Community Policing Hiring Grants: Grant Application and Monitoring Processes Could Be Improved to Further Ensure Grantees Advance Community Policing
Released: 2013-09-25T00:00:00

Letter

Background

Community Policing

The Public Safety Partnership and Community Policing Act of 1994, as amended, authorizes grants to states, units of local government, Indian tribal governments, other public and private entities, and multi- jurisdictional or regional consortia for a variety of community policing- related purposes. Among other things, this includes the hiring and rehiring of law enforcement officers for deployment in community policing and developing and implementing innovative programs to permit members of the community to assist law enforcement agencies in the prevention of crime in the community. The act also requires that grantees not supplant state and local funding, but rather use the federal funds for activities beyond what would have been available without a grant. To administer the grant funds authorized by the act, the Attorney General created the COPS Office in October 1994. Since 1994, the COPS Office has awarded roughly $14 billion to advance community policing through its various grant programs.

The COPS Office defines community policing in its CHP applications and Grant Owner’s Manual, issued annually, as “a philosophy that promotes organizational strategies, which support the systematic use of partnerships and problem-solving techniques, to proactively address the immediate conditions that give rise to public safety issues, such as crime, social disorder, and fear of crime.” The CHP grant applications describe some of these terms: community partnerships: collaborative partnerships between the law enforcement agency and the individuals and organizations they serve to both develop solutions to problems and increase trust in police; organizational transformation: the alignment of organizational management, structure, personnel and information systems to support community partnerships and proactive problem-solving efforts; and problem solving: the process of engaging in the proactive and systematic examination of identified problems to develop effective responses that are rigorously evaluated.

A characteristic of community policing is its emphasis on proactive policing—an approach to preventing crime—which is contrasted with traditional, reactive policing—an approach that responds to crime—both of which the interactive figure 1 illustrates.

Move the mouse over the icons to view more information. This additional information is also reproduced in appendix II for readers of printed copies.

Reactive policing responds to crime after it has occurred.

Proactive policing attempts to prevent crime from occurring. $ From fiscal years 2008 through 2012, the COPS Office managed 10 programs designed to advance community policing. As table 1 illustrates, these 10 programs provided funding to target crime issues, such as school violence, as well as to hire officers or develop crime-fighting technology, among other things.

As table 1 indicates, CHP accounted for 68 percent of the funds awarded through the COPS Office’s various grant programs. The program provides these funds over a 3-year term, on a reimbursable basis, meaning that the COPS Office approves grants for a specified number of officer hires or rehires—in cases where officers have previously been laid off—but provides the funding to the law enforcement agencies once these officers are onboard. Grantees must use the funds to hire or rehire additional officers for deployment in community policing or can redeploy a commensurate number of experienced locally funded officers to community policing after the entry-level officers are hired with CHP funds. By law, each year CHP funding must be split in such a way that the total grant funding awarded to each eligible state—meaning the sum of the grants awarded to applicants in that state—equals at least one-half of 1 percent of the total CHP funding appropriated by Congress for that year. At the same time, the law requires that CHP funding be evenly split between entities serving jurisdictions with populations exceeding 150,000 people and those serving jurisdictions with populations of 150,000 or fewer. Specific award provisions, such as salary and benefit caps per officer funded; grantee fund-matching requirements; and other nuances, including a recent emphasis on the hiring of veterans, have varied each year since the CHP’s first authorization, in 1994. For example, in 2008 and 2012, pursuant to the statutory requirements for the grant program, grantees were required to match the CHP award with at least 25 percent of local nonfederal funds and salary caps of $75,000 and $125,000, respectively, applied. However, under the American Recovery and Reinvestment Act (Recovery Act) these requirements did not apply in 2009, 2010, and 2011. Table 2 highlights changes in the CHP during the past 5 fiscal years that affected the amount of funding available to applicants as well as which applicants received funding.

To select grantees for CHP, the COPS Office requires applicants to respond electronically to closed-end questions and provide a narrative description of the crime problems they are facing, among other things, in their grant applications. For example, one of the close-ended questions asks applicants to add a check mark if their agencies’ strategic plans include specific goals or objectives relating to community partnerships or problem solving. Another close-ended question provides response categories for applicants to select the ways in which their agencies share information with community members. According to COPS Office officials, in consultation with the Associate Attorney General and the Deputy Attorney General, they establish weights for (1) community policing questions, (2) questions pertaining to the applicants’ fiscal health, and (3) reported crime levels. They then score the applications and award funds to those applicants with the highest scores. For example, in fiscal years 2009 and 2010, fiscal health accounted for 50 percent, crime rates accounted for 35 percent, and community policing activities accounted for 15 percent of the total score.

To monitor grantee performance, the COPS Office requires, as a term and condition of its grants, that grantees participate in grant-monitoring and -auditing activities, which can include programmatic and financial reviews of their funded activities. Accordingly, COPS Office officials stated that all grantees are required to submit quarterly progress reports that provide financial and programmatic information, such as their progress in implementing the community policing plan they described in their grant applications for utilizing CHP funds to advance community policing. According to the COPS Office, the goal of its monitoring is to assess grantees’ stewardship of federal funding, performance, innovation, and community policing best practices resulting from COPS Office funding. In addition, according to the COPS Office, because of the number of COPS Office grantees, the COPS Office selects a limited number of grants to monitor based upon a grantee’s level of risk. In addition to the size of the grant award, such risk factors include, but are not limited to, whether or not the grantee has prior federal grant experience, has submitted late reports of its progress or failed to submit progress has requested grant extensions.

Nearly Half of CHP Funding In the Past 5 Years Was Awarded to Grantees in Six States, and Award Amounts Varied Considerably in Certain Years

As the interactive map in figure 2 illustrates, CHP grant awards were distributed throughout the United States from fiscal years 2008 through 2012.

The interactive map can be accessed here: http://www.gao.gov/products/GAO-13-521 As figure 3 illustrates, 48 percent of the funding was awarded to grantees in six states—California, Florida, Michigan, New Jersey, Ohio, and Texas. Across all the states, grantees in California received the highest level of total CHP funding from 2008 through 2012. Specifically, total CHP awards in California equaled approximately $360 million, or more than 20 percent of the total CHP funding awarded.

Officials from the COPS Office cited several factors that influenced the allocation of grant funds across the states and territories. In particular, officials pointed to the population-based statutory provision described previously, which requires the COPS Office to allocate 50 percent of available grant funding to jurisdictions with populations exceeding 150,000 and 50 percent to jurisdictions with a population of 150,000 or fewer. Officials noted that some states—for example, California—have more cities with populations exceeding 150,000 compared with other states. This enables a smaller number of states to compete for half of the total grant funding, while a greater number of states without cities of this size compete for the remaining half of the total. Further, these large cities tend to receive larger awards because they deploy comparatively more officers than smaller cities. Apart from a separate statutory provision, also described previously, which requires that each state receive at least one- half of 1 percent of the total CHP funding appropriated by Congress each year, COPS Office officials emphasized that a grantee’s particular location is not prioritized over the application categories of community policing, crime data, and fiscal health. Regarding fiscal health, officials noted that certain states have been disproportionately affected by fiscal distress, a factor that is directly reflected in the fiscal health component of the CHP application. Finally, the number of law enforcement agencies— and thus potential applicants—varies across states, which contributes additional variation in how funding is ultimately distributed.

For grantees awarded the same number of officers, differences were driven mainly by variation across grantees’ respective entry-level officer salaries and benefits—the only costs CHP allows. However, this variation was more prominent during years when salary and benefit levels were not statutorily capped: 2009 through 2011. Thus, during the period 2009 through 2011, grantees with higher officer salary and benefit levels generally received more CHP funding relative to other CHP grantees to hire, rehire, or prevent layoffs for the same number of officers. For example, in fiscal year 2011, a grantee in California received a CHP award equivalent to its entry-level officer salary and benefits level of $150,753 per officer. In the same fiscal year, a grantee in Connecticut received a CHP award—also based on its entry-level officer salary and benefits—of $64,459 per officer per year. As a result of these local variations in per officer cost, this particular Connecticut grantee received and used 57 percent less federal funding to support each officer it hired or rehired compared with its California counterpart in this example. According to COPS Office officials, geographical differences in the cost of living could partly contribute to wage differences. Additionally, the availability of state and local budgetary resources to support law enforcement salaries and benefits may have affected wages. Further, COPS Office officials stated that other factors unique to certain areas of the country could account for the wage disparity that drives CHP costs. For example, some agencies may participate in more expensive state retirement systems or may not be able to set wages that align with market conditions because of union labor contract obligations. Figure 4 displays the average annual CHP-funded officer salary and benefit levels, by state and territory, for awards made from fiscal year 2009 through 2011—the years in which CHP grants awards were not capped.

In contrast, statutory salary and benefit caps were in place for fiscal years 2008 and 2012; thus during these years, each grantee was limited to receiving the same per officer maximum, irrespective of local differences in salary and benefit levels. Any officer-related expenses over and above the cap were the independent funding responsibility of the grantee and were not covered by CHP funding. As a result, less variation in award amounts occurred in fiscal years 2008 and 2012—when there was a cap—as compared with fiscal years 2009, 2010, and 2011—when there was no cap. According to DOJ officials, some additional variation in average award amounts occurred in 2012 as a result of the COPS Office exercising statutory authority allowing the COPS Office Director to waive the $125,000 salary and benefit cap, as well as the matching requirement when awarding grants. In 2012, the COPS Office granted 41 local match-and-cap waivers out of the 248 applicants that had requested them.

Our analysis shows that interest in CHP funding remains high with the $125,000 per officer cap. From fiscal years 2008 through 2012, the COPS Office received more requests for CHP funding in grant applications than it could accommodate. The cap for fiscal year 2013 is $125,000, and in the President’s budget request for fiscal year 2014, the cap remains at $125,000.

The COPS Office’s CHP Application Collects Information Required by Statute, but Could Be Further Enhanced by Clarifying that CHP- Funded Officers Are Required to Be Engaged in Community Policing Activities

The CHP application solicits information from applicants in accordance with statute, but the COPS office may realize benefits by revising the application to clarify for applicants that CHP-funded officers are required to be the personnel specifically engaged in the community policing activities described on the application. The statute authorizing COPS Office grant programs requires applications, including the CHP application, to gather information from applicants related to several items, including, but not limited to the applicant’s explanation of how the grant will be used to reorient its mission toward plans for obtaining support at the conclusion of federal funding, and detailed implementation plan and long-term strategy that reflects consultation with community groups and appropriate private and public agencies. community policing or enhance its involvement in or commitment to community policing, specific public safety needs, inability to address the needs without federal assistance, The statute does not further specify the content of these items, particularly the content of the detailed implementation plan and long-term strategy. However, the 2012 CHP application requires applicants to provide related information, such as how applicants plan to reorient their mission toward or enhance their involvement in or commitment to community policing. Specifically, COPS Office officials reported that the Law Enforcement & Community Policing Strategy section of the application is intended to obtain information from applicants to address the requirements of a detailed implementation plan and long-term strategy. For instance, this section requires applicants to include information on the crime problem that will be addressed with grant funds, information sources that will be used to improve the understanding of the problem and determine whether the response was effective, and the partnerships the agency will form.

The application further requires applicants to indicate the community policing activities their entire agency was currently engaged in as well as those activities their organization intended to enhance or initiate with CHP funds. The fiscal year 2012 application notes that the COPS Office recognizes that CHP-funded officers will engage in a variety of community policing activities and strategies, including participating in some or all aspects of the applicant’s implementation plan. However, the application does not specifically ask applicants to explain how CHP-funded officers will be deployed in community policing—the primary purpose of the CHP program as expressed by the statute. For instance, the application does not ask applicants to provide information on what community policing activities, such as attending community meetings, CHP-funded officers will be undertaking.

The Domestic Working Group’s guide for improving grant accountability provides best practices for designing grant applications, including specific elements that are recommended to be addressed in grant applications. The Domestic Working Group, composed of federal government inspectors general and chaired by the Comptroller General of the United States, created the guide to share useful and innovative grant management approaches with government executives at the federal, state, and local levels. Specifically, the Domestic Working Group’s guide recommends that agencies require applicants to submit a detailed narrative as evidence of proper work planning to obtain and evaluate information from applicants when making award decisions, and include information to link grant activities with results, which is often referred to as logic modeling. As part of the logic model approach, applicants should, among other efforts, identify the need for funding, their approach to using the funds, specific activities that are crucial to the success of the program, and desired objectives and benefits anticipated—and then logically connect these efforts to a plan for measuring results.

We found through our analysis of a systematic random sample of 103 CHP-funded applications for fiscal years 2010, 2011, and 2012 that the application could be enhanced by applying these best practices to clarify for applicants that CHP-funded officers are required to be the personnel specifically engaged in the community policing activities described on the application. According to our analysis of the application sample, we estimate that less than 20 percent of the applications funded in these years contained evidence showing how additional officers would be deployed in support of community policing.

Several of the questions in the 2010, 2011, and 2012 applications ask for information on the agency-wide actions grantees plan to undertake to facilitate community policing. COPS Office officials reported that individual CHP-funded officers are expected to implement the items indicated in the implementation plan. These actions could include implementing recruitment and hiring practices that reflect an orientation toward problem solving and community engagement, enhancing information technology systems, and implementing organizational performance measurement systems that include community policing metrics. COPS Office officials agreed that the application could be clearer by stating the requirement that CHP-funded officers should be the ones who are specifically engaged in CHP-funded activities.

Revising the application to clarify for applicants that CHP-funded officers are required to be the personnel specifically engaged in the community policing activities described on the application, consistent with best practices, would better position the COPS office to ascertain from applicants how these particular officers’ activities would advance community policing.

The COPS Office’s Monitoring Process Assesses How Grantees Are Using CHP Funds to Advance Community Policing, but Could Be Improved through Additional Monitoring Guidance

The COPS Office Takes a Risk-Based Approach to Grant Monitoring and Has Processes to Monitor How Grantees Are Using Funds

To help ensure that grantees are implementing the activities and meeting the financial requirements they committed to in their respective applications, the COPS Office is required to monitor at least 10 percent of its open, active grant funding annually. According to the Domestic Working Group’s guide for improving grant accountability, it is important that agencies identify, prioritize, and manage potential at-risk grantees. Consistent with this best practice and to fulfill its statutory monitoring requirement, the COPS Office uses a risk-based approach to select which grantees to monitor and visit using its Grant Assessment Tool (GAT), which is currently used by the COPS Office to assess grantee risk. The GAT uses criteria to generate individual risk scores, as illustrated in table 3, and a final, comprehensive risk assessment score is computed for grantees.

Once the monitors review what the GAT has generated, they are to develop a plan for monitoring those grantees with the highest risk scores. According to the COPS Office’s monitoring standards—a guide that describes the responsibilities of grant monitors—the COPS Office monitors these grantees in a number of ways, including, but not limited to, on-site monitoring, office-based grant reviews, and complaint and legal reviews. During on-site monitoring visits, monitors are required by the monitoring standards to review and compare the proposed projects and activities contained in grant applications and quarterly progress and financial status reports with those of the grantees’ performance and progress in carrying them out. Upon completion of their visits, monitors are required to document their observations and assessments in a grant- monitoring report and cite any grant compliance issues, which may be cited in categories including community policing, retention, allowable costs, and the source and amount of matching funds.

Office-based grant reviews, which are used to provide detailed monitoring for those grantees that are not selected for on-site monitoring using the GAT, are similar to on-site reviews in that monitors are required to review grantee documentation, including the application, and follow up directly with the grantee to collect any additional information and documentation on how grantees are using funds. This type of monitoring, according to COPS Office monitoring standards, allows the COPS Office to monitor a larger number of grantees than would be possible through on-site monitoring alone. In addition to these monitoring methods, the COPS Office also uses complaint reviews to investigate internal and external complaints, such as those raised by the media and citizens, regarding grantee noncompliance. The COPS Office’s Legal Division also conducts additional monitoring related to, among other things, supplanting—using federal funds to replace state or local funds—and DOJ IG investigations of grantees involving fraud. According to the monitoring standards, all of these monitoring efforts help the COPS Office determine whether the grantees are complying with the requirements of the grant and that funds are spent properly. Accordingly, the COPS Office uses these various monitoring methods to identify any grant violations, such as not using the funds to hire officers for deployment in community policing, and recommend resolutions to these violations. In cases where the grantee has failed to remedy violations identified by the monitor, the grantee, according to the monitoring standards, may be faced with adverse current and future determinations regarding its suitability for receiving grant funds, the suspension or termination of grant funds, repayment of expended grant funds to the COPS Office, and even criminal liability in the event of fraud.

The COPS Office Has Standards for Monitoring Supplanting, but Could Strengthen Its Guidance for Documenting Supplanting Analysis in Monitoring Reports

The authorizing statute for the COPS grant programs, including CHP, requires that grantees not supplant state and local funding, but rather use the federal funds for activities beyond what would have been available without a grant. As a condition of accepting COPS Office funding, grant applicants must certify they will use grant funding only to increase the total amount of funds available for the hiring or rehiring of law enforcement officers and not supplant state and local funding. To identify supplanting risks, the COPS Office developed standards for monitors to use in assessing the potential for supplanting, which is one of the compliance issues monitors are required to evaluate. Monitors can use these supplanting standards in all forms of monitoring, including on-site, office-based desk, complaint, and Legal Division reviews. The standards contain clear guidance for identifying potential noncompliance with supplanting standards. For example, according to the COPS Office’s grant monitoring standards and, as illustrated in table 4, there are four major patterns of risk associated with supplanting.

The CHP supplanting standards also require grant monitors to conduct an analysis and review of supporting evidence to ensure grantees have not engaged in supplanting. Some of the acceptable documentation, according to the COPS Office, can be: budget documents that can show the replacement rate of officers has documentation that shows the grantee has experienced fiscal distress, or city council minutes showing there has been difficulty in local hiring.

The standards do not specify how monitors should document their analysis and conclusions about potential supplanting issues in the monitoring reports they prepare after site visits. According to COPS Office officials, these reports are a critical component of the monitoring process. The COPS Monitoring Operations Manual—a technical guide for monitoring—requires monitors to identify and provide relevant details in monitoring reports where supplanting is identified. However, it does not require monitors to document their analysis and conclusions in instances in which the determination is ultimately made that supplanting has not occurred. As a result, it may be unclear how the monitors assessed these cases to reach conclusions that supplanting had not occurred in these instances. In our review of the monitoring reports for 39 of 55 grantees that had already begun to use CHP funds and were visited by grant monitors, we found 21grantees for which there was a pattern of risk for potential supplanting. For 16 of these 21, we concluded that the site visit reports clearly documented the analysis and conclusions reached by the monitors regarding supplanting issues. For example, one monitor noted in a site visit report that potential supplanting existed because a police department failed to fill local vacancies at the same time it hired officers using COPS grant funds. The monitor determined that there was no violation for supplanting based on information provided during and after the site visit demonstrating that the department was taking active and timely steps to fill local vacancies and that the department was prohibited from filling vacancies earlier because of a town-wide spending freeze. The site visit report listed the documentation that the monitor reviewed in making a determination that there was no violation, including copies of budget documents demonstrating town-wide cuts in personnel and the town’s fiscal distress, a memorandum implementing a town-wide spending freeze, an online job posting for the vacant officer positions, and the police department’s request to the town for authorization to fill the vacancies.

However, for the remaining 5 of 21 grantees, we found that the monitors did not document their assessments of supplanting issues, and it was not clear how they reached conclusions regarding potential supplanting. The reports for these 5 grantees indicated that there were delays in filling vacancies for locally funded officer positions at the time when officers were hired for CHP-funded positions. For example, in one report, the data showed that there were over 50 vacant locally funded positions in fiscal year 2010 that continued to be unfilled in fiscal year 2011, when the same department hired 27 officers with COPS funding. When the monitor visited the department in August 2012, there were still 59 locally funded vacancies. The site visit report noted that the department anticipated filling the vacancies in November 2012 and did not discuss any supplanting compliance issues. The report did not provide details on documentation reviewed or other information obtained to demonstrate the analysis performed or the basis for determinations on potential supplanting issues. It was unclear from this whether or how the monitor had assessed potential supplanting issues. In following up with the COPS Office on this case, officials provided us with additional evidence that the monitor had assessed supplanting and determined it had not occurred. Specifically, the monitor obtained documentation from the police department supporting that the department had completed recruitment for the positions and was in the middle of the applicant selection process. COPS Office officials also provided us with additional information that monitors had obtained on site visits for the other 4 cases that was not included in the monitoring reports, but supported that the monitors had assessed potential supplanting issues and determined supplanting had not occurred. Including this information in the site visit reports would document that supplanting issues were properly assessed in accordance with the monitoring standards.

Given the statutory prohibition against the supplanting of federal funds and the importance of documentation for agency accountability, monitors should consistently document the results of their supplanting analysis in the monitoring reports for on-site monitoring. According to Standards for Internal Control in the Federal Government, the documentation of agency activities is a key element of accountability for decisions. By enhancing the COPS Office’s monitoring guidance, such as its standards or operations manual, to require monitors to document the results of their supplanting analysis in the on-site monitoring reports for instances where the determination is made that no supplanting has occurred, the COPS Office could be better positioned to ensure that monitors are consistently assessing supplanting and that CHP funding is supplementing and not replacing state and local funding. Additionally, ensuring that monitors consistently document the results of their supplanting analysis would increase transparency and enhance oversight of CHP funds.

Conclusions

The COPS Office awarded approximately $1.7 billion in grant funds from fiscal year 2008 through 2012 for hiring officers to advance community policing. To ensure that grantees are using the funds as intended by the program, the COPS Office’s CHP application collects information required by statute, including information on how applicants will implement community policing on an agency-wide scale. However, the application does not require prospective grantees to provide information on the specific community policing activities of CHP-funded officers or a commensurate number of experienced locally funded officers. Revising the application to clarify for applicants that CHP-funded officers are required to be the personnel specifically engaged in the community policing activities described on the application, consistent with best practices, would better position the COPS office to ascertain from applicants how these particular officers’ activities would advance community policing. In addition, we found that while the COPS Office has developed standards and an operations manual for monitors to use in assessing the potential for supplanting, the COPS Office’s monitoring standards and operations manual do not require monitors to document their analysis and conclusions in instances in which the determination is ultimately made that supplanting has not occurred. We found that for 5 of the 21 grantees for whom we identified as at risk for supplanting, the monitors included information in the monitoring reports on supplanting, but did not document their assessments of the supplanting issues. Enhancing the COPS Office’s monitoring guidance, such as its standards or operations manual, to require monitors to document the results of their supplanting analysis in the on-site monitoring reports for instances where the determination is made that no supplanting has occurred could better position the COPS Office to ensure that monitors are consistently assessing supplanting and ensuring that CHP funding is supplementing and not replacing state and local funding.

Recommendations for Executive Action

To further enhance the accountability of the CHP, the Attorney General should direct the COPS Office Director to take the following two actions: 1. revise the CHP application to clarify for applicants that CHP-funded officers are required to be the personnel specifically engaged in the community policing activities described on the application; and 2. enhance the COPS Office’s guidance, such as its monitoring standards or operations manual, by requiring monitors to document the results of their supplanting analysis in on-site monitoring reports for instances where the determination is made that no supplanting has occurred.

Agency Comments and Our Evaluation

. We provided a draft of this report to DOJ and the COPS Office for review and comment. The COPS Office provided written comments on the draft report, which are summarized below and reproduced in full in appendix III. The COPS Office concurred with the two recommendations in the report and identified actions planned to implement the recommendations. The COPS Office also discussed concerns it had with the discussion of the grant application and wording of the second recommendation in the draft report.

The COPS Office concurred with the first recommendation, that the COPS Office revise the CHP application to clarify for applicants that CHP- funded officers are required to be the personnel specifically engaged in the community policing activities described on the application. The COPS Office stated that, in response to the recommendation, it clarified in the current CHP Grant Owner’s Manual and will clarify in subsequent years’ CHP applications that the questions in the grant application apply not only to the agency overall but to the CHP-funded officers as well. Once the COPS Office has taken action to fully implement this recommendation, it will be better positioned to ascertain from applicants that officers’ activities would advance community policing.

While the COPS Office concurred with the recommendation, it raised concerns in its letter about how we characterized the way the COPS Office collects information via the CHP application on the activities of CHP-funded officers. Specifically, the COPS Office disagreed with the statements that (1) the 2012 CHP application does not specifically ask applicants to explain how CHP-funded officers will be deployed in community policing and that (2) less than 20 percent of the applications funded in 2010, 2011, and 2012 contained evidence showing how additional CHP-funded officers would be deployed to community policing. According to the COPS Office, the CHP application contains over 70 individual close-ended questions and 3 narrative questions regarding activities that CHP-funded officers and agencies will commit to as a requirement of the grant. The report acknowledges that the COPS Office collects an array of information from applicants on the agency-wide activities they plan to conduct. However, our analysis—including the analysis of a systematic random sample of CHP-funded applications— was intended to demonstrate the extent to which CHP applications contained information about how additional officers would be deployed in community policing in the absence of the application not specifically asking applicants to describe which community policing activities individual CHP-funded officers will undertake. Revising the application to clarify for applicants that CHP-funded officers are required to be the personnel specifically engaged in the community policing activities described on the application, consistent with best practices, would better position the COPS Office to ascertain from applicants how these particular officers’ activities would advance community policing.

The COPS Office also disagreed with a statement in the draft report that the COPS Office stated that there could be benefits to revising the application to more clearly delineate the activities in which CHP-funded officers should be engaged. Rather, the COPS Office stated in its letter that the application could be clearer by stating that the office is requiring that COPS-funded officers should be the ones who are specifically engaged in CHP- funded activities. We modified the recommendation and related language in the report to reflect this point. We provided the modified recommendation language to the COPS office, and on September 19th in an e-mail from CHP program officials, the office concurred.

The COPS Office concurred with the second recommendation to enhance the COPS Office’s monitoring guidance by requiring monitors to document the results of their supplanting analysis in on-site monitoring reports for instances where the determination is made that no supplanting has occurred. The office stated that it had checks and balances in its monitoring practices on the review of grantee documents and guidance for documenting analysis results when supplanting is identified.

While the COPS Office concurred with the recommendation, it noted in its letter that our recommendation as originally worded implied that the existing monitoring guidance does not require grant monitors to document the results of their supplanting analysis for cases in which supplanting has been identified. Since the COPS Monitoring Operations Manual requires monitors to identify and provide relevant details in the monitoring reports regarding instances in which supplanting has occurred, the COPS Office requested that we amend the recommendation with language stating that the monitoring reports be enhanced by ensuring that monitors document the results of their supplanting analysis in instances that do not give rise to supplanting concerns. We adjusted the recommendation and related language accordingly to clarify this point.

Further, in response to the recommendation, the COPS Office outlined initiatives it has implemented to modify its COPS Monitoring Operations Manual that reflect changes to data collection tools and instructions on how monitors should document their supplanting analysis, including instances in which monitors determine that no supplanting has occurred, in the monitoring reports. These actions, if implemented effectively, should address the intent of the recommendation.

We are sending copies of this report to the Assistant Attorney General For Administration, and interested congressional committees. In addition, this 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 III.

Appendix I: Objectives, Scope, and Methodology

This report answers the following questions: (1) From fiscal years 2008 through 2012, in what areas of the country was the Community Oriented Policing Services (COPS) Hiring Program (CHP) funding disbursed and to what extent did award amounts vary during this period? (2) To what extent does the COPS Office’s grant application collect information about how applicants plan to use CHP-funded officers to advance community policing? (3) To what extent does the COPS Office’s monitoring process assess whether grantees are using funds to advance community policing?

To address the first question, we reviewed the history of the COPS Office’s programs and related award data from the most recent 5 fiscal years—2008 through 2012—and confirmed that CHP received the largest share of award funds as compared with other programs administered by the COPS Office during this period. We also analyzed COPS Office documentation, such as Grant Owner’s Manuals and COPS Office website materials, to learn about each COPS program’s origin and emphasis. To determine which areas of the United States have received CHP funding, we analyzed the allocation of CHP grant awards—and the numbers of officers funded—by state and mapped the CHP grant award data. Additionally, we analyzed CHP award lists for fiscal years 2008 through 2012 to determine the average CHP entry-level officer salary and benefits by state, and assessed them for variation. To assess the reliability of data used in our review, we reviewed system tests that the COPS Office conducts periodically to ensure data reliability and interviewed COPS Office officials about the integrity of the data they provided to us. We determined that the data were sufficiently reliable for the purposes of our report. We also interviewed COPS Office officials responsible for managing the CHP program to verify grant program information, determine factors that could account for variations in grant award amounts, and learn about other administrative aspects of the program.

To address the second question, we assessed CHP documentation, including CHP grant applications and Grant Owner’s Manuals to determine how the COPS Office’s application collects information about how applicants plan to use CHP-funded officers to advance community policing. We examined the CHP authorizing statute and best practices for grants management identified in the Domestic Working Group Grant Accountability Project’s Guide to Opportunities for Improving Grant Accountability and compared the criteria outlining promising practices for grant applications, such as designing applications to gather sufficient information for making award decisions, with the COPS Office’s approaches for designing the CHP application.

To better understand these approaches, we reviewed the CHP application design, allowable activities, and the COPS Office’s criteria for selecting awardees. Specifically, we used elements of the CHP authorizing statute and key best practices for grant management to develop a data collection instrument we used to review all applications from a sample of 103 out of the 841 grants awarded during fiscal years 2010, 2011, and 2012. We chose to evaluate applications from these 3 fiscal years to provide an assessment of the most recent fiscal years’ application design. Using the data collection instrument, we reviewed the application sample to determine, among other items, the applications’ level of detail in describing applicants’ planned use of funds. Each application was first reviewed by an analyst, and the information recorded in each completed instrument was then verified by a second analyst. To ensure a selection of grants representative of the dollar amount distribution in the population of 841 awarded grants, we sorted the population by the grant dollar amount and then selected a systematic random sample of 104 grants. During our review, we discovered that 1 grant in our sample was out of scope because the grantee did not accept the grant funds and was no longer considered an active grantee. We reviewed the remaining 103 grant applications in our sample and treated them as a simple random sample for purposes of estimation. Because we followed a probability procedure based on random selections, our sample is only one of a large number of samples that we might have drawn. Since each sample could have provided different estimates, we express our confidence in the precision of our particular sample’s results as a 95 percent confidence interval (e.g., plus or minus 9 percentage points). This is the interval that would contain the actual population value for 95 percent of the samples we could have drawn. With the finite population correction factor, the precision for estimates drawn from this sample is no greater than plus or minus 9 percentage points at the 95 percent level of confidence. To ensure the reliability of data used in our review, we interviewed COPS Office officials about the integrity of the data they provided to us and reviewed system tests that the COPS Office conducts periodically to ensure data reliability. We also ensured that the electronic data CHP applicants submitted could not be altered once submitted to the COPS Office. We determined that the data were sufficiently reliable for the purposes of our report.

We also conducted interviews with a nonprobability sample of 20 CHP grantees in California, Florida, Illinois, Massachusetts, Texas, and Wisconsin. We selected these grantees from five metropolitan areas according to criteria that included the amount of funding received by the grantees, the concentration of grantees within a metropolitan area to maximize the amount of information we could collect, and the population size served by grantees. The results of these interviews are not generalizable to all grantees, but provided insight, among other things, into how CHP grant funds are used locally to advance community policing. Finally, we interviewed COPS Office officials who oversee the application process to gather further information on the design of the application, including how the applications were scored.

To address the third question, we obtained and examined the monitoring reports for 55 grantees awarded CHP grants from the 3 most recent fiscal years—2010 through 2012—with completed, available monitoring reports. The COPS Office produced these reports following the on-site monitoring visits it conducts with grantees to assess their progress and identify any compliance issues for CHP grants. Specifically, we developed a data collection instrument to review the monitoring reports to assess the extent to which the COPS Office identified and documented supplanting. We used the questions on the data collection instrument to make these assessments. Each report was first reviewed by an analyst, and the information recorded in each completed instrument was then verified by a second analyst. We then compared the COPS Office’s monitoring practices with best practices identified in the Domestic Working Group Grant Accountability Project’s Guide to Opportunities for Improving Grant Accountability; Standards for Internal Control in the Federal Government; and COPS Office guidance, such as its grant-monitoring standards. For context, we also considered findings from prior GAO work on program evaluation and the COPS Office’s management of its grant programs. To understand how the COPS Office assesses the potential for supplanting, we used COPS Office guidance on determining supplanting in reviewing the monitoring reports to identify grantees at risk of using CHP funds to replace state and local funds. Additionally, we assessed how the monitors addressed and documented instances in which grantees were vulnerable to supplanting, such as collecting and evaluating additional budget documentation from grantees. During the site visits, we interviewed CHP grantees about, among other topics, the community policing strategies they employed with CHP funding and whether their agencies had increased the number of officers dedicated to community policing relative to the number of officers hired with CHP funding. We also interviewed COPS Office officials who oversee the monitoring process about their monitoring practices and discussed with officials how monitoring provided relevant context to what grantees and the COPS Office considered progress. We also obtained the perspective of the COPS Office on the performance of its grant monitors in identifying and documenting instances of potential supplanting in the reports for on-site monitoring We conducted this performance audit from August 2012 to September 2013 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 II: How Proactive and Reactive Policing Differ

This appendix corresponds with figure 1 in the report, which is an interactive figure. Table 5 contains the text that is not accessible to readers of print copies of this report.

Appendix III: Comments from the Department of Justice

Appendix IV: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

In addition to the contact named above, key contributors to this report were Joy Booth, Assistant Director; Glenn Davis, Assistant Director; David Alexander; Carl Barden; Christine Hanson; Eric Hauswirth; Julian King; Linda Miller; Christian Montz; Robin Nye; Brian Schwartz; and Janet Temko.