Drug-Free Communities Support Program: Agencies Have Strengthened Collaboration but Could Enhance Grantee Compliance and Performance Monitoring
Published: 2017-02-07T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: In 2015, approximately 2.2 million adolescents aged 12 to17 were current users of illicit drugs. The Drug-Free Communities Act of 1997 established the DFC Support Program—a federal grant program supporting drug abuse prevention efforts that engage schools, law enforcement, and other sectors of a community. The program targets reductions in the use of alcohol, tobacco, marijuana, and the illicit use of prescription drugs. The Office of National Drug Control Policy Reauthorization Act of 2006 includes a provision that GAO routinely assess ONDCP's programs and operations.
This report addresses: (1) the extent to which ONDCP and SAMHSA use leading practices to coordinate program administration and the types of activities funded; and (2) the extent to which ONDCP's and SAMHSA's' operating procedures both ensure DFC grantees comply with governing statutes and provide a basis for performance monitoring. To conduct this work, GAO analyzed agency policies from 2013-2015 (most recent available); interviewed agency officials; and analyzed coordination efforts against relevant key practices GAO identified previously. GAO reviewed files obtained from a non-generalizable random sample of 30 grantees and interviewed a random subset of 10.
section_title: What GAO Found
paragraphs: The Office of National Drug Control Policy (ONDCP) and the U.S. Department of Health and Human Services' Substance Abuse and Mental Health Services Administration (SAMHSA) employ leading collaboration practices to administer the Drug Free Communities (DFC) Support Program and have funded a range of drug prevention activities. Both agencies have improved their collaboration since GAO last reported on the DFC program in 2008. Their current efforts to jointly manage the DFC Support program are consistent with GAO's relevant key collaboration practices. For example, ONDCP and SAMHSA defined and agreed upon common outcomes, such as prioritizing efforts to increase participation from under-represented communities. The two agencies have also funded a range of DFC grantees' activities and report on these activities in their annual evaluation reports. For example, ONDCP reported that from February through July 2014, grantees educated more than 156,000 youth on topics related to the consequences of substance abuse. To illustrate, the 10 grantees GAO interviewed described their specific efforts, including programs for
Enhancing Skills: To enhance the skills of those in the community, one grantee sponsored a session for local realtors on precautions to take when preparing for open houses—warning them that leftover prescriptions in medicine cabinets present the potential for abuse among those walking through the home for sale.
Enhancing Access/Reducing Barriers: To reduce cultural barriers, another grantee developed signs with text in the multiple languages spoken throughout the community that shopkeepers could display to emphasize the legal purchase age for alcohol.
Providing Information: To provide greater information to parents on the consequences of providing alcohol in their homes, a grantee created a slogan to remind parents of their children's needs, “Be my Parent, not my Bartender.”
The agencies have operating procedures in place, but could enhance grantee compliance and performance monitoring. In particular, SAMHSA does not consistently follow documentation and reporting procedures to ensure grantees' compliance with governing statutes. SAMHSA also has not been accurately reporting to ONDCP on grantee compliance. Specifically for the files GAO reviewed, SAMHSA followed all processes for ensuring that initial applicants had submitted required documentation before awarding them initial grant funding. However, SAMHSA was less consistent in adhering to procedures for confirming documentation in later years of the program. For example, 14 of the 18 grantees that should have had sustainability plans in their files did not. These plans outline how the grantee intends to maintain necessary resources to achieve long-term goals after exiting the program. Prior to GAO's review, ONDCP and SAMHSA officials were not aware of the missing data in the grant files. Without close adherence to existing procedures, and a mechanism to ensure that the documentation it reports to ONDCP is accurate and complete, SAMHSA's performance monitoring capacity is limited and it cannot be certain that grantees are engaging in intended activities and meeting long-term goals.
section_title: What GAO Recommends
paragraphs: GAO recommends that SAMHSA develop an action plan with time frames to strengthen DFC grant monitoring and ensure it sends complete and accurate information to ONDCP. SAMHSA concurred with these recommendations and identified actions to address them.

section_title: Letter
paragraphs: In 2015, approximately 2.2 million adolescents aged 12 to 17 were  current users of illicit drugs, which represented nearly 9 percent of  adolescents in America. To help curb youth substance abuse, the Drug- Free Communities Act of 1997 established the Drug-Free Communities  (DFC) Support Program—a federal program providing grants for the  establishment of community-based, youth-focused, drug abuse  prevention efforts. The DFC Support Program focuses its efforts on the  prevention and reduction of the use of four primary substances, referred  to in this report as drugs: (1) alcohol, (2) tobacco, (3) marijuana, and (4)  the illicit use of prescription drugs. The Office of National Drug Control  Policy (ONDCP) administers the DFC Support Program, in coordination  with the U.S. Department of Health and Human Services’ Substance  Abuse and Mental Health Services Administration (SAMHSA). In addition,  ONDCP is responsible for, among other things, overseeing and  coordinating the implementation of the Administration’s national drug  control strategy.
The Office of National Drug Control Policy Reauthorization Act of 2006  includes a provision that we routinely assess ONDCP’s programs and  operations. In 2008, we reported on the DFC Support Program and  found weaknesses in grant program administration. We recommended that ONDCP (1) strengthen internal controls; (2) ensure that funded grant  applicants satisfy statutory eligibility criteria; and (3) more clearly define  its own and SAMHSA’s roles and responsibilities. ONDCP agreed and  has made significant improvements and implemented all three  recommendations. This report addresses: (1) the extent to which ONDCP  and SAMHSA use leading practices to coordinate program administration  and the types of activities the DFC Support Program recently funded; and  (2) the extent to which ONDCP’s and SAMHSA’s operating procedures  both ensure DFC grantees comply with governing statutes and provide a  basis for performance monitoring.
To assess the extent to which ONDCP and SAMHSA use leading  practices to coordinate program administration, we analyzed relevant  documentation, such as policies and procedures including ONDCP’s and  SAMHSA’s inter-agency agreements for fiscal years 2013, 2014, and  2015 (the most recent data available). In addition, we interviewed officials  responsible for the management of the DFC Support Program to discuss  ONDCP’s and SAMHSA’s collaboration practices and assessed them  against leading practices from prior GAO work. We used a subset of  three key practices among the eight key practices previously reported  because we identified these three as the most relevant to the scope and  nature of ONDCP’s and SAMHSA’s partnership. To determine the types  of activities the DFC Support Program has recently funded, we reviewed  grant files from a non-generalizable random sample of 30 grantees from  fiscal year 2015. (See below for more specific details about sample  selection.) We reviewed documents in these files to identify the nature  and frequency of key activities that grantees reported semi-annually to  SAMHSA in their progress reports. We also analyzed an evaluation  summary report for grantees funded in fiscal year 2013 that an ONDCP  contractor produced to gather additional detail on grantees’ activities and  spoke with the contractor for more details on how the information was  collected and summarized. In addition, we interviewed a subset of 10  grantees that we selected at random from our file review sample to gain  greater insights into the specific activities and initiatives in which they  engaged, as well as to learn more about their interactions with agency  officials who oversee the DFC Support Program.
To assess the extent to which ONDCP’s and SAMHSA’s grant  administration procedures ensure grantees comply with governing  statutes and the agencies have program controls in place to provide a  basis for monitoring and reporting on grantee performance, we reviewed  and analyzed agency policies, guidance documents, and procedures that  were in effect for fiscal years 2013, 2014, and 2015. We then assessed  these procedures and controls against Standards for Internal Control in  the Federal Government. Further, we reviewed the files we obtained  from the non-generalizable sample of 30 out of 697 grantees awarded  funds in fiscal year 2015. Additionally, since in any given year, some  grantees will be first time grant recipients and others will be more tenured,  we widened our review to include the files for fiscal years 2013 and 2014  for any selected grantee in continuation status. Overall, our review  included 79 individual grant files for the 30 selected grantees. Since an  individual DFC Support Program grantee can be in any year of two 5-year  cycles, we divided grantees into three categories—years 1 and 6 of the  grant; years 2 through 5; and years 7 through 10. This categorization also  aligned with how the program establishes grantee documentation  requirements, since for each category the program requires different  forms and reports from grantees. We then randomly selected 10 grantees  from each category. Specifically, we reviewed and analyzed the more  than 20 types of required documents to assess the extent to which the  agencies follow their policies and procedures and ensure grantee  compliance. We also assessed the reliability of data included in the grant  files by interviewing agency officials responsible for maintaining and  managing the systems that store and produce the data. We determined  that the data were sufficiently reliable for the purposes of our reporting  objectives.
We conducted this performance audit from January 2016 to February  2017 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: DFC Support Program Goals
paragraphs: The DFC Support Program’s two major goals are to:  1.  establish and strengthen collaboration among communities, private  non-profit agencies, and federal, state, local, and tribal governments  to support the efforts of community “coalitions” to prevent and reduce  substance abuse among youth; and   2.  reduce substance abuse over time among youth and adults by  addressing the factors in a community that increase the risk of  substance abuse and promoting the factors that minimize the risk of  substance abuse.
Coalitions receiving grant funds through the program are obliged to make  progress toward four core outcome measures. These relate to the  prevalence of drug use among youth in their communities over the past  30 days, youth’s perceptions of the risk, and the separate perceptions of  parental and peer disapproval of drug use—each of which is discussed  later in the report.
section_title: Coalition Composition
paragraphs: Under the DFC Support Program, ONDCP provides federal grants to  coalitions that have established sustainable and accountable anti-drug  efforts involving every major sector of a community, such as law  enforcement and schools. For the purposes of this report we refer to  coalitions as grantees. According to ONDCP officials, a DFC coalition is  collaboration among groups, such as parents and businesses who agree  to work together toward a common goal of building a safe, healthy, and  established through a locally‐based arrangement for cooperation and  drug‐free community. DFC grants are intended to support community  based coalitions and the activities they carry out. Funds are granted to  the coalition, not a particular sector or sector member.
DFC coalitions are broad-based groups consisting of representatives of  youth, parents, businesses, the media, law enforcement, religious or  other civic groups, health care professionals, and other organizations  involved in reducing substance abuse in their communities, especially  among youth—as illustrated in figure 1.
section_title: DFC Support Program Grant Types
paragraphs: ONDCP funds four types of DFC Support Program grants: (1) New; (2)  Continuation; (3) Mentoring; and (4) Mentoring Continuation. For the  purposes of this review, we focused on New and Continuation DFC  grants as they constitute the majority of grants awarded.   1.  New grants represent those openly competing for their 1st or 6th year  of DFC funding.  2.  Continuation grants represent annual “in-cycle” grants for years 2  through 5, or 7 through 10 of DFC funding.  3.  Mentoring grants represent the first in a 2-year grant awarded to  existing coalitions to support their work to create new DFC coalitions.   Mentoring Continuation grants represent the second year of the 2- year award.  4.  Each new and continuation grant awards up to $125,000 per fiscal  year and mentoring grants limit awards to $75,000 per fiscal year.
By statute, eligible coalitions may receive a new grant for 1 year and then  apply for a 1-year continuation grant in each of the subsequent 4 years— for a total first round grant period of 5 years. After the first 5 years,  grantees can apply again for a second 5 year round—the maximum  allowable term is 10 years—and the 6th year begins with another new  grant. Grantees can apply for continuing grants again in each of the 4  years thereafter. According to ONDCP, it bases decisions on whether or  not to continue a grant on the extent to which the coalition has (1) made  satisfactory progress in its efforts to reduce youth substance abuse and  (2) complied with all the terms and conditions of its award.
section_title: Applicant Eligibility Criteria and Program Requirements
paragraphs: To meet the statutory requirements of the DFC Support Program for initial  eligibility—years 1 and 6—a coalition must:  submit an application to the ONDCP Administrator;  consist of one or more representatives from each of the 12 sectors— at least one representative per sector—as illustrated in figure 1; demonstrate that the representatives of the coalition have worked  together on substance abuse reduction initiatives for at least 6 months  (prior to applying); demonstrate substantial participation from volunteer leaders in the have as its principal mission the reduction of substance abuse in a  comprehensive and long-term manner, with a primary focus on youth  in the community; describe and document the nature and extent of the substance abuse  problem in the community; provide a description of the substance abuse prevention and  treatment programs and activities underway at the time of the grant  application and identify substance abuse programs and service gaps  in the community; develop a strategic plan to reduce substance abuse among youth;  and work to develop a consensus regarding the priorities of the  community to combat substance abuse among youth; establish a system to measure and report outcomes;  conduct an initial benchmark survey of drug use among youth and  provide assurances that the entity conducting the evaluation has  sufficient experience in gathering data related to substance abuse  among youth or in evaluating the effectiveness of community anti-drug  coalitions; and demonstrate that the coalition is an “ongoing concern” by  demonstrating that it has established itself as an appropriate legal  entity or organization that receives financial support from non-federal  sources and has a strategy to solicit substantial financial support from  non-federal sources after the expiration of the grant term.
For additional information on the statutory requirements for the DFC  Support Program, see table 2 in appendix I.
In addition to meeting statutory eligibility requirements, grantees must  also comply with DFC Support Program terms and conditions. For  example, the program requires that grantees must develop a  comprehensive 12-Month Action Plan that includes an appropriate  strategy for each drug they will be addressing—as well as a mechanism  for demonstrating their progress along the way. Further, two grantees  may not serve the same zip code, unless both have clearly demonstrated  a plan for collaboration. For more information on the additional program  requirements for the DFC Support Program, see table 3 in appendix I.
section_title: Total DFC Support Program Spending and Grants Management Structure and Processes
paragraphs: In fiscal year 2015, the DFC Support Program’s appropriated budget was  approximately $93.5 million, representing just under a quarter of  ONDCP’s total budget of about $375 million. As table 1 shows, the total  number of DFC Support Program grants increased each fiscal year from  2013 to 2015.
According to ONDCP, since the passage of the Drug-Free Communities  Act in 1997, the DFC Support Program has funded more than 2,000  coalitions and mobilizes nearly 9,000 community volunteers across the  country.
ONDCP and SAMHSA have operated the grant program through an inter- agency agreement since 2005 that they update annually. Specifically,  ONDCP oversees the strategic planning, bi-annual progress reporting,  funding of the DFC Support Program, and SAMHSA conducts day-to-day  administration, such as interacting with grantees on a regular basis and  reviewing their activities. SAMHSA, as directed by ONDCP also awards a  grant to the Community Anti-Drug Coalitions of America (CADCA), which  provides technical assistance and training to grantees in order to enhance  their capacity. For example, CADCA trains grantees in effective  community problem-solving strategies and teaches them how to assess  their local substance abuse-related problems and develop responsive  action plans.
The DFC Support Program operates on a yearly grant cycle, working  through a given calendar year. The DFC grant life cycle follows a typical  federal grant life cycle, as shown in figure 2.
ONDCP and SAMHSA require grantees to submit semi-annual progress  reports through an ONDCP system called DFC Management and  Evaluation (DFC Me). These reports contain descriptions of the activities  the grantees conducted in supporting the program’s two broad goals, as  well as their progress against the program’s four core measures: 1.  Past 30-Day Prevalence of Use—youth who reported use of alcohol,  tobacco, marijuana, or illicit use of prescription drugs at least once in  the past 30 days.  2.  Perception of Risk—youth who reported that the use of alcohol,  tobacco, marijuana, or illicit use of prescription drugs is harmful.  3.  Perception of Parental Disapproval—youth who reported their parents  feel the regular use of alcohol, tobacco, and marijuana, or illicit use of  prescription drugs is wrong or very wrong.  4.  Perception of Peer Disapproval—youth who reported their friends  thought it would be “wrong or very wrong” for them to drink alcohol,  engage in any tobacco or marijuana use, or illicit prescription drug  use. See appendix II for additional details on ONDCP’s core  measures.
As we have previously reported, conducting grant management  processes like those illustrated above, in accordance with internal control  standards, statutory requirements, and leading practices for collaborating  agencies is essential for achieving program outcomes.
section_title: ONDCP and SAMHSA Employ Leading Collaboration Practices and Have Funded a Range of Drug Prevention Activities ONDCP and SAMHSA Use Leading Practices for Interagency Collaboration
paragraphs: ONDCP’s and SAMHSA’s efforts to jointly manage the DFC Support  Program are consistent with relevant, key collaboration practices.  Specifically, in our prior work, we have found that collaboration is  enhanced when partners follow certain key practices, such as (1) defining  a common outcome, (2) agreeing on roles and responsibilities, and (3)  establishing compatible policies, procedures, and other means to operate  across agency boundaries. We have also recognized in prior work that  collaborating agencies should work together to define and agree on their  respective roles and responsibilities, including how the collaborative effort  will be led, designating a lead body, establishing oversight for the  initiative, and employing mechanisms to implement their efforts.
subsections: section_title: DFC Grantee Activities Include Drug Abuse Education Campaigns and Efforts to Reduce Access and Strengthen Enforcement
paragraphs: DFC grantees have engaged in a range of activities, including drug abuse  education campaigns and efforts to enhance enforcement, and they  report on these activities in their semi-annual progress reports to  SAMHSA. ONDCP, through its contractor, routinely reviews the nature  and scope of these activities to ensure they fit within one of the Seven  Strategies for Community Change. For example, according to ONDCP,  one of these seven strategies is “providing information.” As ONDCP  reported, from February 2014 through July 2014, to execute this strategy,  grantees held 7,338 face-to-face information sessions on topics such as  the consequences of youth substance abuse and the importance of drug  abstinence, reaching almost 138,000 adults and more than 156,000  youth. Figure 3 illustrates the DFC Support Program’s overarching goal,  its specific program goals, ONDCP’s seven strategies for goal attainment,  and examples of grantees’ activities aligned with each.
Our review of grant files from 30 grantees also revealed diversity in terms  of specific activities within the seven strategic categories. For example,  grantees reported conducting alcohol prevention outreach activities and  events for parents; implementing a county-wide marijuana prevention  media campaign; and implementing prescription drug take-back, or  collection, events. We also spoke with 10 of the 30 grantees to discuss,  among other things, how they are using their funds to implement one or  more of the seven program strategies. Some examples include the  following.
Providing Support: To provide support to youth working on  prevention and education efforts, a grantee sponsors a “Yearly Youth  Summit,” which is organized partially by their 20 member youth  coalition. The youth coalition selects the topics and guest speakers for  the summit and invites up to 75 peers who discuss and brainstorm  ideas for activities and ways to address a specific substance abuse  problem at their school. Additionally, tables are assigned to  encourage communication outside an individual’s immediate peer  group.
Enhancing Skills: To enhance the skills of those in the community to  be on alert for and vigilant against potential drug abuse, one grantee  sponsored a session for local realtors on precautions to take when  preparing for open houses—warning realtors that leftover prescription  drugs in medicine cabinets present the potential for abuse among  those walking through the home for sale.
Enhancing Access/Reducing Barriers: To reduce cultural barriers,  one grantee developed signs emphasizing the legal purchase age for  alcohol in multiple languages to respect the diversity of languages  spoken across its community—as seen in figure 4. The grantee then  provided these signs to local business owners.
Providing Information: To provide greater information to parents on  what drug prevention steps they could take, one grantee chose to  address the challenges parents may face when hosting teenage  parties at their home. Specifically, this grantee worked with its youth  group to identify house parties as a concern in the community and  provided parents with information on the consequences of providing  alcohol and youth alcohol consumption. The grantee used the slogan  to remind parents of their children’s needs: “Be my Parent, not my  Bartender,” which they told us parents found particularly compelling.
Changing Consequences: To change consequences for adults who  host underage drinking parties, another grantee launched an  anonymous tip line called “QuikTip,” which led to tips coming in daily  to their local 911 call center. One outcome resulting from the QuikTip  line was that a New Year’s underage drinking party was reported,  which led to law enforcement being dispatched to the party.
Modifying/Changing Policies: To modify or enforce policies among  its local businesses, one grantee partnered with the District Attorney’s  office to create a task force that included business owners, local  policy makers, and youth coalition members. This task force made it a  priority to ensure that all clerks selling alcoholic beverages were  taking mandatory beverage service training and also worked to gain  buy-in among task force participants for an increase in alcohol policy  compliance checks. The grantee drew upon its 18- to 20-year old  members to assist in testing store clerks’ adherence to the under  aged drinking laws.
Changing Physical Design: To change the appearance of alcoholic  beverage packages, another coalition reported that its youth group  created stickers as part of a “Keep It Legal” campaign. The group  designed and helped place approximately 540 stickers on alcoholic  items sold throughout the community that contained a message about  the legal drinking age and the consequences of alcohol  consumption—as shown in figure 5.
section_title: Agencies Have Established Operating Procedures but Could Enhance Grantee Compliance and Performance Monitoring ONDCP and SAMHSA Developed Procedures to Help Ensure Compliance with Statutory Requirements
paragraphs: ONDCP and SAMHSA have developed standard operating procedures to  collect relevant information from new applicants and current grantees and  to document grantees’ compliance with eligibility requirements in  governing statutes. Per the IAA between ONDCP and SAMHSA,  SAMHSA is charged with collecting, analyzing, and reporting the status of  grantees’ compliance to ONDCP. The agencies require substantial  documentation from grantees in terms of initial and continuing grant  applications. Some examples include:
A grant application, which includes a grantee’s mission statement,  description of its projects, and a 12-month action plan outlining its  focus areas and planned activities;
Detailed budget narrative and budget sections that accompany the  application. These documents, in part, identify sources of non-federal  matching funds that grantees receive to meet the DFC funds matching  requirement;
Resumes and job descriptions for key personnel, such as the program  director and project coordinator;
Coalition involvement agreements from representatives for all 12  sectors to indicate compliance with the statutory requirement;
Two sets of coalition meetings minutes per year, with attendees listed  out, to demonstrate coalition membership involvement;
Submission of documentation and verification of the organization’s  non-profit status, such as maintaining a 501(c)(3) status;
Semi-annual progress reports through DFC Me to provide accurate  and meaningful statistical representation of youth surveyed on the  core measures and activities in each of the geographical areas served  by the coalition;
Quarterly and annual Federal Financial Reports that demonstrate  compliance with the grant’s purposes by accurately documenting its  funds transactions;
Sustainability plans—required for grantees in year 3 or year 7 of the  grant life cycle to show progress to achieve self-sustainment after  completing the DFC Support Program; and
Letter of Mutual Cooperation between the coalitions with the  identification of zip codes served (if applicable) that requires grantees  to outline their collaborative efforts.
According to ONDCP and SAMHSA officials, their procedures require that  all of this documentation is to be stored and safeguarded in SAMHSA’s  databases to preserve the record of the grant. The procedures also  require that SAMHSA grant management officials review these grantee  files to continually monitor grantees’ compliance with eligibility criteria and  for SAMHSA to report to ONDCP on any grantee compliance issues.  According to the officials, collecting these documents and ensuring that  files are complete and accurate also assists with monitoring the grantees’  progress in implementing their stated strategies and action steps.
In addition to the documentation required to help ensure grantees’  statutory compliance, ONDCP and SAMHSA developed specific DFC  Support Program terms and conditions. They also have procedures in  place to help ensure grantees are meeting these requirements. For  example, one term and condition of the grant is that grantees must agree  in writing to comply with federal grant requirements through the use of a  checklist from the U.S. Department of Health and Human Services— SAMHSA’s parent agency. ONDCP and SAMHSA then developed a  process to track submission of this checklist, which likewise applies to the  submission of all other required documents. Specifically, SAMHSA is to  monitor grantees to ensure receipt of the document and when a grantee  has not submitted it, SAMHSA’s grant management specialists are to  reach out to request it again. If grantee noncompliance becomes an  issue, then SAMHSA is to report the concern to ONDCP during routine  meetings and by documenting it in a tracking spreadsheet for ONDCP’s  review.
In addition to procedures in place to help monitor grantees’ compliance  with statutory provisions and other terms and conditions of the grant,  performance measures and procedures were established to obtain and  analyze grantee performance. The procedures include (1) a system to  collect data from the grantees on performance measures, and (2) a  contract with an evaluation agency to analyze and summarize the  performance measures data. Specifically, ONDCP, through its contractor,  conducts and issues a national evaluation report based on data collected  by grantees. The evaluation report, published annually, provides  information on two sets of data: (1) the activities grantees reported, and  (2) the outcome data reflecting change on the DFC four core measures,  using both qualitative and quantitative data collection and analysis. See  appendix II for additional details on the four core measures and trends in  grantees’ outcomes.
subsections: section_title: SAMHSA Has Not Consistently Followed Documentation and Reporting Procedures
paragraphs: Based on our file review and analysis of the files encompassing the more  than 20 types of required documents from 30 grantees, we found that  SAMHSA does not consistently follow documentation and reporting  procedures to ensure grantees’ compliance with both the statutory  provisions and established grant program terms and conditions.  Specifically, we found that SAMHSA followed all processes for ensuring  that initial applicants had submitted the required documentation before  awarding these applicants their initial grant funding. However, SAMHSA  was less consistent in its adherence to procedures for confirming  documentation for grantees in later years of their grants. We also found  that SAMHSA did not effectively track grantee compliance and therefore,  had not been accurately reporting to ONDCP on the status of grantees’  required documentation.
To conduct our analysis, we reviewed the official grant files for 30  randomly selected grantees that received DFC Support Program funding  in fiscal year 2015. Since in any given year, some grantees will be first  time grant recipients and others will be more tenured, we widened our  review to include the files for fiscal years 2013 and 2014 for any selected  grantee in continuation status. Such a mix of grantees in different years  of funding allowed us to see variation in the content and depth of the  grant documents that ONDCP and SAMHSA require to be on file. For  example, all grantees, regardless of their tenure in the program, are  required to have progress reports on file. In contrast, only grantees who  recently applied for year 3 or year 7 funding, for example, are required to  have sustainability plans.
We found that SAMHSA adhered inconsistently to its documentation and  reporting procedures at different stages of grantees’ tenure. For example,  during our file review, we found that all of the 22 grantees in our sample  that should have had a complete initial application package in the official  grantee file generally had one. However, we also found that:
While all 30 grantees in our sample were required to submit progress  reports every 6 months, at least one report was missing for 26  grantees. Specifically, for the 30 grantees, a total of 128 semi-annual  reports should have been submitted and filed in the official grantee  file, but 83 were missing. According to SAMHSA officials, these  reports were missing because grantees lacked access to designated  databases where progress reports are uploaded. Specifically,  SAMHSA’s database—COMET—went offline in December 2014 and  was replaced by the DFC Management and Evaluation Tool (DFC  Me), which became operational in February 2016. SAMHSA officials  said they did not request progress reports from grantees during the  transition period between Coalition Online Management and  Evaluation Tool (COMET) and DFC Me, which lasted approximately  18 months. However, they were aware that ONDCP’s contractor  provided DFC grantees with an electronic template that allowed the  grantees to collect data and document their progress as required,  outside of the designated databases. In February 2016, ONDCP  requested all grantees to input their progress report information into  DFC Me, to include information covering the transition period. Prior to  that date however, SAMHSA staff did not request this information  from grantees and therefore, did not have it to conduct their  monitoring efforts. SAMHSA officials acknowledged that their staff did  not conduct the necessary follow up to ensure that the files were  stored in the updated system for record keeping purposes. SAMHSA  officials also acknowledged that they were not aware of the number of  reports from grantees that were omitted from the record.
Of the 26 grantees that should have had continuation application  packages in their official grantee files, 9 were missing the required  Federal Financial Report. The Federal Financial Report is a  document in which the grantee details its expenditures,  disbursements, and cash receipts. SAMHSA requires grantees to  submit the Federal Financial Report within 90 days of the fiscal year’s  end. SAMHSA officials acknowledged that the Federal Financial  Reports were likely missing because the grantees did not provide  them and SAMHSA staff did not follow up to obtain them. When we  discussed this finding with SAMHSA officials, they were unaware of  the omission.
Of the 18 grantees that should have had sustainability plans in their  official grantee files, 14 were missing the required plans. These  sustainability plans are to outline how the grantee intends to maintain  the resources necessary to achieve its long-term goals and continued  progress after exiting the DFC Support Program. According to  SAMHSA officials, 12 of the 14 grantees were missing the  sustainability plans because SAMHSA staff had not uploaded them to  the system of record, and the remaining 2 grantees never submitted  them and the grants management specialist did not follow up to obtain  the document. SAMHSA officials were unaware of these omissions.
SAMHSA’s policies and procedures require that the official award file  contain the formal, complete record of the history of an award, such as  documents that support verification of statutory eligibility. SAMHSA  officials also told us that its staff is responsible for ensuring that all files  are stored in a shared database system, in accordance with SAMHSA  policy. In addition, the IAA between ONDCP and SAMHSA outlines that  SAMHSA is responsible for ensuring grantees have submitted all required  documents, following up as needed, and reporting to ONDCP on  grantees’ status. According to ONDCP and SAMHSA officials, SAMHSA  did routinely relay reports to ONDCP on grantees’ status. However,  SAMHSA officials acknowledged that they were unaware that files were  missing, which calls into question the effectiveness of their program  monitoring. It also challenges the accuracy and validity of the grantee  status reports that SAMHSA provided to ONDCP. In particular, ONDCP  officials told us they were never made aware that any required grantee  documents were not included in the official record.
SAMHSA officials said that in March 2016, to strengthen their grants  administration process, they instituted a new internal review process in  which they randomly select 50 grant files per month from their various  grant programs to assess the completeness and accuracy of grantees’  documentation. As part of the internal review process, SAMHSA has also  taken other steps including enhancing training, developing policies and  procedures, and implementing a step-by-step guide and training for grant  managers on entering information into the official grant file. While this  review process had not included the DFC Support Program initially, in  November 2016, while our audit work was nearing completion, officials  said they were planning to expand their focus to incorporate all of  SAMHSA’s grant programs. While officials provided information on how  they planned to address particular deficiencies on a case by case basis,  they did not explain how they planned to ensure systemic remediation of  any issue found repeatedly or a timeframe for implementing the changes.  According to Standards for Internal Control in the Federal Government,  managers are to (1) promptly evaluate findings from audits and other  reviews, including those showing deficiencies and recommendations, (2)  determine proper actions in response to these findings and  recommendations, and (3) complete, within established time frames, all  actions that correct or otherwise resolve the matters brought to  management’s attention.  Ensuring this new review process is fully  implemented in a sustainable manner will be critical for SAMHSA as it  aims to strengthen DFC grants monitoring. Further, developing an action  plan with time frames for addressing any deficiencies it finds through its  reviews and making systemic changes to mitigate deficiencies on a  prospective basis will also help its management of the DFC program.
Further, Standards for Internal Control in the Federal Government states  that all transactions and other significant events need to be clearly  documented and should be readily available for examination. For the DFC  Support Program, such transactions include SAMHSA’s collection,  storage, and review of grantee documentation. It also includes  SAMHSA’s documentation and reporting of grantee status to ONDCP.  Additionally, control activities—policies, procedures, and mechanisms— should enforce management’s directives and help ensure that actions are  taken to address risks, such as ensuring DFC grantees are not remiss in  meeting statutory and program requirements. Related, internal controls  for monitoring should generally be designed to assure that ongoing  monitoring occurs in the course of normal operations. This includes  regular management and supervisory activities, comparisons, and  reconciliations. Deficiencies found during ongoing monitoring or through  separate evaluations should be communicated to the individual  responsible for the function and serious matters should be reported to top  management. Control activities like these should be an integral part of an  entity’s accountability for stewardship of government resources.  SAMHSA’s lack of follow up with grantees and its lack of visibility over  omitted documents resulted in incomplete and inaccurate documentation  of status in its reports to ONDCP. Without a method to ensure that  grantee status reporting to ONDCP is complete and accurate, SAMHSA  cannot be certain that grantees are engaging in intended activities, that  funds are being used in accordance with program requirements, and that  all other statutory requirements and grant program terms and conditions  have been met.
section_title: Conclusions
paragraphs: Since 2008, ONDCP and SAMHSA have taken steps to improve the DFC  Support Program by employing leading collaboration practices and  funding a variety of drug prevention activities. However, SAMHSA’s  inconsistent adherence to some procedures, particularly with respect to  grantees that are funded year after year, has resulted in the persistence  of missing or incomplete documentation in the official grantee files, which  has limited performance monitoring. Developing an action plan that  includes time frames for addressing deficiencies found through its grant  file reviews and making systemic changes based on its findings, as well  as developing a method for ensuring complete and accurate grantee  status reporting to ONDCP, would position SAMHSA officials to further  strengthen monitoring efforts. As the number of youth who engage in illicit  drug use remains a public health concern, the continued focus on funding  grantees and monitoring them for both progress and compliance is vital.
section_title: Recommendations for Executive Action
paragraphs: To better ensure grantees’ compliance with the Drug-Free Communities  Support Program’s statutory requirements and to strengthen monitoring of  grantee activities, we recommend that SAMHSA take the following two  actions: develop an action plan with time frames for addressing any  deficiencies it finds through its reviews and making systemic changes  to mitigate deficiencies on a prospective basis to strengthen the grant  monitoring process, and develop and implement a method for ensuring that the grantee status  reports it provides to ONDCP are complete and accurate.
section_title: Agency Comments and Our Evaluation
paragraphs: ONDCP and the Department of Health and Services (HHS) provided  written comments on a draft of this report. In their comments, both  agencies concurred with our recommendations. In HHS’s written  comments, reproduced in appendix III, HHS stated SAMHSA will  implement a targeted review focusing on the DFC files and strengthen its  grants management processes to ensure that the reports it provides to  ONDCP are timely and accurate. HHS also provided technical comments  which we incorporated where appropriate.
We are sending copies of this report to the Director of the Office of  National Drug Control Policy, the Secretary of Health and Human  Services, and appropriate congressional committees and members, and  other interested parties. In addition, this report is available at no charge  on GAO’s website at http://www.gao.gov.
If you or your staff have any questions, please contact Diana Maurer at  (202) 512-8777 or maurerd@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. GAO staff that made significant contributions to this report  are listed in appendix IV.
section_title: Appendix I: Drug-Free Communities (DFC) Support Program Statutory and Program Requirements
section_title: Appendix II: Drug-Free Communities Four Core Measures and Examples of Trends
paragraphs: The Office of National Drug Control Policy’s (ONDCP) Drug-Free  Communities (DFC) Support program requires grantees to report on four  core measures in progress reports semiannually as listed in table 4.
Grantees collect these core measure data and ONDCP provides it to its  contractor for national-level evaluation and reporting. For example, in the  National Evaluation of Drug-Free Communities Support Program  Summary of Findings through 2014, the percentage change in the past 30  days of drug use among middle school and high school youth is  evaluated and reported bi-annually. Figure 6 shows the trend in drug use  from 2002 through 2014.
Since the program added prescription drugs to the core measures in  2012, figure 7 captures the prevalence of prescriptions drugs in  comparison to alcohol, tobacco, and marijuana in fiscal year 2013.
section_title: Appendix III Comments from the Department of Health and Human Services
section_title: Appendix IV: GAO Contact and Staff Acknowledgements
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Joy Booth (Assistant Director),  Aditi Archer (Analyst-in-Charge), David Alexander, Lyle Brittain, Willie  Commons III, Dominick Dale, Eric Hauswirth, Anna Maria Ortiz, Jeffrey  Paulk, and Justin Snover made key contributions to this report.