Grant Program Consolidations: Lessons Learned and Implications for Congressional Oversight
Published: 2014-12-12T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: GAO has previously reported that consolidations may help increase the effectiveness and efficiency of government programs.
GAO was asked to review grant program consolidations in regard to reducing overlap and duplication. This report: (1) describes approaches taken to grant programs that have been consolidated from fiscal year 1990 through 2012, (2) examines federal, state and local actions taken to administer the programs, and (3) analyzes lessons learned for future consideration of grant program consolidations.
GAO reviewed literature on grant program consolidations. For this review GAO selected three case study grant program consolidations, the TA and CoC programs, and the National Environmental Performance Partnership System. GAO conducted interviews with state and local officials in Colorado, Delaware, Florida, and Massachusetts. GAO selected these states and localities based on several selection criteria, such as state participation and funding. The selected locations and grant program consolidations are not generalizable, but they provided important insights about grant consolidations.
section_title: What GAO Found
paragraphs: Consolidations from fiscal years 1990 through 2012. There is no authoritative, accurate tally of enacted grant program consolidations. In addition, there is no commonly accepted definition of what constitutes a grant program consolidation. From a variety of sources, GAO identified 15 grant program consolidations during this period. Most of these consolidations either combined a number of grant programs used for specific activities (such as Shelter Plus Care), known as categorical grants, into a broader categorical grant, such as the Continuum of Care (CoC) program or established a Performance Partnership, which offers additional flexibility in using funds across multiple programs but maintains accountability for meeting certain performance measures. Block grant approaches to consolidation prior to 1990 combined programs for broad purposes, such as work assistance. The more recent approaches, referred to as hybrid, often combine categorical grant programs and emphasize strong performance standards and accountability. Hybrid approaches can improve the efficiency of grant administration and may reduce fragmentation, overlap, and duplication.
State and local government actions. State and local officials in the three case study consolidations GAO selected for review relied on existing grant management structures and established relationships to facilitate implementation of the grant program consolidations. In the Transportation Alternatives (TA) program the impact of the consolidation was delayed by states and local officials' reliance on carryover funds from predecessor grant programs while these funds were still available. Officials reported both benefits and challenges ranging from administrative flexibility such as lack of central oversight by states, lack of or inaccurate performance data, and conflicting reporting requirements.
Lessons to consider. The key to any grant program consolidation initiative is identifying and agreeing on goals—such as improved grant administration and changed programmatic outcomes—and to design and plan for successful implementation, according to findings from the case studies and prior GAO reports. Grant consolidations offer the opportunity to improve grant administration by expanding the opportunities of narrowly targeted grants and by reducing fragmentation, overlap, and duplication. Consolidation initiatives that answer key questions can provide a data-driven consolidation rationale and show stakeholders that a range of alternatives has been considered. These evaluations should include responses to key questions such as the following: What are the goals of the consolidation? What opportunities will be addressed through the consolidation and what problems will be solved?
GAO's prior work found that few executive branch agencies regularly conduct in-depth program evaluations to assess their programs' impact. The Office of Management and Budget (OMB), as the focal point for overall management in the executive branch, plays a key role in improving the performance of federal grant programs and has developed or contributed many tools to encourage improvements to federal grants and program performance. Agencies, the Congress—as well as grantees—can benefit from guidance, which currently does not exist, to assist with identifying consolidation opportunities, particularly those requiring statutory changes, and developing consolidation proposals.
section_title: What GAO Recommends
paragraphs: GAO recommends OMB develop guidance on identifying grant program consolidation opportunities and the analysis to improve their outcomes. GAO incorporated technical comments from the Environmental Protection Agency, Departments of Housing and Urban Development and Transportation, and OMB.

section_title: Letter
paragraphs: Grants play a significant role in implementing and funding federal  programs: through such programs the federal government’s network of  grantors and grantees provides many services critical to the nation’s  interest. Grant programs help build and maintain our nation’s  infrastructure by funding highways, bridges, and mass transit systems.  They also help care for the sick and economically disadvantaged by  funding medical services, nutrition programs, and housing assistance.leveraging the funds and expertise of entities within a granting network— which can involve federal, state, and local governments, as well as non- profits—these services can be delivered more efficiently. However, while  the federal government and grant recipients often share common  purposes, they have different perspectives. Although both are interested  in efficiency and effectiveness, recipients’ interest also includes seeking  flexibility to be nimble and responsive to state and local priorities while  minimizing grant-related administrative burden. For this reason, grants  from the federal government must strike a balance between federal  interests and priorities of the grant recipients.
The federal government’s use of grants to achieve national objectives has  grown significantly in the last three decades. For example, from fiscal  years 1980 to 2013, federal grant outlays to state and local governments  increased from about $91 billion (about $224 billion in 2013 constant  dollars) to about $546 billion. In addition, governments at all levels— federal, state, and local—face long-term fiscal challenges which could  affect both federal funding of intergovernmental programs and the  potential capacity of state and local governments to help fund and  implement these programs. As the United States continues to  experience federal budgetary constraints, there is increasing attention  being paid to ensure that government resources—including those  awarded through grants—are appropriately targeted.
Since the early 1980s, various forms of grant program consolidations  have been enacted and since that time there has also been substantial  variation in how grant funding is structured as well as growth in both the  level of funding and number of grant programs created. As a result of the  growing diversity and complexity of grant funding and administration,  policymakers have looked to grant program consolidation as a way to  reduce complexity while assuring that the funds are used for the intended  national purpose.
We have previously reported that grant program consolidation can create  opportunities to reassess federal programs in which the balance between  costs and benefits received either do not (or no longer) justify federal  spending. We have also reported that such program consolidations may  reduce fragmentation, overlap, and duplication—which can lead to  increased efficiency and to improvements in performance that  significantly benefit taxpayers and beneficiaries alike. However, the  extent to which consolidated grants have led to more streamlined  operations or to gains in efficiency is not clear: we have previously  identified the management of grant programs as a performance and  accountability challenge.
You asked us to identify what federal grant programs have been  consolidated in the past, to examine whether duplication and overlap can  be reduced by consolidating selected federal grant programs, and to  assess what outcomes have occurred from prior consolidations in terms  of savings or improved performance. This report (1) describes  approaches taken to grant programs that have been consolidated from  fiscal year 1990 through fiscal year 2012, (2) examines federal, state, and  local actions taken to administer the selected case study consolidated  grant programs, and (3) analyzes lessons learned for future consideration  of grant program consolidations.
For the first objective, we conducted an extensive literature review to  identify a list of previously consolidated grant programs. From that review  we developed a list that represents our best efforts to comprehensively  identify all grants consolidated from fiscal year 1990 through fiscal year  2012 (see figure 3) and we interviewed Office of Management and  Budget (OMB) agency staff to discuss the multiple approaches by which  some of these were consolidated. We selected 1990 because federal,  state, and local officials working in these program areas may be more  aware of the consolidations than consolidations that happened at or after  this time than before 1990. For our second and third objectives, we  conducted a case study review in four states (Colorado, Delaware,  Florida, and Massachusetts) of three of the consolidated grant programs  that we identified—the Transportation Alternatives program, Continuum of  Care program, and National Environmental Performance Partnership  System (NEPPS).  We selected the Transportation Alternatives and  Continuum of Care programs in part because they had been created from  predecessor programs within the past six years; NEPPS was selected  because the approach used to consolidate it was different than the other  approaches. In each state we interviewed state and local program  officials and reviewed relevant documents. To select the states, we  reviewed agency documents and data for each program—such as state  specific participation and funding—and considered other factors, such as  states we have conducted prior grant work. We used a similar method to  select localities in each state. The selected locations and grant program  consolidations are not generalizable, but they provided us with important  insights about grant consolidations. Appendix II contains further  information about our objectives, scope, and methodology.
We conducted this performance audit from September 2013 to December  2014 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: Grants constitute a form of federal assistance consisting of payments in  cash or in kind for a specified purpose, allocated to a state or local  government or to a nongovernmental recipient.state and local governments, grants are an important tool used by the  federal government to achieve national objectives. When taken as a  whole, federal grant programs are extremely diverse and complex. They  vary widely in numerous ways, including size, the nature of the recipients,  and the types of programs they fund. For example, grants range from  relatively small dollar amounts, such as a research grant from the  National Science Foundation for less than a couple of thousand dollars, to   By providing funding to  much larger dollar amounts, such as Medicaid grants to individual states,  with outlays of about $265 billion in fiscal year 2013. Grant programs also  vary in two important dimensions: (1) the amount of discretion given the  recipient in determining how the funds will be used, and (2) the way they  are allocated (or awarded).
Grants generally are described as either block grants or categorical  grants. Block grants are less restrictive and permit the use of funds for  broader categories of activities, such as community development or  public health. Block grants generally give greater discretion to recipients  in identifying problems and designing programs to address those  problems using grant funds. In contrast, categorical grants are the most  restrictive, permitting funds to be used only for specific activities related to  their purpose, such as for nutrition for the elderly.
While the distinction between “block” and “categorical” grants is useful, it  is important to recognize that in practice, the labels represent the ends of  a continuum: in the middle range, the two types overlap considerably.  The degree of discretion represented by the identified types of grants  enables a different balance to be struck between the interests of the  federal government —that funds be used efficiently and effectively to  meet specified national objectives—and the ability of grant recipients to  use funds for those (approved) activities that best fit local priorities while  also minimizing administrative burdens associated with accepting the  grant.
subsections: section_title: Grants Play a Significant Role in Funding and Advancing Federal Priorities
paragraphs: Over time, grant program funding has increased steadily, as Congress  and federal grant-making agencies have created greater diversity and  complexity in federal grants management. According to OMB, federal  outlays for grants to state and local governments increased from $91.4  billion in fiscal year 1980 (about $224 billion in 2013 constant dollars) to  about $546 billion in fiscal year 2013, (see figure 1).
section_title: Overview of the Federal Process for Grant Program Consolidations
paragraphs: Consolidation rationale: Prior research by the former U.S. Advisory   indicated that  Commission on Intergovernmental Relations (ACIR) there are two instances where it may be suitable to consolidate  categorical grant programs: when categorical programs are too small to have much impact or to  be worth the cost of administration; and when multiple programs exist in functional areas (including health,  education, and social services) that have a large number of programs,  or are in functional areas (including justice, natural resources, and  occupational health and safety) where there is fragmentation.
The proliferation of grant programs can increase problems related to  fragmentation, overlap, and duplication (see figure 2 for our definition of  these terms, based on our related framework). As we have previously  reported, program consolidations may help address these problems.
Consolidations also have the potential to improve the effectiveness and  performance of federal assistance programs by simplifying grant  administration and facilitating coordination among grant recipients.
Approaches for consolidation: For purposes of this report we classified  consolidations as employing either a block grant approach or a hybrid  approach.
A block grant approach is generally broad in scope. It is intended to  increase state and local flexibility and generally give recipients greater  discretion to identify problems or to design programs addressing  those problems using funding from the grant. Block grants funds are  provided through less restrictive, broader categories of activities, such  as community development or public health.
Hybrid approaches can consolidate a number of narrower categorical  programs while retaining strong standards and accountability for  discrete federal performance goals. Hybrid approaches may also  include Performance Partnerships, offer additional flexibility in using  funds across multiple programs but are held accountable for meeting  certain performance measures. They do so by giving grantees the  flexibility to pool discretionary funds across multiple federal programs  (or agencies) serving similar populations and communities, in   exchange for greater accountability for results. The pooling of  discretionary funds is also referred to as “blended” funding.
Legislative authority: These grant program consolidations require  legislative authorization. Federal agencies do not have inherent authority  to consolidate grant programs or to enter into grant agreements without  affirmative legislative authorization. In authorizing grant programs, federal  laws identify the types of activities that can be funded and the purposes to  be accomplished through the funding. Frequently, legislation establishing  a grant program will define the program objectives and leave the  administering agency to fill in the details by regulation. Grant programs  are typically subject to a wide range of accountability requirements under  their authorizing legislation or appropriation and implementing  regulations: this is done so that funding is spent for its intended  purpose. In addition, grant programs are subject to cross-cutting requirements applicable to most assistance programs (see table 1 for  more information).
section_title: Characteristics and Lessons From the 1980s Grant Program Consolidations
paragraphs: The Omnibus Budget Reconciliation Act of 1981 (OBRA) consolidated  several dozen categorical grant programs (and three existing block  grants) into nine block grants covering health and human services,  education, community services and development, and energy  assistance. These block grants from the 1980s were designed to be  more detailed in their reporting and auditing provisions but had fewer  kinds of planning and spending restrictions than earlier block grants. For  example, OBRA provisions of general applicability impose reporting and  auditing requirements, and require states to conduct public hearings as a  prerequisite to receiving funds in any fiscal year.the OBRA programs include such items as limitations on allowable   In addition, several of  administrative expenses, prohibitions on the use of funds to purchase  land or construct buildings, “maintenance of effort” provisions, and anti- discrimination provisions. Applicable restrictions are not limited to those  contained in the program statute itself—other federal statutes applicable  to the use of grant funds must also be followed. In turn, these additional  restrictions may impose legal responsibilities on grantees. Thus, the block  grant mechanism does not totally remove federal involvement, nor does it  permit the circumvention of federal laws applicable to the use of grant  funds. In this latter respect, a block grant is legally no different from a  categorical grant.
As a result of the 1981 block grants, the states’ role in grants  administration changed in a number of ways.  As we previously reported,  four themes capture these actions (see text box).
Lessons Learned from States’ Experience of 1981 Block Grants  Fiscal strategies. States used block grants to adopt fiscal strategies in response to  federal funding changes. These strategies included the ability to continue using prior  categorical grant funds, to transfer funds among certain block grants, and to use their  state funds to help offset federal cuts.  Programmatic discretion. Block grants reduced the federal role in several domestic  assistance areas and gave states discretion to determine needs, set priorities, and fund  activities within broadly defined areas. Prior involvement in the categorical grant  programs provided an administrative framework for absorbing the new responsibilities.  Managerial improvements. An objective of block grants was to promote management  improvements by reducing federal requirements. Many management improvements were  reported, including reduced time and effort preparing applications and reports, changed  or standardized administrative procedures, improved planning and budgeting practices,  and better use of staff.  Accountability considerations. Monitoring the expenditure of block grant funds to  achieve stated national objectives—a theme throughout the block grant reports—has  been (and is) a central federal accountability function under past and present block grant  legislation. Tracking federally supported activities, recipients, and dollars is a major  evaluation function. Whether federal funds support activities that advance national  objectives is historically of central interest to Congress.
section_title: Description of Consolidated Programs Selected for Studies
subsections: section_title: Transportation Alternatives Program
paragraphs: The Moving Ahead for Progress in the 21st Century Act (MAP-21)  restructured existing highway programs by eliminating or consolidating  numerous programs and establishing a revised, core formula program  structure. As part of this major restructuring, a new program–the  Transportation Alternatives (TA) program–was authorized under MAP- 21 in 2012; in fiscal years 2013 and 2014 the TA program had  authorizations of $809 million and $820 million, respectively. TA  program provides a single source of funding generally replacing separate  funding for individual programs, including the former Transportation  Enhancement (TE) activities (renamed the Transportation Alternatives  activities), the Safe Routes to School (SRTS) Program, and the  Recreational Trails Program (RTP). However, RTP continues to be  separately funded through a set-aside requirement under the TA  program. Not all formerly eligible activities may be funded through the TA  program, though, as MAP-21 also eliminated some eligible activities  formerly included under TE activities. Funds for the TA program—like  funds for other federal-aid to highway programs—are annually  apportioned to the states through a formula.flexibilities regarding how they administer the programs: for example,  each state develops its own process to solicit and select projects for  funding. The TA program funds are awarded at the state or metropolitan  planning organization (MPO) level through a competitive process, but the  authorization does not establish specific standards or procedures for how  this should be done. The TA program added new requirements that did  not previously exist: for example, 50 percent of a state’s apportionment  must be suballocated based on population; states and MPOs must solicit  and select projects through competitive processes and only eligible  entities may sponsor projects, MPOs, and nonprofit entities are not  eligible entities.
section_title: Continuum of Care Program
paragraphs: ESG funds are allocated by formula to metropolitan cities, urban counties, territories,  and states for select outreach, emergency shelter, homelessness prevention, rapid re- housing assistance, and homeless management information systems. 42 U.S.C. §§  11371-11378. providing funding opportunities through the CoC program to nonprofit  organizations and state and local governments that use those funds to  quickly rehouse homeless individuals and families.
The McKinney-Vento Homeless Assistance Act, originally passed in  1987, was the first major federal legislative response to homelessness.  In 2009, Congress passed the HEARTH Act, which significantly amended  Title IV of the McKinney-Vento Act. The amendments are intended to  increase the efficiency and effectiveness of coordinated, community- based systems that provide housing and services to the homeless.Under the CoC program, most of the program components and eligible  costs continue to be the same as those funded under the predecessor  programs. However, they are consolidated so that applicants only need to  apply for CoC program funds, rather than for one of three programs  based on the type of assistance provided. Applications for CoC program  funds are made by a collaborative applicant, which is an organization that  has been designated by the Continuum of Care to submit a joint grant  application to apply for CoC program funds on behalf of all applicants for  funding in a community.
CoC program grants are awarded competitively and HUD awarded nearly  $1.7 billion to projects in fiscal year 2012. Grant recipients are nonprofit  organizations, states, local governments, and state and local government  instrumentalities (such as public housing agencies) that are designated  by the local Continuum of Care to apply for HUD’s competitive CoC  program grant funding.   Continuum of Cares are local groups of providers and key stakeholders in a geographic area that join together to  design the housing and service system that will prevent and end  homelessness within their geographic area.
section_title: National Environmental Performance Partnership System
paragraphs: The National Environmental Performance Partnership System (NEPPS) is  a performance-based system of environmental protection designed to  improve the efficiency and effectiveness of the partnership between  states and the U.S. Environmental Protection Agency (EPA), as both  share responsibility for protecting human health and the environment.  According to EPA documents and state officials, NEPPS is designed to  direct scarce public resources toward improving environmental results,  allow states greater flexibility to achieve those results, and enhance  accountability to the public and taxpayers.
We have previously reported that EPA has had long-standing difficulties  in establishing effective partnerships with the states, which generally have  the lead responsibility in implementing environmental grant programs. To  address these problems and to improve the effectiveness of program  implementation, a state may receive funds in individual environmental  program categorical grants; alternatively, a state (or interstate agency)  may choose to combine funds from two or more environmental program  grants into a single grant—a Performance Partnership Grant (PPG).  PPG funds can be used for any activity that is eligible under at least one  of nineteen environmental programs. PPGs streamline administrative  requirements, give states greater flexibility to direct resources to their  most pressing environmental problems, and make it easier to fund efforts  that cut across program boundaries. Closely affiliated with PPGs,  Performance Partnership Agreements (PPA) are designed to complement  PPGs, with states free to negotiate agreements (or grants) or to decline  participation in NEPPS altogether.
section_title: While Few Grants Have Been Consolidated Since 1990, Hybrid Approaches Are Being Pursued
subsections: section_title: The Number of Federal Grant Program Consolidations Is Difficult to Identify and Approaches for Consolidation Have Shifted
paragraphs: Our research identified few grant program consolidations over the last two  decades. We identified a total of 15 consolidations from fiscal year 1990  through 2012, (see figure 3 and appendix I). Most of these consolidations  either combined a number of grant programs used for specific activities  (such as Shelter Plus Care), known as categorical grants, into a broader  categorical grant, such as the CoC program, or established a  Performance Partnership, which offers additional flexibility in using funds  across multiple programs but is held accountable for meeting certain  performance measures.
The grants we identified in figure 3 are likely not an exhaustive list and  determining a definitive number of grant program consolidations is difficult  for two reasons. First, our research did not identify an authoritative,  government-wide compendium or source that provides an accurate tally  of enacted grant program consolidations. The inability to identify an  authoritative comprehensive source is consistent with prior work reporting  on difficulties associated with determining a definitive number of federal  grant programs. Efforts to accurately identify grant program  consolidations are further complicated by the fact that different entities  have counted grant programs differently for decades, rendering it difficult  to get a count of the number of grant programs, let alone consolidations.Second, there is no commonly accepted definition of what constitutes a  grant program consolidation.
While we were not able to identify a definitive number of grant  consolidations, we were able to generally identify two different  approaches by which these grants were consolidated. The consolidations  from 1990 to 2012 shifted more to hybrid approaches from the earlier  block grant approach.
Block grant approaches: Previously, Congress showed a strong interest  in consolidating narrowly defined categorical grant programs intended for  specific purposes into broader purpose block grants. Consolidating  closely related categorical programs into these broader purpose grants  was intended to improve grant administration, which involves the federal  government awarding a grant to a state or local government. While block  grants generally delegate primary responsibility for monitoring and  overseeing the planning, management, and implementation of activities  financed with federal funds to state and local governments, they also can  create—and have been designed to facilitate—some accountability for  national goals and objectives. One such program—Temporary Assistance  for Needy Families—consolidated a number of social service programs  which provide families with assistance and related support services.
Hybrid approaches: In more recent years, we have noted a rise in hybrid  approaches—possibly the result of concluding that the traditional  devolution of responsibility found in a block grant may not be the most  appropriate approach. Hybrid approaches can provide state and local  governments with greater flexibility in using federal funds, in exchange for  more rigorous accountability for results. Hybrid approaches vary in the  degree to which programmatic flexibility is enabled—in order to balance  between or among programs—and in the degree to which grant  administration, reporting, and accountability requirements are changed.  One grant program consolidation enacted in 2009–HUD’s CoC program— was created by consolidating multiple categorical grant programs. EPA’s  Performance Partnership System takes a slightly different approach.  It  provides states the opportunity to voluntarily enter into agreements with  EPA to use funds from two or more environmental categorical grant  programs in a more flexible and streamlined manner, while enabling  states to delineate which environmental priorities (such as air, water, or  waste) are most important to their needs.
Each of these hybrid approaches can strike a different balance between  the interests of the federal grant-making agency—that funds be used  efficiently and effectively to meet national objectives and the interests of  the recipient—that funds meet local priorities and that the administrative  burdens associated with accepting the grant are minimized.
section_title: Hybrid Approaches May Increase Opportunities to Achieve Program Outcomes, but Challenges Exist
paragraphs: Grants consolidated through hybrid approaches can provide opportunities  to achieve improved program outcomes for both categorical and block  grants. While block grant approaches to consolidation combine programs  for broad purposes, hybrid approaches allow for consolidation by  combining programs that have a narrower scope and may provide  flexibilities. Hybrid approaches can improve the efficiency of grant  administration and may reduce fragmentation, overlap, and duplication.  For example, in 2012 we reported on Department of Justice (DOJ) grants  that provided a range of program areas that were consolidated using   These grants provided a range of  several different hybrid methods.program areas such as crime prevention, law enforcement, and crime  victim services.  At the time, DOJ officials told us that the most  comprehensive way to reduce overlap is by consolidating two programs  with similar purposes into one and by creating unified management.
The use of hybrid approaches to consolidate grants continues to evolve.  The Departments of Labor, Health and Human Services and Education  and Related Agencies Appropriations Act for fiscal year 2014 provided  authority for those entities receiving funds under the act to establish up to  10 Performance Partnership pilots designed to improve outcomes for   Under the pilot authority, a state, local, or tribal  disconnected youth.government may enter into a Performance Partnership agreement with a  lead federal agency, which will allow the pooling of grant funds received  under multiple federal programs as well as the additional waiver of  requirements associated with the federal programs contributing funds.  This pilot is a model and is designed to promote better education,  employment, and other key outcomes for disconnected youth and to ease  administrative burden. The legislation directs OMB to designate the lead  federal agency that will enter into and administer the Performance  Partnership agreement on behalf of that agency and the other  participating federal agencies. OMB is coordinating across multiple  federal agencies to facilitate the design and planning of the Disconnected  Youth Performance Partnership pilot.
OMB Memorandum M-11-21, Implementing the Presidential Memorandum  “Administrative Flexibility, Lower Costs, and Better Results for State, Local, and Tribal  Governments” (Washington, D.C., April. 29, 2011) and OMB Memorandum M-13-17, Next  Steps in the Evidence and Innovation Agenda (Washington, D.C., July 26, 2013). encourage innovation and participation. Organizational culture and an  organization’s ability to perform a joint activity (one intended to produce  greater public value than could be produced acting alone), can  significantly affect interagency collaboration efforts. In addition,  resources and the structure of an organization’s decision-making process  affect the design and implementation of hybrid consolidation initiatives.  OMB also noted the significant amount of effort needed from multiple  stakeholders across different levels of government. In addition, our prior  grant work concluded that administering similar programs in different  agencies can create an environment in which programs may not serve  the grant recipients as efficiently and effectively as possible.
Measuring and tracking outcomes: The use of Performance  Partnerships, such as the pilot previously discussed, involves multiple  funding streams across federal programs and agencies. Agencies,  recipients, and subrecipients lose the ability to track program  performance for individual categorical grants when multiple funding  streams are combined in a Performance Partnership. Performance  Partnership initiatives may put additional requirements on agencies to  measure and track outcomes. For example, before states can enter into a  Performance Partnership grant, they must first negotiate a work plan with  EPA that includes expected outputs and outcomes. When designing  hybrid consolidations, agencies can mitigate certain challenges because  they provide an opportunity to consider new performance measures  aligned with the intended consolidation outcome. We previously  concluded that establishing measurements across agency and federal  programs may be difficult to accomplish due to challenges associated  with coordination and agencies reaching agreement on a common  outcome and as a result, this may be a challenge in implementing the  Disconnected Youth Performance Partnership pilot.
Managing administrative challenges: When DOJ used several hybrid  approaches to consolidate grants in 2012, officials told us that the  statutory creation of grant programs with similar purposes can create  administrative challenges. They said that in many cases, DOJ must seek  statutory authorization to discontinue or consolidate enacted programs  that it believes may be overlapping. In addition, EPA officials told us for  the NEPPS, categorical grant programs within a partnership have their  own statutory and regulatory requirements, which may create an  administrative challenge when states try and focus on achieving program  results.
section_title: Consolidation Design Influenced State and Local Implementation and Dictated Impact on Any Existing Fragmentation, Overlap, or Duplication
subsections: section_title: State and Local Governments’ Consolidation Implementation is Similar to 1980s Block Grant Implementation
paragraphs: State and local officials we interviewed are taking some actions to  implement the selected grant program consolidations. In general, the  actions taken are similar to the 1980s era of block grant actions because  in both instances, state and local governments in the three case study  consolidations relied on existing grant management structures and  established relationships to facilitate implementation of the selected grant  program consolidations. These actions include relying on the existing  grant management structure, identifying the existence of carry-over funds  from predecessor grant programs, and integrating program requirement  changes. In addition to these actions, state officials reported to us that the  TA program and NEPPS case study grant program consolidations  provided them with flexibility in administering the programs. For example,  Delaware officials stated the TA program provides certain flexibilities,  such as choosing which recreational trails projects it funds.
Grant management structure and established relationships: The  HEARTH Act changed neither the eligible recipients nor the delivery  structure for administering the CoC grant program. Funds for the CoC  grant program, like those from the three predecessor homeless grant  programs before it, are distributed to the same eligible recipients, as  illustrated in table 2. Under the CoC program, an eligible applicant (known  as the recipient to whom HUD awards the project and with whom HUD  enters into a grant agreement for the project) must be designated by the  Continuum of Care to apply for a grant from HUD on behalf of the  Continuum that the collaborative applicant represents. The Continuum of  Care is responsible for developing a grant application through a  collaborative process and approving the submission of grant applications  to HUD, among other things.
For example, the Homeless Planning Council of Delaware, a private  nonprofit organization in one of our selected states, serves multiple roles  in the state, including serving as the collaborative applicant for the  statewide Continuum of Care and coordinates the submission, ranking,  and application for the federal CoC grant funding through HUD. Delaware  state officials reported that because there was no change in the structure  of the grant funding stream—meaning the state is not the primary  recipient of the three predecessor homeless grant programs— the CoC  program consolidation has had little or no impact on the state.
Existence of carry-over funds from predecessor grant program:  States reported to us that the budget impact of the TA program  consolidation was delayed because they relied on carry over funds from  predecessor grant programs while these funds were still available. For  example, both Massachusetts and Delaware are spending down federal  SRTS funds authorized in the 2005 Safe, Accountable, Flexible, Efficient  Transportation Equity Act: A Legacy for Users (SAFETEA-LU). Until  these previously apportioned SRTS funds are obligated or rescinded,  they will continue to be available for their specified period of availability,  under the same terms and conditions in effect prior to the effective date of  MAP-21. Delaware state transportation officials told us at the time of our  interview that funds apportioned under the predecessor program provides  a 12- to 18-month period before the consolidation will affect them.
In our prior work we found that most federal funds for highway projects require a 20  percent match from state and local governments. In addition, grants with federal matching  requirements may promote relatively more state and local spending than non-matching  grants, thus reducing the likelihood that states will use the federal funds to replace, rather  than supplement, their own spending. GAO, Federal Grants: Design Improvements Could  Help Federal Resources Go Further, GAO/AIMD-97-7 (Washington, D.C.: Dec. 18, 1996)  and Safe Routes to Schools: Progress in Implementing the Program, but a  Comprehensive Plan to Evaluate Program Outcomes is Needed, GAO-08-789  (Washington: D.C.: July 31, 2008). responsible for providing matching funds. State and local transportation  officials in Delaware and Florida and local transportation officials in  Colorado, also stated that at the time the consolidation was enacted,  decisions regarding federal transportation funding were already made  (through the statewide transportation planning process) and for this  reason, the TA program consolidation had little immediate impact on  them.
section_title: Performance Accountability Challenges Continue and Opportunities Remain to Mitigate Fragmentation, Overlap, and Duplication in Grant Program Consolidations
paragraphs: In our past work, we concluded that there are various ways to design  grants to encourage performance accountability and that effective  performance accountability provisions are of fundamental importance in  determining if grant program goals are being met. Two factors that we  have previously concluded as important for effectively reporting on grant  performance are high-quality performance measures and performance  data. Adding to the complexity of grants management, grant programs  are typically subject to a wide range of accountability requirements (under  their authorizing legislation or appropriation) and implementing  regulations so that funding is spent for its intended purpose. Congress  may also impose increased reporting and oversight requirements on  grant-making agencies and recipients. In addition, grant programs are  subject to crosscutting requirements applicable to most assistance  programs.
Performance accountability challenges persist in the selected case  studies, in part because of statutory, regulatory, or administrative program  requirements were present in the predecessor programs, and that  continued unchanged in the consolidation implementation. These  performance accountability challenges identified by federal, state, and  local officials include lack of central oversight in the states, lack of or  inaccurate performance data, and conflicting reporting requirements, as  illustrated in table 3.
OMB staff told us that they are identifying opportunities to design grant  program consolidation authorizations with greater flexibility. Through its  Uniform Administrative Requirements, Cost Principles, and Audit  Requirements for Federal Awards (Uniform Guidance), OMB has  consolidated its grants management circulars in an effort to promote  consistency among grantees and to reduce administrative burden, such  as, eliminating unnecessary and duplicative requirements, on nonfederal  entities. OMB officials said this may provide greater flexibilities to address  some of these accountability challenges.
State officials reported that these identified accountability challenges  existed prior to the consolidation and that it is unclear how (if at all)  consolidations affect them. The experiences of state and local officials  responsible for grant accountability and consolidation implementation  suggest opportunities for Congress and the executive branch to improve  the development and the implementation of accountability mechanisms  when designing grant program consolidations. For example, building  accountability into newly proposed grant program consolidations is an  important but difficult task—one requiring trade-offs between federal and  state control over program finances, activities, and administration.  Designing accountability provisions provides an opportunity to consider  the potentially conflicting objectives of increasing state and local flexibility,  attaining certain national objectives, and improving reporting,—which  together, leads to better outcome and impact evaluations. Depending on  their focus, evaluations may examine aspects of program consolidation  (such as performance measurements or program reporting) or factors in  that program’s environment that may impede or contribute to the  consolidation’s success. Alternatively, evaluations may assess a  consolidation’s effects beyond its intended objectives, or may estimate  what would have occurred in the absence of the consolidation, in order to  assess the net impact. Striking a balance will inevitably involve  philosophical questions about the proper roles and relationships among  the levels of government in our federal system.
We have previously cited examples of how fragmentation and overlap can  lead to inefficient use of resources. We have previously concluded that  consolidation may also provide an opportunity to reduce fragmentation,  overlap, and duplication. For the three selected program consolidations  we reviewed as case studies, federal, state or local officials identified  opportunities to either reduce fragmentation, overlap, and duplication. For  example, state or local officials in three states (Colorado, Florida, and  Massachusetts) identified duplicative reporting requirements for homeless  assistance grants. In addition, multiple homelessness grants are available  from multiple federal agencies: each offers similar services to similar  beneficiaries, and each has its own grant life cycle (i.e., separate grant  awards, applications, and reporting requirements).fragmentation of services and overlap is partly a result of a program’s  statute and partly result of programs evolving to offer services that meet  the varying needs of recipients. More specifically, we have found the  following;
We have previously concluded that fragmentation, overlap, and  duplication in the homeless grant programs may be reduced by grant  program consolidation. By authorizing the consolidated CoC grant  program, the HEARTH Act helped mitigate this duplication in HUD’s  homeless assistance grant programs but does not fully address it  because of the underlying structure and operations of providing  federal homeless services and grant programs to low-income people  remains fragmented. This is because federal programs may not  always include service providers with expertise and experience in  addressing the needs of homeless people and because these  programs may lack incentives that encourage mainstream service  providers to serve this population. Also, the fragmented nature of  federal mainstream programs can create barriers to providing a  coordinated set of services that addresses the multiple needs of  homeless people.   HUD officials told us that they are working to  decrease fragmentation in homelessness grant programs through  regulations and by working with other federal stakeholders.
GAO, Homelessness: Barriers to Using Mainstream Programs, GAO/RCED-00-184  (Washington, D.C.: July 6, 2000).
The ad hoc nature and fragmentation of federal grant program  authorization contributes to fragmentation, overlap, and duplication. In  the case of the NEPPS program, EPA officials reported three areas  where fragmentation, overlap, and duplication exist, and interfere with  the ability to achieve the NEPPS goals to promote efficiency and  effectiveness. The three areas are: (1) multiple competing reporting  guidance, regulations and individual grant reporting requirements, (2)  duplication in performance measurement requirements, and (3) grants  with similar purposes administered by multiple federal and state  agencies. In some instances—such as when a state receives multiple  categorical water grants—a PPG may provide opportunities for the  state to reduce overlap and duplication by managing the funding  streams available from multiple programs with the flexibilities afforded  by the PPG. However, fragmentation may be exacerbated by the silo  effect (i.e., across multiple federal agencies) of program  implementation.
section_title: Lessons Learned Can Inform Both the Design and Review of Grant Program Consolidations
subsections: section_title: Ambiguity of Consolidations’ Goals May Create Grant Management Challenges
paragraphs: The key to any consolidation initiative is identifying and agreeing on the  goals of the consolidation, regarding grant administration and changed  programmatic outcomes (if any) and designing and planning for  successful implementation, according to findings from the case studies  and our prior GAO work. Grant consolidations offer the opportunity to  improve administration by enlarging the limits of narrowly targeted grants  and by reducing fragmentation, overlap, and duplication. In addition,  consolidations may be undertaken to improve the programmatic  outcomes associated with national goals by designing the consolidation  with consideration of the effects on other closely related grant programs  excluded from the consolidation. This awareness of consolidation  purposes can provide the federal, state and local recipients of the  consolidation the opportunity to develop an implementation plan against a  realistic expectation of how the consolidation goals can be achieved.
While grant program consolidation goals can be compromised by the  complexity and number of grant programs affecting a national goal, and  by the fragmented structure of authorizing new program initiatives across  multiple Congressional committees and subcommittees, OMB officials  told us that building a shared understanding of the consolidation goals  and outcomes among the affected federal, state, and local program  officials can build a strategy for achieving the identified goals. As federal  policy makers consider future grant program design—including  consolidating categorical grant programs or authorizing performance  partnerships—it is important that leaders consider what the consolidation  is trying to achieve and what its impact might be on simplifying grant  administration and improving the effectiveness and performance of  federal assistance programs. Without first identifying goals, a  consolidation may not achieve the desired outcome, such as reducing the  number of programs while still funding the same original program or  activity.
section_title: Leadership-Driven Engagement May Increase the Likelihood of a Successful Implementation
paragraphs: Implementing consolidations is not a simple endeavor and may require  concentrated efforts of both leadership and employees to accomplish new  organization goals. Whether consolidations originate from within an  agency in response to changing conditions or from outside pressures, or  from the most senior levels of government, it is essential that top  government and agency leaders are committed to the consolidation and  play a lead role in executing it. Lessons learned from prior work on  mergers and transformations have shown that, leadership must set the  direction, pace, and tone, as well as provide a clear, consistent rationale  to agency staff in order to increase the likelihood of a successful  consolidation. For example, states and EPA are jointly responsible for  implementing NEPPS program requirements, conducting strategic  planning, and setting priorities that identify optimal ways to leverage  available federal resources alongside state resources. Federal and state  officials involved in implementing EPA’s PPAs or PPGs told us that strong  senior leadership plays an important role in ensuring these  responsibilities are met. Furthermore, they stated that broad adoption of  PPGs requires effective coordination across programs and within EPA  program offices, as well as ongoing senior leadership support.
Our prior work has shown that communication plays a role in grant  management reform. We have concluded that communication is not just  “pushing the message out,” but should facilitate a two-way, honest   For  exchange and allow for feedback from relevant stakeholders.example, HUD officials responsible for managing the CoC program  consolidation told us that establishing a help desk to answer questions  from grant recipients and other community stakeholders enabled HUD to  understand consolidation implementation challenges and to update  guidance accordingly in real time.
section_title: Congress and Agencies Could Help Program Consolidations Through Legislative Action and Program Consolidation Evaluations
paragraphs: In our prior work, we concluded that given the potential benefits and costs  of consolidation, it is imperative that Congress and the executive branch  have information to help them effectively evaluate grant program  consolidation proposals.requirements and congressional oversight can contribute to successful  achievement of national goals in grants and to improve the efficiency and  effectiveness of grant programs.
Legislative action: Our body of grant consolidation work has identified  areas where Congress should consider taking legislative action to  consolidate certain programs in the education, housing, welfare, and  justice areas. When Congress is considering grant program consolidation proposals it is important, that the proposals be supported by  analysis: agencies’ responses to key questions could help inform such  proposals (see text box). Such questions would not necessarily be  exhaustive, nor would it be necessary to consider all questions in every  proposal.
Key Questions to Consider When Evaluating Grant Consolidation Proposals
What are the goals of the consolidation? What opportunities will be addressed  through the consolidation and what problems will be solved? What problems, if any,  will be created?  Is there a way to track and monitor progress toward the short-term and long-term  goals? Does the consolidation proposal include a feedback loop? Does the feedback  enable officials to identify and analyze the causes of the program outcomes and how  this learning can be leveraged for continuous improvement?
What will be the likely costs and benefits of the consolidation? Are sufficiently  reliable data available to support a business-case analysis or cost-benefit analysis?
How can the up-front costs associated with the consolidation, if any, be funded?
Who are the consolidation stakeholders, and how will they be affected? How have  the stakeholders been involved in the decision, and how have their views been  considered? On balance, do stakeholders understand the rationale for  consolidation?  If the proposed consolidation approach does not include all programs with similar  activities or that address similar goals, how will the new structure interact with those  programs not included in the consolidation?  To what extent do plans show change management practices will be used to  implement the consolidation?
Evidence of thinking through some of these considerations may indicate  that agency officials have developed a strong grant program consolidation  proposal. Conversely, the absence of consideration of these questions  could indicate that agency officials have not adequately planned their  consolidation proposal.
Program consolidation evaluations: Executive branch agencies could  conduct and report program evaluations that would assess how well  federal programs are working and identify steps that are needed to  improve them. Program evaluations typically examine processes,  outcomes, impacts, or the cost effectiveness of federal programs.  Evaluation can play a key role in program planning, management, and  oversight by providing feedback on both program design and execution to  program managers, legislative and executive branch policy officials, and  the public. However, as our prior work found few executive branch  agencies regularly conduct in-depth program evaluations to assess their  programs’ impacts or to learn how to improve results. Program  evaluations that use the key questions identified are also important when  programs are being considered for consolidation.  Such analysis is likely  to result in more effective and improved outcomes of a consolidation.   Annually, through the President’s budget process and congressional  budget justification, agencies have the opportunity to present Congress  with the rationale for a program consolidation proposal, such as a  business case analysis. The congressional budget justification can be  used to support a grant program consolidation proposal. For example, the  fiscal year 2012 DOJ congressional budget justification recognized the  potential for consolidation by stating that “whenever possible, the  President’s Budget proposes to consolidate existing programs into larger,  more flexible programs that offer state, local, and tribal grantees greater  flexibility in using grant funding and developing innovative approaches to  their criminal justice needs.”
In carrying out its mission, OMB provides general guidance to federal  agencies, assesses the effectiveness of programs, and ensures that  budget requests are consistent with regulations and presidential  priorities. OMB, as the focal point for overall management in the executive branch, plays a key role in improving the performance of  federal grant programs and has developed or contributed many tools to  encourage improvements to federal grants and program performance.  Therefore, in OMB’s capacity to provide agency guidance, OMB could  help agencies identify consolidation opportunities and conduct program  consolidation evaluations. OMB staff stated there is a need for improved  guidance relative to grant program consolidation opportunities. Agencies  and, the Congress—as well as grantees—can benefit from guidance,  which currently does not exist, to assist with identifying consolidation  opportunities, particularly those requiring statutory changes and  developing consolidation proposals. In conducting reviews of prior agency  budget justifications, we have found opportunities for federal agencies to  improve information that could aid congressional stakeholders in resource  decision making and program oversight. For example, when proposing  a grant program consolidation, all agencies could include a program  consolidation evaluation (or business case) in their budget justification  review that among other things clearly identifies the consolidation goals,  benefits, and stakeholders that will be affected by the consolidation.
GAO-12-542. been consolidated) and are therefore unable to identify a benefit for  consolidating the predecessor categorical grant programs.
EPA’s PPG has elements which illustrate the benefits that can occur  when agencies must present facts and supporting details for a  consolidation. For instance, states first elect whether to participate in a  PPG: if they decide to do so, they identify environmental priorities and  determine which eligible grant programs to potentially include in the  PPA—which illustrates a degree of intentional and rationale decision  making that is consistent with elements of a program consolidation  evaluation (or business case analysis). Finally, to design a PPG, states  and EPA develop and negotiate a grant work plan consistent with  applicable federal statutes; regulations; circulars; executive orders; and  EPA delegations, approvals or authorizations. The work plan documents  how grantees intend to use federal funds and what they will accomplish.  Details included in a work plan include the commitments for each  component and a time frame for their accomplishment, a performance  evaluation process and reporting schedule, and the roles and  responsibilities of the state and EPA in carrying out the work plan  commitments.
section_title: Conclusions
paragraphs: The federal government plays an important role in delivering federal  grant-in-aid to state and local governments. Numerous agencies  administer fragmented programs, and recent assessments have shown  that some programs overlap (that is, provide similar products or serve  similar populations). Consolidating programs carries certain implications  for recipients (e.g., changes in eligibility, process or procedures for  eligible applicants), existing programs, personnel, and associated  information systems. Consolidations can reduce, have no impact on, or  even increase fragmentation, overlap, and duplication of related grant  programs that are not included in the consolidation. In seeking to avoid  increasing unnecessary fragmentation, overlap, and duplication, it is  critical that federal policy-makers consider what other programs or  funding streams exist in related areas and what the impact of the  consolidation on these is likely to be. Even if no changes in these other  programs are undertaken, design of the consolidation can affect the  interaction with other programs and funding streams.
As we have previously reported, consolidation initiatives can be complex,  costly, and difficult to achieve. For this reason, a case-by-case  analysis—one that evaluates the goals of the consolidation against the  realistic possibility of the extent to which those goals would be achieved— is important to ensure effective stewardship of government resources in a  constrained budget environment.
Considering grant program consolidation design features and their  implications can help policymakers ensure that accountability and  information are adequately provided for, whatever type of consolidation  approach is selected. Our findings suggest that the design of a grant  program consolidation involves choosing among policy options that, in  combination, establish the degree of flexibility afforded to states or  localities; prioritize the relevance of performance objectives for grantee  accountability; designate whether accountability for performance rests at  the federal, state, or local level; and identify prospects for measuring  performance through grantee reporting. The design may also allow for an  evaluation of program consolidation performance, an overall assessment  of whether the program works, and identification of adjustments that may  improve the results. The availability of guidance on evaluating grant  program consolidation opportunities could assist agencies’ efforts to  identify such opportunities. Seeking out the interests and concerns of  Congress and key program stakeholders in advance can help ensure that  agency evaluations provide the information necessary for effective  management and congressional oversight of program consolidations. The  experiences of federal, state, and local officials suggest opportunities for  Congress and the executive branch to improve grant program  consolidation design.  These opportunities include, evaluating the delivery  of services with a clear national objective across multiple agencies and  leveraging lessons learned through feedback from implemented  consolidations.  Using those lessons can support continuous  improvement in future grant program consolidations.
section_title: Recommendation for Executive Action
paragraphs: To assist federal agencies seeking to streamline and improve the  efficiency of grant programs and improve their outcomes, we recommend  that the Director of the Office of Management and Budget (OMB) develop  guidance that presents a range of potential consolidation methods, such  as performance partnerships, and other hybrid approaches. This  guidance should assist agencies in identifying consolidation opportunities,  including those that require statutory changes, and in developing sound  consolidation proposals. The guidance should include questions agencies  are expected to include in any consolidation proposals such as,
What are the goals of the consolidation? What opportunities will be  addressed through the consolidation and what problems will be  solved? What challenges, if any, will be created?  Is there a way to track and monitor progress toward the short-term  and long-term goals? Does the consolidation proposal include a  feedback loop? Does the feedback enable officials to identify and  analyze the causes of the program outcomes and how this learning  can be leveraged for continuous improvement?
Who are the consolidation stakeholders and how will they be  affected? What will state, local, or nonprofit entities have to do  differently?
What statutory or regulatory changes are needed to support the  consolidation?  If the proposed consolidation approach does not include all programs  with similar activities or that address similar goals, how will the new  structure interact with those programs not included in the  consolidation?
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report for review and comment to the  Administrator of the Environmental Protection Agency, the Secretaries of  the Departments of Housing and Urban Development and Transportation,  and the Director of the Office of Management and Budget (OMB).  OMB  did not comment on the recommendation but provided technical  comments, as did each of the other agencies.  We incorporated these  technical comments as appropriate. Additionally, we provided excerpts of  the draft report to state and local officials in the four states we interviewed  for this study and incorporated their technical comments as appropriate.
We are sending this report to relevant agencies and congressional  committees. In addition, the report is available at no charge on the GAO  website at http://www.gao.gov.
If you or your staff members have any questions or wish to discuss the  material in this report further, please contact me at (202) 512-6806 or  irvings@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 making key contributions to this report are listed in appendix III.
section_title: Appendix I: Summary of Grant Program Consolidations, Fiscal Year 1990 through 2012 (Text for Interactive Fig. 3)
paragraphs: Appendix I: Summary of Grant Program  Consolidations, Fiscal Year 1990 through 2012  (Text for Interactive Fig. 3)
Table 4 lists the 15 consolidated grants we identified during the time  period of fiscal years 1990 through 2012 along with selected  characteristics for each. There is no single resource that maintains a list  of grant consolidations; therefore, this list may not be exhaustive.
section_title: Appendix II: Objectives, Scope, and Methodology
paragraphs: As part of our ongoing body of work associated with improving grant  design and management across the federal government, we were asked  to identify what federal grant programs have been consolidated in the  past and asked to examine whether overlap and duplication may be  reduced by consolidating several federal grant programs, and to identify  outcomes that have occurred from prior consolidations in terms of savings  or improved performance. To accomplish this, we answered the following  objectives:  1.  Describe approaches taken to grant programs that have been  consolidated from fiscal year 1990 through 2012.  2.  Examine federal, state, and local actions taken to administer the  selected case study consolidated grant programs.  3.  Analyze the lessons learned for future consideration of grant program  consolidations.
For our first reporting objective, we conducted a literature review which  consisted of reviewing the federal government websites  USAspending.govGrants.gov, the Catalog of Federal Domestic  and  Assistance (CFDA), and prior presidential budget submissions and  conference reports. We also reviewed our prior grant management  reports, along with reports from the Congressional Research Service, the  Congressional Budget Office, and the Federal Funds Information for  States (FFIS) database. We reviewed public laws to clarify when we had  identified a potential consolidation through one of these sources. The list  we developed represents our best effort to comprehensively identify all  grants consolidated from fiscal year 1990 through fiscal year 2012.  However, it is possible other grants were consolidated during this time  that our methodology did not identify. We selected 1990 because federal,  state, and local officials working in these program areas may be more  aware of the consolidations that happened at or after that time than  before it.  During our review, we identified that some of the grants on our  list were consolidated using hybrid approaches, and we interviewed  officials at OMB to learn more about these approaches. In conducting this  research, we intentionally excluded grant waivers: while we have  previously reported on them, for this engagement we concluded they  were generally for narrow administrative purposes or specific grant waiver  cases were unrelated to our scope.
Further, for our second and third objectives, we conducted three case  study reviews in four states (and selected localities) to examine how  selected consolidated grant programs were administered. The selected  locations and grant program consolidations are not generalizable, but  they provided important insights about grant consolidations.
Selected grant consolidated programs: We selected two grant  programs—the Department of Housing and Urban Development (HUD)  Continuum of Care (CoC) program and the Department of Transportation  (DOT) Transportation Alternatives (TA) program—in part because they  were both consolidated in the past 6 years, thus increasing the likelihood  of receiving sufficient program information (programs consolidated more  than 6 years ago are less likely to have sufficient information in part  because there are fewer agency officials in the appropriate positions who  oversaw the program). We selected the Environmental Protection Agency  (EPA) National Environmental Performance Partnership System (NEPPS)  because the approach used to consolidate it was different than the other  approaches; in addition, at the time we selected our programs, it was the  only performance partnership established we identified. For purposes of  this report, we considered these three to be consolidated grant programs  because they were identified as such through our literature review. We  reviewed federal data for each program—such as state population and  state grant award amounts—and considered other factors, such as  geographic dispersion, agency documents, our prior reports, and likely  travel costs. For each of the selected programs, we conducted either in- person or telephone interviews with state and local grant officials. To  interview the federal officials involved with these programs, we developed  a semi-structured data collection instrument to ensure uniform data  collection. Furthermore, the Departments of Labor, Health and Human  Services and Education and Related Agencies Appropriations Act for  fiscal year 2014 provided authority for those entities receiving funds under  the act to establish up to 10 Performance Partnership pilots designed to  improve outcomes for disconnected youth.  During our case study  review, we learned that OMB is leading this initiative and we met with  OMB officials to better understand this pilot.
Selected states and entities: After selecting the programs, we chose  four states—and local entities in each—to conduct a case study review of  how the programs were being implemented. The four states we selected  were Colorado, Delaware, Florida, and Massachusetts. To select the  states, we conducted interviews with subject matter specialists seeking  location recommendations for each of the selected programs, including  interviews with federal officials who oversee the grant programs and  relevant national associations. We also reviewed federal agency  documents and data for each program which contained either state  specific participation or funding and we reviewed prior reports we have  issued on the selected programs and we considered other factors such as  states where we have previously conducted prior grant work. To select  localities in each state, we used a similar method.
Table 5 provides details about the states and selected entities included in  our review.
Lessons learned. For objective 3, to analyze lessons learned for future  consideration of grant program consolidations, we reviewed existing  literature pertaining to grants management and identified key questions to  consider when evaluating grant program consolidations, and attributes for  conducting a program consolidation evaluation. In addition, we  interviewed agency officials and reviewed legislation and best practices  developed in our prior reports and OMB memos.
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
paragraphs: Susan J. Irving, (202) 512-6806 or irvings@gao.gov.
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Stanley J. Czerwinski, William J.  Doherty (Assistant Director), and Sandra L. Beattie (Analyst-in-Charge),  supervised this review and the development of the resulting report. Alicia  P. Cackley, Steven L. Cohen, James Cook, Deirdre Duffy, Karin K.  Fangman, Susan E. Iott, Donna Miller, Cynthia Saunders, and Paul J.  Schmidt made key contributions to this report.
section_title: Related GAO Products
paragraphs: 2014 Annual Report: Additional Opportunities to Reduce Fragmentation,  Overlap, and Duplication and Achieve Other Financial Benefits.  GAO-14-343SP. Washington, D.C.: April 8, 2014.
Grants Management: Improved Planning, Coordination, and  Communication Needed to Strengthen Reform Effort. GAO-13-383.  Washington, D.C.: May 23, 2013.
Homelessness: Fragmentation and Overlap in Programs Highlight the  Need to Identify, Assess, and Reduce Inefficiencies. GAO-12-491.  Washington, D.C.: May 10, 2012.
Managing For Results: Key Considerations for Implementing Interagency  Collaborative Mechanisms. GAO-12-1022. Sept. 27, 2012.
Grants to State and Local Governments: An Overview of Federal Funding  Levels and Selected Challenges. GAO-12-1016. Washington, D.C.: Sept.  25, 2012.
Justice Grant Programs: DOJ Should Do More to Reduce the Risk of  Unnecessary Duplication and Enhance Program Assessment.  GAO-12-517. Washington, D.C.: July 12, 2012.
Streamlining Government: Questions to Consider When Evaluating  Proposals to Consolidate Physical Infrastructure and Management  Functions. GAO-12-542. Washington, D.C.: May 23, 2012.
State and Local Governments: Fiscal Pressures Could Have Implications  for Future Delivery of Intergovernmental Programs. GAO-10-899.  Washington, D.C.: July 30, 2010.
Grants Management: Enhancing Accountability Provisions Could Lead to  Better Results. GAO-06-1046. Washington, D.C.: Sept. 29, 2006.
Results-Oriented Cultures: Implementation Steps to Assist Mergers and  Organizational Transformations. GAO-03-669. Washington, D.C.: July 2,  2003.
Federal Assistance: Grant System Continues to Be Highly Fragmented.  GAO-03-718T. Washington, D.C.: April 29, 2003.
Homelessness: Consolidating HUD’s McKinney Programs.  GAO/T-RCED-00-187. Washington, D.C.: May 23, 2000.
Welfare Programs: Opportunities to Consolidate and Increase Program  Efficiencies. GAO/HEHS-95-139. Washington, D.C.: May 31, 1995.
Program Consolidation: Budgetary Implications and Other Issues.  GAO/T-AIMD-95-145. Washington, D.C.: May 23, 1995.
Block Grants: Characteristics, Experience, and Lessons Learned.  GAO/HEHS-95-74. Washington, D.C.: Feb 9, 1995.
State Rather Than Federal Policies Provided the Framework for  Managing Block Grants. GAO/HRD-85-36. Washington, D.C.: March 15,  1985.
Lessons Learned from Past Block Grants: Implications for Congressional  Oversight. GAO/IEP-82-8. Washington, D.C.: September 23, 1982.