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February 3, 2005:

The Honorable James M. Inhofe:

Chairman, Committee on Environment and Public Works:

United States Senate:

Subject: Grants Management: EPA Needs to Strengthen Efforts to Provide 
the Public with Complete and Accurate Information on Grant 
Opportunities:

Dear Mr. Chairman:

The Environmental Protection Agency (EPA) has faced persistent 
challenges for many years in managing its grants, which constitute over 
one-half of the agency's budget, or about $4 billion annually. Among 
other things, EPA has been criticized for not always promoting 
competition in awarding grants, including not completely and accurately 
announcing grant opportunities to the public and potential applicants. 
Informing the public about grant opportunities provides greater 
assurance that EPA will receive proposals from a large and varied pool 
of eligible and highly qualified applicants who otherwise might not 
have known about grant opportunities. One avenue EPA uses to inform the 
public about grant opportunities is the Catalog of Federal Domestic 
Assistance (CFDA), the federal government's listing of available grants 
and other federal funding opportunities (available at 
www.CFDA.gov).[Footnote 1]

The CFDA provides the public and potential applicants with specific 
information about grant opportunities. The CFDA identifies grant 
programs by title and an identifying number, known as a CFDA program 
code. Furthermore, EPA uses the CFDA to describe funding priorities--
that is, the specific major activities, projects, and/or programs that 
EPA will fund for certain grant programs; these priorities can change 
from year to year.[Footnote 2] EPA's segment of the CFDA provides 
information on both discretionary and nondiscretionary grant programs. 
Discretionary grants are those for which EPA has the legislative 
authority to independently determine the recipients and funding levels. 
Nondiscretionary grants are those that Congress directs to prospective 
recipients who meet specific eligibility criteria; these grants are 
often awarded to states on the basis of formulas prescribed by law or 
agency regulation. Information on nondiscretionary grants is valuable 
to the public and potential applicants because, in some cases, states 
receive these grants and local officials can apply to their states for 
funding from them.

EPA's Office of Grants and Debarment (OGD), among other things, 
develops grants policy and guidance and compiles grant information for 
the CFDA. OGD has taken several steps to address criticism regarding 
the lack of complete and accurate information in the CFDA. Most 
notably, OGD has revised its annual CFDA guidance to grant officials, 
emphasizing the need to provide complete and accurate information on 
grant opportunities.

In this context, you asked us to determine whether EPA is providing 
complete and accurate information on grant opportunities to the public 
in the CFDA. To respond to your request, we interviewed and obtained 
policy, guidance, and other documents from OGD officials. We reviewed 
EPA's descriptions of the 78 grant programs listed in the August 2004 
CFDA to determine if the program descriptions identified funding 
priorities and funding level estimates. Of these 78 programs, EPA 
identified 68 as discretionary and 10 as nondiscretionary.[Footnote 3] 
To verify the accuracy of the information in the CFDA, we obtained data 
from EPA's Integrated Grants Management System (IGMS), a computer 
database that OGD uses to manage and report on information about 
grants; we also conducted a limited data reliability assessment of that 
system. We reviewed Office of Management and Budget (OMB) Circulars A-
102 and A-110, which, among other things, lay out requirements for 
announcing funding priorities for discretionary grant 
programs.[Footnote 4] We also reviewed GAO and EPA Office of Inspector 
General reports, the Senate Environment and Public Works majority staff 
report,[Footnote 5] and EPA's response to the Senate report.[Footnote 
6] We focused our review on EPA program funding priorities, funding 
levels, and CFDA program codes in the August 2004 CFDA--the most 
current version at the time of our review--because these elements had 
been identified as incomplete and inaccurate in the past. We performed 
our work from September 2004 through January 2005 in accordance with 
generally accepted government auditing standards.

Results in Brief:

EPA still does not consistently provide complete and accurate 
information on grant opportunities in the CFDA, according to our 
analysis of the 78 grant programs listed in the August 2004 CFDA. 
Without complete and accurate information, potential applicants will 
not be fully informed about grant opportunities, and EPA may not have 
the broadest applicant pool from which to select grantees. 
Specifically, we found problems in the following areas:

Funding priorities. Sixty-two of the 68 discretionary grant programs 
and all 10 nondiscretionary grant programs did not have clearly 
identified fiscal year 2004 funding priorities in the August 2004 CFDA. 
Without these priorities, potential applicants did not benefit from 
knowing the specific activities, projects, and/or programs for which 
funding was available in 2004, which could have influenced their 
decision to apply. OGD did not clearly identify the funding priorities 
primarily because, beginning in April of fiscal year 2004, it 
systematically replaced priorities for 2004--which the public would 
expect to find in the CFDA--with those for 2005. Adding to the 
inaccuracy of the information presented, OGD did not always label the 
fiscal year to which the priorities applied. OGD officials explained 
that the replacement was inadvertent and noted that the 2004 funding 
priorities were accurate from the start of the fiscal year until OGD 
replaced them beginning in April 2004. We believe the problem occurred 
in part because OGD's guidance does not require OGD to include and 
clearly identify both the current and upcoming fiscal years' funding 
priorities in the CFDA. In addition, funding priorities were not always 
clearly identified because EPA program offices did not provide the 
funding priority information to OGD. In these cases, OGD did not follow 
its own guidance to ensure that program offices provided complete CFDA 
program descriptions.

Funding level estimates. For fiscal year 2004, most CFDA program 
descriptions included funding level estimates, but seven discretionary 
grants did not. OGD guidance states that financial information must be 
provided and that it should include funding level estimates. The lack 
of complete funding information makes it difficult for potential 
applicants to determine the level of funding available, which could 
affect their decision to apply. In some of these seven cases, this 
information was missing because program offices did not provide it to 
OGD, and OGD took only limited action to obtain it. In other cases, OGD 
did not designate a single program official to coordinate and develop a 
funding estimate for grant programs involving multiple program offices; 
as a result, no consolidated estimate was provided.

Miscellaneous CFDA program codes. EPA has created 31 more program-
specific codes, but it continues to list grant opportunities in broad, 
miscellaneous codes. EPA has been criticized for this practice. The use 
of these broad codes could make it difficult for potential applicants 
to find information about specific grants, thereby making the CFDA less 
useful. Placing these opportunities in more program-specific codes 
would better inform the public and potential applicants.

OGD was not aware of the continuing problems with funding priorities 
and funding levels in the CFDA that we had identified until we brought 
them to its attention during our review. OGD has begun taking steps to 
correct the problems we identified. Although OGD had issued CFDA 
guidance in 2002 on providing complete and accurate information, it had 
not evaluated the effectiveness of this guidance and its procedures. 
Periodic evaluation of the effectiveness of guidance and procedures is 
necessary to ensure that information is complete and accurate.

During the course of our review, we also identified inaccuracies in 
EPA's IGMS, which OGD uses to generate reports about its grants to the 
public and the Congress. These inaccuracies could impair EPA's ability 
to completely and accurately inform the public and the Congress about 
its $4 billion annual investment in grants. For example, we found 
instances in which the IGMS incorrectly identified funding as being 
awarded under one grant program when the funding should have been 
identified as being awarded under another grant program. Consequently, 
the information on funding levels was inaccurate for multiple programs-
-overstating the amount available in one program and understating it in 
another. OGD might have detected these problems if it had conducted a 
comprehensive review of the IGMS's data quality.

We are making recommendations to address EPA's continuing problems on 
providing complete and accurate information to the public in the CFDA. 
We are further recommending that EPA conduct a comprehensive, 
systemwide data quality review of the IGMS.

Background:

The CFDA provides the public and potential applicants with specific 
information about grant opportunities. EPA's segment of the CFDA Web 
site had about 57,600 "hits" between July 2003 and October 2004. This 
segment contains 78 grant programs, and for each of these grant 
programs, EPA specifies its statutory authority, objectives, funding, 
and contacts for further information, among other things. EPA also 
requires information on funding priorities for discretionary grants in 
the CFDA in order to comply with OMB Circulars A-102 and A-110. These 
circulars require federal agencies to publicly announce funding 
priorities for discretionary grants.

In 2001, EPA's Inspector General found that competition for 
discretionary grants was lacking in part because information in the 
CFDA was not complete and accurate.[Footnote 7] For example, EPA had 
not always (1) identified each program's funding priorities and (2) 
provided the funding levels available for each program. Furthermore, 
the Inspector General found that EPA bundled a number of programs under 
one CFDA program code, 66.606, "Surveys, Studies, Investigations, and 
Special Purpose Grants," thus making it difficult to find information 
about specific grant programs. In a 2003 report, we highlighted the 
Inspector General's finding that EPA had not provided complete and 
accurate information on its grants programs to the public in the 
CFDA.[Footnote 8]

EPA has taken the following steps to address the Inspector General's 
findings:

In 2002, EPA issued an order to promote competition by requiring that 
certain discretionary grants be competed.[Footnote 9] The order 
promoted the widespread announcement of grants and established 
requirements for publishing funding opportunities in the CFDA.

Also in 2002, OGD revised its CFDA guidance to program offices, stating 
that they must include annual funding priorities in the CFDA.[Footnote 
10] OGD's April 2004 version of this guidance emphasized the need to 
provide complete and accurate information on grant opportunities in the 
CFDA.[Footnote 11] OGD guidance also stated that financial information 
must be included and that it should include funding level estimates for 
the 2004 fiscal year.

EPA incorporated into its 2003 grants management plan--which addresses 
long-standing grants management challenges--the goal of promoting 
competition by (1) providing guidance to EPA's program offices on how 
to describe their programs and funding priorities in the CFDA, and (2) 
expanding public awareness of EPA funding opportunities through 
accurate and specific CFDA program descriptions to encourage a large 
and diverse group of grant applicants.[Footnote 12]

EPA added 31 CFDA program codes to better identify grants with more 
program-specific codes in the CFDA.

Most recently, in response to a 2004 report prepared by the Senate 
Committee on Environment and Public Works' majority staff, EPA stated 
in June 2004 that the agency had taken steps to resolve these problems.

To obtain information for the CFDA, OGD contacts EPA's program offices 
in the spring and fall to obtain data on new and updated grant 
programs. It collects most of this information in the first cycle, 
which occurs between February and April. By collecting the upcoming 
year's funding priorities about mid-way through the current fiscal 
year, EPA announces priorities in advance so that potential applicants 
can plan accordingly. During the second cycle, which occurs between 
October and November, EPA asks program offices to identify funding 
priorities only for new grant programs. OGD guidance requires each 
program office's senior resource official to approve the upcoming 
year's funding priorities and states that the official should submit 
this approval by memorandum to the OGD Director.[Footnote 13] This 
memorandum serves as the official agency record of each program 
office's annual funding priorities. EPA's Office of the Chief Financial 
Officer reviews funding level data.

According to OGD officials, they review each grant program description 
to ensure that it is complete and accurate. OGD provides guidance that 
OGD officials return information on funding priorities that is not 
complete and accurate to the program office so that complete 
information can be entered into the CFDA.

After these reviews, OGD submits the data to the General Services 
Administration (GSA) for review. According to OGD officials, CFDA 
analysts at GSA review the information and provide any comments to EPA. 
GSA then submits each program description to OMB, whose budget 
examiners review program funding levels and approve the information for 
the CFDA. GSA then posts the information to the CFDA Web site.

EPA Still Does Not Consistently Provide Complete and Accurate 
Information to the Public on Grant Opportunities:

According to our analysis of the August 2004 CFDA, EPA continues to 
provide incomplete and inaccurate information on funding priorities and 
on estimates of funding levels, and continues to obscure information by 
placing certain grant programs in miscellaneous CFDA program codes. 
Without complete and accurate information, potential applicants will 
not be fully informed about grant opportunities, and EPA may not have 
the broadest applicant pool from which to select grantees. OGD was not 
aware of the continuing problems until we brought them to its attention 
during our review because it has not evaluated the effectiveness of its 
CFDA guidance and its implementation to ensure the accuracy and 
completeness of the information in the CFDA.

EPA Does Not Consistently Provide Complete and Accurate Information on 
Funding Priorities:

EPA listed 78 grant programs--68 discretionary and 10 nondiscretionary-
-in the August 2004 CFDA. (See the enclosure for a complete list of 
these programs.) EPA did not provide complete and accurate information 
on funding priorities for 62 of the 68 discretionary grants and for the 
10 nondiscretionary grants for fiscal year 2004 that it listed in the 
August 2004 CFDA, as table 1 shows. Without complete and accurate 
funding priorities, potential grant applicants do not have information 
on which program areas EPA's offices are considering for grant funding 
and how applicable and useful their grant proposals would be. Publicly 
announced priorities also help ensure that EPA will have a broader, 
more diverse pool of qualified grant applicants from which to choose.

Table 1: EPA Grant Programs Lacking Clearly Identified Funding Priority 
Information in the August 2004 CFDA for Fiscal Year 2004:

Grant type: Discretionary; 
Number of grant programs: 68; 
Number of grant programs lacking clearly identified funding 
priorities: 62; 
Number of grant programs with clearly identified funding priorities: 6. 

Grant type: Nondiscretionary; 
Number of grant programs: 10; 
Number of grant programs lacking clearly identified funding 
priorities: 10; 
Number of grant programs with clearly identified funding priorities: 0.

Grant type: Total; 
Number of grant programs: 78; 
Number of grant programs lacking clearly identified funding 
priorities: 72; 
Number of grant programs with clearly identified funding priorities: 6.

Source: GAO analysis of CFDA data. 

[End of table]

Three factors contributed to the lack of complete and accurate funding 
priority information for fiscal year 2004 discretionary grants in the 
August 2004 CFDA. First, for 47 of the 62 discretionary grant programs 
lacking clearly identified funding priorities, OGD systematically 
replaced the current year's funding priorities--which the public would 
expect to find in the CFDA--with the upcoming fiscal year's priorities, 
and did not identify the fiscal year to which these priorities applied. 
Without this information, potential applicants did not know the major 
project, activities and/or programs for which funding was available in 
2004, which could have affected their decision to apply for a specific 
grant. OGD began these replacements in April 2004, as the program 
offices submitted their CFDA information for fiscal year 2005. OGD 
officials told us this replacement was inadvertent. Although OGD 
officials agreed that funding priorities were replaced beginning in 
April 2004, they noted that funding priorities were complete and 
accurate from October 2003 until they were replaced. This replacement 
and labeling problem occurred in part because OGD's guidance does not 
state that OGD must include and clearly identify the current and 
upcoming fiscal years' priorities in the CFDA. We believe this problem 
could be avoided in the future, and potential applicants could benefit, 
if the guidance required OGD to provide and label such information for 
both current and upcoming fiscal years.

Second, for 14 of the 62 discretionary grant programs, program offices 
did not provide information on funding priorities, and OGD did not 
return CFDA program descriptions that lacked funding priorities to 
program offices, as specified in OGD's guidance. In some cases, 
according to an EPA official, OGD sent follow-up e-mails and made 
telephone inquiries to the program offices. But these efforts did not 
result in complete information. Consequently, OGD submitted incomplete 
information for these grant programs in the CFDA.

Third, for 1 of the 62 discretionary grant programs, the program office 
provided the funding priority, but OGD mistakenly omitted the words 
"funding priority" from the CFDA program description. As a result, the 
public and potential applicants would find it difficult to identify 
funding priority information in the CFDA for this grant program.

Funding priorities for all 10 nondiscretionary grants in fiscal year 
2004 were also incomplete and inaccurate. As it had done with the 
discretionary grants, OGD replaced the fiscal year 2004 funding 
priorities with those for fiscal year 2005 beginning in April 2004 and 
did not identify the fiscal year. OGD officials reiterated that funding 
priority data were complete and accurate until they were replaced.

In addition, we found that, for five discretionary grant programs, two 
program offices did not submit the memorandum, as the guidance states 
they should, from the program offices' senior resource official 
approving the fiscal year 2005 funding priorities. Consequently, OGD 
listed these funding priorities in the CFDA without assurance that the 
information was accurate. For example, EPA's Office of Air and 
Radiation did not provide a memorandum for the funding priorities it 
submitted to OGD for four grant programs. Although OGD's guidance 
states that senior resource officials "must" approve funding 
priorities, the guidance only states that the senior resource officials 
"should" provide the memorandum to the OGD Director. However, OGD 
officials confirmed to us that the memorandum was required and they 
believed that OGD guidance may not be clear.

Finally, OGD's guidance only states that funding priorities must be 
provided for discretionary grant programs, but according to OGD 
officials, funding priorities are required for both discretionary and 
nondiscretionary grant programs. While the guidance does not state this 
requirement for nondiscretionary grants, these officials told us that 
the program offices understood that they had to submit funding 
priorities for nondiscretionary grants and did so.

EPA Does Not Consistently Provide Information on Funding Level 
Estimates:

For fiscal year 2004, most CFDA program descriptions had funding 
estimates, but EPA did not include estimated funding levels for 7 of 
the 68 discretionary grants programs, as table 2 shows. OGD guidance 
states that financial information must be provided and that it should 
include funding level estimates. Without complete funding information, 
potential applicants cannot determine the level of funding available, 
which could affect their decision to apply.

Table 2: EPA Grant Programs with and without Fiscal Year 2004 Funding 
Level Estimates in the August 2004 CFDA:

Grant type: Discretionary; 
Number of grant programs: 68; 
Number of grant programs without FY 2004 funding level estimates: 7; 
Number of grant programs with FY 2004 funding level estimates: 61. 

Grant type: Nondiscretionary; 
Number of grant programs: 10; 
Number of grant programs without FY 2004 funding level estimates: 0; 
Number of grant programs with FY 2004 funding level estimates: 10.

Grant type: Total; 
Number of grant programs: 78; 
Number of grant programs without FY 2004 funding level estimates: 7; 
Number of grant programs with FY 2004 funding level estimates: 71.

Source: GAO analysis of CFDA data.

[End of table]

Three of the seven program descriptions in the CFDA lacked complete 
funding information because one program office failed to provide OGD 
with the estimated funding levels, and OGD did not take the follow-up 
action its guidance called for to obtain this information from the 
program. The other four programs lacking funding estimates involved 
multiple program offices. However, OGD did not designate a single 
program official to serve as a focal point for reporting a consolidated 
funding estimate to OGD, and therefore no such funding estimate was 
presented in the CFDA.

EPA Has Created More Program-Specific Codes But Continues to Use 
Miscellaneous Program Codes in the CFDA:

In 2001, EPA's Inspector General reported that EPA had inappropriately 
placed program-specific grants under the miscellaneous CFDA program 
code 66.606, entitled "Surveys, Studies, Investigations, and Special 
Purpose Grants."[Footnote 14] By combining multiple grant programs 
under one miscellaneous, nonspecific program code, EPA makes it 
difficult for potential applicants to find information about specific 
grants, thereby making the CFDA's information less useful.

In 2002, OGD issued guidance, which it updates annually, requesting 
program offices to reduce their use of the 66.606 program code and 
place grants in more program-specific CFDA program codes. To support 
this effort, EPA created six new CFDA codes for "Surveys, Studies, 
Investigations, and Special Purpose Grants": one each for Clean Air 
(66.034), Safe Drinking Water (66.424), Clean Water (66.436), Office of 
Research and Development (66.510), Office of Administrator (66.610), 
and Educational Outreach (66.716). In addition, OGD officials told us 
that they created another 25 CFDA program codes to better identify 
grants with specific programs.

At the same time, OGD allowed existing 66.606 grants to continue under 
this code until this grant funding ended. It also instructed program 
offices to use the 66.606, program code--"Surveys, Studies, 
Investigations, and Special Purpose Grants"--for both congressional 
earmarks and for multi-media grants (i.e., those with more than one 
statutory authority).

We are concerned by this action for two reasons. First, OGD officials 
could provide no rationale for why congressional earmarks and multi-
media grants should be combined into one program code. The 66.606 CFDA 
program code therefore continues to be a miscellaneous code. Second, it 
is inaccurate to describe congressional earmarks only as "Surveys, 
Studies, Investigations, and Special Purpose Grants"--a term that EPA 
has traditionally applied to research or similar grants. According to 
OGD officials, congressionally earmarked EPA grants are not limited to 
research.

Moreover, in March 2004,[Footnote 15] we reported that between fiscal 
years 1993 and 2003, EPA added grants to another broad miscellaneous 
code--CFDA program code 66.500, "Consolidated Research Grants.'' By 
combining research grants supporting multiple programs into one 
miscellaneous nonspecific code, EPA obscures information about specific 
programs, as it does with the use of the code 66.606.

OGD recognizes that it has a continuing problem with the use of 
miscellaneous CFDA codes. Its 2004 CFDA guidance reiterated to program 
offices that agency policy is to break up "overly-broad" CFDA program 
descriptions, including the six codes it has used since 2002 to better 
specify grants in the 66.606 program code. It has issued similar 
guidance for the 66.500 program code in 2004.

EPA Has Not Evaluated the Accuracy and Completeness of the CFDA 
Information:

OGD was not aware of continuing errors with funding priorities and 
funding level estimates in the CFDA until we identified them during our 
review, but it has begun taking steps to address them. Although OGD 
issued new guidance in 2002 to address criticisms of the CFDA 
information, OGD never evaluated the effectiveness of the guidance and 
its implementation. Periodic evaluation of the effectiveness of 
guidance and procedures is necessary to ensure that information is 
complete and accurate. Such an evaluation could have alerted OGD 
officials to the problems we identified on funding priorities and 
funding levels in the CFDA and allowed them to take corrective actions.

EPA Has Not Conducted a Comprehensive Data Quality Review of the IGMS:

During the course of our review, we also identified inaccuracies in 
EPA's Integrated Grants Management System (IGMS), which OGD uses to 
generate reports on its grant programs to the public and the Congress. 
The IGMS's inaccuracies could impair EPA's ability to accurately and 
comprehensively inform the public and the Congress about its $4 billion 
annual investment in grants.

According to OGD officials, since the IGMS and CFDA report on similar 
information, the two sources should be consistent. We found, however, 
that the CFDA and IGMS were not always consistent and that the 
information extracted from the IGMS could be inaccurate. For example, 
the IGMS information OGD officials provided to us listed the grant 
program, State Grants to Reimburse Operators of Small Water Systems for 
Training and Certification Costs (66.471), as having $5.3 million in 
discretionary grant funds; the CFDA correctly listed this program as 
nondiscretionary. When we brought this inconsistency to OGD's 
attention, officials explained that they had incorrectly drawn 
information from the IGMS,[Footnote 16] thereby incorrectly classifying 
the program as discretionary.

We also found instances in which the IGMS incorrectly placed funding in 
one grant program when the funding belonged in a different program. As 
a result, the IGMS information on funding levels was inaccurate for a 
number of programs. For example, according to the IGMS, the Air 
Pollution Control Program Support grant program had about $471,000 in 
discretionary grant funds and about $76 million in nondiscretionary 
grant funds for fiscal year 2004. However, when we questioned this 
allocation because of information in the CFDA to the contrary, OGD 
found that the $471,000 in discretionary funding belonged in another 
program. Thus, the IGMS incorrectly overstated funding for the air 
pollution control support program by $471,000 and understated the 
funding for another program by the same amount.

OGD officials acknowledged the problems with inaccurate funding data in 
the IGMS. They said that in June 2004, after learning that project 
officers were finding it difficult to link their grants to the 
appropriate CFDA program codes in the IGMS, they instituted new IGMS 
controls. OGD added a "dropdown" menu in the IGMS to help staff 
accurately connect grants to CFDA codes. However, OGD did not correct 
the data that had been inaccurately entered before June 2004.

OGD has never conducted a comprehensive, systemwide data quality review 
of the IGMS, despite the importance of the database for reporting on 
EPA's $4 billion annual investment in grants to the public and the 
Congress. Furthermore, in 2002, EPA issued guidelines for ensuring the 
quality of information.[Footnote 17] These guidelines state, among 
other things, that the agency's offices assess existing data to verify 
that they are of sufficient quantity and quality for their intended 
use. OGD officials have not yet taken the steps identified in these 
guidelines to ensure IGMS data quality.

Conclusions:

OGD has not resolved its long-standing problem of consistently 
providing complete and accurate information to the public and potential 
applicants on grant opportunities in the CFDA. While OGD has issued 
guidance on gathering and presenting correct and accurate information 
in the CFDA, we found weaknesses in the guidance and OGD's 
implementation of it that contributed to the lack of accurate and 
complete information in the CFDA. Without reviewing the effectiveness 
of its guidance and implementation, OGD was unable to detect these 
problems. Until OGD corrects these problems, it will not fully realize 
its goal of promoting competition in awarding grants by providing 
complete and accurate information to potential grant applicants.

Furthermore, OGD's IGMS contains inaccuracies that could impair EPA's 
ability to inform the public and the Congress about its $4 billion 
annual investment in grants. A comprehensive, systemwide data quality 
review is necessary to ensure the accuracy of information reported to 
the public and the Congress.

Recommendations for Executive Action:

To address EPA's continuing problems in consistently providing complete 
and accurate information on grant opportunities to the public in the 
CFDA, we recommend that the Administrator, EPA require the Director of 
the Office of Grants and Debarment to:

* revise the agency's CFDA guidance to state that:

- both current and upcoming fiscal years' funding priorities be 
provided and clearly identified for inclusion in the CFDA;

- information on funding priorities for both discretionary and 
nondiscretionary grant programs be provided in the CFDA; and:

- senior resource officials provide a memorandum documenting approval 
of program funding priorities;

* work closely with:

- program offices so that they always provide complete program 
descriptions, including funding priorities and funding estimates; and:

- senior resource officials to ensure that they provide a memorandum 
documenting approval of the program's funding priorities;

* continue to work on placing grant opportunities under program-
specific codes instead of under miscellaneous codes; and:

* periodically evaluate the effectiveness of CFDA guidance and its 
implementation to ensure that the CFDA contains complete and accurate 
information.

We further recommend that OGD conduct a comprehensive, systemwide data 
quality review of the IGMS in order to ensure the accuracy of the 
information reported from the database to the public and the Congress.

Agency Comments and Our Evaluation:

We provided a draft of this report to EPA for its review and comment. 
The Director of EPA's Office of Grants and Debarment provided oral 
comments. EPA generally agrees with the recommendations in our draft 
report. EPA has formed a work group, which will consider the full range 
of issues we identified regarding both the CFDA and the IGMS. However, 
EPA did not want to revise its guidance to provide both current and 
upcoming fiscal years' funding priorities in the CFDA. The Director 
believes that OGD can best address GAO's concerns by keeping the 
current year's funding priorities in the CFDA and announcing the 
upcoming year's funding priorities--possibly later in the CFDA cycle--
when EPA can ensure their accuracy.

Although we believe that potential applicants would benefit from having 
funding priorities announced in advance, we believe that announcing the 
upcoming year's funding priorities when EPA can ensure their accuracy 
would meet the intent of our recommendation. The Director is also 
asking the work group to review various options for managing the entire 
CFDA process, including when to list the upcoming fiscal year's funding 
priorities in the CFDA. OGD also provided a number of technical 
comments, which we incorporated as appropriate.

We will send copies of this report to the congressional committees with 
jurisdiction over EPA and its activities; the Acting Administrator, 
EPA; and the Director, Office of Management and Budget. In addition, 
this report will be available at no charge on the GAO Web site at 
http://www.gao.gov.

If you or your staff have any questions about this report or need 
additional information, please contact me at (202) 512-3841. Key 
contributors to this report were David Bobruff, Andrea Wamstad Brown, 
Rebecca Shea, Carol Herrnstadt Shulman, Bruce Skud, and Amy Webbink.

Sincerely yours,

Signed by: 

John B. Stephenson:

Director, Natural Resources and Environment:

Enclosure:

Enclosure:

EPA Grant Programs Listed in the CFDA:

Tables 3 and 4 present the Environmental Protection Agency's (EPA) 
grant programs in the Catalog of Federal Domestic Assistance (CFDA) of 
discretionary grants (which the CFDA refers to as project grants) and 
nondiscretionary grants (which the CFDA refers to as formula grants), 
respectively.

Table 3: EPA Discretionary Grant Programs in August 2004 CFDA:

CFDA program code: 66.001; 
CFDA program title: Air Pollution Control Program Support. 

CFDA program code: 66.032; 
CFDA program title: State Indoor Radon Grants. 

CFDA program code: 66.033; 
CFDA program title: Ozone Transport . 

CFDA program code: 66.034; 
CFDA program title: Surveys Studies, Investigations Demonstrations and 
Special Purpose Activities relating to the Clean Air Act. 

CFDA program code: 66.305; 
CFDA program title: Compliance Assistance-Support for Services to the 
Regulated Community and Other Assistance Providers. 

CFDA program code: 66.306; 
CFDA program title: Environmental Justice Collaborative Problem-Solving 
Grants Program. 

CFDA program code: 66.418; 
CFDA program title: Construction Grants for Wastewater Treatment Works. 

CFDA program code: 66.424; 
CFDA program title: Surveys, Studies, Demonstrations and Special 
Purpose Grants - Section 1442 of the Safe Drinking Water Act. 

CFDA program code: 66.436; 
CFDA program title: Surveys, Studies, Investigations, Demonstrations, 
and Training Grants and Cooperative Agreements - Section 104(B)(3) of 
the Clean Water Act. 

CFDA program code: 66.437; 
CFDA program title: Long Island Sound Program. 

CFDA program code: 66.439; 
CFDA program title: Targeted Watershed Grants. 

CFDA program code: 66.456; 
CFDA program title: National Estuary Program. 

CFDA program code: 66.461; 
CFDA program title: Wetland Program Grants. 

CFDA program code: 66.463; 
CFDA program title: Water Quality Cooperative Agreements. 

CFDA program code: 66.466; 
CFDA program title: Chesapeake Bay Program. 

CFDA program code: 66.467; 
CFDA program title: Wastewater Operator Training Grant Program 
(Technical Assistance). 

CFDA program code: 66.469; 
CFDA program title: Great Lakes Program. 

CFDA program code: 66.472; 
CFDA program title: Beach Monitoring and Notification Program 
Implementation Grants. 

CFDA program code: 66.473; 
CFDA program title: Direct Implementation Tribal Cooperative 
Agreements. 

CFDA program code: 66.475; 
CFDA program title: Gulf of Mexico Program. 

CFDA program code: 66.476; 
CFDA program title: Security Planning Grants For Large Drinking Water 
Utilities. 

CFDA program code: 66.477; 
CFDA program title: Vulnerability Assessments and Related Security 
Improvements at Large Privately-Owned Community Drinking Water 
Utilities. 

CFDA program code: 66.478; 
CFDA program title: Water Security Training and Technical Assistance. 

CFDA program code: 66.5; 
CFDA program title: Environmental Protection - Consolidated Research. 

CFDA program code: 66.508; 
CFDA program title: Senior Environmental Employment Program. 

CFDA program code: 66.509; 
CFDA program title: Science to Achieve Results (STAR) Program. 

CFDA program code: 66.51; 
CFDA program title: Surveys, Studies, Investigations and Special 
Purpose Grants within the Office of Research and Development. 

CFDA program code: 66.511; 
CFDA program title: Office of Research and Development Consolidated 
Research. 

CFDA program code: 66.513; 
CFDA program title: Greater Research Opportunities Fellowship Program. 

CFDA program code: 66.514; 
CFDA program title: Science to Achieve Results (STAR) Fellowship 
Program. 

CFDA program code: 66.515; 
CFDA program title: Greater Opportunities Research Program. 

CFDA program code: 66.516; 
CFDA program title: P3 Award: National Student Design Competition for 
Sustainability. 

CFDA program code: 66.6; 
CFDA program title: Environmental Protection Consolidated Grants-
Program Support. 

CFDA program code: 66.604; 
CFDA program title: Environmental Justice Hazardous Substances Research 
Small Grants to Community Groups. 

CFDA program code: 66.605; 
CFDA program title: Performance Partnership Grants. 

CFDA program code: 66.606; 
CFDA program title: Surveys, Studies, Investigations, and Special 
Purpose Grants. 

CFDA program code: 66.607; 
CFDA program title: Training and Fellowships for the Environmental 
Protection Agency. 

CFDA program code: 66.608; 
CFDA program title: Environmental Information Exchange Network Grant 
Program. 

CFDA program code: 66.609; 
CFDA program title: Protection of Children and Older Adults (Elderly) 
from Environmental Health Risks. 

CFDA program code: 66.61; 
CFDA program title: Surveys, Studies, Investigations and Special 
Purpose Grants within the Office of the Administrator. 

CFDA program code: 66.611; 
CFDA program title: Environmental Policy and Innovation Grants. 

CFDA program code: 66.7; 
CFDA program title: Consolidated Pesticide Enforcement Cooperative 
Agreements. 

CFDA program code: 66.701; 
CFDA program title: Toxic Substances Compliance Monitoring Cooperative 
Agreements. 

CFDA program code: 66.707; 
CFDA program title: TSCA Title IV State Lead Grants Certification of 
Lead-Based Paint Professionals. 

CFDA program code: 66.708; 
CFDA program title: Pollution Prevention Grants Program. 

CFDA program code: 66.709; 
CFDA program title: Capacity Building Grants and Cooperative Agreements
for States and Tribes. 

CFDA program code: 66.714; 
CFDA program title: Pesticide Environmental Stewardship - Regional 
Grants . 

CFDA program code: 66.715; 
CFDA program title: Childhood Blood-Lead Screening and Lead Awareness 
(Educational) Outreach for Indian Tribes. 

CFDA program code: 66.716; 
CFDA program title: Surveys, Studies, Investigations, Training 
Demonstrations, and Educational Outreach. 

CFDA program code: 66.717; 
CFDA program title: Source Reduction Assistance. 

CFDA program code: 66.802; 
CFDA program title: Superfund State, Political Subdivision, and Indian 
Tribe Site-Specific Cooperative Agreements. 

CFDA program code: 66.804; 
CFDA program title: State and Tribal Underground Storage Tanks Program. 

CFDA program code: 66.805; 
CFDA program title: Leaking Underground Storage Tank Trust Fund 
Program. 

CFDA program code: 66.806; 
CFDA program title: Superfund Technical Assistance Grants (TAG) for 
Community Groups at National Priority List (NPL) Sites. 

CFDA program code: 66.808; 
CFDA program title: Solid Waste Management Assistance. 

CFDA program code: 66.809; 
CFDA program title: Superfund State and Indian Tribe Core Program 
Cooperative Agreements. 

CFDA program code: 66.81; 
CFDA program title: Chemical Emergency Preparedness and Prevention 
(CEPP) Technical Assistance Grants Program. 

CFDA program code: 66.812; 
CFDA program title: Tribal Hazardous Waste Grants. 

CFDA program code: 66.813; 
CFDA program title: Alternative or Innovative Treatment Technology 
Research, Demonstration, Training, and Hazardous Substance Research 
Grants. 

CFDA program code: 66.814; 
CFDA program title: Brownfields Training, Research, and Technical 
Assistance Grants and Cooperative Agreements. 

CFDA program code: 66.815; 
CFDA program title: Brownfield Job Training Cooperative Agreements. 

CFDA program code: 66.816; 
CFDA program title: Headquarter and Regional Underground Storage Tanks 
Program. 

CFDA program code: 66.817; 
CFDA program title: State and Tribal Response Program Grants. 

CFDA program code: 66.818; 
CFDA program title: Brownfields Assessment and Cleanup Cooperative 
Agreements. 

CFDA program code: 66.926; 
CFDA program title: Indian Environmental General Assistance Program 
(GAP). 

CFDA program code: 66.931; 
CFDA program title: International Financial Assistance Projects 
Sponsored by the Office of International Affairs. 

CFDA program code: 66.95; 
CFDA program title: Environmental Education and Training Program. 

CFDA program code: 66.951; 
CFDA program title: Environmental Education Grants. 

Source:  GAO analysis of CFDA data. 

[End of table]

Table 4:  EPA Nondiscretionary Grant Programs in August 2004 CFDA: 

CFDA program code: 66.419; 
CFDA program title: Water Pollution Control State and Interstate 
Program Support. 

CFDA program code: 66.432; 
CFDA program title: State Public Water System Supervision. 

CFDA program code: 66.433; 
CFDA program title: State Underground Water Source Protection. 

CFDA program code: 66.454; 
CFDA program title: Water Quality Management Planning. 

CFDA program code: 66.458; 
CFDA program title: Capitalization Grants for Clean Water State 
Revolving Fund. 

CFDA program code: 66.46; 
CFDA program title: Nonpoint Source Implementation Grants. 

CFDA program code: 66.468; 
CFDA program title: Capitalization Grants for Drinking Water State 
Revolving Fund. 

CFDA program code: 66.471; 
CFDA program title: State Grants to Reimburse Operators of Small Water 
Systems for Training and Certification Costs. 

CFDA program code: 66.474; 
CFDA program title: Water Protection Grants to the States . 

CFDA program code: 66.801; 
CFDA program title: Hazardous Waste Management State Program Support. 

Source:  GAO analysis of CFDA data. 

[End of table]

(360507):

FOOTNOTES

[1] The General Services Administration and Office of Management and 
Budget's CFDA is a governmentwide compendium of federal programs, 
projects, and activities that provide assistance or benefits to the 
American public. Assistance includes, but is not limited to, financial 
assistance such as grants and cooperative agreements. For simplicity, 
we are referring to grants and cooperative agreements as grants. EPA 
uses other tools for announcing some grant programs, such as the 
Federal Register, and all competitive funding opportunities are 
announced on www.Grants.gov.

[2] EPA uses the CFDA to comply with an Office of Management and Budget 
requirement that federal agencies announce funding priorities for 
discretionary grants.

[3] The CFDA refers to discretionary grants as "project grants" and 
nondiscretionary grants as "formula grants." In addition to these 78 
grant programs, one EPA program provided technical assistance but no 
funding.

[4] OMB Circular No. A-102, Grants and Cooperative Agreements with 
State and Local Governments (10/7/94, as further amended 8/29/97); OMB 
Circular No. A-110, Uniform Administrative Requirements for Grants and 
Agreements with Institutions of Higher Education, Hospitals, and Other 
Non-Profit Organizations (11/19/93, as further amended 9/30/99).

[5] Senate Environment and Public Works Committee Majority Staff, 
Transparency in EPA Grants: Website Access to Available Grants and 
Disclosure of Recipients (Washington, D.C.: May 13, 2004).

[6] U.S. Environmental Protection Agency, Associate Administrator, 
Office of Congressional and Intergovernmental Relations, 
correspondence to the Chairman, Senate Committee on Environment and 
Public Works (Washington, D.C.: June 4, 2004). 

[7] EPA Office of Inspector General, EPA's Competitive Practices for 
Assistance Awards, Report No. 2001-P-00008 (Philadelphia, PA: May 21, 
2001). 

[8] GAO, Grants Management: EPA Needs to Strengthen Efforts to Address 
Persistent Challenges, GAO-03-846 (Washington, D.C.: Aug. 29, 2003).

[9] The order applied to most discretionary grant programs or 
individual grants of more than $75,000. 

[10] EPA Office of Grants and Debarment, Memorandum: Preparation and 
Submission of Catalog of Federal Domestic Assistance Program 
Information for Update Cycle 2002, Mar. 3, 2002.

[11] EPA Office of Grants and Debarment, Memorandum: Preparation and 
Submission of Catalog of Federal Domestic Assistance Program 
Information for Basic Cycle 2004, Apr. 8, 2004.

[12] U.S. Environmental Protection Agency, Grants Management Plan: 
2003-2008, EPA-216-R-03-001 (Washington, D.C.: Apr. 2003).

[13] Senior resource officials are typically deputy assistant 
administrators in headquarters offices and assistant regional 
administrators in regional offices, and are in charge of strengthening 
agencywide fiscal resource management while also ensuring compliance 
with laws and regulations.

[14] EPA Office of Inspector General, EPA's Competitive Practices for 
Assistance Awards, Report No. 2001-P-00008 (Philadelphia, PA: May 21, 
2001). 

[15] GAO, Grants Management: EPA Needs to Better Document Its Decisions 
for Choosing between Grants and Contracts, GAO-04-459 (Washington, 
D.C.: Mar. 31, 2004). 

[16] The IGMS does not label grant programs as discretionary or 
nondiscretionary; instead OGD had to create definitions of 
discretionary and nondiscretionary in order to sort the information in 
the IGMS and extract it. 

[17] U.S. Environmental Protection Agency Office of Environmental 
Information, Guidelines for Ensuring and Maximizing the Quality, 
Objectivity, Utility, and Integrity of Information Disseminated by the 
Environmental Protection Agency, EPA/260R-02-008 (Oct. 2002).