Drug-Free Communities Support Program
Stronger Internal Controls and Other Actions Needed to Better Manage the Grant-Making Process Gao ID: GAO-08-57 July 31, 2008Twenty-five percent of American students ages 13-17 reported using illicit drugs in 2007. The Drug-Free Communities Support Program provides grants to community coalitions involved in reducing youth substance abuse. The Office of National Drug Control Policy (ONDCP) administers the program. ONDCP selected the Substance Abuse and Mental Health Services Administration (SAMHSA) to operate the grant program in fiscal year 2005. In 2005, ONDCP did not award grants to some coalitions who had previously received grant funds (renewal grantees). GAO was asked to assess (1) the extent to which ONDCP and SAMHSA administered grant-related activities for fiscal years 2005 and 2006 consistent with federal internal control standards, statutory requirements, and other guidance and (2) the steps ONDCP has taken since 2006 regarding its administration of grant-related activities. GAO analyzed and compared program documents and grant activities to established guidance, such as federal internal control standards and statutory requirements, and interviewed key program management officials.
In fiscal years 2005 and 2006, ONDCP and SAMHSA did not always adhere to applicable federal internal control standards, statutory requirements, and other guidance during the grant-making process. Standards for internal control in the federal government call for agencies to conduct ongoing monitoring of a program's performance, but ONDCP did not conduct such monitoring of SAMHSA or the program overall. Thus, ONDCP increased its risk of not providing reasonable assurance that SAMHSA conducted grant activities, such as eligibility screening. Internal control standards also require that agencies maintain documentation that grant applicants met eligibility requirements each fiscal year. While SAMHSA officials said that they screened all renewal grantees for eligibility in 2005 and ONDCP officials said they screened all initial grantees in 2006, documentation indicating that such screening had occurred was missing from 47 of the 66 grantee files GAO reviewed. ONDCP also lacked a process to ensure that all renewal applicants met statutory eligibility requirements. For example, ONDCP used a separate screening process in fiscal year 2005 that included a criterion that grantees limit funding for direct services, such as enrolling individuals in a drug prevention program. Only renewal grant applicants that met this or one of two other criteria underwent further screening for statutory eligibility. As a result, ONDCP funded about 86 percent of renewal grantees in 2005 without ensuring that they met the statutory eligibility criteria. Leading practices for collaborating agencies call for strategies to ensure common outcomes. However, the inter-agency agreement between ONDCP and SAMHSA did not fully define roles and responsibilities and lacked specific guidance to SAMHSA on eligibility screening. As a result, confusion occurred over issues, such as the eligibility criteria to apply, hampering the two agencies in their efforts to effectively manage the grant-making process. Since 2006, ONDCP has addressed some of the issues described above, by (1) clarifying its role for the program in its 2007 agreement with SAMHSA, (2) establishing management groups to address monitoring issues, and (3) eliminating its use of the direct services eligibility criterion. However, some internal control and other challenges remain. For example, ONDCP has not yet put a mechanism in place to ensure that documentation confirming eligibility is maintained in the grant files. ONDCP also has not documented its approach to overseeing SAMHSA and the program. Without defined oversight activities for ensuring completion of the work, ONDCP lacks reasonable assurance that required tasks are being performed in accordance with management's directives. Also, roles and responsibilities for key elements of grant administration remain largely undefined in that the agencies have not clarified certain services SAMHSA is to provide related to awarding grants or the role of the program Administrator. Without defining these roles, confusion on the steps to follow in managing the program could continue to occur. Finally, as in 2006, ONDCP officials told GAO that they did not screen renewal grant applicants for eligibility in 2007 because the screening that applicants undergo when they first receive a grant is sufficient.
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-08-57, Drug-Free Communities Support Program: Stronger Internal Controls and Other Actions Needed to Better Manage the Grant-Making Process
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Report to Congressional Requesters:
United States Government Accountability Office:
GAO:
July 2008:
Drug-Free Communities Support Program:
Stronger Internal Controls and Other Actions Needed to Better Manage
the Grant-Making Process:
GAO-08-57:
GAO Highlights:
Highlights of GAO-08-57, a report to congressional requesters.
Why GAO Did This Study:
Twenty-five percent of American students ages 13-17 reported using
illicit drugs in 2007. The Drug-Free Communities Support Program
provides grants to community coalitions involved in reducing youth
substance abuse. The Office of National Drug Control Policy (ONDCP)
administers the program. ONDCP selected the Substance Abuse and Mental
Health Services Administration (SAMHSA) to operate the grant program in
fiscal year 2005. In 2005, ONDCP did not award grants to some
coalitions who had previously received grant funds (renewal grantees).
GAO was asked to assess (1) the extent to which ONDCP and SAMHSA
administered grant-related activities for fiscal years 2005 and 2006
consistent with federal internal control standards, statutory
requirements, and other guidance and (2) the steps ONDCP has taken
since 2006 regarding its administration of grant-related activities.
GAO analyzed and compared program documents and grant activities to
established guidance, such as federal internal control standards and
statutory requirements, and interviewed key program management
officials.
What GAO Found:
In fiscal years 2005 and 2006, ONDCP and SAMHSA did not always adhere
to applicable federal internal control standards, statutory
requirements, and other guidance during the grant-making process.
Standards for internal control in the federal government call for
agencies to conduct ongoing monitoring of a program‘s performance, but
ONDCP did not conduct such monitoring of SAMHSA or the program overall.
Thus, ONDCP increased its risk of not providing reasonable assurance
that SAMHSA conducted grant activities, such as eligibility screening.
Internal control standards also require that agencies maintain
documentation that grant applicants met eligibility requirements each
fiscal year. While SAMHSA officials said that they screened all renewal
grantees for eligibility in 2005 and ONDCP officials said they screened
all initial grantees in 2006, documentation indicating that such
screening had occurred was missing from 47 of the 66 grantee files GAO
reviewed. ONDCP also lacked a process to ensure that all renewal
applicants met statutory eligibility requirements. For example, ONDCP
used a separate screening process in fiscal year 2005 that included a
criterion that grantees limit funding for direct services, such as
enrolling individuals in a drug prevention program. Only renewal grant
applicants that met this or one of two other criteria underwent further
screening for statutory eligibility. As a result, ONDCP funded about 86
percent of renewal grantees in 2005 without ensuring that they met the
statutory eligibility criteria. Leading practices for collaborating
agencies call for strategies to ensure common outcomes. However, the
inter-agency agreement between ONDCP and SAMHSA did not fully define
roles and responsibilities and lacked specific guidance to SAMHSA on
eligibility screening. As a result, confusion occurred over issues,
such as the eligibility criteria to apply, hampering the two agencies
in their efforts to effectively manage the grant-making process.
Since 2006, ONDCP has addressed some of the issues described above, by
(1) clarifying its role for the program in its 2007 agreement with
SAMHSA, (2) establishing management groups to address monitoring
issues, and (3) eliminating its use of the direct services eligibility
criterion. However, some internal control and other challenges remain.
For example, ONDCP has not yet put a mechanism in place to ensure that
documentation confirming eligibility is maintained in the grant files.
ONDCP also has not documented its approach to overseeing SAMHSA and the
program. Without defined oversight activities for ensuring completion
of the work, ONDCP lacks reasonable assurance that required tasks are
being performed in accordance with management‘s directives. Also, roles
and responsibilities for key elements of grant administration remain
largely undefined in that the agencies have not clarified certain
services SAMHSA is to provide related to awarding grants or the role of
the program Administrator. Without defining these roles, confusion on
the steps to follow in managing the program could continue to occur.
Finally, as in 2006, ONDCP officials told GAO that they did not screen
renewal grant applicants for eligibility in 2007 because the screening
that applicants undergo when they first receive a grant is sufficient.
What GAO Recommends:
GAO recommends that ONDCP strengthen internal controls, ensure that
funded grant applicants satisfy statutory eligibility criteria, and
fully define roles and responsibilities. In commenting on a draft of
this report, ONDCP described actions taken to address these
recommendations.
To view the full product, including the scope and methodology, click on
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-57]. For more
information, contact Robert Goldenkoff at (202) 512-6806 or
goldenkoffr@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
Administration of Drug-Free Communities Grant-Making Process Contained
a Number of Implementation Weaknesses:
ONDCP Has Taken Steps to Better Manage the Grant-Making Process, but
These Efforts Can Be Strengthened:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Scope and Methodology:
Appendix II: Timeline of Key Events for Drug-Free Communities Support
Program, Fiscal Year 2005:
Appendix III: Comments from the Office of National Drug Control Policy:
Appendix IV: Comments from the Department of Health and Human Services:
Appendix V: GAO Contact and Staff Acknowledgments:
Table:
Table 1: ONDCP Used Different Screening Process for Initial and Renewal
Grant Applicants in Fiscal Year 2005:
Figures:
Figure 1: Organizational Overview of Drug-Free Communities Support
Program:
Figure 2: Summary of Statutory Eligibility Criteria of the Drug-Free
Communities Support Program:
Figure 3: Screening Process ONDCP Reportedly Used in Fiscal Year 2005
for the Drug-Free Communities Support Program Differed from Typical
Screening Process for Federal Grant Programs:
Figure 4: ONDCP Reported that All Funded Initial Grant Applicants Met
Statutory Eligibility Criteria in Fiscal Year 2005, but Most Funded
Renewal Grant Applicants Were Not Screened:
Figure 5: Timeline of Key Events for Drug-Free Communities Support
Program, Fiscal Year 2005:
Abbreviations:
DOJ: Department of Justice:
FMFIA: Federal Managers' Financial Integrity Act of 1982:
HHS: Department of Health and Human Services:
OMB: Office of Management and Budget:
ONDCP: Office of National Drug Control Policy:
SAMHSA: Substance Abuse and Mental Health Services Administration:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
July 31, 2008:
The Honorable Joseph R. Biden, Jr.
Chairman:
The Honorable Charles E. Grassley:
Co-Chairman:
Caucus on International Narcotics Control:
United States Senate:
The Honorable Elijah E. Cummings:
The Honorable Sander M. Levin:
The Honorable Mark E. Souder:
House of Representatives:
Twenty-five percent of American students between the ages of 13 and 17
reported using illicit drugs in 2007, according to a government survey.
[Footnote 1] To address this problem, various efforts to curb substance
abuse among youth are underway in the United States. One such effort is
the Drug-Free Communities Support Program, which was established by the
Drug-Free Communities Act of 1997 and is administered by the Office of
National Drug Control Policy (ONDCP) within the Executive Office of the
President.[Footnote 2] ONDCP is led by a Director responsible for
establishing a program to support communities in preventing and
treating substance abuse among youth. The Director appoints an
Administrator who is statutorily responsible for carrying out the
program. The Drug-Free Communities Support Program was designed to help
communities develop and implement comprehensive, long-term plans and
programs to prevent and treat substance abuse. Under the Drug-Free
Communities Support Program, ONDCP provides federal grants to
"coalitions" that have established sustainable and accountable anti-
drug efforts involving every major sector of a community. These
coalitions are broad-based groups consisting of representatives of
youth, parents, businesses, the media, law enforcement, religious or
other civic groups, health care professionals, and other organizations
involved in reducing substance abuse in their communities, especially
among the young.
The Drug-Free Communities Support Program supports community coalitions
in their efforts to address and reduce substance abuse among youth by
providing federal grants in the form of initial and renewal grants.
[Footnote 3] These initial and renewal grants are available to eligible
coalitions in amounts up to $125,000 for a fiscal year.[Footnote 4] By
statute, eligible coalitions may receive Drug-Free Communities Support
Program grants for two 5-year cycles (generally, an initial grant and
four renewal grants per 5-year cycle).[Footnote 5] According to ONDCP,
a coalition, after award of an initial grant, will continue to receive
funds during the 5-year cycle if ONDCP determines that the coalition
makes satisfactory progress in its efforts to reduce substance abuse
among youth and the coalition complies with the conditions of their
award, and remains eligible for the grant. For example, the coalition
must have as its principal mission the reduction of substance abuse in
a comprehensive and long-term manner, with a primary focus on youth in
the community. Over the program's 10-year existence, approximately $550
million has been appropriated for grant awards.
The Drug-Free Communities Support Program has undergone administrative
changes in recent years. Since the program's inception in 1997, ONDCP
has delegated authority for the execution of certain grant management
activities to other agencies, as authorized by statute.[Footnote 6]
From fiscal years 1998 to 2004, ONDCP managed the Drug-Free Communities
Support Program in conjunction with the Office of Juvenile Justice and
Delinquency Prevention, an office within the Department of Justice
(DOJ). In fiscal year 2004, as a result of a recommendation from the
program's Advisory Commission[Footnote 7] aimed at determining the
appropriate agency to execute certain grant management activities of
the program,[Footnote 8] ONDCP selected the Substance Abuse and Mental
Health Services Administration (SAMHSA), a component of the Department
of Health and Human Services (HHS), to help manage the program. Fiscal
year 2005 was the first year that the grant program was operated by
ONDCP and SAMHSA under an inter-agency agreement. During the fiscal
year 2005 process, some renewal grant applicants were denied a grant
within their 5-year cycle by ONDCP, which raised questions about how
the grant program was administered and how the grantee application
review process was conducted during that fiscal year.
You requested that we review the grant-related activities, including
how ONDCP and SAMHSA screened applicants to determine eligibility and
communicated with coalitions about the grant program. This report
addresses: (1) the extent to which ONDCP and SAMHSA administered grant-
related activities for fiscal years 2005 and 2006 in accordance with
federal internal control standards, statutory requirements, and leading
practices for collaborating agencies and (2) the steps ONDCP has taken
since fiscal year 2006, if any, concerning its administration of grant-
related activities.
To determine the extent to which ONDCP and SAMHSA conducted its grant-
related activities, including eligibility screening for the Drug-Free
Communities Support Program in accordance with Internal Control
Standards for the Federal Government,[Footnote 9] statutory
requirements, and leading practices for collaborating agencies,
[Footnote 10] we reviewed available documents such as grant
announcements and inter-agency agreements between ONDCP and SAMHSA and
compared them to these criteria. Further, to determine whether ONDCP
and SAMHSA had documented eligibility screening, we reviewed systematic
random samples of available grant applications for fiscal years 2005
and 2006.[Footnote 11] Because the 126 applications we reviewed (of
which 66 were awarded grants) were not representative of all of the
approximately 1,690 applications, we cannot generalize the results to
the larger populations of fiscal year 2005 (about 990 applications) or
fiscal year 2006 applicants (over 700 applications). Even so, our
review of these applications provided us with perspective on how ONDCP
and SAMHSA handled these applications. Additionally, because accurate
counts of the total numbers of applications in fiscal years 2005 and
2006 were not available, we provide approximate numbers of applications
to illustrate orders of magnitude. We compared ONDCP's and SAMHSA's
grant-related activities in fiscal years 2005 through 2007 with
criteria in GAO's Standards for Internal Control in the Federal
Government. These standards, issued pursuant to the requirements of the
Federal Managers' Financial Integrity Act of 1982 (FMFIA),[Footnote 12]
provide the overall framework for establishing and maintaining internal
control in the federal government. Also pursuant to FMFIA, the Office
of Management and Budget (OMB) issued Circular A-123, revised December
21, 2004, to provide the specific requirements for assessing the
reporting on internal controls. Internal control standards and the
definition of internal control in OMB Circular A-123 are based on GAO's
Standards for Internal Control in the Federal Government. We also
considered our prior work on results-oriented government related to
leading practices for federal collaboration.[Footnote 13] In addition,
we compared ONDCP's and SAMHSA's grant-related activities in fiscal
years 2005 through 2007 with statutory criteria included in the Drug-
Free Communities Act of 1997;[Footnote 14] the Drug-Free Communities
Support Program Reauthorization Act of 2001;[Footnote 15] and the
Office of National Drug Control Policy Reauthorization Act of 2006.
[Footnote 16]
To identify the steps ONDCP has taken since fiscal year 2006, if any,
concerning its administration of grant-related activities, we reviewed
the documents and grant applications described above. We also
interviewed key staff at ONDCP and SAMHSA about how they conducted and
documented grant-related activities since 2006. While our discussions
with agency officials from ONDCP and SAMHSA focused on the agencies'
review methods and funding decisions implemented in fiscal years 2005
and 2006, we also obtained information for fiscal year 2007 wherever
possible to provide the most current information on the program. We did
not review the fiscal year 2008 grant-making process because the
process was underway during our review and the results of the process
were not yet available.
We conducted this performance audit from July 2006 through July 2008 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. Additional details on our
scope and methodology are contained in appendix I.
Results in Brief:
In administering the Drug-Free Communities Support Program in fiscal
years 2005 and 2006, the grant award process of ONDCP and SAMHSA did
not always adhere to key internal control standards for the federal
government essential for proper stewardship of public resources, the
statutory requirements governing the program,[Footnote 17] and leading
practices for collaboration and coordination between agencies to ensure
only eligible coalitions were awarded grants.[Footnote 18] Standards
for internal control in the federal government call for on-going
monitoring of a program's performance, and transactions to be clearly
documented and for the documentation to be readily available for
examination, among other actions. Further, the statutory requirements
governing the Drug-Free Communities Support Program require a coalition
to meet each of the statutory eligibility criteria, each fiscal year,
to be eligible to receive an initial or renewal grant. Also, as we
reported in October 2005, collaborating agencies need to establish
strategies that work in concert with those of their partners, which can
help in aligning partner agencies' activities and core processes and
resources.[Footnote 19] However, for fiscal years 2005 and 2006, we
identified weaknesses in the following areas:
* ONDCP and SAMHSA signed inter-agency agreements that did not provide
guidance for monitoring and overseeing the program. Also, ONDCP
officials acknowledged that they did not conduct ongoing monitoring and
oversee the grant program because ONDCP expected SAMHSA to carry out
its duties as specified in the inter-agency agreement and the funding
announcement. Because ONDCP did not engage in ongoing monitoring, the
agency increased its risk that it cannot provide reasonable assurance
that SAMHSA conducted grant activities according to ONDCP's
expectations. Additionally, we found that 47 of 66 (71 percent) of the
files we reviewed for initial and renewal grant applicants that were
awarded funding lacked documentation that showed whether the statutory
eligibility criteria had been met or assessed. Furthermore, the
screening sheet that SAMHSA and ONDCP used in fiscal years 2005 and
2006 to assess grant applicants' eligibility did not include all of the
criteria the statute requires be considered in assessing an applicants'
eligibility. Nor did the files with these screening sheets contain
other documentation to demonstrate that applications were completely
assessed for statutory eligibility. Without documentation of a process
that considers all of the statutory requirements, ONDCP increased its
risk that all grant applicants awarded funding were not statutorily
eligible to receive the grant funds.
* ONDCP also lacked a process to screen renewal grant applicants to
ensure ongoing statutory eligibility. As a result, ONDCP funded the
majority (about 86 percent) of renewal grant applicants in fiscal year
2005 and all of these applicants for fiscal year 2006 without ONDCP or
SAMHSA ensuring that they satisfied the statutory eligibility criteria.
For fiscal year 2005, ONDCP used a separate screening process
consisting of three criteria[Footnote 20]--including one that
applicants limit the amount of grant funds used to provide direct
services to individuals[Footnote 21]--to determine whether grant
applicants would be screened for statutory eligibility. ONDCP officials
told us that they instituted this screening process because late in
fiscal year 2005 SAMHSA did not produce evidence that all applications
had been screened for statutory eligibility and to ensure that funds
were awarded only to eligible coalitions, as required by statute. Under
ONDCP's screening process, renewal grant applicants were subjected to
statutory eligibility screening when they met one or more of the three
criteria. For fiscal year 2006, ONDCP officials told us that they did
not require renewal grant applicants to undergo any process to
determine whether the applicants satisfied the statutory eligibility
criteria because ONDCP believed that an eligibility screen for a
previous year was also sufficient for the current fiscal year. Without
screening renewal grant applicants for statutory eligibility for fiscal
years 2005 and 2006, ONDCP increased its risk that the coalitions it
awarded funding were not statutorily eligible to receive the grant
funds.
* ONDCP and SAMHSA did not follow leading practices for collaboration,
such as agreeing on roles and responsibilities and establishing
compatible policies, procedures, and other means to operate across
agency boundaries. The inter-agency agreements signed by ONDCP and
SAMHSA did not fully define all roles and responsibilities for managing
the grant process, such as the role of SAMHSA in screening renewal
grant applicants for eligibility. As a result, in fiscal year 2005,
confusion occurred over the extent to which eligibility screening had
taken place, hampering ONDCP and SAMHSA in their efforts to effectively
manage the grant-making process.
Since fiscal year 2006, ONDCP has addressed some of the issues
described above by establishing senior-level management groups to
address collaboration and monitoring issues, eliminating its use of the
direct services eligibility criterion in response to reauthorizing
legislation, and clarifying grant program roles and responsibilities.
However, weaknesses in internal controls and other challenges remain.
For example:
* ONDCP has not developed or documented its approach to monitoring
SAMHSA's administration of the grant program and overseeing the grant
program as a whole as required by internal control standards. Without
defined oversight activities for ensuring successful completion of the
work, ONDCP lacks reasonable assurance that required tasks are being
performed in accordance with its directives. Further, ONDCP has not yet
taken steps to ensure that key grant file documentation is maintained
in the grant files. Nor has ONDCP amended the eligibility screening
sheets for fiscal year 2007 to better capture the statutory eligibility
criteria for use in screening initial grant applicants.
* Various challenges in defining roles and responsibilities for program
management have not been fully addressed. Specifically, the two
agencies have yet to develop policies and procedures to clarify certain
services SAMHSA will provide related to awarding grants, as required
under the inter-agency agreement. Additionally, while the agreement
designates the Director of ONDCP as responsible for making final
funding decisions, the agreement does not specifically define the role
of the Administrator for the Drug-Free Communities Support Program.
Because the Administrator for the grant program, by statute, is
responsible for generally carrying out those responsibilities,
including making decisions related to the statutory eligibility
criteria, it is particularly important that the agencies agree upon and
document what this leadership role entails. Without taking action to
fully define these roles and responsibilities, confusion on the steps
to follow in managing the program could continue to occur.
* As in fiscal year 2006, ONDCP officials told us that they did not
screen renewal grant applicants for statutory eligibility in fiscal
year 2007, nor did they require grantees to submit any supporting
documentation to show that the statutory eligibility criteria had been
met. Without screening for statutory eligibility, ONDCP increased its
risk that the renewal grant applicants it awarded funding to in fiscal
year 2007 were not statutorily eligible for such funding.
To improve the internal controls and management of the Drug-Free
Communities Support Program, we are recommending that the Director of
ONDCP (1) develop and document its approach to monitoring and
overseeing SAMHSA and the program as a whole, (2) ensure that the
coalitions receiving an initial grant or a renewal grant satisfy all of
the statutory eligibility criteria and the basis for grant decisions is
fully documented, and (3) fully define the roles and responsibilities
of SAMHSA and ONDCP, including those of the Drug-Free Communities
Support Program Administrator, in operating the program.
We provided a draft of this report to ONDCP, HHS, and DOJ for review.
The Director of ONDCP described actions underway or planned to address
the recommendations and raised some issues with our presentation of
certain data, such as difficulties in using ONDCP data to accurately
identify the number of applications received by the program in fiscal
years 2005 and 2006. In its comments, SAMHSA described strategies
underway to improve internal controls and management of the Drug-Free
Communities Support Program within SAMHSA and in their partnership with
ONDCP. DOJ provided technical comments.
Background:
The Drug-Free Communities Act of 1997 established the Drug-Free
Communities Support Program.[Footnote 22] The program's two major goals
are to: (1) establish and strengthen collaboration among communities,
private non-profit agencies, and federal, state, local, and tribal
governments to support the efforts of community coalitions to prevent
and reduce substance abuse among youth; and (2) reduce substance abuse
over time among youth and adults by addressing the factors in a
community that increase the risk of substance abuse and promoting the
factors that minimize the risk of substance abuse. As authorized by
statute, the Director of ONDCP may employ any necessary staff and enter
into contracts or agreements with national drug control agencies,
including inter-agency agreements to delegate authority for the
execution of grants and for such other activities necessary to carry
out the program.[Footnote 23]
Since the program's inception in 1997, ONDCP has delegated certain
grant administration activities to other agencies through inter-agency
agreements. These inter-agency agreements are drafted each fiscal year,
reflecting the necessary changes and lessons learned from the previous
year, and are put into effect once they are agreed upon and signed by
both parties. In fiscal year 2005, ONDCP administered the program with
SAMHSA. This inter-agency agreement was the vehicle through which,
consistent with the terms of the statutory requirements, ONDCP sought
to ensure the proper management of the program. This inter-agency
agreement provided ONDCP with an opportunity to set forth the processes
and procedures for the award and management of grants.
An Administrator, appointed by the Director of ONDCP, is responsible
for carrying out a program to support communities in the development
and implementation of plans and programs to prevent and treat substance
abuse among youth. The Administrator is responsible for carrying out
the program, including setting forth various standards related to the
statutory eligibility requirements.[Footnote 24]
From fiscal years 1998 to 2004, the grant program was administered by
the Office of Juvenile Justice and Delinquency Prevention Programs,
organized under the Department of Justice and headed by the Office of
the Assistant Attorney General. From fiscal year 2005 to the present,
the grant program has been administered by SAMHSA, organized under the
Department of Health and Human Services and headed by its Secretary.
See figure 1 for an organizational overview of the program, including
the Office of Juvenile Justice and Delinquency Prevention Program's
past involvement.
Figure 1: Organizational Overview of Drug-Free Communities Support
Program:
[See PDF for image]
This figure contains a timeline, as well as an organizational overview
of Drug-Free Communities Support Program, as follows:
Executive Branch:
* Department of Justice;
- OJP;
- OJJDP (Drug Free Communities partner 1998-2004);
* ONDCP (Drug Free Communities Administrator);
- Drug-Free Communities Support Program;
- Program Advisory Commission (interacts with ONDCP);
* Department of Health and Human Services;
- SAMSHA (Drug Free Communities partner 2005-present);
- Division of Grants Management;
- Center for Substance Abuse Prevention.
OJP: Office of Justice Programs;
OJJDP: Office of Juvenile Justice and Delinquency Prevention;
ONDCP: Office of National Drug Control Policy;
SAMHSA: Substance Abuse and Mental Health Services Administration.
Source: GAO analysis of agencies' data.
[End of figure]
General Overview of the Drug-Free Communities Support Program Grant
Management and Funding Process:
Under the Drug-Free Communities Support Program, grantees receive
federal funds each fiscal year[Footnote 25] and are required to match
federal grant funds with non-federal funds including, at the discretion
of the Administrator, in-kind contributions for that fiscal year.
[Footnote 26] Grantees may receive funding on a fiscal year basis in
two 5-year cycles (although grantees must reapply each fiscal year),
for a total of up to 10 years of funding. There are two classes of
applicants that a coalition may fall under when applying for funding;
each class of applicant has its own set of requirements or
characteristics, as shown below.
* Initial grant applicants are those that are (1) either applying for
their first grant, (2) have received 5 years of funding and are
applying for a sixth year, or (3) have had a lapse in their funding in
the previous fiscal year.
* Renewal grant applicants have received an award in the previous year
and are applying each fiscal year for funding for years 2 through 5 or
years 7 through 10. Renewal grant applicants generally do not compete
with other applicants for funds.[Footnote 27]
Each fiscal year, initial grant applicants submit their applications
for review. Those applications deemed eligible are then forwarded on
for peer review. Peer reviewers are external experts who examine
applications and score them on the basis of several areas, such as the
extent to which a coalition demonstrates effective strategic planning
and implementation. These scores are used to assess the applicant and
range from 0 (lowest score) to 100 (highest score). ONDCP then
determines which coalitions will receive funding, generally awarding
grants from the highest peer review score down until all of the funding
has been used.[Footnote 28]
Each fiscal year, renewal grant applicants submit abbreviated
applications, which include a budget and work-plan, to SAMHSA. SAMHSA
reviews these applications to gather required information on the grant
applicant's progress. Then, ONDCP determines whether to continue
federal grant support.[Footnote 29]
Administration of Drug-Free Communities Grant-Making Process Contained
a Number of Implementation Weaknesses:
The 2005 and 2006 grant award process of ONDCP and SAMHSA did not
adhere to standards for internal control in the federal government,
statutory requirements, and leading practices for collaborating
agencies. The process did not adhere to certain federal internal
control standards because ONDCP lacked mechanisms for monitoring SAMHSA
and ensuring that application reviews were fully documented.
Furthermore, ONDCP instituted procedures for screening grant
applications that did not ensure that all renewal grantees met
statutory eligibility requirements. Finally, ONDCP and SAMHSA
experienced collaboration challenges, such as a lack of fully defined
roles and responsibilities and procedures for conducting eligibility
screening, which hampered their management of the grant-making process.
The Grant Process of ONDCP and SAMHSA Did Not Adhere to Certain
Internal Control Standards Related to Monitoring and Documentation:
Standards for internal control in the federal government are essential
for proper stewardship of public resources because they help ensure
accountability and minimize operational problems. Having internal
controls that operate as intended related to monitoring and oversight
could provide assurance that SAMHSA is conducting its activities in
accordance with the inter-agency agreement signed by both agencies. In
addition, in managing the Drug-Free Communities Support Program,
adequate internal controls, such as ensuring proper documentation of
eligibility screening activities, are key to providing accountability
in the process.
According to internal control standards, management should provide
ongoing monitoring of performance. Neither the inter-agency agreement
between ONDCP and SAMHSA nor other documentation associated with the
grant-making process defined how ONDCP would oversee SAMHSA in
conducting its monitoring responsibilities. In July 2006, we reported
that in using inter-agency agreements, the issuing agency, among other
things, should clearly define roles and responsibilities for conducting
monitoring and oversight.[Footnote 30] However, the inter-agency
agreement for fiscal year 2005 did not articulate such specific roles
and responsibilities for each of the two agencies. The statute states
that ONDCP may enter into inter-agency agreements with other national
drug control agencies to delegate authority for the execution of grants
and for such other activities necessary to carry out the program. As
reflected in the legislative history of the Drug-Free Communities Act
of 1997, the ONDCP Administrator of the program would use the terms of
the inter-agency agreement to oversee the program and ensure that it is
operated and grants are awarded in accordance with the policies and
criteria established for the program. [Footnote 31] However, our review
of the inter-agency agreement found no references about how ONDCP would
monitor SAMHSA in administering the grant-making process or a
description of roles related to these activities. Moreover, we found
that no specific policies and procedures for monitoring the program
were established before the grant process had begun.
Furthermore, ONDCP officials told us that while the inter-agency
agreement was intended to serve as the document for the monitoring,
oversight, and management of the program, they acknowledged that this
was not the case in fiscal year 2005, though officials told us that
staff from both agencies met periodically to review the grant program
process. ONDCP officials acknowledged, however, that they did not
regularly monitor and oversee the grant program because ONDCP expected
SAMHSA to carry out its duties as specified in the inter-agency
agreement and the funding announcement. Because ONDCP did not conduct
ongoing monitoring, the agency increased its risk that it could not
provide reasonable assurance that SAMHSA was conducting grant
activities, such as eligibility screening, according to ONDCP's
expectations.
Standards for Internal Control in the Federal Government call for
transactions and other significant events to be clearly documented and
all documentation to be properly managed and maintained.[Footnote 32]
However, we found that such documentation was not consistently
maintained for reviews of grant applications for statutory eligibility.
Specifically, ONDCP and SAMHSA did not provide us documentation on
whether fiscal year 2005 renewal grant applicants were screened for
statutory eligibility, as we requested. As a result, we asked 10 SAMHSA
project officers whether they conducted the screening, of which 5
reported that they screened renewal grant applicants for eligibility in
fiscal year 2005.[Footnote 33] We also reviewed 66 grant application
files for funded initial and renewal grantees, that covered fiscal
years 2005 and 2006, to determine whether the files contained
documentary evidence that screening for statutory eligibility had
occurred. Documentary evidence was missing from 47 of the 66 grant
files (71 percent) we reviewed. Specifically, for fiscal year 2005,
files for 21 funded renewal grant applicants and 1 funded initial
applicant contained no documentation. For fiscal year 2006, 25 files
for funded initial grant applicants were missing documentary evidence
that eligibility screening took place.[Footnote 34] While our review
cannot be generalized to all grant files for fiscal years 2005 and
2006, the lack of documentation in most of the grant files we reviewed
indicates increased risk that neither ONDCP nor SAMHSA could provide
reasonable assurance that all funded grant applicants were screened for
eligibility.
In addition, the screening sheets used by agency officials to determine
whether an applicant was an eligible coalition did not include all of
the statutory eligibility criteria (see fig. 2 for our summary of the
statutory eligibility criteria).[Footnote 35]
Figure 2: Summary of Statutory Eligibility Criteria of the Drug-Free
Communities Support Program:
[See PDF for image]
Under 21 U.S.C. § 1532(a), to be eligible to receive an initial grant
or a renewal grant, a coalition must meet each of the following
criteria:
Application:
The coalition shall submit an application in writing which is subject
to the review of the Administrator.
Major Sector Involvement:
The coalition shall consist of 1 or more representatives from each of
the following categories: Youth; Parents; Businesses; The media;
Schools; Organizations serving youth; Law enforcement; Religious or
fraternal organizations; Civic and volunteer groups; Health care
professionals; State, local or tribal governmental agencies with
expertise in the field of substance abuse; and other organizations
involved in reducing substance abuse. An individual who is a member of
the coalition may serve on the coalition as a representative of not
more than 1 category as listed above.
Commitment:
The coalition shall demonstrate, to the satisfaction of the
Administrator, that the representatives of the coalition have worked
together on substance abuse reduction initiatives for a period of not
less than 6 months, acting through entities such as task forces,
subcommittees, or community boards. The coalition shall also
demonstrate, to the satisfaction of the Administrator, substantial
participation from volunteer leaders in the community involved
(especially in cooperation with individuals involved with youth such as
parents, teachers, coaches, youth workers, and members of the clergy).
Mission and Strategies:
The coalition shall, with respect to the community involved, have as
its principal mission the reduction of substance abuse in a
comprehensive and long-term manner, with a primary focus on youth in
the community.The coalition shall describe and document the nature and
extent of the substance abuse problem in the community.The coalition
shall provide a description of substance abuse prevention and treatment
and activities in existence at the time of the grant application; and
identify substance abuse programs and service gaps in the community;
develop a strategic plan to reduce substance abuse among youth in a
comprehensive and long-term fashion; and work to develop consensus
regarding the priorities of the community to combat substance abuse
among youth.
Sustainability:
The coalition shall demonstrate that the coalition is an ongoing
concern by demonstrating that the coalition is a nonprofit
organization, or an entity that the Administrator determines to be
appropriate, or part of, or is associated with, an established legal
entity. The coalition shall demonstrate that the coalition is an
ongoing concern by demonstrating that the coalition receives financial
support from non-Federal sources.The coalition shall demonstrate that
the coalition is an ongoing concern by demonstrating that the coalition
has a strategy to solicit substantial financial support from non-
Federal sources to ensure that the coalition and the programs operated
by the coalition are self-sustaining.
Accountability:
The coalition shall establish a system to measure and report outcomes
consistent with common indicators and evaluation protocols established
and approved by the Administrator.For an initial grant, the coalition
shall conduct an initial benchmark survey of drug use among youth (or
use local surveys or performance measures available or accessible in
the community at the time of the grant application). The coalition
shall conduct biennial surveys (or incorporate local surveys in
existence at the time of the evaluation) to measure the progress and
effectiveness of the coalition.The coalition shall provide assurances
that the entity conducting these evaluations or from which the
coalition receives information, has experience in gathering data
related to substance abuse among youth or in evaluating the
effectiveness of community anti-drug coalitions.
Additional Criteria[A]:
The Director shall not impose any eligibility criteria on new
applicants or renewal grantees not provided by statute.
[A] The Office of National Drug Control Policy Reauthorization Act of
2006, Pub. L. No. 109-469, § 804, 120 Stat. 3502, 3535, enacted on
December 29, 2006 (after the fiscal year 2006 grant cycle), amended the
Drug Free Communities Act of 1997 by adding this statutory provision
prohibiting the Director from imposing any eligibility criteria on new
applicants or renewal grantees not provided by statute.
Source: GAO analysis of the statute.
[End of figure]
Specifically, our review of an example of eligibility screening sheets
used for fiscal years 2005 and 2006, and our file review of 19 initial
grantee applications for fiscal year 2005 where eligibility screening
sheets were present, found that the eligibility criteria delineated in
the screening sheets used by ONDCP and SAMHSA officials to determine
whether an applicant was an eligible coalition omitted some of the
statutory eligibility criteria.[Footnote 36] For example, the screening
sheet did not capture whether an applicant had described and documented
the nature and extent of the substance abuse problem in the community;
described the substance abuse prevention and treatment programs and
activities; developed a strategic plan to reduce substance abuse among
youth in a comprehensive and long-term fashion; and worked to develop a
consensus regarding the priorities of the community to combat substance
abuse among youth as required by statute.[Footnote 37] Nor did the
screening sheet examine whether a coalition had established a system to
measure and report outcomes consistent with common indicators and
evaluation protocols established and approved by the Administrator.
[Footnote 38] Without having all of the statutory eligibility criteria
on the screening sheet, ONDCP increased its risk that all statutory
eligibility criteria were not assessed and met and that all funded
grant applicants were not statutorily eligible to receive either an
initial or renewal grant.
Grant Applicants Were Not Screened for Statutory Eligibility in Fiscal
Years 2005 and 2006:
For the Drug-Free Communities Support Program, by statute, a coalition
must meet each of the statutory eligibility criteria each fiscal year
to be eligible to receive an initial grant or a renewal grant.[Footnote
39] ONDCP implemented a separate screening process, not described in
the funding announcement, for initial and renewal grant applicants 1
month before the fiscal year 2005 grant awards were to be announced,
including the introduction of a criterion that grant applicants could
not propose to use over a certain percentage of grant funds for direct
services. Direct services are used to provide a distinct and ongoing
service or activity for an individual or group of individuals such as
prevention programs. ONDCP officials told us that they instituted this
screening process because SAMHSA did not produce evidence that all
applications had been screened for statutory eligibility in fiscal year
2005 and to ensure that funds were awarded only to eligible coalitions,
as required by statute. ONDCP officials told us that because of time
constraints, ONDCP did not review all of the approximately 990 initial
and renewal grant applicants to determine if they met all of the
statutory eligibility criteria. Instead, ONDCP officials said that they
established a separate screening process that would enable the agency
to more carefully scrutinize initial or renewal grant applicants who
met one or more of the three criteria, as described in table 1.
Table 1: ONDCP Used Different Screening Process for Initial and Renewal
Grant Applicants in Fiscal Year 2005:
Criteria: Criterion 1;
Initial grant applicants denied funding when they met one or more of
the following: Peer review score was 68 points or below (out of 100
points).[A];
Renewal grant applicants subjected to statutory eligibility screening
when they met one or more of the following: Coalition intended to use
40 percent or more of its projected Drug-Free Communities Support
Program grant funds to provide direct services to the community.
Criteria: Criterion 2;
Initial grant applicants denied funding when they met one or more of
the following: Postal zip code of the area served by the coalition
overlapped with a coalition already receiving Drug-Free Communities
Support Program grant funds (a renewal grantee) and the coalitions were
not collaborating.[B];
Renewal grant applicants subjected to statutory eligibility screening
when they met one or more of the following: Peer review score was 40
points or below (out of 100 points).
Criteria: Criterion 3;
Initial grant applicants denied funding when they met one or more of
the following: Coalition intended to use 20 percent or more of its
projected Drug-Free Communities Support Program grant funds to provide
direct services to the community;
Renewal grant applicants subjected to statutory eligibility screening
when they met one or more of the following: Any budgetary or other
financial concerns existed.
Source: ONDCP.
[A] Peer reviewers are external experts that scored the grant
applications on the basis of several areas, including, for example, the
extent to which a coalition demonstrated effective capacity building
and strategic planning.
[B] By statute, the Administrator may, with respect to a community,
make a grant to one eligible coalition that represents that community.
The Administrator may award a grant to more than one eligible coalition
that represents a community if the eligible coalitions demonstrate they
are collaborating with one another and each of the coalitions has
independently met the statutory eligibility criteria.
[End of table]
The separate screening process that ONDCP officials said they used for
the Drug-Free Communities Support Program in fiscal year 2005 differed
from the process for federal grant programs in general, as shown in
figure 3.
Figure 3: Screening Process ONDCP Reportedly Used in Fiscal Year 2005
for the Drug-Free Communities Support Program Differed from Typical
Screening Process for Federal Grant Programs:
[See PDF for image]
Actual Screening Process ONDCP Used In 2005:
After the fiscal year 2005 Request for Applications outlining the grant
application requirements was issued, ONDCP officials said that they
implemented a different screening process for initial and renewal grant
applications. The fiscal year 2005 Request for Applications did not
describe ONDCP‘s new screening process.
As a result of implementing its new screening process 1 month before
the fiscal year 2005 grants were to be announced, ONDCP officials
reported that they did not screen all initial and renewal grant
applicants for statutory eligibility.
Typical Screening Process:
Step 1: Funding announcement:
Request for Applications; Requirements explained in funding
announcement.
Step 2: Application screening:
Checklist:
* length;
* date of receipt;
* completeness;
* technical format.
Does application meet screening?
Yes: Pass, move to step 3;
No: Fail, applicant disqualified.
Step 3: Eligibility screening:
Statutory Eligibility Requirements Assessed:
Does application meet eligibility?
Yes: Applicant qualified;
No: applicant disqualified.
Source: GAO analysis of UNDCP and SAMSHA data.
[End of figure]
The criteria and procedures ONDCP officials told us they implemented
for the separate screening process differed for initial and renewal
grant applicants. One key difference was the direct services threshold
applied--20 percent or more of funds could not be used for direct
services for initial grant applicants and 40 percent or more of funds
could not be used for direct services for renewal grant applicants.
Table 1 describes the different screening process and criteria ONDCP
officials said they used for initial and renewal grant applicants in
fiscal year 2005.
In addition, ONDCP officials reported different outcomes for its
separate screening process for initial and renewal grant applicants.
For the initial grant applicants, ONDCP officials reported that all of
the approximately 180 that were funded met the statutory eligibility
requirements. However, ONDCP officials acknowledged that most or about
515 of the approximately 600 (about 86 percent) renewal grant
applicants were funded in fiscal year 2005 without ONDCP or SAMHSA
ensuring that these grantees satisfied the statutory eligibility
criteria.[Footnote 40] The results of ONDCP's review are shown in
figure 4.
Figure 4: ONDCP Reported that All Funded Initial Grant Applicants Met
Statutory Eligibility Criteria in Fiscal Year 2005, but Most Funded
Renewal Grant Applicants Were Not Screened:
[See PDF for image]
This figure contains two pie-charts and one subchart depicting the
following data:
Initial grant applicants, FY 2005:
Not screened for statutory eligibility criteria and were denied
grants[A]: 49% (190);
Screened for statutory eligibility criteria and eligible for grants:
46% (180); Satisfied statutory eligibility criteria and were awarded
grants: 100% (180);
Screened for statutory eligibility criteria and not eligible for
grants: 5% (20).
Total = approximately 390 initial grant applicants.
Renewal grant applicants, FY 2005:
Were not screened for statutory eligibility criteria, but were awarded
grants: 86% (515);
About 55 grant applicants were screened for statutory eligibility
criteria and were not eligible for grants and about 30 satisfied
statutory eligibility criteria and were awarded grants: 14% (85).
Total = approximately 600 renewal applicants.
Note: Numbers may not add due to rounding.
[A] Met one or more of the three criteria in table 1.
Source: ONDCP.
[End of figure]
For the fiscal year 2006 screening process, ONDCP officials said they
applied the direct services criterion differently than in fiscal year
2005. The direct services criterion was also described explicitly as an
additional eligibility criterion to be applied (that is, eligibility
criterion apart from the statutory eligibility criteria) in the 2006
funding announcement. For fiscal year 2006, for initial grant
applicants only, the 20 percent direct services threshold was
explicitly described in both the inter-agency agreement and in the
fiscal year 2006 funding announcement. The inter-agency agreement
between ONDCP and SAMHSA stated that "ONDCP shall review [initial]
applications for compliance with the 20 percent direct services
policy." The funding announcement provided to initial grant applicants
stated that "No more than 20 percent of [Drug-Free Communities] grant
funds may be used for direct services." The funding announcement also
stated that if initial grant applicants did not meet this eligibility
requirement, their applications would not be forwarded for peer review.
While ONDCP clarified the funding announcement for grant applicants in
fiscal year 2006, ONDCP did not screen renewal grant applicants for the
statutory eligibility criteria in fiscal year 2006 because, according
to ONDCP officials, these applicants were already considered to be
statutorily eligible for grant funds. ONDCP officials told us that they
believed that the initial eligibility screening conducted in a previous
year was sufficient for the 4 remaining fiscal years. However, the Drug-
Free Communities Support Program's statutory framework requires that
all coalitions meet each of the statutory eligibility requirements each
fiscal year to be eligible to receive an initial grant or a renewal
grant. As a result of ONDCP's policy in fiscal year 2006, all of the
renewal grant applicants that received renewal grants did so without
ONDCP determining whether these applicants satisfied the statutory
eligibility criteria for that fiscal year.
ONDCP and SAMHSA's Grant-Making Process Was Hindered by a Lack of
Defined Roles and Responsibilities and Written Policies and Procedures:
ONDCP and SAMHSA experienced collaboration challenges, which
contributed to the irregularities we identified for fiscal years 2005
and 2006. In October 2005, we identified leading practices that can be
used to help enhance and sustain collaboration in instances where
multiple agencies have shared responsibility for a program or function.
These practices include, among other things, establishing mutually
reinforcing or joint strategies, agreeing on roles and
responsibilities, and establishing compatible policies, procedures, and
other means to operate across agency boundaries.[Footnote 41] Lack of
fully defined roles and responsibilities and documented procedures to
follow for eligibility screening hampered the efforts of ONDCP and
SAMHSA to effectively manage the grant-making process.
As we reported in our prior work, collaborating agencies need to
establish strategies that work in concert with those of their partners,
which can help in aligning partner agencies' activities, core
processes, and resources to accomplish a common outcome.[Footnote 42]
In fiscal years 2005 and 2006, ONDCP and SAMHSA signed inter-agency
agreements, which were intended to provide a strategy for managing the
grant-making process. Further, as reflected in the legislative history
of the Drug-Free Communities Act of 1997, the Administrator of the
program would use the terms of the inter-agency agreement to oversee
the program and ensure that it is operated and grants are awarded in
accordance with the policies and criteria established for the program.
[Footnote 43]
In June 2006, we reported that the use of inter-agency agreements
requires, among other things, that the issuing agency define roles and
responsibilities for managing the program.[Footnote 44] However, the
inter-agency agreement for fiscal year 2005 did not fully articulate
roles and responsibilities for ONDCP's management of SAMHSA, such as
the role of SAMHSA in screening renewal grant applicants for
eligibility, and for the grant program overall. Therefore, in fiscal
year 2005, confusion occurred over the extent to which eligibility
screening had taken place, resulting in ONDCP implementing its separate
screening process.
Furthermore, procedures governing the grant-making process were not
fully documented for the two agencies, as called for by internal
control standards for the federal government, to operationalize
SAMHSA's tasks. The inter-agency agreement for fiscal year 2005 states
that SAMHSA is responsible for tasks in several broad areas, including
issuing the notice of funding, the application renewal process for
renewal grantees, and making decisions jointly with ONDCP regarding the
selection of grantees and the awarding of initial grantees and renewal
awards. However, the inter-agency agreement did not specify what
guidance SAMHSA was to follow with respect to screening renewal grant
applicants for eligibility. For example, in the absence of detailed
information on how ONDCP and SAMHSA would screen initial and renewal
grant applicants, SAMHSA officials said they relied on established HHS
grant guidance to determine how and when activities such as eligibility
screening were to be performed. The inter-agency agreement also did not
discuss how ONDCP and SAMHSA would agree upon the policies to be
followed in the grant-making process and how those policies would be
documented. In addition, ONDCP officials reported that they believed
that SAMHSA had agreed to conduct the eligibility screening, and when
SAMHSA did not produce its screening sheets, ONDCP officials said they
could not be certain that SAMHSA had conducted the eligibility
screening. Without formal, written policies and procedures both
agencies experienced confusion over what steps would be followed to
manage the program.
ONDCP Has Taken Steps to Better Manage the Grant-Making Process, but
These Efforts Can Be Strengthened:
Since fiscal year 2006, ONDCP has taken steps to strengthen its
management of the grant-making process by establishing senior-level
management groups to address collaboration and monitoring issues,
eliminating its use of the direct services eligibility criterion in
response to reauthorizing legislation, and clarifying grant program
roles and responsibilities. However, effective oversight is still
lacking because ONDCP has neither developed nor documented its approach
to monitoring and overseeing the program as a whole. Furthermore, roles
and responsibilities for managing the program continue to remain fully
undefined, including the appropriate role of the program Administrator.
The ONDCP Reauthorization Act of 2006 prohibited the Director of ONDCP
from imposing any eligibility criteria on initial applicants or renewal
grantees not included in the statute. In response, ONDCP changed
certain procedures for fiscal year 2007 but has not changed its
procedures to ensure that renewal grant applicants are screened for
statutory eligibility.
Lack of Ongoing Monitoring, Documentation Problems, and Undefined Roles
and Responsibilities Remain Challenges for the Grant-Making Process:
In response to our inquiries about what steps have been taken to
monitor and oversee the grant program since fiscal year 2005, senior
ONDCP officials told us that they have taken action to clarify
monitoring roles and responsibilities and improve related
documentation. However, effective oversight is still lacking because
ONDCP has neither developed nor documented its approach to monitoring
and overseeing the program as a whole. According to ONDCP officials, to
address long-term strategic issues involving, among other things,
monitoring activities, various senior-level management groups have been
established, at least one of which meets every 4 to 6 weeks to address
collaboration and monitoring issues. These officials said that no
charter or mission statements were developed for these meetings, and
officials were unable to provide us with information on any specific
outcomes or policy changes that have occurred to enhance oversight of
the program. The fiscal year 2007 inter-agency agreement includes a
brief statement that SAMHSA is to provide a monthly report on high-risk
grantees to ONDCP for, in their view, "the effective oversight" of the
program, but no other program monitoring and oversight information is
specifically discussed. Without defined oversight activities for
ensuring successful completion of the work across all activities, ONDCP
lacks reasonable assurance that required tasks are being performed in
accordance with its directives.
ONDCP officials acknowledged that they were aware that grant file
documentation was missing during fiscal years 2005 and 2006. However,
as of fiscal year 2007, ONDCP had not yet put in place mechanisms to
ensure that documentation of eligibility screening were included in
grant files, as called for by internal control standards.[Footnote 45]
Nor had ONDCP amended the eligibility screening sheets for fiscal year
2007 to capture all the statutory eligibility criteria. Without
ensuring that screening sheets contain all the required statutory
eligibility criteria, ONDCP increased its risk that grantees were not
statutorily eligible to receive grants.
ONDCP and SAMHSA have taken steps to clarify their respective roles and
responsibilities for handling program administration and coordination
issues in their fiscal year 2007 inter-agency agreement. For example,
whereas the inter-agency agreement for fiscal year 2005 did not
delineate roles and responsibilities for administering the grant-making
process, the inter-agency agreement written for fiscal year 2007
provides additional information. Specifically, the fiscal year 2007
agreement includes a new attachment describing ONDCP's role and
responsibilities for the program. The fiscal year 2007 inter-agency
agreement states, for example, that ONDCP will convene "cooperative
partners" meetings with the Center for Substance Abuse Prevention to
enhance program coordination and collaboration. Further, the inter-
agency agreement states that SAMHSA would provide certain services in
connection with the awarding of grants in accordance with policies and
procedures agreed upon by ONDCP and SAMHSA. However, all of these
policies and procedures that ONDCP and SAMHSA agreed to are not
documented in the inter-agency agreement or in other documentation. For
example, the agreement states that ONDCP and SAMHSA shall agree on
terms of the programmatic and budget review prior to reviewing renewal
applications and that ONDCP shall make final funding decisions for
these grants. However, the fiscal year 2007 agreement does not specify
what the programmatic and budget review processes are and when they
should be completed and by which agency.
While efforts to clarify how the grant program is to be administered
and the designation of the Director of ONDCP as responsible for making
final funding decisions represents a step in the right direction, the
Administrator's role is still not specified in the inter-agency
agreement. As noted earlier, the Administrator's role is defined by
statute as the entity that generally carries out the grant program.
While the fiscal year 2007 agreement states that the Director of ONDCP
will make final funding decisions, the role of the Administrator is not
specifically identified, described, or defined in the inter-agency
agreement. Leading practices for collaborating agencies state that
agreement on roles and responsibilities is a necessary element for a
collaborative working relationship.[Footnote 46] Because the
Administrator is responsible for generally carrying out the grant
program, it is particularly important that the agencies agree upon and
document what this leadership role entails. Without doing so, confusion
over managing the program could continue to occur.
Despite ONDCP's Elimination of Certain Eligibility Criterion in
Response to Reauthorizing Legislation, ONDCP Did Not Screen Renewal
Grantees for Statutory Eligibility:
In response to congressional concerns and complaints from renewal grant
applicants that were not funded in fiscal year 2005, the ONDCP
Reauthorization Act of 2006 prohibited the Director of ONDCP from
imposing any eligibility criteria on initial applicants or renewal
grantees not included in the statute.[Footnote 47] ONDCP officials said
that, as a result of the prohibition in the reauthorizing act, they
eliminated their use of the 20 percent direct services eligibility
criterion for fiscal year 2007. Moreover, the fiscal year 2007 inter-
agency agreement no longer contains the 20 percent direct services
criterion, consistent with the reauthorization act. Instead, ONDCP
officials stated that they take direct services into account as part of
the overall evaluation of an application during the peer review
process.
Nonetheless, ONDCP continues to not screen renewal grant applicants for
statutory eligibility. As stated earlier in this report, by statute, to
be eligible to receive a renewal grant, a coalition shall meet all of
the statutory eligibility criteria. However, ONDCP officials stated
that they consider the initial screening they conduct to be sufficient
for the remaining 4 years for renewal grantees.[Footnote 48] In fiscal
year 2007, renewal grant applicants were not required to submit any
supporting documentation (e.g., proof of eligible coalition members) to
verify that they met all the statutory eligibility criteria nor were
they screened for statutory eligibility. ONDCP's approach does not take
into account that a coalition's eligibility status could change from
one fiscal year to another if, for example, representatives from the
different sectors in fiscal year 2006 left the coalition in fiscal year
2007 and were not replaced. ONDCP's decision to not screen renewal
grant applicants for eligibility in fiscal year 2007 raises questions
about whether the agency could provide reasonable assurance that
participating coalitions remain statutorily eligible. ONDCP officials
told us that the eligibility criteria that were missing from the
eligibility screening sheets (e.g., whether an applicant had described
and documented the nature and extent of the substance abuse problem in
the community) are not used during the eligibility process, but rather
are considered during the peer review process. However, these criteria
are intended to be used to determine statutory eligibility for grant
funds. According to ONDCP's practices, peer reviewers do not typically
determine eligibility; they examine only eligible applications for an
application's strength. Without ensuring that all statutory eligibility
criteria were met, ONDCP cannot be certain that all funded grant
applicants were eligible.
Conclusions:
For fiscal years 2005 and 2006, ONDCP and SAMHSA did not adhere to key
federal internal controls standards in the federal government and did
not meet all statutory requirements in administering the Drug-Free
Communities Support grant program. ONDCP has been unable to show that
only eligible coalitions received grants in accordance with the Drug-
Free Communities Support Program's statutory framework. In particular,
because ONDCP has decided not to conduct eligibility screening each
fiscal year for renewal grant applicants, it is unable to ensure that
these coalitions remain eligible for their duration in the program,
consistent with statutory requirements. Without well-functioning
internal controls, such as maintaining grant documentation and
conducting on-going monitoring, ONDCP cannot demonstrate consistent
implementation of the key steps required in the grant-making process--
notably, the screening of grantees to determine their eligibility--to
Congress, grant-seeking applicants, and the public at large. Such lack
of assurance raises questions about whether public resources are
properly safeguarded.
ONDCP took steps following fiscal year 2006 to enhance its
administration of the grant program, such as informing applicants of
changes in its eligibility screening processes and revising its
procedures to address internal control and other deficiencies. However,
ongoing weaknesses in the monitoring and oversight of the program mean
it may not be possible to ensure that all appropriate guidance and
policies are being met or communicated to grant applicants. And while
ONDCP and SAMHSA have made an effort to define roles and
responsibilities in the fiscal year 2007 inter-agency agreement,
important functions, such as the leadership role of the Administrator,
remain unaddressed. Without fully defined and agreed upon roles and
responsibilities, the agencies may not be able to avoid
miscommunication and lack of collaboration over the grant-making
process in the future.
Recommendations for Executive Action:
To strengthen its administration, oversight, and internal controls for
the Drug-Free Communities Support Program, we recommend that the
Director of the Office of National Drug Control Policy take the
following three actions:
1. Develop and document its approach to monitoring and overseeing
SAMHSA and the program as a whole.
2. Ensure that the coalitions receiving an initial grant or a renewal
grant satisfy all of the statutory eligibility criteria for each fiscal
year and that this is fully documented.
3. Fully define the roles and responsibilities of SAMHSA and ONDCP,
including those of the Drug-Free Communities Support Program
Administrator, in the inter-agency agreement prepared for each fiscal
year.
Agency Comments and Our Evaluation:
We provided a draft of this report to ONDCP, HHS, and DOJ for review
and comment. ONDCP and HHS provided written comments, which are
summarized below and included in their entirety in appendixes III and
IV, respectively. In addition, ONDCP and DOJ provided technical
comments, which we incorporated as appropriate.
In commenting on the draft report, the Director of ONDCP described the
efforts it has underway or planned to address our recommendations.
Although these actions are intended to strengthen the management of the
grant review process, based on the ONDCP Director's response,
additional efforts could help ensure that our recommendations are fully
implemented, as discussed below.
Regarding our first recommendation on developing and documenting an
approach to program monitoring and oversight, the Director noted that
ONDCP has added more detail in the inter-agency agreement on the roles
and responsibilities of ONCDP and SAMHSA and created and implemented a
policy manual for the program, which was implemented in 2007. However,
our analysis of ONDCP's policy manual showed that it does not include
information on whether and how ONDCP will conduct oversight and
monitoring. The Director also stated that ONDCP has documentation of
minutes and activities that take place at their monthly interagency
management meetings. During our review, we repeatedly requested these
minutes but ONDCP officials said that no formal minutes were developed
or maintained and did not provide them. However, we have modified the
report to delete the statement that minutes were not available. We
continue to believe that this recommendation remains valid because,
without defined oversight activities for ensuring successful completion
of the work across all activities, ONDCP increases its risk that it
cannot provide reasonable assurance that required tasks are being
performed in accordance with its directives.
Concerning our second recommendation that ONDCP ensure that the
coalitions receiving an initial grant or a renewal grant satisfy all of
the statutory eligibility criteria for each fiscal year and that these
decisions are fully documented, the ONDCP Director noted that they have
taken steps to ensure that all renewal applicants are screened for
eligibility, consistent with our recommendation, and documentation
related to screening applicants is maintained in grant files. However,
the ONDCP Director took issue with our position that all statutory
eligibility requirements should be included on the screening sheets
used to document application reviews. The Director said that the
initial joint review by ONDCP and SAMHSA staff, combined with the
application review and scoring process conducted during peer reviews,
effectively ensure that applications recommended for funding meet
statutory eligibility requirements. However, we continue to maintain
that including all statutory eligibility requirements on the screening
sheets could increase ONDCP's assurance that all funded applicants are
statutorily eligible and that these decisions are fully documented.
Regarding the third recommendation on clearly defining roles and
responsibilities, the ONDCP Director noted that ONDCP plans to add
additional details to the inter-agency agreement on the role of the
Drug-Free Communities Support Program Administrator.
The ONDCP Director commented on some of the data we presented in this
report. Specifically, the Director expressed concern that we were
unable to accurately identify the number of applications for fiscal
years 2005 and fiscal years 2006, noting that ONDCP had provided us
with spreadsheets that identified the number of applications received
and their disposition. During our review, we worked continuously with
ONDCP officials in an effort to obtain accurate data on the number of
applications received. Nonetheless, we were unable to do so because,
despite our numerous attempts, we could not resolve inconsistencies in
the information ONDCP provided over the course of our review, causing
us to question its accuracy. However, we believe that the numbers we
present on grant applications are sufficient to illustrate orders of
magnitude. We revised our scope and methodology discussion in appendix
I to explain the efforts we took to obtain the most accurate
information available from ONDCP.
Moreover, the Director took issue with our presentation of ONDCP's data
in figure 4, which showed that ONDCP excluded approximately 190 initial
applicants in fiscal year 2005 from the possibility of being funded
without being screened for statutory eligibility. He indicated that by
doing so ONDCP would have incurred an unnecessary expenditure of
taxpayer dollars to review applications which fell below the funding
threshold (range of peer review scores for which applicants are awarded
funding). We agree that taxpayer dollars should not be expended
unnecessarily. However, we disagree that figure 4 conveys the point the
director is asserting; rather, our analysis of ONDCP's data shows that
some of these approximately 190 initial applicants had peer review
scores above the funding threshold and were excluded on the basis of
one or more of the other criteria in the separate screening process.
The Assistant Secretary for Legislation at HHS also commented on a
draft of this report. Specifically, he described actions that SAMSHA
has taken, in partnership with ONDCP, to strengthen internal controls
and management of the DFC grant program. For example, the Assistant
Secretary said that program information has been consolidated into the
SAMHSA Drug-Free Communities Support Program Operations Manual, SAMHSA
and ONDCP officials are meeting monthly to enhance inter-agency
coordination, and SAMHSA and ONDCP are currently jointly screening
applications for statutory eligibility and SAMHSA retains the screening
checklists.
As agreed with your offices, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days
from the date of this report. At that time, we will send copies of this
report to the Director of the Office of National Drug Control Policy,
the Secretary of the Department of Health and Human Services, the
Attorney General of the Department of Justice, and interested
congressional committees. We will also make copies to others upon
request. In addition, the report is available at no charge on GAO's Web
site at [hyperlink, http://www.gao.gov].
If you or your staff members have any questions regarding this report
or would like to discuss it further, please contact me at (202) 512-
6806 or by email at goldenkoffr@gao.gov. Contact points for our Office
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 V.
Signed by:
Robert N. Goldenkoff:
Director, Strategic Issues:
[End of section]
Appendix I: Scope and Methodology:
To examine the extent to which Office of National Drug Control Policy
(ONDCP) and the Substance Abuse and Mental Health Services
Administration (SAMHSA) conducted its screening and grant-related
activities for the Drug-Free Communities Support Program in accordance
with standards for internal control in the federal government,[Footnote
49] established laws, and leading practices for collaborating agencies,
we reviewed available program documents, including, but not limited to,
the Request for Applications funding announcements; the inter-agency
agreements between ONDCP and SAMHSA, and the documented outcomes of
specific review activities and recommendations for grant funding
decisions. We compared ONDCP's and SAMHSA's grant-related activities in
fiscal years 2005 through 2007 with criteria in GAO's Standards for
Internal Control in the Federal Government. These standards, issued
pursuant to the requirements of the Federal Managers' Financial
Integrity Act of 1982 (FMFIA), provide the overall framework for
establishing and maintaining internal control in the federal
government. Also pursuant to FMFIA, the Office of Management and Budget
(OMB) issued Circular A-123, revised December 21, 2004, to provide the
specific requirements for assessing the reporting on internal controls.
Internal controls and the definition of internal control in OMB
Circular A-123 are based on GAO's Standards for Internal Control in the
Federal Government. We also considered our prior work on results-
oriented government related to leading practices for federal
collaboration as well as leading practices for awarding grants.
[Footnote 50] In addition, we compared ONDCP and SAMHSA's grant related
activities in fiscal years 2005 through 2007 with statutory criteria
included in the Drug-Free Communities Act of 1997,[Footnote 51] the
Drug-Free Communities Support Program Reauthorization Act of 2001,
[Footnote 52] and the Office of National Drug Control Policy
Reauthorization Act of 2006.[Footnote 53] Further, to determine whether
ONDCP and SAMHSA had documented eligibility screening, we reviewed
grant applications for fiscal years 2005 and 2006. We did not review
all available applications because this was not practical. Instead, we
attempted to select probability samples of applications to review; this
would have allowed us to generalize the results to all of the fiscal
year 2005 and 2006 applications (about 990 and over 700, respectively,
for a total of about 1,690). However, because ONDCP and SAMHSA were
unable to provide accurate counts of the total numbers of applications
in either year, we were unable to do so. We made numerous attempts to
resolve inconsistencies in the information ONDCP provided over the
course of our review, which caused us to question its accuracy.
Consequently, we reviewed systematic random samples of available funded
and unfunded applications for these years.[Footnote 54] For fiscal year
2005, we reviewed 20 funded, initial applications and 21 funded,
renewal applications, 30 unfunded, initial applications, and 20
unfunded, renewal applications.[Footnote 55] For fiscal year 2006, we
reviewed 25 funded, initial applications and 10 unfunded, initial
applications. Although the applications we reviewed for both fiscal
years were randomly selected, because the applications were not
representative of all applications in either year we cannot generalize
the results to the larger populations of fiscal year 2005 or 2006
applicants. Even so, our review of these 126 grant applications
provided us with perspective on how ONDCP and SAMHSA handled these
applications. Additionally, because accurate counts of the total
numbers of applications in fiscal years 2005 and 2006 were not
available, we provide approximate numbers of applications to illustrate
orders of magnitude.
In addition to our review of documents and grant files described above,
we interviewed key staff at ONDCP and SAMHSA about how they conducted
and documented grant-related activities since 2006. While our
discussions with the agency officials from ONDCP and SAMHSA focused on
the agencies' review methods and funding decisions implemented in
fiscal years 2005 and 2006, we also obtained information for fiscal
year 2007 wherever possible to provide the most current information on
the program. We did not review the fiscal year 2008 grant-making
process because the process was underway during our review and the
results of the process were not yet available.
We conducted this performance audit from July 2006 through July 2008 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.
[End of section]
Appendix II: Timeline of Key Events for Drug-Free Communities Support
Program, Fiscal Year 2005:
This appendix presents a timeline of key events for the Drug-Free
Communities Support Program in fiscal year 2005.
Figure 5: Timeline of Key Events for Drug-Free Communities Support
Program, Fiscal Year 2005:
[See PDF for image]
Fiscal year: 2004;
October: ONDCP transfers Drug-Free Communities Support Program from
OJJDP to SAMHSA.
Fiscal year: 2005;
March-April: Initial and renewal applications due.
April-May: SAMHSA sends initial and renewal applications to peer
review.
May-July: SAMHSA receives peer review scores for all applications.
May: SAMHSA hires contractor to calculate 20 percent direct services
scores for renewal applications. ONDCP asks contractor to also
calculate scores for initial applications.
August: SAMHSA delivers to ONDCP 20 percent direct services scores for
all applications.
August: ONDCP has concerns about SAMHSA‘s screening process and whether
all applicants were screened for eligibility prior to SAMHSA sending
nearly all applications to peer review. ONDCP said SAMHSA could not
provide its screening sheets.
August: ONDCP implements its own screening process. ONDCP screens some
applications for statutory eligibility.
August: ONDCP announces its fiscal year 2005 grantees. More renewal
applicants were denied funding than in past years.
Fiscal year: 2006;
January: Renewal applicants that were denied funding raise concerns to
Congress about the fiscal year 2005 application review process and
funding decisions.
February-March: In response to applicants‘ concerns, ONDCP rechecks its
decisions for renewal applications that were denied funding. ONDCP
funds several of these applications.
Legend:
ONDCP: Office of National Drug Control Policy.
OJJDP: Office of Juvenile Justice and Delinquency Prevention.
SAMHSA: Substance Abuse and Mental Health Services Administration.
Source: Based on information provided to GAO by ONDCP and SAMHSA.
[End of figure]
[End of section]
Appendix III: Comments from the Office of National Drug Control Policy:
Executive Office Of The President:
Office Of National Drug Control Policy:
Washington, D.C. 20503:
July 11, 2008:
Mr. Gene L. Dodaro:
Acting Comptroller General:
Government Accountability Office:
411 G Street, NW:
Washington, DC 20548:
Dear Mr. Dodaro:
I have received and reviewed your draft report of the Drug Free
Communities (DFC) Support Program. While I appreciate the time and
energy your staff has put forth examining DFC, much has changed about
our oversight and management of this Program since GAO initiated its
inquiry two years ago. In reading the draft findings, I find that many
of the issues GAO identified that led to the challenges faced in FY2005
have long ago been corrected in our partnership with the Substance
Abuse and Mental Health Services Administration (SAMHSA).
GAO's draft document identifies three primary recommendations that the
examiners feel will help improve the internal controls and management
of the DFC program. I am pleased to share with you, as my staff has
done during frequent interaction with GAO staff over the last several
years, that ONDCP and SAMHSA have fully implemented changes that
resolve GAO's concerns as outlined in the report. Our responses to your
recommendations are as follows:
1. Monitor and Oversight Documentation - in the time since GAO began
its review of DFC, we have added extensive details about the roles and
responsibilities of both ONDCP and SAMHSA to our annual Interagency
Agreement (IAA) as a result of the lessons learned in the FY2005
process. Those details include specific job duties for Government
Project Officers and Grants Management Officers at SAMHSA as well as
more clearly defining the authority of the DFC Administrator at ONDCP.
Additionally, in partnership with SAMHSA we have created and
implemented a policy manual for the management of the program which was
implemented in FY2007 and provided to you during your review of DFC.
Additionally, we have documentation of the minutes and activities that
take place at our monthly interagency management meeting for DFC, and
can document changes to policy and practice that have resulted from
this increased collaboration.
2. Eligibility Requirements - as GAO learned during its review of DFC,
the start of the problems that occurred in the FY2005 process are
traced back to our inability to ensure that grant applications had been
screened for eligibility. It was for that reason that ONDCP conducted
the screening in FY05.
Since that time, ONDCP has taken progressive steps each year to ensure
that applicants are screened for eligibility and that screening
documentation remains in the SAMHSA master grant file, with a copy kept
in the control of the DFC Administrator at ONDCP. In addition to being
able to document the eligibility screening process used for FY2007 and
FY2008 new applicants, we are, consistent with your findings, now also
screening all Renewal Grant Applicants (non-competing in years 2-5 and
7-10 of the program) for eligibility. SAMHSA is maintaining
documentation of this screening in the SAMHSA master grant file.
3. Roles and Responsibilities - because we believe the role of
Administrator for DFC is clearly defined in the statute, we had not
previously restated that information or descriptive details in our
management documents with SAMHSA. As the result of your input, we will
add additional details as to the role of the Administrator to the
already expanded IAA descriptions for other key staff and for our two
agencies as a whole.
While I believe that ONDCP and SAMHSA have effectively addressed each
of the three recommendations GAO made in the report, we will continue
to look for ways to use this document to help strengthen those
oversights and management tools. Additionally, I need to correct and
clarify for the record several of the points you made in your document.
First, I am disturbed that you report in your findings that you were
unable to accurately identify the number of applications received by
the program in FY2005 and FY2006. ONDCP has provided GAO spreadsheets
from both of those years (and FY2007 as well) that clearly identify the
number of applications received and the disposition of each. We concur
with your finding that the FY2005 master grant files do not contain
evidence of the statutory eligibility screening process, which is why
ONDCP stepped in to take a more hands-on approach that year. While
ONDCP now provides clear and explicit instructions to SAMHSA with
regards to the management of the grant files, we began to manage
parallel documentation related to the new applicant eligibility
screening process at ONDCP beginning in FY2007 and each succeeding
cycle to ensure that the program complies with Congressional intent on
the issue of eligibility assurance. Consistent with GAO's findings,
ONDCP and SAMHSA have also begun screening all Renewal Grant
Applications (non-competing) beginning with the FY2008 cycle, and
SAMHSA is maintaining documentation of that effort in the master grant
files.
GAO also indicated in the report concerns about the eligibility sheets
used by ONDCP and SAMHSA to screen initial applicants for statutory
eligibility. As ONDCP staff outlined for GAO during the interview
process, ONDCP and SAMHSA have created a two-stage process that
combines the involvement of ONDCP and SAMHSA staff in the eligibility
review process, along with that of independent peer reviewers who are
doing drug prevention work in community coalitions across the country.
We believe that the initial joint review by ONDCP and SAMHSA staff,
combined with the application review and scoring process conducted
during the field review, effectively ensure that applications
recommended for funding meet the eligibility standards defined in the
Drug Free Communities Act.
Finally, as pertaining to the statutory eligibility process, GAO
appears to advocate in Figure 4 of the report that GAO believes ONDCP
and SAMHSA should have spent government resources reviewing the 190
grants that were not reviewed for statutory eligibility despite the
fact they fell well below the fundable score range for FY2005. I do not
believe it is prudent to expend tax dollars reviewing grants for
eligibility that have scored below the funding threshold and will not
receive a grant regardless of statutory eligibility.
I am very pleased with the progress we have made in the three funding
cycles since FY2005. We have not only improved our oversight of DFC, we
have also improved our support of our grantees' efforts to push back
against youth drug use in their communities. We have increased the
level of detail in our Interagency Agreements to assist both SAMHSA and
ONDCP in managing expectations and improving our management of the
program. Through our interagency workgroup we have developed and
implemented new policies and procedures to strengthen oversight and
improve effectiveness. While we have already implemented changes that
address the concerns outlined in this document, we will continue to
look for ways to reduce the government's risk while improving our
grantees' effectiveness, and will use your guidance in these efforts.
Sincerely,
Signed by:
John P. Walters:
Director:
[End of section]
Appendix IV: Comments from the Department of Health and Human Services:
Department Of Health And Human Services Office Of The Secretary:
Assistant Secretary for Legislation:
Washington, DC 20201:
July 17, 2008:
Robert N. Goldenkoff:
Director, Strategic Issues:
Government Accountability Office:
411 G Street, NW:
Washington, DC 20548:
Dear Mr. Goldenkoff:
Enclosed are the Department's comments on the U.S. Government
Accountability Office's (GAO) draft report entitled, "Drug-Free
Communities Support Program: Stronger Internal Controls and Other
Actions Needed to Better Manage the Grant-Making Process" (GAO 08-57).
The Department appreciates the opportunity to review and comment on
this report before its publication.
Sincerely,
Signed by:
Jennifer R. Luong, for:
Vincent J. Ventimiglia, Jr.
Assistant Secretary for Legislation:
Attachment:
General Comments For The Department Of Health And Human Services (HHS)
On The U.S. Government Accountability Office's (GAO) Draft Report
Entitled: "Drug-Free Communities Support Program: Stronger Internal
Controls And Other Actions Needed To Better Manage The Grant-Making
Process" (GAO 08-57):
The Department supports the Executive Office of the President, Office
of National Drug Control Policy (ONDCP) in their role as Drug Free
Communities (DFC) Program Administrator. DFC aligns with the clear
vision and mission that Substance Abuse and Mental Health Services
(SAMHSA) has established in supporting States, local agencies, and
individuals in building resilience and capacity for communities at risk
of substance abuse. DFC has become a cornerstone in our work in
communities across the nation. Both ONDCP and SAMHSA have worked
together to tightly manage the DFC grant program.
In responding to the GAO report, the Department is pleased to report
that significant progress continues to be made in cooperation with
ONDCP. SAMHSA has historically maintained internal controls that
include detailed policies and procedures for managing large grant
programs. This information was adapted to meet the special needs of the
DFC Program.
* Internal Controls for DFC Management: The DFC information is now
consolidated into the SAMHSA DFC Operations Manual. Content is updated
as ONDCP and SAMHSA work closely on key policy and program tools and
resources in order to effectively manage the DFC grant program. The
manual consists of a base document of roles and responsibilities for
ONDCP and across SAMHSA; a detailed annual grant work plan with
timelines; Inter-Agency Agreement and amendments; grant management
policy materials and tools; grant review materials and peer review
processes; program site visit and technical assistance protocols; and
Freedom of Information procedures for coordination with ONDCP.
* Inter-Agency Coordination: SAMHSA holds DFC policy management
meetings weekly in order to plan across SAMHSA, track Inter-Agency
Agreement deliverables for ONDCP, and address any barriers in
successfully completing the work. Participants are from key leadership
across SAMHSA. As the DFC Administrator, ONDCP participates in an
official joint meeting the first Monday of each month, makes
recommendations for agenda topics, and approves the meeting summary, an
official record of the meeting. ONDCP and SAMHSA's Center for Substance
Abuse Prevention also hold monthly program meetings with DFC program
managers and project officers and grant specialists.
* Statutory Eligibility Screening: SAMHSA and ONDCP now jointly screens
DFC standard applications for statutory eligibility and SAMHSA retains
the screening checklists in an agreed upon location. If an application
is funded, then the checklist is retained in their official grant file.
Unfunded applicant screening sheets are retained for 1 year by SAMHSA's
Office of Grant Review.
* Appeals Process for Grantee: ONDCP and SAMHSA have developed and
implemented a "Progressive Discipline and Appeals Process" that is
being widely disseminated to grant recipients. Through a Memorandum of
Understanding with the HHS Departmental Appeals Board, grant recipients
have appeals right for both grant suspensions and terminations, a
change in SAMHSA policy.
These steps are illustrative of strategies that have improved internal
controls and management of the DFC program within SAMHSA and in our
partnership with ONDCP.
[End of section]
Appendix V: GAO Contact and Staff Acknowledgments:
GAO Contact:
Robert N. Goldenkoff, (202) 512-6806 or goldenkoffr@gao.gov:
Staff Acknowledgments:
In addition to the contact named above, key contributors to this report
were Glenn G. Davis, Assistant Director, Lisa G. Shibata, David P.
Alexander, Duren Banks, Amy Bernstein, Randall J. Cole, Willie Commons
III, Daniel S. Kaneshiro, Alison Martin, Linda S. Miller, Jan B.
Montgomery, Raymond J. Rodriguez, and Adam Vogt.
[End of section]
Footnotes:
[1] National Institute on Drug Abuse, Monitoring the Future
(Washington, D.C.: 2007).
[2] Pub. L. No. 105-20, 111 Stat. 224, codified at 21 U.S.C. § 1521 et
seq.
[3] For purposes of this report, "initial" grant applicants refer to
those applying for year 1 or year 6 of funding or who have had a lapse
in their funding in the previous fiscal year. "Renewal" grant
applicants received funding in the previous year and are applying for 1
fiscal year of funding, either year 2-5 or year 7-10.
[4] The Office of National Drug Control Policy Reauthorization Act of
2006, Pub. L. No. 109-469, § 803, 120 Stat. 3502, 3535, authorized an
increase in the maximum amount of the grant award to $125,000 per
fiscal year; the maximum was previously $100,000. In fiscal year 2008,
ONDCP will begin awarding grants up to $125,000.
[5] 21 U.S.C. § 1532.
[6] 21 U.S.C. § 1531(d).
[7] The Advisory Commission is comprised of 11 members appointed by the
President.
[8] Given the growth of the program, the Advisory Commission
recommended the review.
[9] GAO, Standards for Internal Control in the Federal Government,
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO/AIMD-00-21.3.1]
(Washington, D.C.: Nov. 1999).
[10] GAO, Results Oriented Government Practices That Can Help Enhance
and Sustain Collaboration among Federal Agencies, [hyperlink,
http://www.gao.gov/cgi-bin/getrpt?GAO-06-15] (Washington, D.C.: Oct.
21, 2005).
[11] A systematic random sample is when the population is listed in
some order and every 10th grant application, for example, is selected
for the sample. A random start is used to select the initial element,
or starting point, for the sample.
[12] Pub. L. No. 97-255, 96 Stat. 814.
[13] [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-15].
[14] Pub. L. No. 105-20, 111 Stat. 224.
[15] Pub. L. No. 107-82, 115 Stat. 814.
[16] Pub. L. No. 109-469, 120 Stat. 3502.
[17] See fig. 2 for a summary of the program's statutory eligibility
criteria.
[18] An "eligible coalition" is defined as a coalition that meets the
applicable statutory eligibility criteria.
[19] [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-15].
[20] The other two criteria are described later in this report; see
table 1.
[21] For renewal grant applicants, 40 percent or more of funds could
not be used for direct services, whereas for initial grant applicants,
20 percent or more of funds could not be used for direct services.
[22] Since the Drug-Free Communities Support Program was established by
the Drug-Free Communities Act of 1997, Pub. L. No. 105-20, 111 Stat.
224, the program has been reauthorized by the Drug-Free Communities
Support Program Reauthorization Act of 2001, Pub. L. No. 107-82, 115
Stat. 814, and by the Office of National Drug Control Policy
Reauthorization Act of 2006, Pub. L. No. 109-469, 120 Stat. 3502.
[23] 21 U.S.C. § 1531(d).
[24] 21 U.S.C. §§ 1531(c), 1532(a).
[25] Prior to fiscal year 2008, grantees were eligible to receive up to
$100,000 per fiscal year. The Office of National Drug Control Policy
Reauthorization Act of 2006, Pub. L. No. 109-469, § 803, 120 Stat.
3502, 3535, authorized an increase in the maximum amount of the grant
award up to $125,000 per fiscal year. In fiscal year 2008, ONDCP will
begin awarding grants up to $125,000.
[26] The program's fiscal year 2007 funding announcement defines "in-
kind contributions" as the value of goods and services donated to the
operations of the coalition such as office space, volunteer secretarial
services, pro bono accounting services, or other personnel serving in a
volunteer capacity.
[27] For fiscal year 2005, ONDCP designated the applicants slightly
differently. "Initial grant applicants" were those applicants that
were: (1) not current Drug-Free Communities Support Program grantees,
(2) former grantees that had a lapse in funding in the previous year,
or (3) grantees applying for their sixth year of funding. ONDCP defined
those grant applicants that had received grants in the previous year,
but were not applying for their sixth year of funding as "competing
renewal" grant applicants. ONDCP also referred to "competing renewal"
grant applicants as "continuing" grant applicants. For purposes of this
report, we refer to grant applicants as "initial" or "renewal."
[28] ONDCP uses peer reviewers' ratings and any resulting
recommendations for advisory purposes.
[29] For fiscal year 2005, SAMHSA forwarded all but one grant
application to peer review without documenting that renewal grant
applicants were screened for statutory eligibility. After peer review,
ONDCP developed a screening process to determine which applications
would be screened for statutory eligibility and funded.
[30] GAO, Homeland Security: Contract Management and Oversight for
Visitor and Immigrant Status Program Need to Be Strengthened,
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-404] (Washington,
D.C.: July 10, 2006).
[31] H.R. Rep. No. 105-105, pt. 1, at 18 (1997).
[32] [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO/AIMD-00-21.3.1].
[33] Four of the five remaining project officers said that they
screened initial grant applicants for eligibility. The fifth project
officer did not recall whether she screened initial or renewal grant
applicants for eligibility.
[34] While ONDCP officials could not provide the eligibility screening
sheets, they did provide documentation on the results of their fiscal
year 2006 eligibility screening process.
[35] 21 U.S.C. §1532(a).
[36] We reviewed a total of 20 initial grantee applications for fiscal
year 2005, 1 of which did not contain an eligibility screening sheet.
[37] 21 U.S.C. § 1532(a)(4).
[38] 21 U.S.C. § 1532(a)(6)(A).
[39] 21 U.S.C. § 1532(a).
[40] We attempted to select probability samples of grant applications
to review; this would have allowed us to generalize the results to all
fiscal year 2005 and fiscal year 2006 grant applications. However,
because ONDCP and SAMHSA lacked documentation to provide accurate
counts of the total numbers of applications in either year, we were
unable to do so.
[41] [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-15].
[42] [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-15].
[43] H.R. Rep. No. 105-105, pt. 1, at 18 (1997).
[44] [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-404].
[45] [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO/AIMD-00-21.3.1].
[46] [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-15].
[47] Pub. L. No. 109-469, § 804, 102 Stat. 3502, 3535.
[48] According to ONDCP, all initial grant applicants were screened for
statutory eligibility in fiscal year 2007. However, it is beyond the
scope of our work to independently verify whether this has occurred and
been documented.
[49] GAO, Standards for Internal Control in the Federal Government,
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO/AIMD-00-21.3.1]
(Washington, D.C.: Nov. 1999).
[50] GAO, Results-Oriented Government: Practices That Can Help Enhance
and Sustain Collaboration among Federal Agencies, [hyperlink,
http://www.gao.gov/cgi-bin/getrpt?GAO-06-15] (Washington, D.C.: Oct.
21, 2005).
[51] Pub. L. No. 105-20, 111 Stat. 224.
[52] Pub. L. No. 107-82, 115 Stat. 814.
[53] Pub. L. No. 109-469, 120 Stat. 3502.
[54] A systematic random sample is when the population is listed in
some order and every kth element is selected for the sample (e.g.,
every 10th grant application). A random start is used to select the
initial element, or starting point, for the sample.
[55] Our methodology involved reviewing a minimum number of grant
application files. We reviewed additional files to enhance our sample.
[End of section]
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