Justice Grant Programs: DOJ Should Do More to Reduce the Risk of Unnecessary Duplication and Enhance Program Assessment
Released: 2012-07-12T00:00:00


Highlights: section_title: Why GAO Did This Study
paragraphs: Since fiscal year 2005, approximately $33 billion has been appropriated to DOJ for the administration of more than 200 federal financial assistance solicitations, such as grants, that support criminal justice activities at the state and local levels. Pursuant to section 21 of Public Law 111-139, this report addresses the extent to which (1) overlap exists across DOJ grant programs and if it contributes to the risk of unnecessary duplication in grant awards, (2) DOJ has taken steps to reduce overlap and the potential for unnecessary duplication in its grants awards, and (3) DOJ uses monitoring and assessment to determine grant program effectiveness and uses the results to enhance its grant programs. GAO assessed DOJ’s fiscal year 2010 announcements of grant award funding; categorized them according to key justice areas to identify any overlap; and interviewed DOJ officials about their grant making practices, systems, and assessment methods. Further, GAO interviewed officials from 11 states receiving DOJ grants, selected for the levels and types of funding received. Though not generalizable, the interviews provided their perspectives on funding.

section_title: What GAO Found
paragraphs: The Department of Justice’s (DOJ) grant programs overlap across 10 justice areas contributing to the risk of unnecessarily duplicative grant awards for the same or similar purposes. For example, GAO reviewed all 253 grant award announcements that DOJ’s Office of Justice Programs (OJP), the Office on Violence Against Women (OVW), and the Community Oriented Policing Services (COPS) Office published on their websites for fiscal year 2010 and found overlap across the justice areas. For example, 56 of DOJ’s 253 grant solicitations—or more than 20 percent—were providing grant funds for victim assistance and related research. GAO also found instances where applicants used the same or similar language to apply for funding from these overlapping programs. In one example, a grant recipient applied for, and received, funding from both OJP’s Internet Crimes Against Children program and the COPS Office’s Child Sexual Predator Program to provide training for cyber crime investigations and establish an Internet safety program. In some instances, DOJ may deem it appropriate for distinct grant programs to serve one goal, or for one community or grantee to benefit from multiple streams of grant funding. However, DOJ generally lacks visibility over the extent to which its grant programs overlap and thus is not positioned to minimize the risk of potential, unnecessary duplication before making grant awards.

DOJ has taken some actions that address overlap in its grant programs; for example, by requesting statutory authorization in some instances to consolidate programs that are similar. However, DOJ has not conducted an assessment of its grant programs to systematically identify and reduce overlap. Doing so would enable DOJ to identify program areas where overlap may be desirable and where a consolidation of programs may be more efficient. Further, OJP and OVW use a separate grants management system than the COPS Office uses, limiting their ability to share information on the funding they have awarded or are preparing to award to a recipient. According to COPS Office officials, its mission and grant management processes are unique enough to necessitate a separate system. However, OJP officials told GAO that its system has been and can be modified with minimal investment to accommodate different grant processes. DOJ has initiated a study to assess the feasibility, costs, and benefits of unifying the systems among other options. By ensuring that such a study accounts for the effort necessary to harmonize departmental grant processes, DOJ could ensure that variations in such processes do not encumber system unification.

DOJ’s Office of Audit, Assessment, and Management (OAAM) oversees monitoring of grantees’ compliance and conducts grant program assessments to gauge program effectiveness. GAO found that OAAM’s program assessments yield richer information than its monitoring reports because they identify improvement areas. OAAM officials believe additional assessments could be beneficial. They also said they lacked resources to conduct more, but had not conducted a feasibility analysis to confirm this. By OAAM examining its mix of monitoring and assessment activities, including the costs and benefits of current resource allocations, it could better ensure continuous improvement in grant programs.

section_title: What GAO Recommends
paragraphs: GAO recommends, among other things, that the department assess its grant programs for overlap, ensure its comprehensive study of DOJ grant management systems also includes an analysis of steps necessary to harmonize business processes, and examine its mix of grant monitoring and program assessment activities. DOJ agreed with GAO’s recommendations.

section_title: Letter
paragraphs: Since fiscal year 2005, approximately $33 billion has been appropriated  to support crime prevention, law enforcement, and crime victim services  through more than 200 federal financial assistance programs that the  U.S. Department of Justice (DOJ) manages. In fiscal year 2010, DOJ  awarded nearly $3.6 billion in grants through its three granting agencies— the Office of Justice Programs (OJP), the Office on Violence Against  Women (OVW), and the Community Oriented Policing Services (COPS)  Office. Many of the grant programs that OJP, OVW, and the COPS Office  administer are, pursuant to their originating statutes, similar in scope, and  grant applicants can apply for and receive grant awards from more than  one program. Moreover, statutes may also require that grant recipients  award a portion of their grants to subgrantees. Where statutes do not  require subgranting, a grantee may voluntarily choose to award all or a  portion of its funds to subgrantees. These subgrantees may also apply  directly to DOJ for funding through other grant programs for purposes that  are the same or similar to the purpose for which they received the  subgrant. The number of grant programs and recipients, and the billions  of dollars in funds awarded annually, present administrative challenges  for DOJ.

We have identified management of programs that support state and local  crime reduction efforts as a major performance and accountability  challenge for DOJ. We previously reported on evaluations of grant  programs to assist communities in addressing gang problems, and the  quality of DOJ’s tool to measure grantees’ performances under Recovery  Act funding for one of OJP’s largest grant programs. Moreover, the DOJ  Inspector General (IG) has listed grant management as one of the top 10  challenges for DOJ every year from 2000 through 2011 and has identified  overlap in grant programs and duplicative oversight and monitoring  services. Specifically, a 2003 IG audit found overlap in grant programs  between OJP and the COPS Office, which it noted resulted from statutes  that created multiple grant programs to fund similar justice areas. The IG  audit also found that no formal communication procedures between OJP  and the COPS Office existed to ensure that grantees did not receive  funds for similar purposes from both granting agencies and made  recommendations to address this coordination issue as discussed later in  this report. In addition, DOJ’s Acting IG testified in June 2011 that certain  monitoring and oversight performed by OVW and the COPS Office are  duplicative of services that are available through OJP.

As the United States experiences budgetary constraints, there is an ever- increasing need to ensure that governmental resources—including those  awarded through grants and subgrants—are appropriately targeted and  that overlap and unnecessary duplication are mitigated. In February 2012,  we reported that DOJ had not assessed its grant programs to identify  overlap and that DOJ did not routinely coordinate grant awards to avoid  unnecessary duplication. This report provides further elaboration on the  February 2012 report’s findings, as well as addresses DOJ’s ability to  assess the results of its grant programs.

To examine overlap and potential duplication within DOJ—and in support  of our ongoing efforts to explore duplication, overlap, and fragmentation  governmentwide(1) To what extent does overlap across DOJ grant programs exist and  contribute to the risk of unnecessary duplication in grant awards? (2) To  what extent has DOJ taken steps to reduce overlap in its grant programs  and the potential for unnecessary duplication in grant awards? (3) To  what extent does DOJ use grant monitoring and assessment to determine  grant program effectiveness and use the results to enhance its grant  programs?  —this report addresses the following three questions:  Using the framework established in our prior work addressing overlap and  duplication, we use the following definitions for purposes of assessing  DOJ’s grant programs:

Overlap occurs when multiple granting agencies or grant programs  have similar goals, engage in similar activities or strategies to achieve  these goals, or target the same or similar beneficiaries. Overlap may  result from statutory or other limitations beyond an agency’s control.

Duplication occurs on multiple levels. It occurs when a single grantee  uses grant funds from different federal sources to pay for the exact  same expenditure. Duplication also occurs when two or more granting  agencies or grant programs engage in the same or similar activities or  provide funding to support the same or similar services to the same  beneficiaries. Duplication thus stems from overlap. When granting  agencies do not identify overlap, assess its impact, or coordinate their  activities in acknowledgment of the overlap, there is a heightened risk  of unnecessary duplication because one granting agency may not  be knowledgeable of the ways in which its funding decision duplicates  another’s. At times, federal funding is leveraged by design to achieve  a single purpose through multiple federal funding streams. These  funding arrangements are not characterized as unnecessary  duplication for purposes of this review so long as federal agencies are  aware of them or have deliberately planned for grant programs to be  complementary.

To determine potential areas of overlap across DOJ’s grant programs, we  identified a total of 253 DOJ grant solicitations—announcements to  applicants of funding opportunities—for fiscal year 2010 by reviewing the  solicitation lists posted on the OJP, OVW, and COPS Office websites and  confirming the accuracy of the information with DOJ officials. We  established 10 categories of criminal justice areas and then sorted the  solicitations into each category to determine whether these solicitations  were announcing grant funding available for similar purposes. We  developed these 10 categories after reviewing comparable justice areas  identified within DOJ materials, such as a website it operates to discuss  criminal justice research and strategic planning documents. After  identifying solicitations with similar scopes, we reviewed a nonprobability  sample of 26 successful grant applications that were awarded under  similar solicitations to identify and assess specific examples of how the  recipients planned to use funds from multiple programs in the same or  similar manner and whether this creates the risk of unnecessary  duplication in DOJ grant funding. The sample was selected based upon  applicants receiving multiple grant awards from overlapping grant  programs. The sample we reviewed is not generalizable to all DOJ grant  programs because an ideal sample size based upon nearly 11,000  funded grant applications was impractical to select, review, and analyze.  However, the results from our sample illustrate the potential for  unnecessary duplication.

To examine the extent to which DOJ has taken action to reduce or  mitigate overlap and ensure that DOJ does not unnecessarily award  funds from multiple grant programs to support similar purposes, we  analyzed agency policies, procedures, and guidance, current as of 2012,  on grant program design and award, such as the OJP Grant Manager’s  Manual. In addition, we interviewed DOJ officials from OJP, OVW, and  the COPS Office to discuss, among other topics, their grant program  design and award processes and the extent to which they coordinate and  share information with one another. We also visited or conducted phone  interviews with officials from 11 states to discuss the type and timeliness  of information on grant awards and subawards that they provide to or  receive from DOJ. We selected these states based on the amount of  Edward Byrne Memorial Justice Assistance Grant (JAG) funding they  receive and the existence of other recipients in their communities  receiving DOJ discretionary grants for potentially similar purposes. The  results of these contacts are not generalizable to all states, but provided  insight into how DOJ grant funds were used locally and communication  occurred between states and DOJ. We also compared agency grant  design and award practices against Standards for Internal Control in the  Federal Government and promising practices identified in the Domestic  Working Group Grant Accountability Project’s Guide to Opportunities for  Improving Grant Accountability.

To analyze the extent to which DOJ uses grant monitoring and  assessment to determine program effectiveness and uses the results to  enhance its grant programs, we analyzed DOJ documentation, such as  assessments DOJ conducted of its programs and specific programmatic  grant monitoring reports. We also interviewed DOJ officials from the granting agencies, including those tasked with assessment, as well as  grantees responsible for measuring the effectiveness of grant programs  for OVW.

We conducted this performance audit from May 2011 to July 2012 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. Appendix I contains further  information on our scope and methodology.
subsections: section_title: Background
paragraphs: DOJ awards federal financial assistance to state and local governments,  for-profit and nonprofit organizations, tribal jurisdictions, and educational  institutions to help prevent crime, assist victims of crime, and promote  innovative law enforcement efforts. Federal financial assistance can take  the form of discretionary grants, formula grants, cooperative agreements,  and payment programs, which all are generally referred to as grants.  Grant programs are generally created by statute and funded through  annual appropriations. As such, Congress has a central role in  determining the scope and nature of federal financial assistance  programs. In addition, the Office of Management and Budget (OMB)  establishes general guidance which governs administration of all such  federal financial assistance and DOJ has flexibility in how to administer  assistance that is discretionary in nature.

In fiscal year 2010, DOJ provided direct grant funding to nearly 11,000  grantees.assistance.

section_title: DOJ Grant Programs Overlap, Contributing to the Risk of Unnecessarily Duplicative Grant Awards for the Same or Similar Purposes
subsections: section_title: DOJ’s Grant Solicitations Overlap across 10 Key Justice Areas
paragraphs: We reviewed all 253 of the fiscal year 2010 grant solicitations that OJP,  OVW, and the COPS Office published on their respective websites and  found overlap across 10 justice areas—as table 2 illustrates. These  solicitations announced funding available to grantees for criminal and  juvenile justice activities, including direct assistance for crime victims and  the hiring of police officers. These solicitations also announced funding  available for grantees to collect criminal justice data, conduct research, or  provide related training and technical assistance. We developed these  10 categories of justice areas after reviewing comparable justice areas  identified within OJP’s CrimeSolutions.gov website, which OJP officials  stated covers a variety of justice topics, including some topic areas that  OVW and the COPS Office fund; OJP’s Fiscal Year 2010 Program Plan;  and other materials from OVW and the COPS Office, such as justice  program themes from their respective websites. Within the justice areas,  a variety of activities—including research, direct service provision, or  technical assistance—can be conducted. We examined the purpose  areas of the 253 grant solicitations and then categorized them by justice  area.

In conducting this analysis, we recognize that overlapping grant programs  across common programmatic areas result in part from authorizing  statutes, and that overlap itself may not be problematic. However, the  existence of overlapping grant programs is an indication that agencies  should increase their visibility of where their funds are going and  coordinate to ensure that any resulting duplication in grant award funding  is purposeful rather than unnecessary. Overlap and the associated risk of  unnecessary duplication occur throughout the government, as we have  reported previously, and are not isolated to DOJ. However, when  coupled with consistent programmatic coordination, the risk of  unnecessary duplication can be diminished.

As table 2 illustrates, we found overlap across the various DOJ grant  programs. For example, 56 of DOJ’s 253 grant solicitations—or more  than 20 percent—were providing grant funds available for activities  related to victim assistance or to support the research and prevention of  violence against women. Eighteen of these 56 programs were  administered by offices other than OVW and OJP’s Office for Victims of  Crime. In addition, more than 50 percent of all grant solicitations  provided funding that could be used in support of the same three justice  areas—victim assistance, technology and forensics, and juvenile justice— indicating concentrated and overlapping efforts. The justice area with the  least overlap was juvenile justice, with 30 of 33 grant programs  administered by the Office of Juvenile Justice and Delinquency  Prevention.

There are some instances in which overlap occurs because of the statute  that established programs. Further, we recognize that overlap among  DOJ’s grant programs may be desirable because such overlap can  enable DOJ’s granting agencies to leverage multiple funding streams to  serve a single justice purpose. However, coordination across the  administering granting agencies is critical for such leveraging to occur. In  the section below, we discuss the ways in which overlapping grant  programs increase the risk of unnecessarily duplicative grant awards for  the same or similar purposes. In subsequent sections, we discuss the  steps DOJ has taken to enhance coordination and some ways in which  DOJ’s efforts can be improved.

section_title: In Some Instances, DOJ Awarded Grant Funding from Overlapping Programs to the Same Applicants for the Same or Similar Purposes
paragraphs: We found that in some instances, DOJ’s granting agencies awarded  multiple grants to the same grantees for the same or similar purposes.  Applicants can apply directly to DOJ for funding through a variety of grant  programs that DOJ announces annually. Recipients of such grant awards  are referred to as prime grantees. Since many of DOJ’s grant programs  allow prime grantees to award subgrants, applicants also can apply  directly to a prime grantee for award funding. As a result, prime grantees  receiving money from DOJ through one funding stream also can be  subgrantees receiving money from a prime grantee through another  funding stream. If an applicant, either as a prime grantee or as a  subgrantee, receives multiple grant awards from overlapping programs,  the risk of unnecessary duplication increases since the applicant may  receive funding from more than one source for the same or similar  purpose without DOJ being aware that this situation exists. Such  duplication may be unnecessary if, for example, the total funding received  exceeds the applicant’s need, or if neither granting agency was aware of  the original funding decision.

After reviewing a sample of 26 grant applications from recipients who  received funds from grant programs we identified as having similar  purpose areas, we found instances where applicants used the same or  similar language to apply for multiple streams of funding. For example,  one grant recipient applied for funding to reduce child endangerment  through cyber investigations from both the COPS Office’s Child Sexual   and OJP’s Internet Crimes Against Children  Predator (CSPP) Program(ICAC) program. In both of these applications, the applicant stated that it  planned to use the grants to increase the number of investigations in the  state, provide training for cyber crime investigations, serve as a forensic  resource for the state, and establish an Internet safety program. Further,  included in this applicant’s proposed budgets for both funding streams  were plans to purchase equipment, such as forensic computers and the  same specialized software to investigate Internet crimes against children.  Another grant recipient from a different jurisdiction also applied for  funding from OJP and the COPS Office programs to support the same  types of investigations. In a third instance, an applicant received fiscal  year 2010 grant funding for planned sexual assault victim services from  both OJP’s Office for Victims of Crime and OVW. The applicant used  similar language in both applications, noting that it intended to use the  funding to support child victim services through its child advocacy center.

After we shared these examples with DOJ, DOJ officials followed up with  the grant recipients involved and reported to us that the grantees were  not using awarded funds for duplicative purposes—which DOJ defines as  grantees using funds to pay for the exact same item. However, such  follow-up for the purpose of assessing duplication is not a routine practice  for DOJ. Further, DOJ’s narrow definition of duplication curtails it from  assessing the use of funds for the same or a similar overall purpose on a  grant project.

In fiscal year 2010, DOJ’s three granting agencies awarded nearly 11,000  prime grant awards, but officials told us that they do not consider the  flow of grant funds to subgrantees when making grant award decisions.  Because DOJ does not have visibility of the flow of funds to these  recipients, agency officials were not positioned to tell us what activities, or  for what purposes, the subgrantees were spending their federal funds.  Thus, to obtain more information, we surveyed JAG SAAs, who are  responsible for managing the subgrants they make, to obtain information  related to the purpose areas of their funding.

In our survey, we asked the JAG SAAs if they or their subgrantees used  grant funding in fiscal year 2010 for key justice areas such as funding sex  offender registry notification systems; correctional officer salaries, and  sexual assault services; purchasing bullet-resistant vests; and hiring  police officers. DOJ supports all of these areas through JAG, as well as  through targeted grant programs specifically addressing each of these  topics. On the basis of survey responses, we found several instances  where SAAs reported that JAG funds were used to support activities that  could have been funded through other DOJ grants. For instance, 11 of 50  responding SAAs, or 22 percent, reported that they or their subgrantees  used JAG funding to support correctional officer salaries. Further, 23 of  the 50 SAAs, or nearly 50 percent, reported that they or their subgrantees  used JAG funding to hire police officers, even though a separate DOJ  program dedicates funding exclusively to hiring law enforcement  personnel.

The COPS Office hiring grant awarded to this county was for fiscal year 2009. COPS  Office hiring grants last up to 3 years, and the county used the grant in fiscal years 2010  and 2011 as well. These grants support the hiring or the rehiring of career law  enforcement officers to increase community policing and crime prevention strategies. received funding for drug court–assisted substance abuse treatment and  mental health counseling through both a JAG program subaward and a  grant directly from OJP’s Adult Drug Court Grant Program. Officials from  one of these counties informed us that they received so much DOJ  funding from the two grant programs that it exceeded the county’s need  and they planned to return a portion to DOJ.

The IG has previously identified the risk of OJP and the COPS Office  funding duplicative grant awards. For example, in 2003, the IG identified  duplication between the COPS Office Hiring Program and the Local Law  Enforcement Block Grant Program, the predecessor to the JAG grant  program. The IG reported that while the COPS Hiring Grant program is  required to advance community policing, the Local Law Enforcement  Block Grant Program grants are sometimes used for the same or similar  purposes. According to the IG, in such cases the grants are duplicative. In 2010, the IG reported that it had identified potential overlap between  the COPS Office Hiring Recovery Program and OJP’s JAG Formula  Program and Edward Byrne Competitive Grant Program. As a result, the  IG recommended that the COPS Office work with OJP to avoid  duplication of future funding by coordinating closely on grantee selection  decisions, as discussed later in this report.

U.S. Department of Justice Office of the Inspector General, Audit Division, Streamlining  of Administrative Activities and Federal Financial Assistance Functions in the Office of  Justice Programs and the Office of Community Oriented Policing Services, Audit Report  03-27 (Washington D.C.: Aug. 2003).

section_title: DOJ Has Taken Actions That Address Overlap in Grant Programs but Could Further Reduce the Risk of Unnecessary Duplication in Grant Funding
subsections: section_title: DOJ Has Taken Some Action to Consolidate and Coordinate Similar Grant Programs
paragraphs: According to DOJ officials, the statutory creation of grant programs with  similar purposes requires grant design coordination within and among  DOJ’s granting agencies to limit the risk of unnecessary duplication from  overlapping programs. The primary purpose of consolidation or  coordination may not be to limit this risk, but officials reported that  reducing the risk may be a secondary benefit. Officials from all three  granting agencies stated that they meet with one another to coordinate  the goals and objectives of their grant programs, especially joint grant  programs that they believe are complementary. For example, the Bureau  of Justice Assistance and the Office for Victims of Crime issued a joint  solicitation for anti-human trafficking programs where each office issued  separate awards based on coordinated proposals from collaborating  police departments and community-based victim service organizations.  Further, according to officials, DOJ recently launched the Coordinated  Tribal Assistance Solicitation to provide a single application for most of  DOJ’s tribal grant programs.

Consolidating two programs with similar purposes into one, with unified  management, is the most comprehensive way to reduce overlap,  according to DOJ officials. However, they stated that the statutory  creation of grant programs with similar purposes can create  administrative challenges because in many cases, DOJ must seek  statutory authorization to discontinue or consolidate enacted programs  that DOJ believes may be overlapping. Officials told us they have sought  congressional action in a few instances for these purposes and will  continue to do so, but because the process is complex, they have also  taken administrative steps on an ad hoc basis to mitigate overlap of  purpose areas as illustrated in table 3.

Officials stated that they meet with one another when they determine it is  needed to coordinate the goals and objectives of their grant programs,  especially those programs that they believe are complementary. In  addition, an OJP official told us that in 2010 the office prioritized  coordination as 1 of its 10 management goals and cited benefits that  resulted from this focus, including reduced administrative costs, fewer  grant solicitations, and a reduced number of competitive grant peer  reviews. However, these officials told us that these coordination and  consolidation efforts, as well as those illustrated in table 3, do not occur  routinely.

section_title: DOJ Has Not Assessed Its Grant Programs to Identify and Reduce Overlap
paragraphs: Even with efforts to coordinate its programs, DOJ officials told us they  have not conducted a formal assessment or study of their grant programs  to determine if and to what extent they overlap and where opportunities  exist to more consistently pursue consolidation or better coordinate grant  programs. Further, we found that coordination among granting agencies  occurred on an ad hoc basis and that without an assessment of its  overlapping programs, DOJ was not well positioned to identify and  describe areas of potential for unnecessary duplication across its grant  programs.

A senior OJP official told us that the department had not formally  assessed or studied its grant programs to determine the extent of overlap  because of the significant investment of time and staff resources that it  would require. DOJ officials emphasized that since these programs were  statutorily established as distinct programs, they are not certain that any  attempt at harmonization—beyond what they have already done—would  be viable. For example, they said that in some cases, statutes creating  what may appear to be similar programs also create very different  eligibility criteria for grant applicants. Thus, the officials stated, some  programs may not be easily merged through administrative efforts such  as announcing similar grant programs in a single solicitation. We agree  that similar grant programs may have unique features that could render  grant consolidation or coordination impractical, but DOJ has not taken the  steps to catalogue all of its programs across each of the three granting  agencies, and then determine which have the potential to be consolidated  or coordinated and what barriers might exist to achieve such changes.

The IG continues to include DOJ’s grants management among its list of  top challenges affecting the department, and in previous reports, has  identified fragmentation and duplication among DOJ’s granting agencies  as an area of concern. Further, developing agency procedures to avoid  grant duplication is one of the promising practices that the federal  Domestic Working Group Grant Accountability Project suggested in its   Given the  Guide to Opportunities for Improving Grant Accountability.specific knowledge of these grant programs’ statutory authorities, their  histories of funding certain types of activities, and the nuances related to  their administration, officials within OJP, OVW, and the COPS Office are  uniquely positioned to assess their programs for overlap. Doing so could  yield positive dividends for the granting agencies and the department over  the longer term. Specifically, such assessments could include  understanding the areas in which individual granting agencies may be  awarding funds for the same or similar purposes, determining whether  these grant programs appropriately channel the department’s resources  across the justice areas it funds, and determining whether any existing  overlap is desirable. By conducting an assessment of its grant programs  of this kind, DOJ would be better positioned to take action, such as  through consolidation and coordination of its programs, in a more  systematic way to limit overlap and mitigate the risk of unnecessary  duplication.

section_title: DOJ’s Granting Agencies Do Not Have Policies and Procedures to Ensure Coordination to Limit the Risk of Unnecessary Duplication
paragraphs: OJP, OVW, and the COPS Office do not routinely share lists of current  and potential awardees to consider both the current and planned  dispersion and purposes of all DOJ grant funding before finalizing new  award decisions. Not having routine coordination in the pre-award phase  limits each of DOJ’s granting agencies’ visibility of the funds each  respectively awards rather than to the overall flow of department dollars.  Thus, in the instances where DOJ made multiple grant awards to  applicants for the same or similar purposes, officials made these awards  without always being aware of the potential for unnecessary duplication or  whether funding from multiple streams was warranted. DOJ officials  stated that their annual process to formulate budgets for grant  administration, OJP’s annual planning process to develop solicitations,  and the department’s overall grant oversight functions address the risks  of unnecessary duplication in grant awards. However, these activities do  not specifically relate to the pre-award phase when any potential for  unnecessary duplication can best be avoided. DOJ officials also stated  that they meet bi-monthly to discuss grantees on DOJ’s High Risk List to  avoid funding grantees who in the past have demonstrated deficiencies in   However, the purpose of these  properly managing their federal awards.discussions is not to prevent or reduce duplication. Developing agency  policies and procedures to avoid unnecessary grant duplication in the  awarding of funds is one of the promising practices that the federal  Domestic Working Group Grant Accountability Project suggested in its  Guide to Opportunities for Improving Grant Accountability.

As a result of our work, OJP officials informed us that as of March 2012,  they had begun to pilot solicitation language in two of its grant programs  requiring grant applicants to disclose any pending applications submitted  in the last 12 months for other federally funded assistance to support the  same costs associated with the same projects outlined in applicants’  budgets. Additionally, officials stated they are currently developing a grant  special condition for all fiscal year 2012 grant awards that would require  grantees to report to OJP if they receive any funding for a specific project  cost that is duplicative of the funding OJP provides. OJP officials told us  that if grantees report duplicative funding for a specific project cost, OJP  staff will work with the grantees to ensure return of the OJP funds. We  believe this requirement will improve OJP’s ability to limit the risks of  duplicative funding for single items; however, OJP continues to take a  more narrow view of the term “duplication.” OJP defines duplicative  funding to include only instances where grantees are using federal money  for the same exact item. In doing so, OJP excludes from its purview all  federal funding that grant applicants have been awarded to carry out the  same or similar activities within a proposed project. Thus, in making  funding decisions without asking for information about and considering  other sources of an applicant’s federal funding to carry out the same or  similar activities, OJP may be awarding funds for proposed projects that  are already partially or fully funded. It may also be doing so at the  expense of other applicants who, in the absence of other funding sources,  may demonstrate to OJP greater financial need for their proposals.  Further, DOJ’s new approach—while an important step—relies solely on  grantee reporting. By independently assessing its own lists of actual and  prospective grantees prior to awarding funds, DOJ could have additional  assurance that it is taking actions to mitigate the risk of unnecessary  duplication.

In addition, OVW officials stated that for fiscal year 2013, they intend to  require those applying to four of its grant programs to identify in their  grant applications all federal funding that they recently applied for or have  received. By enhancing visibility over various sources of grant funding,  OVW would be better positioned to avoid unnecessary duplication in  awarding grants for these four programs. It could also provide OVW with  opportunities to best leverage OVW funding in a manner that  complements other funding streams the applicant already has available or  may soon receive. For example, if an applicant reports to OVW that it  already receives money through a non-OVW grant to provide counseling  services to victims, OVW can ensure that OVW funds are available for  other project-related activities such as providing training to counselors  who serve victims. However, beyond what OJP is piloting and what OVW  has proposed for four of its programs, DOJ generally does not require  grant applicants to identify other funding that they have received or any  pending funding yet to be awarded, including funding received through a  subgrant. Further, while the COPS Office’s grants management system  automatically includes information on other COPS Office funding a COPS  Office applicant may already be receiving, it does not identify other DOJ  grant funding or any other federal funding sources. As a result, DOJ’s  three granting agencies could take additional steps to increase their  visibility over what applicants may already be receiving before awarding  new funds.

OJP, OVW, and the COPS Office have not established policies and  procedures requiring consistent coordination and information sharing  among its granting agencies. Having such policies and procedures would  provide guidance to DOJ granting agencies to help ensure they take  action to mitigate the risks of unnecessary duplication before finalizing  award decisions. By routinely coordinating to ensure the sharing of grant  applications and potential grant awards among DOJ granting agencies  prior to finalizing grant award decisions and documenting its methods for  doing so, DOJ could also improve its oversight and better leverage  information already at its disposal.

The IG recommended in August 2003 that OJP and the COPS Office  establish procedures to coordinate to ensure that grantees do not receive  funds for the same purpose from both agencies.the COPS Office signed a memorandum of understanding to establish  procedures for avoiding duplication by coordinating grants and grant  programs that were identified by the IG and grant programs where the   In response, OJP and  potential for duplication exists. Further, the agencies committed to  reviewing any new guidance affecting grants or grant programs where the  potential for duplication exists. Specifically, for grants and grant programs  identified as having potential for duplication, OJP and the COPS Office  agreed to minimize potential duplicative grant awards in a manner  consistent with statutory provisions, and include a grant award special  condition requiring that grantees not use OJP and COPS Office grant  funds to pay for the same expenses. During the course of our audit  work, we asked COPS Office and OJP officials for examples of the type  of coordination they have been engaging in since the IG’s  recommendations. Officials provided evidence from fiscal year 2009,  when they coordinated funding decisions with OJP prior to awarding  grants for two similar grant programs funded under the Recovery Act.

However, in some cases, granting agencies continue to provide funding  for the same or similar purposes without each being aware of the others’  actions. Further, we examined grant special conditions for the COPS  Office CSP program and OJP’s ICAC grant program and neither agency  included special conditions in the grant awards requiring grantees to  identify and report duplication. However, the 2010 COPS Child Sexual  Predator Program Grant Owner’s Manual did include a requirement that  grantees inform the COPS Office if they receive other funding for the  same cost or service already funded by the COPS Office while their grant  is underway. The Grant Manager’s Manual used by OJP lists grant award  special conditions, and except for the duplication condition that  specifically applies to CTAS, there were no other grant duplication special  conditions listed.

Officials from OJP and the COPS Office told us that state and local  communities have expansive criminal justice needs and therefore they  encourage applicants to seek out as much DOJ grant funding as possible,  including from grant programs that may have similar objectives or allow  for similar activities. In some instances, DOJ may deem it appropriate for  distinct grant programs to serve the same goal, or for one community or  grantee to benefit from multiple streams of grant funding. For example, if  DOJ granting officials are coordinating their activities across overlapping  grant programs and are aware that a grantee is receiving funds from  more than one DOJ program, making funding decisions of this kind may  be warranted. However, DOJ’s granting agencies are not routinely  engaging in such coordination. Unless DOJ improves granting agencies’  coordination, and considers information available on current, past, and  prospective funding, it cannot know where all of its funding goes, how it is  being or will be used, and whether it is awarding grant dollars in the most  efficient way possible. Further, if the granting agencies are not aware of  which recipients are receiving funds from multiple grants, they may be  inadvertently awarding multiple grants that exceed the demonstrated  need of a recipient or community at the expense of another applicant or  community with similar demonstrated needs. In addition, they may be  missing opportunities to award grants to recipients who may use funding  in a complementary way, whereby funding may be leveraged by a  grantee or a community to accomplish a single goal. With the exception of  OVW’s plan to have four grant program recipients identify all federal  funding they receive and OJP’s solicitation pilot and plan to have  applicants identify duplicative cost items, DOJ does not have policies and  procedures that require grant applicants to identify all sources of current  or pending DOJ funding in their grant applications in a manner that  provides DOJ a complete picture of DOJ grant project funding. If DOJ had  (1) a coordinated approach to share applicants’ funding intentions, and  (2) policies and procedures to share lists of applicants that each granting  agency plans to fund, DOJ could improve its understanding in the pre- award phase as to whether its funding would complement or  unnecessarily duplicate other federal funding.

DOJ officials told us that the timeline for reviewing applications, making  recommendations, and processing awards each year is compressed and  that it would be difficult to build in the extra time and level of coordination  required to complete an intradepartmental review for potentially  unnecessary duplication of funding prior to making awards. The officials  added that it would take even more time if granting agencies were to  attempt a pre-award duplication review at the subgrantee level. Thus,  officials told us that they rely upon post-award activities through grant  monitoring, Single Grant Audits, and IG audits to determine if duplicative  expenses have occurred after grants are under way. However, relying  upon monitoring and external audits to identify duplication after it has  occurred should not substitute for the mitigation of potential unnecessary  duplication in the pre-award phase. We acknowledge that the time  necessary to complete annual grant awards makes such a review  process more difficult; however, actions to make coordination more  consistent and efficient as well as the leveraging of grant award  information, including subgrants, could help overcome this challenge.  Moreover, using tools such as existing grant data available on  USASpending.gov, which we address later in this report, could aid DOJ in  validating other grant funding that grant applicants report and allow for an  expedient way to search for subgrant funding. In addition, DOJ could limit  its pre-award coordination to those grant programs that DOJ identifies as  overlapping with other DOJ grant programs. For certain grant programs,  OJP and OVW have taken important first steps to require grant applicants  to report other sources of funding, but expanding this requirement to all  grant programs across all granting agencies, such that every applicant  would report both past and prospective sources of DOJ grant funding,  could provide broader coverage and help DOJ better mitigate the risk of  unnecessary duplication.

section_title: DOJ Uses Separate Grant Management Systems, a Fact That Limits Award Coordination
paragraphs: While OJP and OVW use a single grants management system called  GMS, the COPS Office uses a separate grants management system— CMS—which limits the sharing of grant award information across the  granting agencies. Specifically, OJP, OVW, and the COPS Office use  GMS and CMS to track and manage awards throughout the grant life  cycle. For example, agency grant staff in OJP, OVW, and the COPS  Office use their grant management systems to review and approve  applications and to plan and document grant monitoring activities.  Grantees use the grant management systems to submit financial status  reports that include summary information on grant expenditures and  program income as well as progress or performance reports. DOJ has  spent about $36 million from 2008 through 2010 to maintain and upgrade  these two separate grants management systems, including about $8  million for CMS and $28 million for GMS.

DOJ’s continued use of two systems to manage grant programs impedes  coordination because GMS and CMS are not linked with each other, and  the agencies’ access is limited to the grants management systems they  utilize. OJP and OVW can access information through GMS about grants  awarded by each other, but they cannot access CMS to see the grantees  that have received COPS Office funds. As a result, these granting  agencies cannot use these grants management systems to inform  themselves of all of the funding DOJ has awarded or is preparing to  award to a recipient and consider this information before making  additional awards. According to an OJP official, over the long term, it  would be helpful if GMS could connect to CMS. Pursuant to the statute  establishing OAAM—the office overseeing programmatic grant monitoring  and assessment across OJP and COPS Office programs—the Director of  OAAM was required to establish and maintain a modern, automated  system for managing all information relating to grants made under  programs within its purview. grant management systems in the department.

See 42 U.S.C. § 3712h(g) (providing that the OAAM Director shall establish and  maintain such a system in consultation with the chief information officer of the office). and monitoring, such as through remote access to CMS. The IG  concluded that oversight agencies should have direct, instant, and  complete access to grant information, which is not provided using the  current system, which relies on hard copies of documents. In response,  COPS Office officials reported that they would provide OJP with real-time  hard copy reports necessary to carry out oversight work and that CMS  could be accessed only by employees using remote access to the COPS  Office or through a COPS Office laptop.

DOJ contractors completed a gap analysis of CMS and GMS in 2006 to  outline the differences—or gaps—between the two systems and propose  solutions for reconciling them. At the time, the contractor found key gaps  between the two systems related to business processes—in particular,  programmatic grant monitoring, financial monitoring, and progress- reporting capabilities. Thus, the contractor recommended either building a  new single grants system or maintaining the status quo because in the  analysis, business process differences between OJP and the COPS  Office were reportedly obstacles that made using either one of the two  grants systems for both agencies untenable. Since 2007, OJP has  upgraded GMS, which has closed some of the system gaps that the  contractor initially identified, but the two systems remain distinct and  unlinked.

According to COPS Office officials, CMS continues to better meet their  needs than GMS could because CMS captures and stores data in such a  way that it can be more easily queried than data in GMS and CMS  uniquely aligns with COPS Office grant processes. This is helpful to the  officials when the COPS Office is evaluating grant applications for its  largest program, the COPS Hiring Program. Rather than evaluating  qualitative grant project narratives through external peer review, the  COPS Office considers quantitative data related to applicant fiscal  distress, reported crime statistics, and community policing strategies  when determining where to award COPS Hiring Program grants. Because  COPS Hiring Program grant applicants use CMS to upload their data,  COPS officials are positioned to use CMS for automated aggregation and  analysis of applicant responses.

In contrast, OJP officials said that because of recent upgrades, GMS  could be used or modified in order to query individual searchable  elements. They also stated that variation in the information required by  individual grant programs would not present an insurmountable barrier to  unifying systems. In addition, GMS has served multiple agencies in the  past and can be modified when circumstances warrant. For example, in  2010 and 2011, COPS Office officials successfully used GMS for  awarding purposes under CTAS. According to OJP officials, the initial  coordination with the COPS Office for CTAS purposes required additional  modifications to GMS, but these were not onerous or costly. The officials  said that with relative ease, after the modifications, OJP, OVW, and  COPS Office grant managers all accessed GMS to perform some of the  phases of the CTAS grant process. For example, GMS supports the  management of CTAS by storing all applications, managing peer review  comments, and registering awards once decisions are final. Besides  OVW’s use of GMS to award and manage its grants, the Department of  Homeland Security’s (DHS) Federal Emergency Management Agency  (FEMA) also uses GMS to award and manage grants, though it has future   Further, OJP officials stated that  plans to use a DHS grants system.GMS has a current storage capacity well in excess of what it currently  uses. They also emphasized that OVW and FEMA have grant business  processes that do not completely align with OJP’s, but with small  investments, OJP has been able to adjust GMS to accommodate OVW  and FEMA.

In June 2012, DOJ officials informed us they had engaged a contractor to  assess whether a single grants management system, among a range of  other options, can best serve DOJ’s granting agencies. They plan for the  contractor to report back within 6 months of beginning the analysis and  said that they envision the assessment including an evaluation of costs,  benefits, and technical requirements, such as those needed to harmonize  business processes. Engaging a contractor for this purpose is an  important first step, and doing so could help DOJ make better investment  decisions about the most efficient way to manage its grants systems,  especially when it considers the costs and benefits of having fragmented  grants systems. In the interim, however, DOJ could take a more  immediate solution to foster information sharing across GMS and CMS by  providing system access to appropriate OJP, OVW, and COPS Office  staff—for example, through common login names and passwords, just as  department staff have done in limited instances such as the CTAS  Program.

section_title: DOJ Does Not Timely Submit Grant Data to USASpending.gov and Is Not Fully Leveraging the Website’s Subgrant Award Information before Making Grant Award Decisions
paragraphs: DOJ’s granting agencies are not submitting grant award information to  USASpending.gov in a timely way. In accordance with the Federal  Funding and Transparency Act of 2006 (FFATA), USASpending.gov was  created to increase the transparency and accountability for federal  funding awarded through contracts, loans, grants, and other awards.  OMB issued guidance on reporting the receipt and use of federal funds.  OMB also launched USASpending.gov in December 2007 to allow the  public to view federal spending and engaged the General Services  Administration (GSA) to build and maintain USASpending.gov, among  other FFATA-related websites.guidelines for agencies related to the requirement for prime grantees to  report all subgrants over $25,000 in fiscal year 2011. The  USASpending.gov website includes the subgrantees’ names,  geographical locations of funded activities, specific subgrant amounts,  and the funded purposes. A GSA official told us that the FFATA reporting  infrastructure is the first time that comprehensive federal grant and  subgrant information, including DOJ grant information, has been made  widely available on a single website. Through the steps that granting  agencies, as well as the grantees, take to supply this website’s content,  the public and DOJ’s granting agencies can better track the flow of funds  and identify communities receiving funds from multiple streams.

In August 2010, OMB established  OMB’s FFATA guidance requires agencies to submit grant award data by  the 5th of each month. USASpending.gov contains validation software  used to validate agency data submissions, and if data are rejected,  agencies receive automated notification. OMB guidance then requires  agencies to resubmit the corrected data to USASpending.gov within 5  working days of the rejection notification. OJP manages submissions to  USASpending.gov for all of DOJ—that is for OJP, OVW, and the COPS  Office—and an OJP official reported that DOJ submits grant award  information to USASpending.gov twice per month. However, more than a  quarter of the grant award information that DOJ submitted to  USASpending.gov in fiscal year 2011 was rejected and resubmission took   Figure 3 illustrates the  more than 80 days after the fiscal year ended.flow of grant award information from both DOJ and grantees and some  issues we identified related to DOJ’s fiscal year 2011 reporting.

Agency reporting of prime grant award information in USASpending.gov  is a critical step in the FFATA reporting process because prime grantees  cannot upload their subgrant award information until it occurs. For fiscal  year 2011, DOJ submitted 4,346 distinct prime grant award records to  USASpending.gov; however, GSA rejected 1,152 of these because of  incomplete or inaccurate data associated with some of these grant files,  and DOJ did not resubmit the records within 5 working days as required  under OMB guidance. Specifically, DOJ did not correct and resubmit the  rejected records until December 22, 2011, which was after we raised this  issue with DOJ and 83 days after the end of the fiscal year. Five out of 11  DOJ prime grantees we interviewed who had awarded subgrants  indicated that, after searching, they could not view their prime DOJ grant  awards on FSRS.gov or USASpending.gov and indicated that DOJ had  not uploaded the information to the websites. Further, another prime  grantee among the 11 with whom we spoke indicated that it was unaware  that subgrant reporting was a requirement. As a result, these prime  grantees were unable to submit their subgrant award information and thus  were unable to comply with OMB subgrant reporting requirements. DOJ  has taken action to help ensure that prime grantees and DOJ grants staff  are aware of FFATA reporting requirements. For example, OJP offered  FFATA reporting training for all DOJ grants staff and grantees, and all  three granting agencies required a special condition in grant awards that  included FFATA reporting requirements. These steps may have informed  grantees of their FFATA responsibilities, but DOJ’s untimely submission  of grant award information to USASpending.gov led to prime grantees  being unable to access their grant awards to submit their subgrant award  information as required by OMB.

OJP officials stated that since 2007 they have been coordinating with  OMB, other federal agencies, and contractors on issues related to  reporting guidelines and other technical requirements related to subgrant  reporting, but that it was not until August 2010 that OMB established  guidelines for the collection and reporting of subgrant information.  Nevertheless, OJP officials stated that the current allotment of 5 days for  agencies to review and resubmit data that GSA originally rejected is an  unreasonable time frame given the time-intensive nature of checking and  correcting errors. Officials also noted that OJP would like to see GSA  allow for the posting of individual records that pass system validation  rather than waiting for entire blocks to be corrected at once before GSA  will post award information to USASpending.gov. In addition, OJP officials  indicated that the information prime grantees ultimately posted about their  subgrantees was limited and in most cases very brief. As a result, the  officials said they were not considering such information before making  new awards.

We recognize that 5 days may not be adequate to correct errors in grant  award information, but we also believe that timely submission of grant  award information on USASpending.gov is key to transparency and the  overall utility of the system for grant decision makers, the criminal justice  community, Congress, and taxpayers. By DOJ ensuring that it submits its  grant award information to USASpending.gov in as timely a manner as is  possible, prime grantees’ abilities to report their subgrant activities would  likely improve. As a result, DOJ could have greater visibility over which  subgrantees were using its money and for what purposes before DOJ  makes its grant award decisions. Further, even if DOJ does not believe  that the information that prime grantees ultimately post about their  subgrantees is ideally descriptive in every instance, the information could  provide DOJ with important details—that it currently does not consider or  otherwise have access to before finalizing award decisions—related to  how subgrantees are using their funds.

section_title: DOJ Could Benefit from Examining Its Programmatic Grant Monitoring and Assessment Functions and Considering Expansion of OAAM’s Authorities
subsections: section_title: OAAM Uses Programmatic Grant Monitoring and Program Assessment for Grant Oversight, but Program Assessments Yield Richer Information
paragraphs: The statute establishing OAAM tasked the OAAM Director with selecting  and carrying out program assessments of not less than 10 percent of the  aggregate amount of grant funding awarded annually by OJP, the COPS  Office, and any other grant programs carried out by DOJ that the Attorney   OAAM officials told us that to meet the  General considers appropriate.directive to conduct program assessments, and in recognition of its own  resource constraints, OAAM relies on the programmatic grant monitoring  that OJP’s and the COPS Office’s grant staff already conduct. To oversee  and track these monitoring efforts, OAAM develops and implements  standards and protocols, including a framework and methodology for   OAAM also tracks OJP’s  systematically identifying high-risk grantees.and the COPS Office’s monitoring progress and compares it against an  established annual monitoring plan. For example, in its fiscal year 2010  annual report—the latest available—on both OJP and the COPS Office’s  monitoring goals and activities, OAAM found that both offices exceeded  their goals of monitoring 10 percent of total award funding. OJP  monitored 1,447 grantees with awards totaling $3.05 billion, and the  COPS Office monitored 185 grantees with awards totaling $234.74  million. In addition to overseeing monitoring activities, OAAM also  conducts program assessments of OJP and COPS Office grant  programs. OAAM considers monitoring—and its oversight of it—as  responsive to its originating statute’s intent, but it also recognizes that  assessments have utility and serve a separate but important function in  helping the office improve grant management. Table 4 illustrates the  distinction between OJP’s and the COPS Office’s monitoring and OAAM’s  assessment functions.

In general, both monitoring and assessment are important and  complementary tools for grant oversight. Nevertheless, we found that  OAAM’s program assessments yield richer information to enhance grant  programs than either OJP’s or the COPS Office’s individual monitoring  reports or the summary reports that OAAM’s Program Assessment  Division (PAD) compiles because the program assessments are more  analytical and broader in perspective. OAAM’s PAD Standard Operating  Procedures define a program assessment as “a systematic review and  evaluation of programs to gauge effectiveness, identify promising  practices, document impediments, and when necessary, make  recommendations for improvement.” OAAM reported to us that from 2008  through mid-February, 2012, its staff had produced 28 products; however,  when we reviewed the 28, we found that 7 met OAAM’s definition for a  program assessment.assessment report on the COPS Office Methamphetamine Initiative. In  2011, it completed one on BJA payment programs, and in 2010, it  assessed the ICAC Training and Technical Assistance Program. The  other 21 publications were user guides; summaries of monitoring reports,  such as those described earlier; or Recovery Act risk indicator reports,  which identify potentially high-risk grantees so that the program offices  can work with those grantees to resolve issues and prevent potential  problems. According to OJP, all of OAAM’s publications contribute to  improving OJP’s grant programs and operations by strengthening internal  controls, streamlining processes to be more efficient, or reporting on how  well programs and policies are meeting their objectives.

For example, in 2012, OAAM completed an  Of the 7 publications meeting OAAM’s definition for program  assessments, 2 reviewed a single aspect of the grant cycle—program  awarding—within a particular grant program rather than the grant  program overall.thorough review of the extent to which a grant program is meeting its  intended purpose. Moreover, each recommended specific actions to  address identified program deficiencies, and implementation of these  recommendations has helped DOJ enhance its grant programs. For  example, the 2010 ICAC assessment report contained 11  recommendations related to the collection and use of performance  measurement data, financial management, fair and open competition for  awards, and improving grant management and oversight. In our review of  the six monitoring reports that the ICAC grant manager completed for the  ICAC program’s sole grantee, there was no mention of the same  deficiencies. In particular, none of the six monitoring reports identified the  unallowable costs, conflict of interest, or inadequate oversight and  documentation of grant activity that the OAAM assessment report  identified. Instead, the monitoring reports showed that the grantee was  progressing as expected on implementation of the program, and was on  schedule with no problems noted.

Nevertheless, all 7 were based on a much more  OAAM also assessed BJA’s payment programs, which otherwise are not  subject to BJA grant monitoring. In the November 2011 report, OAAM  assessed the processes that BJA used to verify the eligibility and  accuracy of reimbursement requests submitted by grantees. The  assessment concluded that BJA is administering its payment programs  appropriately to verify the eligibility and accuracy of payments, but it also  determined that additional internal controls were necessary and that  procedures were not sufficient to identify duplicate payment requests from  grantees. As a result of the assessment, OAAM made six  recommendations to BJA, including implementing additional procedures  to identify duplicate requests for payments of detention expenses. In  particular, one of OAAM’s recommendations was that BJA implement a  process to identify overlapping requests for reimbursement between two  of the programs for expenses related to detention of criminal aliens. In  response, BJA compared all of those programs’ applications for  reimbursement for fiscal year 2011 to identify whether jurisdictions were  requesting reimbursement for the detention of the same individuals over  the same period of time. BJA’s review led to the removal of approximately  $5.8 million in requests for reimbursement prior to generating the final  reimbursement awards.

Standards for Internal Control in the Federal Government calls for  managers to compare actual performance with planned or expected  results throughout the organization and analyze significant differences.  These standards also identify that program managers need both  operational and financial data to determine whether they are meeting their  agencies’ strategic and annual performance plans and meeting their  goals for accountability for effective and efficient use of resources. The  programmatic grant monitoring reports that each of the granting agencies  compile contribute to meeting these standards at the grantee level by  tracking the progress and, when necessary, providing assistance to  individual grant recipients. OAAM’s summaries of these reports then roll  up the statistics and ensure the compliance monitoring occurs as  required. However, OAAM’s program assessments are more  comprehensive than both the individual grant monitoring reports and the  summary reports OAAM prepares because their broader perspective  allows for reporting on program successes, impediments, and potential  areas for improvement. While monitoring 10 percent or more of the  aggregate amount of grant funding awarded annually is important and  beneficial to the grant management process, the 7 program assessment  reports that OAAM has issued since 2008 have led to more than 50  recommendations for the improvement of OJP and COPS Office grant  programs.

According to OAAM officials, additional program assessments would be  beneficial; however, they told us that OAAM does not have sufficient  resources to conduct more. They said that conducting program  assessments on 10 percent of the aggregate amount of grant funds  awarded annually would not be possible given current resources, but they  also noted that the department has not conducted a feasibility analysis  that considers the costs and benefits of having OAAM conduct  assessments on a larger number of grant programs. Further, OJP officials  stated that since the establishment of OAAM, the administration has  never requested, and the department has not received, the full amount  authorized for appropriation under OAAM’s governing statute. DOJ  officials did not explain the rationale for the administration’s budget  proposals and officials did not report any plans to increase OAAM’s  resources. As of December 2011, out of a total of 49 staff (26 federal staff  authorized by DOJ and 23 contractors) spread across OAAM’s three  divisions, OAAM had 8 staff (5 federal staff authorized by DOJ and 3  contractors)—or less than 20 percent—in its PAD dedicated to performing  program assessments in addition to overseeing OJP and COPS Office  programmatic monitoring. OAAM also has 18 staff (10 federal staff  authorized by DOJ and 8 contractors)—or more than 30 percent— working in its Audit and Review Division to coordinate IG, GAO, and  Single Grant Audit resolutions, and to conduct A-123 reviews—activities  that are not specifically addressed in OAAM’s authorizing statute.  Appendix V contains further discussion of the different activities of  OAAM’s three divisions. Because DOJ considers its resources to be  limited, it is important that OAAM’s resources be used as efficiently as  possible to maximize the investment in grant programs. Thus, given the  different roles that grant monitoring and program assessment play in  assessing the overall effectiveness of grant programs, considering  whether it employs an appropriate mix of monitoring and program  assessments could aid DOJ in awarding grant funds in the most efficient  and effective way possible.

section_title: Not Including OVW in OAAM’s Oversight Has Resulted in Inconsistent Assessment of the Effectiveness of DOJ Grant Programs
paragraphs: Consistent with the 2000 reauthorization of the Violence Against Women  Act, the Attorney General submits a biennial report to Congress on the  effectiveness of VAWA-funded grant programs. OVW uses the VAWA  Measuring Effectiveness Initiative, conducted under a noncompetitive  cooperative agreement with a university to develop and implement  reporting tools, as the primary way it meets statutory requirements to  report on the effectiveness of VAWA-funded programs. Staff from the  university also provide data collection training to grantees to ensure that  they use the forms and database properly, and then use the information  collected to summarize grantee performance in semiannual summary  data reports. The results of this initiative are summary data reports that  university staff compile from the semiannual or annual progress reports  that grantees submit to OVW. OVW then uses these summaries to meet  biennial reporting requirements for its discretionary grant programs under  VAWA and, for example, the Services, Training, Officers, Prosecutors  (STOP) Violence Against Women Formula Grant Program (STOP  Program).  The STOP Program promotes a coordinated,  multidisciplinary approach to improving the criminal justice system’s  response to violent crimes against women and increasing the availability  of victim services.

OVW’s biennial reports are composed of three main components: a literature review of research showing (where available) the  effectiveness of grant-funded activities and (when such research is  not available) information on promising or best practices in the field of  victims services; a summary of performance measure data, such as the number of  grant-funded staff, the number of people trained, and the number of  victims/survivors seeking services that are served, partially served,  and not served, as reported by the grantees to OVW through OJP’s  GMS; and anecdotal evidence from grantees on the benefit of what they are able  to do with grant funds.

The statute establishing OAAM did not give it oversight authority for OVW  programs. Provisions in the authorizing statute, however, provide the  Attorney General with discretion to expand OAAM’s scope beyond OJP  and COPS Office programs, which the Attorney General has not  undertaken. As a result, while OVW uses its data collection and analysis  to report on grant program effectiveness, in accordance with the VAWA  requirement, by providing information on activities carried out with grant  funds and the number of persons served using those funds, it does not  benefit from the monitoring oversight and grant program assessments  that OAAM provides. Such assessments could provide OVW with more  substantive information on its grant programs.

Table 5 contains a comparison of the analytical approaches that OVW  uses when it reports to Congress on the effectiveness of its grant  programs against those that OAAM uses in its program assessments. On  the basis of a review of seven OVW reports and seven OAAM grant  program assessment reports, we found that OVW’s reports contain less  analysis than the OAAM reports do. Specifically, these OVW reports  summarized performance measurement data rather than analyzed it.  Further, these OVW reports did not address grant program operations  and management. OAAM, in contrast, used more varied approaches to  analyze grant programs, which provided information on both grant  program performance and operations, identified areas for improvement,  and resulted in specific recommendations to OJP’s bureaus and program  offices, and the COPS Office.

Unlike the OAAM analysts who conduct assessments of OJP and COPS  Office grant programs, the university staff responsible for the Measuring  Effectiveness Initiative do not have access to grant program financial data  or OVW grant monitoring reports. Additionally, university staff involved in  the initiative do not conduct site visits to validate the data provided by  grant recipients and the work they perform. Instead, OVW staff in each  program area review the results of the biennial reports and the  semiannual summary data reports compiled from grantee progress  reports to identify priority areas where there is an unmet need. The OVW  reports contain sections on “remaining areas of need” identified by grant  recipients. However, the areas of need that OVW identified are based on  comments grant recipients provided on gaps in service, rather than being  based on an independent assessment that OVW conducted on the overall  grant programs. Moreover, unlike the grant program assessments that  OAAM conducts, beyond identifying areas of need, the biennial reports do  not result in concrete recommendations for improving OVW’s grant  programs. OVW officials told us that for the upcoming 2012 biennial  report, they plan to focus more attention to the discussion of remaining  areas of need.

According to OVW’s 2010 Biennial Report to Congress on the  Effectiveness of Grant Programs Under the Violence Against Women Act,  demonstrating the effectiveness of services provided by agencies funded  under OVW presents a challenge for those charged with meeting the  reporting mandate of VAWA 2000. An OVW official told us that it is  difficult to discern between output and outcomes when dealing with the  grant programs in OVW and that it is difficult to measure outcomes with  service grant programs. For example, OVW might consider whether an  abuse victim not only gets a protective order but also receives additional  services. Additionally, according to OVW officials, it would be difficult to  track how many victims received different types of services in multiple  areas, because OVW service provider grantees only track the first  instance in which a victim receives services and do not follow up on  related services.

According to the federal Domestic Working Group Grant Accountability  Project’s Guide to Opportunities for Improving Grant Accountability,  agencies need a process for managing performance once grants are  awarded, and the ability to assess grant results and use those results  when awarding future grants. The Working Group identified engaging  outside experts to assess program performance, inspecting projects after  completion, and conducting evaluations to identify factors affecting results  among its promising practices to improve program performance. These  activities are not part of OVW’s current approach to program oversight.

OVW conducts its grant program monitoring as well as IG audit follow-up.  Additionally, OVW has a Grant Assessment Tool (GAT)—designed by the  same company that produced the GAT for OJP.conducts Single Audit follow-ups; manages the high-risk grantee list; and  oversees DOJ’s combined programmatic and financial monitoring plan,  which is the combined monitoring list of all the sites that OJP, OVW, and  the COPS Office plan to visit for the year. In a March 2011 audit, the IG  found that OVW and the COPS Office perform certain monitoring and  oversight services that are duplicative of the services available through  OJP and recommended that DOJ standardize the oversight services   OAAM currently  provided to OVW and the COPS Office to eliminate such duplication and  provide uniformity in oversight among DOJ granting agencies. OAAM  provides certain administrative services that facilitate grant program  management, but DOJ officials told us the reason OAAM does not have  oversight over OVW is because the Attorney General has not extended  OAAM’s purview. OJP officials told us that they have not been provided  the scope of work that OVW oversight may encompass and, as such,  OAAM has not conducted any analyses using a workforce model to  determine the staffing levels, associated resources, and other possible  impacts (i.e., costs and benefits) of having OVW under its purview on  OAAM operations.

OVW officials expressed concern that OAAM staff would not have any  expertise in violence against women issues. However, OAAM currently  has oversight over specialized bureaus and offices such as the Office for  Victims of Crime and the Office of Sex Offender Sentencing, Monitoring,  Apprehending, Registering, and Tracking. Additionally, OVW officials  stated that OAAM does not perform data collection and analysis activities,  which are the primary activities of the Measuring Effectiveness Initiative.  However, as a part of its assessments, OAAM has collected performance  measures and conducted analysis. For example, in its assessment of the  ICAC Training and Technical Assistance Program, OAAM collected and  analyzed national performance metrics related to training. Given the  nature of OAAM assessments, along with the other oversight services it  provides to OJP and the COPS Office, the information resulting from  OAAM assessments of OVW grant programs could better inform OVW  about its grant programs and funding to assist with future program design  and award decisions while also providing Congress with a more complete  picture on the effectiveness of programs funded under VAWA.  Accordingly, DOJ could benefit from assessing the feasibility, costs, and  benefits of OAAM providing grant program assessments for OVW.

section_title: Conclusions
paragraphs: The statutory design of DOJ’s grant programs has contributed to overlap  across a number of justice areas. We recognize that even when programs  overlap, there may be meaningful differences in their eligibility criteria or  objectives, or they may be providing similar types of services in different  ways. We also recognize that a number of grant programs are formula- driven and therefore grantees’ eligibility is predetermined. However,  because DOJ exercises independent judgment when making  discretionary awards and therefore has full responsibility for how it  conducts its pre-award reviews, it will be important for the department to  maximize visibility over how grantees plan to spend the funds they  receive from multiple funding streams. In some instances, DOJ may  deem it appropriate for large numbers of distinct grant programs to serve  one goal, or for the same communities to benefit from multiple streams of  its grant funding. In these cases, duplication may be warranted. However,  because we found routine coordination and consistent policies and  procedures for sharing information across the granting agencies during  DOJ’s pre-award phase limited, we do not believe DOJ knows with  certainty if such duplication is always necessary.

DOJ’s three granting agencies have taken some steps to coordinate their  grant-related activities and have sought congressional approval in some  instances for grant program consolidation. Further, they have initiated  other, limited actions to ensure that grantees report additional streams of  funding. However, DOJ limits its view of duplication to instances where  grant applicants apply for and receive multiple streams of funding,  including DOJ funding, to support single costs associated with a single  grant project. Using this definition, DOJ believes that any unnecessary  duplication can be identified through monitoring grantees post-award. We  take a broader view of duplication and consider it potentially unnecessary  when DOJ is unaware that grantees have applied for and are receiving  funding for potentially the very same or similar purposes. Therefore, we  believe it is incumbent that DOJ take steps in the pre-award phase to  make purposeful judgments about funding necessity before finalizing the  awards. Doing so would help the department better mitigate this risk for  potential, unnecessary duplication. Specifically, by conducting a broad  examination of all DOJ grant programs to systematically identify justice  areas for which funding overlaps, DOJ would have greater visibility over  how its funding can be used and whether it is awarding grant dollars in  the most efficient way possible. Further, developing and implementing  policies and procedures to require granting agencies to routinely share  and consider information each may have about past or prospective  grantee funding could provide DOJ with more strategic visibility over its  awarding decisions. In addition, requiring all grantees to report current or  prospective federal funding sources when applying for DOJ grants could  provide DOJ with more information to better target its limited financial  resources before it finalizes new grant awards.

Additionally, by taking interim steps to expand access to the two distinct  grant management systems—CMS and GMS—DOJ could better ensure  that grant managers and decision makers can leverage all existing tools  while a longer-term study to consider the feasibility, costs, and benefits of  potential options for DOJ grant management systems is underway. Such  options could include unifying the systems, creating a DOJ-wide system,  or using off-the-shelf software to bridge information gaps. Related, DOJ  can have greater confidence that any variation in how the granting  agencies are currently managing their portfolios does not hinder any  potential unification by ensuring that its planned study include an  assessment of the steps needed to harmonize DOJ grant processes.  Further, with additional steps to ensure that DOJ is submitting grant  award information to USASpending.gov in the most timely manner  possible, the department could facilitate prime grantees’ uploading of  information on subgrantees’ use of funds and therefore make the website  a more useful resource to DOJ’s own grant decision makers. Finally,  recognizing the value of OAAM’s role, assessing whether the office relies  on an appropriate mix of programmatic grant monitoring and program  assessment—as well as considering expansion of OAAM’s coverage to  include OVW—could improve the overall operation of grant programs  departmentwide.

section_title: Recommendations for Executive Action
paragraphs: To ensure that DOJ can identify overlapping grant programs to either  consolidate or coordinate similar programs, mitigate the risk of  unnecessary grant award duplication in its programs, and enhance DOJ’s  ability to gauge grant program effectiveness, we recommend that the  Attorney General take the following eight actions:  1.  Conduct an assessment to better understand the extent to which the  department’s grant programs overlap with one another and determine  if grant programs may be consolidated to mitigate the risk of  unnecessary duplication. To the extent that DOJ identifies any  statutory obstacles to consolidating its grant programs, it should work  with Congress to address them, as needed.  2.  Coordinate within and among granting agencies on a consistent basis  to review potential or recent grant awards from grant programs that  DOJ identifies as overlapping, including subgrant awards reported by  prime grant awardees, to the extent possible, before awarding grants.  DOJ should also take steps to establish written policies and  procedures to govern this coordination and help ensure that it occurs. 3.  Require its grant applicants to report all federal grant funding,  including all DOJ funding, that they are currently receiving or have  recently applied for in their grant applications. 4.  Provide appropriate OJP and COPS Office staff with access to both  GMS and CMS and appropriate OVW staff with access to CMS.  5.  As part of DOJ’s evaluation of its grant management systems, DOJ  should ensure that it assesses the feasibility, costs, and benefits of  moving to a single grants management system, including the steps  needed to harmonize DOJ grant processes, so that any variation in  how the granting agencies manage their portfolios is not an  encumbrance to potential system unification. 6.  Ensure the most timely reporting possible of grant award information  to USASpending.gov according to OMB guidelines, which would  enable its grantees to comply with their reporting responsibilities  according to the same guidelines. 7.  Assess whether OAAM relies on an appropriate mix of programmatic  grant monitoring and program assessment, and determine whether  the office could support additional program assessments. 8.  Assess the feasibility, costs, and benefits of OAAM providing  assessments for OVW, in addition to OJP and the COPS Office. If  DOJ determines that OAAM assessments of OVW grant programs  would be more cost-effective and provide greater insight into the  effectiveness of OVW grant programs than OVW’s current approach,  then the Attorney General should extend OAAM’s oversight to include  OVW.

section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to DOJ for comment. DOJ provided  written comments, which are reproduced in full in appendix VI, and  concurred with all eight of the recommendations. DOJ also described  actions it has underway or plans to take to address the recommendations.

DOJ agreed with the first recommendation that it conduct an  assessment to better understand the extent to which the department’s  grant programs overlap with one another. DOJ stated it will explore  options for carrying out such an assessment in an effort to reduce the  risk associated with unnecessary or inappropriate program  duplication. For example, DOJ stated it is considering tasking OAAM  to conduct such an assessment. Since DOJ is developing options for  how it will implement this recommendation, it is too soon to know what  specific actions DOJ will take, when they will be completed, and  whether they will fully address the intent of the recommendation.

DOJ agreed with the second recommendation that it coordinate within  and among granting agencies, to the extent possible, before awarding  grants. DOJ stated that its grant-making agencies will continue to  closely collaborate and share information prior to making grant  awards. DOJ also stated it plans to use the results of the assessment  referenced in the first recommendation to develop a targeted and  strategic approach for reviewing grant applications during the pre- award process. Since DOJ is considering how it will implement this  recommendation, it is too soon to know what specific actions DOJ will  take, when they will be completed, and whether they will fully address  the intent of the recommendation.

DOJ agreed with the third recommendation that DOJ require its grant  applicants to report all federal grant funding, including all DOJ  funding, that they are currently receiving or have recently applied for  in their grant applications. DOJ stated it plans to use a risk-based  approach to implement this recommendation, using the results from  its assessment in response to the first recommendation. This is a  positive step toward ensuring that DOJ has a more complete picture  of an applicant’s access to other federal funding. However, since DOJ  has not yet developed its approach, it is too soon to tell whether  DOJ’s actions will address the intent of the recommendation.

DOJ agreed with the fourth recommendation that DOJ provide  appropriate OJP and COPS Office staff with access to both GMS and  CMS and appropriate OVW staff with access to CMS. DOJ noted that  OJP will provide read-only GMS access to COPS Office staff and that  the COPS Office will provide reports to OJP and OVW from CMS,  given the technological barriers to providing external system access.  These actions, when implemented, should address the intent of this  recommendation.

DOJ agreed with the fifth recommendation that as part of its  evaluation of its grant management systems, DOJ should ensure it  assesses the feasibility, costs, and benefits of moving to a single  grants management system. DOJ stated that it had initiated such a  study and plans to complete it within the next six months. When  effectively completed, this study, along with any actions taken to  implement its findings, should address the intent of this  recommendation.

DOJ agreed with the sixth recommendation that DOJ ensure the most  timely reporting possible of grant award information to  USASpending.gov. DOJ committed to doing its best to ensure timely  reporting, but did not provide specific actions or plans to address the  intent of the recommendation.

DOJ agreed with the seventh recommendation that DOJ assess  whether OAAM relies on an appropriate mix of programmatic grant  monitoring and program assessment, and whether the office could  support additional program assessments. DOJ stated that additional  program assessments would be beneficial and contribute to the  improvement of grant programs and operations. DOJ also stated it  would explore ways to conduct more program assessments, but did  not provide specific actions or plans to address the intent of the  recommendation.

DOJ agreed with the eighth recommendation that DOJ assess the  feasibility, costs, and benefits of OAAM providing assessments for  OVW, in addition to OJP and the COPS Office. DOJ stated that  discussions have been initiated between OAAM and OVW related to  this recommendation. This is a positive first step, but it is too soon to  know whether the results of these discussions and any resulting  potential future actions will address the intent of the recommendation.

In addition, DOJ raised concerns about the methodology we used to  identify overlap in DOJ’s fiscal year 2010 grant program solicitations  across 10 broad justice themes. DOJ stated that our analysis of potential  overlap between DOJ funding solicitations substantially overstated the  number of programs that might be duplicative. DOJ commented that the  table we used to show the overlap was an indication that DOJ was  involved in “wasteful duplication.” Our analysis, as summarized in table 2  of this report, demonstrates overlap in the justice areas that DOJ’s grant  programs aim to support. Having several overlapping grant programs  within individual justice areas requires greater visibility and pre-award  coordination on the part of DOJ to diminish the risk of unnecessary  duplication at the grant project level. As such, our analysis does not, on  its own, indicate unnecessary duplication among DOJ grant programs,  but instead identifies the potential risk of unnecessary duplication.  Implementing the recommendations in this report that DOJ assess grant  program overlap and coordinate grant award decisions will help DOJ  identify areas of overlap and mitigate the risk of unnecessary duplication  in grants. DOJ also considered the categories we developed for our  analysis such as “community crime prevention strategies” as too broad  and exclusive of specialized programs such as community policing. We  developed our 10 broad justice areas based mainly on programmatic  information contained on DOJ granting agency websites and other DOJ  literature and believe they fairly demonstrate overlap among DOJ’s  various grant programs. We recognize that the more detailed analysis we  recommended and DOJ agreed to undertake is necessary to determine  the extent of any unnecessary duplication.

DOJ also commented that our sample size of grant applications was too  small in number and was not generalizable. As discussed in this report,  our sample size was not intended to be generalizable across the entire  scope of DOJ grant program awards, but instead was meant to illustrate  the potential for unnecessary duplication. DOJ further commented that  their investigation of the examples of unnecessary duplication we  provided proved that no duplication actually existed in the grant  programs. DOJ conducted its review after we provided our examples and  focused on how grantees were using the funds they had received. Our  analysis of potential duplication focused on grant applications—how  applicants proposed to spend federal grant dollars—and not on the  verification of activities grantees carried out once DOJ funded them.  DOJ’s plans to improve pre-award coordination are positive steps and we  believe that by doing so, DOJ will be better positioned to make better  informed decisions about the financial needs of grantees and  communities for their proposed projects.

Finally, DOJ expressed concern that the report implies that DOJ is not  tracking subgrantees’ activities. Our analysis focused on pre-award  coordination, not DOJ’s efforts to track subgrantee activities. As such, we  recommended that DOJ use the subgrant award information it does have  to help inform DOJ’s grant award decision making. We believe that  subgrant award information could provide DOJ decision makers with a  more complete financial picture of applicants and the projects they  propose to be funded by DOJ.

We are sending copies of this report to the Attorney General, selected  congressional committees, and other interested parties. In addition, the  report is available at no charge on the GAO website at  http://www.gao.gov.

If you or your staff have any questions about this report, please contact  me at (202) 512-9627 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. Key contributors to this report are listed in  appendix VII.

section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: This report answers the following questions: (1) To what extent does  overlap across Department of Justice (DOJ) grant programs exist and  contribute to the risk of unnecessary duplication in grant awards? (2) To  what extent has DOJ taken steps to reduce overlap in its grant programs  and the potential for unnecessary duplication in grant awards? (3) To  what extent does DOJ use programmatic grant monitoring and  assessment to determine grant program effectiveness and use the results  to enhance its grant programs?

To examine the extent to which overlap across DOJ grant programs  exists, we identified the total number of DOJ grant solicitations for fiscal  year 2010. To do this, we reviewed the lists posted on the Office of  Justice Programs (OJP), Office on Violence Against Women (OWV), and  Community Oriented Policing Services (COPS) Office websites and  confirmed the currency of the information with DOJ officials. To determine  whether these solicitations were announcing grant funding available for  similar or overlapping purposes, we first established 10 categories of  criminal justice areas. We developed these 10 categories after reviewing  comparable justice areas identified within OJP’s CrimeSolutions.gov  website, which OJP officials stated includes themes addressed through  OVW and COPS Office programs; OJP’s Fiscal Year 2010 Program Plan;  and other materials from OVW and the COPS Office, such as justice  program themes from their respective websites. Next, through analyst  consensus, we sorted the grant solicitations according to the 10 justice  categories. After identifying solicitations with similar scopes, we then  reviewed 26 successful grant applications that were awarded under  similar solicitations to identify and assess specific examples of how the  recipients planned to use funds from multiple programs in the same or  similar manner. The sample we reviewed is not generalizable to all DOJ  grant programs because we did not review all of the more than 11,000  grant applications that DOJ funded in fiscal year 2011, but it illustrates the  potential for unnecessary duplication. To determine if DOJ could take  more action to avoid program overlap that can lead to unnecessary  duplication, we applied the Domestic Working Group Grant Accountability  Project’s Guide to Opportunities for Improving Grant Accountability.

To examine the extent to which DOJ has taken steps to reduce overlap in  its grant programs and the potential for unnecessary duplication in grant  awards, we reviewed agency policies, procedures, and guidance on grant  program design and award, such as the COPS Office Program  Development Team charter and template, and the OJP Grant Manager’s  Manual. Further, we interviewed DOJ officials from the three granting  agencies to obtain additional information on grant program design and  award processes, and the extent to which the three agencies coordinate  and share information. We also visited or conducted phone interviews  with officials from 11 states, including the five largest and five smallest  state recipients of Edward Byrne Memorial Justice Assistance Grant  (JAG) funding. These officials represent the state administering agencies  (SAA) responsible for distributing JAG and other DOJ formula block grant  funds to subrecipients in California, Florida, New York, North Dakota,  Pennsylvania, South Dakota, Rhode Island, Tennessee, Texas, Vermont,  and Wyoming. These officials provided their views regarding the type and  timeliness of information on grant awards and subawards they provide to  and receive from DOJ. We selected these 11 states based on the amount  of JAG funding they receive and the existence of other recipients in their  communities receiving DOJ discretionary grants for potentially similar  purposes. The results of these contacts are not generalizable to all states,  but provided insight into how DOJ grant funds are used locally and into  the communication between states and DOJ. To determine if JAG  recipients expended grant funds in fiscal year 2010 on sexual assault  services, bullet and stab-resistant vests, sex offender registry and  notification systems, Internet crime against children task forces, hiring  police officers, and correctional officer salaries, we conducted a web- based survey of all recipients of DOJ JAG grant funding who received an  award from fiscal years 2005 through 2010. The survey response rate  related to SAAs was 89 percent, with 50 out of 56 SAAs answering the  questionnaire. We compared agency grant design and award practices  against Standards for Internal Control in the Federal Government and  promising practices identified in the Domestic Working Group Grant  Accountability Project’s Guide to Opportunities for Improving Grant  Accountability.

To analyze the extent to which DOJ uses programmatic grant monitoring  and assessment to determine grant program effectiveness and uses the  results to enhance its grant programs, we analyzed DOJ documentation,  such as assessments DOJ conducted of its own programs and specific  programmatic grant monitoring reports. We also interviewed DOJ officials  from the granting agencies, including those tasked with assessment, as  well as contractors responsible for assessing grant programs for OVW.  This report focuses solely on the types of assessment conducted by DOJ  granting agencies on its grant programs. Training and technical  assistance provided by the department and its program offices and  bureaus to grantees to support the evaluation of individual grant projects,  such as the Bureau of Justice Assistance (BJA) Center for Program  Evaluation and Performance Measurement, is not included in this report.  Also excluded from this report are the outcome evaluations of the impact  of grant programs such as those funded by the National Institute of  Justice (NIJ).

section_title: Appendix II: DOJ Granting Agencies’ Organizational Structure

section_title: Appendix III: Structure, Purpose, and Funding of DOJ Granting Agencies
paragraphs: OVW  Following the enactment of the  Violence Against Women Act of  1994, the department established  the Violence Against Women  Office, which later became OVW  under OJP. OVW now functions  as a separate and distinct office  within DOJ and is headed by a  presidentially appointed, Senate- confirmed Director.

COPS Office  The Attorney General  established the COPS Office  in October 1994 to  administer community  policing grants authorized  under the Violent Crime  Control and Law  Enforcement Act of 1994.  The Attorney General  appoints a Director to head  the COPS Office.

Bureau of Justice Assistance  Bureau of Justice Statistics

National Institute of Justice

Office of Juvenile Justice

Office for Victims of Crime

Office of Sex Offender  Sentencing, Monitoring,  Apprehending, Registering  and Tracking  OJP provides grants to various  organizations, including state and  local governments, universities,  and private foundations, which  are intended to develop the  nation’s capacity to prevent and  control crime, administer justice,  and assist crime victims.

OVW administers financial and  technical assistance to local,  state, and tribal governments;  courts; nonprofit organizations;  community-based organizations;  secondary schools; institutions of  higher education; and state and  tribal coalitions. OVW provides  grants for developing programs,  policies, and practices aimed at  ending domestic violence, dating  violence, sexual assault, and  stalking.

The COPS Office provides  grants to and shares  information with the state,  local, territory, and tribal law  enforcement agencies to  advance community policing.

From fiscal years 2005 to 2012,  OJP received approximately $24  billion for OJP grant programs.  In 2010, almost 3 billion was  available to OJP to fund grants,  and OJP issued 223 solicitations  for grants.ª According to OJP, it  awarded nearly 5,000 grants in  2010.

From fiscal years 2005 to 2012,  OVW received approximately  $3.4 billion for OVW grant  programs.  In 2010, OVW received $418.5  million for OVW grant programs,  and OVW issued 19 solicitations  for grants.

From fiscal years 2005 to  2012, the COPS Office  received approximately $5.3  billion to fund COPS Office  grant programs.  In 2010, the COPS Office  received $791.6 million to  fund COPS Office grants,  and the COPS Office issued  nine solicitations for grants.

Solicitations are announcements of new grant funding available and explain areas for which funding  can be used. These numbers reflect solicitations provided by each individual office and do not reflect  any joint solicitations, which are those offered in tandem with other program offices, either within or  external to DOJ (e.g., other DOJ components or federal agencies).

section_title: Appendix IV: Consolidated, Braided, and Blended Grant Program Solicitations
paragraphs: According to DOJ officials, there are three ways in which DOJ grant  programs can be merged or better coordinated—through consolidation,  braiding, and blending. Figures 4,5, and 6 explain these mechanisms.

section_title: Appendix V: Office of Audit Assessment and Management Structure
subsections: section_title: Audit and Review Division
paragraphs: coordinates audits, such as Single Audits that independent  nongovernmental auditors conduct, as well as those that the Inspector  General (IG) and GAO conduct,  reviews internal control processes (A-123), and manages DOJ’s High Risk Grantee Program, which applies criteria to  identify grantees most at risk of fraud, waste, or abuse in use of their  grant funds.

section_title: Program Assessment Division
paragraphs: oversees OJP and COPS Office programmatic monitoring, including  development and implementation of standards and protocols, and assesses grant programs and initiatives of OJP and the COPS Office,  as well as operational activities.

section_title: Grants Management Division
paragraphs: serves as the primary resource for OJP grants management policies  and procedures by producing authoritative guidance, develops and facilitates grants related training to staff and grantees, manages Grants Management System (GMS) and other tools and  facilitates OJP’s business process improvement efforts.

section_title: Appendix VI: Comments from the Department of Justice

section_title: Appendix VII: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact

section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Joy Booth, Assistant Director,  and Christian Montz, Analyst-in-Charge, managed this assignment. Julie  E. Silvers, Marya Link, Caitlin Carlberg, and Michael Sweet made  significant contributions to the work. Michele Fejfar assisted with design  and methodology. Janet Temko and Tom Lombardi provided legal  support. Lara Miklozek provided assistance in report preparation.


Question-summary annotations: questions: question: What is the result of the DOJ's overlapping grant programs?
answer: The Department of Justice’s (DOJ) grant programs overlap across 10 justice areas contributing to the risk of unnecessarily duplicative grant awards for the same or similar purposes.

question: What did GAO find in their review?
answer: For example, GAO reviewed all 253 grant award announcements that DOJ’s Office of Justice Programs (OJP), the Office on Violence Against Women (OVW), and the Community Oriented Policing Services (COPS) Office published on their websites for fiscal year 2010 and found overlap across the justice areas.
child_questions: question: What instances did GAO find where applicants got funding from overlapping programs?
answer: For example, 56 of DOJ’s 253 grant solicitations—or more than 20 percent—were providing grant funds for victim assistance and related research. GAO also found instances where applicants used the same or similar language to apply for funding from these overlapping programs. In one example, a grant recipient applied for, and received, funding from both OJP’s Internet Crimes Against Children program and the COPS Office’s Child Sexual Predator Program to provide training for cyber crime investigations and establish an Internet safety program.

question: Why are overlapping grant programs generally bad for the DOJ?
answer: In some instances, DOJ may deem it appropriate for distinct grant programs to serve one goal, or for one community or grantee to benefit from multiple streams of grant funding. However, DOJ generally lacks visibility over the extent to which its grant programs overlap and thus is not positioned to minimize the risk of potential, unnecessary duplication before making grant awards.

questions: question: How has DOJ addressed overlap in its grant programs?
answer: DOJ has taken some actions that address overlap in its grant programs; for example, by requesting statutory authorization in some instances to consolidate programs that are similar.

question: How would DOJ benefit from conducting an assessment of its grant programs?
answer: Doing so would enable DOJ to identify program areas where overlap may be desirable and where a consolidation of programs may be more efficient.

question: How does OJP and OVW using separate grant management systems from COPS affect the overlap in grants awarded?
answer: Further, OJP and OVW use a separate grants management system than the COPS Office uses, limiting their ability to share information on the funding they have awarded or are preparing to award to a recipient.
child_questions: question: What is COPS's justification for using a separate system?
answer: According to COPS Office officials, its mission and grant management processes are unique enough to necessitate a separate system.

question: What is the purpose of the study DOJ has initiated?
answer: DOJ has initiated a study to assess the feasibility, costs, and benefits of unifying the systems among other options.
child_questions: question: What effects could the study have?
answer: By ensuring that such a study accounts for the effort necessary to harmonize departmental grant processes, DOJ could ensure that variations in such processes do not encumber system unification.

questions: question: What is the purpose of DOJ's Office of Audit, Assessment, and Management?
answer: DOJ’s Office of Audit, Assessment, and Management (OAAM) oversees monitoring of grantees’ compliance and conducts grant program assessments to gauge program effectiveness.

question: Why do OAAM's program assessments yield richer information than its monitoring reports?
answer: GAO found that OAAM’s program assessments yield richer information than its monitoring reports because they identify improvement areas.
child_questions: question: What have OAAM officials said about additional assessments?
answer: OAAM officials believe additional assessments could be beneficial. They also said they lacked resources to conduct more, but had not conducted a feasibility analysis to confirm this.

question: How can OAAM ensure continuous improvement in grant programs?
answer: By OAAM examining its mix of monitoring and assessment activities, including the costs and benefits of current resource allocations, it could better ensure continuous improvement in grant programs.

questions: question: Why has $33 billion been appropriated to DOJ?
answer: Since fiscal year 2005, approximately $33 billion has been appropriated to DOJ for the administration of more than 200 federal financial assistance solicitations, such as grants, that support criminal justice activities at the state and local levels.

question: What does the report address?
answer: Pursuant to section 21 of Public Law 111-139, this report addresses the extent to which (1) overlap exists across DOJ grant programs and if it contributes to the risk of unnecessary duplication in grant awards, (2) DOJ has taken steps to reduce overlap and the potential for unnecessary duplication in its grants awards, and (3) DOJ uses monitoring and assessment to determine grant program effectiveness and uses the results to enhance its grant programs.

question: What steps did GAO take to assess DOJ?
answer: GAO assessed DOJ’s fiscal year 2010 announcements of grant award funding; categorized them according to key justice areas to identify any overlap; and interviewed DOJ officials about their grant making practices, systems, and assessment methods. Further, GAO interviewed officials from 11 states receiving DOJ grants, selected for the levels and types of funding received.
child_questions: question: What information did the interviews that GAO conducted provide?
answer: Though not generalizable, the interviews provided their perspectives on funding.