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United States Government Accountability Office: 
GAO: 

Report to Congressional Committees: 

July 2012: 

Justice Grant Programs:

DOJ Should Do More to Reduce the Risk of Unnecessary Duplication and 
Enhance Program Assessment:

GAO-12-517:

GAO Highlights:

Highlights of GAO-12-517, a report to congressional committees. 

Why GAO Did This Study:

Since fiscal year 2005, approximately $33 billion has been 
appropriated to DOJ for the administration of more than 200 federal 
financial assistance solicitations, such as grants, that support 
criminal justice activities at the state and local levels. Pursuant to 
section 21 of Public Law 111-139, this report addresses the extent to 
which (1) overlap exists across DOJ grant programs and if it 
contributes to the risk of unnecessary duplication in grant awards, 
(2) DOJ has taken steps to reduce overlap and the potential for 
unnecessary duplication in its grants awards, and (3) DOJ uses 
monitoring and assessment to determine grant program effectiveness and 
uses the results to enhance its grant programs. GAO assessed DOJ’s 
fiscal year 2010 announcements of grant award funding; categorized 
them according to key justice areas to identify any overlap; and 
interviewed DOJ officials about their grant making practices, systems, 
and assessment methods. Further, GAO interviewed officials from 11 
states receiving DOJ grants, selected for the levels and types of 
funding received.  Though not generalizable, the interviews provided 
their perspectives on funding. 

What GAO Found:

What GAO Found
The Department of Justice’s (DOJ) grant programs overlap across 10 
justice areas contributing to the risk of unnecessarily duplicative 
grant awards for the same or similar purposes.  For example, GAO 
reviewed all 253 grant award announcements that DOJ’s Office of 
Justice Programs (OJP), the Office on Violence Against Women (OVW), 
and the Community Oriented Policing Services (COPS) Office published 
on their websites for fiscal year 2010 and found overlap across the 
justice areas. For example, 56 of DOJ’s 253 grant solicitations—-or 
more than 20 percent-—were providing grant funds for victim assistance 
and related research.  GAO also found instances where applicants used 
the same or similar language to apply for funding from these 
overlapping programs. In one example, a grant recipient applied for, 
and received, funding from both OJP’s Internet Crimes Against Children 
program and the COPS Office’s Child Sexual Predator Program to provide 
training for cyber crime investigations and establish an Internet 
safety program.  In some instances, DOJ may deem it appropriate for 
distinct grant programs to serve one goal, or for one community or 
grantee to benefit from multiple streams of grant funding.  However, 
DOJ generally lacks visibility over the extent to which its grant 
programs overlap and thus is not positioned to minimize the risk of 
potential, unnecessary duplication before making grant awards. 

DOJ has taken some actions that address overlap in its grant programs; 
for example, by requesting statutory authorization in some instances 
to consolidate programs that are similar. However, DOJ has not 
conducted an assessment of its grant programs to systematically 
identify and reduce overlap. Doing so would enable DOJ to identify 
program areas where overlap may be desirable and where a consolidation 
of programs may be more efficient. Further, OJP and OVW use a separate 
grants management system than the COPS Office uses, limiting their 
ability to share information on the funding they have awarded or are 
preparing to award to a recipient. According to COPS Office officials, 
its mission and grant management processes are unique enough to 
necessitate a separate system. However, OJP officials told GAO that 
its system has been and can be modified with minimal investment to 
accommodate different grant processes. DOJ has initiated a study to 
assess the feasibility, costs, and benefits of unifying the systems 
among other options. By ensuring that such a study accounts for the 
effort necessary to harmonize departmental grant processes, DOJ could 
ensure that variations in such processes do not encumber system 
unification. 

DOJ’s Office of Audit, Assessment, and Management (OAAM) oversees 
monitoring of grantees’ compliance and conducts grant program 
assessments to gauge program effectiveness. GAO found that OAAM’s 
program assessments yield richer information than its monitoring 
reports because they identify improvement areas. OAAM officials 
believe additional assessments could be beneficial. They also said 
they lacked resources to conduct more, but had not conducted a 
feasibility analysis to confirm this. By OAAM examining its mix of 
monitoring and assessment activities, including the costs and benefits 
of current resource allocations, it could better ensure continuous 
improvement in grant programs. 

What GAO Recommends:

GAO recommends, among other things, that the department assess its 
grant programs for overlap, ensure its  comprehensive study of DOJ 
grant management systems also includes an analysis of steps necessary 
to harmonize business processes,  and examine its mix of grant 
monitoring and program assessment activities. DOJ agreed with GAO’s 
recommendations. 

View GAO-12-517. For more information, contact David C.Maurer at (202) 
512-9627 or maurerd@gao.gov. 

[End of section] 

Contents:

Letter:

Background:

DOJ Grant Programs Overlap, Contributing to the Risk of Unnecessarily 
Duplicative Grant Awards for the Same or Similar Purposes:

DOJ Has Taken Actions That Address Overlap in Grant Programs but Could 
Further Reduce the Risk of Unnecessary Duplication in Grant Funding:

DOJ Could Benefit from Examining Its Programmatic Grant Monitoring and 
Assessment Functions and Considering Expansion of OAAM's Authorities:

Conclusions:

Recommendations for Executive Action:

Agency Comments and Our Evaluation:

Appendix I: Objectives, Scope, and Methodology:

Appendix II: DOJ Granting Agencies' Organizational Structure:

Appendix III: Structure, Purpose, and Funding of DOJ Granting Agencies:

Appendix IV: Consolidated, Braided, and Blended Grant Program 
Solicitations:

Appendix V: Office of Audit Assessment and Management Structure:

Appendix VI: Comments from the Department of Justice:

Appendix VII: GAO Contact and Staff Acknowledgments:

Tables:

Table 1: Types and Examples of Federal Financial Assistance:

Table 2: Breakdown of Fiscal Year 2010 DOJ Grant Solicitations by 
Granting Agency and Justice Area:

Table 3: Consolidation and Coordination of DOJ Grant Programs and 
Illustrative Examples:

Table 4: Comparison of Programmatic Grant Monitoring and Program 
Assessment Activities:

Table 5: Comparison of OVW and OAAM Measurement of Grant Program 
Effectiveness:

Figures:

Figure 1: DOJ Grant Funding Appropriated from Fiscal Years 2005 
through 2012:

Figure 2: Grant Life Cycle of Federal Awarding Agency:

Figure 3. DOJ Grant and Subgrant Award Information Flow to 
USASpending.gov:

Figure 4: Consolidated Grant Programs:

Figure 5: Braided Grant Programs:

Figure 6: Blended Grant Programs:

Abbreviations:

BJA: Bureau of Justice Assistance:

BJS: Bureau of Justice Statistics:

CMS: COPS Management System:

COPS: Community Oriented Policing Services:

CSPP: Child Sexual Predator Program:

CTAS: Coordinated Tribal Assistance Solicitation:

DHS: Department of Homeland Security:

DOJ: Department of Justice:

FEMA: Federal Emergency Management Agency:

FFATA: Federal Funding Accountability and Transparency Act:

FMIS 2: Financial Management Information System 2:

GAT: Grant Assessment Tool:

GMS: Grants Management System:

GSA: General Services Administration:

ICAC: Internet Crimes Against Children:

IG: Inspector General:

JAG: Edward Byrne Memorial Justice Assistance Grant:

NIJ: National Institute of Justice:

OAAM: Office of Audit, Assessment, and Management:

OJJDP: Office of Juvenile Justice and Delinquency Prevention:

OJP: Office of Justice Programs:

OMB: Office of Management and Budget:

OVC: Office for Victims of Crime:

OVW: Office on Violence Against Women:

PAD: Program Assessment Division:

SAA: state administering agency:

VAWA: Violence Against Women Act:

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

July 12, 2012:

Congressional Committees:

Since fiscal year 2005, approximately $33 billion has been 
appropriated[Footnote 1] to support crime prevention, law enforcement, 
and crime victim services through more than 200 federal financial 
assistance programs that the U.S. Department of Justice (DOJ) manages. 
[Footnote 2] In fiscal year 2010, DOJ awarded nearly $3.6 billion in 
grants through its three granting agencies--the Office of Justice 
Programs (OJP), the Office on Violence Against Women (OVW), and the 
Community Oriented Policing Services (COPS) Office. Many of the grant 
programs that OJP, OVW, and the COPS Office administer are, pursuant 
to their originating statutes, similar in scope, and grant applicants 
can apply for and receive grant awards from more than one program. 
Moreover, statutes may also require that grant recipients award a 
portion of their grants to subgrantees. Where statutes do not require 
subgranting, a grantee may voluntarily choose to award all or a 
portion of its funds to subgrantees.[Footnote 3] These subgrantees may 
also apply directly to DOJ for funding through other grant programs 
for purposes that are the same or similar to the purpose for which 
they received the subgrant. The number of grant programs and 
recipients, and the billions of dollars in funds awarded annually, 
present administrative challenges for DOJ.

We have identified management of programs that support state and local 
crime reduction efforts as a major performance and accountability 
challenge for DOJ.[Footnote 4] We previously reported on evaluations 
of grant programs to assist communities in addressing gang problems, 
and the quality of DOJ's tool to measure grantees' performances under 
Recovery Act funding for one of OJP's largest grant programs.[Footnote 
5] Moreover, the DOJ Inspector General (IG) has listed grant 
management as one of the top 10 challenges for DOJ every year from 
2000 through 2011 and has identified overlap in grant programs and 
duplicative oversight and monitoring services. Specifically, a 2003 IG 
audit found overlap in grant programs between OJP and the COPS Office, 
which it noted resulted from statutes that created multiple grant 
programs to fund similar justice areas.[Footnote 6] The IG audit also 
found that no formal communication procedures between OJP and the COPS 
Office existed to ensure that grantees did not receive funds for 
similar purposes from both granting agencies and made recommendations 
to address this coordination issue as discussed later in this report. 
In addition, DOJ's Acting IG testified in June 2011 that certain 
monitoring and oversight performed by OVW and the COPS Office are 
duplicative of services that are available through OJP.[Footnote 7]

As the United States experiences budgetary constraints, there is an 
ever-increasing need to ensure that governmental resources--including 
those awarded through grants and subgrants--are appropriately targeted 
and that overlap and unnecessary duplication are mitigated. In 
February 2012, we reported that DOJ had not assessed its grant 
programs to identify overlap and that DOJ did not routinely coordinate 
grant awards to avoid unnecessary duplication.[Footnote 8] This report 
provides further elaboration on the February 2012 report's findings, 
as well as addresses DOJ's ability to assess the results of its grant 
programs.

To examine overlap and potential duplication within DOJ--and in 
support of our ongoing efforts to explore duplication, overlap, and 
fragmentation governmentwide[Footnote 9]--this report addresses the 
following three questions: (1) To what extent does overlap across DOJ 
grant programs exist and contribute to the risk of unnecessary 
duplication in grant awards? (2) To what extent has DOJ taken steps to 
reduce overlap in its grant programs and the potential for unnecessary 
duplication in grant awards? (3) To what extent does DOJ use grant 
monitoring and assessment to determine grant program effectiveness and 
use the results to enhance its grant programs?

Using the framework established in our prior work addressing overlap 
and duplication, we use the following definitions for purposes of 
assessing DOJ's grant programs:[Footnote 10]

* Overlap occurs when multiple granting agencies or grant programs 
have similar goals, engage in similar activities or strategies to 
achieve these goals, or target the same or similar beneficiaries. 
Overlap may result from statutory or other limitations beyond an 
agency's control.

* Duplication occurs on multiple levels. It occurs when a single 
grantee uses grant funds from different federal sources to pay for the 
exact same expenditure. Duplication also occurs when two or more 
granting agencies or grant programs engage in the same or similar 
activities or provide funding to support the same or similar services 
to the same beneficiaries. Duplication thus stems from overlap. When 
granting agencies do not identify overlap, assess its impact, or 
coordinate their activities in acknowledgment of the overlap, there is 
a heightened risk of unnecessary duplication because one granting 
agency may not be knowledgeable of the ways in which its funding 
decision duplicates another's. At times, federal funding is leveraged 
by design to achieve a single purpose through multiple federal funding 
streams. These funding arrangements are not characterized as 
unnecessary duplication for purposes of this review so long as federal 
agencies are aware of them or have deliberately planned for grant 
programs to be complementary.

To determine potential areas of overlap across DOJ's grant programs, 
we identified a total of 253 DOJ grant solicitations--announcements to 
applicants of funding opportunities--for fiscal year 2010 by reviewing 
the solicitation lists posted on the OJP, OVW, and COPS Office 
websites and confirming the accuracy of the information with DOJ 
officials. We established 10 categories of criminal justice areas and 
then sorted the solicitations into each category to determine whether 
these solicitations were announcing grant funding available for 
similar purposes. We developed these 10 categories after reviewing 
comparable justice areas identified within DOJ materials, such as a 
website it operates to discuss criminal justice research and strategic 
planning documents. After identifying solicitations with similar 
scopes, we reviewed a nonprobability sample of 26 successful grant 
applications that were awarded under similar solicitations to identify 
and assess specific examples of how the recipients planned to use 
funds from multiple programs in the same or similar manner and whether 
this creates the risk of unnecessary duplication in DOJ grant funding. 
The sample was selected based upon applicants receiving multiple grant 
awards from overlapping grant programs. The sample we reviewed is not 
generalizable to all DOJ grant programs because an ideal sample size 
based upon nearly 11,000 funded grant applications was impractical to 
select, review, and analyze. However, the results from our sample 
illustrate the potential for unnecessary duplication.

To examine the extent to which DOJ has taken action to reduce or 
mitigate overlap and ensure that DOJ does not unnecessarily award 
funds from multiple grant programs to support similar purposes, we 
analyzed agency policies, procedures, and guidance, current as of 
2012, on grant program design and award, such as the OJP Grant 
Manager's Manual. In addition, we interviewed DOJ officials from OJP, 
OVW, and the COPS Office to discuss, among other topics, their grant 
program design and award processes and the extent to which they 
coordinate and share information with one another. We also visited or 
conducted phone interviews with officials from 11 states to discuss 
the type and timeliness of information on grant awards and subawards 
that they provide to or receive from DOJ.[Footnote 11] We selected 
these states based on the amount of Edward Byrne Memorial Justice 
Assistance Grant (JAG) funding they receive and the existence of other 
recipients in their communities receiving DOJ discretionary grants for 
potentially similar purposes.[Footnote 12] The results of these 
contacts are not generalizable to all states, but provided insight 
into how DOJ grant funds were used locally and communication occurred 
between states and DOJ. We also compared agency grant design and award 
practices against Standards for Internal Control in the Federal 
Government and promising practices identified in the Domestic Working 
Group Grant Accountability Project's Guide to Opportunities for 
Improving Grant Accountability.[Footnote 13]

To analyze the extent to which DOJ uses grant monitoring and 
assessment to determine program effectiveness and uses the results to 
enhance its grant programs, we analyzed DOJ documentation, such as 
assessments DOJ conducted of its programs and specific programmatic 
grant monitoring reports.[Footnote 14] We also interviewed DOJ 
officials from the granting agencies, including those tasked with 
assessment, as well as grantees responsible for measuring the 
effectiveness of grant programs for OVW.

We conducted this performance audit from May 2011 to July 2012 in 
accordance with generally accepted government auditing standards. 
[Footnote 15] 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. Appendix I contains further information on our scope and 
methodology.

Background:

DOJ awards federal financial assistance to state and local 
governments, for-profit and nonprofit organizations, tribal 
jurisdictions, and educational institutions to help prevent crime, 
assist victims of crime, and promote innovative law enforcement 
efforts. Federal financial assistance can take the form of 
discretionary grants, formula grants, cooperative agreements, and 
payment programs, which all are generally referred to as grants. Grant 
programs are generally created by statute and funded through annual 
appropriations. As such, Congress has a central role in determining 
the scope and nature of federal financial assistance programs. In 
addition, the Office of Management and Budget (OMB) establishes 
general guidance which governs administration of all such federal 
financial assistance and DOJ has flexibility in how to administer 
assistance that is discretionary in nature.

In fiscal year 2010, DOJ provided direct grant funding to nearly 
11,000 grantees.[Footnote 16] Table 1 describes the various forms of 
federal financial assistance.

Table 1: Types and Examples of Federal Financial Assistance:

Types of assistance: Discretionary grant: Applicants generally compete 
for funding that agencies award at their discretion;  
Examples: Enhanced Collaborative Model to Combat Human Trafficking 
funds sites that use a comprehensive approach to combating all forms 
of trafficking--sex trafficking and labor trafficking of foreign 
nationals and U.S. citizens (male and female, adults and minors). 

Types of assistance: Formula grant: Recipients and award amounts are 
generally based on statutorily defined calculations that may 
incorporate a state's population and violent crime rate. Formula 
grants are usually administered and managed by state administering 
agencies. States use part of their grant to pass through their funds 
to local subrecipients. These subrecipients may be nonprofit 
organizations or other units of government. Formula grants can take 
the form of either block grants or categorical grants. Block grants 
are generally broad in scope and allow the states discretion in the 
use of the grant funds. Categorical grants are generally limited to 
more narrowly defined activities;  
Examples: Edward Byrne Memorial JAG State Grant Program supports all 
components of the criminal justice system, from multijurisdictional 
drug and gang task forces to crime prevention and domestic violence 
programs, courts, corrections, treatment, and justice information-
sharing initiatives. JAG-funded projects may address crime through the 
provision of services directly to individuals or communities and by 
improving the effectiveness and efficiency of criminal justice 
systems, processes, and procedures. 

Types of assistance: Cooperative agreements: Typically awarded at 
DOJ's discretion. According to OJP, a cooperative agreement is a legal 
instrument that permits DOJ to transfer money or something of value to 
accomplish a public purpose of support authorized by federal statute 
and used when substantial involvement of DOJ may be required in 
completion of the grantee's activity;  
Examples: Violence Against Women Act (VAWA) Measuring Effectiveness 
Initiative supports, among other things, the collection and 
documentation of performance information to measure the work of OVW 
grantees nationwide. 

Types of assistance: Payment programs: Provide recipients with funds 
for specific purposes. These are unique types of programs that provide 
funds for designated purposes and do not involve activities after the 
funding has been awarded;  
Examples: Southwest Border Prosecution Initiative reimburses state and 
local governments for their costs associated with the prosecution and 
pretrial detention of federally initiated criminal cases that are 
declined by U.S. Attorneys' offices and referred to state and local 
jurisdictions for prosecution. 

Source: GAO analysis of DOJ information. 

[End of table] 

DOJ administers its grant programs through three granting agencies-- 
OJP, OVW, and the COPS Office. Appendix II illustrates this 
organization. OJP is the largest of DOJ's granting agencies and in 
fiscal year 2011 had approximately $2.4 billion in funding for grants. 
Its mission to develop the nation's capacity to prevent and control 
crime, administer justice, and assist crime victims is broader than 
that of OVW or the COPS Office. For example, OJP's bureaus and offices 
administer grant programs that address victim assistance, technology 
and forensics, and juvenile justice, among other things. The COPS 
Office had approximately $495 million in funding for grants in fiscal 
year 2011, and its grant programs focus on advancing community 
policing. OVW had approximately $420 million for grant awards in 
fiscal year 2011. OVW administers grant programs related to domestic 
violence, dating violence, sexual assault, and stalking. Trends in 
amounts appropriated to these DOJ components since fiscal year 2005 
for grant funding are illustrated in figure 1. For additional 
information on the structure, purpose, and funding of DOJ granting 
agencies, see appendix III.

Figure 1: DOJ Grant Funding Appropriated from Fiscal Years 2005 
through 2012:

[Refer to PDF for image: multiple line graph] 

Fiscal year: 2005; 
OJP: $2.667 billion; 
COPS: $697 million; 
OVW: $382 million. 

Fiscal year: 2006; 
OJP: $2.679 billion; 
COPS: $562 million; 
OVW: $382 million. 

Fiscal year: 2007; 
OJP: $2.915 billion; 
COPS: $346 million; 
OVW: $359 million. 

Fiscal year: 2008; 
OJP: $2.372 billion; 
COPS: $685 million; 
OVW: $415 million. 

Fiscal year: 2009; 
OJP: $5.472 billion; 
COPS: $1.551 billion; 
OVW: $640 million. 

Fiscal year: 2010; 
OJP: $2.988 billion; 
COPS: $792 million; 
OVW: $419 million. 

Fiscal year: 2011; 
OJP: $2.403 billion; 
COPS: $495 million; 
OVW: $418 million. 

Fiscal year: 2012; 
OJP: $2.321 billion; 
COPS: $199 million; 
OVW: $413 million. 

Source: GAO analysis of DOJ data. 

Note: Funding levels in fiscal year 2009 include amounts appropriated 
through the American Recovery and Reinvestment Act of 2009. See Pub. 
L. No. 111-5, 123 Stat. 115, 129-30. These amounts do not reflect any 
applicable rescinded, reprogrammed, or transferred funding. 

[End of figure] 

The Grant Life Cycle:

The grants that OJP, OVW, and the COPS Office award generally follow a 
similar life cycle, including pre-award, award, implementation, and 
closeout stages, which is shown in figure 2.[Footnote 17]

Figure 2: Grant Life Cycle of Federal Awarding Agency:

[Refer to PDF for image: illustration] 

Stage: Preaward stage: 
Agency processes: 
Announce opportunity: 
* Provide administrative and technical support; 
Receive applications: 
* Authenticate applicant, apply business rules, and ensure 
administrative compliance; 
Review and decision: 
* Conduct reviews (administrative, budget, policy, merit, business, 
application, certifications, and assurances). 
  
Stage: Award stage; 
Agency process: Award notification; 
* Notify the grantee and publicly announce the award. 

Stage: Implementation stage; 
Agency processes: 
Disburse payment: 
* Process payments to grantee; 
Management and oversight: 
* Review grantee reports and may choose to conduct site visits. 

Stage: Closeout stage; 
Agency process: Closeout;  
* Review and reconcile final audit and other reports. 

Source: GAO. 

[End of figure]

In the pre-award phase for a competitive grant, the agency announces 
the grant opportunity with a grant solicitation, which notifies 
potential applicants of the grant's purpose, the terms of the award, 
the amount available, and the eligibility criteria, among other 
information. During the pre-award phase, the agency also receives and 
reviews applications and makes award decisions based on requirements 
set by statute and the grantor agency, as appropriate. Once the agency 
makes the award, it must report the grant information to 
USAspending.gov.[Footnote 18]

During the implementation stage, the agency is responsible for 
monitoring the grant. After the end date of a grant, the closeout 
process should ensure that each recipient has met all of the grant's 
financial requirements, returned any unused funds, and provided final 
reports. OJP and OVW use a web-based system--the Grants Management 
System (GMS)--to manage this process, while the COPS Office uses a 
separate COPS Management System (CMS), which is a desktop application 
that communicates with a centralized database. In our June 2011 report 
on the grant life cycle, we noted that effective internal control 
systems are important at each stage in the process.[Footnote 19]

Grant Monitoring and Assessment:

OJP, OVW, and the COPS Office are responsible for monitoring their 
grants to ensure that the grants are being implemented as intended and 
that grantees are compliant with statutory or regulatory requirements 
as well as any applicable policy guidelines. The granting agencies 
conduct programmatic grant monitoring by collecting information 
through telephone calls to grantees, file reviews of the documents and 
reports that grantees submit, and on-site visits to monitor grantees' 
activities at their locations. OJP's Office of the Chief Financial 
Officer provides fiscal policy guidance and financial monitoring of 
grantees for the three agencies. Financial monitoring generally 
consists of reviewing expenditures of grantees compared with their 
approved budgets and allowable grant expenditures, and reviewing 
compliance with grant requirements such as the submission of required 
grant reports.

In addition, pursuant to the Violence Against Women Act of 2000, the 
Attorney General reports biennially on the effectiveness of OVW 
grantee activities carried out with VAWA grant funds.[Footnote 20] To 
meet this requirement, OVW entered into a cooperative agreement with a 
university to develop and implement reporting tools to measure the 
effectiveness of projects and activities that OVW funds through its 
grants. In 2006, the Violence Against Women and Department of Justice 
Reauthorization Act of 2005, established an Office of Audit, 
Assessment, and Management (OAAM) within OJP and gave it statutory 
authority to provide additional oversight for OJP and the COPS Office 
programs, as well as any other DOJ grant program the Attorney General 
considers appropriate.[Footnote 21] DOJ's Acting Associate Attorney 
General approved the organizational structure of OAAM in 2007, the 
same year the office became operational and was staffed. The office 
was not fully staffed until 2009, but OJP reports that as of May 2012, 
its staff level is 20 percent below the office's authorized number of 
positions.

Currently, OAAM oversees OJP and the COPS Office granting activities. 
According to OJP, among its other activities, OAAM has the following 
four main responsibilities (see appendix V for more details):

1. ensures financial grant compliance and auditing of OJP's internal 
controls to prevent waste, fraud, and abuse;

2. conducts program assessments of OJP and COPS Office grant programs;

3. oversees programmatic monitoring activities of OJP and COPS Office; 
and:

4. serves as a central source for OJP grant management policy.

DOJ Grant Programs Overlap, Contributing to the Risk of Unnecessarily 
Duplicative Grant Awards for the Same or Similar Purposes:

DOJ's Grant Solicitations Overlap across 10 Key Justice Areas:

We reviewed all 253 of the fiscal year 2010 grant solicitations that 
OJP, OVW, and the COPS Office published on their respective websites 
and found overlap across 10 justice areas--as table 2 illustrates. 
These solicitations announced funding available to grantees for 
criminal and juvenile justice activities, including direct assistance 
for crime victims and the hiring of police officers. These 
solicitations also announced funding available for grantees to collect 
criminal justice data, conduct research, or provide related training 
and technical assistance.[Footnote 22] We developed these 10 
categories of justice areas after reviewing comparable justice areas 
identified within OJP's CrimeSolutions.gov website, which OJP 
officials stated covers a variety of justice topics, including some 
topic areas that OVW and the COPS Office fund; OJP's Fiscal Year 2010 
Program Plan; and other materials from OVW and the COPS Office, such 
as justice program themes from their respective websites. Within the 
justice areas, a variety of activities--including research, direct 
service provision, or technical assistance--can be conducted. We 
examined the purpose areas of the 253 grant solicitations and then 
categorized them by justice area.

In conducting this analysis, we recognize that overlapping grant 
programs across common programmatic areas result in part from 
authorizing statutes, and that overlap itself may not be problematic. 
However, the existence of overlapping grant programs is an indication 
that agencies should increase their visibility of where their funds 
are going and coordinate to ensure that any resulting duplication in 
grant award funding is purposeful rather than unnecessary. Overlap and 
the associated risk of unnecessary duplication occur throughout the 
government, as we have reported previously, and are not isolated to 
DOJ.[Footnote 23] However, when coupled with consistent programmatic 
coordination, the risk of unnecessary duplication can be diminished. 

Table 2: Breakdown of Fiscal Year 2010 DOJ Grant Solicitations by 
Granting Agency and Justice Area: 

Component/program office: COPS; 
Justice Area: 
Victim assistance: 0; 
Technology and forensics: $1; 
Juvenile justice: 0; 
Enhancing policing: $2; 
Justice information sharing: 0; 
Courts: 0; 
Community crime prevention strategies: $3; 
Mental illness, substance abuse, and crime: $1; 
Corrections, recidivism, and reentry: 0; 
Multi-purpose[A]: 0; 
Total: $7.

Component/program office: Joint[B]; 
Justice Area: 
Victim assistance: 0; 
Technology and forensics: 0; 
Juvenile justice: $1; 
Enhancing policing: 0; 
Justice information sharing: 0; 
Courts: 0; 
Community crime prevention strategies: 0; 
Mental illness, substance abuse, and crime: 0; 
Corrections, recidivism, and reentry: $2; 
Multi-purpose[A]: $3; 
Total: $6.

Component/program office: OVW; 
Justice Area: 
Victim assistance: $15; 
Technology and forensics: 0; 
Juvenile justice: 0; 
Enhancing policing: 0; 
Justice information sharing: 0; 
Courts: $1; 
Community crime prevention strategies: 0; 
Mental illness, substance abuse, and crime: 0; 
Corrections, recidivism, and reentry: 0; 
Multi-purpose[A]: $1; 
Total: $17.

Component/program office: OJP[C]; 
Justice Area: 
Victim assistance: [Empty]; 
Technology and forensics: [Empty]; 
Juvenile justice: [Empty]; 
Enhancing policing: [Empty]; 
Justice information sharing: [Empty]; 
Courts: [Empty]; 
Community crime prevention strategies: [Empty]; 
Mental illness, substance abuse, and crime: [Empty]; 
Corrections, recidivism, and reentry: [Empty]; 
Multi-purpose[A]: [Empty]; 
Total: [Empty].

Component/program office: BJA; 
Justice Area: 
Victim assistance: $2; 
Technology and forensics: $2; 
Juvenile justice: 0; 
Enhancing policing: $7; 
Justice information sharing: $3; 
Courts: $7; 
Community crime prevention strategies: $3; 
Mental illness, substance abuse, and crime: $6; 
Corrections, recidivism, and reentry: $7; 
Multi-purpose[A]: $5; 
Total: $42.

Component/program office: BJS; 
Justice Area: 
Victim assistance: $5; 
Technology and forensics: $2; 
Juvenile justice: $2; 
Enhancing policing: $3; 
Justice information sharing: $6; 
Courts: $4; 
Community crime prevention strategies: $1; 
Mental illness, substance abuse, and crime: $1; 
Corrections, recidivism, and reentry: $4; 
Multi-purpose[A]: $2; 
Total: $30.

Component/program office: CCDO[D]; 
Justice Area: 
Victim assistance: 0; 
Technology and forensics: 0; 
Juvenile justice: 0; 
Enhancing policing: 0; 
Justice information sharing: 0; 
Courts: 0; 
Community crime prevention strategies: $2; 
Mental illness, substance abuse, and crime: 0; 
Corrections, recidivism, and reentry: 0; 
Multi-purpose[A]: 0; 
Total: $2.

Component/program office: NIJ; 
Justice Area: 
Victim assistance: $3; 
Technology and forensics: $36; 
Juvenile justice: 0; 
Enhancing policing: $4; 
Justice information sharing: 0; 
Courts: $1; 
Community crime prevention strategies: $4; 
Mental illness, substance abuse, and crime: 0; 
Corrections, recidivism, and reentry: $5; 
Multi-purpose[A]: $8; 
Total: $61.

Component/program office: OJJDP; 
Justice Area: 
Victim assistance: $8; 
Technology and forensics: 0; 
Juvenile justice: $30; 
Enhancing policing: $7; 
Justice information sharing: $1; 
Courts: $8; 
Community crime prevention strategies: $4; 
Mental illness, substance abuse, and crime: 0; 
Corrections, recidivism, and reentry: 0; 
Multi-purpose[A]: $3; 
Total: $61.

Component/program office: OVC; 
Justice Area: 
Victim assistance: $23; 
Technology and forensics: 0; 
Juvenile justice: 0; 
Enhancing policing: 0; 
Justice information sharing: 0; 
Courts: 0; 
Community crime prevention strategies: 0; 
Mental illness, substance abuse, and crime: 0; 
Corrections, recidivism, and reentry: 0; 
Multi-purpose[A]: 0; 
Total: $23.

Component/program office: SMART; 
Justice Area: 
Victim assistance: 0; 
Technology and forensics: 0; 
Juvenile justice: 0; 
Enhancing policing: 0; 
Justice information sharing: $2; 
Courts: 0; 
Community crime prevention strategies: 0; 
Mental illness, substance abuse, and crime: 0; 
Corrections, recidivism, and reentry: $2; 
Multi-purpose[A]: 0; 
Total: $4.

Component/program office: Total solicitations; 
Justice Area: 
Victim assistance: $56; 
Technology and forensics: $41; 
Juvenile justice: $33; 
Enhancing policing: $23; 
Justice information sharing: $12; 
Courts: $21; 
Community crime prevention strategies: $17; 
Mental illness, substance abuse, and crime: $8; 
Corrections, recidivism, and reentry: $20; 
Multi-purpose[A]: $22; 
Total: $253.

Component/program office: Total award amount (in millions)[E]; 
Justice Area: 
Victim assistance: $872; 
Technology and forensics: $325; 
Juvenile justice: $264; 
Enhancing policing: $386; 
Justice information sharing: $98; 
Courts: $77; 
Community crime prevention strategies: $77; 
Mental illness, substance abuse, and crime: $53; 
Corrections, recidivism, and reentry: $430; 
Multi-purpose[A]: $810; 
Total: $3,393[F].

Source: GAO analysis of DOJ information.

Notes: Solicitations in this table reflect those for direct 
assistance, such as funds DOJ provides for the hiring of police 
officers, as well as those for research, data collection, and 
technical assistance on the related justice areas.

[A] Multipurpose solicitations were solicitations for grants that 
addressed more than one justice area within a single solicitation.

[B] Joint refers to solicitations issued jointly by multiple program 
offices, components, or departments (e.g., DOJ and the Department of 
Health and Human Services, or DOJ's Bureau of Justice Assistance and 
Office of Juvenile Justice and Delinquency Prevention).

[C] OJP is composed of a number of smaller bureaus and offices. BJA is 
the Bureau of Justice Assistance; BJS is the Bureau of Justice 
Statistics; CCDO is the Community Capacity Development Office; NIJ is 
the National Institute of Justice; OJJDP is the Office of Juvenile 
Justice and Delinquency Prevention; OVC is the Office for Victims of 
Crime; and SMART is the Sex Offender Sentencing, Monitoring, 
Apprehending, Registering, and Tracking Office.

[D] Federal funding reductions in fiscal year 2011 included CCDO's 
Weed and Seed Program. Without funding for this program, CCDO closed, 
and all remaining open, active CCDO grants were transferred to and are 
presently managed by BJA effective June 6, 2011.

[E] Actual amount awarded to grantees in millions. Total award amounts 
will not sum because of rounding.

[F] This amount excludes benefits paid through DOJ's Public Safety 
Officers' Benefits Program. 

[End of table] 

As table 2 illustrates, we found overlap across the various DOJ grant 
programs. For example, 56 of DOJ's 253 grant solicitations--or more 
than 20 percent--were providing grant funds available for activities 
related to victim assistance or to support the research and prevention 
of violence against women. Eighteen of these 56 programs were 
administered by offices other than OVW and OJP's Office for Victims of 
Crime.[Footnote 24] In addition, more than 50 percent of all grant 
solicitations provided funding that could be used in support of the 
same three justice areas--victim assistance, technology and forensics, 
and juvenile justice--indicating concentrated and overlapping efforts. 
The justice area with the least overlap was juvenile justice, with 30 
of 33 grant programs administered by the Office of Juvenile Justice 
and Delinquency Prevention.

There are some instances in which overlap occurs because of the 
statute that established programs. Further, we recognize that overlap 
among DOJ's grant programs may be desirable because such overlap can 
enable DOJ's granting agencies to leverage multiple funding streams to 
serve a single justice purpose. However, coordination across the 
administering granting agencies is critical for such leveraging to 
occur. In the section below, we discuss the ways in which overlapping 
grant programs increase the risk of unnecessarily duplicative grant 
awards for the same or similar purposes. In subsequent sections, we 
discuss the steps DOJ has taken to enhance coordination and some ways 
in which DOJ's efforts can be improved.

In Some Instances, DOJ Awarded Grant Funding from Overlapping Programs 
to the Same Applicants for the Same or Similar Purposes:

We found that in some instances, DOJ's granting agencies awarded 
multiple grants to the same grantees for the same or similar purposes. 
Applicants can apply directly to DOJ for funding through a variety of 
grant programs that DOJ announces annually. Recipients of such grant 
awards are referred to as prime grantees. Since many of DOJ's grant 
programs allow prime grantees to award subgrants, applicants also can 
apply directly to a prime grantee for award funding. As a result, 
prime grantees receiving money from DOJ through one funding stream 
also can be subgrantees receiving money from a prime grantee through 
another funding stream. If an applicant, either as a prime grantee or 
as a subgrantee, receives multiple grant awards from overlapping 
programs, the risk of unnecessary duplication increases since the 
applicant may receive funding from more than one source for the same 
or similar purpose without DOJ being aware that this situation exists. 
Such duplication may be unnecessary if, for example, the total funding 
received exceeds the applicant's need, or if neither granting agency 
was aware of the original funding decision.

After reviewing a sample of 26 grant applications from recipients who 
received funds from grant programs we identified as having similar 
purpose areas, we found instances where applicants used the same or 
similar language to apply for multiple streams of funding. For 
example, one grant recipient applied for funding to reduce child 
endangerment through cyber investigations from both the COPS Office's 
Child Sexual Predator (CSPP) Program[Footnote 25] and OJP's Internet 
Crimes Against Children (ICAC) program. In both of these applications, 
the applicant stated that it planned to use the grants to increase the 
number of investigations in the state, provide training for cyber 
crime investigations, serve as a forensic resource for the state, and 
establish an Internet safety program. Further, included in this 
applicant's proposed budgets for both funding streams were plans to 
purchase equipment, such as forensic computers and the same 
specialized software to investigate Internet crimes against children. 
Another grant recipient from a different jurisdiction also applied for 
funding from OJP and the COPS Office programs to support the same 
types of investigations. In a third instance, an applicant received 
fiscal year 2010 grant funding for planned sexual assault victim 
services from both OJP's Office for Victims of Crime and OVW. The 
applicant used similar language in both applications, noting that it 
intended to use the funding to support child victim services through 
its child advocacy center.

After we shared these examples with DOJ, DOJ officials followed up 
with the grant recipients involved and reported to us that the 
grantees were not using awarded funds for duplicative purposes--which 
DOJ defines as grantees using funds to pay for the exact same item. 
However, such follow-up for the purpose of assessing duplication is 
not a routine practice for DOJ. Further, DOJ's narrow definition of 
duplication curtails it from assessing the use of funds for the same 
or a similar overall purpose on a grant project.

In fiscal year 2010, DOJ's three granting agencies awarded nearly 
11,000 prime grant awards,[Footnote 26] but officials told us that 
they do not consider the flow of grant funds to subgrantees when 
making grant award decisions.[Footnote 27] Because DOJ does not have 
visibility of the flow of funds to these recipients, agency officials 
were not positioned to tell us what activities, or for what purposes, 
the subgrantees were spending their federal funds. Thus, to obtain 
more information, we surveyed JAG SAAs, who are responsible for 
managing the subgrants they make, to obtain information related to the 
purpose areas of their funding.[Footnote 28]

In our survey, we asked the JAG SAAs if they or their subgrantees used 
grant funding in fiscal year 2010 for key justice areas such as 
funding sex offender registry notification systems; correctional 
officer salaries, and sexual assault services; purchasing bullet-
resistant vests; and hiring police officers. DOJ supports all of these 
areas through JAG, as well as through targeted grant programs 
specifically addressing each of these topics. On the basis of survey 
responses, we found several instances where SAAs reported that JAG 
funds were used to support activities that could have been funded 
through other DOJ grants. For instance, 11 of 50 responding SAAs, or 
22 percent, reported that they or their subgrantees used JAG funding 
to support correctional officer salaries. Further, 23 of the 50 SAAs, 
or nearly 50 percent, reported that they or their subgrantees used JAG 
funding to hire police officers, even though a separate DOJ program 
dedicates funding exclusively to hiring law enforcement personnel. 
[Footnote 29]

The survey results indicate an increased risk of DOJ funding 
unnecessarily duplicative grant awards. If DOJ were aware that an 
applicant had received JAG funding through a subgrant to conduct 
community policing patrols, DOJ would be better positioned to decide 
whether that applicant should receive additional funding as a prime 
grantee from its community policing discretionary grant program. The 
results from our site visits confirmed this heightened risk. For 
example, in one state we visited, a county had received a JAG program 
subaward and used the funding for its officers to conduct community 
policing. The same county also received a COPS Office hiring grant and 
used the funding for an officer to conduct community policing. 
[Footnote 30] Additionally, the largest city in this county received a 
COPS Office hiring grant to conduct community policing. Because this 
city received the COPS Office funding to conduct community policing 
and grant-supported officers conducted patrols in geographical areas 
that overlapped with areas in the county already served by JAG-funded 
police officers, three DOJ grant awards were used to provide community 
policing to overlapping areas in the county. During the course of our 
audit work, COPS Office officials told us that community policing is 
not an activity but rather a philosophy for how policing should be 
conducted. As such, the officials consider multiple awards to the same 
communities to be complimentary. Since the COPS Office does not 
routinely consider the variety of federal funding that current and 
prospective grantees already use or may soon benefit from before 
making grant award decisions, they are not positioned to determine 
whether such funding arrangements are complementary. Further, 
officials from two additional counties in this state told us they 
received funding for drug court-assisted substance abuse treatment and 
mental health counseling through both a JAG program subaward and a 
grant directly from OJP's Adult Drug Court Grant Program. Officials 
from one of these counties informed us that they received so much DOJ 
funding from the two grant programs that it exceeded the county's need 
and they planned to return a portion to DOJ.[Footnote 31]

The IG has previously identified the risk of OJP and the COPS Office 
funding duplicative grant awards. For example, in 2003, the IG 
identified duplication between the COPS Office Hiring Program and the 
Local Law Enforcement Block Grant Program, the predecessor to the JAG 
grant program. The IG reported that while the COPS Hiring Grant 
program is required to advance community policing, the Local Law 
Enforcement Block Grant Program grants are sometimes used for the same 
or similar purposes. According to the IG, in such cases the grants are 
duplicative.[Footnote 32] In 2010, the IG reported that it had 
identified potential overlap between the COPS Office Hiring Recovery 
Program and OJP's JAG Formula Program and Edward Byrne Competitive 
Grant Program. As a result, the IG recommended that the COPS Office 
work with OJP to avoid duplication of future funding by coordinating 
closely on grantee selection decisions, as discussed later in this 
report.[Footnote 33]

DOJ Has Taken Actions That Address Overlap in Grant Programs but Could 
Further Reduce the Risk of Unnecessary Duplication in Grant Funding:

DOJ Has Taken Some Action to Consolidate and Coordinate Similar Grant 
Programs:

According to DOJ officials, the statutory creation of grant programs 
with similar purposes requires grant design coordination within and 
among DOJ's granting agencies to limit the risk of unnecessary 
duplication from overlapping programs. The primary purpose of 
consolidation or coordination may not be to limit this risk, but 
officials reported that reducing the risk may be a secondary benefit. 
Officials from all three granting agencies stated that they meet with 
one another to coordinate the goals and objectives of their grant 
programs, especially joint grant programs that they believe are 
complementary. For example, the Bureau of Justice Assistance and the 
Office for Victims of Crime issued a joint solicitation for anti-human 
trafficking programs where each office issued separate awards based on 
coordinated proposals from collaborating police departments and 
community-based victim service organizations. Further, according to 
officials, DOJ recently launched the Coordinated Tribal Assistance 
Solicitation to provide a single application for most of DOJ's tribal 
grant programs.

Consolidating two programs with similar purposes into one, with 
unified management, is the most comprehensive way to reduce overlap, 
according to DOJ officials. However, they stated that the statutory 
creation of grant programs with similar purposes can create 
administrative challenges because in many cases, DOJ must seek 
statutory authorization to discontinue or consolidate enacted programs 
that DOJ believes may be overlapping. Officials told us they have 
sought congressional action in a few instances for these purposes and 
will continue to do so, but because the process is complex, they have 
also taken administrative steps on an ad hoc basis to mitigate overlap 
of purpose areas as illustrated in table 3.

Table 3: Consolidation and Coordination of DOJ Grant Programs and 
Illustrative Examples:

Consolidation: Statutory authority is generally required to merge two 
or more existing grant programs. Once programs have been consolidated, 
a single DOJ office announces and manages the newly merged grant 
program; 
* In accordance with DOJ's fiscal year 2012 appropriations act, OVW 
will consolidate four existing youth victim-oriented grant programs 
into a single program.[A] By creating one solicitation, an OVW 
official reported that the grant application process may be 
streamlined, and cost efficiencies related to reviewing applications 
may be achieved (see appendix IV for more details). 

Coordination: Congressional action is not required, and officials 
explained two approaches they have taken to improve coordination. The 
first approach is "blending," whereby DOJ coordinates grant management 
from within a single office while keeping funding streams from 
separate appropriations distinct. The second approach is "braiding," 
whereby DOJ continues to manage the programs through separate offices 
and separate funding streams but issues a single grant announcement; 
* OJJDP coordinated 9 of its youth grant programs to create 1 grant 
program known as SafeFutures. The program assisted recipients and 
communities through a single program (see appendix IV for more 
details); 
* In fiscal year 2010, DOJ coordinated several of its tribal grant 
programs to create the Coordinated Tribal Assistance Solicitation 
(CTAS), which involves OJP's, OVW's, and the COPS Office's tribal 
grant programs. The CTAS program combined 10 DOJ tribal grant program 
solicitations into 1 for purposes of streamlining the application and 
selection process, and OJP officials reported reducing the 
administrative burden on its applicants as a result. These programs 
continue to be managed by separate DOJ bureaus and offices (see 
appendix IV for more details). 

Source: GAO analysis of DOJ information.

[A] See Pub. L. No. 112-55, Div. B, 125 Stat. 552, 612-13 (2011). 

[End of table] 

Officials stated that they meet with one another when they determine 
it is needed to coordinate the goals and objectives of their grant 
programs, especially those programs that they believe are 
complementary. In addition, an OJP official told us that in 2010 the 
office prioritized coordination as 1 of its 10 management goals and 
cited benefits that resulted from this focus, including reduced 
administrative costs, fewer grant solicitations, and a reduced number 
of competitive grant peer reviews. However, these officials told us 
that these coordination and consolidation efforts, as well as those 
illustrated in table 3, do not occur routinely.

DOJ Has Not Assessed Its Grant Programs to Identify and Reduce Overlap:

Even with efforts to coordinate its programs, DOJ officials told us 
they have not conducted a formal assessment or study of their grant 
programs to determine if and to what extent they overlap and where 
opportunities exist to more consistently pursue consolidation or 
better coordinate grant programs. Further, we found that coordination 
among granting agencies occurred on an ad hoc basis and that without 
an assessment of its overlapping programs, DOJ was not well positioned 
to identify and describe areas of potential for unnecessary 
duplication across its grant programs.

A senior OJP official told us that the department had not formally 
assessed or studied its grant programs to determine the extent of 
overlap because of the significant investment of time and staff 
resources that it would require. DOJ officials emphasized that since 
these programs were statutorily established as distinct programs, they 
are not certain that any attempt at harmonization--beyond what they 
have already done--would be viable. For example, they said that in 
some cases, statutes creating what may appear to be similar programs 
also create very different eligibility criteria for grant applicants. 
Thus, the officials stated, some programs may not be easily merged 
through administrative efforts such as announcing similar grant 
programs in a single solicitation. We agree that similar grant 
programs may have unique features that could render grant 
consolidation or coordination impractical, but DOJ has not taken the 
steps to catalogue all of its programs across each of the three 
granting agencies, and then determine which have the potential to be 
consolidated or coordinated and what barriers might exist to achieve 
such changes.

The IG continues to include DOJ's grants management among its list of 
top challenges affecting the department, and in previous reports, has 
identified fragmentation and duplication among DOJ's granting agencies 
as an area of concern. Further, developing agency procedures to avoid 
grant duplication is one of the promising practices that the federal 
Domestic Working Group Grant Accountability Project suggested in its 
Guide to Opportunities for Improving Grant Accountability.[Footnote 
34] Given the specific knowledge of these grant programs' statutory 
authorities, their histories of funding certain types of activities, 
and the nuances related to their administration, officials within OJP, 
OVW, and the COPS Office are uniquely positioned to assess their 
programs for overlap. Doing so could yield positive dividends for the 
granting agencies and the department over the longer term. 
Specifically, such assessments could include understanding the areas 
in which individual granting agencies may be awarding funds for the 
same or similar purposes, determining whether these grant programs 
appropriately channel the department's resources across the justice 
areas it funds, and determining whether any existing overlap is 
desirable. By conducting an assessment of its grant programs of this 
kind, DOJ would be better positioned to take action, such as through 
consolidation and coordination of its programs, in a more systematic 
way to limit overlap and mitigate the risk of unnecessary duplication.

DOJ's Granting Agencies Do Not Have Policies and Procedures to Ensure 
Coordination to Limit the Risk of Unnecessary Duplication:

OJP, OVW, and the COPS Office do not routinely share lists of current 
and potential awardees to consider both the current and planned 
dispersion and purposes of all DOJ grant funding before finalizing new 
award decisions. Not having routine coordination in the pre-award 
phase limits each of DOJ's granting agencies' visibility of the funds 
each respectively awards rather than to the overall flow of department 
dollars. Thus, in the instances where DOJ made multiple grant awards 
to applicants for the same or similar purposes, officials made these 
awards without always being aware of the potential for unnecessary 
duplication or whether funding from multiple streams was warranted. 
DOJ officials stated that their annual process to formulate budgets 
for grant administration, OJP's annual planning process to develop 
solicitations, and the department's overall grant oversight functions 
address the risks of unnecessary duplication in grant awards. However, 
these activities do not specifically relate to the pre-award phase 
when any potential for unnecessary duplication can best be avoided. 
DOJ officials also stated that they meet bi-monthly to discuss 
grantees on DOJ's High Risk List to avoid funding grantees who in the 
past have demonstrated deficiencies in properly managing their federal 
awards.[Footnote 35] However, the purpose of these discussions is not 
to prevent or reduce duplication. Developing agency policies and 
procedures to avoid unnecessary grant duplication in the awarding of 
funds is one of the promising practices that the federal Domestic 
Working Group Grant Accountability Project suggested in its Guide to 
Opportunities for Improving Grant Accountability.

As a result of our work, OJP officials informed us that as of March 
2012, they had begun to pilot solicitation language in two of its 
grant programs requiring grant applicants to disclose any pending 
applications submitted in the last 12 months for other federally 
funded assistance to support the same costs associated with the same 
projects outlined in applicants' budgets. Additionally, officials 
stated they are currently developing a grant special condition for all 
fiscal year 2012 grant awards that would require grantees to report to 
OJP if they receive any funding for a specific project cost that is 
duplicative of the funding OJP provides.[Footnote 36] OJP officials 
told us that if grantees report duplicative funding for a specific 
project cost, OJP staff will work with the grantees to ensure return 
of the OJP funds. We believe this requirement will improve OJP's 
ability to limit the risks of duplicative funding for single items; 
however, OJP continues to take a more narrow view of the term 
"duplication." OJP defines duplicative funding to include only 
instances where grantees are using federal money for the same exact 
item. In doing so, OJP excludes from its purview all federal funding 
that grant applicants have been awarded to carry out the same or 
similar activities within a proposed project. Thus, in making funding 
decisions without asking for information about and considering other 
sources of an applicant's federal funding to carry out the same or 
similar activities, OJP may be awarding funds for proposed projects 
that are already partially or fully funded. It may also be doing so at 
the expense of other applicants who, in the absence of other funding 
sources, may demonstrate to OJP greater financial need for their 
proposals. Further, DOJ's new approach--while an important step--
relies solely on grantee reporting. By independently assessing its own 
lists of actual and prospective grantees prior to awarding funds, DOJ 
could have additional assurance that it is taking actions to mitigate 
the risk of unnecessary duplication.

In addition, OVW officials stated that for fiscal year 2013, they 
intend to require those applying to four of its grant programs to 
identify in their grant applications all federal funding that they 
recently applied for or have received. By enhancing visibility over 
various sources of grant funding, OVW would be better positioned to 
avoid unnecessary duplication in awarding grants for these four 
programs. It could also provide OVW with opportunities to best 
leverage OVW funding in a manner that complements other funding 
streams the applicant already has available or may soon receive. For 
example, if an applicant reports to OVW that it already receives money 
through a non- OVW grant to provide counseling services to victims, 
OVW can ensure that OVW funds are available for other project-related 
activities such as providing training to counselors who serve victims. 
However, beyond what OJP is piloting and what OVW has proposed for 
four of its programs, DOJ generally does not require grant applicants 
to identify other funding that they have received or any pending 
funding yet to be awarded, including funding received through a 
subgrant.[Footnote 37] Further, while the COPS Office's grants 
management system automatically includes information on other COPS 
Office funding a COPS Office applicant may already be receiving, it 
does not identify other DOJ grant funding or any other federal funding 
sources. As a result, DOJ's three granting agencies could take 
additional steps to increase their visibility over what applicants may 
already be receiving before awarding new funds.

OJP, OVW, and the COPS Office have not established policies and 
procedures requiring consistent coordination and information sharing 
among its granting agencies. Having such policies and procedures would 
provide guidance to DOJ granting agencies to help ensure they take 
action to mitigate the risks of unnecessary duplication before 
finalizing award decisions. By routinely coordinating to ensure the 
sharing of grant applications and potential grant awards among DOJ 
granting agencies prior to finalizing grant award decisions and 
documenting its methods for doing so, DOJ could also improve its 
oversight and better leverage information already at its disposal.

The IG recommended in August 2003 that OJP and the COPS Office 
establish procedures to coordinate to ensure that grantees do not 
receive funds for the same purpose from both agencies.[Footnote 38] In 
response, OJP and the COPS Office signed a memorandum of understanding 
to establish procedures for avoiding duplication by coordinating 
grants and grant programs that were identified by the IG and grant 
programs where the potential for duplication exists. Further, the 
agencies committed to reviewing any new guidance affecting grants or 
grant programs where the potential for duplication exists. 
Specifically, for grants and grant programs identified as having 
potential for duplication, OJP and the COPS Office agreed to minimize 
potential duplicative grant awards in a manner consistent with 
statutory provisions, and include a grant award special condition 
requiring that grantees not use OJP and COPS Office grant funds to pay 
for the same expenses.[Footnote 39] During the course of our audit 
work, we asked COPS Office and OJP officials for examples of the type 
of coordination they have been engaging in since the IG's 
recommendations. Officials provided evidence from fiscal year 2009, 
when they coordinated funding decisions with OJP prior to awarding 
grants for two similar grant programs funded under the Recovery Act. 
[Footnote 40] However, in some cases, granting agencies continue to 
provide funding for the same or similar purposes without each being 
aware of the others' actions. Further, we examined grant special 
conditions for the COPS Office CSP program and OJP's ICAC grant 
program and neither agency included special conditions in the grant 
awards requiring grantees to identify and report duplication. However, 
the 2010 COPS Child Sexual Predator Program Grant Owner's Manual did 
include a requirement that grantees inform the COPS Office if they 
receive other funding for the same cost or service already funded by 
the COPS Office while their grant is underway. The Grant Manager's 
Manual used by OJP lists grant award special conditions, and except 
for the duplication condition that specifically applies to CTAS, there 
were no other grant duplication special conditions listed.

Officials from OJP and the COPS Office told us that state and local 
communities have expansive criminal justice needs and therefore they 
encourage applicants to seek out as much DOJ grant funding as 
possible, including from grant programs that may have similar 
objectives or allow for similar activities. In some instances, DOJ may 
deem it appropriate for distinct grant programs to serve the same 
goal, or for one community or grantee to benefit from multiple streams 
of grant funding. For example, if DOJ granting officials are 
coordinating their activities across overlapping grant programs and 
are aware that a grantee is receiving funds from more than one DOJ 
program, making funding decisions of this kind may be warranted. 
However, DOJ's granting agencies are not routinely engaging in such 
coordination. Unless DOJ improves granting agencies' coordination, and 
considers information available on current, past, and prospective 
funding, it cannot know where all of its funding goes, how it is being 
or will be used, and whether it is awarding grant dollars in the most 
efficient way possible. Further, if the granting agencies are not 
aware of which recipients are receiving funds from multiple grants, 
they may be inadvertently awarding multiple grants that exceed the 
demonstrated need of a recipient or community at the expense of 
another applicant or community with similar demonstrated needs. In 
addition, they may be missing opportunities to award grants to 
recipients who may use funding in a complementary way, whereby funding 
may be leveraged by a grantee or a community to accomplish a single 
goal. With the exception of OVW's plan to have four grant program 
recipients identify all federal funding they receive and OJP's 
solicitation pilot and plan to have applicants identify duplicative 
cost items, DOJ does not have policies and procedures that require 
grant applicants to identify all sources of current or pending DOJ 
funding in their grant applications in a manner that provides DOJ a 
complete picture of DOJ grant project funding. If DOJ had (1) a 
coordinated approach to share applicants' funding intentions, and (2) 
policies and procedures to share lists of applicants that each 
granting agency plans to fund, DOJ could improve its understanding in 
the pre-award phase as to whether its funding would complement or 
unnecessarily duplicate other federal funding.

DOJ officials told us that the timeline for reviewing applications, 
making recommendations, and processing awards each year is compressed 
and that it would be difficult to build in the extra time and level of 
coordination required to complete an intradepartmental review for 
potentially unnecessary duplication of funding prior to making awards. 
The officials added that it would take even more time if granting 
agencies were to attempt a pre-award duplication review at the 
subgrantee level. Thus, officials told us that they rely upon post- 
award activities through grant monitoring, Single Grant Audits, and IG 
audits to determine if duplicative expenses have occurred after grants 
are under way. However, relying upon monitoring and external audits to 
identify duplication after it has occurred should not substitute for 
the mitigation of potential unnecessary duplication in the pre-award 
phase. We acknowledge that the time necessary to complete annual grant 
awards makes such a review process more difficult; however, actions to 
make coordination more consistent and efficient as well as the 
leveraging of grant award information, including subgrants, could help 
overcome this challenge. Moreover, using tools such as existing grant 
data available on USASpending.gov, which we address later in this 
report, could aid DOJ in validating other grant funding that grant 
applicants report and allow for an expedient way to search for 
subgrant funding. In addition, DOJ could limit its pre-award 
coordination to those grant programs that DOJ identifies as 
overlapping with other DOJ grant programs. For certain grant programs, 
OJP and OVW have taken important first steps to require grant 
applicants to report other sources of funding, but expanding this 
requirement to all grant programs across all granting agencies, such 
that every applicant would report both past and prospective sources of 
DOJ grant funding, could provide broader coverage and help DOJ better 
mitigate the risk of unnecessary duplication.

DOJ Uses Separate Grant Management Systems, a Fact That Limits Award 
Coordination:

While OJP and OVW use a single grants management system called GMS, 
the COPS Office uses a separate grants management system--CMS--which 
limits the sharing of grant award information across the granting 
agencies.[Footnote 41] Specifically, OJP, OVW, and the COPS Office use 
GMS and CMS to track and manage awards throughout the grant life 
cycle. For example, agency grant staff in OJP, OVW, and the COPS 
Office use their grant management systems to review and approve 
applications and to plan and document grant monitoring activities. 
Grantees use the grant management systems to submit financial status 
reports that include summary information on grant expenditures and 
program income as well as progress or performance reports. DOJ has 
spent about $36 million from 2008 through 2010 to maintain and upgrade 
these two separate grants management systems, including about $8 
million for CMS and $28 million for GMS.[Footnote 42]

DOJ's continued use of two systems to manage grant programs impedes 
coordination because GMS and CMS are not linked with each other, and 
the agencies' access is limited to the grants management systems they 
utilize. OJP and OVW can access information through GMS about grants 
awarded by each other, but they cannot access CMS to see the grantees 
that have received COPS Office funds. As a result, these granting 
agencies cannot use these grants management systems to inform 
themselves of all of the funding DOJ has awarded or is preparing to 
award to a recipient and consider this information before making 
additional awards. According to an OJP official, over the long term, 
it would be helpful if GMS could connect to CMS. Pursuant to the 
statute establishing OAAM--the office overseeing programmatic grant 
monitoring and assessment across OJP and COPS Office programs--the 
Director of OAAM was required to establish and maintain a modern, 
automated system for managing all information relating to grants made 
under programs within its purview.[Footnote 43] However, GMS and CMS 
remain distinct grant management systems in the department.

Standards for Internal Control in the Federal Government highlights 
the importance of program managers having access to operational and 
financial data to determine whether they are meeting their goals for 
accountability and efficient use of resources. In addition, the 
Domestic Working Group Grant Accountability Project's Guide to 
Opportunities for Improving Grant Accountability identified 
consolidating systems as a promising practice. Further, in 2010, the 
IG found that, as of 2009, OJP's Office of the Chief Financial 
Officer, which has oversight over the COPS Office, did not have access 
to basic data in CMS needed for financial monitoring site visits and 
other financial compliance reviews. The IG recommended that the COPS 
Office improve coordination with OJP by providing OJP additional 
grants management documentation for oversight and monitoring, such as 
through remote access to CMS.[Footnote 44] The IG concluded that 
oversight agencies should have direct, instant, and complete access to 
grant information, which is not provided using the current system, 
which relies on hard copies of documents. In response, COPS Office 
officials reported that they would provide OJP with real-time hard 
copy reports necessary to carry out oversight work and that CMS could 
be accessed only by employees using remote access to the COPS Office 
or through a COPS Office laptop.

DOJ contractors completed a gap analysis of CMS and GMS in 2006 to 
outline the differences--or gaps--between the two systems and propose 
solutions for reconciling them. At the time, the contractor found key 
gaps between the two systems related to business processes--in 
particular, programmatic grant monitoring, financial monitoring, and 
progress-reporting capabilities. Thus, the contractor recommended 
either building a new single grants system or maintaining the status 
quo because in the analysis, business process differences between OJP 
and the COPS Office were reportedly obstacles that made using either 
one of the two grants systems for both agencies untenable. Since 2007, 
OJP has upgraded GMS, which has closed some of the system gaps that 
the contractor initially identified, but the two systems remain 
distinct and unlinked.

According to COPS Office officials, CMS continues to better meet their 
needs than GMS could because CMS captures and stores data in such a 
way that it can be more easily queried than data in GMS and CMS 
uniquely aligns with COPS Office grant processes. This is helpful to 
the officials when the COPS Office is evaluating grant applications 
for its largest program, the COPS Hiring Program. Rather than 
evaluating qualitative grant project narratives through external peer 
review, the COPS Office considers quantitative data related to 
applicant fiscal distress, reported crime statistics, and community 
policing strategies when determining where to award COPS Hiring 
Program grants. Because COPS Hiring Program grant applicants use CMS 
to upload their data, COPS officials are positioned to use CMS for 
automated aggregation and analysis of applicant responses.

In contrast, OJP officials said that because of recent upgrades, GMS 
could be used or modified in order to query individual searchable 
elements. They also stated that variation in the information required 
by individual grant programs would not present an insurmountable 
barrier to unifying systems. In addition, GMS has served multiple 
agencies in the past and can be modified when circumstances warrant. 
For example, in 2010 and 2011, COPS Office officials successfully used 
GMS for awarding purposes under CTAS. According to OJP officials, the 
initial coordination with the COPS Office for CTAS purposes required 
additional modifications to GMS, but these were not onerous or costly. 
The officials said that with relative ease, after the modifications, 
OJP, OVW, and COPS Office grant managers all accessed GMS to perform 
some of the phases of the CTAS grant process. For example, GMS 
supports the management of CTAS by storing all applications, managing 
peer review comments, and registering awards once decisions are final. 
Besides OVW's use of GMS to award and manage its grants, the 
Department of Homeland Security's (DHS) Federal Emergency Management 
Agency (FEMA) also uses GMS to award and manage grants, though it has 
future plans to use a DHS grants system.[Footnote 45] Further, OJP 
officials stated that GMS has a current storage capacity well in 
excess of what it currently uses. They also emphasized that OVW and 
FEMA have grant business processes that do not completely align with 
OJP's, but with small investments, OJP has been able to adjust GMS to 
accommodate OVW and FEMA.

In June 2012, DOJ officials informed us they had engaged a contractor 
to assess whether a single grants management system, among a range of 
other options, can best serve DOJ's granting agencies. They plan for 
the contractor to report back within 6 months of beginning the 
analysis and said that they envision the assessment including an 
evaluation of costs, benefits, and technical requirements, such as 
those needed to harmonize business processes. Engaging a contractor 
for this purpose is an important first step, and doing so could help 
DOJ make better investment decisions about the most efficient way to 
manage its grants systems, especially when it considers the costs and 
benefits of having fragmented grants systems. In the interim, however, 
DOJ could take a more immediate solution to foster information sharing 
across GMS and CMS by providing system access to appropriate OJP, OVW, 
and COPS Office staff--for example, through common login names and 
passwords, just as department staff have done in limited instances 
such as the CTAS Program.

DOJ Does Not Timely Submit Grant Data to USASpending.gov and Is Not 
Fully Leveraging the Website's Subgrant Award Information before 
Making Grant Award Decisions:

DOJ's granting agencies are not submitting grant award information to 
USASpending.gov in a timely way. In accordance with the Federal 
Funding and Transparency Act of 2006 (FFATA), USASpending.gov was 
created to increase the transparency and accountability for federal 
funding awarded through contracts, loans, grants, and other awards. 
[Footnote 46] OMB issued guidance on reporting the receipt and use of 
federal funds. OMB also launched USASpending.gov in December 2007 to 
allow the public to view federal spending and engaged the General 
Services Administration (GSA) to build and maintain USASpending.gov, 
among other FFATA-related websites.[Footnote 47] In August 2010, OMB 
established guidelines for agencies related to the requirement for 
prime grantees to report all subgrants over $25,000 in fiscal year 
2011. The USASpending.gov website includes the subgrantees' names, 
geographical locations of funded activities, specific subgrant 
amounts, and the funded purposes. A GSA official told us that the 
FFATA reporting infrastructure is the first time that comprehensive 
federal grant and subgrant information, including DOJ grant 
information, has been made widely available on a single website. 
Through the steps that granting agencies, as well as the grantees, 
take to supply this website's content, the public and DOJ's granting 
agencies can better track the flow of funds and identify communities 
receiving funds from multiple streams.

OMB's FFATA guidance requires agencies to submit grant award data by 
the 5th of each month. USASpending.gov contains validation software 
used to validate agency data submissions, and if data are rejected, 
agencies receive automated notification. OMB guidance then requires 
agencies to resubmit the corrected data to USASpending.gov within 5 
working days of the rejection notification.[Footnote 48] OJP manages 
submissions to USASpending.gov for all of DOJ--that is for OJP, OVW, 
and the COPS Office--and an OJP official reported that DOJ submits 
grant award information to USASpending.gov twice per month. However, 
more than a quarter of the grant award information that DOJ submitted 
to USASpending.gov in fiscal year 2011 was rejected and resubmission 
took more than 80 days after the fiscal year ended.[Footnote 49] 
Figure 3 illustrates the flow of grant award information from both DOJ 
and grantees and some issues we identified related to DOJ's fiscal 
year 2011 reporting.

Figure 3: DOJ Grant and Subgrant Award Information Flow to 
USASpending.gov:

[Refer to PDF for image: illustration] 

DOJ is not submitting grant award data according guidance. Out of the 
4,346 grant awards that DOJ, 1,152 or, 27 percent, of DOJ's FY 2011 
rejected because 10 percent or more of the data batches contained 
errors. The grant award not resubmitted to USASpending.gov until 83 
days after the end of FY 2011. This may have contributed to DOJ prime 
grantees being unable to view their awards in either FSRS.gov or 
USASpending.gov in order to upload their subgrant award information 
for public viewing on USASpending.gov. 

DOJ prime grantees are unable to report their subgrant awards until 
DOJ successfully submits its prime grant award information in 
USASpending.gov. Of the prime grantees who submitted their subgrant 
award information in FY2011, 1,210 out of 2,116, or 57 percent, of 
these prime grantees did not report their subgrant awards consistent 
with OMB guidelines. 

OMB guidance requires DOJ to submit its prime grant award information 
by the 5th of each month. DOJ must resubmit corrections of grant award 
information previously rejected by USASpending.gov within 5 business 
days of receiving the notices of rejection. OJP submits prime grant 
award information on behalf of the COPS Office and OVW. 

GSA's data validation tool software on USASpending.gov is used to 
validate agency submitted grant award data. If 10 percent or more of 
grant award information submitted as a data batch contains errors such 
as duplicate awards or erroneous grantee identifier numbers, the 
entire batch is rejected and agencies are notified by USASpending.gov 
within 24 hours. Validated information is available on USASpending.gov 
within 24 hours of agency submission. 

OMB guidance requires prime grantees to report their subgrant awards 
over $25,000 through FSRS.gov, which directly feeds to 
USASpending.gov, by the end of the following month in which they award 
subgrants. 

Source: GAO analysis of GSA and USASpending.gov data. 

[End of figure]

Agency reporting of prime grant award information in USASpending.gov 
is a critical step in the FFATA reporting process because prime 
grantees cannot upload their subgrant award information until it 
occurs. For fiscal year 2011, DOJ submitted 4,346 distinct prime grant 
award records to USASpending.gov; however, GSA rejected 1,152 of these 
because of incomplete or inaccurate data associated with some of these 
grant files, and DOJ did not resubmit the records within 5 working 
days as required under OMB guidance. Specifically, DOJ did not correct 
and resubmit the rejected records until December 22, 2011, which was 
after we raised this issue with DOJ and 83 days after the end of the 
fiscal year. Five out of 11 DOJ prime grantees we interviewed who had 
awarded subgrants indicated that, after searching, they could not view 
their prime DOJ grant awards on FSRS.gov or USASpending.gov and 
indicated that DOJ had not uploaded the information to the websites. 
Further, another prime grantee among the 11 with whom we spoke 
indicated that it was unaware that subgrant reporting was a 
requirement. As a result, these prime grantees were unable to submit 
their subgrant award information and thus were unable to comply with 
OMB subgrant reporting requirements. DOJ has taken action to help 
ensure that prime grantees and DOJ grants staff are aware of FFATA 
reporting requirements. For example, OJP offered FFATA reporting 
training for all DOJ grants staff and grantees, and all three granting 
agencies required a special condition in grant awards that included 
FFATA reporting requirements. These steps may have informed grantees 
of their FFATA responsibilities, but DOJ's untimely submission of 
grant award information to USASpending.gov led to prime grantees being 
unable to access their grant awards to submit their subgrant award 
information as required by OMB.

OJP officials stated that since 2007 they have been coordinating with 
OMB, other federal agencies, and contractors on issues related to 
reporting guidelines and other technical requirements related to 
subgrant reporting, but that it was not until August 2010 that OMB 
established guidelines for the collection and reporting of subgrant 
information. Nevertheless, OJP officials stated that the current 
allotment of 5 days for agencies to review and resubmit data that GSA 
originally rejected is an unreasonable time frame given the time- 
intensive nature of checking and correcting errors. Officials also 
noted that OJP would like to see GSA allow for the posting of 
individual records that pass system validation rather than waiting for 
entire blocks to be corrected at once before GSA will post award 
information to USASpending.gov. In addition, OJP officials indicated 
that the information prime grantees ultimately posted about their 
subgrantees was limited and in most cases very brief. As a result, the 
officials said they were not considering such information before 
making new awards.

We recognize that 5 days may not be adequate to correct errors in 
grant award information, but we also believe that timely submission of 
grant award information on USASpending.gov is key to transparency and 
the overall utility of the system for grant decision makers, the 
criminal justice community, Congress, and taxpayers. By DOJ ensuring 
that it submits its grant award information to USASpending.gov in as 
timely a manner as is possible, prime grantees' abilities to report 
their subgrant activities would likely improve. As a result, DOJ could 
have greater visibility over which subgrantees were using its money 
and for what purposes before DOJ makes its grant award decisions. 
Further, even if DOJ does not believe that the information that prime 
grantees ultimately post about their subgrantees is ideally 
descriptive in every instance, the information could provide DOJ with 
important details-- that it currently does not consider or otherwise 
have access to before finalizing award decisions--related to how 
subgrantees are using their funds.

DOJ Could Benefit from Examining Its Programmatic Grant Monitoring and 
Assessment Functions and Considering Expansion of OAAM's Authorities:

OAAM Uses Programmatic Grant Monitoring and Program Assessment for 
Grant Oversight, but Program Assessments Yield Richer Information:

The statute establishing OAAM tasked the OAAM Director with selecting 
and carrying out program assessments of not less than 10 percent of 
the aggregate amount of grant funding awarded annually by OJP, the 
COPS Office, and any other grant programs carried out by DOJ that the 
Attorney General considers appropriate.[Footnote 50] OAAM officials 
told us that to meet the directive to conduct program assessments, and 
in recognition of its own resource constraints, OAAM relies on the 
programmatic grant monitoring that OJP's and the COPS Office's grant 
staff already conduct. To oversee and track these monitoring efforts, 
OAAM develops and implements standards and protocols, including a 
framework and methodology for systematically identifying high-risk 
grantees.[Footnote 51] OAAM also tracks OJP's and the COPS Office's 
monitoring progress and compares it against an established annual 
monitoring plan. For example, in its fiscal year 2010 annual report-- 
the latest available--on both OJP and the COPS Office's monitoring 
goals and activities, OAAM found that both offices exceeded their 
goals of monitoring 10 percent of total award funding. OJP monitored 
1,447 grantees with awards totaling $3.05 billion, and the COPS Office 
monitored 185 grantees with awards totaling $234.74 million. In 
addition to overseeing monitoring activities, OAAM also conducts 
program assessments of OJP and COPS Office grant programs. OAAM 
considers monitoring--and its oversight of it--as responsive to its 
originating statute's intent, but it also recognizes that assessments 
have utility and serve a separate but important function in helping 
the office improve grant management. Table 4 illustrates the 
distinction between OJP's and the COPS Office's monitoring and OAAM's 
assessment functions.

Table 4: Comparison of Programmatic Grant Monitoring and Program 
Assessment Activities:

OJP's and the COPS Office's programmatic grant monitoring: 

Who conducts: 
* Grant staff in OJP's program offices and COPS Office's Grant 
Monitoring Division; 
Scope: 
* Focuses on individual grant recipients one at a time.; 
Characteristics: 
* Checks that the grantee complies with the programmatic, 
administrative, and financial requirements; 
* Advocates responsible stewardship of awarded funds; 
* Verifies that grant implementation is consistent with the grantee's 
stated plan, policy guidelines, and applicable DOJ rules and 
regulations; 
* Observes and verifies project implementation for promising practices; 
Results: 
* Provides guidance to the grantee on DOJ policies and procedures, and 
programmatic, administrative, and financial reporting requirements; 
* Works with the grantee to identify any problems and provide 
assistance to resolve them; 
* Recommends appropriate and available training or technical 
assistance. 

OAAM's grant program assessments: 

Who conducts: 
* Analysts in OAAM; 
Scope: 
* Can focus on a whole or one aspect of a grant program; 
Characteristics: 
* Systematic review and evaluation of programs to gauge effectiveness, 
identify promising practices, and document impediments; 
* Begins with research into a grant program's issue area, origin, and 
original purpose, along with key program challenges and issues; 
* Uses a variety of analytical approaches, depending on the goals of 
the assessment, to provide bureaus and program offices with 
information to improve their programs; 
Results: 
* May result in recommendations to grant-making offices and bureaus 
for improving their grant programs; 
* When recommendations are made, OAAM staff work with program offices 
to implement recommendations. 

Source: GAO analysis of DOJ information. 

[End of table] 

In general, both monitoring and assessment are important and 
complementary tools for grant oversight. Nevertheless, we found that 
OAAM's program assessments yield richer information to enhance grant 
programs than either OJP's or the COPS Office's individual monitoring 
reports or the summary reports that OAAM's Program Assessment Division 
(PAD) compiles because the program assessments are more analytical and 
broader in perspective. OAAM's PAD Standard Operating Procedures 
define a program assessment as "a systematic review and evaluation of 
programs to gauge effectiveness, identify promising practices, 
document impediments, and when necessary, make recommendations for 
improvement." OAAM reported to us that from 2008 through mid-February, 
2012, its staff had produced 28 products; however, when we reviewed 
the 28, we found that 7 met OAAM's definition for a program 
assessment.[Footnote 52] For example, in 2012, OAAM completed an 
assessment report on the COPS Office Methamphetamine Initiative. In 
2011, it completed one on BJA payment programs, and in 2010, it 
assessed the ICAC Training and Technical Assistance Program. The other 
21 publications were user guides; summaries of monitoring reports, 
such as those described earlier; or Recovery Act risk indicator 
reports, which identify potentially high-risk grantees so that the 
program offices can work with those grantees to resolve issues and 
prevent potential problems. According to OJP, all of OAAM's 
publications contribute to improving OJP's grant programs and 
operations by strengthening internal controls, streamlining processes 
to be more efficient, or reporting on how well programs and policies 
are meeting their objectives. 

[Side bar: Program Assessment Example: 
A 2010 program assessment report on the ICAC Training and Technical 
Assistance Program made 11 recommendations related to the collection 
and use of performance measurement data, financial management, fair 
and open competition for awards, and improving grant management and 
oversight. Program monitoring did not find areas for improvement or 
make related recommendations. End of side bar] 

Of the 7 publications meeting OAAM's definition for program 
assessments, 2 reviewed a single aspect of the grant cycle--program 
awarding--within a particular grant program rather than the grant 
program overall.[Footnote 53] Nevertheless, all 7 were based on a much 
more thorough review of the extent to which a grant program is meeting 
its intended purpose. Moreover, each recommended specific actions to 
address identified program deficiencies, and implementation of these 
recommendations has helped DOJ enhance its grant programs. For 
example, the 2010 ICAC assessment report contained 11 recommendations 
related to the collection and use of performance measurement data, 
financial management, fair and open competition for awards, and 
improving grant management and oversight. In our review of the six 
monitoring reports that the ICAC grant manager completed for the ICAC 
program's sole grantee, there was no mention of the same deficiencies. 
In particular, none of the six monitoring reports identified the 
unallowable costs, conflict of interest, or inadequate oversight and 
documentation of grant activity that the OAAM assessment report 
identified. Instead, the monitoring reports showed that the grantee 
was progressing as expected on implementation of the program, and was 
on schedule with no problems noted.

[Side bar: Program Assessment Example: 
A 2011 program assessment of OJP's payment programs revealed, among 
other findings, unallowable reimbursement requests totaling
$5.8 million from jurisdictions that requested reimbursement for 
overlapping detention days from two different programs. OAAM's 
identification of the request led to its removal and savings for the 
program, DOJ, and the taxpayer. OJP does not conduct program 
monitoring for its payment programs. End of side bar] 

OAAM also assessed BJA's payment programs, which otherwise are not 
subject to BJA grant monitoring. In the November 2011 report, OAAM 
assessed the processes that BJA used to verify the eligibility and 
accuracy of reimbursement requests submitted by grantees.[Footnote 54] 
The assessment concluded that BJA is administering its payment 
programs appropriately to verify the eligibility and accuracy of 
payments, but it also determined that additional internal controls 
were necessary and that procedures were not sufficient to identify 
duplicate payment requests from grantees. As a result of the 
assessment, OAAM made six recommendations to BJA, including 
implementing additional procedures to identify duplicate requests for 
payments of detention expenses. In particular, one of OAAM's 
recommendations was that BJA implement a process to identify 
overlapping requests for reimbursement between two of the programs for 
expenses related to detention of criminal aliens. In response, BJA 
compared all of those programs' applications for reimbursement for 
fiscal year 2011 to identify whether jurisdictions were requesting 
reimbursement for the detention of the same individuals over the same 
period of time. BJA's review led to the removal of approximately $5.8 
million in requests for reimbursement prior to generating the final 
reimbursement awards.

Standards for Internal Control in the Federal Government calls for 
managers to compare actual performance with planned or expected 
results throughout the organization and analyze significant 
differences. These standards also identify that program managers need 
both operational and financial data to determine whether they are 
meeting their agencies' strategic and annual performance plans and 
meeting their goals for accountability for effective and efficient use 
of resources. The programmatic grant monitoring reports that each of 
the granting agencies compile contribute to meeting these standards at 
the grantee level by tracking the progress and, when necessary, 
providing assistance to individual grant recipients. OAAM's summaries 
of these reports then roll up the statistics and ensure the compliance 
monitoring occurs as required. However, OAAM's program assessments are 
more comprehensive than both the individual grant monitoring reports 
and the summary reports OAAM prepares because their broader 
perspective allows for reporting on program successes, impediments, 
and potential areas for improvement. While monitoring 10 percent or 
more of the aggregate amount of grant funding awarded annually is 
important and beneficial to the grant management process, the 7 
program assessment reports that OAAM has issued since 2008 have led to 
more than 50 recommendations for the improvement of OJP and COPS 
Office grant programs.

According to OAAM officials, additional program assessments would be 
beneficial; however, they told us that OAAM does not have sufficient 
resources to conduct more. They said that conducting program 
assessments on 10 percent of the aggregate amount of grant funds 
awarded annually would not be possible given current resources, but 
they also noted that the department has not conducted a feasibility 
analysis that considers the costs and benefits of having OAAM conduct 
assessments on a larger number of grant programs. Further, OJP 
officials stated that since the establishment of OAAM, the 
administration has never requested, and the department has not 
received, the full amount authorized for appropriation under OAAM's 
governing statute.[Footnote 55] DOJ officials did not explain the 
rationale for the administration's budget proposals and officials did 
not report any plans to increase OAAM's resources. As of December 
2011, out of a total of 49 staff (26 federal staff authorized by DOJ 
and 23 contractors) spread across OAAM's three divisions, OAAM had 8 
staff (5 federal staff authorized by DOJ and 3 contractors)--or less 
than 20 percent--in its PAD dedicated to performing program 
assessments in addition to overseeing OJP and COPS Office programmatic 
monitoring.[Footnote 56] OAAM also has 18 staff (10 federal staff 
authorized by DOJ and 8 contractors)--or more than 30 percent--working 
in its Audit and Review Division to coordinate IG, GAO, and Single 
Grant Audit resolutions,[Footnote 57] and to conduct A-123 reviews-- 
activities that are not specifically addressed in OAAM's authorizing 
statute.[Footnote 58] Appendix V contains further discussion of the 
different activities of OAAM's three divisions. Because DOJ considers 
its resources to be limited, it is important that OAAM's resources be 
used as efficiently as possible to maximize the investment in grant 
programs. Thus, given the different roles that grant monitoring and 
program assessment play in assessing the overall effectiveness of 
grant programs, considering whether it employs an appropriate mix of 
monitoring and program assessments could aid DOJ in awarding grant 
funds in the most efficient and effective way possible.

Not Including OVW in OAAM's Oversight Has Resulted in Inconsistent 
Assessment of the Effectiveness of DOJ Grant Programs:

Consistent with the 2000 reauthorization of the Violence Against Women 
Act, the Attorney General submits a biennial report to Congress on the 
effectiveness of VAWA-funded grant programs.[Footnote 59] OVW uses the 
VAWA Measuring Effectiveness Initiative, conducted under a 
noncompetitive cooperative agreement with a university to develop and 
implement reporting tools, as the primary way it meets statutory 
requirements to report on the effectiveness of VAWA-funded 
programs.[Footnote 60] Staff from the university also provide data 
collection training to grantees to ensure that they use the forms and 
database properly, and then use the information collected to summarize 
grantee performance in semiannual summary data reports. The results of 
this initiative are summary data reports that university staff compile 
from the semiannual or annual progress reports that grantees submit to 
OVW. OVW then uses these summaries to meet biennial reporting 
requirements for its discretionary grant programs under VAWA and, for 
example, the Services, Training, Officers, Prosecutors (STOP) Violence 
Against Women Formula Grant Program (STOP Program). [Footnote 61] The 
STOP Program promotes a coordinated, multidisciplinary approach to 
improving the criminal justice system's response to violent crimes 
against women and increasing the availability of victim services.

OVW's biennial reports are composed of three main components:

* a literature review of research showing (where available) the 
effectiveness of grant-funded activities and (when such research is 
not available) information on promising or best practices in the field 
of victims services;

* a summary of performance measure data, such as the number of grant- 
funded staff, the number of people trained, and the number of victims/ 
survivors seeking services that are served, partially served, and not 
served, as reported by the grantees to OVW through OJP's GMS; and:

* anecdotal evidence from grantees on the benefit of what they are 
able to do with grant funds.

The statute establishing OAAM did not give it oversight authority for 
OVW programs. Provisions in the authorizing statute, however, provide 
the Attorney General with discretion to expand OAAM's scope beyond OJP 
and COPS Office programs, which the Attorney General has not 
undertaken. As a result, while OVW uses its data collection and 
analysis to report on grant program effectiveness, in accordance with 
the VAWA requirement, by providing information on activities carried 
out with grant funds and the number of persons served using those 
funds, it does not benefit from the monitoring oversight and grant 
program assessments that OAAM provides. Such assessments could provide 
OVW with more substantive information on its grant programs.

Table 5 contains a comparison of the analytical approaches that OVW 
uses when it reports to Congress on the effectiveness of its grant 
programs against those that OAAM uses in its program assessments. On 
the basis of a review of seven OVW reports and seven OAAM grant 
program assessment reports, we found that OVW's reports contain less 
analysis than the OAAM reports do. Specifically, these OVW reports 
summarized performance measurement data rather than analyzed it. 
Further, these OVW reports did not address grant program operations 
and management. OAAM, in contrast, used more varied approaches to 
analyze grant programs, which provided information on both grant 
program performance and operations, identified areas for improvement, 
and resulted in specific recommendations to OJP's bureaus and program 
offices, and the COPS Office.

Table 5: Comparison of OVW and OAAM Measurement of Grant Program 
Effectiveness:

Analytical approaches: Comparative analysis--seeks to identify the 
strengths and weaknesses of two or more comparable programs or 
processes; 
Number of OVW reports including approach: 0; 
Number of OAAM reports including approach: 1.

Analytical approaches: Compliance analysis--determines whether a 
program is being operated within the laws and regulations under which 
it is funded; 
Number of OVW reports including approach: 0; 
Number of OAAM reports including approach: 2.

Analytical approaches: Grant administrative requirements review--
examines the extent to which grants comply with grant administrative 
requirements; 
Number of OVW reports including approach: 0; 
Number of OAAM reports including approach: 5.

Analytical approaches: Financial/grant expenditure review--reviews the 
financial history of a grant to ensure that grantees properly 
accounted for expenditures; 
Number of OVW reports including approach: 0; 
Number of OAAM reports including approach: 3.

Analytical approaches: Literature review--examines related research on 
the effectiveness of grant-funded programs or best practices in the 
field; 
Number of OVW reports including approach: 7; 
Number of OAAM reports including approach: 1.

Analytical approaches: Output analysis--identifies the direct products 
or services delivered by a program; 
Number of OVW reports including approach: 7; 
Number of OAAM reports including approach: 2.

Analytical approaches: Performance measurement analysis--determines 
whether a grant program or its grantee has useful and appropriate 
performance data to measure program effectiveness; 
Number of OVW reports including approach: 0; 
Number of OAAM reports including approach: 3.

Analytical approaches: Process analysis--determines the extent to 
which a program is operating under its original intent or whether 
there are particular processes that could be improved; 
Number of OVW reports including approach: 0; 
Number of OAAM reports including approach: 7.

Analytical approaches: Trend analysis--examines historical results to 
attempt to identify patterns and trends in order to predict a future 
outcome; 
Number of OVW reports including approach: 0; 
Number of OAAM reports including approach: 2.

Source: GAO analysis of information from DOJ and the Measuring 
Effectiveness Initiative. 

[End of table] 

Unlike the OAAM analysts who conduct assessments of OJP and COPS 
Office grant programs, the university staff responsible for the 
Measuring Effectiveness Initiative do not have access to grant program 
financial data or OVW grant monitoring reports. Additionally, 
university staff involved in the initiative do not conduct site visits 
to validate the data provided by grant recipients and the work they 
perform. Instead, OVW staff in each program area review the results of 
the biennial reports and the semiannual summary data reports compiled 
from grantee progress reports to identify priority areas where there 
is an unmet need. The OVW reports contain sections on "remaining areas 
of need" identified by grant recipients. However, the areas of need 
that OVW identified are based on comments grant recipients provided on 
gaps in service, rather than being based on an independent assessment 
that OVW conducted on the overall grant programs. Moreover, unlike the 
grant program assessments that OAAM conducts, beyond identifying areas 
of need, the biennial reports do not result in concrete 
recommendations for improving OVW's grant programs. OVW officials told 
us that for the upcoming 2012 biennial report, they plan to focus more 
attention to the discussion of remaining areas of need.

According to OVW's 2010 Biennial Report to Congress on the 
Effectiveness of Grant Programs Under the Violence Against Women Act, 
demonstrating the effectiveness of services provided by agencies 
funded under OVW presents a challenge for those charged with meeting 
the reporting mandate of VAWA 2000. An OVW official told us that it is 
difficult to discern between output and outcomes when dealing with the 
grant programs in OVW and that it is difficult to measure outcomes 
with service grant programs.[Footnote 62] For example, OVW might 
consider whether an abuse victim not only gets a protective order but 
also receives additional services. Additionally, according to OVW 
officials, it would be difficult to track how many victims received 
different types of services in multiple areas, because OVW service 
provider grantees only track the first instance in which a victim 
receives services and do not follow up on related services.

According to the federal Domestic Working Group Grant Accountability 
Project's Guide to Opportunities for Improving Grant Accountability, 
agencies need a process for managing performance once grants are 
awarded, and the ability to assess grant results and use those results 
when awarding future grants. The Working Group identified engaging 
outside experts to assess program performance, inspecting projects 
after completion, and conducting evaluations to identify factors 
affecting results among its promising practices to improve program 
performance. These activities are not part of OVW's current approach 
to program oversight.

OVW conducts its grant program monitoring as well as IG audit follow- 
up. Additionally, OVW has a Grant Assessment Tool (GAT)--designed by 
the same company that produced the GAT for OJP.[Footnote 63] OAAM 
currently conducts Single Audit follow-ups; manages the high-risk 
grantee list; and oversees DOJ's combined programmatic and financial 
monitoring plan, which is the combined monitoring list of all the 
sites that OJP, OVW, and the COPS Office plan to visit for the year. 
In a March 2011 audit, the IG found that OVW and the COPS Office 
perform certain monitoring and oversight services that are duplicative 
of the services available through OJP and recommended that DOJ 
standardize the oversight services provided to OVW and the COPS Office 
to eliminate such duplication and provide uniformity in oversight 
among DOJ granting agencies. OAAM provides certain administrative 
services that facilitate grant program management, but DOJ officials 
told us the reason OAAM does not have oversight over OVW is because 
the Attorney General has not extended OAAM's purview. OJP officials 
told us that they have not been provided the scope of work that OVW 
oversight may encompass and, as such, OAAM has not conducted any 
analyses using a workforce model to determine the staffing levels, 
associated resources, and other possible impacts (i.e., costs and 
benefits) of having OVW under its purview on OAAM operations.

OVW officials expressed concern that OAAM staff would not have any 
expertise in violence against women issues. However, OAAM currently 
has oversight over specialized bureaus and offices such as the Office 
for Victims of Crime and the Office of Sex Offender Sentencing, 
Monitoring, Apprehending, Registering, and Tracking. Additionally, OVW 
officials stated that OAAM does not perform data collection and 
analysis activities, which are the primary activities of the Measuring 
Effectiveness Initiative. However, as a part of its assessments, OAAM 
has collected performance measures and conducted analysis. For 
example, in its assessment of the ICAC Training and Technical 
Assistance Program, OAAM collected and analyzed national performance 
metrics related to training. Given the nature of OAAM assessments, 
along with the other oversight services it provides to OJP and the 
COPS Office, the information resulting from OAAM assessments of OVW 
grant programs could better inform OVW about its grant programs and 
funding to assist with future program design and award decisions while 
also providing Congress with a more complete picture on the 
effectiveness of programs funded under VAWA. Accordingly, DOJ could 
benefit from assessing the feasibility, costs, and benefits of OAAM 
providing grant program assessments for OVW.

Conclusions:

The statutory design of DOJ's grant programs has contributed to 
overlap across a number of justice areas. We recognize that even when 
programs overlap, there may be meaningful differences in their 
eligibility criteria or objectives, or they may be providing similar 
types of services in different ways. We also recognize that a number 
of grant programs are formula-driven and therefore grantees' 
eligibility is predetermined. However, because DOJ exercises 
independent judgment when making discretionary awards and therefore 
has full responsibility for how it conducts its pre-award reviews, it 
will be important for the department to maximize visibility over how 
grantees plan to spend the funds they receive from multiple funding 
streams. In some instances, DOJ may deem it appropriate for large 
numbers of distinct grant programs to serve one goal, or for the same 
communities to benefit from multiple streams of its grant funding. In 
these cases, duplication may be warranted. However, because we found 
routine coordination and consistent policies and procedures for 
sharing information across the granting agencies during DOJ's pre-
award phase limited, we do not believe DOJ knows with certainty if 
such duplication is always necessary.

DOJ's three granting agencies have taken some steps to coordinate 
their grant-related activities and have sought congressional approval 
in some instances for grant program consolidation. Further, they have 
initiated other, limited actions to ensure that grantees report 
additional streams of funding. However, DOJ limits its view of 
duplication to instances where grant applicants apply for and receive 
multiple streams of funding, including DOJ funding, to support single 
costs associated with a single grant project. Using this definition, 
DOJ believes that any unnecessary duplication can be identified 
through monitoring grantees post-award. We take a broader view of 
duplication and consider it potentially unnecessary when DOJ is 
unaware that grantees have applied for and are receiving funding for 
potentially the very same or similar purposes. Therefore, we believe 
it is incumbent that DOJ take steps in the pre-award phase to make 
purposeful judgments about funding necessity before finalizing the 
awards. Doing so would help the department better mitigate this risk 
for potential, unnecessary duplication. Specifically, by conducting a 
broad examination of all DOJ grant programs to systematically identify 
justice areas for which funding overlaps, DOJ would have greater 
visibility over how its funding can be used and whether it is awarding 
grant dollars in the most efficient way possible. Further, developing 
and implementing policies and procedures to require granting agencies 
to routinely share and consider information each may have about past 
or prospective grantee funding could provide DOJ with more strategic 
visibility over its awarding decisions. In addition, requiring all 
grantees to report current or prospective federal funding sources when 
applying for DOJ grants could provide DOJ with more information to 
better target its limited financial resources before it finalizes new 
grant awards.

Additionally, by taking interim steps to expand access to the two 
distinct grant management systems--CMS and GMS--DOJ could better 
ensure that grant managers and decision makers can leverage all 
existing tools while a longer-term study to consider the feasibility, 
costs, and benefits of potential options for DOJ grant management 
systems is underway. Such options could include unifying the systems, 
creating a DOJ-wide system, or using off-the-shelf software to bridge 
information gaps. Related, DOJ can have greater confidence that any 
variation in how the granting agencies are currently managing their 
portfolios does not hinder any potential unification by ensuring that 
its planned study include an assessment of the steps needed to 
harmonize DOJ grant processes. Further, with additional steps to 
ensure that DOJ is submitting grant award information to 
USASpending.gov in the most timely manner possible, the department 
could facilitate prime grantees' uploading of information on 
subgrantees' use of funds and therefore make the website a more useful 
resource to DOJ's own grant decision makers. Finally, recognizing the 
value of OAAM's role, assessing whether the office relies on an 
appropriate mix of programmatic grant monitoring and program 
assessment--as well as considering expansion of OAAM's coverage to 
include OVW--could improve the overall operation of grant programs 
departmentwide.

Recommendations for Executive Action:

To ensure that DOJ can identify overlapping grant programs to either 
consolidate or coordinate similar programs, mitigate the risk of 
unnecessary grant award duplication in its programs, and enhance DOJ's 
ability to gauge grant program effectiveness, we recommend that the 
Attorney General take the following eight actions:

1. Conduct an assessment to better understand the extent to which the 
department's grant programs overlap with one another and determine if 
grant programs may be consolidated to mitigate the risk of unnecessary 
duplication. To the extent that DOJ identifies any statutory obstacles 
to consolidating its grant programs, it should work with Congress to 
address them, as needed.

2. Coordinate within and among granting agencies on a consistent basis 
to review potential or recent grant awards from grant programs that 
DOJ identifies as overlapping, including subgrant awards reported by 
prime grant awardees, to the extent possible, before awarding grants. 
DOJ should also take steps to establish written policies and 
procedures to govern this coordination and help ensure that it occurs.

3. Require its grant applicants to report all federal grant funding, 
including all DOJ funding, that they are currently receiving or have 
recently applied for in their grant applications.

4. Provide appropriate OJP and COPS Office staff with access to both 
GMS and CMS and appropriate OVW staff with access to CMS.

5. As part of DOJ's evaluation of its grant management systems, DOJ 
should ensure that it assesses the feasibility, costs, and benefits of 
moving to a single grants management system, including the steps 
needed to harmonize DOJ grant processes, so that any variation in how 
the granting agencies manage their portfolios is not an encumbrance to 
potential system unification.

6. Ensure the most timely reporting possible of grant award 
information to USASpending.gov according to OMB guidelines, which 
would enable its grantees to comply with their reporting 
responsibilities according to the same guidelines.

7. Assess whether OAAM relies on an appropriate mix of programmatic 
grant monitoring and program assessment, and determine whether the 
office could support additional program assessments.

8. Assess the feasibility, costs, and benefits of OAAM providing 
assessments for OVW, in addition to OJP and the COPS Office. If DOJ 
determines that OAAM assessments of OVW grant programs would be more 
cost-effective and provide greater insight into the effectiveness of 
OVW grant programs than OVW's current approach, then the Attorney 
General should extend OAAM's oversight to include OVW.

Agency Comments and Our Evaluation:

We provided a draft of this report to DOJ for comment. DOJ provided 
written comments, which are reproduced in full in appendix VI, and 
concurred with all eight of the recommendations. DOJ also described 
actions it has underway or plans to take to address the recommendations.

* DOJ agreed with the first recommendation that it conduct an 
assessment to better understand the extent to which the department's 
grant programs overlap with one another. DOJ stated it will explore 
options for carrying out such an assessment in an effort to reduce the 
risk associated with unnecessary or inappropriate program duplication. 
For example, DOJ stated it is considering tasking OAAM to conduct such 
an assessment. Since DOJ is developing options for how it will 
implement this recommendation, it is too soon to know what specific 
actions DOJ will take, when they will be completed, and whether they 
will fully address the intent of the recommendation.

* DOJ agreed with the second recommendation that it coordinate within 
and among granting agencies, to the extent possible, before awarding 
grants. DOJ stated that its grant-making agencies will continue to 
closely collaborate and share information prior to making grant 
awards. DOJ also stated it plans to use the results of the assessment 
referenced in the first recommendation to develop a targeted and 
strategic approach for reviewing grant applications during the pre- 
award process. Since DOJ is considering how it will implement this 
recommendation, it is too soon to know what specific actions DOJ will 
take, when they will be completed, and whether they will fully address 
the intent of the recommendation.

* DOJ agreed with the third recommendation that DOJ require its grant 
applicants to report all federal grant funding, including all DOJ 
funding, that they are currently receiving or have recently applied 
for in their grant applications. DOJ stated it plans to use a risk-
based approach to implement this recommendation, using the results 
from its assessment in response to the first recommendation. This is a 
positive step toward ensuring that DOJ has a more complete picture of 
an applicant's access to other federal funding. However, since DOJ has 
not yet developed its approach, it is too soon to tell whether DOJ's 
actions will address the intent of the recommendation.

* DOJ agreed with the fourth recommendation that DOJ provide 
appropriate OJP and COPS Office staff with access to both GMS and CMS 
and appropriate OVW staff with access to CMS. DOJ noted that OJP will 
provide read-only GMS access to COPS Office staff and that the COPS 
Office will provide reports to OJP and OVW from CMS, given the 
technological barriers to providing external system access. These 
actions, when implemented, should address the intent of this 
recommendation.

* DOJ agreed with the fifth recommendation that as part of its 
evaluation of its grant management systems, DOJ should ensure it 
assesses the feasibility, costs, and benefits of moving to a single 
grants management system. DOJ stated that it had initiated such a 
study and plans to complete it within the next six months. When 
effectively completed, this study, along with any actions taken to 
implement its findings, should address the intent of this 
recommendation.

* DOJ agreed with the sixth recommendation that DOJ ensure the most 
timely reporting possible of grant award information to 
USASpending.gov. DOJ committed to doing its best to ensure timely 
reporting, but did not provide specific actions or plans to address 
the intent of the recommendation.

* DOJ agreed with the seventh recommendation that DOJ assess whether 
OAAM relies on an appropriate mix of programmatic grant monitoring and 
program assessment, and whether the office could support additional 
program assessments. DOJ stated that additional program assessments 
would be beneficial and contribute to the improvement of grant 
programs and operations. DOJ also stated it would explore ways to 
conduct more program assessments, but did not provide specific actions 
or plans to address the intent of the recommendation.

* DOJ agreed with the eighth recommendation that DOJ assess the 
feasibility, costs, and benefits of OAAM providing assessments for 
OVW, in addition to OJP and the COPS Office. DOJ stated that 
discussions have been initiated between OAAM and OVW related to this 
recommendation. This is a positive first step, but it is too soon to 
know whether the results of these discussions and any resulting 
potential future actions will address the intent of the recommendation.

In addition, DOJ raised concerns about the methodology we used to 
identify overlap in DOJ's fiscal year 2010 grant program solicitations 
across 10 broad justice themes. DOJ stated that our analysis of 
potential overlap between DOJ funding solicitations substantially 
overstated the number of programs that might be duplicative. DOJ 
commented that the table we used to show the overlap was an indication 
that DOJ was involved in "wasteful duplication." Our analysis, as 
summarized in table 2 of this report, demonstrates overlap in the 
justice areas that DOJ's grant programs aim to support. Having several 
overlapping grant programs within individual justice areas requires 
greater visibility and pre-award coordination on the part of DOJ to 
diminish the risk of unnecessary duplication at the grant project 
level. As such, our analysis does not, on its own, indicate 
unnecessary duplication among DOJ grant programs, but instead 
identifies the potential risk of unnecessary duplication. Implementing 
the recommendations in this report that DOJ assess grant program 
overlap and coordinate grant award decisions will help DOJ identify 
areas of overlap and mitigate the risk of unnecessary duplication in 
grants. DOJ also considered the categories we developed for our 
analysis such as "community crime prevention strategies" as too broad 
and exclusive of specialized programs such as community policing. We 
developed our 10 broad justice areas based mainly on programmatic 
information contained on DOJ granting agency websites and other DOJ 
literature and believe they fairly demonstrate overlap among DOJ's 
various grant programs. We recognize that the more detailed analysis 
we recommended and DOJ agreed to undertake is necessary to determine 
the extent of any unnecessary duplication.

DOJ also commented that our sample size of grant applications was too 
small in number and was not generalizable. As discussed in this 
report, our sample size was not intended to be generalizable across 
the entire scope of DOJ grant program awards, but instead was meant to 
illustrate the potential for unnecessary duplication. DOJ further 
commented that their investigation of the examples of unnecessary 
duplication we provided proved that no duplication actually existed in 
the grant programs. DOJ conducted its review after we provided our 
examples and focused on how grantees were using the funds they had 
received. Our analysis of potential duplication focused on grant 
applications--how applicants proposed to spend federal grant dollars--
and not on the verification of activities grantees carried out once 
DOJ funded them. DOJ's plans to improve pre-award coordination are 
positive steps and we believe that by doing so, DOJ will be better 
positioned to make better informed decisions about the financial needs 
of grantees and communities for their proposed projects.

Finally, DOJ expressed concern that the report implies that DOJ is not 
tracking subgrantees' activities. Our analysis focused on pre-award 
coordination, not DOJ's efforts to track subgrantee activities. As 
such, we recommended that DOJ use the subgrant award information it 
does have to help inform DOJ's grant award decision making. We believe 
that subgrant award information could provide DOJ decision makers with 
a more complete financial picture of applicants and the projects they 
propose to be funded by DOJ.

We are sending copies of this report to the Attorney General, selected 
congressional committees, and other interested parties. In addition, 
the report is available at no charge on the GAO website at [hyperlink, 
http://www.gao.gov].

If you or your staff have any questions about this report, please 
contact me at (202) 512-9627 or maurerd@gao.gov. Contact points for 
our Offices 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 VII. 

Signed by: 

David C. Maurer: 
Director, Homeland Security and Justice Issues: 

List of Congressional Committees:

The Honorable Patrick J. Leahy: 
Chairman: 
The Honorable Chuck Grassley: 
Ranking Member: 
Committee on the Judiciary: 
United States Senate: 

The Honorable Lamar Smith: 
Chairman: 
The Honorable John Conyers, Jr. 
Ranking Member: 
Committee on the Judiciary: 
House of Representatives: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology:

This report answers the following questions: (1) To what extent does 
overlap across Department of Justice (DOJ) grant programs exist and 
contribute to the risk of unnecessary duplication in grant awards? (2) 
To what extent has DOJ taken steps to reduce overlap in its grant 
programs and the potential for unnecessary duplication in grant 
awards? (3) To what extent does DOJ use programmatic grant monitoring 
and assessment to determine grant program effectiveness and use the 
results to enhance its grant programs?

To examine the extent to which overlap across DOJ grant programs 
exists, we identified the total number of DOJ grant solicitations for 
fiscal year 2010. To do this, we reviewed the lists posted on the 
Office of Justice Programs (OJP), Office on Violence Against Women 
(OWV), and Community Oriented Policing Services (COPS) Office websites 
and confirmed the currency of the information with DOJ officials. To 
determine whether these solicitations were announcing grant funding 
available for similar or overlapping purposes, we first established 10 
categories of criminal justice areas. We developed these 10 categories 
after reviewing comparable justice areas identified within OJP's 
CrimeSolutions.gov website, which OJP officials stated includes themes 
addressed through OVW and COPS Office programs; OJP's Fiscal Year 2010 
Program Plan; and other materials from OVW and the COPS Office, such 
as justice program themes from their respective websites. Next, 
through analyst consensus, we sorted the grant solicitations according 
to the 10 justice categories. After identifying solicitations with 
similar scopes, we then reviewed 26 successful grant applications that 
were awarded under similar solicitations to identify and assess 
specific examples of how the recipients planned to use funds from 
multiple programs in the same or similar manner. The sample we 
reviewed is not generalizable to all DOJ grant programs because we did 
not review all of the more than 11,000 grant applications that DOJ 
funded in fiscal year 2011, but it illustrates the potential for 
unnecessary duplication. To determine if DOJ could take more action to 
avoid program overlap that can lead to unnecessary duplication, we 
applied the Domestic Working Group Grant Accountability Project's 
Guide to Opportunities for Improving Grant Accountability.

To examine the extent to which DOJ has taken steps to reduce overlap 
in its grant programs and the potential for unnecessary duplication in 
grant awards, we reviewed agency policies, procedures, and guidance on 
grant program design and award, such as the COPS Office Program 
Development Team charter and template, and the OJP Grant Manager's 
Manual. Further, we interviewed DOJ officials from the three granting 
agencies to obtain additional information on grant program design and 
award processes, and the extent to which the three agencies coordinate 
and share information. We also visited or conducted phone interviews 
with officials from 11 states, including the five largest and five 
smallest state recipients of Edward Byrne Memorial Justice Assistance 
Grant (JAG) funding. These officials represent the state administering 
agencies (SAA) responsible for distributing JAG and other DOJ formula 
block grant funds to subrecipients in California, Florida, New York, 
North Dakota, Pennsylvania, South Dakota, Rhode Island, Tennessee, 
Texas, Vermont, and Wyoming. These officials provided their views 
regarding the type and timeliness of information on grant awards and 
subawards they provide to and receive from DOJ. We selected these 11 
states based on the amount of JAG funding they receive and the 
existence of other recipients in their communities receiving DOJ 
discretionary grants for potentially similar purposes. The results of 
these contacts are not generalizable to all states, but provided 
insight into how DOJ grant funds are used locally and into the 
communication between states and DOJ. To determine if JAG recipients 
expended grant funds in fiscal year 2010 on sexual assault services, 
bullet and stab-resistant vests, sex offender registry and 
notification systems, Internet crime against children task forces, 
hiring police officers, and correctional officer salaries, we 
conducted a web-based survey of all recipients of DOJ JAG grant 
funding who received an award from fiscal years 2005 through 2010. The 
survey response rate related to SAAs was 89 percent, with 50 out of 56 
SAAs answering the questionnaire. We compared agency grant design and 
award practices against Standards for Internal Control in the Federal 
Government and promising practices identified in the Domestic Working 
Group Grant Accountability Project's Guide to Opportunities for 
Improving Grant Accountability.

To analyze the extent to which DOJ uses programmatic grant monitoring 
and assessment to determine grant program effectiveness and uses the 
results to enhance its grant programs, we analyzed DOJ documentation, 
such as assessments DOJ conducted of its own programs and specific 
programmatic grant monitoring reports. We also interviewed DOJ 
officials from the granting agencies, including those tasked with 
assessment, as well as contractors responsible for assessing grant 
programs for OVW. This report focuses solely on the types of 
assessment conducted by DOJ granting agencies on its grant programs. 
Training and technical assistance provided by the department and its 
program offices and bureaus to grantees to support the evaluation of 
individual grant projects, such as the Bureau of Justice Assistance 
(BJA) Center for Program Evaluation and Performance Measurement, is 
not included in this report. Also excluded from this report are the 
outcome evaluations of the impact of grant programs such as those 
funded by the National Institute of Justice (NIJ). 

[End of section] 

Appendix II: DOJ Granting Agencies' Organizational Structure: 

[Refer to PDF for image: organizational chart] 

Top level: 
Office of the Attorney General: 

Second level, reporting to Office of the Attorney General: 
Deputy Attorney General. 

Third level, reporting to Deputy Attorney General: 
Associate Attorney General. 
 
Fourth level, reporting to Associate Attorney General: 
COPS Office; 
OVW; 
OJP: 
* Office of Audit, Assessment, and Management; 
* Bureau of Justice Assistance; 
* Office of Juvenile Justice and Delinquency Prevention; 
* Bureau of Justice Statistics; 
* Office for Victims of Crime; 
* National Institute Justice; 
* Office of Sex Offender Sentencing, Monitoring, of Apprehending, 
Registering, and Tracking. 

Source: GAO analysis of DOJ information. 

[End of figure] 

[End of section] 

Appendix III: Structure, Purpose, and Funding of DOJ Granting Agencies:

Establishment and structure: 
OJP: OJP, established by the Justice Assistance Act of 1984, is the 
primary grant-making arm of DOJ. A presidentially appointed Assistant 
Attorney General leads OJP. The Assistant Attorney General and all OJP 
bureau heads are presidentially appointed and confirmed by the Senate; 
OJP Bureaus and Offices: 
* Bureau of Justice Assistance; 
* Bureau of Justice Statistics; 
* National Institute of Justice; 
* Office of Juvenile Justice and Delinquency Prevention; 
* Office for Victims of Crime; 
* Office of Sex Offender Sentencing, Monitoring, Apprehending, 
Registering and Tracking; 
OVW: Following the enactment of the Violence Against Women Act of 
1994, the department established the Violence Against Women Office, 
which later became OVW under OJP. OVW now functions as a separate and 
distinct office within DOJ and is headed by a presidentially 
appointed, Senate-confirmed Director; 
COPS Office: The Attorney General established the COPS Office in 
October 1994 to administer community policing grants authorized under 
the Violent Crime Control and Law Enforcement Act of 1994. The 
Attorney General appoints a Director to head the COPS Office. 

Purpose: 
OJP: OJP provides grants to various organizations, including state and 
local governments, universities, and private foundations, which are 
intended to develop the nation's capacity to prevent and control 
crime, administer justice, and assist crime victims; 
OVW: OVW administers financial and technical assistance to local, 
state, and tribal governments; courts; nonprofit organizations; 
community-based organizations; secondary schools; institutions of 
higher education; and state and tribal coalitions. OVW provides grants 
for developing programs, policies, and practices aimed at ending 
domestic violence, dating violence, sexual assault, and stalking; 
COPS Office: The COPS Office provides grants to and shares information 
with the state, local, territory, and tribal law enforcement agencies 
to advance community policing. 

Programs and funding: 
OJP: From fiscal years 2005 to 2012, OJP received approximately $24 
billion for OJP grant programs. In 2010, almost 3 billion was 
available to OJP to fund grants, and OJP issued 223 solicitations for 
grants.[A] According to OJP, it awarded nearly 5,000 grants in 2010; 
OVW: From fiscal years 2005 to 2012, OVW received approximately $3.4 
billion for OVW grant programs. In 2010, OVW received $418.5 million 
for OVW grant programs, and OVW issued 19 solicitations for grants; 
COPS Office: From fiscal years 2005 to 2012, the COPS Office received 
approximately $5.3 billion to fund COPS Office grant programs; 
In 2010, the COPS Office received $791.6 million to fund COPS Office 
grants, and the COPS Office issued nine solicitations for grants. 

Source: GAO analysis of information from DOJ.

Note: Funding levels in fiscal year 2009 include amounts appropriated 
through the American Recovery and Reinvestment Act of 2009. See Pub. 
L. No. 111-5, 123 Stat. 115, 129-30.

[A] Solicitations are announcements of new grant funding available and 
explain areas for which funding can be used. These numbers reflect 
solicitations provided by each individual office and do not reflect 
any joint solicitations, which are those offered in tandem with other 
program offices, either within or external to DOJ (e.g., other DOJ 
components or federal agencies). 

[End of table] 

[End of section] 

Appendix IV: Consolidated, Braided, and Blended Grant Program 
Solicitations:

According to DOJ officials, there are three ways in which DOJ grant 
programs can be merged or better coordinated--through consolidation, 
braiding, and blending. Figures 4,5, and 6 explain these mechanisms.

Figure 4: Consolidated Grant Programs:

[Refer to PDF for image: illustration] 

1. Children and Youth Exposed to Violence Grant Program; 
2. Engaging Men and Youth Program; 
3. Services to Advocate for and Respond to Youth Grant Program; 
4. Services, Training, Education and Policies to Reduce Domestic 
Violence, Dating Violence, Sexual Assault and Stalking in Secondary 
Schools (STEP) Grant Program. 

Consolidated: 
Cost efficiencies may be achieved for fiscal year 2012 by 
consolidating OVW grant programs.  
Four grant programs consolidated into single grant program.   
     
Consolidated Youth Oriented Program. 
     
Source: GAO analysis of DOJ information. 

[End of figure]

Figure 5: Braided Grant Programs:

[Refer to PDF for image: illustration] 

Ten Independent Solicitations Prior to Braiding: 

OJP solicitations: 
1. Indian Alcohol and Substance Abuse Prevention Program (BJA)-—
prevent and reduce alcohol- and substance abuse-related crimes. 

2. Tribal Courts Assistance Program (BJA)-—develop and enhance the 
operation of tribal justice systems. 

3. Correctional Facilities on Tribal Land Program (BJA)-—plan, 
renovate, or construct correctional or correctional alternative 
facilities. 

4. Tribal Elder Outreach Program (OVC)-—provide community outreach and 
victim assistance services to address elder abuse. 

5. Tribal Youth Program (0JJDP)-—prevent and control delinquency and 
improve the juvenile justice system. 

6. Tribal Youth Program (OJJDP)—develop new demonstration projects on 
violence prevention and rehabilitation. 

7. Tribal Juvenile Accountability Discretionary Program (OJJDP)-—
enhance accountability for delinquent behavior. 

COPS Office solicitations: 
   
8. Tribal Resources Grant Program-—improve public safety and enhance 
community policing capacity. 

OVW solicitations: 

9. Tribal Sexual Assault Services Program—-provide direct intervention 
and related assistance to victims of sexual assault. 

10. Tribal Governments Program-—enhance responses to violence 
committed against Indian women and girls. 

Braided: 
DOJ Coordinated Tribal Assistance Solicitation: 
DOJ reports that it reduced the  administrative burden for federally 
recognized Native American tribes who applied for funding. 
  
Ten grant programs are now announced in a single grant solicitation. 

Source: GAO analysis of DOJ information.

[End of figure]

Figure 6: Blended Grant Programs:

[Refer to PDF for image: illustration] 

1. Pathways to success. 
2. Juvenile Mentoring Programs (JUMP). 
3. Family strengthening and support services. 
4. Mental health services for at-risk and adjudicated youth
5. Delinquency prevention programs. 
6. Comprehensive communitywide approaches to gang-free schools and 
communities. 
7. Community-based day treatment programs—Bethesda Day Treatment 
Center model. 
8. Continuum-of-care services for at-risk and delinquent girls. 
9. Serious, Violent, and Chronic Juvenile Offender (SVCJO) programs. 

Blended: 
This blending involved the pooling of differing grant program funding 
streams into a single program to address juvenile delinquency. 

Safe Futures Demonstration Grant Program: 
Nine grant programs are now announced and managed as a single grant 
program. 
Source: GAO analysis of DOJ information. 

[End of figure] 

[End of section] 

Appendix V: Office of Audit Assessment and Management Structure:

The three divisions within OAAM--the Audit and Review Division, the 
Program Assessment Division, and the Grants Management Division-- 
together carry out the following primary functions of OAAM for one or 
more of DOJ's three granting agencies:

Audit and Review Division:

* coordinates audits, such as Single Audits that independent 
nongovernmental auditors conduct, as well as those that the Inspector 
General (IG) and GAO conduct,[Footnote 64]

* reviews internal control processes (A-123),[Footnote 65] and:

* manages DOJ's High Risk Grantee Program, which applies criteria to 
identify grantees most at risk of fraud, waste, or abuse in use of 
their grant funds.

Program Assessment Division:

* oversees OJP and COPS Office programmatic monitoring, including 
development and implementation of standards and protocols, and:

* assesses grant programs and initiatives of OJP and the COPS Office, 
as well as operational activities.

Grants Management Division:

* serves as the primary resource for OJP grants management policies 
and procedures by producing authoritative guidance,

* develops and facilitates grants related training to staff and 
grantees,

* manages Grants Management System (GMS) and other tools and systems, 
and:

* facilitates OJP's business process improvement efforts. 

[End of section] 

Appendix VI: Comments from the Department of Justice: 

U.S. Department of Justice: 
Washington, DC 20530: 

June 29, 2012: 

Mr. David C. Maurer: 
Director: 
Homeland Security and Justice Issues: 
Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Mr. Maurer: 

Thank you for the opportunity to review and comment on the draft 
Government Accountability Office (GAO) report entitled, "Justice Grant 
Programs: DOJ Should do More to Reduce the Risk of Unnecessary 
Duplication and Enhance Program Assessment" (GA0-12-517). 

Improving the effectiveness and efficiency of Federal programs is a 
critical priority of the U.S. Department of Justice (DOJ, Department), 
DOJ appreciates the work of the GAO and has carefully considered the 
findings and recommendations presented in GAO's draft report. DOJ 
agrees that, especially in the current fiscal climate, preventing 
unnecessary duplication in government programs is a critical priority. 
Under this Administration, the Department's grant-making agencies -- 
the Office of Justice Programs (OJP), the Office on Violence Against
Women (OVW), and the Office of Community Oriented Policing Services 
(COPS Office) — have significantly improved collaboration and 
information-sharing among themselves and other Federal agencies to 
identify overlap and mitigate the risk of duplicative federal spending. 

The Department is committed to continuing efforts to prevent 
unnecessary duplication, identify overlap in programs, and streamline 
through approaches such as the consolidation of grant programs. The 
Department's grant-making components will continue to coordinate with 
one another to ensure sound stewardship and management of the 
Department's funds. 

The Department would like to take this opportunity to reiterate its 
concerns and overarching comments on the draft report and findings. 

(1) In DOJ's response to GAO's annual report on duplication and 
overlap released in February 2012, DOJ expressed significant concerns 
with GAO's methodology and identified what it believes are problematic 
flaws in its methodology and analysis. GAO uses the same methodology 
and analysis in this review, and accordingly, DOJ must reiterate its 
concerns. Specifically, the Department believes that the flawed 
methodology used by GAO in analyzing potential overlap between DOJ 
funding solicitations, resulted in a substantial overstatement of the 
number of programs that might be duplicative. In its analysis, the GAO 
has distilled 253 grant solicitations issued by the three grant-making 
components into 10 broad justice areas. This distillation is 
problematic and misleading. First, it conflates clearly disparate 
areas of topics, including research; statistical collections; 
provision of training or technical assistance to outside 
organizations; and, direct service delivery. While the broad topical 
areas may be the same, the purposes are distinctly different and 
represented a coordinated approach to addressing justice issues. 
Second, many of the programs within the 10 broad categories have very 
different eligibility requirements associated with their unique 
purposes, and thus, they cannot be duplicative. 

GAO's reliance on this oversimplified and imprecise approach serves to 
produce large number of solicitations in each broad category, but does 
not represent wasteful duplication or a situation where funds should 
necessarily be divided to another category. Narrowing the justice 
areas would have provided for a more informative analysis of where DOJ 
funding is being applied. For example, the "technology and forensics" 
category is extraordinarily and unnecessarily expansive. Refining this 
justice area — such as information sharing standards development, 
criminal intelligence sharing, criminal record and system 
improvements, DNA backlog reduction, equipment and materials testing — 
would have been more informative, accurate and less misleading. 

These 10 categories also fail to capture the statutory scope and 
purpose of programs that both OVW and the COPS Office administer. GAO 
places 15 of OVW's grant programs in the "victim assistance" category, 
even though only a handful of OVW programs solely fund direct victim 
services: most OVW funding is designed to reform the criminal justice 
system's response to violent crimes against women. For example, GAO 
categorized OVW's Grants to Encourage Arrest Policies and Enforcement 
of Protection Orders program as a victim assistance program, even 
though the primary purpose of that program is to encourage 
jurisdictions to treat domestic violence, dating violence, sexual 
assault, and stalking as serious violations of criminal law. The 
Department regrets that GAO did not include a category specific to 
violence against women, which would better capture OVW programs that 
focus on improving systemic response to these crimes, rather than 
simply assistance to victims. In addition, there is no category in the 
GAO chart that accurately categorizes the COPS Office programs, all of 
which are primarily to advance public safety through the practice of 
community policing in the nation's state, local, territories, and tribal
law enforcement agencies. Furthermore, the COPS Office programs are 
the only DOJ-funded programs principally devoted to advancing public 
safety through the practice of community policing, and should, 
therefore be listed together in their own category. 

Additionally, GAO relied on a very small sample of grant applications 
to assess and generalize the extent of duplication across multiple 
components. Specifically, the GAO reviewed 26 out of approximately 
7,000 grants as a sample, or less than half of one percent, of the 
fiscal year (FY) 2010 DOJ grants thereby limiting its ability to 
generalize its findings. For those examples cited by GAO as potential 
duplication and where GAO agreed to identify the specifics of the 
examples, DOJ examined the cases and found no unnecessary or 
inappropriate duplication. Given that the sample by GAO's admission is 
too small and not generalizable and no actual duplication was 
identified by GAO, it is unclear how the sample reviewed by GAO is 
evidence of the potential for unnecessary duplication.

(2) As related to proper oversight of grants and subgrants, DOJ finds 
it necessary to establish that the grant-making components do in fact 
monitor, track, and assess the flow of grant funds to subgrantees. GAO 
statements throughout the draft report imply that DOJ is not 
monitoring or tracking funds of subgrantees. DOJ uses many mechanisms 
to monitor its prime recipients granting of subawards and obtain 
information on these subgrantees, including: 1) site visits and other 
monitoring activities; 2) grantee data submitted through OJP's Grants 
Management System's (GMS) subaward module, progress reports, and 
performance measurement tools; 3) single and grant audit findings; 4) 
annual subgrantee progress reports; 5) quarterly Recovery Act reports 
submitted to Federalreporting.gov; and 6) prime recipient reports 
submitted to the Federal Subaward Reporting System and posted on 
USASpending.gov. 

The draft GAO report contains eight Recommendations for Executive 
Action to the DOJ, which are restated in bold text below and are 
followed by our response. 

To ensure that DOJ can identify overlapping grant programs to either 
consolidate or coordinate similar programs, mitigate the risk of 
unnecessary grant award duplication in its programs, and enhance DOJ's 
ability to gauge grant program effectiveness, we recommend that the 
Attorney General take the following eight actions: 

1. Conduct an assessment to better understand the extent to which the 
department's grant programs overlap with one another and determine if 
grant programs may be consolidated to mitigate the risk of unnecessary 
duplication. To the extent that DOJ identifies any statutory obstacles 
to consolidating its grant programs, it should work with Congress to 
address them, as needed. 

The Department agrees with the Recommendation for Executive Action. 
DOJ will explore options to carry out an assessment for the purposes 
of determining the extent of unnecessary or inappropriate duplication 
(if any) and the risk associated with unnecessary or inappropriate 
program duplication within and across OW, OVW, and COPS Office funding 
programs. One option under consideration is to dedicate resources from 
its Office of Audit, Assessment, and Management (OAAM) to conduct such 
a study. 

2. Coordinate within and among granting agencies on a consistent basis 
to review potential or recent grant awards from grant programs that 
DOJ identifies as overlapping, including subgrant awards reported by 
prime grant awardees, to the extent possible, before awarding grants. 
DOJ should also take steps to establish written policies and 
procedures to govern this coordination and help ensure that it occurs. 

The Department agrees with the Recommendation for Executive Action. 
The DOJ grant-making agencies will continue to closely collaborate on 
the development and implementation of grant programs and share 
information with each other to improve coordination prior to making 
awards. Using results from the DOJ assessment referred to
in Recommendation 1, DOJ will be in a better position to develop a 
targeted and strategic approach to carry out a review of applications 
across all three components during the pre-award process. As part of 
this approach, DOJ will work to establish policies and procedures to 
govern this coordinated effort. 

3. Require its grant applicants to report all federal grant funding, 
including all DOJ funding, that they are currently receiving or have 
recently applied for in their grant applications. 

The Department agrees with the Recommendation for Executive Action. 
The results of the DOJ assessment referred to in Recommendation I will 
be used to guide DOJ on determining the appropriate breadth, scope, 
and application of this requirement. In the interim, each grant-making 
component will continue, upon issuing a solicitation, to make a 
determination whether information from its applicants on other Federal 
grant funding, as related to the purposes of the solicitation, would 
better inform its award decisions. For example, as presented in the 
GAO draft report, OVW determined that in FY 2012, four of its grant 
programs would obtain data from applicants on other Federal grant 
funding.[Footnote 1] Similarly, in FY 2012, OJP's Office for Victims 
of Crime determined it was beneficial to request information on all 
sources of funding under its Wraparound Victim Legal Assistance 
Network Demonstration Project Solicitation. 

4. Provide appropriate OJP and COPS Office staff with access to both 
GMS and CMS and appropriate OVW staff with access to CMS. 

The Department agrees with the Recommendation for Executive Action, 
where this is technologically possible. OJP's Office of Chief 
Information Officer (OCIO) will provide COPS Office staff with read-
only access to GMS and the Grants Payment Request System (GPRS). 

The existing legacy version of the CMS application is not designed to 
enable access to users external to the COPS Office. However, the COPS 
Office is able to provide OJP and OVW with reports of CMS data and 
will work with OJP and OVW to provide such reports. In addition, COPS 
will pursue opportunities to leverage enterprise reporting systems 
managed by OJP when technically feasible. 

Finally, one of the primary goals of the feasibility study referenced 
in Recommendation 5 is to improve information and data sharing among 
the grant-making components. 

5. Ensure that the planned evaluation of the feasibility, costs, and 
benefits of moving to a single grants management system include an 
assessment of the steps needed to harmonize DOJ grant processes so 
that any variation in how the granting agencies manage their 
portfolios is not an encumbrance to potential system unification. 

The Department agrees with the Recommendation for Executive Action. 
OJP, OVW, and the COPS Office have initiated the feasibility study. 
The project kickoff meeting has been concluded and the first 
interviews were conducted on June 5, 2012. DOJ anticipates the study 
to be completed within the next six months. Identifying potential 
"harmonizing steps" represent one, but not all, facets of the study.

6. Ensure the most timely reporting possible of grant award 
information to USASpending.gov according to OMB guidelines, which 
would enable its grantees to comply with their reporting 
responsibilities according to the same guidelines. 

The Department agrees with the Recommendation for Executive Action. 
DOJ agrees that timely reporting and posting of grant award 
information to USASpending.gov is critical to ensuring the 
accountability and transparency of Federal funding. As such, OJP will 
continue to do its best, within the constraints and limitations of the 
current reconciliation and remediation process, to timely make DOJ's 
grant information publicly available at USASpending.gov. Additionally, 
OJP will continue to inform the Office of Management and Budget (OMB) 
of the challenges and obstacles it faces under the current reporting 
regimen established by OMB and Grants.gov. 

7. Assess whether OAAM relies on an appropriate mix of grant 
monitoring and program assessment, and determine whether the Office 
could support additional program assessments. 

The Department agrees with the Recommendation for Executive Action. In 
March 2011 the DOJ Office of the Inspector General (OIG) issued an 
audit report on OJP's monitoring and oversight of Recovery Act and Non-
Recovery Act grants (Audit Report 11-19). As part of this review, OIG 
found that: 

"While OJP could have chosen to use the 3 percent of annual grant 
funding allowed by law to establish a much larger staff within OAAM to
actually perform the on-site monitoring of grants awarded, it chose 
instead to implement a model in which the OJP program offices and 
bureaus use existing staff to perform on-site monitoring of grants 
awarded, and OAAM provides oversight and review of the monitoring 
performed by the program offices and bureaus. We believe that OJP and 
OAAM, while initially slow to implement this approach, have developed 
a reasonable approach for monitoring and overseeing Department grants." 

Relying on the work of its OIG, the Department supports OJP's approach 
to monitoring and oversight. 

The Department agrees that based on results of previous assessments, 
additional program assessments would be beneficial and would 
contribute to the improvement of grant programs and operations. 
However, the breadth of work carried out by OAAM, must, to the 
greatest extent possible, be informed by the corresponding funding 
available and the current resource environment. That said, DOJ will 
continue to explore creative and cost effective ways to support 
additional assessments. 

8. Assess the feasibility, costs, and benefits of OAAM providing 
assessments for OVW, in addition to OJP and the COPS Office. If DOJ 
determines that OAAM assessments of OVW grant programs would be more 
cost-effective and provide greater insight into the effectiveness of 
OVW grant programs than OVW's current approach, then the Attorney 
General should extend OAAM's oversight to include OVW. 

The Department agrees with the Recommendation for Executive Action. 
OJP and OVW have initiated discussions regarding OAAM functions and 
services and whether they might benefit OVW and its grantees. Although 
OAAM program assessments may enhance OVW's performance by tracking 
compliance with procedures and identifying program deficiencies, OVW 
does not anticipate that they would replace OVW's measuring 
effectiveness initiative. OAAM program assessments do not include all 
the components of OVW's current approach to measuring the 
effectiveness of its grantees' activities, including extensive 
training and technical assistance to grantees to support their data 
collection efforts, cleaning of grantee data, and an ongoing review of 
existing research to ensure that OVW-funded programs reflect current 
knowledge regarding best and evidence-based practices. 

If I may be of further assistance to you, please do not hesitate to 
contact me. Your staff may also contact Louise Duhamet, Acting 
Assistant Director, Audit Liaison Group on 202-514-0469. 

Sincerely, 

Signed by: 

Lee J. Loftus: 
Assistant Attorney General for Administration: 

cc: Tony West: 
Acting Associate Attorney General: 

Anna Martinez: 
Senior Advisor to the Associate Attorney General: 
Office of the Associate Attorney General: 

Mary Lou Leary: 
Acting Assistant Attorney General: 
Office of Justice Programs: 

Beatrice Hanson: 
Acting Director: 
Office on Violence Against Women: 

Bernard Melekian: 
Director: 
Office of Community Oriented Policing Services: 

Louise Duhamel, Ph.D. 
Acting Director, Audit Liaison Group: 
Internal Review and Evaluation Office: 
Justice Management Division: 

James H. Burch, II: 
Deputy Assistant Attorney General for Operations and Management: 
Office of Justice Programs: 

Maureen Henneberg: 
Director: 
Office of Audit, Assessment, and Management: 
Office of Justice Programs: 

Rebekah Whiteaker: 
Chief of Staff: 
Office of Community Oriented Policing Services: 

Appendix VI Footnote: 

[1] As explained in the Department's technical comments, OVW included 
this provision in four of its FY 2012 solicitations, not its FY 2013 
ones, which have not yet been released. 

[End of section] 

Appendix VII: GAO Contact and Staff Acknowledgments:

GAO Contact:

David C. Maurer, (202) 512-9627 or maurerd@gao.gov:

Staff Acknowledgments:

In addition to the contact named above, Joy Booth, Assistant Director, 
and Christian Montz, Analyst-in-Charge, managed this assignment. Julie 
E. Silvers, Marya Link, Caitlin Carlberg, and Michael Sweet made 
significant contributions to the work. Michele Fejfar assisted with 
design and methodology. Janet Temko and Tom Lombardi provided legal 
support. Lara Miklozek provided assistance in report preparation.

[End of section] 

Footnotes: 

[1] In addition to fiscal year funding from 2005 through 2012, this 
amount includes $4 billion appropriated in fiscal year 2009 through 
the American Recovery and Reinvestment Act of 2009 (Recovery Act) 
(Pub. L. No. 111-5, 123 Stat. 115, 129-30), which includes $10 million 
for salaries and expenses to manage, administer, and oversee the grant 
programs. This approximate amount does not reflect amounts, if any, 
that have been rescinded, reprogrammed, or transferred. 

[2] Federal financial assistance programs provide funding pursuant to 
statutory authorization through formula grants, discretionary grants, 
cooperative agreements, and other payment programs, but are all 
generally referred to as grants. Formula grant programs are 
noncompetitive awards based on a predetermined formula, typically 
established in statute. Discretionary grants are usually awarded on 
the basis of a competitive selection process. A cooperative agreement 
is a type of federal financial assistance similar to a grant except 
the federal government is more substantially involved with the grant. 
Payment programs typically take the form of reimbursements to state 
and local law enforcement entities for purchases such as body armor. 

[3] COPS Office, however, prohibits grantees from subawarding any 
portion of COPS Office grants.

[4] GAO, Major Management Challenges and Program Risks: Department of 
Justice, [hyperlink, http://www.gao.gov/products/GAO-03-105] 
(Washington, D.C:. Jan. 1, 2003).

[5] GAO, Community Policing Grants: COPS Grants Were a Modest 
Contributor to Declines in Crime in the 1990s, [hyperlink, 
http://www.gao.gov/products/GAO-06-104] (Washington, D.C.; Oct. 14, 
2005); Combating Gangs: Better Coordination and Performance 
Measurement Would Help Clarify Roles of Federal Agencies and 
Strengthen Assessment of Efforts, [hyperlink, 
http://www.gao.gov/products/GAO-09-708] (Washington, D.C.: July 24, 
2009); and Recovery Act: Department of Justice Could Better Assess 
Justice Assistance Grant Program Impact, [hyperlink, 
http://www.gao.gov/products/GAO-11-87] (Washington, D.C.: Oct. 15, 
2010). 

[6] U.S. Department of Justice Office of the Inspector General, Audit 
Division, Streamlining of Administrative Activities and Federal 
Financial Assistance Functions in the Office of Justice Programs and 
the Office of Community Oriented Policing Services, Audit Report 03-27 
(Washington D.C.: Aug. 2003).

[7] Hearing before the U.S. House of Representatives Committee on 
Oversight and Government Reform Subcommittee on Technology, 
Information Policy, Intergovernmental Relations and Procurement Reform 
concerning Improving Oversight and Accountability in Federal Grant 
Programs, June 23, 2011.

[8] GAO, 2012 Annual Report: Opportunities to Reduce Duplication, 
Overlap, and Fragmentation, Achieve Savings, and Enhance Revenue, 
[hyperlink, http://www.gao.gov/products/GAO-12-342SP] (Washington, 
D.C.: Feb. 28, 2012).

[9] We conducted this work in support of our mandate to conduct 
routine investigations to identify programs, agencies, offices, and 
initiatives with duplicative goals and activities within departments 
and governmentwide, and report annually to Congress. See Pub. L. No. 
111- 139, § 21, 124 Stat. 8, 29-30 (2010) (31 U.S.C. § 712 Note). As 
such, we included portions of this report in our 2012 annual report. 
See [hyperlink, http://www.gao.gov/products/GAO-12-342SP].

[10] [hyperlink, http://www.gao.gov/products/GAO-12-342SP]. 

[11] We selected California, Florida, New York, North Dakota, 
Pennsylvania, South Dakota, Rhode Island, Tennessee, Texas, Vermont, 
and Wyoming.

[12] DOJ established the JAG program following enactment of the 
Violence Against Women and Department of Justice Reauthorization Act 
of 2005, which merged the Edward Byrne Memorial State and Local Law 
Enforcement Assistance Program with the Local Government Law 
Enforcement Block Grants Program. See Pub. L. No. 109-162, § 1111, 119 
Stat. 2960, 3094-3102 (2006). The JAG program is the leading source of 
federal justice funding to state and local jurisdictions. JAG provides 
funding to support a range of program areas, including law 
enforcement; prosecution and courts; prevention and education; 
corrections and community corrections; drug treatment and enforcement; 
planning, evaluation, and technology improvement; and crime victim and 
witness initiatives. The program provides 60 percent of the JAG awards 
directly to the state agencies that administer JAG funds--known as 
state administering agencies (SAA)--and 40 percent of the awards 
directly to local units of government. Local recipients of JAG funding 
can receive money either as a direct payment from the JAG program, as 
a pass- through from the SAA, or, in some cases, from both the program 
and the SAA.

[13] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999); Domestic Working Group, Grant 
Accountability Project, Guide to Opportunities for Improving Grant 
Accountability (Washington, D.C.: October 2005).

[14] Programmatic monitoring is conducted by federal grant program 
staff and includes, among other requirements, a general review of 
grant compliance and grantee progress.

[15] We reported some of our findings in February 2012. See 
[hyperlink, http://www.gao.gov/products/GAO-12-342SP]. 

[16] Grant recipients awarded funds directly from OJP and OVW may in 
turn award them to subrecipients. The COPS Office Prohibits 
subawarding. In the case of the JAG State program, for example, 
grantees are required to pass through--or award through a subgrant--a 
predetermined portion of the funding to local communities. Direct 
grant funding includes all funding awarded by DOJ, including awards 
made to recipients from DOJ's various payment programs. 

[17] GAO, Federal Grants: Improvements Needed in Oversight and 
Accountability Processes, [hyperlink, 
http://www.gao.gov/products/GAO-11-773T] (Washington, D.C.: June 23, 
2011). 

[18] OMB established USASpending.gov in 2007 to comply with the 
Federal Funding Accountability and Transparency Act (FFATA) of 2006. 
See Pub. L. No. 109-282, § 2, 120 Stat. 1186. FFATA required OMB to 
ensure the existence and operation of a single searchable website that 
includes for each federal award: (1) the name of the entity receiving 
the award, (2) the amount of the award, (3) information on the award 
including transaction type and funding agency, (4) the location of the 
entity receiving the award and the primary location of performance 
under the award, and (5) a unique identifier of the entity receiving 
the award; among other information. As of October 2010, 
USASpending.gov has been updated to include first-tier subaward data, 
such as subawards states may distribute using a DOJ grant that was 
awarded to the state.

[19] [hyperlink, http://www.gao.gov/products/GAO-11-773T].

[20] Specifically, the Violence Against Women Act of 2000 provided 
that the Attorney General or Secretary of Health and Human Services, 
as applicable, shall require grantees under any program authorized or 
reauthorized under the act to report on the effectiveness of the 
activities carried out with amounts made available for the program. 
See Pub. L. No. 106-386, Div. B, § 1003(a), 114 Stat. 1464, 1491 
(2000) (codified at 42 U.S.C. § 3789p(a)). It further required the 
Attorney General or Secretary, as applicable, to report biennially to 
the Committees on the Judiciary of the Senate and House of 
Representatives on the grant programs described, including any 
information reported by grantees. See 42 U.S.C. § 3789p(b).

[21] See Pub. L. No. 109-162, § 1158, 119 Stat. 2960, 3114-16 (2006) 
(codified as amended at 42 U.S.C. § 3712h).

[22] The 253 solicitations that we reviewed in August 2011 represent 
those for new grant programs available in fiscal year 2010 that agency 
officials told us were archived on their websites. These solicitations 
are in addition to grant programs that DOJ continues to administer 
from prior fiscal years or more recently began administering. Because 
DOJ's grant awards can last from 1 to 5 years, the total number of 
active DOJ grant programs can be higher than what is presented in 
table 2, which is a single year of grant program solicitations.

[23] [hyperlink, http://www.gao.gov/products/GAO-12-342SP].

[24] OVW's mission is to provide federal leadership in developing the 
nation's capacity to reduce violence against women and administer 
justice for and strengthen services to victims of domestic violence, 
among others. OVC's mission is to enhance the nation's capacity to 
assist crime victims and to provide leadership in changing attitudes, 
policies, and practices to promote justice and healing for all victims 
of crime. 

[25] DOJ's fiscal year 2013 performance budget justification does not 
include a request for funding to continue this grant program.

[26] This number includes all formula, discretionary, and payment 
program awards.

[27] The public website USASpending.gov is designed to make such 
information transparent.

[28] Survey of Indigent Defense Funding from Byrne Memorial Justice 
Assistance Grants, GAO (2012). This survey and the results are 
published in Indigent Defense: Surveys of Grant Recipients, Select 
Tribes, and Indigent Defense Providers [hyperlink, 
http://www.gao.gov/products/GAO-12-661SP], May 2012, an E- supplement 
to [hyperlink, http://www.gao.gov/products/GAO-12-569], [hyperlink, 
http://www.gao.gov/products/GAO-12-661SP] (Washington, D.C. May 30, 
2012). The survey was conducted to support the GAO report: Indigent 
Defense: DOJ Could Increase Awareness of Eligible Funding and Better 
Determine the Extent to Which Funds Help Support This Purpose, 
[hyperlink, http://www.gao.gov/products/GAO-12-569] (Washington, D.C.: 
May 9, 2012). "Indigent defense," as we used the term in that report, 
refers to direct and indirect activities that help ensure indigent 
defendants are afforded counsel in criminal cases, and includes 
activities such as hiring additional public defenders, investigators, 
or other support staff; providing training for public defenders; and 
making technological improvements in defenders' offices or systems. In 
fiscal year 2010, all SAA JAG recipients, except for U.S. territory 
SAAs, subawarded some of their awards. Thirty-two of the 50 state SAAs 
subawarded a majority of their JAG funding. More information on the 
survey is included in appendix I.

[29] Eight of the 50 responding SAAs, or about 16 percent, reported 
that they or their subgrantees used JAG funding to support sex 
offender registry and notification systems; 11 out of the 50, or 22 
percent, reported JAG funding was used to support sexual assault 
services; 15 out of the 50, or 30 percent, reported funding was used 
to support bullet-resistant vest purchases. 

[30] The COPS Office hiring grant awarded to this county was for 
fiscal year 2009. COPS Office hiring grants last up to 3 years, and 
the county used the grant in fiscal years 2010 and 2011 as well. These 
grants support the hiring or the rehiring of career law enforcement 
officers to increase community policing and crime prevention strategies.

[31] According to DOJ officials, existing oversight mechanisms, such 
as programmatic and financial monitoring, as well as IG audits, help 
them ensure that grantees only expend federal financial assistance for 
allowable costs approved by DOJ in applicants' budgets. 

[32] U.S. Department of Justice Office of the Inspector General, Audit 
Division, Streamlining of Administrative Activities and Federal 
Financial Assistance Functions in the Office of Justice Programs and 
the Office of Community Oriented Policing Services, Audit Report 03-27 
(Washington D.C.: Aug. 2003).

[33] U.S. Department of Justice Office of the Inspector General, Audit 
Division, A Review of the Selection Process for the COPS Hiring 
Recovery Program, Audit Report 10-25 (Washington D.C.: May 2010).

[34] The Domestic Working Group is composed of 18 federal government 
inspectors general, other state and local audit organizations, and is 
chaired by the Comptroller General of the United States.

[35] DOJ designates grantees as high risk based on a number of 
factors, including but not limited to, a history of unsatisfactory 
performance, financial instability, an inadequate financial management 
system, or nonconformance to terms and conditions of previous awards. 
Additional reporting requirements are imposed on high-risk recipients. 
OAAM's Audit and Review Division coordinates the high-risk grantee 
list and works to either resolve the issues underlying the high-risk 
designation or to impose conditions on high-risk grantees to ensure 
appropriate stewardship of federal funds and enhance programmatic 
results.

[36] Special conditions set forth specific terms that grantees must 
meet, in addition to the general conditions associated with the grant, 
in order to receive funds.

[37] In fiscal year 2009, OVW required applicants from its OVW 
Recovery Act grant program to identify other sources of DOJ funding on 
their grant applications and as a grant special condition, required 
recipients to inform OVW if they receive any other DOJ funding during 
the term of the grant. This process was repeated for a different OVW 
grant program in fiscal year 2010. Additionally, OJP issued 2 grant 
program solicitations for fiscal year 2012 requiring applicants to 
report all pending federal and state grant applications which propose 
to support the same project and the same costs in both applications. 

[38] U.S. Department of Justice Office of the Inspector General, Audit 
Division, Streamlining of Administrative Activities and Federal 
Financial Assistance Functions in the Office of Justice Programs and 
the Office of Community Oriented Policing Services, Audit Report 03-27 
(Washington D.C.: Aug. 2003). 

[39] The IG's understanding of OJP and the COPS Office's approach to 
addressing the IG's recommendation, as stated in their response to the 
agencies' review of the report, was that the agencies will develop 
procedures to ensure that duplicative awards are not made to the same 
grantee for similar purposes. 

[40] The American Recovery and Reinvestment Act of 2009 (Recovery 
Act), Pub. L. No. 111-5, 123 Stat 115, was enacted on February 17, 
2009. See Pub. L. No. 111-5, 123 Stat. 115. Purposes of the act 
include promoting economic recovery, providing investments needed to 
increase economic efficiency, and stabilizing state and local 
government budgets to minimize and avoid reductions in essential 
services. DOJ awarded grants under a variety of Recovery Act grant 
programs. 

[41] There is a cross-DOJ system for financial management, the 
Financial Management Information System 2 (FMIS 2), that can be used 
to identify awards and grant disbursements, but it does not show the 
intended purpose of the grants or grant information related to grant 
activities grantees currently have under way. 

[42] These costs include software and hardware upgrade acquisitions 
and maintenance but do not include costs such as user training for 
each system. In the case of GMS costs, a portion of the costs was 
capitalized from 2008 through 2013. Had those costs not been 
capitalized, GMS costs would appear higher for this 3-year period. 

[43] See 42 U.S.C. § 3712h(g) (providing that the OAAM Director shall 
establish and maintain such a system in consultation with the chief 
information officer of the office).

[44] U.S. Department of Justice Office of the Inspector General, Audit 
Division, A Review of the Selection Process for the COPS Hiring 
Recovery Program, Audit Report 10-25 (Washington D.C.: May 2010).

[45] Both OVW and FEMA pay OJP to use GMS through an interagency 
agreement, and the rates they have paid in the last 5 years have 
remained relatively stable. 

[46] See Pub. L. No. 109-282, 120 Stat. 1186 (2006).

[47] To support OMB efforts, GSA hired a vendor to maintain the FFATA 
reporting infrastructure including the FFATA Subaward Reporting System 
(FSRS.gov), a federal government website used by federal contractors 
and grantees to submit data such as subaward information to 
USASpending.gov, and the USASpending.gov websites. In 2010, 
USASpending.gov logged 1.8 million website visits.

[48] Office of Management and Budget, Memorandum for the Heads of 
Departments and Agencies: Guidance on Data Submission under the 
Federal Funding Accountability and Transparency Act, M-09-19 
(Washington, D.C.: June 1, 2009).

[49] DOJ typically submits batches of grant award information, and 
each batch can contain hundreds of distinct grant awards. Under 
current OMB guidelines, if more than 10 percent of the awards in the 
batch contain errors, such as mistakes in the codes uniquely assigned 
to grantees, the entire batch of grant award information is rejected. 
Upon receipt of the batch returned, DOJ is then charged with reviewing 
the entire batch and correcting the identified errors before GSA will 
post it. 

[50] See 42 U.S.C. § 3712h(b), (c).

[51] DOJ designates grantees as high risk based on a number of 
factors, including but not limited to, a history of unsatisfactory 
performance, financial instability, an inadequate financial management 
system, or nonconformance to terms and conditions of previous awards. 
Additional reporting requirements are imposed on high-risk recipients. 
OAAM's Audit and Review Division coordinates the high-risk grantee 
list and works to either resolve the issues underlying the high-risk 
designation or to impose conditions on high-risk grantees to ensure 
appropriate stewardship of federal funds and enhance programmatic 
results.

[52] OAAM considered eight of its products to be program assessments. 
However, we eliminated one because it did not specifically look at a 
DOJ grant program.

[53] In 2011, OAAM issued assessment reports for the Bureau of Justice 
Assistance Recovery Act Programs Combating Criminal Narcotics Activity 
Stemming from the Southern Border of the United States (CCNA program), 
and the Assistance to Rural Law Enforcement to Combat Crime and Drugs 
(RLE program).

[54] This assessment included the following programs: the Bulletproof 
Vest Partnership Program, which assists state, local, and tribal law 
enforcement agencies with purchasing body armor for sworn personnel; 
the State Criminal Alien Assistance Program (SCAAP),which provides 
assistance to states and localities by reimbursing them for 
correctional officer salary costs associated with incarcerating 
undocumented criminal aliens; the Southwest Border Prosecution 
Initiative (SWBPI); and the Northern Border Prosecution Initiative 
(NBPI), which reimburses state, local, and tribal jurisdictions for 
prosecuting criminal cases declined by U.S. Attorneys' offices and for 
pretrial detention expenses in states along the southern and northern 
borders, respectively.

[55] Pursuant to its authorizing statute, not more than 3 percent of 
all funding made available for programs under OAAM's purview in a 
fiscal year shall be available to OAAM for, among other things, 
carrying out and coordinating program assessments. See 42 U.S.C. § 
3712h(a)(2).

[56] In a March 2011 report the IG reported that, as of May 2009, OAAM 
had filled all of its 49 federal employee and contractor positions, 
but in May 2012, OJP reported that OAAM has undergone attrition and is 
currently 20 percent below its authorized staffing level. See U.S. 
Department of Justice, Office of the Inspector General, Audit 
Division, Audit of the Office of Justice Programs' Monitoring and 
Oversight of Recovery Act and Non-Recovery Act Grants, Audit Report 11-
19 (Washington D.C.: March 2011).

[57] Pursuant to the Single Audit Act, as amended, each nonfederal 
entity that expends $500,000 or more in federal awards, including 
grants and other assistance, in a fiscal year must obtain an annual 
"Single Audit," which includes an audit of the entity's financial 
statements and a schedule of the expenditure of federal awards, as 
well as, among other things, a review of related internal controls. 
See 31 U.S.C. §§ 7501-07.

[58] OAAM annually reviews OJP's critical business processes in the 
areas of financial management, information technology, and grant 
management and makes recommendations to enhance and strengthen 
internal controls as required by OMB Circular A-123, "Management's 
Responsibility for Internal Control."

[59] Specifically, the Violence Against Women Act of 2000 provided 
that the Attorney General or Secretary of Health and Human Services, 
as applicable, shall require grantees under any program authorized or 
reauthorized under the act report on the effectiveness of the 
activities carried out with amounts made available for the program. 
See Pub. L. No. 106-386, Div. B, § 1003(a), 114 Stat. 1464, 1491 
(2000) (codified at 42 U.S.C. § 3789p(a)). It further required the 
Attorney General or Secretary, as applicable, to report biennially to 
the Committees on the Judiciary of the Senate and House of 
Representatives on the grant programs described, including any 
information reported by grantees. See 42 U.S.C. § 3789p(b).

[60] Information on which the Attorney General shall report related to 
the effectiveness of activities carried out with VAWA grant funds 
includes the number of persons served and, if applicable, the number 
of persons seeking services who could not be served.

[61] Prior to enactment of the Violence Against Women Act of 2005, 
VAWA required that the Attorney General report annually on the STOP 
Program.

[62] Outputs are the direct products or services delivered by a 
program. Outcomes are the results of those products and services.

[63] OVW's Grant Assessment Tool is a database containing 18 standard 
elements to evaluate the level of risk associated with grantees in 
order to prioritize monitoring.

[64] Pursuant to the Single Audit Act, as amended, each nonfederal 
entity that expends $500,000 or more in federal awards, including 
grants and other assistance, in a fiscal year must obtain an annual 
"Single Audit," which includes an audit of the entity's financial 
statements and a schedule of the expenditure of federal awards, as 
well as, among other things, a review of related internal controls. 
See 31 U.S.C. §§ 7501-07.

[65] Office of Audit, Assessment, and Management (OAAM) annually 
reviews OJP's critical business processes in the areas of financial 
management, information technology, and grant management and makes 
recommendations to enhance and strengthen internal controls as 
required by OMB Circular A-123, "Management's Responsibility for 
Internal Control." 

[End of section] 

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