Grant Monitoring
Department of Education Could Improve Its Processes with Greater Focus on Assessing Risks, Acquiring Financial Skills, and Sharing Information Gao ID: GAO-10-57 November 19, 2009The Department of Education (Education) awards about $45 billion in grants each year to school districts, states, and other entities. In addition, the American Recovery and Reinvestment Act of 2009 provided an additional $97 billion in grant funding. In a series of reports from 2002 to 2009, Education's Inspector General cited a number of grantees for failing to comply with financial and programmatic requirements of their grant agreements. GAO was asked to determine: (1) what progress Education has made in implementing a risk-based approach to grant monitoring, (2) to what extent Education's program offices have the expertise necessary to monitor grantees' compliance with grant program requirements, and (3) to what extent information is shared and used within Education to ensure the effectiveness of grant monitoring. To do this, GAO reviewed agency documentation related to Education's internal controls and interviewed senior Education officials and staff in 12 of the 34 offices that monitor grants.
In October 2006, Education began to look at ways to improve the efficiency and effectiveness of the department's grant management processes; in particular, it sought ways to more effectively monitor its grants after they were made. In 2007, Education created the Risk Management Service (RMS) to work with all components of the department to ensure that each office has an effective risk management strategy in place. Effective monitoring protocols and tools based on accepted control standards are key to ensuring that waste, fraud, and abuse are not overlooked and program funds are being spent appropriately. Such tools include identifying the nature and extent of grantee risks and managing those risks, having skilled staff to oversee grantees to ensure they are using sound financial practices and meeting program objectives and requirements, and using and sharing information about grantees throughout the organization. Our review of Education's current grant monitoring processes and controls found that it: (1)Has made uneven progress in implementing a department-wide, risk-based approach to grant monitoring. Education has not disseminated department-wide guidance on grantee risk assessment, but it has planned some new efforts in this area. In the absence of guidance on a department-wide risk assessment strategy, individual program offices have developed their own strategies for assessing and managing risk that vary in rigor. (2) Has limited financial expertise and training, hindering effective monitoring of grantees' compliance with financial requirements. Education has monitoring tools that aid in reviewing basic financial compliance, but the lack of staff expertise limits the ability to probe more deeply into grantees' use of funds. (3) Lacks a systematic means of sharing information on grantees and promising practices in grant monitoring throughout the department. These shortcomings can lead to weaknesses in program implementation that ultimately result in failure to effectively serve the students, parents, teachers, and administrators those programs were designed to help.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-10-57, Grant Monitoring: Department of Education Could Improve Its Processes with Greater Focus on Assessing Risks, Acquiring Financial Skills, and Sharing Information
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Report to Congressional Requesters:
United States Government Accountability Office:
GAO:
November 2009:
Grant Monitoring:
Department of Education Could Improve Its Processes with Greater Focus
on Assessing Risks, Acquiring Financial Skills, and Sharing
Information:
GAO-10-57:
GAO Highlights:
Highlights of GAO-10-57, a report to congressional requesters.
Why GAO Did This Study:
The Department of Education (Education) awards about $45 billion in
grants each year to school districts, states, and other entities. In
addition, the American Recovery and Reinvestment Act of 2009 provided
an additional $97 billion in grant funding. In a series of reports from
2002 to 2009, Education‘s Inspector General cited a number of grantees
for failing to comply with financial and programmatic requirements of
their grant agreements. GAO was asked to determine: (1) what progress
Education has made in implementing a risk-based approach to grant
monitoring, (2) to what extent Education‘s program offices have the
expertise necessary to monitor grantees‘ compliance with grant program
requirements, and (3) to what extent information is shared and used
within Education to ensure the effectiveness of grant monitoring. To do
this, GAO reviewed agency documentation related to Education‘s internal
controls and interviewed senior Education officials and staff in 12 of
the 34 offices that monitor grants.
What GAO Found:
In October 2006, Education began to look at ways to improve the
efficiency and effectiveness of the department‘s grant management
processes; in particular, it sought ways to more effectively monitor
its grants after they were made. In 2007, Education created the Risk
Management Service (RMS) to work with all components of the department
to ensure that each office has an effective risk management strategy in
place.
Effective monitoring protocols and tools based on accepted control
standards are key to ensuring that waste, fraud, and abuse are not
overlooked and program funds are being spent appropriately. Such tools
include identifying the nature and extent of grantee risks and managing
those risks, having skilled staff to oversee grantees to ensure they
are using sound financial practices and meeting program objectives and
requirements, and using and sharing information about grantees
throughout the organization. Our review of Education‘s current grant
monitoring processes and controls found that it:
* Has made uneven progress in implementing a department-wide, risk-
based approach to grant monitoring. Education has not disseminated
department-wide guidance on grantee risk assessment, but it has planned
some new efforts in this area. In the absence of guidance on a
department-wide risk assessment strategy, individual program offices
have developed their own strategies for assessing and managing risk
that vary in rigor.
* Has limited financial expertise and training, hindering effective
monitoring of grantees‘ compliance with financial requirements.
Education has monitoring tools that aid in reviewing basic financial
compliance, but the lack of staff expertise limits the ability to probe
more deeply into grantees‘ use of funds.
* Lacks a systematic means of sharing information on grantees and
promising practices in grant monitoring throughout the department.
These shortcomings can lead to weaknesses in program implementation
that ultimately result in failure to effectively serve the students,
parents, teachers, and administrators those programs were designed to
help.
Figure: Gaps in Grant Monitoring at Education:
[Refer to PDF for image: illustration]
Properly assessing risk;
Having required skills and resources;
Sharing information.
Source: GAO analysis.
[End of figure]
What GAO Recommends:
GAO recommends Education improve its oversight of risk management,
increase financial expertise among its grant monitoring staff, and
develop an accessible mechanism to share information. Education
generally agreed with our recommendations and provided additional
information on its monitoring practices. We incorporated that
information when appropriate.
View [hyperlink, http://www.gao.gov/products/GAO-10-57] or key
components. For more information, contact Cornelia Ashby at (202) 512-
7215 or ashbyc@gao.gov.
[End of section]
Contents:
Letter:
Background:
Education Has Made Uneven Progress in Implementing a Department-wide,
Risk-based Approach to Grant Monitoring:
Limitations in Financial Expertise and Training Hinder Education's
Ability to Effectively Monitor Grantees:
Limitations in Education's Information-Sharing Systems Hinder Effective
Grant Monitoring:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Comparison of Grant Funding in the Department of
Education's Principal and Program Offices:
Appendix II: Comments from the Department of Education:
Appendix III: GAO Contact and Staff Acknowledgments:
Table:
Table 1: Twelve Program Offices Reviewed:
Figures:
Figure 1: Organizational Structure at the Department of Education:
Figure 2: The Grant Life Cycle at the Department of Education:
Figure 3: Opportunities for Sharing Information about Recipients of
Multiple Education Grants:
Figure 4: Comparison of Grant Funding in Education Department Principal
Offices:
Abbreviations:
Education: Department of Education:
OCFO: Office of Chief Financial Officer:
OPE: Office of Postsecondary Education:
OSEP: Office of Special Education Programs:
Recovery Act: American Recovery and Reinvestment Act of 2009:
RMS: Risk Management Service:
SASA: Student Achievement and School Accountability:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
November 19, 2009:
The Honorable John P. Kline:
Ranking Member:
Committee on Education and Labor:
House of Representatives:
The Honorable Michael Castle:
Ranking Member:
Subcommittee on Early Childhood, Elementary and Secondary Education:
Committee on Education and Labor:
House of Representatives:
The Honorable Howard P. "Buck" McKeon:
House of Representatives:
The Department of Education (Education) administers about 200 programs
that award grants totaling about $44 billion per year to state and
local educational agencies, institutions of higher education, and other
eligible entities. Currently, there are 18,650 grantees with open grant
awards from Education. In addition, as part of the American Recovery
and Reinvestment Act of 2009 (Recovery Act),[Footnote 1] Congress
dramatically increased Education's grant funding by an additional $97
billion. However, in a series of reports between 2002 and 2009, the
Department of Education's Office of Inspector General identified a
number of problems related to the management of grant funding by state
and local educational agencies and institutions of higher education.
Such findings raise questions about Education's ability to monitor its
grantees, particularly when coupled with such a large increase in
funding from the Recovery Act. How well Education, or any agency, can
oversee grantees depends on the management and accountability tools and
controls it has in place to properly implement monitoring in order to
prevent or detect abuses by grantees. Such tools and controls include
identifying the nature and extent of risks and managing those risks,
having skilled staff to implement oversight activities to ensure that
program objectives are fulfilled, and using and sharing relevant
information throughout the organization. If any of the tools or
controls are weak or not in place in a grant monitoring process, there
is heightened risk of the program not fully meeting its objectives.
Because of the Office of Inspector General's findings and other reports
on the improper use of funds by grantees and the implications for how
well Education monitors its grants, you asked us to review Education's
grant monitoring process. In meeting with your staff, we agreed to
examine various aspects of Education's grant monitoring. Specifically,
our objectives were to determine: (1) What progress has Education made
in implementing a risk-based approach to grant monitoring? (2) To what
extent do Education's program offices have the expertise necessary to
monitor grantees' compliance with grant program requirements? (3) To
what extent is information shared and used within Education to ensure
the effectiveness of grant monitoring?
To answer these questions, we used information collected from current
and past GAO engagements related to grant monitoring,[Footnote 2] and
held additional discussions with department officials to gain an
understanding of grant monitoring at Education. We documented our
understanding of Education's grant monitoring process and asked
department officials to review the document and provide comments. They
confirmed that our understanding was consistent with their grant
monitoring practices and procedures. We based our evaluation of
Education's grant monitoring process on GAO's standards for internal
control in the federal government. We selected 12 of the department's
34 program offices from which to obtain more detailed information about
their grant monitoring activities (see table 1). We selected these
program offices because they encompass a wide variety of grant programs
and they administer approximately 91 percent of grant funds in the
department. Nine of the 12 program offices reside in four of the
principal offices, which collectively administer the department's
largest grant programs in terms of total funding. To ensure that we
included programs from all seven of the principal offices administering
grants to entities that provide education or education-related services
to students, we also selected the program offices that administered the
largest amount of grant funds in the other three principal offices.
[Footnote 3] (Appendix I illustrates where the offices we selected are
in Education's principal office structure.)
Table 1: Twelve Program Offices Reviewed:
Principal office: Office of Elementary and Secondary Education;
Program office: Student Achievement and School Accountability;
Total grant funds administered: $14,429,333,331;
Percentage of Education grant funds: 32.6%.
Principal office: Office of Elementary and Secondary Education;
Program office: Academic Improvement and Teacher Quality Programs;
Total grant funds administered: $5,130,800,896;
Percentage of Education grant funds: 11.6%.
Principal office: Office of Elementary and Secondary Education;
Program office: Impact Aid Programs;
Total grant funds administered: $1,240,717,000;
Percentage of Education grant funds: 2.8%.
Principal office: Office of Elementary and Secondary Education;
Program office: Office of Migrant Education;
Total grant funds administered: $415,009,353;
Percentage of Education grant funds: 0.9%.
Principal office: Office of Special Education and Rehabilitative
Services;
Program office: Office of Special Education Programs;
Total grant funds administered: $11,957,593,817;
Percentage of Education grant funds: 27.0%.
Principal office: Office of Special Education and Rehabilitative
Services;
Program office: Rehabilitation Services Administration;
Total grant funds administered: $3,169,591,222;
Percentage of Education grant funds: 7.2%.
Principal office: Office of Vocational and Adult Education;
Program office: Academic and Technical Education Division;
Total grant funds administered: $1,271,880,064;
Percentage of Education grant funds: 2.9%.
Principal office: Office of Vocational and Adult Education;
Program office: Adult Education and Literacy Division;
Total grant funds administered: $576,494,357;
Percentage of Education grant funds: 1.3%.
Principal office: Office of Postsecondary Education;
Program office: Higher Education Preparation and Support Service;
Total grant funds administered: $897,209,118;
Percentage of Education grant funds: 2.0%.
Principal office: Office of English Language Acquisition;
Program office: Continuation and Professional Grants Division;
Total grant funds administered: $720,547,414;
Percentage of Education grant funds: 1.6%.
Principal office: Office of Innovation and Improvement;
Program office: Parental Options and Information;
Total grant funds administered: $400,299,834;
Percentage of Education grant funds: 0.9%.
Principal office: Office of Safe and Drug-Free Schools;
Program office: Drug-Violence Prevention - State Programs;
Total grant funds administered: $290,102,482;
Percentage of Education grant funds: 0.7%.
Percentage of total Education grant funds covered by review: 91.5%.
Source: GAO analysis of Department of Education data.
[End of table]
We interviewed the directors and other supervisory staff involved in
grant monitoring in these 12 offices and held discussions in each
office with groups of program specialists ranging from 4 to 10 program
specialists.[Footnote 4] In offices with large numbers of program
specialists, we interviewed random samples of program specialists.
[Footnote 5] In smaller offices, we interviewed all the program
specialists who were available to meet with us. From these interviews,
we obtained information on how grant monitoring was implemented by
program office staff, which monitoring activities staff considered to
be reasonably effective in ensuring compliance with federal
requirements, and where improvements in the grant monitoring process
were needed.
We corroborated the information from the interviews and small group
discussions with review and analysis of plans, guidance, and protocols
used by each program office to conduct its monitoring, as well as
documentation concerning monitoring outcomes, interviews with officials
from department management, and the results of outside evaluations or
audits.
We conducted this performance audit from November 2008 to November 2009
in accordance with generally accepted government auditing standards.
The 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 the
evidence obtained provides a reasonable basis for findings and
conclusions based on our audit objectives.
Background:
Department of Education:
The Department of Education's mission is to promote student achievement
and preparation for global competitiveness by fostering educational
excellence and ensuring equal access. Toward this end, Education
distributes federal grant funds to applicants throughout the nation to
improve access to and the quality of education. Education supplements
and complements the efforts of states, local school systems, the
private sector, public and private nonprofit educational research
institutions, other community-based organizations, parents, and
students.
Education has seven principal offices that administer grants to
entities that provide education or education-related services to
students (see figure 1). The principal offices focus on specific areas
of education, such as special education, elementary and secondary
education, and postsecondary education. Within each of these principal
offices, there are individual program offices responsible for one or
more specific grant programs. For example, the Office of Special
Education Programs and the Rehabilitation Services Administration are
program offices in the principal Office of Special Education and
Rehabilitative Services. Program offices have directors, supervisors,
and program specialists responsible for the everyday administration of
grants in the department. Department-wide offices--the Risk Management
Service, Office of Chief Financial Officer, Office of General Counsel,
and Budget Service--provide technical assistance and guidance to the
principal and program offices.
Figure 1: Organizational Structure at the Department of Education:
[Refer to PDF for image: illustration]
Department of Education:
Technical assistance and guidance from:
* Office of General Counsel (OGC);
* Budget Service (BS);
* Risk Management Service (RMS);
* Office of Chief Financial Officer (OCFO).
Second level, under the Department of Education:
* Office of English Language:
Number of program offices: 2.
* Office of Vocational and Adult Education:
Number of program offices: 3.
* Office of Special Education and Rehabilitative Service:
Number of program offices: 3.
* Office of Postsecondary Education:
Number of program offices: 5.
* Office of Elementary and Secondary Education:
Number of program offices: 6.
* Office of Innovation and Improvement:
Number of program offices: 6.
* Office of Safe and Drug-Free Schools:
Number of program offices: 6.
Program Offices are made up of:
* a Program Director;
* one or more Supervisors;
* multiple Program Specialists.
Source: GAO analysis of Department of Education information; seal
(DOE).
[End of figure]
Grant Monitoring at Education:
Education describes its grant management processes as a "cradle-to-
grave" strategy. As shown in figure 2, this strategy includes phases
for pre-award, award, post-award, and close-out. Monitoring to ensure
administrative, financial, and performance compliance occurs primarily
during the post-award phase, after the grantee has successfully applied
for and been awarded a grant from Education.
Figure 2: The Grant Life Cycle at the Department of Education:
[Refer to PDF for image: illustration]
Pre-Award and Award Monitoring:
Activities necessary for selecting applications, awarding new grants
and making continuation awards for existing Education grants.
Post-Award Monitoring:
Develops partnership with grantees in order to administer and monitor
grant awards;
* Grant Monitoring:
- Performance Compliance: Assessing the extent to which projects meet
grant program goals and objectives;
- Administrative Compliance: Seeking adherence to legislative and
regulatory requirements, applicable policies, as well as terms and
conditions of the grant;
- Financial Compliance: Reviewing drawdowns and expenditures to ensure
adherence to federal cash management regulations.
Close-Out Monitoring:
Starts when project period ends and continues until all required
reports are submitted and there are no funds left in grant account.
Source: GAO analysis of Department of Education information.
[End of figure]
In Education, grant monitoring is the responsibility of each program
office. Each program office has the flexibility to tailor its
monitoring to its respective grant programs. For example, program
offices that oversee formula grants to state agencies generally conduct
on-site monitoring on a 3-to-5-year cycle but can make more frequent
visits if necessary. For discretionary grants, site visits to the
recipients are generally less frequent, in part because of the
relatively small size of the awards and the relatively large number of
discretionary grant awards made by the department. Relatively more desk-
top monitoring is used in monitoring discretionary grants. In general,
recipients of grants from Education must:
* conform to the approved grant application and approved revisions;
* adhere to laws, regulations, conditions of the grant, and
certifications;
* share progress on established performance measures; and:
* manage federal funds according to federal cash management
requirements.
Education's grant monitoring practices and procedures require that
program office staff undertake numerous activities to monitor grantees
for compliance with administrative, financial, and performance
regulations and requirements to protect against fraud, waste, and abuse
of federal resources. These activities include on-site visits and desk
reviews of grantees, review of annual reports submitted by grantees,
and evaluation of grant projects with respect to performance. For
example, some financial monitoring activities that program office staff
perform include reviewing reports generated in the Grant Administration
and Payment System, Education's primary information system and tool for
financial oversight, and available audit reports. In cases where
technical assistance and normal monitoring do not improve grantee
performance, special grant conditions may be imposed on the grantee
such as requiring the grantee to obtain prior approval for certain
expenditures. Findings of material noncompliance are reported to other
offices in Education, such as the Office of General Counsel, while
findings of potential illegal activity involving fraud, waste, and
abuse are reported to the Office of Inspector General for further
action. Continuous monitoring of grantees offers program office staff
the opportunity to provide customized technical assistance, appropriate
feedback, and follow-up to help grantees improve in areas of need,
identify project strengths, and recognize significant achievements.
Education Has Made Uneven Progress in Implementing a Department-wide,
Risk-based Approach to Grant Monitoring:
Education allows individual program offices to develop their own
procedures for assessing grantee risk. While the department has not yet
provided department-wide guidance on grantee risk assessment, the Risk
Management Service (RMS) is planning to introduce several new efforts
designed to help in this area. In the absence of a department-wide
strategy for risk assessment procedures, we found that in the program
offices we visited, the procedures for assessing grantee risk varied in
rigor, with some offices using a variety of indicators or data elements
to measure relative risk, while others had no formal grantee risk
assessment process in place.
Education Has Not Yet Provided Department-wide Guidance on Risk
Assessment but Is Developing New Grantee Risk Assessment Tools:
Federal guidance directs that management should identify internal and
external risks that may prevent an organization from meeting its
objectives.[Footnote 6] In 2007, the department's Grants Pilot Project
Team recommended the establishment of a coordinated, comprehensive, and
department-wide approach to risk-based grant monitoring for
discretionary and formula grants. The Secretary created RMS in October
2007 to work with all components of the department to ensure that each
office has effective procedures in place to assess and mitigate risk
among its grantees. Specifically, RMS is to develop tools to assess
grantee risk for use throughout the department and train department
staff to use the tools.[Footnote 7] RMS has not yet issued department-
wide guidance on assessing grantee risk, and key guidance, such as the
updated discretionary grant handbook, does not provide information on
how to develop a risk-based approach to monitoring grants. Program
officials said that such guidance would be a valuable tool for program
offices in developing their own risk assessment procedures. RMS is
currently testing software it developed that would assist Education
staff in evaluating grantee risk. For example, the new software
collects financial information from Dun and Bradstreet, among other
sources, and uses that information to calculate a score reflecting the
financial stability of grantees. The software will also help with risk
assessment by providing other information from agency and outside
sources, along with relevant findings from grantee audits. However, RMS
does not have a timetable for using this new software throughout the
department.
RMS has worked closely with the Office of Postsecondary Education (OPE)
to develop risk assessment procedures, and hopes to work with officials
in the other principal offices for this purpose. RMS helped OPE develop
an index that ranks the potential risk level of grantees based on such
risk criteria as net operating results, status with an accrediting
agency, enrollment trends, and ability to manage federal funds. RMS
also provides OPE with monthly analyses of grantees' level of financial
risk. In the meantime, some program offices have developed risk
assessment procedures on their own.
Grantee Risk Assessment Procedures Used by Program Offices Vary in
Rigor:
We observed a wide range of risk assessment procedures that varied in
rigor among the program offices we reviewed. In discussing how program
offices assess grantees' financial risk, we noted there was an
indicator that program offices routinely reviewed to assess a grantee's
financial risk: the rate at which a grantee draws down grant funds,
known as the drawdown rate. Although staff we met with in all of the
offices that disburse funds through periodic drawdowns reported
checking the drawdown rate, the frequency varied from office to office,
with some checking the rate monthly and others checking it quarterly.
Further, the drawdown rate is limited as an indicator of the soundness
of a grantee's financial management practices because it only shows
when the grantee is using funds and does not show what the funds are
used for.
In addition to monitoring the grantees' drawdown rates, staff in three
of the offices we met with OPE, Student Achievement and School
Accountability (SASA), and Office of Special Education Programs (OSEP)
described using more rigorous risk assessment procedures than those
developed in the other offices we visited. As discussed above, OPE
worked with RMS to develop new risk assessment procedures. Staff in
SASA have recently moved to risk-based monitoring procedures; they use
a risk assessment procedure that incorporates an extensive list of risk
indicators and numerous sources of information to determine an
individual grantee's level of risk and whether grantees are meeting
performance expectations. These indicators include program performance
data, the grantee staff's level of experience, the size of the grant
and the population served, and issues raised by the Office of Inspector
General. Once the program specialists in that office collect and
analyze the information, they tailor monitoring and technical
assistance accordingly. The staff routinely track major compliance or
performance issues, and also conduct staff briefings before site visits
to share information the office has developed about the grantee and
issues that may arise, and afterwards, to discuss findings and possible
corrective action plans.
Specialists in OSEP reported that they categorize grantees based on
such factors as audit findings, data indicating how well the grantee is
accomplishing its objectives, and special conditions attached to the
grant. Based on this information, they categorize the level of risk for
the grantee and the level of monitoring and technical assistance the
grantee requires. For example, a grantee that has high staff turnover
or recurring problems in external audits, or is unable to meet its
performance expectations, would be monitored more closely and receive
more technical assistance than a grantee with experienced staff that is
consistently meeting the program's administrative, financial, and
performance requirements.
Program specialists from OPE, Parental Options and Information, and the
Continuation and Professional Grants Division told us that their risk
assessment process begins when they first contact grantees and provide
expectations for reporting performance and financial information. This
early contact gives these program specialists a sense of the level of
experience the grantee has in managing federal grants. In developing
those assessments, the program specialists and supervisors said they
can tailor their monitoring to provide additional technical assistance,
for example, or reach out more frequently than they might otherwise to
grantees that appear likely to have compliance problems.
While some of Education's program offices are making progress assessing
and managing grantee risk as discussed above, staff in three other
program offices described significant limitations of the risk
assessment process in place for their grant programs:
* Program specialists in one office told us that experienced program
specialists rely on their skills and experience to determine what to
look for. However, without a formalized risk assessment process, they
said a new hire might miss key issues while monitoring a grantee. They
added that a more formal risk assessment process would be helpful.
* The program specialists in another office said they are not able to
review all possible risk indicators that may pertain to grantees or do
more in-depth risk assessments because of competing demands on their
time. For example, one program specialist described a situation in
which grant funds were improperly paid out to a grantee because the
program specialist did not have time to check whether the grantee was
in good standing. He added that the office was able to recover the
funds, but he was concerned this could happen again and result in
losses.
* One program office director told us that the large number of grantees
makes it impossible to conduct routine risk assessments of them all.
Program specialists from that office told us that because of their
heavy work load--ranging from 85 to 260 grants per specialist--they did
not have enough time to review all the grantees identified as being at
risk.
Limitations in Financial Expertise and Training Hinder Education's
Ability to Effectively Monitor Grantees:
Directors and supervisors in the program offices we visited noted that
while their staff generally have the expertise needed to perform their
monitoring duties, limited financial expertise and training hinder
effective monitoring of grantees' compliance with financial
requirements. In many of the program offices we visited, program
specialists monitor grantees for compliance with administrative,
financial, and performance requirements. In most program offices, staff
we spoke with--including directors, supervisors, and specialists--said
that the program specialists have limited financial knowledge and lack
the skills needed for conducting financial reviews and ensuring
grantees' financial compliance. While monitoring protocols aid in
reviewing compliance with basic financial requirements, the ability to
verify or evaluate what grantees report about their use of funds is
limited by a lack of expertise. For example, using findings from
consolidated audit reports on grantees' financial statements is an
activity that aids in identifying monitoring issues, but staff in some
program offices have difficulty accessing these reports or are not able
to determine how to use the report findings to identify areas that need
closer monitoring. Some program office staff said that training on
performing financial reviews is needed to help fill the gap in this
skill area. Education has identified the need for more financial review
capability in its grant program staff through a skills assessment
inventory it has conducted for the last several years. However,
Education has not fully developed a strategy to enhance the financial
review capacity of its grant program staff.
Lack of Financial Expertise Limits the Depth of Grantee Monitoring,
Hindering Its Effectiveness:
According to federal control standards, as part of their management
responsibilities, agencies should have standards or criteria for hiring
qualified people. Program office directors and supervisors told us
their staffs generally have the background and expertise needed to
monitor grantees, but directors, supervisors, and staff in eight of the
program offices we reviewed said their program specialists generally
did not have a sufficient level of financial knowledge or skills needed
to review grantee compliance in that area. Several noted that some of
their program specialists previously worked in state or local education
systems or have strong backgrounds in education programs, and that they
seek individuals with these backgrounds or experience specific to their
programs. However, program specialists from three of the groups we met
with--that administer about 47 percent of Education's total grant
funding--told us specifically that they, as a group, did not possess
the needed knowledge or skills for reviewing grantee financial
compliance and that this hindered their offices' ability to adequately
monitor grantees. The director in one of those offices also expressed
doubt that, in general, his staff have the ability to conduct more in-
depth financial reviews of grantees beyond reviewing drawdown activity
reports.
Program offices took different steps to try to ensure proper financial
reviews. Five of the 12 offices we reviewed addressed their need for
financial expertise by designating staff to perform financial
compliance reviews. However, the directors or supervisors from three of
these offices said that more of their program specialist staff will
need to be trained in financial monitoring as their office's workload
increases and as individuals with fiscal expertise retire.
Program office staff can work with the department-wide offices that
provide technical assistance and guidance (see figure 1) on financial
compliance issues. Six offices obtained assistance in conducting
financial monitoring from other offices such as RMS and the Office of
Chief Financial Officer (OCFO). However, these arrangements sometimes
had limits. One program office found OCFO's ability to assist was
limited by their lack of program knowledge. RMS is responsible for
providing principal and program offices with advice and assistance on
issues concerning grant administration, but officials in RMS told us
their offers of assistance to program offices are often met with
skepticism or resistance. The director of RMS also has concluded that
he would need additional staff to provide support to the program
offices, including development of financial monitoring standards and
training.
In addition to designating staff to perform financial compliance
reviews or obtaining assistance in conducting financial monitoring from
other Education offices, four of the offices retained contractors to
assist with monitoring activities, including participating in site
visits. However, staff in two of these offices found that the
contractor personnel also lacked sufficient knowledge and skills to
conduct financial compliance monitoring. Another office terminated its
contract because the contractor was not meeting the office's standards
for preparing site visit reports. Some of these program offices that
used contractors did so to complement their own staffs with additional
resources in order to meet their monitoring needs. One director told us
he used contractors because more money was available for contractors
than for hiring or training staff. Education has not assessed the
effectiveness of using contractors to conduct fiscal monitoring. An
official in the Office of the Secretary told us he was not aware of any
attempts at such an analysis.
Most of the program offices we reviewed use written tools or protocols
that typically give instruction for monitoring compliance, including
compliance with financial requirements, but these protocols generally
do not provide instruction or guidance on verifying or evaluating
information obtained during the review. The group of program
specialists we met with in one office told us they usually have to rely
on grantees' self-reporting about their use of funds. These specialists
said they do not have the background or skills needed to corroborate
what the grantees are reporting, and the office's protocols we reviewed
do not provide further guidance or instruction on corroborating or
evaluating information obtained. The director in this office also
acknowledged his staff's lack of financial skills and said he would
like to see the department develop some better tools for assuring that
grantees are complying with financial requirements and using their
funds consistently with their plans.
Education Has Not Fully Developed a Strategy to Enhance the Financial
Review Capacity of Its Monitoring Staff:
While Education has begun an effort to inventory the skills of its
grant monitoring staff, it has not yet developed a training program or
other strategy to fill gaps in their financial monitoring capacity.
Some program office staff noted that training specifically in financial
monitoring is needed and would help improve skills. Also, the Grants
Pilot Project Team concluded that initial training efforts in financial
monitoring had not yet yielded long-term and sustained improvements or
a critical mass of better trained staff. To identify where financial
monitoring training is needed, the department has been conducting an
inventory of the skills of its program specialist staff for the last
several years.[Footnote 8] Supervisory staff in the program offices are
asked to identify the skills needs of each person reporting to them,
including financial compliance knowledge. The results of the inventory
are to be used to design training in financial compliance and determine
how much training is needed in each office. Supervisors are encouraged
to meet with their staff, discuss the skills needs, and inform those
individuals about available training. However, under this program,
financial management or analysis skills are not competencies on which
all program specialist staff are assessed. Only about 10 percent of
staff with grant administration responsibilities are assessed on a
financial skills competency. Based on the most recent year for which
inventory results are available, 25 of the individuals assessed on
financial skills were identified as needing training on financial
compliance.
Financial monitoring is currently available as a module in classes on
grant monitoring, but the course material is limited to use of the
Grant Administration and Payment System and grantees' use of tools such
as fund carryovers and budget transfers. In addition, there are two
courses on understanding the role of audits in grantee compliance, but
they have been offered only once in 2007 and once in 2008 with an
enrollment limit of 30. Similarly, Education also offers a course on
basic accounting theory and principles for any department staff without
prior accounting training. One of its goals is to provide knowledge for
monitoring use of funds by grantees. The course most recently has been
offered three times in 2009, and department officials estimate about 23
program office staff with grant monitoring responsibilities have
successfully completed or are currently taking it.
Education is planning to make changes in the financial compliance
components of its grant administration training, but these efforts are
just beginning and management has not committed to a time frame for
full implementation. RMS is developing a class on grants management
that will focus on financial and administrative requirements and
compliance. Preliminary materials we reviewed indicate it will cover
such topics as grantee cash management and payment systems, cost
principles for grantees, and financial reporting. Two program offices
have expressed interest in registering their staffs to take this class
when it becomes available. RMS is also planning to develop a curriculum
for newly hired grant administration staff that would be offered
through "just-in-time" modules, one of which would focus on financial
compliance. According to the RMS official responsible for developing
these courses, though, the development is being delayed while he
implements similar courses for grantees and their subrecipients. He
also noted that his own instructor staff have limited financial
knowledge, which could impose a constraint on the success of the new
training.
Limitations in Education's Information-Sharing Systems Hinder Effective
Grant Monitoring:
Education staff responsible for grant monitoring generally do not have
access to relevant information on how well grantees comply with the
requirements of other Education grants and whether their performance
with respect to those grants meets expectations. Because many grantees
receive multiple grants from Education in a given year, program
specialists said this type of information sharing could help program
specialists carry out their grant monitoring responsibilities more
effectively (see figure 3). Additionally, the program offices
responsible for grant monitoring lack a systematic means to share
information on promising practices for conducting grant monitoring.
Program office managers and staff said it would be helpful to have
information on ways to improve or enhance current monitoring practices.
Figure 3: Opportunities for Sharing Information about Recipients of
Multiple Education Grants:
[Refer to PDF for image: illustration]
Grant programs:
LSL Grant;
FLAP Grant;
PIRC Grant;
Title I, Part A Grant.
All grant programs have opportunities for sharing information through
an information exchange with:
AITQ Program Specialists;
OELA Program Specialists;
SASA Program Specialists;
POI Program Specialists.
[End of figure]
Source: GAO analysis of Department of Education grant programs.
Note: Foreign Language Assistance Program (FLAP) grants are monitored
by the Continuation and Professional Grants Division program office in
the Office of English Language Acquisition (OELA). Parental Information
and Resources Centers (PIRC) grants are monitored by the Parental
Options and Information (POI) program office in the Office of
Innovation and Improvement. Improving Basic Programs (Title I, Part A)
and Improving Literacy through School Libraries (LSL) grants are
monitored by the Student Achievement and School Accountability (SASA)
and Academic Improvement and Teacher Quality (AITQ) program offices
respectively, in the Office of Elementary and Secondary Education.
[End of figure]
Program office management and staff identified challenges in accessing
information relevant to grant monitoring. Program management and
specialists acknowledged that while it might be useful to share
information with other principal or program offices, there is no formal
mechanism to do so. One program office director, for example, said such
exchanges might provide other program offices information about
systemic management or personnel problems state grantees are
experiencing, since these types of problems could affect a wide variety
of the department's grant programs. A supervisor in another office
observed that if his staff find questionable issues with a grantee,
they do not have a systematic method of reporting it to other program
or principal offices that may also be funding that same grantee.
Moreover, program staff within the same office said they do not always
have access to information about a grantee's performance. In one of our
discussion groups with program specialists, one participant was aware a
grantee was having performance issues but another participant who also
monitors the same grantee under a different grant was unaware of these
performance issues. Had he known about these issues, he would have
intensified his monitoring of that grantee. The program specialists in
this office said they do not know who works with which grantees and
there is no formal process within the program office to share
information.
Managers in several program offices said they have databases or other
repositories housing grant monitoring information including findings
and past program performance, but these databases are not available to
staff outside their program office. In those offices, information is
available for internal program office use but is not typically shared
with or accessible to monitoring staff in other program offices. For
example, one principal office has a database of monitoring findings and
recommendations from the last 6 years, but we were told it was for use
only in that principal office. Program office management and staff
noted that Education has a shared computer drive where program offices
may store current and historical information on grantees' performance
in folders, but access to their information on the drive is typically
restricted to their own staff. The shared drive was never intended for
sharing information among different principal offices. Staff in one
program office would need to be given access to browse files saved in
another program office's folder on the shared drive. However, even with
access to the folders on the shared drive, the information may not be
easily searchable according to some program staff. One program officer
explained to us that in his office, he and his colleagues can use this
drive as a repository for all documents related to their work. However,
they have to notify each other of what is available on the drive.
One notable exception to the limitations in information sharing
involves the department-wide team headed by RMS that is responsible for
coordinating the monitoring of designated high-risk grantees. The
designation is assigned when the results of audits or other monitoring
activities show the grantee has significant deficiencies and is not
meeting program, financial, or administrative requirements. Currently
there are 17 grantees with this designation. This team meets weekly and
includes representatives from the program offices, OCFO, and other
department-wide offices. At these meetings, the team shares information
about the high-risk grantees, monitoring issues involving those
grantees, progress made in addressing corrective action plans, and
other issues that may arise. As noted previously, RMS is nearing
completion of an information-sharing tool for the department that would
provide program specialists with relevant information related to all
grantees department-wide. However, RMS does not have a targeted
implementation date for the information-sharing tool.
In addition to the limited accessibility of information on grantees, we
found there is limited information on promising practices in grant
monitoring. In 2007, the department's Grants Pilot Project Team
recommended disseminating promising practices for grant monitoring to
all program offices. However, the program office directors and other
staff we interviewed were generally not aware of a formal mechanism for
sharing promising practices and desired a more formal approach. While
management staff in some offices said they share information on
promising practices through informal contacts and networks, managers in
four of the offices we visited said that a means to share such
information more systematically would be helpful to all offices and a
good way to improve grant monitoring practices.
Conclusions:
Since it created RMS in October 2007, Education has made progress in
developing a risk-based approach to monitoring its more than 18,000
grantees. While allowing individual program offices to develop their
own procedures might make sense given the range of programs and
missions in the various offices, not all of the program offices have
developed procedures for assessing grantee risk. RMS is developing
training, software, and technical assistance that the program offices
can use to aid in the development of their own risk assessment
procedures; however, many of these efforts are in the planning stages
and do not have an implementation timeline.
The shortcomings we have identified in Education's risk assessment
practices provide challenges for the department in targeting its
monitoring efforts to the grantees most likely to have compliance
problems, identifying potential misuse or waste of grant funds that
could deprive other areas of needed scarce resources, and improving its
monitoring processes through a wider exchange of information about
grantees. With regard to reviewing grantee financial compliance, the
lack of financial expertise among program specialists and training
opportunities prevents staff from routinely conducting more thorough
reviews and probing more deeply into grantee financial information,
risking failure to identify misuse or waste of grant funds. Without
more widespread sharing of information, Education cannot ensure that
problems with a grantee identified by one office become known to other
offices supporting the same grantee, or promising practices that can
improve the effectiveness of the monitoring process are adopted on a
wider scale.
Recommendations for Executive Action:
In order to better target grant monitoring and ensure that monitoring
staff have the knowledge and information that would help them focus
their monitoring efforts, we recommend that the Secretary of Education
take the following three actions:
* Develop department-wide guidance on risk assessment, continue efforts
to develop new grantee risk assessment tools that can be implemented
department-wide, and work with the program offices to ensure these
tools are implemented.
* Implement a strategy to ensure each program office has staff with
sufficient financial monitoring expertise to conduct or assist other
program specialists in conducting financial compliance reviews. This
could include proceeding with plans for enhanced financial training and
also assessing options such as using dedicated staff or contractors to
conduct grantee financial reviews.
* Develop an easily accessible mechanism for sharing information across
all offices about grantees' past and present performance, and an
accessible forum for sharing promising practices in grant monitoring to
ensure all program offices are able to effectively and efficiently
perform all of their duties and responsibilities.
Agency Comments and Our Evaluation:
We provided a draft of this report to the Secretary of Education.
Education's comments are presented in appendix II. Education generally
agreed with our recommendations and said it is taking various steps to
address them. However, Education believed the draft report should
provide a more complete and accurate picture of its overall monitoring
efforts and provided technical comments to provide a more complete and
accurate analysis of its monitoring practices. We believe our draft
report provided an accurate portrayal of Education's monitoring efforts
and presented appropriate evidence for our conclusions and
recommendations. We reviewed Education's technical comments and
incorporated them when appropriate.
We are sending copies of this report to appropriate congressional
committees, the Secretary of Education, and other interested parties.
In addition, the report will be available at no charge on GAO's Web
site at [hyperlink, http://www.gao.gov]. Please contact me at (202) 512-
7215 if you or your staff have any questions about this report. Contact
points for our offices of Congressional Relations and Public Affairs
may be found on the last page of this report. Other major contributors
to this report are listed in appendix III.
Signed by:
Cornelia M. Ashby:
Director Education, Workforce, and Income Security Issues:
[End of section]
Appendix I: Comparison of Grant Funding in the Department of
Education's Principal and Program Offices:
Each pie chart in figure 4 represents a principal office in Education
that awards grants to state and local educational agencies,
institutions of higher education, and other eligible entities. The
chart for each office is sized according to its share of the total
amount of Education's grant funding in that office based on fiscal year
2008 appropriations. The program offices we included in our review, and
their percentage of principal office grant funds, are shown by the
labeled slices. The unlabeled slices represent the program offices that
were not included in our review.
Figure 4: Comparison of Grant Funding in Education Department Principal
Offices:
[Refer to PDF for image: 8 pie-charts]
Program Offices reviewed by GAO:
OESE: $21.8 billion:
Student Achievement and School Accountability: 66%;
Academic Improvement and Teacher Quality Programs: 23%;
Impact Aid Programs: 6%;
Migrant Education: 2%;
Program Offices not reviewed by GAO: 3%.
OSERS: $15.2 billion:
Office of Special Education Program: 78%;
Rehabilitation Services Administration: 21%;
Program Offices not reviewed by GAO: 1%.
OPE: $2.8 billion:
Higher Education Preparation and Support Service: 32%;
Program Offices not reviewed by GAO: 68%.
OVAE: $1.9 billion:
Academic and Technical Education: 69%;
Adult Education and Literacy: 31%.
OII: $848 million:
Parental Options and Information: 47%;
Program Offices not reviewed by GAO: 53%.
OELA: $721 million:
Continuation and Professional Grants: 100%.
OSDFS: $684 million:
Drug-Violence Prevention-State Programs: 42%;
Program Offices not reviewed by GAO: 58%.
OIE: $280 million:
Program Offices not reviewed by GAO: 100%.
Source: GAO analysis of Department of Education data.
Notes: OESE = Office of Elementary and Secondary Education; OPE =
Office of Postsecondary Education; OSDFS = Office of Safe and Drug-Free
Schools; OSERS = Office of Special Education and Rehabilitative
Services; OII = Office of Innovation and Improvement; OELA = Office of
English Language Acquisition;IES = Institute of Education Sciences;
OVAE = Office of Vocational and Adult Education.
[End of figure]
[End of section]
Appendix II: Comments from the Department of Education:
United States Department Of Education:
The Deputy Secretary:
400 Maryland Ave., S.W.
Washington, D.C. 20202-0500:
[hyperlink, http://www.ed.gov]
Our mission is to ensure equal access to education and to promote
educational excellence throughout the Nation.
November 16, 2009:
Ms. Cornelia Ashby:
Director, Education Workforce and Income Security Issues:
Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Dear Ms. Ashby:
Thank you for the opportunity to respond to the Government
Accountability Office (GAO) draft report, Grant Monitoring: Department
of Education Could Improve its Processes with Greater Focus on
Assessing Risks, Acquiring Financial Skills, and Sharing Information
(GAO-10-57). The report contains three recommendations for improving
the U.S. Department of Education's ability to effectively and
efficiently monitor grantees for programmatic, financial, and
administrative compliance. The Department generally agrees with the
recommendations, which are consistent with the Department's goal of
continuously improving the effectiveness of the agency's monitoring and
increasing the use of risk-based methodologies. However, we believe
the report should provide a more complete and accurate picture of the
Department's overall monitoring efforts and have submitted technical
edits that provide a more complete and accurate analysis of the
Department's monitoring practices. Below are the Department's responses
to GAO's specific recommendations.
Recommendation: Develop department-wide guidance on risk assessment,
continue efforts to develop new grantee risk assessment tools that can
be implemented department-wide, and work with the program offices to
ensure these tools are implemented.
The Department agrees that a Department-wide grant monitoring strategy,
including an enhanced risk-based approach, could strengthen its
monitoring and oversight. As discussed in the technical edits, the
Department already uses risk-based factors as part of its monitoring
efforts. To further promote the use of risk-based factors and continue
to improve monitoring across the agency, the Department is currently
developing an enhanced risk-based approach to grant monitoring that
will include automated tools to assist grant managers in assessing
grantees' risks in the areas of financial and grants management
compliance, and provide staff easier access to audit findings on both
program and financial compliance issues.
Recommendation: Implement a strategy to ensure each program office has
staff with sufficient financial monitoring expertise to conduct or
assist other program specialists in conducting financial compliance
reviews. This could include proceeding with plans for enhanced
financial training and also assessing options such as using dedicated
staff or contractors to conduct grantee financial reviews.
As noted in the technical edits, the Department uses resources from
other offices (e.g., Risk Management Service, Office of the General
Counsel, Office of the Chief Financial Officer) with expertise in
fiscal matters to advise, train, and supplement the resources of the
program offices when needed. However, we recognize the importance of
oversight of grantees' compliance with government-wide rules for
financial and grants administration and believe that our efforts will
be enhanced by further increasing program staffs' expertise related to
financial management, and further developing the expertise and the
capacity necessary to monitor compliance with the federal grant
requirements related to financial management. The Department is
evaluating options for building capacity in this area, including those
recommended by GAO, such as providing additional financial training to
Department staff or engaging contractors to conduct grantee financial
reviews.
Recommendation: Develop an easily accessible mechanism for sharing
information across all offices about grantees' past and present
performance, and an accessible forum for sharing promising practices
for grant monitoring to ensure all program offices are able to
effectively and efficiently perform all of their duties and
responsibilities.
As noted in the technical edits, much consultation among programs and
other offices already takes place, and currently there are effective
means to coordinate information. However, the Department-wide grant
monitoring efforts could be enhanced by improving access to monitoring
findings and other information on grantees' past performance for all of
the Department's program offices. The Department agrees that additional
easily accessible mechanisms for sharing information across programs on
grantees' past performance will further improve the Department's
ability to assess risk and provide targeted technical assistance to
help grantees improve their grants administration.
We appreciate the opportunity we have had to discuss with you our
responses to these recommendations, as well as our technical edits in
response to GAO's draft findings. Please let me know if you have any
questions.
Sincerely,
Signed by:
Anthony W. Miller:
[End of section]
Appendix III: GAO Contact and Staff Acknowledgments:
GAO Contact:
Cornelia M. Ashby, (202)512-7215, or ashbyc@gao.gov:
Staff Acknowledgments:
In addition to the individual named above, other GAO staff who made key
contributions to this report are Bill Keller, Assistant Director; Joel
Marus, Analyst-in-Charge; Travis Hill; Jill Yost; Charles Willson; Kate
Van Gelder; Luann Moy; Walter Vance; Jim Rebbe; and James Bennett.
[End of section]
Footnotes:
[1] Pub. L. No. 111-5, 123 Stat. 115 (2009).
[2] See, for example, GAO, Low-Income and Minority Serving
Institutions: Management Attention to Long-standing Concerns Needed to
Improve Education's Oversight of Grant Programs, [hyperlink,
http://www.gao.gov/products/GAO-09-309] (Washington, D.C.: Aug. 17,
2009) and Teacher Quality: Sustained Coordination among Key Federal
Education Programs Could Enhance State Efforts to Improve Teacher
Quality, [hyperlink, http://www.gao.gov/products/GAO-09-593]
(Washington, D.C.: July 6, 2009).
[3] We did not include the Office of Federal Student Aid, which
oversees student financial assistance grants, or the Institute of
Education Sciences because the grant programs they administer generally
do not give funds for providing education or education-related services
to students.
[4] When referring to program specialists throughout the report, we are
referring to program specialists in the 12 program offices.
[5] Although we used random sampling, we requested that program
specialists with only brief experience in the offices be excluded. In
addition, in some cases offices noted that they had a program
specialist with financial expertise and we requested that the person be
included in the group discussion.
[6] Office of Management and Budget Circular A-123, Management's
Responsibility for Internal Control, December 21, 2004.
[7] U.S. Department of Education, FY 2007 Performance and
Accountability Report, November 15, 2007.
[9] For purposes of describing staff covered under this skills
inventory, we are including three job classifications among program
specialist staff: program specialists, education research analysts, and
management program analysts.
[End of section]
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