CMHS awards two types of grants—formula grants and discretionary grants—to support mental health programs. According to CMHS, in fiscal year 2013, about 61 percent of CMHS’s $822 million in grant funding was awarded through formula grants and about 39 percent was awarded through discretionary grants. (See fig. 1.) Formula grants are awarded to eligible grantees that meet specified criteria outlined in formulas prescribed by statute or regulation. These formulas may consider factors such as the population-at-risk and cost of services. These grants are generally awarded to states and territories that distribute funds to various governmental or nongovernmental entities, such as a state mental health agency or a community mental health center. In fiscal year 2013, CMHS awarded about $501 million under three formula grant programs: 1. the MHBG program, which supports adults with serious mental illness (SMI) or children with serious emotional disturbances (SED); 2. the PAIMI program, which supports protection and advocacy systems designed to ensure the rights of individuals with mental illness who are at risk for abuse and neglect; and 3. the Projects for Assistance in Transition from Homelessness program, which supports outreach, mental health, and other support services to homeless people with SMI. Discretionary grants are generally awarded on a competitive basis for specified projects that meet statutory eligibility and program requirements. Discretionary grants allow CMHS to allocate funding to a particular issue, such as suicide prevention, or to areas and populations with the greatest need. CMHS discretionary grants may be awarded to state, local, territorial, and tribal governments; institutions of higher education; other non-profit organizations (including tribal organizations); and hospitals. These grant applications are solicited through RFAs that specify the purpose of the grant, eligibility requirements, and grantee reporting requirements throughout the grant’s project period. The duration of a grant’s project period and the amount of funding available each year differ by grant program based on program requirements or statutory requirements. In fiscal year 2013, CMHS awarded 589 discretionary grants totaling about $321 million. The smallest grant award was about $30,000 and the largest grant award was about $6 million. CMHS uses separate processes for reviewing and awarding grants for the formula and discretionary grant programs from which we drew our selection; figures 2 and 3 illustrate these two processes. After CMHS awards grants, grantees can use a variety of different approaches to treat individuals with mental illness, including evidence- based practices. Since 1997, SAMHSA has sponsored a National Registry of Evidence-Based Programs and Practices, which is a searchable online registry of programs and services that are considered by SAMHSA to be evidence-based. According to SAMHSA the purpose of this system is to help the public, including grantees that have been awarded grants by CMHS, learn more about available evidence-based practices. The criteria CMHS established for awarding grants to grantees for the MHBG, PAIMI, and selected discretionary grant programs varied by program. CMHS did not document its application of criteria when awarding grants to grantees for about a third of the grantees we reviewed. The criteria CMHS established for awarding grants to grantees for the MHBG, PAIMI, and selected discretionary grant programs varied by program. These criteria identify the requirements grantees must meet in order to receive a grant, including any requirements identified in statute, regulation, or the terms and conditions for the grant program, such as those outlined in RFAs. For example, one of the five programs that awarded grants to grantees we reviewed—Project LAUNCH—required its grantees to state that they will use evidence-based practices to treat individuals with mental illness in their applications when such practices are available, while the others did not. See table 2 for examples of CMHS’s criteria for awarding grants to grantees. During the 2-year period covered by our review, CMHS did not document its application of the criteria it used to award grants to 6 of the 16 grantees we reviewed. Specifically, we found instances across the 2 years in which CMHS did not clearly document the application of its criteria for 4 MHBG grantees and 2 PAIMI grantees. We found that CMHS documented the criteria it applied when awarding grants to discretionary grantees. The grants manual states that CMHS must maintain appropriate file documentation to support decisions in the financial assistance process, including funding decisions, and that transactions and significant events are to be clearly documented to help management with decision-making to help ensure operations are carried out as intended. In addition, Standards for Internal Control in the Federal Government state that all transactions and other significant events need to be clearly documented. CMHS officials said that they follow the grants manual but said that they do not have written guidance that is specific to the MHBG and PAIMI programs that would assist project officers in using the tools that CMHS has developed, such as checklists, to document their application of criteria. Examples of instances in which CMHS did not document its application of criteria when awarding grants to the grantees we reviewed include the following: MHBG. For fiscal year 2012, CMHS officials did not clearly document the application of most criteria for any of the four MHBG grantees we reviewed; however, officials did document how they applied most of the criteria for fiscal year 2013. Because fiscal year 2013 was the second year of the grant project period that corresponded to the application for continued funding, it required that CMHS apply fewer criteria than in the initial application for fiscal year 2012. Specifically, CMHS officials use checklists to help them determine whether grantees meet the agency’s criteria when deciding whether to award grants to grantees. Grantees are expected to provide sufficient information to demonstrate that they have satisfied the criteria in their grant applications. However, for all four of the grantees we reviewed, the checklists for the application covering fiscal year 2012 data listed “N/A” or had missing responses for most of the items in the checklist—the majority of which were related to criteria identified in statute. One grantee’s checklist we reviewed listed “N/A” or had missing responses for nearly all of the items related to statutory requirements. For example, all items related to the five criteria that must be addressed by the required plan submitted as part of the application were listed as “N/A”, and none of the items related to the required state priorities were completed by the project officer. One project officer told us that if a required item on the checklist is listed as “N/A”, it is because the project officer did not have the specified information from the grantee and would therefore request the information. However, we did not see evidence that the project officer updated the checklists after receiving additional information. In another case, officials told us that there was a technical problem with the system that electronically stores the checklists and the responses were automatically populated with “N/A” for these items. While we found that none of the checklists for the MHBG applications covering fiscal year 2012 data clearly documented how CMHS applied criteria when reviewing applications, we found that the checklists covering fiscal year 2013 data for the four grantees clearly documented the use of most criteria. However, officials explained that the 2013 application and the corresponding checklist was less extensive because it was an application for continued funding; project officers reviewed 19 criteria for the 2013 checklist compared to 129 for 2012. PAIMI. For fiscal year 2012, CMHS officials documented the application of criteria for three of the four PAIMI grantees we reviewed. However, we were unable to determine whether CMHS applied the criteria for the fourth grantee because CMHS officials were not able to provide the checklist they used to review this grantee. For fiscal year 2013, we found that accurate documentation of the application of criteria was not available for 2 of the 4 grantees we reviewed. Similar to the MHBG program, officials use checklists to help them determine whether grantees met CMHS’s criteria, such as whether the grantee demonstrated that it had identified priorities and objectives that were relevant to the PAIMI program. All four of the grantees’ checklists for the fiscal year 2013 applications contained documentation that indicated that the project officer found that the objectives identified by the grantee were not relevant to the PAIMI program. However, CMHS officials said that this finding was an error for two of the grantees, but was correct for the other two grantees. The officials told us that, as of October 2014, they had not conducted any follow-up with the two grantees to request additional information regarding the noted concerns. Officials told us that they would only follow up with the grantees on the noted concerns if they conducted a site visit. We found that there were a variety of reasons why CMHS did not adequately document the application of criteria when awarding grants to grantees. One reason was that officials told us they lacked program- specific guidance to document the application of criteria for some programs. CMHS has developed tools for project officers to use for their application of criteria, but project officers sometimes had different ideas about how to use those tools and what to do if a grantee could not provide needed information. For example, officials told us that for the MHBG program there was no written guidance, during the period covered by our review, that described how project officers were to complete the application review checklists to help ensure grantees met the grant criteria. Officials developed program-specific guidance for project officers in fiscal year 2014 for the review of MHBG applications, but we did not assess whether this guidance fully addressed the issues we identified. CMHS officials told us that they also provide training to project officers and that they believe the process is clear; however, we found that project officers had different understandings of how to complete the checklists that are intended to document their review of criteria. Officials also noted a technical problem in the system used to document the application review checklists in fiscal year 2012.