The Police Corps program was established to provide federal financial assistance to (1) prospective police officers who participate in the program (i.e., in the form of college scholarships for baccalaureate or graduate studies); (2) the entity selected and approved to provide basic training to the state’s Police Corps participants, either prior to or following completion of a bachelor’s degree; (3) the state and local law enforcement agencies that ultimately hire these individuals (i.e., they receive $10,000 per year during each of a participant’s first 4 years on the force); and (4) the dependent children of fallen officers. As of September 30, 1999, Police Corps programs were approved for 24 states and the Virgin Islands. Congress first appropriated funding of $10 million for the Police Corps program in fiscal year 1996. Police Corps funding increased to $20 million in fiscal year 1997 and to $30 million each in fiscal years 1998 and 1999. For fiscal year 2000, the appropriation directed that $30 million of available unobligated balances from COPS program funds were to be used for the Police Corps. As currently operated under OJP, the Office of the Police Corps provides funds to participating states, who in turn provide the funds to individual program participants, colleges, approved law enforcement training providers, and law enforcement agencies. In states that wish to participate, the governors must designate a lead agency that will submit a state plan to the Office of the Police Corps and administer the program in the state. Each year the Police Corps invites submission of state Police Corps program plans through a letter to the governor of each state and the appropriate official in the other eligible jurisdictions. States already approved for the program are to submit plans that describe their status, progress, and need for additional participants. Other states apply to participate by submitting a comprehensive state plan. The state plan must provide that the designated state lead agency will work in cooperation with local law enforcement liaisons, representatives of police labor and management organizations, and other appropriate agencies to develop and implement interagency agreements. The state also must agree to advertise the availability of Police Corps funds and make special efforts to seek applicants among members of all racial, ethnic, and gender groups but may not deviate from competitive standards for selection. DOJ originally placed the Office of the Police Corps under COPS, which DOJ established in 1994 pursuant to statute with the goal of funding 100,000 new community police officers by the end of the year 2000. However, because the COPS program is legislatively scheduled to end at the close of fiscal year 2000, DOJ asked for and received approval in the Conference report accompanying the Fiscal Year 1999 Omnibus Consolidated and Emergency Appropriation Bill to transfer the Office of the Police Corps to OJP. This transfer took place on December 10, 1998. To determine the extent of, and causes for, delays in Police Corps implementation, we (1) assessed COPS’ and OJP’s respective financial and management practices, (2) reviewed COPS’ and OJP’s respective legal interpretations of Police Corps’ statutory authority, (3) analyzed COPS and OJP reimbursement payment data, (4) reviewed program files at COPS and OJP, and (5) interviewed current and former Police Corps program officials as well as DOJ officials responsible for oversight. To obtain certain states’ perspective on implementation delays, we visited four states— Florida, Maryland, Oregon, and Texas. We selected Maryland and Oregon because they started their programs during the first year that the Police Corps program was funded and received the most funding. We selected Florida because a state university had been delegated state lead agency responsibility. We selected Texas because it experienced difficulty becoming fully operational due to issues concerning training program requirements. In each state we interviewed program officials representing the lead agency and the training program; in Maryland and Oregon, we interviewed representatives of law enforcement agencies that had employed Police Corps graduates. To broaden our understanding of the implementation of the Police Corps program, we also conducted structured telephone interviews with Police Corps lead agency representatives of the other 19 states participating in the program at that time (see app. III for the questions we asked). We asked officials to rate possible program problem areas on a four-point scale ranging from “not a reason” to a “very major reason.” Additionally, we conducted telephone interviews with cognizant officials in the governors’ offices of 12 nonparticipating states (see app. IV for the questions we asked). We used the same four-point scale that was used with the participating states to determine whether the possible problems affected program participation. We included an open-ended question that gave respondents the opportunity to identify problem areas not included among those we listed. To obtain information on the provision of Police Corps basic law enforcement training, determine how much assistance was being provided to law enforcement agencies and what it was being used for, and determine how many scholarships had been awarded to dependent children of fallen officers, we reviewed files and interviewed officials at COPS and OJP. In addition, we reviewed Police Corps program legislation, program guidance, correspondence files, participating states’ files, and available studies of the Police Corps program. We also interviewed current and former COPS officials and current officials at OJP. We performed our work between March 1999 and January 2000 in accordance with generally accepted government auditing standards. During its first 4 years of operation, the Police Corps program failed to fill most of the available participant slots. As shown in table 1, as of September 30, 1999, 430 (or approximately 43 percent) of the approved 1,007 participant positions had been filled. According to federal and state officials, two of the factors that contributed to this slow start were that (1) COPS dedicated insufficient staff to implement the program, which resulted in delays in providing program guidance and backlogs in processing program applications and reimbursements and (2) the Police Corps statute did not provide funding for states’ administrative or recruiting costs, which slowed program growth in some states and led several states to decline to participate in the program. In addition, statutory language led COPS to operate the Police Corps as a direct reimbursement program, which in turn made it difficult for Congress to determine the status of program funds. The Police Corps statute was enacted in 1994, and funds were specifically appropriated for the program in fiscal year 1996, when Congress provided $10 million. COPS hired a program director for the Police Corps in September 1996. In January 1997, COPS hired a program specialist to (1) receive and process student applications and service agreements; (2) develop standardized forms for student participant applications and requests for reimbursement from participants and institutions; (3) receive, record, and review requests for reimbursements; and (4) respond to inquiries from states and the general public. State officials said that the lack of COPS office staff led to delays in providing formal program guidance. According to state officials, COPS did not provide program guidance for recruiting and selecting participants until May 1997. Several state officials said that their attempts to get directions from COPS in writing or by telephone had failed. Similarly, state officials complained about backlogs in reviewing funding applications, conducting state budget reviews, and processing requests for reimbursable payments. For example, officials in all four states that we visited said that their programs experienced significant delays in receiving reimbursement from COPS for training expenditures. In an effort to secure more staffing for the program, in March 1998, COPS notified the House Committee on Appropriations of a proposed reprogramming action that would allow for an increase in staffing for the Office of the Police Corps. In April 1998, the Committee approved this proposed action. As a result COPS dedicated three full-time positions to the Police Corps to supplement the two COPS staff who were already performing Police Corps duties on a full-time basis. COPS officials said that the reason they did not devote more staff to the Police Corps program is that they interpreted their legal authority as not authorizing the payment of federal program administration costs with Police Corps funds. The Department of Justice has not provided us with the legal analysis underlying this position. As a result of this interpretation, COPS determined that it had to pay such costs from COPS operating funds. COPS officials said that, while they made an effort to provide staffing to the Police Corps program, their options were limited because the entire COPS Office was understaffed. COPS officials acknowledged that Police Corps program delays resulted in part from this understaffing. The Police Corps statute states, “There is established in the Department of Justice, under the general authority of the Attorney General, an Office of the Police Corps and Law Enforcement Education,” and the statute lays out the responsibilities of the Office. Although the Police Corps statute is silent regarding the payment of federal administrative costs, we believe that options were available to the COPS office for the payment of these costs. In our view, the COPS office could have charged the Police Corps line-item appropriations for fiscal years 1996 through 1998 to pay for these costs. A primary statute dealing with the use of appropriated funds, 31 U.S.C. 1301(a), provides that “Appropriations shall be applied only to the objects for which the appropriations were made except as otherwise provided by law.” However, it does not require, nor would it be reasonably possible, that every item of expenditure be specified in an appropriation act. The spending agency has reasonable discretion in determining how to carry out the objects of the appropriation. This concept is known as the “necessary expense” doctrine. For an expenditure to be justified under the necessary expense doctrine, three tests must be met: (1) the expenditure must bear a logical relationship to the appropriation to be charged; (2) the expenditure must not be prohibited by law; and (3) the expenditure cannot be authorized if it is otherwise provided for under a more specific appropriation or statutory funding mechanism.