:    Develop additional rules and data checks in the Recovery Act Data  System, so that these data will accurately identify contract milestones  such as award dates and amounts, and provide guidance to states to revise  existing contract data.
Make publicly available—within 60 days after the September 30, 2010,  obligation deadline—an accurate accounting and analysis of the extent to  which states directed funds to economically distressed areas, including  corrections to the data initially provided to Congress in December 2009.
As of the time of this report, the Department of Transportation (DOT) was  in the process of developing its plans in response to these  recommendations.
section_title: Open Recommendation
paragraphs: To better understand the impact of Recovery Act investments in  transportation, we believe that the Secretary of Transportation should  ensure that the results of these projects are assessed and a determination  made about whether these investments produced long-term benefits.  Specifically, in the near term, we recommend the Secretary direct FHWA  and the Federal Highway Administration (FTA) to determine the types of  data and performance measures they would need to assess the impact of  the Recovery Act and the specific authority they may need to collect data  and report on these measures.
In its response, DOT noted that it expected to be able to report on  Recovery Act outputs, such as the miles of road paved, bridges repaired,  and transit vehicles purchased, but not on outcomes, such as reductions in  travel time, nor did it commit to assessing whether transportation  investments produced long-term benefits. DOT further explained that  limitations in its data systems, coupled with the magnitude of Recovery  Act funds relative to overall annual federal investment in transportation,  would make assessing the benefits of Recovery Act funds difficult. DOT  indicated that, with these limitations in mind, it is examining its existing  data availability and, as necessary, would seek additional data collection  authority from Congress if it became apparent that such authority were  needed. DOT plans to take some steps to assess its data needs, but it has  not committed to assessing the long-term benefits of Recovery Act  investments in transportation infrastructure. We are therefore keeping our  recommendation on this matter open.
section_title: Open Recommendation
paragraphs: The Secretary of Transportation should gather timely information on the  progress they are making in meeting the maintenance-of-effort  requirement and to report preliminary information to Congress within 60  days of the certified period (September 30, 2010), (1) on whether states  met required program expenditures as outlined in their maintenance-of- effort certifications, (2) the reasons that states did not meet these certified  levels, if applicable, and (3) lessons learned from the process.
DOT concurred in part with our March 2010 recommendation that it gather  and report more timely information on the progress states are making in  meeting the maintenance-of-effort requirements. DOT officials stated that  DOT will encourage states to report preliminary data for the certified  period ending September 30, 2010, and deliver a preliminary report to  Congress within 60 days of the certified period. On October 1, 2010, DOT  officials requested that each state update its actual aggregate expenditure  data for the types of projects funded under each transportation covered  program in FHWA’s Recovery Act Data System by November 1, 2010. DOT  also requested that each state provide an explanation of why the state did  not meet its certified MOE amount in any or all transportation programs,  as appropriate.
section_title: Department of Treasury
subsections: section_title: Open Recommendation
paragraphs: Treasury should expeditiously provide Housing Finance Agencies (HFAs)  with guidance on monitoring project spending and develop plans for  dealing with the possibility that projects could miss the spending deadline  and face further project interruptions.
Treasury commented that it has taken a number of steps to ensure HFAs  and project owners have a complete understanding of the 30 percent  deadline and are prepared to comply with that requirement. Further,  Treasury said it plans to continue monitoring the impact of the 30 percent  deadline on the program and to provide additional guidance necessary to  address unforeseen or unexpected circumstances. Although Treasury  officials said that they recently asked HFAs whether any projects could  potentially miss the end of the year deadline, no HFAs have indicated that  projects may miss the deadline. Also, although Treasury currently has not  provided additional guidance to HFAs, it intends to continue working with  HFAs and make a decision about further guidance at the end of the year,  after it identifies any projects that do not meet the 30 percent deadline.
section_title: Matters for Congressional Consideration
subsections: section_title: Matter
paragraphs: To the extent that appropriate adjustments to the Single Audit process are  not accomplished under the current Single Audit structure, Congress  should consider amending the Single Audit Act or enacting new legislation  that provides for more timely internal control reporting, as well as audit  coverage for smaller Recovery Act programs with high risk.
We continue to believe that Congress should consider changes related to  the Single Audit process.
section_title: Matter
paragraphs: To the extent that additional coverage is needed to achieve accountability  over Recovery Act programs, Congress should consider mechanisms to  provide additional resources to support those charged with carrying out  the Single Audit Act and related audits.
We continue to believe that Congress should consider changes related to  the Single Audit process.
section_title: Matter
paragraphs: To provide housing finance agencies (HFA) with greater tools for  enforcing program compliance, in the event the Section 1602 Program is  extended for another year, Congress may want to consider directing  Treasury to permit HFAs the flexibility to disburse Section 1602 Program  funds as interest-bearing loans that allow for repayment.
We continue to believe that Congress should consider directing Treasury  to permit HFAs the flexibility to disburse Section 1602 Program funds as  interest-bearing loans that allow for repayment.
section_title: Appendix IV: GAO Contacts and Staff Acknowledgments
subsections: section_title: Staff Acknowledgments
paragraphs: In addition to the contacts above, the following individuals made key  contributions to this report: Susan Baker, Thomas Beall, James Bennett,  Sue Bernstein, Anna Bonelli, Andrew Ching, Holly Dye, Alexandra  Edwards, Thomas James, Susan Lawless, Sheila R. McCoy, Jeffrey G.  Miller, Carol Patey, Beverly Ross, Christine San, Linda Siegel, Jon Stehle,  Andrew J. Stephens, Wayne Sylvia, Kate Van Gelder, Betty Ward- Zukerman, Craig Winslow, Elizabeth Wood, William T. Woods, Ethan  Wozniak, and Amber Yancey-Carroll.
section_title: Related GAO Products
paragraphs: Recovery Act: FEMA Could Take Steps to Protect Sensitive Port Security  Grant Details and Improve Recipient Reporting Instructions. GAO-11-88.  Washington, D.C.: October 15, 2010.
Recovery Act: Department of Justice Could Better Assess Justice  Assistance Grant Program Impact. GAO-11-87. Washington, D.C.: October  15, 2010.
Recovery Act: Increased Medicaid Funds Aided Enrollment Growth, and  Most States Reported Taking Steps to Sustain Their Programs.  GAO-11-58. Washington, D.C.: October 8, 2010.
Recovery Act: Opportunities Exist to Increase the Public’s  Understanding of Recipient Reporting on HUD Programs. GAO-10-966.  Washington, D.C.: September 30, 2010.
Participants in SBA’s Microloan Program Could Provide Additional  Information to Enhance the Public’s Understanding of Recovery Act  Fund Uses and Expected Outcomes. GAO-10-1032R. Washington, D.C.:  September 29, 2010.
Child Care and Development Fund: Undercover Tests Show Five State  Programs Are Vulnerable to Fraud and Abuse. GAO-10-1062. Washington,  D.C.: September 22, 2010.
Temporary Assistance for Needy Families: Implications of Caseload and  Program Changes for Families and Program Monitoring. GAO-10-815T.  Washington, D.C.: September 21, 2010.
Recovery Act: Survey of State Housing Finance Agencies’ Use of the Low- Income Housing Tax Credit Assistance Program (TCAP) and the Section  1602 Program. GAO-10-1022R. Washington, D.C.: September 20, 2010.
Recovery Act: Opportunities to Improve Management and Strengthen  Accountability over States’ and Localities’ Uses of Funds. GAO-10-999.  Washington, D.C.: September 20, 2010.
Recovery Act: Opportunities to Improve Management and Strengthen  Accountability over States’ and Localities’ Uses of Funds (Appendixes).  GAO-10-1000SP. Washington, D.C.: September 20, 2010.
Older Americans Act: Preliminary Observations on Services Requested  by Seniors and Challenges in Providing Assistance. GAO-10-1024T.  Washington, D.C.: September 7, 2010.
Tax Administration: Usage and Selected Analyses of the First-Time  Homebuyer Credit. GAO-10-1025R. Washington, D.C.: September 2, 2010.
Challenges Facing Government and the Contracting Community.  GAO-10-1021CG. Washington, D.C.: August 23, 2010.
National Institutes of Health: Awarding Process, Awarding Criteria, and  Characteristics of Extramural Grants Made with Recovery Act Funding.  GAO-10-848. Washington, D.C.: August 6, 2010.
Social Security Administration: Cases of Federal Employees and  Transportation Drivers and Owners Who Fraudulently and/or  Improperly Received SSA Benefits. GAO-10-949T. Washington, D.C.:  August 4, 2010.
Recovery Act: Further Opportunities Exist to Strengthen Oversight of  Broadband Stimulus Programs. GAO-10-823. Washington, D.C.: August 4,  2010.
Recovery Act: States Could Provide More Information on Education  Programs to Enhance the Public’s Understanding of Fund Use.  GAO-10-807. Washington, D.C.: July 30, 2010  Recovery Act: Most DOE Cleanup Projects Appear to Be Meeting Cost and  Schedule Targets, but Assessing Impact of Spending Remains a  Challenge. GAO-10-784. Washington, D.C.: July 29, 2010.
Recovery Act: Contracting Approaches and Oversight Used by Selected  Federal Agencies and States. GAO-10-809. Washington, D.C.: July 15, 2010.
Department of Energy: Further Actions Are Needed to Improve DOE’s  Ability to Evaluate and Implement the Loan Guarantee Program.  GAO-10-627. Washington, D.C.: July 12, 2010.
GAO Review of LEA Controls over and Uses of Recovery Act Education  Funds (Avery County Schools). GAO-10-746R. Washington, D.C.: July 9,  2010.
GAO Review of LEA Controls over and Uses of Recovery Act Education  Funds (Winston-Salem/Forsyth County Schools). GAO-10-747R.  Washington, D.C.: July 9, 2010.
Independent Oversight of Recovery Act Funding for Mississippi’s  Weatherization Assistance Program. GAO-10-796R. Washington, D.C.:  June 30, 2010.
High Speed Rail: Learning From Service Start-ups, Prospects for  Increased Industry Investment, and Federal Oversight Plans.  GAO-10-625. Washington, D.C.: June 17, 2010.
Federal Energy Management: GSA’s Recovery Act Program Is on Track,  but Opportunities Exist to Improve Transparency, Performance  Criteria, and Risk Management. GAO-10-630. Washington, D.C.: June 16,  2010.
GAO Proactive Testing of ARRA Tax Credits for COBRA Premium  Payments. GAO-10-804R. Washington, D.C.: June 14, 2010.
Temporary Assistance for Needy Families: Implications of Recent  Legislative and Economic Changes for State Programs and Work  Participation Rates. GAO-10-525. Washington, D.C.: May 28, 2010.
Recovery Act: Increasing the Public’s Understanding of What Funds Are  Being Spent on and What Outcomes Are Expected. GAO-10-581.  Washington, D.C.: May 27, 2010.
Recovery Act: Clean Water Projects Are Underway, but Procedures May  Not Be in Place to Ensure Adequate Oversight. GAO-10-761T. Washington,  D.C.: May 26, 2010.
Recovery Act: States’ and Localities’ Uses of Funds and Actions Needed  to Address Implementation Challenges and Bolster Accountability.  GAO-10-604. Washington, D.C.: May 26, 2010.
Recovery Act: States’ and Localities’ Uses of Funds and Actions Needed  to Address Implementation Challenges and Bolster Accountability  (Appendixes). GAO-10-605SP. Washington, D.C.: May, 26, 2010.
Head Start: Undercover Testing Finds Fraud and Abuse at Selected Head  Start Centers. GAO-10-733T. Washington, D.C.: May 18, 2010.
Child Care: Multiple Factors Could Have Contributed to the Recent  Decline in the Number of Children Whose Families Receive Subsidies.  GAO-10-344. Washington, D.C.: May 5, 2010.
Health Coverage Tax Credit: Participation and Administrative Costs.  GAO-10-521R. Washington, D.C.: April 30, 2010.  2010 Census: Plans for Census Coverage Measurement Are on Track, but  Additional Steps Will Improve Its Usefulness. GAO-10-324. Washington,  D.C.: April 23, 2010.
American Samoa and Commonwealth of the Northern Mariana Islands:  Wages, Employment, Employer Actions, Earnings, and Worker Views  Since Minimum Wage Increases Began. GAO-10-333. Washington, D.C.:  April 8, 2010.
Energy Star Program: Covert Testing Shows the Energy Star Program  Certification Process Is Vulnerable to Fraud and Abuse. GAO-10-470.  Washington, D.C.: March 5, 2010.
Recovery Act: California’s Use of Funds and Efforts to Ensure  Accountability. GAO-10-467T. Washington, D.C.: March 5, 2010.
Recovery Act: Factors Affecting the Department of Energy’s Program  Implementation. GAO-10-497T. Washington, D.C.: March 4, 2010.
Recovery Act: One Year Later, States’ and Localities’ Uses of Funds and  Opportunities to Strengthen Accountability. GAO-10-437. Washington,  D.C.: March 3, 2010.
State and Local Governments’ Fiscal Outlook March 2010 Update.  GAO-10-358. Washington, D.C.: March 2, 2010.
Recovery Act: Officials’ Views Vary on Impacts of Davis-Bacon Act  Prevailing Wage Provision. GAO-10-421. Washington, D.C.: February 24,  2010.  2010 Census: Key Enumeration Activities Are Moving Forward, but  Information Technology Systems Remain a Concern. GAO-10-430T.  Washington, D.C.: February 23, 2010.
Electronic Personal Health Information Exchange: Health Care Entities’  Reported Disclosure Practices and Effects on Quality of Care.  GAO-10-361. Washington, D.C.: February 17, 2010.
Recovery Act: Project Selection and Starts Are Influenced by Certain  Federal Requirements and Other Factors. GAO-10-383. Washington, D.C.:  February 10, 2010.
Recovery Act: IRS Quickly Implemented Tax Provisions, but Reporting  and Enforcement Improvements Are Needed. GAO-10-349. Washington,  D.C.: February 10, 2010.
Status of the Small Business Administration’s Implementation of  Administrative Provisions in the American Recovery and Reinvestment  Act of 2009. GAO-10-298R. Washington, D.C.: January 19, 2010.
Recovery Act: States’ Use of Highway and Transit Funds and Efforts to  Meet the Act’s Requirements. GAO-10-312T. Washington, D.C.: December  10, 2009.
Recovery Act: Status of States’ and Localities’ Use of Funds and Efforts  to Ensure Accountability. GAO-10-231. Washington, D.C.: December 10,  2009.
Recovery Act: Status of States’ and Localities’ Use of Funds and Efforts  to Ensure Accountability (Appendixes). GAO-10-232SP. Washington,  D.C.: December 10, 2009.
Recovery Act: Planned Efforts and Challenges in Evaluating Compliance  with Maintenance of Effort and Similar Provisions. GAO-10-247.  Washington, D.C.: November 30, 2009.
Recovery Act: Contract Oversight Activities of the Recovery  Accountability and Transparency Board and Observations on Contract  Spending in Selected States. GAO-10-216R. Washington, D.C.: November  30, 2009.
Recovery Act: Recipient Reported Jobs Data Provide Some Insight into  Use of Recovery Act Funding, but Data Quality and Reporting Issues  Need Attention. GAO-10-223. Washington, D.C.: November 19, 2009.
Recovery Act: Recipient Reported Jobs Data Provide Some Insight into  Use of Recovery Act Funding, but Data Quality and Reporting Issues  Need Attention. GAO-10-224T. Washington, D.C.: November 19, 2009.
Recovery Act: Agencies Are Addressing Broadband Program Challenges,  but Actions Are Needed to Improve Implementation. GAO-10-80.  Washington, D.C.: November 16, 2009.
Recovery Act: Preliminary Observations on the Implementation of  Broadband Programs. GAO-10-192T. Washington, D.C.: October 27, 2009.
First-Time Homebuyer Tax Credit: Taxpayers’ Use of the Credit and  Implementation and Compliance Challenges. GAO-10-166T. Washington,  D.C.: October 22, 2009.
Federal Energy Management: Agencies Are Taking Steps to Meet High- Performance Federal Building Requirements, but Face Challenges.  GAO-10-22. Washington, D.C.: October 30, 2009.
High Speed Passenger Rail: Developing Viable High Speed Rail Projects  under the Recovery Act and Beyond. GAO-10-162T. Washington, D.C.:  October 14, 2009.
Tax Administration: Opportunities Exist for IRS to Enhance Taxpayer  Service and Enforcement for the 2010 Filing Season. GAO-09-1026.  Washington, D.C.: September 23, 2009.
Recovery Act: Funds Continue to Provide Fiscal Relief to States and  Localities, While Accountability and Reporting Challenges Need to Be  Fully Addressed. GAO-09-1016. Washington, D.C.: September 23, 2009.
Recovery Act: Funds Continue to Provide Fiscal Relief to States and  Localities, While Accountability and Reporting Challenges Need to Be  Fully Addressed (Appendixes). GAO-09-1017SP. Washington, D.C.:  September 23, 2009.
Recovery Act: States’ and Localities’ Current and Planned Uses of Funds  While Facing Fiscal Stresses. GAO-09-908T. Washington, D.C.: September  10, 2009.
Recovery Act: States’ Use of Highway Infrastructure Funds and  Compliance with the Act’s Requirements. GAO-09-926T. Washington,  D.C.: July 31, 2009.
Unemployment Insurance Measures Included in the American Recovery  and Reinvestment Act of 2009, as of July 2009. GAO-09-942R.  Washington, D.C.: July 27, 2009.
Grants Management: Grants.gov Has Systematic Weaknesses That  Require Attention. GAO-09-589. Washington, D.C.: July 15, 2009.
Recovery Act: States’ and Localities’ Current and Planned Uses of Funds  While Facing Fiscal Stresses. GAO-09-829. Washington, D.C.: July 8, 2009.
Recovery Act: States’ and Localities’ Current and Planned Uses of Funds  While Facing Fiscal Stresses. GAO-09-831T. Washington, D.C.: July 8,  2009.
Recovery Act: States’ and Localities’ Current and Planned Uses of Funds  While Facing Fiscal Stresses (Appendixes). GAO-09-830SP. Washington,  D.C.: July 8, 2009.
Recovery Act: The Department of Transportation Followed Key Federal  Requirements in Developing Selection Criteria for Its Supplemental  Discretionary Grants Program. GAO-09-785R. Washington, D.C.: June 30,  2009.
High Speed Passenger Rail: Effectively Using Recovery Act Funds for  High Speed Rail Projects. GAO-09-786T. Washington, D.C.: June 23, 2009.
Recovery Act: GAO’s Efforts to Work with the Accountability Community  to Help Ensure Effective and Efficient Oversight. GAO-09-672T.  Washington, D.C.: May 5, 2009.
Recovery Act: Consistent Policies Needed to Ensure Equal Consideration  of Grant Applications. GAO-09-590R. Washington, D.C.: April 29, 2009.
Recovery Act: Initial Results on States’ Use of and Accountability for  Transportation Funds. GAO-09-597T. Washington, D.C.: April 29, 2009.
Social Security Administration: Effective Information Technology  Management Essential for Data Center Initiative. GAO-09-662T.  Washington, D.C.: April 28, 2009.
Recovery Act: As Initial Implementation Unfolds in States and  Localities, Continued Attention to Accountability Issues Is Essential.  GAO-09-580. Washington, D.C.: April 23, 2009.
Recovery Act: As Initial Implementation Unfolds in States and  Localities, Continued Attention to Accountability Issues Is Essential.  GAO-09-631T. Washington, D.C.: April 23, 2009.
Small Business Administration’s Implementation of Administrative  Provisions in the American Recovery and Reinvestment Act.  GAO-09-507R. Washington, D.C.: April 16, 2009.
American Recovery and Reinvestment Act: GAO’s Role in Helping to  Ensure Accountability and Transparency for Science Funding.  GAO-09-515T. Washington, D.C.: March 19, 2009.
American Recovery and Reinvestment Act: GAO’s Role in Helping to  Ensure Accountability and Transparency. GAO-09-453T. Washington,  D.C.: March 5, 2009.
Estimated Adjusted Medicaid Funding Allocations Related to the  Proposed American Recovery and Reinvestment Act. GAO-09-371R.  Washington, D.C.: February 5, 2009.
Estimated Temporary Medicaid Funding Allocations Related to Section  5001 of the American Recovery and Reinvestment Act. GAO-09-364R.  Washington, D.C.: February 4, 2009.