Grants Management
EPA Needs to Strengthen Efforts to Provide the Public with Complete and Accurate Information on Grant Opportunities Gao ID: GAO-05-149R February 3, 2005The Environmental Protection Agency (EPA) has faced persistent challenges for many years in managing its grants, which constitute over one-half of the agency's budget, or about $4 billion annually. Among other things, EPA has been criticized for not always promoting competition in awarding grants, including not completely and accurately announcing grant opportunities to the public and potential applicants. One avenue EPA uses to inform the public about grant opportunities is the Catalog of Federal Domestic Assistance (CFDA), the federal government's listing of available grants and other federal funding opportunities. EPA's Office of Grants and Debarment (OGD), among other things, develops grants policy and guidance and compiles grant information for the CFDA. OGD has taken several steps to address criticism regarding the lack of complete and accurate information in the CFDA. In this context the Chairman, Senate Committee on Environment and Public Works, asked us to determine whether EPA is providing complete and accurate information on grant opportunities to the public in the CFDA.
EPA still does not consistently provide complete and accurate information on grant opportunities in the CFDA. Without complete and accurate information, potential applicants will not be fully informed about grant opportunities, and EPA may not have the broadest applicant pool from which to select grantees. Specifically, we found problems in the following areas: (1) funding priorities; (2) funding level estimates; and (3) miscellaneous CFDA program codes. OGD was not aware of the continuing problems with funding priorities and funding levels in the CFDA that we had identified until we brought them to its attention during our review. OGD has begun taking steps to correct the problems we identified. Although OGD had issued CFDA guidance in 2002 on providing complete and accurate information, it had not evaluated the effectiveness of this guidance and its procedures. Periodic evaluation of the effectiveness of guidance and procedures is necessary to ensure that information is complete and accurate. During the course of our review, we also identified inaccuracies in EPA's Integrated Grants Management System (IGMS), which OGD uses to generate reports about its grants to the public and the Congress. These inaccuracies could impair EPA's ability to completely and accurately inform the public and the Congress about its $4 billion annual investment in grants. OGD might have detected these problems if it had conducted a comprehensive review of the IGMS's data quality.
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-05-149R, Grants Management: EPA Needs to Strengthen Efforts to Provide the Public with Complete and Accurate Information on Grant Opportunities
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February 3, 2005:
The Honorable James M. Inhofe:
Chairman, Committee on Environment and Public Works:
United States Senate:
Subject: Grants Management: EPA Needs to Strengthen Efforts to Provide
the Public with Complete and Accurate Information on Grant
Opportunities:
Dear Mr. Chairman:
The Environmental Protection Agency (EPA) has faced persistent
challenges for many years in managing its grants, which constitute over
one-half of the agency's budget, or about $4 billion annually. Among
other things, EPA has been criticized for not always promoting
competition in awarding grants, including not completely and accurately
announcing grant opportunities to the public and potential applicants.
Informing the public about grant opportunities provides greater
assurance that EPA will receive proposals from a large and varied pool
of eligible and highly qualified applicants who otherwise might not
have known about grant opportunities. One avenue EPA uses to inform the
public about grant opportunities is the Catalog of Federal Domestic
Assistance (CFDA), the federal government's listing of available grants
and other federal funding opportunities (available at
www.CFDA.gov).[Footnote 1]
The CFDA provides the public and potential applicants with specific
information about grant opportunities. The CFDA identifies grant
programs by title and an identifying number, known as a CFDA program
code. Furthermore, EPA uses the CFDA to describe funding priorities--
that is, the specific major activities, projects, and/or programs that
EPA will fund for certain grant programs; these priorities can change
from year to year.[Footnote 2] EPA's segment of the CFDA provides
information on both discretionary and nondiscretionary grant programs.
Discretionary grants are those for which EPA has the legislative
authority to independently determine the recipients and funding levels.
Nondiscretionary grants are those that Congress directs to prospective
recipients who meet specific eligibility criteria; these grants are
often awarded to states on the basis of formulas prescribed by law or
agency regulation. Information on nondiscretionary grants is valuable
to the public and potential applicants because, in some cases, states
receive these grants and local officials can apply to their states for
funding from them.
EPA's Office of Grants and Debarment (OGD), among other things,
develops grants policy and guidance and compiles grant information for
the CFDA. OGD has taken several steps to address criticism regarding
the lack of complete and accurate information in the CFDA. Most
notably, OGD has revised its annual CFDA guidance to grant officials,
emphasizing the need to provide complete and accurate information on
grant opportunities.
In this context, you asked us to determine whether EPA is providing
complete and accurate information on grant opportunities to the public
in the CFDA. To respond to your request, we interviewed and obtained
policy, guidance, and other documents from OGD officials. We reviewed
EPA's descriptions of the 78 grant programs listed in the August 2004
CFDA to determine if the program descriptions identified funding
priorities and funding level estimates. Of these 78 programs, EPA
identified 68 as discretionary and 10 as nondiscretionary.[Footnote 3]
To verify the accuracy of the information in the CFDA, we obtained data
from EPA's Integrated Grants Management System (IGMS), a computer
database that OGD uses to manage and report on information about
grants; we also conducted a limited data reliability assessment of that
system. We reviewed Office of Management and Budget (OMB) Circulars A-
102 and A-110, which, among other things, lay out requirements for
announcing funding priorities for discretionary grant
programs.[Footnote 4] We also reviewed GAO and EPA Office of Inspector
General reports, the Senate Environment and Public Works majority staff
report,[Footnote 5] and EPA's response to the Senate report.[Footnote
6] We focused our review on EPA program funding priorities, funding
levels, and CFDA program codes in the August 2004 CFDA--the most
current version at the time of our review--because these elements had
been identified as incomplete and inaccurate in the past. We performed
our work from September 2004 through January 2005 in accordance with
generally accepted government auditing standards.
Results in Brief:
EPA still does not consistently provide complete and accurate
information on grant opportunities in the CFDA, according to our
analysis of the 78 grant programs listed in the August 2004 CFDA.
Without complete and accurate information, potential applicants will
not be fully informed about grant opportunities, and EPA may not have
the broadest applicant pool from which to select grantees.
Specifically, we found problems in the following areas:
Funding priorities. Sixty-two of the 68 discretionary grant programs
and all 10 nondiscretionary grant programs did not have clearly
identified fiscal year 2004 funding priorities in the August 2004 CFDA.
Without these priorities, potential applicants did not benefit from
knowing the specific activities, projects, and/or programs for which
funding was available in 2004, which could have influenced their
decision to apply. OGD did not clearly identify the funding priorities
primarily because, beginning in April of fiscal year 2004, it
systematically replaced priorities for 2004--which the public would
expect to find in the CFDA--with those for 2005. Adding to the
inaccuracy of the information presented, OGD did not always label the
fiscal year to which the priorities applied. OGD officials explained
that the replacement was inadvertent and noted that the 2004 funding
priorities were accurate from the start of the fiscal year until OGD
replaced them beginning in April 2004. We believe the problem occurred
in part because OGD's guidance does not require OGD to include and
clearly identify both the current and upcoming fiscal years' funding
priorities in the CFDA. In addition, funding priorities were not always
clearly identified because EPA program offices did not provide the
funding priority information to OGD. In these cases, OGD did not follow
its own guidance to ensure that program offices provided complete CFDA
program descriptions.
Funding level estimates. For fiscal year 2004, most CFDA program
descriptions included funding level estimates, but seven discretionary
grants did not. OGD guidance states that financial information must be
provided and that it should include funding level estimates. The lack
of complete funding information makes it difficult for potential
applicants to determine the level of funding available, which could
affect their decision to apply. In some of these seven cases, this
information was missing because program offices did not provide it to
OGD, and OGD took only limited action to obtain it. In other cases, OGD
did not designate a single program official to coordinate and develop a
funding estimate for grant programs involving multiple program offices;
as a result, no consolidated estimate was provided.
Miscellaneous CFDA program codes. EPA has created 31 more program-
specific codes, but it continues to list grant opportunities in broad,
miscellaneous codes. EPA has been criticized for this practice. The use
of these broad codes could make it difficult for potential applicants
to find information about specific grants, thereby making the CFDA less
useful. Placing these opportunities in more program-specific codes
would better inform the public and potential applicants.
OGD was not aware of the continuing problems with funding priorities
and funding levels in the CFDA that we had identified until we brought
them to its attention during our review. OGD has begun taking steps to
correct the problems we identified. Although OGD had issued CFDA
guidance in 2002 on providing complete and accurate information, it had
not evaluated the effectiveness of this guidance and its procedures.
Periodic evaluation of the effectiveness of guidance and procedures is
necessary to ensure that information is complete and accurate.
During the course of our review, we also identified inaccuracies in
EPA's IGMS, which OGD uses to generate reports about its grants to the
public and the Congress. These inaccuracies could impair EPA's ability
to completely and accurately inform the public and the Congress about
its $4 billion annual investment in grants. For example, we found
instances in which the IGMS incorrectly identified funding as being
awarded under one grant program when the funding should have been
identified as being awarded under another grant program. Consequently,
the information on funding levels was inaccurate for multiple programs-
-overstating the amount available in one program and understating it in
another. OGD might have detected these problems if it had conducted a
comprehensive review of the IGMS's data quality.
We are making recommendations to address EPA's continuing problems on
providing complete and accurate information to the public in the CFDA.
We are further recommending that EPA conduct a comprehensive,
systemwide data quality review of the IGMS.
Background:
The CFDA provides the public and potential applicants with specific
information about grant opportunities. EPA's segment of the CFDA Web
site had about 57,600 "hits" between July 2003 and October 2004. This
segment contains 78 grant programs, and for each of these grant
programs, EPA specifies its statutory authority, objectives, funding,
and contacts for further information, among other things. EPA also
requires information on funding priorities for discretionary grants in
the CFDA in order to comply with OMB Circulars A-102 and A-110. These
circulars require federal agencies to publicly announce funding
priorities for discretionary grants.
In 2001, EPA's Inspector General found that competition for
discretionary grants was lacking in part because information in the
CFDA was not complete and accurate.[Footnote 7] For example, EPA had
not always (1) identified each program's funding priorities and (2)
provided the funding levels available for each program. Furthermore,
the Inspector General found that EPA bundled a number of programs under
one CFDA program code, 66.606, "Surveys, Studies, Investigations, and
Special Purpose Grants," thus making it difficult to find information
about specific grant programs. In a 2003 report, we highlighted the
Inspector General's finding that EPA had not provided complete and
accurate information on its grants programs to the public in the
CFDA.[Footnote 8]
EPA has taken the following steps to address the Inspector General's
findings:
In 2002, EPA issued an order to promote competition by requiring that
certain discretionary grants be competed.[Footnote 9] The order
promoted the widespread announcement of grants and established
requirements for publishing funding opportunities in the CFDA.
Also in 2002, OGD revised its CFDA guidance to program offices, stating
that they must include annual funding priorities in the CFDA.[Footnote
10] OGD's April 2004 version of this guidance emphasized the need to
provide complete and accurate information on grant opportunities in the
CFDA.[Footnote 11] OGD guidance also stated that financial information
must be included and that it should include funding level estimates for
the 2004 fiscal year.
EPA incorporated into its 2003 grants management plan--which addresses
long-standing grants management challenges--the goal of promoting
competition by (1) providing guidance to EPA's program offices on how
to describe their programs and funding priorities in the CFDA, and (2)
expanding public awareness of EPA funding opportunities through
accurate and specific CFDA program descriptions to encourage a large
and diverse group of grant applicants.[Footnote 12]
EPA added 31 CFDA program codes to better identify grants with more
program-specific codes in the CFDA.
Most recently, in response to a 2004 report prepared by the Senate
Committee on Environment and Public Works' majority staff, EPA stated
in June 2004 that the agency had taken steps to resolve these problems.
To obtain information for the CFDA, OGD contacts EPA's program offices
in the spring and fall to obtain data on new and updated grant
programs. It collects most of this information in the first cycle,
which occurs between February and April. By collecting the upcoming
year's funding priorities about mid-way through the current fiscal
year, EPA announces priorities in advance so that potential applicants
can plan accordingly. During the second cycle, which occurs between
October and November, EPA asks program offices to identify funding
priorities only for new grant programs. OGD guidance requires each
program office's senior resource official to approve the upcoming
year's funding priorities and states that the official should submit
this approval by memorandum to the OGD Director.[Footnote 13] This
memorandum serves as the official agency record of each program
office's annual funding priorities. EPA's Office of the Chief Financial
Officer reviews funding level data.
According to OGD officials, they review each grant program description
to ensure that it is complete and accurate. OGD provides guidance that
OGD officials return information on funding priorities that is not
complete and accurate to the program office so that complete
information can be entered into the CFDA.
After these reviews, OGD submits the data to the General Services
Administration (GSA) for review. According to OGD officials, CFDA
analysts at GSA review the information and provide any comments to EPA.
GSA then submits each program description to OMB, whose budget
examiners review program funding levels and approve the information for
the CFDA. GSA then posts the information to the CFDA Web site.
EPA Still Does Not Consistently Provide Complete and Accurate
Information to the Public on Grant Opportunities:
According to our analysis of the August 2004 CFDA, EPA continues to
provide incomplete and inaccurate information on funding priorities and
on estimates of funding levels, and continues to obscure information by
placing certain grant programs in miscellaneous CFDA program codes.
Without complete and accurate information, potential applicants will
not be fully informed about grant opportunities, and EPA may not have
the broadest applicant pool from which to select grantees. OGD was not
aware of the continuing problems until we brought them to its attention
during our review because it has not evaluated the effectiveness of its
CFDA guidance and its implementation to ensure the accuracy and
completeness of the information in the CFDA.
EPA Does Not Consistently Provide Complete and Accurate Information on
Funding Priorities:
EPA listed 78 grant programs--68 discretionary and 10 nondiscretionary-
-in the August 2004 CFDA. (See the enclosure for a complete list of
these programs.) EPA did not provide complete and accurate information
on funding priorities for 62 of the 68 discretionary grants and for the
10 nondiscretionary grants for fiscal year 2004 that it listed in the
August 2004 CFDA, as table 1 shows. Without complete and accurate
funding priorities, potential grant applicants do not have information
on which program areas EPA's offices are considering for grant funding
and how applicable and useful their grant proposals would be. Publicly
announced priorities also help ensure that EPA will have a broader,
more diverse pool of qualified grant applicants from which to choose.
Table 1: EPA Grant Programs Lacking Clearly Identified Funding Priority
Information in the August 2004 CFDA for Fiscal Year 2004:
Grant type: Discretionary;
Number of grant programs: 68;
Number of grant programs lacking clearly identified funding
priorities: 62;
Number of grant programs with clearly identified funding priorities: 6.
Grant type: Nondiscretionary;
Number of grant programs: 10;
Number of grant programs lacking clearly identified funding
priorities: 10;
Number of grant programs with clearly identified funding priorities: 0.
Grant type: Total;
Number of grant programs: 78;
Number of grant programs lacking clearly identified funding
priorities: 72;
Number of grant programs with clearly identified funding priorities: 6.
Source: GAO analysis of CFDA data.
[End of table]
Three factors contributed to the lack of complete and accurate funding
priority information for fiscal year 2004 discretionary grants in the
August 2004 CFDA. First, for 47 of the 62 discretionary grant programs
lacking clearly identified funding priorities, OGD systematically
replaced the current year's funding priorities--which the public would
expect to find in the CFDA--with the upcoming fiscal year's priorities,
and did not identify the fiscal year to which these priorities applied.
Without this information, potential applicants did not know the major
project, activities and/or programs for which funding was available in
2004, which could have affected their decision to apply for a specific
grant. OGD began these replacements in April 2004, as the program
offices submitted their CFDA information for fiscal year 2005. OGD
officials told us this replacement was inadvertent. Although OGD
officials agreed that funding priorities were replaced beginning in
April 2004, they noted that funding priorities were complete and
accurate from October 2003 until they were replaced. This replacement
and labeling problem occurred in part because OGD's guidance does not
state that OGD must include and clearly identify the current and
upcoming fiscal years' priorities in the CFDA. We believe this problem
could be avoided in the future, and potential applicants could benefit,
if the guidance required OGD to provide and label such information for
both current and upcoming fiscal years.
Second, for 14 of the 62 discretionary grant programs, program offices
did not provide information on funding priorities, and OGD did not
return CFDA program descriptions that lacked funding priorities to
program offices, as specified in OGD's guidance. In some cases,
according to an EPA official, OGD sent follow-up e-mails and made
telephone inquiries to the program offices. But these efforts did not
result in complete information. Consequently, OGD submitted incomplete
information for these grant programs in the CFDA.
Third, for 1 of the 62 discretionary grant programs, the program office
provided the funding priority, but OGD mistakenly omitted the words
"funding priority" from the CFDA program description. As a result, the
public and potential applicants would find it difficult to identify
funding priority information in the CFDA for this grant program.
Funding priorities for all 10 nondiscretionary grants in fiscal year
2004 were also incomplete and inaccurate. As it had done with the
discretionary grants, OGD replaced the fiscal year 2004 funding
priorities with those for fiscal year 2005 beginning in April 2004 and
did not identify the fiscal year. OGD officials reiterated that funding
priority data were complete and accurate until they were replaced.
In addition, we found that, for five discretionary grant programs, two
program offices did not submit the memorandum, as the guidance states
they should, from the program offices' senior resource official
approving the fiscal year 2005 funding priorities. Consequently, OGD
listed these funding priorities in the CFDA without assurance that the
information was accurate. For example, EPA's Office of Air and
Radiation did not provide a memorandum for the funding priorities it
submitted to OGD for four grant programs. Although OGD's guidance
states that senior resource officials "must" approve funding
priorities, the guidance only states that the senior resource officials
"should" provide the memorandum to the OGD Director. However, OGD
officials confirmed to us that the memorandum was required and they
believed that OGD guidance may not be clear.
Finally, OGD's guidance only states that funding priorities must be
provided for discretionary grant programs, but according to OGD
officials, funding priorities are required for both discretionary and
nondiscretionary grant programs. While the guidance does not state this
requirement for nondiscretionary grants, these officials told us that
the program offices understood that they had to submit funding
priorities for nondiscretionary grants and did so.
EPA Does Not Consistently Provide Information on Funding Level
Estimates:
For fiscal year 2004, most CFDA program descriptions had funding
estimates, but EPA did not include estimated funding levels for 7 of
the 68 discretionary grants programs, as table 2 shows. OGD guidance
states that financial information must be provided and that it should
include funding level estimates. Without complete funding information,
potential applicants cannot determine the level of funding available,
which could affect their decision to apply.
Table 2: EPA Grant Programs with and without Fiscal Year 2004 Funding
Level Estimates in the August 2004 CFDA:
Grant type: Discretionary;
Number of grant programs: 68;
Number of grant programs without FY 2004 funding level estimates: 7;
Number of grant programs with FY 2004 funding level estimates: 61.
Grant type: Nondiscretionary;
Number of grant programs: 10;
Number of grant programs without FY 2004 funding level estimates: 0;
Number of grant programs with FY 2004 funding level estimates: 10.
Grant type: Total;
Number of grant programs: 78;
Number of grant programs without FY 2004 funding level estimates: 7;
Number of grant programs with FY 2004 funding level estimates: 71.
Source: GAO analysis of CFDA data.
[End of table]
Three of the seven program descriptions in the CFDA lacked complete
funding information because one program office failed to provide OGD
with the estimated funding levels, and OGD did not take the follow-up
action its guidance called for to obtain this information from the
program. The other four programs lacking funding estimates involved
multiple program offices. However, OGD did not designate a single
program official to serve as a focal point for reporting a consolidated
funding estimate to OGD, and therefore no such funding estimate was
presented in the CFDA.
EPA Has Created More Program-Specific Codes But Continues to Use
Miscellaneous Program Codes in the CFDA:
In 2001, EPA's Inspector General reported that EPA had inappropriately
placed program-specific grants under the miscellaneous CFDA program
code 66.606, entitled "Surveys, Studies, Investigations, and Special
Purpose Grants."[Footnote 14] By combining multiple grant programs
under one miscellaneous, nonspecific program code, EPA makes it
difficult for potential applicants to find information about specific
grants, thereby making the CFDA's information less useful.
In 2002, OGD issued guidance, which it updates annually, requesting
program offices to reduce their use of the 66.606 program code and
place grants in more program-specific CFDA program codes. To support
this effort, EPA created six new CFDA codes for "Surveys, Studies,
Investigations, and Special Purpose Grants": one each for Clean Air
(66.034), Safe Drinking Water (66.424), Clean Water (66.436), Office of
Research and Development (66.510), Office of Administrator (66.610),
and Educational Outreach (66.716). In addition, OGD officials told us
that they created another 25 CFDA program codes to better identify
grants with specific programs.
At the same time, OGD allowed existing 66.606 grants to continue under
this code until this grant funding ended. It also instructed program
offices to use the 66.606, program code--"Surveys, Studies,
Investigations, and Special Purpose Grants"--for both congressional
earmarks and for multi-media grants (i.e., those with more than one
statutory authority).
We are concerned by this action for two reasons. First, OGD officials
could provide no rationale for why congressional earmarks and multi-
media grants should be combined into one program code. The 66.606 CFDA
program code therefore continues to be a miscellaneous code. Second, it
is inaccurate to describe congressional earmarks only as "Surveys,
Studies, Investigations, and Special Purpose Grants"--a term that EPA
has traditionally applied to research or similar grants. According to
OGD officials, congressionally earmarked EPA grants are not limited to
research.
Moreover, in March 2004,[Footnote 15] we reported that between fiscal
years 1993 and 2003, EPA added grants to another broad miscellaneous
code--CFDA program code 66.500, "Consolidated Research Grants.'' By
combining research grants supporting multiple programs into one
miscellaneous nonspecific code, EPA obscures information about specific
programs, as it does with the use of the code 66.606.
OGD recognizes that it has a continuing problem with the use of
miscellaneous CFDA codes. Its 2004 CFDA guidance reiterated to program
offices that agency policy is to break up "overly-broad" CFDA program
descriptions, including the six codes it has used since 2002 to better
specify grants in the 66.606 program code. It has issued similar
guidance for the 66.500 program code in 2004.
EPA Has Not Evaluated the Accuracy and Completeness of the CFDA
Information:
OGD was not aware of continuing errors with funding priorities and
funding level estimates in the CFDA until we identified them during our
review, but it has begun taking steps to address them. Although OGD
issued new guidance in 2002 to address criticisms of the CFDA
information, OGD never evaluated the effectiveness of the guidance and
its implementation. Periodic evaluation of the effectiveness of
guidance and procedures is necessary to ensure that information is
complete and accurate. Such an evaluation could have alerted OGD
officials to the problems we identified on funding priorities and
funding levels in the CFDA and allowed them to take corrective actions.
EPA Has Not Conducted a Comprehensive Data Quality Review of the IGMS:
During the course of our review, we also identified inaccuracies in
EPA's Integrated Grants Management System (IGMS), which OGD uses to
generate reports on its grant programs to the public and the Congress.
The IGMS's inaccuracies could impair EPA's ability to accurately and
comprehensively inform the public and the Congress about its $4 billion
annual investment in grants.
According to OGD officials, since the IGMS and CFDA report on similar
information, the two sources should be consistent. We found, however,
that the CFDA and IGMS were not always consistent and that the
information extracted from the IGMS could be inaccurate. For example,
the IGMS information OGD officials provided to us listed the grant
program, State Grants to Reimburse Operators of Small Water Systems for
Training and Certification Costs (66.471), as having $5.3 million in
discretionary grant funds; the CFDA correctly listed this program as
nondiscretionary. When we brought this inconsistency to OGD's
attention, officials explained that they had incorrectly drawn
information from the IGMS,[Footnote 16] thereby incorrectly classifying
the program as discretionary.
We also found instances in which the IGMS incorrectly placed funding in
one grant program when the funding belonged in a different program. As
a result, the IGMS information on funding levels was inaccurate for a
number of programs. For example, according to the IGMS, the Air
Pollution Control Program Support grant program had about $471,000 in
discretionary grant funds and about $76 million in nondiscretionary
grant funds for fiscal year 2004. However, when we questioned this
allocation because of information in the CFDA to the contrary, OGD
found that the $471,000 in discretionary funding belonged in another
program. Thus, the IGMS incorrectly overstated funding for the air
pollution control support program by $471,000 and understated the
funding for another program by the same amount.
OGD officials acknowledged the problems with inaccurate funding data in
the IGMS. They said that in June 2004, after learning that project
officers were finding it difficult to link their grants to the
appropriate CFDA program codes in the IGMS, they instituted new IGMS
controls. OGD added a "dropdown" menu in the IGMS to help staff
accurately connect grants to CFDA codes. However, OGD did not correct
the data that had been inaccurately entered before June 2004.
OGD has never conducted a comprehensive, systemwide data quality review
of the IGMS, despite the importance of the database for reporting on
EPA's $4 billion annual investment in grants to the public and the
Congress. Furthermore, in 2002, EPA issued guidelines for ensuring the
quality of information.[Footnote 17] These guidelines state, among
other things, that the agency's offices assess existing data to verify
that they are of sufficient quantity and quality for their intended
use. OGD officials have not yet taken the steps identified in these
guidelines to ensure IGMS data quality.
Conclusions:
OGD has not resolved its long-standing problem of consistently
providing complete and accurate information to the public and potential
applicants on grant opportunities in the CFDA. While OGD has issued
guidance on gathering and presenting correct and accurate information
in the CFDA, we found weaknesses in the guidance and OGD's
implementation of it that contributed to the lack of accurate and
complete information in the CFDA. Without reviewing the effectiveness
of its guidance and implementation, OGD was unable to detect these
problems. Until OGD corrects these problems, it will not fully realize
its goal of promoting competition in awarding grants by providing
complete and accurate information to potential grant applicants.
Furthermore, OGD's IGMS contains inaccuracies that could impair EPA's
ability to inform the public and the Congress about its $4 billion
annual investment in grants. A comprehensive, systemwide data quality
review is necessary to ensure the accuracy of information reported to
the public and the Congress.
Recommendations for Executive Action:
To address EPA's continuing problems in consistently providing complete
and accurate information on grant opportunities to the public in the
CFDA, we recommend that the Administrator, EPA require the Director of
the Office of Grants and Debarment to:
* revise the agency's CFDA guidance to state that:
- both current and upcoming fiscal years' funding priorities be
provided and clearly identified for inclusion in the CFDA;
- information on funding priorities for both discretionary and
nondiscretionary grant programs be provided in the CFDA; and:
- senior resource officials provide a memorandum documenting approval
of program funding priorities;
* work closely with:
- program offices so that they always provide complete program
descriptions, including funding priorities and funding estimates; and:
- senior resource officials to ensure that they provide a memorandum
documenting approval of the program's funding priorities;
* continue to work on placing grant opportunities under program-
specific codes instead of under miscellaneous codes; and:
* periodically evaluate the effectiveness of CFDA guidance and its
implementation to ensure that the CFDA contains complete and accurate
information.
We further recommend that OGD conduct a comprehensive, systemwide data
quality review of the IGMS in order to ensure the accuracy of the
information reported from the database to the public and the Congress.
Agency Comments and Our Evaluation:
We provided a draft of this report to EPA for its review and comment.
The Director of EPA's Office of Grants and Debarment provided oral
comments. EPA generally agrees with the recommendations in our draft
report. EPA has formed a work group, which will consider the full range
of issues we identified regarding both the CFDA and the IGMS. However,
EPA did not want to revise its guidance to provide both current and
upcoming fiscal years' funding priorities in the CFDA. The Director
believes that OGD can best address GAO's concerns by keeping the
current year's funding priorities in the CFDA and announcing the
upcoming year's funding priorities--possibly later in the CFDA cycle--
when EPA can ensure their accuracy.
Although we believe that potential applicants would benefit from having
funding priorities announced in advance, we believe that announcing the
upcoming year's funding priorities when EPA can ensure their accuracy
would meet the intent of our recommendation. The Director is also
asking the work group to review various options for managing the entire
CFDA process, including when to list the upcoming fiscal year's funding
priorities in the CFDA. OGD also provided a number of technical
comments, which we incorporated as appropriate.
We will send copies of this report to the congressional committees with
jurisdiction over EPA and its activities; the Acting Administrator,
EPA; and the Director, Office of Management and Budget. In addition,
this report will be available at no charge on the GAO Web site at
http://www.gao.gov.
If you or your staff have any questions about this report or need
additional information, please contact me at (202) 512-3841. Key
contributors to this report were David Bobruff, Andrea Wamstad Brown,
Rebecca Shea, Carol Herrnstadt Shulman, Bruce Skud, and Amy Webbink.
Sincerely yours,
Signed by:
John B. Stephenson:
Director, Natural Resources and Environment:
Enclosure:
Enclosure:
EPA Grant Programs Listed in the CFDA:
Tables 3 and 4 present the Environmental Protection Agency's (EPA)
grant programs in the Catalog of Federal Domestic Assistance (CFDA) of
discretionary grants (which the CFDA refers to as project grants) and
nondiscretionary grants (which the CFDA refers to as formula grants),
respectively.
Table 3: EPA Discretionary Grant Programs in August 2004 CFDA:
CFDA program code: 66.001;
CFDA program title: Air Pollution Control Program Support.
CFDA program code: 66.032;
CFDA program title: State Indoor Radon Grants.
CFDA program code: 66.033;
CFDA program title: Ozone Transport .
CFDA program code: 66.034;
CFDA program title: Surveys Studies, Investigations Demonstrations and
Special Purpose Activities relating to the Clean Air Act.
CFDA program code: 66.305;
CFDA program title: Compliance Assistance-Support for Services to the
Regulated Community and Other Assistance Providers.
CFDA program code: 66.306;
CFDA program title: Environmental Justice Collaborative Problem-Solving
Grants Program.
CFDA program code: 66.418;
CFDA program title: Construction Grants for Wastewater Treatment Works.
CFDA program code: 66.424;
CFDA program title: Surveys, Studies, Demonstrations and Special
Purpose Grants - Section 1442 of the Safe Drinking Water Act.
CFDA program code: 66.436;
CFDA program title: Surveys, Studies, Investigations, Demonstrations,
and Training Grants and Cooperative Agreements - Section 104(B)(3) of
the Clean Water Act.
CFDA program code: 66.437;
CFDA program title: Long Island Sound Program.
CFDA program code: 66.439;
CFDA program title: Targeted Watershed Grants.
CFDA program code: 66.456;
CFDA program title: National Estuary Program.
CFDA program code: 66.461;
CFDA program title: Wetland Program Grants.
CFDA program code: 66.463;
CFDA program title: Water Quality Cooperative Agreements.
CFDA program code: 66.466;
CFDA program title: Chesapeake Bay Program.
CFDA program code: 66.467;
CFDA program title: Wastewater Operator Training Grant Program
(Technical Assistance).
CFDA program code: 66.469;
CFDA program title: Great Lakes Program.
CFDA program code: 66.472;
CFDA program title: Beach Monitoring and Notification Program
Implementation Grants.
CFDA program code: 66.473;
CFDA program title: Direct Implementation Tribal Cooperative
Agreements.
CFDA program code: 66.475;
CFDA program title: Gulf of Mexico Program.
CFDA program code: 66.476;
CFDA program title: Security Planning Grants For Large Drinking Water
Utilities.
CFDA program code: 66.477;
CFDA program title: Vulnerability Assessments and Related Security
Improvements at Large Privately-Owned Community Drinking Water
Utilities.
CFDA program code: 66.478;
CFDA program title: Water Security Training and Technical Assistance.
CFDA program code: 66.5;
CFDA program title: Environmental Protection - Consolidated Research.
CFDA program code: 66.508;
CFDA program title: Senior Environmental Employment Program.
CFDA program code: 66.509;
CFDA program title: Science to Achieve Results (STAR) Program.
CFDA program code: 66.51;
CFDA program title: Surveys, Studies, Investigations and Special
Purpose Grants within the Office of Research and Development.
CFDA program code: 66.511;
CFDA program title: Office of Research and Development Consolidated
Research.
CFDA program code: 66.513;
CFDA program title: Greater Research Opportunities Fellowship Program.
CFDA program code: 66.514;
CFDA program title: Science to Achieve Results (STAR) Fellowship
Program.
CFDA program code: 66.515;
CFDA program title: Greater Opportunities Research Program.
CFDA program code: 66.516;
CFDA program title: P3 Award: National Student Design Competition for
Sustainability.
CFDA program code: 66.6;
CFDA program title: Environmental Protection Consolidated Grants-
Program Support.
CFDA program code: 66.604;
CFDA program title: Environmental Justice Hazardous Substances Research
Small Grants to Community Groups.
CFDA program code: 66.605;
CFDA program title: Performance Partnership Grants.
CFDA program code: 66.606;
CFDA program title: Surveys, Studies, Investigations, and Special
Purpose Grants.
CFDA program code: 66.607;
CFDA program title: Training and Fellowships for the Environmental
Protection Agency.
CFDA program code: 66.608;
CFDA program title: Environmental Information Exchange Network Grant
Program.
CFDA program code: 66.609;
CFDA program title: Protection of Children and Older Adults (Elderly)
from Environmental Health Risks.
CFDA program code: 66.61;
CFDA program title: Surveys, Studies, Investigations and Special
Purpose Grants within the Office of the Administrator.
CFDA program code: 66.611;
CFDA program title: Environmental Policy and Innovation Grants.
CFDA program code: 66.7;
CFDA program title: Consolidated Pesticide Enforcement Cooperative
Agreements.
CFDA program code: 66.701;
CFDA program title: Toxic Substances Compliance Monitoring Cooperative
Agreements.
CFDA program code: 66.707;
CFDA program title: TSCA Title IV State Lead Grants Certification of
Lead-Based Paint Professionals.
CFDA program code: 66.708;
CFDA program title: Pollution Prevention Grants Program.
CFDA program code: 66.709;
CFDA program title: Capacity Building Grants and Cooperative Agreements
for States and Tribes.
CFDA program code: 66.714;
CFDA program title: Pesticide Environmental Stewardship - Regional
Grants .
CFDA program code: 66.715;
CFDA program title: Childhood Blood-Lead Screening and Lead Awareness
(Educational) Outreach for Indian Tribes.
CFDA program code: 66.716;
CFDA program title: Surveys, Studies, Investigations, Training
Demonstrations, and Educational Outreach.
CFDA program code: 66.717;
CFDA program title: Source Reduction Assistance.
CFDA program code: 66.802;
CFDA program title: Superfund State, Political Subdivision, and Indian
Tribe Site-Specific Cooperative Agreements.
CFDA program code: 66.804;
CFDA program title: State and Tribal Underground Storage Tanks Program.
CFDA program code: 66.805;
CFDA program title: Leaking Underground Storage Tank Trust Fund
Program.
CFDA program code: 66.806;
CFDA program title: Superfund Technical Assistance Grants (TAG) for
Community Groups at National Priority List (NPL) Sites.
CFDA program code: 66.808;
CFDA program title: Solid Waste Management Assistance.
CFDA program code: 66.809;
CFDA program title: Superfund State and Indian Tribe Core Program
Cooperative Agreements.
CFDA program code: 66.81;
CFDA program title: Chemical Emergency Preparedness and Prevention
(CEPP) Technical Assistance Grants Program.
CFDA program code: 66.812;
CFDA program title: Tribal Hazardous Waste Grants.
CFDA program code: 66.813;
CFDA program title: Alternative or Innovative Treatment Technology
Research, Demonstration, Training, and Hazardous Substance Research
Grants.
CFDA program code: 66.814;
CFDA program title: Brownfields Training, Research, and Technical
Assistance Grants and Cooperative Agreements.
CFDA program code: 66.815;
CFDA program title: Brownfield Job Training Cooperative Agreements.
CFDA program code: 66.816;
CFDA program title: Headquarter and Regional Underground Storage Tanks
Program.
CFDA program code: 66.817;
CFDA program title: State and Tribal Response Program Grants.
CFDA program code: 66.818;
CFDA program title: Brownfields Assessment and Cleanup Cooperative
Agreements.
CFDA program code: 66.926;
CFDA program title: Indian Environmental General Assistance Program
(GAP).
CFDA program code: 66.931;
CFDA program title: International Financial Assistance Projects
Sponsored by the Office of International Affairs.
CFDA program code: 66.95;
CFDA program title: Environmental Education and Training Program.
CFDA program code: 66.951;
CFDA program title: Environmental Education Grants.
Source: GAO analysis of CFDA data.
[End of table]
Table 4: EPA Nondiscretionary Grant Programs in August 2004 CFDA:
CFDA program code: 66.419;
CFDA program title: Water Pollution Control State and Interstate
Program Support.
CFDA program code: 66.432;
CFDA program title: State Public Water System Supervision.
CFDA program code: 66.433;
CFDA program title: State Underground Water Source Protection.
CFDA program code: 66.454;
CFDA program title: Water Quality Management Planning.
CFDA program code: 66.458;
CFDA program title: Capitalization Grants for Clean Water State
Revolving Fund.
CFDA program code: 66.46;
CFDA program title: Nonpoint Source Implementation Grants.
CFDA program code: 66.468;
CFDA program title: Capitalization Grants for Drinking Water State
Revolving Fund.
CFDA program code: 66.471;
CFDA program title: State Grants to Reimburse Operators of Small Water
Systems for Training and Certification Costs.
CFDA program code: 66.474;
CFDA program title: Water Protection Grants to the States .
CFDA program code: 66.801;
CFDA program title: Hazardous Waste Management State Program Support.
Source: GAO analysis of CFDA data.
[End of table]
(360507):
FOOTNOTES
[1] The General Services Administration and Office of Management and
Budget's CFDA is a governmentwide compendium of federal programs,
projects, and activities that provide assistance or benefits to the
American public. Assistance includes, but is not limited to, financial
assistance such as grants and cooperative agreements. For simplicity,
we are referring to grants and cooperative agreements as grants. EPA
uses other tools for announcing some grant programs, such as the
Federal Register, and all competitive funding opportunities are
announced on www.Grants.gov.
[2] EPA uses the CFDA to comply with an Office of Management and Budget
requirement that federal agencies announce funding priorities for
discretionary grants.
[3] The CFDA refers to discretionary grants as "project grants" and
nondiscretionary grants as "formula grants." In addition to these 78
grant programs, one EPA program provided technical assistance but no
funding.
[4] OMB Circular No. A-102, Grants and Cooperative Agreements with
State and Local Governments (10/7/94, as further amended 8/29/97); OMB
Circular No. A-110, Uniform Administrative Requirements for Grants and
Agreements with Institutions of Higher Education, Hospitals, and Other
Non-Profit Organizations (11/19/93, as further amended 9/30/99).
[5] Senate Environment and Public Works Committee Majority Staff,
Transparency in EPA Grants: Website Access to Available Grants and
Disclosure of Recipients (Washington, D.C.: May 13, 2004).
[6] U.S. Environmental Protection Agency, Associate Administrator,
Office of Congressional and Intergovernmental Relations,
correspondence to the Chairman, Senate Committee on Environment and
Public Works (Washington, D.C.: June 4, 2004).
[7] EPA Office of Inspector General, EPA's Competitive Practices for
Assistance Awards, Report No. 2001-P-00008 (Philadelphia, PA: May 21,
2001).
[8] GAO, Grants Management: EPA Needs to Strengthen Efforts to Address
Persistent Challenges, GAO-03-846 (Washington, D.C.: Aug. 29, 2003).
[9] The order applied to most discretionary grant programs or
individual grants of more than $75,000.
[10] EPA Office of Grants and Debarment, Memorandum: Preparation and
Submission of Catalog of Federal Domestic Assistance Program
Information for Update Cycle 2002, Mar. 3, 2002.
[11] EPA Office of Grants and Debarment, Memorandum: Preparation and
Submission of Catalog of Federal Domestic Assistance Program
Information for Basic Cycle 2004, Apr. 8, 2004.
[12] U.S. Environmental Protection Agency, Grants Management Plan:
2003-2008, EPA-216-R-03-001 (Washington, D.C.: Apr. 2003).
[13] Senior resource officials are typically deputy assistant
administrators in headquarters offices and assistant regional
administrators in regional offices, and are in charge of strengthening
agencywide fiscal resource management while also ensuring compliance
with laws and regulations.
[14] EPA Office of Inspector General, EPA's Competitive Practices for
Assistance Awards, Report No. 2001-P-00008 (Philadelphia, PA: May 21,
2001).
[15] GAO, Grants Management: EPA Needs to Better Document Its Decisions
for Choosing between Grants and Contracts, GAO-04-459 (Washington,
D.C.: Mar. 31, 2004).
[16] The IGMS does not label grant programs as discretionary or
nondiscretionary; instead OGD had to create definitions of
discretionary and nondiscretionary in order to sort the information in
the IGMS and extract it.
[17] U.S. Environmental Protection Agency Office of Environmental
Information, Guidelines for Ensuring and Maximizing the Quality,
Objectivity, Utility, and Integrity of Information Disseminated by the
Environmental Protection Agency, EPA/260R-02-008 (Oct. 2002).
