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Testimony: 

Before the Subcommittee on Insular Affairs, Oceans and Wildlife, 
Committee on Natural Resources, House of Representatives: 

United States Government Accountability Office: 
GAO: 

For Release on Delivery: 
Expected at 2:00 p.m. EDT:
Thursday, July 15, 2010: 

U.S. Insular Areas: 

Interior's Management and Oversight of Insular Area Grants: 

Statement of Anu K. Mittal, Director: 
Natural Resources and Environment: 

GAO-10-917T: 

GAO Highlights: 

Highlights of GAO-10-917T, a testimony before the Subcommittee on 
Insular Affairs, Oceans and Wildlife, Committee on Natural Resources, 
House of Representatives. 

Why GAO Did This Study: 

U.S. insular areas face serious economic and fiscal challenges and 
rely on federal funding to support their governments and deliver 
critical services. The Department of the Interior, through its Office 
of Insular Affairs (OIA), provides about $70 million in grants 
annually, including technical assistance grants, to increase insular 
area self-sufficiency. In the past, GAO and others have raised 
concerns regarding insular areas’ internal control weaknesses, which 
increase the risk of grant fund mismanagement, fraud, and abuse. 

In March 2010, GAO reported on insular area grants (GAO-10-347); this 
testimony summarizes that report and focuses on (1) whether previously 
reported internal control weaknesses have been addressed and, if not, 
to what extent they are prevalent among OIA grant projects, including 
technical assistance grant projects, as of March 2010; and (2) the 
extent to which OIA has taken action to improve the implementation and 
management grant projects, as of March 2010. 

For the March 2010 report, GAO reviewed a random sample of 173 OIA 
grant project files and interviewed OIA and insular area officials. 
For this testimony, GAO conducted additional analysis for the 49 
technical assistance grant projects included in the sample. 

GAO’s March 2010 report contained three recommendations. Interior 
agreed with the recommendations. This testimony statement contains no 
new recommendations. 

What GAO Found: 

Internal control weaknesses previously reported by GAO and others 
continue to exist, and about 40 percent of grant projects funded 
through OIA have these weaknesses, which may increase their 
susceptibility to mismanagement. These weaknesses can be categorized 
into three types of activities: grant recipient activities, joint 
activity between grant recipients and OIA, and OIA’s grant management 
activities. As shown in the table below, for the 49 technical 
assistance grant projects in GAO’s sample, the most prevalent 
weaknesses were insufficient reporting and record-keeping 
discrepancies. 

Table: Prevalence of GAO-identified Internal Control Weaknesses for 49 
Technical Assistance Grant Projects Included in GAO’s Sample of 173 
OIA Grant Project Files: 

Internal control weakness: Grant recipient activities: Failure to 
submit required status reports in full and on time; 
Number of grant projects with internal control weakness[A]: 42 out of 
49. 

Internal control weakness: Grant recipient activities: Failure to 
submit required final reports on time (closed grants only); 
Number of grant projects with internal control weakness[A]: 16 out of 
30. 

Internal control weakness: Grant recipient activities: Projects’ 
expected or actual completion date fall after grant expiration; 
Number of grant projects with internal control weakness[A]: 8 out of 
49. 

Internal control weakness: Grant recipient activities: Drawing down 
funds faster than project progress (open grants only); 
Number of grant projects with internal control weakness[A]: 0 out of 
19. 

Internal control weakness: Joint activity between grant recipients and 
OIA: Redirection of project funds; 
Number of grant projects with internal control weakness[A]: Not 
applicable. 

Internal control weakness: OIA grant management activities: 
Information in grant management database does not match grant file; 
Number of grant projects with internal control weakness[A]: 39 out of 
49. 

Internal control weakness: OIA grant management activities: Unexpended 
funds are not deobligated (closed grants only); 
Number of grant projects with internal control weakness[A]: 0 out of 
30. 

Internal control weakness: OIA grant management activities: Field 
representatives perform less than half of all site visits; 
Number of grant projects with internal control weakness[A]: Not 
applicable. 

Source: GAO analysis of OIA documents. 

[A] Results based on GAO’s independent review of 49 technical 
assistance grant project files. 

[End of table] 

Over the past 5 years, OIA has taken steps to improve project 
implementation and management. Most notably, OIA established 
incentives for financial management improvements and project 
completion by tying a portion of each insular area’s annual allocation 
to the insular governments’ efforts in these areas—such as their 
efforts to submit financial and status reports on time. In addition, 
OIA established expiration dates for grants to encourage expeditious 
use of the funds. Despite these and other efforts, some insular areas 
are still not completing their projects in a timely and effective 
manner, and OIA faces key obstacles in compelling them to do so. 
Specifically, (1) current OIA grant procedures provide few sanctions 
for delayed or inefficient projects, and the office is not clear on 
its authorities to modify its policies; (2) resource constraints 
impede effective project completion and proactive monitoring and 
oversight; (3) inconsistent and insufficiently documented project 
redirection policies do little to discourage insular areas from 
redirecting grant funds in ways that hinder project completion; and 
(4) OIA’s current data system for tracking grants is limited and lacks 
specific features that could allow for more efficient grant management. 

View [hyperlink, http://www.gao.gov/products/GAO-10-917T] or key 
components. For more information, contact Anu K. Mittal at (202) 512-
3481 or mittala@gao.gov. 

[End of section] 

Madam Chairwoman and Members of the Subcommittee: 

I am pleased to be here today to participate in your hearing to 
discuss technical assistance grants to the U.S. insular areas. U.S. 
insular areas--which include American Samoa, the Commonwealth of the 
Northern Mariana Islands (CNMI), Guam, the U.S. Virgin Islands (USVI), 
and three Freely Associated States (the Federated States of 
Micronesia, Palau, and the Republic of the Marshall Islands)--face 
serious economic and fiscal challenges. Consequently, these insular 
areas, some of which are under U.S. sovereignty, and some of which are 
independent nations that have signed Compacts of Free Association with 
the United States, rely on federal funding to support their 
governments and deliver critical services. The Department of the 
Interior, through its Office of Insular Affairs (OIA), provides 
approximately $400 million annually in financial assistance to insular 
area governments--roughly $70 million of which is awarded annually as 
grants to insular areas for capital improvement projects, operations 
and maintenance improvement projects, technical assistance, and other 
purposes, to increase the self-sufficiency of the insular areas. For 
example, technical assistance grants are used to conduct feasibility 
studies or train government staff. 

Although OIA grants are essential in supporting insular areas' 
economies, we and others--including Interior's Office of Inspector 
General--have had long-standing concerns with insular area 
governments' internal control weaknesses, which increase the risk of 
fraud, waste, abuse, and mismanagement.[Footnote 1] These internal 
control weaknesses have been documented in several reports between 
2000 and 2009. Internal control is an integral component of an 
organization's management that provides reasonable assurance that 
operations are effective and efficient, financial reporting is 
reliable, and applicable laws and regulations are complied with. 
Internal control also serves as the first line of defense in 
safeguarding assets and preventing and detecting errors and fraud. 
Under the federal standards for internal control, federal agencies are 
to employ internal control activities--the policies, procedures, 
techniques, and mechanisms that enforce management's directives--that 
are integral to the accountability for stewardship of government 
resources and achieving effective results, and help ensure that 
actions are taken to address risks.[Footnote 2] Examples of such 
internal control activities include accurate and timely recording of 
transactions and events and controls over information processing. If 
federal agencies do not use effective internal control activities, or 
have weaknesses in their internal controls, they can increase the risk 
of potential mismanagement or misuse and waste of grant funds. 

My testimony is based on our recent March 2010 report, in which we 
reviewed OIA's grant management and oversight.[Footnote 3] Based on 
that report, I will discuss (1) whether long-standing internal control 
weaknesses have been addressed and, if not, to what extent they were 
prevalent among OIA grant projects, including technical assistance 
grant projects, as of March 2010; and (2) the extent to which OIA has 
taken actions to improve grant project implementation and management, 
as of March 2010. 

For our March 2010 report, we focused on insular areas that receive 
noncompact grants--including American Samoa, the CNMI, Guam, the USVI, 
and the Freely Associated States.[Footnote 4] We reviewed OIA's 
policies, procedures, and other documents as well as best practices in 
grant management. We interviewed OIA grant managers and division 
directors regarding OIA's policies and procedures and grant 
management. In addition, we also reviewed a random sample of 173 grant 
project files to determine whether and the extent to which internal 
control weaknesses are still prevalent. We were able to project our 
sample results to the 1,771 OIA grant projects in the grant management 
database as of April 27, 2009. For this testimony, using the data from 
our random sample of 173 grant project files, we identified 49 
technical assistance grants and conducted additional analyses. 
[Footnote 5] 

For the March report, we conducted our audit work from March 2009 to 
March 2010, in accordance with generally accepted government auditing 
standards. Appendix I of our report contains a detailed description of 
our scope and methodology. 

Background: 

U.S. insular areas receive hundreds of millions of dollars in federal 
grants from a variety of federal agencies, including the Departments 
of Agriculture, Education, Health and Human Services, Homeland 
Security, the Interior, Labor, and Transportation. The Secretary of 
the Interior has administrative responsibility over the insular areas 
for all matters that do not fall within the program responsibility of 
another federal department or agency. OIA, established in 1995, is 
responsible for carrying out the Secretary's responsibilities for U.S. 
insular areas.[Footnote 6] OIA's mission is to promote the self-
sufficiency of the insular areas by providing financial and technical 
assistance, encouraging private sector economic development, promoting 
sound financial management practices in the insular governments, and 
increasing federal responsiveness to the unique needs of the island 
communities. 

Much of the assistance that OIA administers to insular areas is in the 
form of what it considers mandatory assistance, including compact 
assistance,[Footnote 7] permanent payments to U.S. territories, 
American Samoa operations funding, and capital improvement project 
grants. OIA also administers discretionary assistance through, for 
example, technical assistance grants and operations and maintenance 
improvement program grants. The administration and management of OIA 
grants is guided by OIA's Financial Assistance Manual. OIA grants 
other than compact assistance are subject to Interior's Grants 
Management Common Rule,[Footnote 8] relevant Office of Management and 
Budget (OMB) circulars,[Footnote 9] and specific terms and conditions 
that OIA outlines in each grant agreement, such as semiannual 
narrative and financial reporting and grant expiration dates. 

Within OIA, two divisions are largely responsible for grant 
administration and management--the Technical Assistance Division and 
the Budget and Grants Management Division. The Technical Assistance 
Division, which administers general technical assistance grants in 
addition to several other types of technical assistance, has a 
director and two grant managers. The Budget and Grants Management 
Division, which covers capital improvement project and operations and 
maintenance improvement program grants, has a director and three grant 
managers.[Footnote 10] A third OIA division--the Policy and Liaison 
Division--also provides some staff for grant-related tasks, including 
staff that focus on OIA's accountability and audit responsibilities. 
[Footnote 11] The majority of OIA's budget is directed to compact 
assistance and permanent fiscal payments (see table 1). About 2 
percent of OIA's budget is dedicated to administrative costs, leaving 
less than 16 percent for noncompact grants and technical assistance. 

Table 1: Breakdown of the Office of Insular Affairs' Fiscal Year 2010 
Budget: 

Component of OIA's budget: Compact of Free Association; 
Dollars in thousands: $218,289; 
Percentage of OIA budget: 45.4%. 

Component of OIA's budget: Permanent fiscal payments[A]; 
Dollars in thousands: $177,000; 
Percentage of OIA budget: 36.8%. 

Component of OIA's budget: Office of Insular Affairs (administrative); 
Dollars in thousands: $9,280; 
Percentage of OIA budget: 1.9%. 

Component of OIA's budget: Noncompact grants and technical assistance: 
American Samoa operations; 
Dollars in thousands: $22,752; 
Percentage of OIA budget: 4.7%. 

Component of OIA's budget: Noncompact grants and technical assistance: 
Capital improvement project grants (covenant grants); 
Dollars in thousands: $27,720; 
Percentage of OIA budget: 5.8%. 

Component of OIA's budget: Noncompact grants and technical assistance: 
Operations and maintenance improvement program grants; 
Dollars in thousands: $2,241; 
Percentage of OIA budget: 0.5%. 

Component of OIA's budget: Noncompact grants and technical assistance: 
Technical assistance grants; 
Dollars in thousands: $21,202; 
Percentage of OIA budget: 4.4%. 

Component of OIA's budget: Noncompact grants and technical assistance: 
Guam infrastructure grants; 
Dollars in thousands: $2,000; 
Percentage of OIA budget: 0.4%. 

Component of OIA's budget: Subtotal; 
Dollars in thousands: $75,915; 
Percentage of OIA budget: 15.8%. 

Component of OIA's budget: Total; 
Dollars in thousands: $480,484; 
Percentage of OIA budget: 100%[B]. 

Source: OIA budget justification and performance information, fiscal 
year 2011. 

[A] Permanent fiscal payments include payments to Guam (section 30 
income taxes) and the U.S. Virgin Islands (rum excise taxes). 

[B] Column does not add up to 100 percent due to rounding. 

[End of table] 

Among the random sample of 173 OIA grant project files that we 
reviewed in our March 2010 report, we identified 49 OIA technical 
assistance grant projects from a variety of technical assistance grant 
types (see table 2). 

Table 2: Breakdown of the 49 Technical Assistance Grant Projects 
Included in GAO's March 2010 Report by Type of Technical Assistant 
Grant Project and Whether the Grant Project Was Open or Closed as of 
April 27, 2009: 

Type of technical assistance grant project: General technical 
assistance; 
Description of grant type: To foster insular area development 
economically or in other areas such as training and education, energy, 
safety and health; 
Number of open technical assistance grant projects: 7; 
Closed technical assistance grant projects: Number: 14; 
Closed technical assistance grant projects: Time span: 2004-2009. 

Type of technical assistance grant project: Brown treesnake control; 
Description of grant type: To control ecological and economic damage 
caused by the brown treesnake on Guam and prevent dispersal to other 
islands, such as the State of Hawaii; 
Number of open technical assistance grant projects: 1; 
Closed technical assistance grant projects: Number: 1; 
Closed technical assistance grant projects: Time span: 2003-2007. 

Type of technical assistance grant project: Coral reef initiative; 
Description of grant type: To promote sound management and 
conservation of coral reefs in insular areas; 
Number of open technical assistance grant projects: 7; 
Closed technical assistance grant projects: Number: 3; 
Closed technical assistance grant projects: Time span: 2006-2008. 

Type of technical assistance grant project: Insular management 
controls; 
Description of grant type: To promote and develop insular institutions 
and capabilities that improve financial management and accountability; 
Number of open technical assistance grant projects: 1; 
Closed technical assistance grant projects: Number: 2; 
Closed technical assistance grant projects: Time span: 2006-2008. 

Type of technical assistance grant project: Single Audit; 
Description of grant type: To assist insular areas in the preparation 
of annual Single Audit reports; 
Number of open technical assistance grant projects: 1; 
Closed technical assistance grant projects: Number: 0; 
Closed technical assistance grant projects: Time span: Not applicable. 

Type of technical assistance grant project: Other technical assistance; 
Description of grant type: To address other technical assistance needs 
of insular areas, such as water and wastewater; 
Number of open technical assistance grant projects: 2; 
Closed technical assistance grant projects: Number: 10; 
Closed technical assistance grant projects: Time span: 2003-2008. 

Type of technical assistance grant project: Total; 
Number of open technical assistance grant projects: 19; 
Closed technical assistance grant projects: Number: 30; 
Closed technical assistance grant projects: Time span: 2003-2009. 

Source: GAO and OIA. 

[End of table] 

The 49 technical assistance grant projects that we reviewed in our 
March 2010 report, were geographically dispersed among the insular 
areas and the State of Hawaii (see table 3).[Footnote 12] 

Table 3: Distribution of the 49 Technical Assistance Grant Projects in 
GAO's March 2010 Report by Location: 

Location: Commonwealth of the Northern Mariana Islands (CNMI); 
Number of technical assistance grant projects included in our sample: 
17. 

Location: Palau; 
Number of technical assistance grant projects included in our sample: 
9. 

Location: Federated States of Micronesia; 
Number of technical assistance grant projects included in our sample: 
5. 

Location: Guam; 
Number of technical assistance grant projects included in our sample: 
4. 

Location: U.S. Virgin Islands (USVI); 
Number of technical assistance grant projects included in our sample: 
3. 

Location: American Samoa; 
Number of technical assistance grant projects included in our sample: 
2. 

Location: Republic of the Marshall Islands; 
Number of technical assistance grant projects included in our sample: 
2. 

Location: State of Hawaii; 
Number of technical assistance grant projects included in our sample: 
2. 

Location: Other[A]; 
Number of technical assistance grant projects included in our sample: 
5. 

Location: Total; 
Number of technical assistance grant projects included in our sample: 
49. 

Source: GAO. 

[A] Location is described as "Other" when funds are granted to a non- 
governmental entity, such as a non-profit or multinational 
organization. 

[End of table] 

Nearly 40 Percent of OIA Grant Projects Have Internal Control 
Weaknesses That Could Increase Susceptibility to Mismanagement: 

On the basis of our review of grant files from a random sample of 
grant projects,[Footnote 13] we determined that the long-standing 
internal control weaknesses that we, Interior's Office of Inspector 
General, and others, identified between 2000 and 2009 still exist. We 
estimated that 39 percent of the 1,771 grant projects in OIA's grant 
management database demonstrate at least one internal control weakness 
that may increase the projects' susceptibility to mismanagement. 
[Footnote 14] Of the 49 technical assistance grant projects in our 
sample, 47 grant projects demonstrated one or more of the internal 
control weaknesses that we assessed, which is more than double our 
estimated 39 percent occurrence rate for OIA grants as a whole. 

The eight internal control weaknesses that we assessed can be grouped 
into three categories based on the entity responsible for the 
activities: grant recipient activities, OIA grant management 
activities, or joint activities between grant recipients and OIA. 
Table 4 shows (1) how often we estimated each internal control 
weakness would occur within the universe of OIA grants based on our 
random sample, and (2) specific data on the 49 technical assistance 
grants included in our sample. The most prevalent weaknesses for the 
49 technical assistance grant projects were insufficient reporting and 
record-keeping discrepancies. 

Table 4: Internal Control Weaknesses Present in OIA Grant Projects: 

Internal control weakness: Grant recipient activities: Failure to 
submit required status reports in full and on time; 
Estimated percentage of projects with internal control weakness for 
all grant types from our March 2010 report[A]: 60; 
Number of technical assistance grant projects in our sample with 
internal control weakness[B]: 42 out of 49. 

Internal control weakness: Grant recipient activities: Failure to 
submit required final reports on time (closed grants); 
Estimated percentage of projects with internal control weakness for 
all grant types from our March 2010 report[A]: 58[C]; 
Number of technical assistance grant projects in our sample with 
internal control weakness[B]: 16 out of 30. 

Internal control weakness: Grant recipient activities: Projects' 
expected or actual completion dates fall after grant expiration; 
Estimated percentage of projects with internal control weakness for 
all grant types from our March 2010 report[A]: 19; 
Number of technical assistance grant projects in our sample with 
internal control weakness[B]: 8 out of 49. 

Internal control weakness: Grant recipient activities: Drawing down 
funds faster than project progress (open grants); 
Estimated percentage of projects with internal control weakness for 
all grant types from our March 2010 report[A]: 0; 
Number of technical assistance grant projects in our sample with 
internal control weakness[B]: 0 out of 19. 

Internal control weakness: Joint activity between grant recipients and 
OIA: Redirection of project funds[D]; 
Estimated percentage of projects with internal control weakness for 
all grant types from our March 2010 report[A]: 30; 
Number of technical assistance grant projects in our sample with 
internal control weakness[B]: Not applicable. 

Internal control weakness: OIA grant management activities: 
Information in grant management database does not match grant file[E]; 
Estimated percentage of projects with internal control weakness for 
all grant types from our March 2010 report[A]: 41; 
Number of technical assistance grant projects in our sample with 
internal control weakness[B]: 39 out of 49. 

Internal control weakness: OIA grant management activities: Field 
representatives perform less than half of all site visits[D]; 
Estimated percentage of projects with internal control weakness for 
all grant types from our March 2010 report[A]: 10; 
Number of technical assistance grant projects in our sample with 
internal control weakness[B]: Not applicable. 

Internal control weakness: OIA grant management activities: Unexpended 
funds are not deobligated (closed grants); 
Estimated percentage of projects with internal control weakness for 
all grant types from our March 2010 report[A]: 0; 
Number of technical assistance grant projects in our sample with 
internal control weakness[B]: 0 out of 30. 

Source: GAO analysis of OIA documents. 

Notes: Unless otherwise specified, internal control weaknesses apply 
to both open and closed grant projects. For additional information on 
how we selected the internal control weaknesses and assessed grant 
projects for the presence of those weaknesses see appendix I of our 
March 2010 report, U.S. Insular Areas: Opportunities Exist to Improve 
Interior's Grant Oversight and Reduce the Potential for Mismanagement, 
GAO-10-347 (Washington, D.C.: Mar. 16, 2010). 

[A] Not all internal control weaknesses apply to every grant project. 
For example, we could only assess the field representative-related 
internal control weakness for grants awarded to the two insular areas 
with field representatives--American Samoa and the CNMI. Our data 
analysis takes the applicability of the internal control weaknesses 
into account. As a result, numbers reported for individual weaknesses 
apply only to the relevant subset of projects. These percentage 
estimates from the file review have margins of error at the 95 percent 
confidence level within plus or minus 10 percentage points or less, 
unless otherwise noted: 

[B] We cannot make precise generalizable estimates for technical 
assistance grant projects based on the results for the 49 technical 
assistance grant project files we reviewed as part of our sample. 

[C] The confidence interval for this estimate is within +/-11 percent. 

[D] Two of the eight internal control weaknesses that we assessed are 
not applicable to technical assistance grant projects: (1) redirection 
of project funds is not allowed in discretionary technical assistance 
grants; and (2) field representative site visits are not formally used 
for technical assistance grant projects. 

[E] The database contains at least one piece of information that does 
not match corresponding information in the grant file. 

[End of table] 

Table 5 shows how many internal control weaknesses were demonstrated 
by the 49 technical assistance grant projects in our sample. 

Table 5: Number of Internal Control Weaknesses Present in 49 OIA 
Technical Assistance Grant Projects: 

Number of internal control weaknesses: 5; 
Number of open technical assistance grant projects: Not applicable; 
Number of closed technical assistance grant projects: 0. 

Number of internal control weaknesses: 4; 
Number of open technical assistance grant projects: 0; 
Number of closed technical assistance grant projects: 5. 

Number of internal control weaknesses: 3; 
Number of open technical assistance grant projects: 0; 
Number of closed technical assistance grant projects: 12. 

Number of internal control weaknesses: 2; 
Number of open technical assistance grant projects: 12; 
Number of closed technical assistance grant projects: 7. 

Number of internal control weaknesses: 1; 
Number of open technical assistance grant projects: 5; 
Number of closed technical assistance grant projects: 6. 

Number of internal control weaknesses: 0; 
Number of open technical assistance grant projects: 2; 
Number of closed technical assistance grant projects: 0. 

Number of internal control weaknesses: Total; 
Number of open technical assistance grant projects: 19; 
Number of closed technical assistance grant projects: 30. 

Source: GAO analysis of OIA documents. 

Note: Of the eight internal control weaknesses that we identified in 
our March 2010 report, five are applicable to closed technical 
assistance grant projects and four are applicable to open technical 
assistance grant projects. 

[End of table] 

For example, one general technical assistance grant project that we 
reviewed in detail--the 2005 grant for the USVI Household Income and 
Expenditures Survey (HIES) project--had 4 out of 5 applicable internal 
control weaknesses. In 2005, OIA awarded a general technical 
assistance grant to the Eastern Caribbean Center (ECC) at the 
University of the Virgin Islands for the purpose of collecting data to 
update important economic and demographic indicators for the 
territory. Because of funding constraints, OIA was not able to award 
the entire amount requested at that time. In addition, OIA later 
reduced its financial support of the project after data collection was 
underway, thereby reducing the scope of data collection efforts. The 
Director of the ECC reported that OIA's decision to reduce available 
funding after data collection had begun was disastrous to the 
statistical integrity of the survey. 

In reviewing this grant project, we found the following four internal 
control weaknesses, (1) failure to submit the required status report 
in full and on time, (2) failure to submit the required final reports 
on time, (3) expected or actual completion dates that occurred after 
grant expiration, and (4) information in OIA's grant management 
database that did not match information in the grant file.[Footnote 
15] These weaknesses and other problems affected project completion in 
several ways, including the loss of additional funding that OIA later 
awarded. In 2007, OIA granted additional funds for the HIES project to 
complete tabulation of the data that had been collected. However, 
because so much time had passed since the initial data collection 
effort, the Director of the ECC stated that it was not possible to 
complete the data collection as originally planned. Due to the lack of 
activity with the grant and the fact that no narrative status reports 
were submitted, OIA deobligated these additional grant funds in their 
entirety in February 2009. The final HIES report also was not 
completed until September 2009, more than 4 years after the initial 
grant was awarded. 

OIA Has Taken Actions to Improve Grant Project Implementation and 
Management but Faces Several Obstacles: 

OIA has taken several important steps to improve grant project 
implementation and management but faces several obstacles in its 
efforts to compel insular areas to complete their projects in a timely 
and effective manner. 

OIA Has Taken Steps to Improve the Implementation and Management of 
Grant Projects: 

Over the past 5 years, OIA has taken the following steps to improve 
grant project implementation and management: 

* Competitive allocation system. In fiscal year 2005, OIA implemented 
a new competitive allocation system for the $27.7 million in capital 
improvement project grants that it administers to the insular areas. 
[Footnote 16] This system provides incentives for financial management 
improvements and project completion by tying a portion of each insular 
area's annual allocation to the insular governments' efforts in these 
areas--such as their efforts to submit financial and status reports on 
time. Through this system, OIA scores each insular area against a set 
of performance-based criteria and increases allocations to those 
insular areas with higher scores, thereby lowering allocations to 
insular areas with lower scores. 

* Grant expiration dates. Beginning in 2005, to encourage expeditious 
use of funds, OIA established 5-year expiration dates in the terms and 
conditions of new capital improvement project grants. Beginning in 
2008, OIA also notified insular area officials of expiration dates for 
grant projects that had been ongoing for more than 5 years with no or 
limited progress. OIA officials explained that while the expiration 
dates have not yet pushed all of the insular areas to complete 
projects, they have encouraged some areas to do so. The officials also 
stated that the expiration dates have helped OIA grant managers 
administer and manage grants--which they believe has improved 
accountability--and have been useful for insular area grantees whose 
agencies have high staff turnover and were unaware of the status of 
older grants. Technical assistance projects have shorter grant terms 
than capital improvement projects, with expiration dates within 1 to 2 
years; we found that OIA extended the grant expiration date at least 
once for 18 of the 49 technical assistance grant projects in our 
sample. 

* Actions to improve insular area grant management continuity. OIA has 
also taken steps to help with the continuity of grant administration 
at the insular level. For example, in March 2008, OIA awarded a 
$770,000 grant for capital improvement project administration in the 
CNMI, which provided funding for positions in the local central grant 
management office in that insular area. According to the grant manager 
for CNMI capital improvement projects, the grant was given to help 
ensure that the central grant management office had the staff 
necessary to help move implementation of projects forward. 

Several Obstacles to Timely and Effective Project Completion Remain: 

Despite OIA's efforts, some insular areas are still not completing 
their projects in a timely and effective manner, and OIA faces the 
following key obstacles in compelling them to do so: 

* Lack of sanctions for delayed or inefficient projects. Current OIA 
grant procedures provide few sanctions for delayed or inefficient 
projects. For example, although OIA established grant expiration 
dates, they have little practical effect. In theory, a grant 
expiration date encourages timely completion of a project because if a 
project is not completed on time, the funds are taken away from the 
recipient. However, if an insular area's OIA grant funds expire, while 
the funds do not remain immediately available for the project, the 
insular area does not lose the funds because OIA treats its capital 
improvement project grants as mandatory funding with "no-year funds," 
based on the agency's interpretation of relevant laws.[Footnote 17] 
Thus, after a grant expires, OIA deobligates the funds and they are 
returned to the insular area's capital improvement project account to 
be reobligated for the same or other projects. Recently, OIA has taken 
steps to identify possible solutions and actions that could help 
provide effective sanctions for insular areas that do not efficiently 
complete projects and expend funds. In doing so, OIA has faced 
uncertainty regarding the authorities it has to change its current 
policies and practices, which are guided by many special agreements, 
laws, and regulations. 

* OIA resource constraints. OIA officials report that resource 
constraints impede effective project completion and proactive 
monitoring and oversight. Although they could not provide us with 
data, numerous officials in OIA asserted that heavy workloads are a 
key challenge in managing grants. The effects of insufficient 
resources vary across grant type but include impacts on the ability to 
maintain files, adopt a proactive oversight approach that could aid 
project completion, conduct more detailed financial reviews of 
projects, and conduct site visits to more projects to better ensure 
that mismanagement is detected. Importantly, although grant managers 
for capital improvement projects noted that the most effective action 
they can take to move projects along is to conduct site visits, they 
also asserted that their current workloads only afford one visit per 
year. Despite their concurrence that additional resources are needed, 
OIA division directors confirmed that they have not formally 
communicated these needs to decision makers, or higher levels within 
Interior, and have not developed a workforce plan or other formal 
process that demonstrates a need for additional resources. Moreover, 
OIA does not track workload measures, such as the number of grants 
handled by each grant manager, to show changes over time that would 
help justify the need for additional resources. 

* Inconsistent and insufficiently documented project redirection 
policies. OIA's current project redirection approval practices do 
little to discourage insular areas from redirecting project funds in 
ways that hinder project completion. We found that insular areas shift 
priorities and frequently redirect grant project funds, which in some 
cases expedites project completion and in other cases impedes it. 
Currently, OIA's policies for granting project redirection requests 
vary across insular areas. Specifically, in American Samoa, project 
redirection is limited to changes within a priority category because 
the insular area's grants are issued by priority areas.[Footnote 18] 
In contrast, the other insular areas each receive grants as one 
capital improvement grant and are able to redirect money between 
projects with widely different purposes. Furthermore, OIA's policies 
for granting project redirection requests are also not well-
documented. Project redirection is a particular concern in instances 
where a project starts and federal money is expended but the project 
is never completed, leading to the waste of both federal resources and 
the local governments' limited technical capacity to implement 
projects. 

* Inefficient grant management system. OIA's current data system for 
tracking grants is limited in the data elements it contains, leading 
to inconsistencies in the data that some grant managers rely on for 
monitoring and oversight activities. Grant managers vary in the degree 
to which they rely upon OIA's database, as well as the priority they 
place on keeping information in the database up to date. While grant 
managers for all grant types reported relying on the database for 
information on the amount of funds drawn down from grants and for 
responding to requests for data from outside parties (such as 
Interior's Office of Inspector General and GAO), some told us that 
they do not find OIA's database useful and therefore maintain their 
own separate spreadsheets to track some information, including 
expiration dates, grant status, and receipt dates for the most recent 
financial and narrative reports. As reported in the Domestic Working 
Group's Guide to Opportunities for Improving Grant Accountability, 
consolidating information systems can enable agencies to better manage 
grants.[Footnote 19] Along these lines, Interior is currently phasing 
in a centralized agencywide system--the Financial and Business 
Management System--that is scheduled to be implemented in OIA in 2011. 

Our March 2010 report contained three recommendations to the Secretary 
of the Interior designed to improve the department's management and 
oversight of grants to the insular areas,[Footnote 20] including one 
that would directly impact OIA's technical assistance grant programs. 
Specifically, we recommended that the Secretary of the Interior direct 
OIA to create a workforce plan and reflect in its plan the staffing 
levels necessary to adopt a proactive monitoring and oversight 
approach. Such proactive monitoring and oversight would apply to all 
of OIA's grant programs, including the technical assistance programs. 
OIA agreed with our report and told us that it will implement these 
recommendations. 

In conclusion, Madam Chairwoman, OIA has made important strides in 
implementing grant reforms, particularly in its efforts to establish 
disincentives for insular areas that do not complete grant projects in 
a timely and effective manner. However, the unique characteristics and 
situations facing insular area governments, and the need to mindfully 
balance respect for insular governments' self-governance and political 
processes with the desire to promote efficiency in grant project 
implementation, limit as a practical matter some of the actions that 
OIA can take to improve the implementation of grant projects. 
Nonetheless, OIA has not exhausted all of its available opportunities 
to better oversee grants and reduce the potential for mismanagement 
and we will continue to monitor its implementation of our 
recommendations. 

Madam Chairwoman, this concludes my prepared statement. I would be 
pleased to answer any questions that you or other Members of the 
Subcommittee may have at this time. 

GAO Contact and Staff Acknowledgments: 

For further information about this testimony, please contact Anu K. 
Mittal at (202) 512-3841 or mittala@gao.gov. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this statement. Individuals making key contributions 
to this testimony include Jeffery D. Malcolm and Emil Friberg, 
Assistant Directors; Elizabeth Beardsley; Keesha Egebrecht; and 
Isabella Johnson. 

[End of section] 

Footnotes: 

[1] GAO, U.S. Insular Areas: Economic, Fiscal, and Financial 
Accountability Challenges, [hyperlink, 
http://www.gao.gov/products/GAO-07-119] (Washington, D.C.: Dec. 12, 
2006). Department of the Interior, Office of Inspector General, Report 
on Grants Administered by the Office of Insular Affairs, Report No. 
2003-I-0071 (Washington, D.C.: September 2003). 

[2] In assessing the adequacy of internal controls, we used the 
criteria in GAO's 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). These standards, issued pursuant to the requirements 
of the Federal Managers' Financial Integrity Act of 1982 (FMFIA), 
provide the overall framework for establishing and maintaining 
internal control in the federal government. Also pursuant to FMFIA, 
the Office of Management and Budget issued Circular A-123, revised 
December 21, 2004, to provide the specific requirements for assessing 
the reporting on internal controls. Internal control standards and the 
definition of internal control in Circular A-123 are based on GAO's 
Standards for Internal Control in the Federal Government. 

[3] U.S. Insular Areas: Opportunities Exist to Improve Interior's 
Grant Oversight and Reduce the Potential for Mismanagement, GAO-10-347 
(Washington, D.C.: Mar. 16, 2010). 

[4] Noncompact grants include those provided for capital improvement 
projects, operations and maintenance improvement projects, technical 
assistance and other purposes. The seven insular areas listed above 
receive at least some noncompact grant funding. Compact funding is the 
assistance the United States provides to the Federated States of 
Micronesia, the Republic of the Marshall Islands, and Palau through 
Compacts of Free Association. We specifically excluded compact funds 
from this review because GAO is required to review and report on the 
effectiveness of U.S. oversight of compact funds on a regular basis. 
For example, we recently reported on compact assistance to the 
Federated States of Micronesia and the Republic of the Marshall 
Islands. See GAO, Compacts of Free Association: Micronesia and the 
Marshall Islands Face Challenges in Planning for Sustainability, 
Measuring Progress, and Ensuring Accountability, [hyperlink, 
http://www.gao.gov/products/GAO-07-163] (Washington, D.C.: Dec. 15, 
2006). 

[5] Our random sample of 173 grant project files included 49 technical 
assistance grant projects. The sample was designed to make 
generalizable estimates about the entire population of OIA grant 
projects; however, because the number of technical assistance grant 
projects in the sample was small, we did not use the data from these 
grant projects to make precise generalizable estimates about technical 
assistance grant projects. 

[6] Interior underwent restructuring in 1995. It eliminated the Office 
of Territorial and International Affairs, which previously carried out 
Interior's insular responsibilities, and created the Office of Insular 
Affairs. 

[7] Compact funding is the assistance the United States provides to 
the Federated States of Micronesia, the Republic of the Marshall 
Islands, and Palau through Compacts of Free Association. 

[8] 43 C.F.R. part 12. 

[9] OIA grants, as applicable, are subject to OMB Circulars A-102, 
"Grants and Cooperative Agreements with State and Local Governments"; 
A-110, "Grants and Other Agreements with Institutions of Higher 
Education, Hospitals, and Other Non-Profit Organizations"; A-87, "Cost 
Principles for State and Local Governments"; A-21, "Cost Principles 
for Educational Institutions"; A-122, "Cost Principles for Non-Profit 
Organizations"; and A-133, "Audits of States, Local Governments, and 
Non-Profit Organizations." 

[10] In addition, the division maintains an office in Hawaii for 
compact oversight in the Federated States of Micronesia and the 
Republic of the Marshall Islands and has a field presence in the CNMI, 
the Federated States of Micronesia, Palau, and the Republic of the 
Marshall Islands. 

[11] The division maintains a field presence in American Samoa and the 
CNMI. 

[12] Interior is authorized to provide technical assistance--research, 
planning assistance, studies, and demonstration projects--to the 
insular areas through OIA staff time, reimbursements to other federal 
agencies, grants to or cooperative agreements with state or local 
governments, or the employment of private individuals or companies. In 
some instances, OIA may provide such technical assistance through work 
that is conducted at locations, such as Hawaii, other than insular 
areas. 

[13] We reviewed a random sample of 173 OIA grant projects, selected 
from 1,771 grant projects in OIA's grant management database as of 
April 27, 2009. Our sample included 49 technical assistance grants. 

[14] All percentage estimates for the entire universe of OIA grant 
projects have margins of error at the 95 percent confidence level 
within plus or minus 10 percentage points or less, unless otherwise 
noted. 

[15] Information refers to one or more database elements. 

[16] The Section 702 Funding Agreement between the Government of the 
United States and the Government of the CNMI, entered June 21, 2004, 
established a system for OIA's allocation of capital improvement 
project funds among the eligible territories and provided that a 
portion of such funds would be allocated using competitive criteria. 
Previous agreements between the governments regarding the capital 
improvement project funds did not allow for such a process but set 
fixed amounts. 

[17] A "no-year" appropriation is one that is available for obligation 
for an indefinite period, such as those funds appropriated as 
available until expended. 

[18] OIA's unique policy for American Samoa stems in part from the law 
authorizing capital improvement project grants, which places 
particular conditions, such as the requirement for a master plan 
identifying priorities, on grants to this insular area. 

[19] Domestic Working Group, Grant Accountability Project, Guide to 
Opportunities for Improving Grant Accountability (October 2005). 

[20] [hyperlink, http://www.gao.gov/products/GAO-10-347]. 

[End of section] 

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