Faith-Based and Community Initiative:

Improvements in Monitoring Grantees and Measuring Performance Could Enhance Accountability

GAO-06-616: Published: Jun 19, 2006. Publicly Released: Jul 18, 2006.

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The Administration's efforts to improve the federal government's provision of social services through its Faith-Based and Community Initiative have sparked considerable interest. GAO was asked to examine (1) the activities of the initiative-related centers in five federal agencies; (2) the grant award procedures for selected grants; (3) the extent to which selected federal and state agencies are providing information on and ensuring compliance with safeguards designed to protect faith-based organizations (FBO), beneficiaries, and the government; and (4) how the progress of the initiative is being measured. We interviewed government officials administering 10 grant programs and officials from 26 FBOs.

In 2001 the Administration introduced the Faith-Based and Community Initiative and established initiative-related centers in five federal agencies. The centers employ a range of activities and resources to implement the initiative. Since fiscal year 2002, these centers have cumulatively spent more than $24 million on administrative activities. In reviewing grant applications and awarding grants, federal and state agencies reported using the same process for FBOs as they do for other organizations in the 10 grant programs we reviewed. Since 2001, federal agencies have awarded over $500 million through new grant programs to provide training and technical assistance to faith-based and community organizations and to increase the participation of these organizations in providing federally funded social services. The government agencies administering the programs that we reviewed provided grantees with some information on the safeguards designed to protect the interests of FBOs, beneficiaries, and the government. Most of the agencies provided grantees with an explicit statement on the safeguard prohibiting the use of direct federal funds for inherently religious activities. If these activities are offered, they must be offered separately in time or location from services provided with direct federal funds and must be voluntary for the beneficiary. However, we found that Justice's regulation and guidance related to these activities is unclear for its correctional programs. We also found that only four programs provided a statement on the rights of program beneficiaries and only three provided information on permissible hiring by FBOs. While officials in all 26 FBOs that we visited said that they understood that federal funds cannot be used for inherently religious activities, a few FBOs described activities that appeared to violate this safeguard. Four of the 13 FBOs that provided voluntary religious activities did not separate in time or location some religious activities from federally funded program services. Government agencies are not required to monitor FBO grantees differently than secular organizations. Few of the federal and state agencies administering these programs included references in their monitoring guidelines on grantee compliance with the safeguards. OMB and the White House Office of Faith-Based and Community Initiatives assess agencies' progress in implementing the short-term goals of the initiative and highlight this progress through a number of published vehicles. However, it is unclear whether the data reported on grants awarded to FBOs provide policymakers with a sound basis to assess the progress of agencies in meeting the initiative's long-term goal of greater participation of faith-based and community organizations. Moreover, little information is available to assess progress toward another long-term goal of improving participant outcomes because outcome-based evaluations for many pilot programs have not begun. Also, OMB faces other challenges in measuring and reporting on agencies' progress in meeting the long-term goals of the initiative.

Recommendations for Executive Action

  1. Status: Closed - Not Implemented

    Comments: According to the White House Office of Faith-Based and Community Initiative, OMB is not planning to establish a definition for faith-based organizations. As they stated in their agency comments (June 2006), they are concerned about the practical and legal difficulties inherent in developing a uniform definition for what constitutes an faith-based organization. In September 2008, OMB reported that they do not plan to develop such a definition. They note that the data is intended as a tool for providing a fuller understanding of the organizations that receive competitive federal grants and not as a definitive measure the Initiative's success. In FY10, after repeated requests for a status update, OMB did not provide us with any information.

    Recommendation: To improve accountability of the Faith-Based and Community Initiative, the Director of OMB should work with the Secretaries of Education, Health and Human Service, Housing and Urban Development, and Labor, and Justice's Attorney General, to develop a consistently applied method that will provide more accurate data on which organizations receiving federal funds are faith-based. This effort could consider options such as developing consistently applied criteria of what constitutes a faith-based organization, making the voluntary OMB survey of grant applicants mandatory, or modifying OMB's mandatory grant application form to include a category for faith-based organizations.

    Agency Affected: Executive Office of the President: Office of Management and Budget

  2. Status: Closed - Implemented

    Comments: In its September 11, 2006, corrective action plan (ALG #06-045), the Department of Justice provided the language it had approved to be incorporated into contracts to clarify the scope of the exception to the prohibition on using federal funds for inherently religious activities. The corrective action plan stated that the Department of Justice would insert this new language into contracts beginning October 1, 2006. Justice provided an example of a contract for a residential reentry center (RRC) formerly community correction centers. The contract includes a detailed section that clarifies when an offender can and cannot receive religious activities from an RRC staff, including a notification that chaplains will not be reimbursed with federal funds for providing spiritual services.

    Recommendation: To ensure that contractors for Justice's correctional programs understand the exception to the prohibition on using federal funds for inherently religious activities, the Attorney General should include a clear explanation of the exception and its scope in the contracts for Justice's correctional programs.

    Agency Affected: Department of Justice

  3. Status: Closed - Implemented

    Comments: In September 2006, the Department of Justice issued a corrective action plan noting that the Federal Bureau of Prisons had drafted language to be incorporated into the Residential Reentry Center (formerly known as the Community Corrections Center) contracts to clarify the scope of the exception for chaplains. In August 2007, Justice provided us with a copy of such a contract that included the additional language as we recommended.

    Recommendation: To ensure that contractors for Justice's correctional programs understand the exception to the prohibition on using federal funds for inherently religious activities, the Attorney General should clarify the scope of the exception for chaplains and organizations assisting chaplains to the general prohibition against using federal funds for religious activities.

    Agency Affected: Department of Justice

  4. Status: Closed - Not Implemented

    Comments: Because the new Administration changed the White House Faith-Based office (new name, possible new orientation), we waited to see if OMB would implement this recommendation. After GAO repeatedly contacted OMB for information in FY10, OMB did not provide us with any information as to how it would address this recommendation.

    Recommendation: To improve grantee understanding and federal agency oversight of the equal treatment regulations for programs in which faith-based organizations are eligible for federal funding, the Director of OMB should ensure that program-specific single audit supplements, where appropriate, include a reference to these safeguards.

    Agency Affected: Executive Office of the President: Office of Management and Budget

  5. Status: Closed - Implemented

    Comments: OMB has added to its Proud to Be document (which went into effect July 1, 2008) best practices that executive agencies must adhere to in order to receive a satisfactory performance rating from OMB. Several of the best practices relate to the monitoring tools of federal, state, and local agencies. Federal executive agencies are to coordinate with program offices within their departments to ensure appropriate monitoring that will in turn ensure compliance with the equal treatment regulations. Agencies must know 1) which office will be responsible for monitoring; 2) what means of monitoring will be used (site visits, spot checks by phone); 3)whether equal treatment regulations need to be added to existing compliance checklists; 4) and must work with appropriate offices within a specific agency to address issues when monitoring efforts uncover a violation. Guidance is also provided to the OMB examiners to ensure that the examiners ascertain from agency officials, when determining the PMA rating of each FBCI agency, the same 4 issues cited above.

    Recommendation: To improve grantee understanding and federal agency oversight of the equal treatment regulations for programs in which faith-based organizations are eligible for federal funding, the Director of OMB should direct federal agencies and, where appropriate, state agencies, to include a reference to the equal treatment safeguards in their monitoring tools the agencies use to oversee federally funded grantees.

    Agency Affected: Executive Office of the President: Office of Management and Budget

  6. Status: Closed - Implemented

    Comments: OMB has included in its guidance to OMB examiners, who oversee the President Management Agenda (PMA) rating) of each FBCI executive agency, that they are to confirm that all grant solicitations (for which faith-based and community groups are eligible) include information on the equal treatment regulations. According to OMB, if any grant solicitations are found not to contain appropriate references to the equal treatment regulations, the agency must demonstrate that steps have been take to ensure inclusion of the regulations in future solicitations.

    Recommendation: To improve grantee understanding and federal agency oversight of the equal treatment regulations for programs in which faith-based organizations are eligible for federal funding, the Director of OMB should ensure that all agencies with initiative-related centers include information on the equal treatment safeguards in program grant documents for which faith-based organizations are eligible.

    Agency Affected: Executive Office of the President: Office of Management and Budget

  7. Status: Closed - Implemented

    Comments: The Acting White House Office Faith-Based and Community Initiative Director stated that they have reassessed the two-long term goals and have determined that these two core goals remain the primary objectives of the FBCI. He noted that each FBCI center emphasizes a range of objectives that have developed each year, but the ultimate goals remain the same.

    Recommendation: To improve accountability of the Faith-Based and Community Initiative, the Director of OMB should develop a plan for measuring and reporting on progress in achieving the long-term goals of the faith-based and community initiative. This effort may involve reassessing the two current long-term goals to determine whether they should be revised and clarifying their connection to the Standards for Success.

    Agency Affected: Executive Office of the President: Office of Management and Budget

 

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