Drug-Free Communities Support Program:

Stronger Internal Controls and Other Actions Needed to Better Manage the Grant-Making Process

GAO-08-57: Published: Jul 31, 2008. Publicly Released: Sep 2, 2008.

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Twenty-five percent of American students ages 13-17 reported using illicit drugs in 2007. The Drug-Free Communities Support Program provides grants to community coalitions involved in reducing youth substance abuse. The Office of National Drug Control Policy (ONDCP) administers the program. ONDCP selected the Substance Abuse and Mental Health Services Administration (SAMHSA) to operate the grant program in fiscal year 2005. In 2005, ONDCP did not award grants to some coalitions who had previously received grant funds (renewal grantees). GAO was asked to assess (1) the extent to which ONDCP and SAMHSA administered grant-related activities for fiscal years 2005 and 2006 consistent with federal internal control standards, statutory requirements, and other guidance and (2) the steps ONDCP has taken since 2006 regarding its administration of grant-related activities. GAO analyzed and compared program documents and grant activities to established guidance, such as federal internal control standards and statutory requirements, and interviewed key program management officials.

In fiscal years 2005 and 2006, ONDCP and SAMHSA did not always adhere to applicable federal internal control standards, statutory requirements, and other guidance during the grant-making process. Standards for internal control in the federal government call for agencies to conduct ongoing monitoring of a program's performance, but ONDCP did not conduct such monitoring of SAMHSA or the program overall. Thus, ONDCP increased its risk of not providing reasonable assurance that SAMHSA conducted grant activities, such as eligibility screening. Internal control standards also require that agencies maintain documentation that grant applicants met eligibility requirements each fiscal year. While SAMHSA officials said that they screened all renewal grantees for eligibility in 2005 and ONDCP officials said they screened all initial grantees in 2006, documentation indicating that such screening had occurred was missing from 47 of the 66 grantee files GAO reviewed. ONDCP also lacked a process to ensure that all renewal applicants met statutory eligibility requirements. For example, ONDCP used a separate screening process in fiscal year 2005 that included a criterion that grantees limit funding for direct services, such as enrolling individuals in a drug prevention program. Only renewal grant applicants that met this or one of two other criteria underwent further screening for statutory eligibility. As a result, ONDCP funded about 86 percent of renewal grantees in 2005 without ensuring that they met the statutory eligibility criteria. Leading practices for collaborating agencies call for strategies to ensure common outcomes. However, the inter-agency agreement between ONDCP and SAMHSA did not fully define roles and responsibilities and lacked specific guidance to SAMHSA on eligibility screening. As a result, confusion occurred over issues, such as the eligibility criteria to apply, hampering the two agencies in their efforts to effectively manage the grant-making process. Since 2006, ONDCP has addressed some of the issues described above, by (1) clarifying its role for the program in its 2007 agreement with SAMHSA, (2) establishing management groups to address monitoring issues, and (3) eliminating its use of the direct services eligibility criterion. However, some internal control and other challenges remain. For example, ONDCP has not yet put a mechanism in place to ensure that documentation confirming eligibility is maintained in the grant files. ONDCP also has not documented its approach to overseeing SAMHSA and the program. Without defined oversight activities for ensuring completion of the work, ONDCP lacks reasonable assurance that required tasks are being performed in accordance with management's directives. Also, roles and responsibilities for key elements of grant administration remain largely undefined in that the agencies have not clarified certain services SAMHSA is to provide related to awarding grants or the role of the program Administrator. Without defining these roles, confusion on the steps to follow in managing the program could continue to occur. Finally, as in 2006, ONDCP officials told GAO that they did not screen renewal grant applicants for eligibility in 2007 because the screening that applicants undergo when they first receive a grant is sufficient.

Status Legend:

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  • Review Pending-GAO has not yet assessed implementation status.
  • Open-Actions to satisfy the intent of the recommendation have not been taken or are being planned, or actions that partially satisfy the intent of the recommendation have been taken.
  • Closed-implemented-Actions that satisfy the intent of the recommendation have been taken.
  • Closed-not implemented-While the intent of the recommendation has not been satisfied, time or circumstances have rendered the recommendation invalid.
    • Review Pending
    • Open
    • Closed - implemented
    • Closed - not implemented

    Recommendations for Executive Action

    Recommendation: To strengthen its administration, oversight, and internal controls for the Drug-Free Communities Support Program, the Director of the Office of National Drug Control Policy should develop and document its approach to monitoring and overseeing SAMHSA and the program as a whole.

    Agency Affected: Office of National Drug Control Policy

    Status: Closed - Implemented

    Comments: The Office of National Drug Control Policy (ONDCP) is responsible for the administration of the Drug-Free Communities (DFC) Support Program. Fiscal year 2005 was the first year that the grant program was operated by ONDCP and the Substance Abuse and Mental Health Services Administration (SAMHSA) under an interagency agreement. In 2008, we found that ONDCP had not developed or documented its approach to monitoring SAMHSA's administration of the grant program and overseeing the grant program as a whole. For example, neither the fiscal year 2007 interagency agreement between ONDCP and SAMHSA nor other documentation associated with the grant-making process defined how ONDCP would oversee SAMHSA in conducting its monitoring responsibilities. Without defined oversight activities for ensuring successful completion of the work across all activities, ONDCP lacked reasonable assurance that required tasks were being performed in accordance with its directives. As a result, we recommended that the Director of ONDCP develop and document its approach to monitoring and overseeing SAMHSA and the program as a whole. ONDCP and SAMHSA jointly signed an interagency agreement for fiscal year 2009 that outlined new oversight responsibilities. The agreement contained sections for general and specific ONDCP and SAMHSA roles and responsibilities, including those related to program oversight and the grant awards process. A current fiscal year 2012 interagency agreement references, and continues, the oversight outlined in the 2009 agreement. Further, ONDCP and SAMHSA jointly developed Standard Operating Procedures as the process guide for routine operations of the DFC program. These procedures include, among other things, ONDCP oversight roles and responsibilities; SAMHSA oversight roles and responsibilities; SAMHSA DFC program administration, monitoring, and technical assistance; and the grant award process. These revised documents are consistent with our recommendation.

    Recommendation: To strengthen its administration, oversight, and internal controls for the Drug-Free Communities Support Program, the Director of the Office of National Drug Control Policy should ensure that the coalitions receiving an initial grant or a renewal grant satisfy all of the statutory eligibility criteria for each fiscal year and that this is fully documented.

    Agency Affected: Office of National Drug Control Policy

    Status: Closed - Implemented

    Comments: The Office of National Drug Control Policy (ONDCP) is responsible for the administration of the Drug-Free Communities (DFC) Support Program. Fiscal year 2005 was the first year that the grant program was operated by ONDCP and the Substance Abuse and Mental Health Services Administration (SAMHSA) under an interagency agreement. In 2008, we found that ONDCP did not screen renewal grant applicants for statutory eligibility in fiscal year 2007, nor did ONDCP require grantees to submit any supporting documentation to show that the statutory eligibility criteria had been met. Without screening for statutory eligibility, ONDCP increased its risk that the renewal grant applicants it awarded funding to in fiscal year 2007 were not statutorily eligible for such funding. As a result, we recommended that the Director of ONDCP ensure that the coalitions receiving an initial grant or a renewal grant satisfy all of the statutory eligibility criteria for each fiscal year and that this is fully documented. ONDCP and SAMHSA included in the fiscal year 2009 interagency agreement and the Standard Operating Procedures for the DFC program processes for verifying the statutory eligibility for initial and renewal grantees. Specifically, new applicants are to be jointly screened to determine that the grantee has met all of the statutory eligibility criteria, and screening sheets are to be included with the grantee's application file. As part of the annual grant renewal process, grantees are required to complete an eligibility certification checklist, which captures all of the statutory eligibility criteria. These processes are consistent with our recommendation.

    Recommendation: To strengthen its administration, oversight, and internal controls for the Drug-Free Communities Support Program, the Director of the Office of National Drug Control Policy should fully define the roles and responsibilities of SAMHSA and ONDCP, including those of the Drug-Free Communities Support Program Administrator, in the inter-agency agreement prepared for each fiscal year.

    Agency Affected: Office of National Drug Control Policy

    Status: Closed - Implemented

    Comments: The Office of National Drug Control Policy (ONDCP) is responsible for the administration of the Drug-Free Communities (DFC) Support Program. Fiscal year 2005 was the first year that the grant program was operated by ONDCP and the Substance Abuse and Mental Health Services Administration (SAMHSA) under an interagency agreement. In 2008, we found that the two agencies had not developed policies and procedures to clarify certain services SAMHSA would provide related to awarding grants. For example, the fiscal year 2007 interagency agreement did not specify what the programmatic and budget review processes were, when they should be completed, and by which agency. Additionally, the fiscal year 2007 agreement did not specifically define the role of the Administrator for the Drug-Free Communities Support Program. Without taking action to fully define these roles and responsibilities, confusion on the steps to follow in managing the program could occur. As a result, we recommended that the Director of ONDCP fully define the roles and responsibilities of SAMHSA and ONDCP, including those of the Drug-Free Communities Support Program Administrator, in the inter-agency agreement prepared for each fiscal year. ONDCP and SAMHSA jointly signed an interagency agreement for fiscal year 2009 that outlined roles and responsibilities for the two agencies. The agreement contained sections for general and specific ONDCP and SAMHSA roles and responsibilities, including those for the Administrator and those related to program oversight and the budget review process. A current fiscal year 2012 interagency agreement references, and continues, the oversight outlined in the 2009 agreement. Further, ONDCP and SAMHSA jointly developed Standard Operating Procedures as the process guide for routine operations of the DFC program. These procedures include, among other things, ONDCP oversight roles and responsibilities; SAMHSA oversight roles and responsibilities; SAMHSA DFC program administration, monitoring, and technical assistance; and the grant award process. These revised documents are consistent with our recommendation.

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