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entitled 'Recovery Act: Energy Efficiency and Conservation Block Grant 
Recipients Face Challenges Meeting Legislative and Program Goals and 
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United States Government Accountability Office: 
GAO: 

Report to the Congress: 

April 2011: 

Recovery Act: 

Energy Efficiency and Conservation Block Grant Recipients Face 
Challenges Meeting Legislative and Program Goals and Requirements: 

GAO-11-379: 

GAO Highlights: 

Highlights of GAO-11-379, a report to the Congress. 

Why GAO Did This Study: 

The American Recovery and Reinvestment Act of 2009 (Recovery Act) 
provided $3.2 billion for the Department of Energy’s (DOE) Energy 
Efficiency and Conservation Block Grant Program (EECBG) to develop and 
manage projects to improve energy efficiency and reduce energy use and 
fossil fuel emissions. The Recovery Act requires GAO to review funds 
made available under the act and to comment on recipients’ estimates 
of jobs created or retained. GAO examined (1) how EECBG recipients 
used EECBG funds and challenges they faced, if any; (2) DOE and 
recipients’ oversight and monitoring activities and challenges, if 
any; (3) the extent to which the EECBG program is meeting Recovery Act 
and program goals for energy savings; and (4) the quality of jobs data 
reported by Recovery Act recipients, particularly EECBG recipients. 
GAO also updates the status of open recommendations from previous 
bimonthly and recipient reporting reviews. GAO analyzed DOE recipient 
data and interviewed DOE officials and a nonprobability sample of 
EECBG recipients, among other things. 

What GAO Found: 

According to DOE data, EECBG recipients primarily used funds for 3 of 
the 14 activities eligible for EECBG funding. These activities are 
energy-efficiency retrofits, financial incentive programs, and 
buildings and facilities projects. Some DOE officials, recipients, and 
others identified challenges in obligating and spending funds due to 
local jurisdictional requirements and staff and resource limitations. 
In addition, in April 2010 DOE determined that many recipients were 
not on a trajectory to obligate and spend funds within specified time 
frames, so DOE issued new milestones for obligating and spending 
funds. Many recipients reported having had difficulty meeting the new 
milestones. DOE is taking steps to address these difficulties. 

According to DOE officials and documentation, DOE follows a 
programwide monitoring plan to oversee the use of Recovery Act funds 
and uses a variety of techniques to monitor recipients. Overall, 
recipients also use various methods to monitor contractors and 
subrecipients, but DOE does not always collect information on 
recipients’ monitoring activities. As a result, DOE does not always 
know whether the monitoring activities of recipients are sufficiently 
rigorous to ensure compliance with federal requirements. Some DOE 
officials, recipients, and others have reported to GAO that some DOE 
staff and recipients faced challenges with overseeing the use of 
funds, including (1) technical challenges with a Web-based reporting 
application DOE uses as a primary oversight tool and (2) staffing and 
expertise limitations, such as some recipients’ unfamiliarity with 
federal grant procedures. 

Recipients contacted and some DOE officials reported to GAO that 
recipients are using EECBG funds to develop projects designed to 
reduce energy use and increase energy savings in line with Recovery 
Act and program goals. However, DOE officials have experienced 
challenges in assessing the extent to which the EECBG program is 
meeting those goals. Because actual energy savings data are generally 
available only after a project is completed, DOE officials said that 
most recipients report estimates to comply with program reporting 
requirements. DOE takes steps to assess the reasonableness of these 
estimates but does not require recipients to report the methods or 
tools used to develop estimates. In addition, while DOE provides 
recipients with a tool to estimate energy savings, DOE does not 
require that recipients use the most recent, updated version of its 
estimating tool. 

GAO’s analysis of the Recovery.gov data that recipients reported, 
including jobs funded, shows data quality this quarter reflects minor 
amounts of inconsistencies or illogical data. The portion of EECBG 
recipients reporting some jobs funded has continued to increase. DOE 
headquarters and field officials continue to address data quality 
concerns, including ensuring that recipients and reviewers had the 
updated Office of Management and Budget guidance on narrative 
descriptions. However, data across reporting periods may not be 
comparable because, in earlier periods, some confusion existed about 
methods for calculating jobs funded. 

What GAO Recommends: 

GAO recommends that DOE (1) explore a means to capture information on 
recipients’ monitoring activities, and (2) solicit information on 
recipients’ methods for estimating energy-related impact metrics and 
verify that recipients use the most recent version of DOE’s estimating 
tool. DOE generally agreed with GAO’s recommendations. 

View [hyperlink, http://www.gao.gov/products/GAO-11-379] or key 
components. For more information, contact Mark E. Gaffigan at (202) 
512-3841 or gaffiganm@gao.gov or Yvonne D. Jones at (202) 512-6806 or 
jonesy@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Grant Recipients Are Using EECBG Funds Primarily for Three Activities 
but Face Several Challenges in Obligating and Spending These Funds: 

DOE and Recipients Are Taking Actions to Provide Oversight of EECBG 
Funds but Report Facing Challenges in Meeting Recovery Act and Other 
Program Requirements: 

DOE Has Faced Challenges in Determining the Extent to Which the EECBG 
Program is Meeting Recovery Act and Program Goals for Energy Savings: 

Oversight of Recipient Reporting Data Quality Continues for the Sixth 
Round of Reporting: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Comments from the Department of Energy: 

Appendix III: Status of Prior Open Recommendations and Matters for 
Congressional Consideration: 

Appendix IV: GAO Contacts and Staff Acknowledgments: 

Related GAO Products: 

Tables: 

Table 1: Activities Eligible for EECBG Funding: 

Table 2: Number of Projects and Percentage of EECBG Funds Allocated to 
Activities: 

Table 3: Total EECBG Funds Obligated and Spent by Recipients as of 
December 31, 2010: 

Table 4: Recipients That Met DOE's September 30, 2010, Spending 
Milestone: 

Table 5: Planned Frequency of EECBG Monitoring Activities: 

Table 6: DOE-Reported EECBG Monitoring Progress as of February 14, 
2011: 

Figure: 

Figure 1: Portion of EECBG Recipients Reporting Funding at Least a 
Partial FTE in 2010: 

Abbreviations: 

CFO: Chief Financial Officer: 

DOE: Department of Energy: 

EECBG: Energy Efficiency and Conservation Block Grant: 

EECS: Energy Efficiency and Conservation Strategy: 

EISA: Energy Independence and Security Act of 2007: 

FTE: full-time equivalent: 

HVAC: heating, ventilation, and air conditioning: 

LED: light-emitting diode: 

NACo: National Association of Counties: 

NASEO: National Association of State Energy Officials: 

OMB: Office of Management and Budget: 

OWIP: Office of Weatherization and Intergovernmental Programs: 

PAGE: Performance and Accountability for Grants in Energy: 

Recovery Act: American Recovery and Reinvestment Act of 2009: 

USCM: U.S. Conference of Mayors: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

April 7, 2011: 

Report to the Congress: 

Since the American Recovery and Reinvestment Act of 2009 (Recovery 
Act) was enacted in February 2009, the Department of the Treasury has 
paid out approximately $205.4 billion[Footnote 1] of the Recovery Act 
funds for use by states and localities. The Recovery Act directed 
states to use the funds for various purposes, including to preserve 
and create jobs; assist those most affected by the recession; and 
invest in transportation, environmental protection, and other 
infrastructure to provide long-term economic benefits.[Footnote 2] Of 
the Recovery Act funds, about $3.2 billion were provided as grants to 
states, territories, federally recognized Indian tribes and local 
communities through the Department of Energy's (DOE) Office of Energy 
Efficiency and Renewable Energy's newly funded Energy Efficiency and 
Conservation Block Grant program (EECBG). DOE provides EECBG funds to 
grant recipients to develop, promote, and manage projects to improve 
energy efficiency and reduce energy use and fossil fuel emissions in 
local communities. DOE further encourages EECBG recipients to develop 
new and innovative approaches; prioritize energy efficiency and 
conservation; develop projects in a cost-effective manner that will 
stimulate the economy; and to the extent possible, to develop programs 
that will continue beyond the funding period. 

DOE provides EECBG funds to grant recipients in two forms: through 
formula grants and competitive grants. Of the $3.2 billion, DOE 
awarded about $2.7 billion through formula grants to local communities 
and states. About 61 percent of the total EECBG funds ($1.94 billion) 
was awarded as formula grants to more than 2,000 local communities-- 
including cities, counties, and tribal communities--and about 24 
percent of the total EECBG funds ($767 million) was awarded to the 
states, five territories, and the District of Columbia. About 1 
percent of the total EECBG funds ($40 million) was allocated to 
Administrative and Training/Technical Assistance. In addition to the 
approximately $2.7 billion in formula grants, DOE awarded about 14 
percent of the total EECBG funds ($453 million) through competitive 
grants to local communities. 

This report, the ninth in a series of bimonthly GAO reviews, responds 
to a mandate in the Recovery Act, which requires that GAO conduct such 
reviews of funds made available under the act to determine how funds 
are used, including whether funds are achieving the stated purposes of 
the act. The Recovery Act also requires GAO to comment on estimates of 
jobs created or retained as reported by recipients.[Footnote 3] Over 
the past 2 years, our bimonthly reviews of Recovery Act programs have 
covered a wide range of programs including Medicaid, education, Head 
Start, highways and transit, housing construction and tax credit 
assistance, emergency food and shelter, justice assistance and 
community-oriented policing, workforce investment, and environmental 
and energy projects. 

In this report, we reviewed and updated recipients' information 
available on the EECBG program, focusing on the approximately $2.7 
billion awarded through formula funding to eligible states and local 
and tribal communities. Specifically, our objectives were to determine 
(1) how EECBG funds are being used, and what challenges, if any, EECBG 
recipients face in obligating and spending their funds; (2) actions 
DOE officials and EECBG recipients are taking to provide oversight of 
EECBG funds and challenges, if any, they face in meeting Recovery Act 
and other requirements; (3) the extent to which EECBG recipients and 
the EECBG program are meeting Recovery Act and EECBG program goals for 
energy savings and what challenges, if any, recipients have 
encountered in measuring and reporting energy savings; and (4) how the 
quality of estimates of jobs created and retained reported by Recovery 
Act recipients, particularly EECBG recipients, has changed over time. 

To address these objectives, we reviewed relevant federal laws and 
regulations, as well as DOE guidance documents. We analyzed DOE's 
EECBG program data from DOE databases. We interviewed EECBG program 
officials, including about 30 project officers, technical monitors, 
and contractors in the field offices responsible for managing and 
monitoring awards. We also interviewed representatives from several 
energy and public service organizations, including the National 
Association of State Energy Officials (NASEO), the National 
Association of Counties (NACo), and the U.S. Conference of Mayors 
(USCM). In addition, we e-mailed questions to a sample of 91 
purposefully selected city and county recipients that are eligible to 
receive EECBG funding. We received responses from 49 recipients to 
questions on the various aspects of our objectives, such as obligating 
and spending funds, guidance, best practices, monitoring, and 
challenges experienced. The responses from this nonprobability sample 
of recipients are not generalizable to the 2,185 EECBG states, cities, 
counties, and tribal grant recipients eligible for formula funding 
nationwide. To comment on recipients' estimates of jobs created or 
retained, we analyzed the quality of estimates of jobs created or 
retained provided by recipients. The Recovery Act requires that 
nonfederal recipients of Recovery Act funds--including grants, 
contracts, and loans--submit quarterly reports. These reports include 
a list of each project or activity for which Recovery Act funds were 
expended or obligated and information concerning the amount and use of 
funds and jobs created or retained by these projects and activities, 
among other information. The latest of these recipient reports covered 
the activity as of the Recovery Act's passage through the quarter 
ending December 31, 2010. We assessed these reports for completeness 
and reliability and found them sufficiently reliable for the purposes 
of this report. 

Our oversight of programs funded by the Recovery Act has resulted in 
more than 10 related products in or after December 2010 and more than 
90 related products with numerous recommendations since we began 
reporting on the Recovery Act (see the Related GAO Products list for 
reports issued in or after December 2010 and GAO's Web site for a list 
of all GAO reports related to Recovery Act funding). In addition to 
the objectives outlined above, this report updates agency actions in 
response to recommendations from previous bimonthly and recipient 
reporting reviews that have not been fully implemented (open 
recommendations), including our prior recommendations regarding the 
use of Recovery Act funds for the Weatherization Assistance Program 
(see appendix III).[Footnote 4] 

We conducted this performance audit from September 2010 to April 2011 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Background: 

The goals of the Recovery Act are to preserve and create jobs and 
promote economic recovery; to assist those most impacted by the 
recession; to provide investments needed to increase economic 
efficiency by spurring technological advances in science and health; 
to invest in transportation, environmental protection, and other 
infrastructure that will provide long-term economic benefits; and to 
stabilize state and local government budgets, in order to minimize and 
avoid reductions in essential services and counterproductive state and 
local tax increases. 

The EECBG program was authorized in the Energy Independence and 
Security Act of 2007 (EISA),[Footnote 5] which intended to move the 
United States toward greater energy independence and security and to 
increase the production of clean renewable fuels, among other things. 
The EECBG program was funded for the first time by the Recovery Act, 
through formula and competitive grants. Through the program, DOE 
allocates formula grants to the 50 states, the District of Columbia, 
and five territories; to city and county recipients based on their 
resident and commuter populations; and to Native American tribes based 
on population and climatic conditions. Applicants eligible for formula 
funding include cities or city-equivalent units of government, such as 
towns or villages with populations of at least 35,000; counties, which 
include county-equivalent units of local government, such as parishes 
or boroughs with populations of at least 200,000; and all Indian 
tribes and any Alaska Native village. A city or county is also 
eligible for direct funding if it is one of the 10 highest-populated 
cities or counties of the state in which it is located. 

The EECBG program has broad goals for energy-related outcomes. DOE 
encourages EECBG recipients to develop new and innovative approaches 
to meet the purposes of the program: to prioritize energy efficiency 
and conservation; develop projects in a cost-effective manner that 
will maximize benefits over time; stimulate the economy; leverage 
other public or private resources; promote energy market 
transformation; and to the extent possible, to develop programs that 
will provide sustainable, and measurable energy savings, job creation, 
and economic stimulus benefits that will continue beyond the funding 
period. 

DOE announced the funding opportunity for interested applicants to 
submit applications for EECBG formula grant funding on March 26, 2009. 
DOE required applicants to submit an Energy Efficiency and 
Conservation Strategy (EECS) that described their strategy for 
achieving the Recovery Act's goals of the program. DOE had 120 days to 
review and approve or disapprove recipients' EECSs. DOE's funding 
announcement also required that recipients select projects from the 14 
eligible activities identified in Section 544 of EISA, shown in table 
1. 

Table 1: Activities Eligible for EECBG Funding: 

Eligible activity: 1. Energy Efficiency and Conservation Strategy 
(EECS); 
Description: Developing a strategy for using EECBG funds to promote 
energy efficiency and conservation goals. All recipients are required 
to develop and submit an EECS. 

Eligible activity: 2. Technical consultant services; 
Description: Retaining a technical consultant to assist in developing 
an EECS. 

Eligible activity: 3. Residential and commercial buildings energy 
audits; 
Description: Conducting energy audits of residential and commercial 
buildings. 

Eligible activity: 4. Financial incentive programs; 
Description: Providing programs for energy-efficiency improvements, 
such as energy-saving performance contracting, on-bill financing, and 
revolving loan funds. 

Eligible activity: 5. Energy-efficiency retrofits; 
Description: Providing grants to nonprofit organizations and 
governmental agencies for retrofitting existing facilities to improve 
energy efficiency. 

Eligible activity: 6. Buildings and facilities; 
Description: Developing and implementing energy efficiency and 
conservation programs for buildings and facilities within the 
recipient's jurisdiction, such as measurement and verification 
protocols, public education, and identifying energy-efficient 
technology. 

Eligible activity: 7. Transportation programs; 
Description: Developing programs to conserve energy used in 
transportation, such as bike lanes, synchronizing traffic signals, and 
programs that reduce commuting. 

Eligible activity: 8. Codes and inspections; 
Description: Developing building codes and inspection services to 
promote building energy efficiency. 

Eligible activity: 9. Energy distribution; 
Description: Implementing energy distribution technologies that 
significantly increase energy efficiency, including distributed 
resources, combined heat and power, and district heating and cooling 
systems. 

Eligible activity: 10. Material conservation programs; 
Description: Developing and implementing material conservation 
programs, including source reduction, recycling, and recycled content 
procurement programs that increase energy efficiency. 

Eligible activity: 11. Reduction/capture of methane/greenhouse gases; 
Description: Purchasing or implementing technologies to reduce and 
capture methane and greenhouse gases generated by landfills or similar 
waste-related sources. 

Eligible activity: 12. Lighting; 
Description: Replacing traffic signals and street lighting with energy-
efficient lighting technologies, such as light emitting diodes. 

Eligible activity: 13. Renewable energy technologies; 
Description: Developing on-site renewable energy technology on or in a 
government building, including solar energy, wind energy, fuel cells, 
and biomass. 

Eligible activity: 14. Other; 
Description: Undertaking any other appropriate activity that meets the 
purposes of the program and is approved by DOE, such as using EECBG 
funds to leverage public and private sector funds and partnering with 
third party lenders. 

Source: EISA Pub. L. No. 110-140, § 544; DOE, Financial Assistance 
Funding Opportunity Announcement: Recovery Act - Energy Efficiency and 
Conservation Block Grants - Formula Grants, DE-FOA-0000013 (Mar. 26, 
2009); DOE, Energy Efficiency and Conservation Block Grant Program 
Notice 10-011 (April 21, 2010); DOE, Energy Efficiency and 
Conservation Block Grant Program Notice 10-021 (Jan. 4, 2011). 

[End of table] 

The Recovery Act increased the importance of transparency and 
accountability in its use of funds. Accordingly, DOE requires grant 
recipients to report grant-level expenditure information and 
performance information including hours worked, energy cost savings, 
and percent of work completed as well as other figures, through a Web- 
based application called the Performance and Accountability for Grants 
in Energy (PAGE) system within 30 calendar days of the end of each 
quarter year.[Footnote 6] PAGE allows recipients to electronically 
submit and manage grant performance and financial information to DOE. 
In addition, grant recipients are required to report through 
www.FederalReporting.gov within 10 days after the end of each quarter. 
This information is made available to the general public through the 
Recovery.gov Web site. 

Grant Recipients Are Using EECBG Funds Primarily for Three Activities 
but Face Several Challenges in Obligating and Spending These Funds: 

Grant recipients are using EECBG funds primarily for three activities: 
energy-efficiency retrofits, financial incentive programs, and 
building and facilities programs. However, recipients have reported 
several challenges that have delayed their efforts to obligate and 
spend these funds. 

Grant Recipients Have Allocated Almost Two-Thirds of EECBG Funds to 3 
of the 14 Eligible Activities: 

Grant recipients have allocated most EECBG funds to 3 of the 14 
activities that DOE designated as eligible for EECBG funding in 
accordance with EISA. As shown in table 2, recipients have allocated 
nearly two-thirds (65.1 percent) of EECBG funds for three types of 
activities: (1) energy-efficiency retrofits (36.8 percent), which 
includes activities such as grants to nonprofit organizations and 
governmental agencies for retrofitting existing facilities to improve 
energy efficiency; (2) financial incentive programs (18.5 percent), 
which includes activities such as rebates, subgrants, and revolving 
loans to promote energy-efficiency improvements; and (3) energy- 
efficiency and conservation programs for buildings and facilities (9.8 
percent), which includes activities such as installing storm windows 
or solar hot water technology. Some EECBG recipients are using their 
awards to fund projects in all three of these categories. For example, 
according to information reported through PAGE, New York City plans to 
use $31 million of its $80.8 million award to fund energy-efficiency 
retrofits at municipal buildings such as schools, courthouses, police 
precincts, and firehouses. It has also allocated $16.1 million to a 
financial incentive program that will provide loans to capital- 
constrained building owners for energy-efficient retrofits to 
residential, commercial, or industrial buildings. New York City 
designated another $2 million for buildings and facilities projects 
and will fund a retro-commissioning program at city facilities 
designed to identify efficiency measures and address anomalies in 
energy use, equipment schedules, and control sequences that may cause 
energy waste. As indicated in table 2, these three activities account 
for 48 percent of all the projects funded through the EECBG program, 
or 3,674 out of 7,594 total projects. 

Table 2: Number of Projects and Percentage of EECBG Funds Allocated to 
Activities: 

Activity: 1. Energy Efficiency and Conservation Strategy (EECS)[A]; 
Budget: $151,438,205; 
Percent of budget: 5.2%; 
Number of projects: 801; 
Percent of all projects: 10.5%. 

Activity: 2. Technical consultant services; 
Budget: $71,982,608; 
Percent of budget: 2.5%; 
Number of projects: 555; 
Percent of all projects: 7.3%. 

Activity: 3. Residential and commercial buildings and audits; 
Budget: $68,330,175; 
Percent of budget: 2.4%; 
Number of projects: 443; 
Percent of all projects: 5.8%. 

Activity: 4. Financial incentive programs; 
Budget: $534,573,604; 
Percent of budget: 18.5%; 
Number of projects: 406; 
Percent of all projects: 5.3%. 

Activity: 5. Energy-efficiency retrofits; 
Budget: $1,065,779,447; 
Percent of budget: 36.8%; 
Number of projects: 2,460; 
Percent of all projects: 32.4%. 

Activity: 6. Buildings and facilities; 
Budget: $284,711,283; 
Percent of budget: 9.8%; 
Number of projects: 808; 
Percent of all projects: 10.6%. 

Activity: 7. Transportation; 
Budget: $122,182,595; 
Percent of budget: 4.2%; 
Number of projects: 528; 
Percent of all projects: 7.0%. 

Activity: 8. Codes and inspections; 
Budget: $19,765,501; 
Percent of budget: 0.7; 
Number of projects: 117; 
Percent of all projects: 1.5. 

Activity: 9. Energy distribution; 
Budget: $35,628,958; 
Percent of budget: 1.2%; 
Number of projects: 77; 
Percent of all projects: 1.0%. 

Activity: 10. Material conservation programs; 
Budget: $35,677,882; 
Percent of budget: 1.2%; 
Number of projects: 163; 
Percent of all projects: 2.1%. 

Activity: 11. Reduction/capture of methane/greenhouse gases; 
Budget: $30,474,297; 
Percent of budget: 1.1%; 
Number of projects: 48; 
Percent of all projects: 0.6%. 

Activity: 12. Lighting; 
Budget: $198,321,849; 
Percent of budget: 6.9%; 
Number of projects: 622; 
Percent of all projects: 8.2%. 

Activity: 13. Renewable energy technologies; 
Budget: $175,410,392; 
Percent of budget: 6.1%; 
Number of projects: 478; 
Percent of all projects: 6.3%. 

Activity: 14. Other; 
Budget: $100,112,235; 
Percent of budget: 3.5%; 
Number of projects: 88; 
Percent of all projects: 1.2%. 

Activity: Total; 
Budget: $2,894,389,031[B]; 
Percent of budget: 100.0%[C]; 
Number of projects: 7,594; 
Percent of all projects: 100.0%. 

Source: DOE. 

[A] The number of projects funded under this activity is relatively 
high because all recipients were required to complete an energy 
efficiency and conservation strategy as part of their grant 
application and some recipients used EECBG funds to cover the cost of 
preparing these strategies. 

[B] According to DOE officials, budgeted amounts are reported by 
recipients at the activity level and as a result there is some 
discrepancy between this figure and the total amount awarded 
(approximately $2.7 billion). 

[C] Totals may not add up to 100 percent due to rounding. 

[End of table] 

According to DOE officials, a number of factors explain why energy- 
efficiency retrofits, financial incentive programs, and buildings and 
facilities programs account for such a large portion of all EECBG- 
funded projects. DOE officials told us that some recipients had 
previously identified needed improvements to their buildings and 
facilities. Recipients also told us that EECBG funds allowed them to 
undertake planned facilities projects that previously lacked the 
requisite funding. DOE officials told us that other recipients 
allocated EECBG funds to these projects to save money on future energy 
bills and many recipients chose retrofit programs because these 
programs allowed them to use EECBG funds to engage their broader 
communities by retrofitting commercial and residential buildings, in 
addition to government facilities. DOE also encouraged recipients to 
pursue these projects. In the EECBG program's funding announcement, 
DOE asked recipients to "prioritize energy efficiency and conservation 
first as the cheapest, cleanest, and fastest ways to meet energy 
demand" and to "develop programs and strategies that will continue 
beyond the funding period."[Footnote 7] Energy efficiency retrofits 
and buildings and facilities projects meet both of these goals. 

Although financial incentive programs appear to be the second highest 
funded activity--receiving over 18 percent of EECBG funds--the data 
for this activity require further explanation. According to DOE 
officials, approximately 73 percent of activities classified as 
financial incentive programs are subgrants made by state governments 
to units of local government within the state.[Footnote 8] Such 
subgrant recipients can use these funds for any of the 14 eligible 
activities, such as lighting, retrofits, and transportation. The state 
awarding the subgrant can report details of the activities funded by 
subgrant recipients. However, the state government reports these 
details in narrative fields within DOE's PAGE system while the primary 
activity type, reflected in table 2, is simply classified as 
"financial incentive programs." High-level summary data on these 
activities may give the impression that over 18 percent of EECBG funds 
are allocated to financial incentive programs however, nearly three-
quarters of these funds may ultimately be used for any of the 14 
eligible activities. Although DOE collects information on how these 
funds are ultimately used, these data are not readily available. 

DOE has obligated all EECBG funds to recipients, and recipients are 
beginning to obligate and spend these funds. The Recovery Act required 
DOE to obligate all funds to recipients by September 30, 2010, and DOE 
has done so. DOE staff told us that recipients have completed the 
planning stages of their projects and they expect that recipient 
spending will soon hit a peak before leveling off as funds are 
expended. As of December 2010, recipients reported obligating 
approximately $1.7 billion, 57 percent of their EECBG budgets, and 
reported spending more than $655 million, approximately 23 percent of 
their EECBG budgets. DOE officials expect recipients' spending to 
increase significantly in forthcoming reporting periods as work begins 
or increases on more projects. The table below shows the total funds 
budgeted, obligated, and spent and the percentages of budgeted funds 
spent for each eligible activity. 

Table 3: Total EECBG Funds Obligated and Spent by Recipients as of 
December 31, 2010: 

Activity: 1. Energy Efficiency and Conservation Strategy (EECS); 
Budget: $151,438,205; 
Obligated by recipients: $103,869,366; 
Spent by recipients: $41,251,127; 
Percent of budget spent: 27.2%. 

Activity: 2. Technical consultant services; 
Budget: $71,982,608; 
Obligated by recipients: $48,167,480; 
Spent by recipients: $18,209,103; 
Percent of budget spent: 25.3%. 

Activity: 3. Residential and commercial buildings and audits; 
Budget: $68,330,175; 
Obligated by recipients: $31,872,116; 
Spent by recipients: $14,454,762; 
Percent of budget spent: 21.2%. 

Activity: 4. Financial incentive programs; 
Budget: $534,573,604; 
Obligated by recipients: $368,791,277; 
Spent by recipients: $92,384,019; 
Percent of budget spent: 17.3%. 

Activity: 5. Energy-efficiency retrofits; 
Budget: $1,065,779,447; 
Obligated by recipients: $569,119,301; 
Spent by recipients: $249,773,284; 
Percent of budget spent: 23.4%. 

Activity: 6. Buildings and facilities; 
Budget: $284,711,283; 
Obligated by recipients: $148,324,716; 
Spent by recipients: $68,106,739; 
Percent of budget spent: 23.9%. 

Activity: 7. Transportation; 
Budget: $122,182,595; 
Obligated by recipients: $49,087,408; 
Spent by recipients: $29,754,830; 
Percent of budget spent: 24.4%. 

Activity: 8. Codes and inspections; 
Budget: $19,765,501; 
Obligated by recipients: $13,710,406; 
Spent by recipients: $4,961,257; 
Percent of budget spent: 25.1%. 

Activity: 9. Energy distribution; 
Budget: $35,628,958; 
Obligated by recipients: $11,075,534; 
Spent by recipients: $5,568,287; 
Percent of budget spent: 15.6%. 

Activity: 10. Material conservation programs; 
Budget: $35,677,882; 
Obligated by recipients: $12,767,443; 
Spent by recipients: $10,834,821; 
Percent of budget spent: 30.4%. 

Activity: 11. Reduction/capture of methane/greenhouse gases; 
Budget: $30,474,297; 
Obligated by recipients: $24,816,635; 
Spent by recipients: $5,518,184; 
Percent of budget spent: 18.1%. 

Activity: 12. Lighting; 
Budget: $198,321,849; 
Obligated by recipients: $97,181,881; 
Spent by recipients: $57,828,029; 
Percent of budget spent: 29.2%. 

Activity: 13. Renewable energy technologies; 
Budget: $175,410,392; 
Obligated by recipients: $79,385,833; 
Spent by recipients: $43,722,847; 
Percent of budget spent: 24.9%. 

Activity: 14. Other; 
Budget: $100,112,235; 
Obligated by recipients: $94,853,487; 
Spent by recipients: $12,769,706; 
Percent of budget spent: 12.8%. 

Activity: Total; 
Budget: $2,894,389,031[A]; 
Obligated by recipients: $1,653,022,884; 
Spent by recipients: $655,136,996; 
Percent of budget spent: 22.6%. 

Source: DOE. 

[A] According to DOE officials, budgeted amounts are reported by 
recipients at the activity level and as a result there is some 
discrepancy between this figure and the total amount awarded 
(approximately $2.7 billion). 

[End of table] 

EECBG Recipients Face Several Challenges in Obligating and Spending 
Recovery Act Funds and Meeting DOE's New Obligating and Spending 
Milestones: 

Some recipients and others have identified several challenges that 
have delayed spending of Recovery Act funds under this newly funded 
EECBG program. DOE has made efforts to help recipients address some of 
these challenges, including launching a Technical Assistance Program 
and Solution Center to provide recipients with one-on-one assistance, 
an online resource library, training, webcasts, and a peer-exchange 
forum for sharing best practices and lessons learned. 

Inexperienced DOE Program Administrators: 

Because the EECBG program is relatively new--authorized by EISA in 
2007 but not funded until the Recovery Act was passed in 2009--some 
DOE administrators had little previous experience with the program and 
its requirements. DOE's Inspector General reported that some of the 
DOE staff assigned to review EECBG grant applications lacked financial 
assistance experience and failed to obtain the information necessary 
to issue awards, which required additional requests for documentation 
that further delayed awards.[Footnote 9] The Inspector General also 
reported that the program lacked a permanent Program Director until 
April 2010. Some EECBG project officers--the DOE staff primarily 
responsible for overseeing and interacting with EECBG recipients--told 
us that they faced a steep learning curve during the initial months of 
the program, when they began working with recipients to resolve 
obstacles to applying for funds and address questions about meeting 
requirements and reporting outcomes. Several project officers compared 
managing the EECBG program to flying a plane while it is still being 
built. 

Limitations in Recipient Staff and Resources: 

In addition, several DOE project officers told us that some 
recipients' efforts to effectively manage grants and spend funds have 
been complicated by staff and resource limitations. Some recipients 
lack the staff and resources needed to comply with EECBG and Recovery 
Act requirements. For example, a project officer told us that one 
county has only two staff members who were entirely responsible for 
managing the grant and meeting reporting requirements, in addition to 
their regular workload. The economic downturn exacerbated some 
recipients' staffing challenges as budget shortfalls led to furloughs 
and hiring freezes. For example, one county reported to DOE that 
staffing shortages due to budget cuts had delayed its planned retrofit 
projects. Another recipient reported project delays due to a furlough 
that closed the city government and prevented the city council from 
approving their plans for a financial incentive program. 

Jurisdictional Requirements: 

Some recipients also told us that they experienced local 
jurisdictional requirements that delayed their ability to spend 
Recovery Act funds. DOE's Inspector General reported that local budget 
and procurement requirements prevented some recipients from obligating 
funds until DOE made the entire award amount available. In addition, 
several project officers told us that some recipients cannot initiate 
their proposed EECBG-funded projects until their spending decisions 
and budgets are approved by local officials, which can delay projects 
and spending for months or even longer in localities where local 
officials only meet quarterly or twice a year. In response to 
questions about spending delays, one recipient told us that although 
local procedures can be time-consuming, these procedures also protect 
tax dollars. Another recipient told us that DOE needs to take local 
procedures into consideration so that spending milestones are more 
flexible and realistic. Both representatives from NACo told us that 
although recipients are grateful for the opportunity to implement 
critical projects that they previously could not have funded, DOE has 
not adapted guidance and deadlines to the needs, timelines, or 
procedures of local governments and that this has created some 
challenges. Some project officers expressed similar views in our 
meetings with them, stating that the federal government in general 
lacked an appreciation of city and county government processes. Both 
USCM representatives also told us that although DOE's guidance and 
support had improved significantly, this lack of understanding of how 
city governments worked had a negative impact on the success of the 
program. 

Reporting Requirements: 

Additionally, some recipients told us that meeting the reporting 
requirements for EECBG Recovery Act funds is time-intensive and that 
requiring recipients to submit similar information through PAGE and 
FederalReporting.gov makes the reporting process unnecessarily 
duplicative. For example, one recipient told us that the required 
reporting for EECBG takes two to three times longer than other federal 
grants. Some recipients told us that the EECBG program's reporting 
requirements were more cumbersome than other federal grant programs. 
One recipient with decades of federal grant experience told DOE's 
Recovery Act help line that although DOE staff had been very helpful 
in providing information, the reporting requirements for EECBG 
Recovery Act funds were the most onerous he had experienced in 20 
years of government work despite regularly applying for millions of 
dollars in federal grants. Another recipient told us that his city 
canceled one of its planned projects, a geothermal system, because the 
reporting requirements would have been too burdensome. Similarly, 
project officers told us that some small recipients were so 
overwhelmed with the reporting requirements that they declined their 
awards. However, the vast majority of recipients accepted their awards. 

Delays in Acquiring Needed Materials and Products: 

Some recipients have also faced challenges in acquiring needed 
materials and products in a timely manner. EECBG recipients have 
created a large demand for energy-efficient materials. As a result, 
some of the materials and products needed to complete projects are out 
of stock or on back order, which can delay the implementation of these 
projects and the spending of funds allocated for these projects. For 
example, project officers told us that shortages of lighting and 
heating, ventilation, and air conditioning (HVAC) systems products 
have delayed some of the projects requiring these items. Both NASEO 
representatives told us that shortages were also an issue for solar 
and energy-efficient lighting projects. 

DOE Established New Obligating and Spending Milestones for Recipients: 

When DOE announced funding opportunities through the EECBG program in 
March 2009, it stated that recipients must obligate all funds within 
18 months of their effective award date[Footnote 10] and spend all 
funds within 36 months of their effective award date.[Footnote 11] 
These original time frames require recipients that were awarded grants 
in fall 2009--the majority of recipients--to obligate 100 percent of 
their funds by spring 2011 and to spend these funds by fall 2012. 

However, in April 2010 DOE determined that many recipients were not on 
a trajectory to obligate and spend all of their funds within this time 
frame. DOE sent letters to all EECBG recipients outlining new 
obligation and spending milestones in an effort to increase obligating 
and spending rates among recipients and ensure that all funds are 
spent before the 36-month deadline. DOE's new milestones encouraged 
recipients to obligate 90 percent of their funds by June 25, 2010, 
spend 20 percent of their funds by September 30, 2010, and spend 50 
percent of their funds by June 30, 2011. Officials from the Office of 
Weatherization and Intergovernmental Programs (OWIP), the DOE office 
which manages the EECBG program, told us that DOE and the 
Administration expressed an urgency to spend funds quickly, thereby 
creating jobs and stimulating the economy--primary purposes of the 
Recovery Act. 

These OWIP officials told us that many recipients found the milestone 
letters useful to facilitate local procurement processes and overcome 
other barriers to obligations and payments. DOE initiated Operation 
Clear Path to meet the September 2010 spending milestone by contacting 
600 targeted recipients through telephone calls and helping these 
recipients develop strategies and tactics to accelerate their 
spending. An internal DOE newsletter reported that Operation Clear 
Path was yielding real gains by reaching out to recipients of grants 
over $3 million. DOE cited recent spending increases among targeted 
recipients as evidence that this approach was succeeding. For example, 
one city moved $600,000 from a revolving loan fund to a lighting 
retrofit, bringing the city's spending up to 31 percent. Additional 
examples given from other cities include $10 million spent to 
capitalize a revolving loan fund and $4 million spent on a lighting 
equipment purchase. 

However, many recipients have had difficulty meeting these new 
milestones. According to DOE's data, about 41 percent of recipients 
met DOE's new milestone of spending 20 percent of EECBG funds by 
September 30, 2010 (see table 4). 

Table 4: Recipients That Met DOE's September 30, 2010, Spending 
Milestone: 

Award amount: Over $2 million; 
Total number of grants: 294; 
Number of recipients that spent over 20% of funds by Sept. 30, 
2010[A]: 95; 
Percent of recipients that spent over 20% of funds by Sept. 30, 2010: 
32%. 

Award amount: Between $250,000 and $2 million; 
Total number of grants: 909; 
Number of recipients that spent over 20% of funds by Sept. 30, 
2010[A]: 339; 
Percent of recipients that spent over 20% of funds by Sept. 30, 2010: 
37%. 

Award amount: Less than $250,000; 
Total number of grants: 984; 
Number of recipients that spent over 20% of funds by Sept. 30, 
2010[A]: 467; 
Percent of recipients that spent over 20% of funds by Sept. 30, 2010: 
47%. 

Award amount: Total number of grant recipients; 
Total number of grants: 2,187[B]; 
Number of recipients that spent over 20% of funds by Sept. 30, 
2010[A]: 901; 
Percent of recipients that spent over 20% of funds by Sept. 30, 2010: 
41%. 

Source: DOE. 

[A] Note that spending is determined by funds drawn down from the 
Automated Standard Application for Payments system. The system was 
developed by the Financial Management Service through which recipient 
organizations receiving federal funds can draw from accounts pre- 
authorized by federal agencies. 

[B] Note: two recipients have withdrawn from the program since 
September 30, 2010. The current number of recipients, as of February 
14, 2011, is 2,185. 

[End of table] 

Furthermore, some project officers told us that DOE's new spending and 
obligation milestones confused recipients. These project officers 
stated that some recipients were concerned about the consequences they 
would face for not being able to meet the new milestones. Although DOE 
officials told us that there were no repercussions for recipients that 
failed to meet these milestones, some project officers told us that 
some recipients did not understand this and were concerned that they 
might lose their funding. In some cases, project officers told us that 
they too were unsure of the consequences of recipients' failing to 
meet these milestones. 

In addition, some representatives from NASEO told us that these new 
milestones were not consistent with the timelines set in the terms and 
conditions of award agreements that DOE had already approved. Some 
project officers told us they are concerned that DOE is sending 
conflicting messages by encouraging recipients to spend funds more 
quickly than the time frame recipients had agreed to in the terms of 
their grants. Further, DOE's Inspector General reported in August 2010 
that DOE's new obligating and spending milestones "may increase the 
risks associated with ensuring compliance with regulatory requirements…
 as well as, maintaining effective financial control over the 
expenditure of funds."[Footnote 12] 

DOE has initiated a second round of telephone calls to targeted 
recipients, some of which may have been contacted during the first 
round of follow-up telephone calls, in an effort to increase spending 
to meet DOE's new milestone of spending 50 percent of EECBG funds by 
June 30, 2011. DOE staff continue to work with recipients and project 
officers to share best practices, overcome challenges, and ensure that 
the EECBG program advances the goals of energy efficiency and job 
creation. However, it is still unclear whether this effort will 
overcome the challenges recipients face in obligating and spending 
EECBG funds and meeting DOE's new milestones. 

DOE and Recipients Are Taking Actions to Provide Oversight of EECBG 
Funds but Report Facing Challenges in Meeting Recovery Act and Other 
Program Requirements: 

Both DOE and recipients are taking a variety of actions to provide 
oversight of EECBG funds, with some recipients providing much more 
rigorous oversight than others. DOE and recipients reported having 
experienced technical, staffing, and expertise challenges that hinder 
their ability to meet Recovery Act and program requirements. DOE is 
taking steps to address many of these challenges. 

DOE and Recipients Are Taking a Variety of Actions to Provide 
Oversight of EECBG Funds, and the Level of Recipient Oversight Varies: 

DOE and recipients are using a variety of oversight actions for EECBG 
funds such as program office monitoring and oversight by the DOE Chief 
Financial Officer (CFO) and the Inspector General. Recipients are also 
providing oversight, and the level of this oversight may vary by the 
recipient's resources and the nature of the project. 

DOE's Oversight Actions: 

DOE's framework for oversight is its programwide monitoring plan that 
was issued in August 2009 and revised in March and June 2010. 
According to DOE documentation, DOE developed the plan to, among other 
things, provide a structure for oversight of recipients' procedures 
and processes, ensure consistent application of program and reporting 
standards, and provide clear and transparent guidelines. As outlined 
in the monitoring plan, OWIP oversees the administration and oversight 
of EECBG funds. The office plans and budgets programmatic requirements 
and resources, develops standardized monitoring practices, provides 
expertise to review and analyze performance measures, and helps 
provide guidance and technical expertise to meet programmatic 
requirements, among other activities. Specifically, OWIP has issued 
guidance to help recipients and DOE program staff meet Recovery Act 
and program requirements such as Buy American,[Footnote 13] Davis-
Bacon,[Footnote 14] and monitoring requirements, as well as to help to 
ensure that funds are spent efficiently. OWIP also develops and hosts 
Web seminars on specific topics such as designing retrofit and 
appliance rebate programs. 

To monitor recipients' use of funds, DOE project officers act as the 
primary support to recipients, as well as liaisons between recipients 
and DOE. DOE's monitoring plan directs project officers to gather key 
program data from recipients, provide information on training and 
technical assistance opportunities, and coordinate monitoring 
activities. In addition to project officers, DOE also uses other 
monitoring staff such as technical monitors, contract specialists, and 
staff accountants.[Footnote 15] The plan and guidance also identify 
goals and actions for three primary components of oversight and 
monitoring: (1) desktop monitoring, (2) on-site monitoring, and (3) 
worksite visits. Specifically: 

* Desktop monitoring: According to DOE, all EECBG grant awards are to 
be reviewed through quarterly desktop monitoring--remote monitoring 
conducted by the project officer. This includes examining recipients' 
financial and other reports to assess progress and determine 
compliance with federal requirements, as well as examining recipients' 
planned goals and objectives and the reporting and tracking of 
resources expended by the recipient and subrecipients.[Footnote 16] 
DOE also directs project officers and other monitors to use 
information gained from desktop monitoring for further monitoring and 
potential corrective action. 

* On-site monitoring: DOE conducts periodic on-site monitoring of 
grant recipients. On-site monitoring primarily occurs at the recipient 
and contractor levels and can also include field inspections on 
projects that have achieved milestones since the previous visit. Prior 
to on-site monitoring, monitors also review the previous findings of 
other DOE project officers and monitoring staff to determine 
deficiencies and to determine what steps are being taken to resolve 
the issues. During on-site monitoring, project officers review what 
specific internal controls[Footnote 17] recipients have in place, such 
as segregation of duties, accounting standards and practices, and 
payment procedures. Monitoring staff also interview contractors to 
determine if follow-up procedures were used and deficiencies were 
corrected. 

* Project worksite reviews: DOE monitoring staff also visit some 
worksites during on-site monitoring to review the progress of 
activities at the project, facility, or building being completed. 
Staff also review the quality of work performed and compliance with 
federal requirements, such as the Buy American provision. DOE 
officials stated that worksite reviews were conducted as determined 
necessary by the project officer, though project officers made an 
effort to visit at least one worksite during every on-site visit. 

Overall, DOE officials stated that they planned to prioritize their 
monitoring based on the size of the grant rather than on the expected 
risk of the project. For example, all recipients with over $2 million 
in Recovery Act funds--which as a group, represent about 70 percent of 
all EECBG Recovery Act formula funds--receive significantly more on- 
site monitoring than would recipients of grants of under $250,000. 
Table 5 shows the frequency of DOE's planned monitoring activities. 

Table 5: Planned Frequency of EECBG Monitoring Activities: 

Type of monitoring: Percent of total grant funds[A]; 
Recipients receiving less than $250,000: 4%; 
Recipients receiving less than $1M but at least $250,000: 16%; 
Recipients receiving less than $2M but at least $1M: 9%; 
Recipients receiving $2M or greater: 70%. 

Type of monitoring: Desktop reviews; 
Recipients receiving less than $250,000: Quarterly; 
Recipients receiving less than $1M but at least $250,000: Quarterly; 
Recipients receiving less than $2M but at least $1M: Quarterly; 
Recipients receiving $2M or greater: Quarterly. 

Type of monitoring: On-site reviews; 
Recipients receiving less than $250,000: One in the life of the grant 
for 10% of the grants; 
Recipients receiving less than $1M but at least $250,000: One in the 
life of the grant for 25% of the grants; 
Recipients receiving less than $2M but at least $1M: One in the life 
of the grant; 
Recipients receiving $2M or greater: One to two per year. 

Type of monitoring: Worksite reviews; 
Recipients receiving less than $250,000: As needed; 
Recipients receiving less than $1M but at least $250,000: As needed; 
Recipients receiving less than $2M but at least $1M: As needed; 
Recipients receiving $2M or greater: As needed. 

Source: DOE. 

[A] Numbers do not add to 100 percent due to rounding. 

[End of table] 

To conduct and track monitoring activities, DOE monitoring staff make 
extensive use of a Web-based application, the PAGE system. For 
example, DOE monitoring staff use PAGE data to inform and target 
further monitoring actions such as on-site monitoring. Additionally, 
DOE has also created a monitoring tool within PAGE that compiles the 
checklists used by project officers to determine the compliance of 
recipients with the program's statutes and requirements. DOE guidance 
states that through the use of PAGE, monitoring staff can target 
recipients with low spending rates or reporting delays for additional 
follow-up to help ensure that funds were spent in a timely manner. 
Project officers also stated that they use financial data reported in 
PAGE to identify potential areas of concern for further analysis. 

Overall, DOE officials stated that they have almost met their desktop 
monitoring goals with a rate of over 90 percent of their planned 
monitoring complete, and based on their current rate, are on track to 
meet on-site monitoring goals (see table 6). DOE officials stated that 
they do not currently track the number of worksite reviews, but that 
all initial on-site monitoring visits also include a worksite review. 

Table 6: DOE-Reported EECBG Monitoring Progress as of February 14, 
2011: 

Type of monitoring: Total recipients; 
Recipients receiving less than $250,000: 982; 
Recipients receiving less than $1M but at least $250,000: 733; 
Recipients receiving less than $2M but at least $1M: 176; 
Recipients receiving $2M or greater: 294; 
Total: 2,185[A]. 

Type of monitoring: Total on-site visits; 
Recipients receiving less than $250,000: 67; 
Recipients receiving less than $1M but at least $250,000: 61; 
Recipients receiving less than $2M but at least $1M: 51; 
Recipients receiving $2M or greater: 293; 
Total: 472. 

Type of monitoring: Total desktop reports submitted--CY 2010 Q3 (CY 
2010 Q4); 
Recipients receiving less than $250,000: 915 (790); 
Recipients receiving less than $1M but at least $250,000: 732 (94); 
Recipients receiving less than $2M but at least $1M: 176 (16); 
Recipients receiving $2M or greater: 293 (104); 
Total: 2,116 (1,004). 

Type of monitoring: Percentage desktop reports submitted--CY 2010 Q3 
(CY 2010 Q4); 
Recipients receiving less than $250,000: 93.2% (80.4%); 
Recipients receiving less than $1M but at least $250,000: 99.9% 
(12.8%); 
Recipients receiving less than $2M but at least $1M: 100.0% (9.1%); 
Recipients receiving $2M or greater: 99.6% (35.4%); 
Total: 96.8% (45.9%). 

Source: DOE: 

Note: "CY" refers to calendar year and "Q" refers to quarter. 

[A] Total number of recipients for table 4 and table 6 do not match 
because two recipients withdrew from the program. 

[End of table] 

In addition to desktop monitoring and site visits, several DOE 
officials reported almost meeting their planned staffing goals for 
project officers and other monitoring staff. Specifically, as of 
December 20, 2010, these DOE officials reported that approximately 60 
project officers, 20 contract specialists, and 35 full-time 
equivalents (FTE) of contractor support were assigned to administer 
the EECBG program.[Footnote 18] These staff members are located in 
Washington, D.C.; Oak Ridge, Tennessee; Golden, Colorado; and Las 
Vegas, Nevada. As of December 2010, DOE officials stated they had met 
their staffing goals with the exception of one field office, which had 
recently lost several of its staff. These DOE officials said they 
hoped to fill those positions soon. 

DOE monitoring also includes specific financial management oversight 
in DOE field offices, as well as independent oversight through DOE's 
Inspector General. Specifically, financial management oversight is 
conducted by the DOE Office of the CFO in the Golden, Colorado, and 
Oak Ridge, Tennessee, field offices. In addition, the project officers 
in the Las Vegas, Nevada, field office also oversee disbursements of 
DOE funds. Data on the disbursement of funds are then made available 
to DOE employees, including headquarters employees and the CFO. DOE's 
Inspector General also provides oversight of the EECBG program and has 
issued a report on the status of implementation of EECBG, as well as 
the management controls over the development and implementation of 
PAGE.[Footnote 19] Along with issuing such reports, DOE's Inspector 
General takes actions to investigate allegations related to fraud, 
waste, and abuse for the EECBG program. To date, DOE's Inspector 
General has received four complaints regarding the use of EECBG funds 
and is handling two of them through ongoing investigations, while the 
other two were sent back to the program office for resolution. A DOE 
Inspector General official stated that the complaints are related to 
potential conflicts of interest and potential ethics violations. 
Additionally, while not investigating EECBG directly, DOE's Inspector 
General recently issued a management alert related to DOE's State 
Energy Efficient Appliance Rebate Program.[Footnote 20] Some 
recipients also used EECBG funds to help fund rebate programs. In its 
alert, DOE's Inspector General identified an incident in which a 
consumer in Georgia was able to purchase water heaters at a store, 
return them, and still inappropriately apply for and receive a rebate 
through the state's rebate program. DOE's Inspector General report 
noted that the incident showed that if similar process vulnerabilities 
exist in other jurisdictions, then the rebate program could be exposed 
to abusive practices on a broad scale. 

Recipients' Oversight Actions: 

The extent of recipients' oversight through the monitoring of Recovery 
Act funds may depend on the individual recipient's resources and the 
nature of the project. Broadly stated, federal law, federal 
regulations, and DOE guidance require that recipients comply with 
applicable laws, including provisions in the Recovery Act, such as Buy 
American, and other federal requirements, including regulatory and 
procedural requirements. Recipients are responsible for informing 
subrecipients of all applicable laws and other federal requirements 
and ensuring their subrecipients' compliance with program, fiscal, and 
audit requirements. The Single Audit Act, as amended, requires 
recipients passing on the funds to subrecipients to monitor the 
subrecipients' use of the federal funds through site visits, limited 
scope audits, and other means.[Footnote 21] DOE did not require 
recipients to conduct any specific oversight actions but instead 
released guidance on October 26, 2010, identifying a number of best 
practices for monitoring by recipients to ensure their and their 
subrecipients' compliance with federal requirements for monitoring. 
Further, DOE has also provided additional resources regarding the 
monitoring of subrecipients, such as workshops and guidance. 

We found that recipients contacted are using various methods to meet 
applicable laws and other federal requirements, and recipients, DOE 
officials, and project officers stated that some recipients are 
providing substantially more rigorous monitoring than others. For 
example, while it is required that recipients monitor subrecipients, 
in response to our questions, one recipient did not indicate that it 
monitored subrecipients and instead stated that it included terms in 
their contracts that required contractor adherence to applicable 
federal requirements. Other recipients reported actively monitoring 
funds but using relatively limited techniques such as reviewing 
invoices and other reports submitted by vendors. DOE officials 
acknowledged that many recipients are resource constrained, limiting 
their ability to monitor and ensure compliance with applicable federal 
requirements, and DOE would need to evaluate on a case-by-case basis 
whether the grant recipient's subrecipient monitoring system is 
sufficient to meet compliance requirements. However, officials stated 
that DOE does not gather specific information on recipient monitoring 
practices except during on-site visits. Additionally, because less 
than 25 percent of grants under $1 million are to receive on-site 
visits, DOE does not have specific information on monitoring for many 
recipients. DOE officials stated that they focused monitoring efforts 
on recipients of larger grants because they were more likely to have 
subrecipients. DOE officials also said that they adopted standard, 
well-accepted audit sampling practices to achieve the most effective 
coverage in verifying monitoring practices and conducted additional on-
site reviews of recipients that have demonstrated cause for concern 
such as not filing quarterly reports. Officials stated that if they 
identified a concern during an on-site visit, they would work with the 
recipient to develop an alternative system to monitor subrecipients. 

While some recipients reported less rigorous monitoring activities, in 
other instances, recipients reported having detailed monitoring 
practices with multiple components. For example, one recipient 
reported collecting monthly progress reports, which included financial 
reports, from all subrecipients, vendors, and contractors, as well as 
conducting site visits. Additionally, the recipient reported that 
their auditor and grant services staff also conducted internal audits 
of all Recovery Act programs. Another recipient also reported using a 
variety of monitoring practices such as inspections, site visits, and 
regular billing of vendors. The recipient's staff also reported that 
they planned to use third-party oversight of site visits in the coming 
year and that they had recently hired a grant compliance analyst who 
would be administering a subrecipient monitoring plan in the coming 
year. 

Some grant sizes and project types may not lend themselves to the same 
level of oversight as others. DOE project officers stated that some 
larger projects included specific monitoring requirements in the 
contract to help ensure that the project met key goals including 
achieving project outcomes and ensuring that funds were used 
efficiently. For example, project officers stated that some recipients 
were able to use expertise provided by contractors that perform energy-
savings work to generate energy-cost savings to help determine 
estimated versus achieved energy savings. Other smaller contracts, 
however, were not large enough to include these types of oversight. In 
another instance, one recipient noted that because the grants with 
subrecipients they were using were so small, ranging from $8,000 to 
$55,000, that the recipient did not see the need to conduct internal 
and financial audits but did report conducting on-site visits on some 
projects. 

DOE Officials and Recipients Reported Technical, Staffing, and 
Expertise Challenges That Hinder Efforts to Ensure Requirements Are 
Met: 

DOE officials and some recipients reported experiencing technical, 
staffing, and expertise challenges that hinder the ability of both DOE 
and recipients to provide oversight to ensure that Recovery Act and 
program requirements are met, but DOE is taking steps to address many 
of these challenges. 

Technical Challenges: 

Some DOE project officers and recipients reported experiencing 
technical challenges using PAGE. For example, project officers told us 
that monitoring was challenging because of the extensive amount of 
time that they spent helping recipients use the PAGE system, which 
recipients found cumbersome and difficult to use. In particular, some 
project officers said that they provide ongoing support during 
reporting cycles to help fix reporting errors and, in some cases, help 
walk recipients through the reporting process and help fix reporting 
errors. For example, some DOE project officers in one field office 
told us that during the reporting period--the last week of the quarter 
and the following 2 months--project officers spent approximately 70 to 
85 percent of their time helping recipients fill out their PAGE and 
federal reporting forms.[Footnote 22] Other project officers with the 
same office also told us that recipients often cannot figure out how 
to enter data into PAGE and do not understand the reporting system. In 
another field office, a DOE project officer stated that almost all of 
the initial PAGE reports for each quarter were initially rejected for 
issues such as missing or incorrect data entries and that recipients 
reported having difficulties with entering data in every field. Some 
recipients have also reported difficulties using PAGE--for example, 
though not asked about PAGE issues specifically in our structured 
questions, one recipient stated in a response regarding challenges 
faced that "PAGE reporting is the biggest challenge" while another 
recipient noted that "technical glitches" in PAGE made reporting more 
challenging. 

Incorrect data entered into PAGE has also limited project officers' 
ability to monitor recipients. For example, some project officers 
stated that some recipients continued to enter incorrect information 
in PAGE for data fields such as total hours worked and estimated 
energy savings--key project measures used to help gauge project 
progress and status--in part due to difficulties recipients had 
understanding PAGE data fields. Specifically, some project officers 
stated that some PAGE data field names were difficult to interpret, 
confusing some recipients. Some project officers also stated that 
recipients entered incorrect job information using incorrect job 
calculation formulas or that they entered incorrect energy data and 
that DOE project officers had to spend time locating the errors and 
working with the recipient to ensure that the correct data were 
entered. In previous work looking at EECBG, as well as the State 
Energy Program and Weatherization Assistance Program, we have also 
reported on both DOE monitoring staff and recipients having problems 
with PAGE that hindered DOE's ability to administer the 
program.[Footnote 23] Specifically, we previously reported that some 
DOE staff and recipients noted that the time and effort that project 
officers spent with recipients to help them understand and navigate 
the PAGE system significantly increased the administrative burden of 
the program. 

In reviewing PAGE's development process, DOE's Inspector General found 
significant issues, noting that DOE did not seek input from grant 
recipients in designing PAGE because it had to be developed and 
implemented so quickly. The Inspector General's report noted that user 
input significantly increases the likelihood that the system will meet 
user needs and also helps avoid rework costs due to a lack of 
functionality. Similarly, we previously reported on the importance of 
eliciting the users' needs to identify and prioritize system 
requirements.[Footnote 24] Without gathering this information, 
programs and systems may not meet the needs of their users. 

DOE officials stated that they have implemented a number of 
improvements to both the administration of PAGE, and the system 
itself, to help address user concerns and that they are currently 
implementing more changes. For example, DOE established a PAGE hotline 
to assist users and gather users' feedback and also provided training 
videos for recipients using PAGE. DOE officials also stated that they 
recently implemented a new software tool to gather and prioritize user 
feedback from large numbers of recipients to better address users' 
major concerns. Additionally, DOE officials said that among other 
improvements, they plan to incorporate a new interface in the next few 
months for DOE staff to review data reported in PAGE, which was 
designed to improve usability of the system. DOE officials stated that 
these improvements will take time to implement and have to be 
carefully considered so as not to negatively affect other PAGE 
functions. For example, PAGE is also used for recipient reporting by 
DOE's Weatherization Assistance and State Energy programs. DOE 
officials also stated that they have had to adapt their process to 
handle the large number of PAGE users, in contrast to the previous 
system. Specifically, DOE officials stated that approximately 50 state 
users and a limited number of federal staff used the previous system, 
while PAGE had 4,292 recipient and 411 federal users as of December 8, 
2010. 

Staffing and Expertise Challenges: 

Some DOE officials, monitoring staff, and grant recipients, as well as 
all stakeholders we contacted, stated that some recipients are also 
encountering staffing and expertise challenges that have limited their 
ability to monitor the use of Recovery Act funds and ensure effective 
and efficient use of funds while also meeting Recovery Act and other 
federal requirements. As noted previously, some project officers 
stated that some recipients may lack sufficient resources and staffing 
for program oversight such as monitoring. Some DOE officials also 
acknowledged the significant recipient workload associated with 
monitoring. These officials stated that the biggest overall challenge 
to monitoring was the need to determine the right amount of 
information to collect from recipients so as to ensure recipient 
compliance with applicable federal requirements while not burdening 
recipients with reporting requirements. These officials also stated 
that they took steps to decrease the reporting burden on recipients, 
including decreasing certain monitoring requirements. Further, these 
DOE officials also stated that some recipients said that they might 
have trouble ensuring compliance with program requirements due to 
limited staffing and were focused on Recovery Act requirements such as 
Davis-Bacon and Buy American. Finally, the NASEO and USCM 
representatives we spoke with stated that some recipients have 
expressed concerns about complying with Davis-Bacon requirements, 
especially with limited staff and a large number of projects. For 
example, both USCM representatives stated that while some city and 
county projects already had Davis-Bacon or Buy American requirements 
before the Recovery Act, they were typically on much larger projects 
in excess of $30 million, such as transportation projects, with 
dedicated resources to ensure compliance with these requirements. 

Some DOE monitoring staff and the NASEO and USCM representatives 
stated that some recipients found compliance with federal laws, 
including Recovery Act provisions, such as those for financial 
management monitoring and Davis-Bacon, difficult because of a lack of 
previous expertise with those requirements. Additionally, some DOE 
monitoring staff stated that some recipients have limited experience 
with federal grants and faced a steep learning curve with implementing 
projects, and that this inexperience has limited monitoring efforts, 
making it more difficult to ensure that funds were spent properly. For 
example, several DOE staff in one field office stated that, in 
particular, those recipients that did not have previous experience 
performing a Single Audit Act report[Footnote 25] tended to have more 
trouble meeting EECBG requirements than others due to inexperience. 
Additionally, some DOE project officers also stated that some smaller 
recipients with fewer staff did not have specific expertise in energy 
management and that this made it more difficult to monitor programs. 
Further, these DOE project officers also noted that certain project 
types, such as energy loan programs, may have fewer tangible outcomes 
than others such as building retrofits, and are thus more difficult to 
monitor, especially without specific staff expertise. Additionally, 
certain Recovery Act requirements can also prove more difficult to 
ensure compliance with than others. For example, both NASEO 
representatives stated that some recipients found compliance with the 
Buy American provision difficult, especially for items with multiple 
components such as air conditioners. 

DOE is taking steps to address staffing and expertise challenges by 
expanding support to recipients. Some DOE officials and the NASEO and 
USCM representatives stated that DOE's administration of EECBG was 
initially limited during the program's early stages and that this 
hindered early program administration including oversight. Overall, 
the NASEO and USCM representatives stated that while the DOE program 
office has improved significantly in providing support such as 
guidance to recipients, the program was significantly impacted by 
these early delays. DOE has gradually expanded the amount of support 
provided to recipients. For example, while DOE project officers 
continue to provide individualized support to recipients, DOE has also 
developed a Technical Assistance and Solution Center to provide 
information related to monitoring recipient activities such as project 
implementation. Through the Technical Assistance and Solution Center, 
DOE has provided near daily Web seminars on specific energy topics 
while also helping connect recipients with specific technical 
expertise. Further, DOE continues to issue programwide guidance to 
help recipients comply with Recovery Act and program requirements. For 
example, on January 4, 2011, DOE issued guidance to help recipients 
determine the eligibility of recipient programs for Recovery Act 
funds. DOE has also hosted seminars with recipients and subrecipients 
to help identify and share monitoring best practices. Finally, DOE is 
working with the Office of Management and Budget (OMB) to update OMB's 
Compliance Supplement to its guidance for the Single Audit Act (Cir. 
No. A-133) regarding EECBG program requirements. 

DOE Has Faced Challenges in Determining the Extent to Which the EECBG 
Program is Meeting Recovery Act and Program Goals for Energy Savings: 

EECBG program recipients reported using EECBG grant funding to develop 
projects designed to achieve a variety of benefits in line with 
Recovery Act and program goals, including reducing total energy use 
and increasing energy savings for local governments and residents. For 
example, some recipients we contacted reported anticipating energy 
savings and reduced overall energy usage from such projects as 
powering the electrical needs for a large city park with solar panels; 
maximizing the use of day lighting in government buildings; installing 
more energy-efficient technology in households and businesses; 
replacing convention center light fixtures with light-emitting diode 
(LED) bulbs to reduce energy usage; and updating and remodeling a 40- 
year-old public building with more energy-efficient products, 
including new windows and doors, and HVAC systems. 

Furthermore, DOE officials told us that some recipients are already 
reporting achieving benefits consistent with Recovery Act and program 
goals. For example, DOE reported that according to initial recipient 
self-reporting through December 2010, EECBG recipients have upgraded 
more than 10,000 buildings, installed 40,000 efficient street lights, 
and upgraded more than 100,000 traffic signals. DOE has put some 
examples of program successes on its Web site. For example, a small 
town in southwestern Wyoming used its EECBG funds to convert its 
streetlights to LED fixtures. Town officials reported better lighting 
quality and visibility, less light pollution, and lower energy use 
that has reduced lighting-related energy costs by almost two-thirds. 
In North Carolina, local officials used EECBG funds to convert an 
abandoned grocery store into an energy-efficient community training 
center and classroom. By installing a more energy-efficient roof, new 
insulation, and HVAC systems, local officials said they anticipate 
achieving substantial energy savings. Another recipient in Oklahoma 
used EECBG funds to purchase five wind turbines. According to the 
recipient, the new wind energy technology has offset the electrical 
costs for all town-owned buildings, and the recipient reported 
anticipating saving $24,000 annually. 

However, DOE officials have experienced challenges in assessing 
whether the EECBG program is meeting Recovery Act and program goals 
for energy savings because most recipients do not measure energy 
savings by collecting actual data and several factors affect the 
reasonableness of energy-savings estimates. Additionally, while DOE 
officials say they have anecdotal examples of program successes, DOE 
lacks actual programwide data on energy savings. DOE guidance requires 
that recipients report impact metrics--which include energy savings, 
energy cost savings, renewable-energy generation, and emissions 
reductions--on a quarterly basis and verify cumulative totals when 
grants are closed out, but it does not require that these impact 
metrics be based on actual, as opposed to estimated, data.[Footnote 
26] Furthermore, according to some DOE officials, there have been only 
a few opportunities for recipients to collect actual energy-savings 
data because in most cases actual data are only available after a 
project has been completed, and recipients are just beginning to 
complete projects. These officials said that instead of collecting 
actual energy-savings data, most recipients report estimates to comply 
with program reporting requirements. 

As part of the quarterly review process, DOE's monitoring plan 
appendix requires project officers to assess whether recipients' 
estimates of impact metrics, including energy savings, are reasonable 
[Footnote 27] and to determine whether grant recipients have an 
adequate procedure in place to collect, verify, and report these data. 
Project officers are further instructed, as part of this quarterly 
review process, to review recipients' reported impact metrics and 
determine whether they are within a range of values that DOE would 
expect. For example, DOE's EECBG desktop review guidance instructs 
project officers to consider rejecting recipients' quarterly reports 
in cases where the estimates entered by recipients appear too low or 
too high. 

According to DOE officials, several factors affect the extent to which 
estimates are reasonable. One factor is the variance in the type and 
robustness of methodologies that recipients use to develop estimates. 
DOE guidance allows recipients flexibility in how they estimate impact 
metrics, such as energy savings. For example, DOE's Program Notice 10- 
07B requires that recipients "take care to account for other 
determinant factors (e.g., weather variation)" when recipients develop 
estimates. DOE officials said that they prefer that recipients rely on 
certain estimation methods and tools that DOE would expect to produce 
more accurate and sophisticated estimates of grant project results-- 
such as contractor-or engineering-supplied estimates of project 
savings or estimates calculated with the Environmental Protection 
Agency's Portfolio Manager tool.[Footnote 28] For recipients that are 
not able to use methods or tools that are specific to their grant 
projects, DOE has provided recipients with tools that DOE officials 
believe are capable of calculating "high-level" estimates of energy-
related impact metrics.[Footnote 29] Since the beginning of the EECBG 
program in 2009, DOE has updated and refined its estimating tool and 
underlying assumptions several times and may update the tool and 
assumptions in the future as well. While DOE officials said they 
believe that estimates calculated with the current version of this 
tool are more accurate than those calculated with previous versions, 
DOE does not require that recipients who use its estimating tool to 
use the most updated version when calculating and reporting estimates. 
Consequently, some recipients may use DOE's earlier, less refined tool 
to develop estimates of energy-related impact metrics. 

Another factor that affects DOE officials' ability to assess 
reasonableness is the fact that the agency recommends but does not 
require, that recipients report the methods or tools used to calculate 
estimates, so DOE officials do not know which recipients are using 
older versions of DOE's estimation tool or other methods to estimate 
energy-related impact metrics. Knowing which method or version of a 
tool recipients used to calculate estimates may be more important for 
smaller grant recipients, as DOE officials told us they believe that 
smaller grant recipients who do not have the expertise at hand or 
resources to hire energy-efficiency experts are more likely to use a 
DOE-supplied estimation tool. Without knowing the methods being used 
by recipients to estimate energy-related impacts, DOE cannot identify 
instances where the method along with the associated assumptions being 
used in calculating estimates may need to be more carefully reviewed. 

A third factor that DOE officials said can affect the development and 
reporting of reasonable estimates is the level of expertise available 
to recipients to develop impact metrics, as this can vary. According 
to DOE officials, some EECBG recipients are receiving federal grants 
for the very first time through the EECBG program, which was 
implemented in March 2009. Some communities may have limited (if any) 
direct experience with federal grant program requirements, and 
likewise have limited experience in measuring and reporting impact 
metrics. As a result, DOE officials reported that some recipients have 
had difficulty developing their estimates. In addition, DOE officials 
said that some recipients may also have made errors in reporting their 
estimates of energy-related impact metrics. For example, DOE officials 
said that some recipients may be incorrectly aggregating impact 
metrics from multiple project sites and, as a result, producing errors 
in the estimated energy-related impacts. 

In December 2010, DOE issued guidance to recipients outlining the 
steps DOE and recipients must take to formally close out EECBG grants. 
As part of this process, project officers are required to review 
recipients' final quarterly performance report and federal financial 
report for completeness and reasonableness. However, this guidance 
does not specify how project officers should assess reasonableness. 
DOE officials said that the agency is in the process of drafting 
internal closeout guidance for its project officers that will outline 
the procedures the project officers must follow to formally close out 
a grant. According to DOE officials, the upcoming internal closeout 
guidance intends to recommend, but not require, that recipients 
confirm they are reporting the most accurate data available at the 
time of closeout. DOE officials told us that once a grant is closed 
out, the agency does not require and cannot legally obligate the 
recipients to capture additional energy-savings data. For the few 
grants that have been closed, DOE expects its project officers to rely 
on their own expertise to assess the reasonableness of the estimates, 
according to DOE officials. For example, one project officer told us 
that as a project is completed, he determines whether the reported 
energy savings are reasonable by comparing the estimate when the 
project is completed to the recipient's original estimates, saying 
that he expects the estimates to be comparable unless the recipient 
has changed the scope of the project or received updated information 
from vendors or engineers. Even if the scope of the project has not 
changed or no new information has been provided, differences may be 
observed if recipients used an earlier version of the DOE tool to 
prepare an initial estimate and then used the updated DOE tool to 
compute the energy savings at the end of the project. Given that DOE 
may not know what method the recipient used to estimate energy 
savings, project officers may not be able to determine the level of 
review necessary to ensure reasonable reporting. Additionally, some of 
the project officers noted that they do not have the technical 
expertise to independently verify energy-savings estimates. 

To determine overall program outcomes, DOE officials told us they plan 
to conduct a program-wide evaluation measurement and verification 
study after the end of the EECBG program, which will be designed to 
measure and report the program's energy savings and cost savings. 
However, this effort is still in the design phase. As part of this 
study, the officials said that they would need to capture more than a 
year's worth of data to account for weather and seasonal variations 
that impact energy needs. While DOE collects some information 
regarding expected energy savings, officials noted that they were 
uncomfortable reporting these numbers before completing the study, 
which may be as long as 2 to 3 years after the projects are completed. 

Oversight of Recipient Reporting Data Quality Continues for the Sixth 
Round of Reporting: 

To meet our mandate to comment on recipient reports, we have continued 
monitoring data that recipients reported for Recovery.gov, including 
data on jobs funded. This time we focused our review on the EECBG 
recipient data in addition to the national data. Analyzing these data 
can help in improving the accuracy and completeness of the 
Recovery.gov data and in planning analyses of recipient reports. 
Overall, this round's results were similar to those we observed in 
previous rounds. According to Recovery.gov as of January 30, 2011, 
recipients reported on over 209,400 awards across multiple programs 
indicating that the Recovery Act funded approximately 585,654 jobs 
during the quarter beginning October 1, 2010, and ending December 31, 
2010.[Footnote 30] This included 2,051 prime reports associated with 
EECBG recipients.[Footnote 31] As reported by the Recovery 
Accountability and Transparency Board, job calculations are based on 
the number of hours worked in a quarter and funded under the Recovery 
Act--expressed in FTEs.[Footnote 32] 

Analysis of Sixth Round Recipient Reporting Data Shows Data Quality 
Remains Relatively Stable: 

Using the sixth reporting period data, we continued our monitoring of 
errors or potential problems by repeating the analyses and edit checks 
reported in our previous reports. We reviewed 71,643 prime recipient 
report records from all programs posted on Recovery.gov for this sixth 
round. This was, for the first time, a decrease of 6,068 prime 
recipient reports or about an 8 percent drop from round five. The size 
of this decline in reporting was somewhat mitigated by the number of 
prime recipients reporting for the first time in round six. In round 
five, 7,465 recipients identified that round as their final report and 
did not report in round six. This was more than three times the number 
of prime recipients reporting for the first time in round six and 
suggests that further decreases in the number of recipients reporting 
in the next quarter are likely. For our analyses, in addition to this 
sixth round of recipient report data, we also used all the previous 
rounds of data as posted on Recovery.gov as of February 2, 2011. 

In examining recipient reports, we continued to look for progress in 
addressing limitations we noted in our prior reports. In those prior 
rounds, we reviewed data logic and consistency and reviewed unusual or 
atypical data. Data logic and consistency provide information on 
whether the data are believable, given program guidelines and 
objectives; unusual or atypical data values indicate potential 
inaccuracies. As with previous quarterly report rounds, these reviews 
included (1) the ability to link reports for the same project across 
quarters and (2) concerns in the data logic and consistency, such as 
reports marked final that show a significant portion of the award 
amount not spent. We continued to see minor variations in the number 
or percent of reports appearing atypical or showing some form of data 
discrepancy. For example, we continued to find a small number of prime 
recipient reports for which there were potential linkage issues across 
quarters. For this latest round, there was a slight increase from 1.5 
percent to 2.2 percent in the number of prime reports appearing across 
all quarters showing a skip in reporting for one or more quarters. 
This may impact the ability to track project funding and FTEs over 
quarters. The number of reports marked "final" for which there 
appeared to be some discrepancy, such as reports marked "final" but 
for which project status was marked as less than 50 percent completed, 
continued to be quite small and unchanged from the previous round. 

We continued to examine the recipient reports' agency review flag 
field as part of our examination of data logic and consistency, since 
we have noted inconsistencies between agencies' accounts of their 
review process and the data shown in that field. Prime recipient 
report records include a review flag indicating whether or not a 
federal agency reviewed the record during the data quality review time 
frames. Prior analyses suggested that, for some agencies, the data in 
this field might not correctly reflect the extent of their review 
process. However, this did not seem to be the case for the EECBG 
program. EECBG program data in this field in this sixth round showed 
that 93 percent of the prime recipient reports were marked as reviewed 
by DOE, which was generally consistent with accounts of agency 
officials about their review process. However, we continue to observe 
some inconsistency when another data field on recipient reports, which 
shows whether or not a correction was initiated, is considered in 
conjunction with agency and recipient review flags. A correction could 
be initiated by either the prime recipient or the reviewing agency. 
Logically, one might expect that if a correction was made, it would 
have been initiated by a reviewer, and therefore the review flag 
should also be set to "yes." In this sixth round, as in the prior 
round, 10 percent of all prime recipient reports for all programs had 
this correction flag set to "yes" even though the review flags 
indicated that neither the agency nor prime recipient had reviewed 
those reports. 

As part of our focus on EECBG recipient reports for this sixth round 
of reporting, we examined reported FTE data since they can provide 
insight into the use and impact of the Recovery Act funds. Recipient 
reports of FTEs, however, cover only direct jobs funded by the 
Recovery Act. They do not include the employment impact on suppliers 
(indirect jobs) or on the local community (induced jobs).[Footnote 33] 
Our analyses of EECBG reporting for the last five quarters showed a 
steady increase in the number of FTEs reported in each quarterly 
reporting period. As shown in figure 1, there was also a similar 
steady increase in the percent of EECBG recipients reporting funding 
at least a partial FTE with Recovery Act funds. 

Figure 1: Portion of EECBG Recipients Reporting Funding at Least a 
Partial FTE in 2010: 

[Refer to PDF for image: stacked horizontal bar graph] 

Reporting quarter: Second (Oct.-Dec. 2009); 
Number of recipients reporting funding at least a partial FTE:	393 
(21%); 
Number of recipients reporting no FTEs: 1,504 (79%); 
Total number of recipients: 1,897. 

Reporting quarter: Third (Jan.-Mar. 2010); 
Number of recipients reporting funding at least a partial FTE:	685 
(33%); 
Number of recipients reporting no FTEs: 1,375 (67%); 
Total number of recipients: 2,060. 

Reporting quarter: Fourth (Apr.-June 2010); 
Number of recipients reporting funding at least a partial FTE:	934 
(44%); 
Number of recipients reporting no FTEs: 1,186 (56%); 
Total number of recipients: 2,120. 

Reporting quarter: Fifth (July-Sept. 2010); 
Number of recipients reporting funding at least a partial FTE:	1,167 
(55%); 
Number of recipients reporting no FTEs: 948 (45%); 
Total number of recipients: 2,115. 

Reporting quarter: Sixth (Oct.-Dec. 2010); 
Number of recipients reporting funding at least a partial FTE:	1,243 
(61%); 
Number of recipients reporting no FTEs: 808 (39%); 
Total number of recipients: 2,051. 

Source: GAO analysis of Recovery.gov data. 

Note: We did not include data from the first reporting quarter due to 
concerns about reliability. 

[End of figure] 

For this report, we have chosen not to show the count of EECBG FTEs 
reported, out of concern about the comparability and reliability of 
the figures across quarterly reporting periods. As we noted in our 
September 2010 report, our field work had shown that the FTE 
calculations continued to be difficult for some recipients. This 
concern, while still present, based on information gathered from DOE 
officials in headquarters and DOE project officers in the field, 
continues to be addressed by DOE officials at all levels. As we noted 
in September, some confusion may have existed about the acceptability 
and use of some methods for calculating FTEs over the course of the 
reporting periods.[Footnote 34] This decision is also based on some 
irregularities and inconsistencies we observed in our analyses of the 
FTE data across quarters and the relationship of the hours worked, as 
reported to DOE by recipients, with the FTE values the recipients 
directly reported to FederalReporting.gov.[Footnote 35],[Footnote 36] 
DOE officials indicated that they continue to assess compliance with 
and encourage recipients to follow the DOE and Office of Management 
and Budget (OMB) guidance on how to correctly report FTEs. Moving 
forward, as these issues in reporting methods are addressed, it is 
likely that the comparability and reliability of the figures may 
improve. 

Quality Reviews Performed on EECBG Data by DOE and Prime Recipients 
Included a Focus on Updated OMB Guidance Requirements: 

Each quarter, DOE performs quality assurance steps on the data that 
recipients provide to FederalReporting.gov, including checks that are 
performed centrally across all their Recovery Act programs and reviews 
done by EECBG project officers at the program level. Based on these 
reviews, DOE officials reported that most recipients of Recovery Act 
funds have reported to FederalReporting.gov in previous rounds and now 
understand the reporting process, resulting in the reporting 
proceeding more smoothly. 

As in previous rounds, DOE performed several checks of the data 
centrally as information became available. For example, officials 
compared the amount recipients reported as funds awarded with agency 
internal records. They also compared jobs data from DOE's PAGE 
reporting system with FTEs reported to FederalReporting.gov. When 
discrepancies were found, project officers were instructed to contact 
recipients to make the necessary corrections. DOE followed up with 
grant recipients who did not report to FederalReporting.gov. For the 
sixth round, DOE reported 36 recipients to OMB as not in compliance. 
Of these, 34 are EECBG grant recipients. Several are tribal recipients 
that are in remote locations where reporting online is particularly 
challenging. 

EECBG project officers' efforts also helped ensure the quality of 
information recipients reported to FederalReporting.gov. For example, 
one group of project officers we interviewed reported spending a large 
portion of time helping recipients complete reporting requirements and 
ensuring the quality of reports. Project officers cited helping 
recipients understand terminology, such as distinguishing between 
vendors and recipients of subawards. They reported taking steps, 
including following up when large increases in job numbers were 
reported, reports were missing, a recipient in a remote location had 
difficulty submitting reports, or recipients had questions about 
definitions. 

DOE officials notified both recipients and reviewers, such as project 
officers, of the need to ensure that narrative descriptions met 
requirements laid out in OMB's September 2010 guidance.[Footnote 37] 
On September 29, 2010--a few days after OMB's guidance was released 
but before recipients started reporting for the quarter--DOE e-mailed 
both recipients and project officers instructions related to the 
guidance. The e-mail to recipients informed recipients of the need to 
provide sufficiently clear descriptions to facilitate the public's 
understanding, and stated that overly general or unclear award 
descriptions could be considered material omissions. Similarly, the e- 
mail to reviewers restated the guidance. It instructed reviewers to 
make sure they read the descriptions in the narrative data fields, and 
provide a comment to the recipient if they believed clarification was 
required. DOE also included this information in its webinars on 
recipient reporting designed for grant recipients and contractors. 
Further, it included a step in the reviewers' checklist to determine 
if the narrative descriptions provided clear and complete information 
on the award's purpose, scope, and activities. 

DOE officials also reported that during the last three quarters' 
reviews they have focused on ensuring that reports marked "final" 
correctly reflect that status. They have reached out to educate 
recipients on what that designation means and to ensure that those 
marked "final" are correctly identified. This includes looking at the 
amount reported as spent. DOE's quality assurance process flags 
reports in which it appears the designation may not be correct based 
on financial analyses, and encourages recipients to make needed 
corrections during the continuous corrections process. 

Conclusions: 

The Recovery Act pledges unprecedented transparency and accountability 
in its use of funds. In light of this pledge, the ability of the EECBG 
program to ensure compliance with applicable laws, including the 
Recovery Act and program requirements is critical, and will help 
determine the extent to which the program is meeting Recovery Act and 
program goals. DOE and recipients are taking steps to monitor the use 
of funds to help ensure that Recovery Act and program requirements are 
met, but DOE assesses recipients' monitoring practices only in a 
limited number of cases. Because of this limited assessment, DOE is 
not always able to identify when recipients' monitoring practices are 
sufficient to ensure compliance with applicable federal requirements. 
If DOE is not aware of recipients' monitoring practices, it cannot 
ensure that they have effective monitoring practices in place. 

In addition to ensuring that Recovery Act and program requirements are 
met, DOE must also be able to determine the extent to which the EECBG 
program is meeting Recovery Act and program goals for energy-related 
outcomes, such as energy savings. Because actual energy-savings data 
are often unavailable, DOE must rely on estimates. DOE takes some 
steps to assess the reasonableness of energy-related estimates, but 
without knowing which methodology or tool recipients used, it is 
difficult to do such an assessment. For example, without knowing if 
recipients who used DOE's estimating tool--which has been revised in 
the past and may be revised again in the future--were using the best 
available information for calculating metrics in the most recent 
version, project officers cannot be sure that recipients used sound 
estimating methods. Without more information regarding the recipients' 
estimating methods, DOE's assessment of the reasonableness of these 
estimates may not be sufficient to support the defensible development 
of programwide estimates of energy-related impacts, and therefore, the 
assessment of progress toward program goals. 

Recommendations for Executive Action: 

To better ensure that EECBG funds are used to meet Recovery Act and 
program goals, we are recommending that the Secretary of Energy take 
the following two actions: 

* Explore a means to capture information on the monitoring processes 
of all recipients to make certain that recipients have effective 
monitoring practices. 

* Solicit information from recipients regarding the methodology they 
used to calculate their energy-related impact metrics and verify that 
recipients who use DOE's estimation tool use the most recent version 
when calculating these metrics. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to the Department of Energy for 
review and comment. DOE's comments are reproduced in appendix II. DOE 
agreed with GAO's recommendations, stating that "implementing the 
report's recommendations will help ensure that the Program continues 
to be well managed and executed." DOE also provided additional 
information on steps it has initiated or planned to implement. In 
particular, with respect to our first recommendation, DOE elaborated 
on additional monitoring practices it performs over high dollar value 
grant recipients, such as its reliance on audit results obtained in 
accordance with the Single Audit Act and its update to the EECBG 
program requirements in the Compliance Supplement to OMB Circular No. 
A-133. However, these monitoring practices only focus on larger grant 
recipients, and we believe that the program could be more effectively 
monitored if DOE captured information on the monitoring practices of 
all recipients. 

We are sending copies of this report to appropriate congressional 
committees, the Secretary of Energy, the Director of the Office of 
Management and Budget, and other interested parties. The report will 
also be available at no charge on the GAO Web site at [hyperlink, 
http://www.gao.gov]. 

If you or your staffs have any questions about this report, please 
contact Mark E. Gaffigan at (202) 512-3841 or gaffiganm@gao.gov, or 
Yvonne D. Jones at (202) 512-6806 or jonesy@gao.gov. Contact points 
for our Offices of Congressional Relations and Public Affairs may be 
found on the last page of this report. GAO staff who made major 
contributions to this report are listed in appendix IV. 

Signed by: 

Mark E. Gaffigan: 
Managing Director Natural Resources and Environment: 

Signed by: 

Yvonne D. Jones: 
Director, Strategic Issues: 

List of Committees: 

The Honorable Daniel Inouye:
Chairman:
The Honorable Thad Cochran:
Vice Chairman:
Committee on Appropriations:
United States Senate: 

The Honorable Harold Rogers:
Chairman:
The Honorable Norman D. Dicks:
Ranking Member:
Committee on Appropriations:
House of Representatives: 

The Honorable Joseph I. Lieberman:
Chairman:
The Honorable Susan M. Collins:
Ranking Member:
Committee on Homeland Security and Governmental Affairs:
United States Senate: 

The Honorable Darrell E. Issa:
Chairman:
The Honorable Elijah Cummings:
Ranking Member:
Committee on Oversight and Government Reform:
House of Representatives: 

The Honorable Fred Upton:
Chairman:
The Honorable Henry Waxman:
Ranking Member:
Committee on Energy and Commerce:
House of Representatives: 

The Honorable Jeff Bingaman:
Chairman:
The Honorable Lisa Murkowski:
Ranking Member:
Committee on Energy and Natural Resources:
United States Senate: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

Objectives: 

We took a number of steps to address our objectives, which were to 
determine (1) how Energy Efficiency and Conservation Block Grant 
(EECBG) funds are being used, and what challenges, if any, do EECBG 
recipients face in obligating and spending their funds; (2) actions 
Department of Energy (DOE) officials and EECBG recipients are taking 
to provide oversight of EECBG funds and challenges, if any, they face 
in meeting Recovery Act and other requirements; (3) the extent to 
which EECBG program recipients and the EECBG program are meeting 
Recovery Act and EECBG program goals for energy savings, and what 
challenges, if any, have recipients encountered in measuring and 
reporting energy savings; and (4) how the quality of estimates of jobs 
created and retained reported by Recovery Act recipients, particularly 
EECBG recipients, has changed over time. 

Scope and Methodology: 

To address these objectives, we reviewed and analyzed relevant federal 
laws and regulations, as well as federal agency guidance related to 
program goals, use of funds, monitoring, and reporting outcomes. We 
interviewed agency officials and about 30 staff members in DOE field 
offices that have some role in managing and monitoring awards 
including project officers, technical monitors, contract specialists 
and contractors, and compliance officers, as well as those that 
provide direct support including attorneys and accountants, to discuss 
the roles and responsibilities for managing awards, project management 
guidance and communication, activities undertaken and challenges faced 
in providing support to recipients with obligating and spending funds, 
monitoring, and reporting outcomes. We also met with officials from 
the DOE Office of Inspector General to better understand their role in 
the expanded grant-awarding process and in monitoring recipients. We 
also interviewed representatives from associations and organizations, 
including the National Association of Counties (NACo), the National 
Association of State Energy Officials (NASEO), and the U.S. Conference 
of Mayors (USCM) to better understand best practices identified and 
challenges faced by recipients in using funds, monitoring projects, 
and reporting outcomes. 

We also reviewed reports prepared by DOE and analyzed data from DOE's 
iPortal database on the number of grant awards, amount of obligations 
and expenditures, and number of users. In addition, we reviewed 
reports prepared by DOE and analyzed data from DOE's PAGE database on 
the number and type of program activities. We assessed the reliability 
of the program data we used by reviewing DOE documentation and 
Inspector General reports on the Performance and Accountability for 
Grants in Energy (PAGE) system; interviewing knowledgeable DOE 
officials about the quality and potential limitations of the data and 
what checks and controls were in place to ensure data accuracy; and 
performing edit checks on iPortal and PAGE data. We determined the 
data were sufficiently reliable for our purposes. 

In addition, we developed a set of questions to be administered to a 
nonprobability sample of 50 grant recipients eligible to receive 
formula funding. These questions addressed various aspects of our 
first three objectives, such as obligating and spending funds, 
guidance, best practices, internal controls, monitoring, working with 
DOE officials, and challenges faced in implementing projects. We pre-
tested and revised these questions and sent them in an e-mail to 50 
EECBG grant recipients in cities and counties in the United States. 
Using October 2010 data from DOE's iPortal and PAGE information 
systems, and from data gathered from Recovery.gov, we purposefully 
identified and selected a sample of city, county, and tribal 
recipients that included a range of grants by project activity types 
(e.g., building retrofit, incentive program); award size;[Footnote 38] 
state; different DOE project officers and monitors; and different 
stages of completion. We received responses from 25 of the 50 city and 
county grant recipients. No tribal communities responded. The 
responses from recipients in this sample are not generalizable to the 
2,185 state, city, county and tribal recipients receiving formula 
EECBG funds nationwide. 

To obtain additional information regarding our objective addressing 
program goals for saving energy and reporting those savings, we 
selected another nonprobability sample of 41 EECBG grant recipients 
and sent them a similar e-mail questionnaire. We selected a range of 
recipients for this sample similar to the sample previously described. 
In addition, however, these recipients were selected because they had 
completed many, if not all, projects in their award as of October 
2010. We selected these recipients in order to obtain information on 
best practices, strengths and weaknesses in reporting outcomes and 
challenges in measuring jobs, and cost and energy savings. The 
questionnaire sent to this sample of recipients included questions 
addressing these topics along with a few of the same questions asked 
of the other recipient sample. We received responses from 24 of the 41 
grant recipients in the sample. One tribal grant recipient in our 
sample responded. The responses from this sample are also not 
generalizable to the population of EECBG recipients nationwide. 

In making our selection of grant recipients in both samples, we did 
not include grant recipients whose grant applications or awards were 
the subject of data collection efforts for previous GAO or DOE 
Inspector General reports. For both samples, we sent follow-up e-mails 
to recipients who did not respond after several weeks to our initial e-
mail, encouraging them to complete the questionnaire. We were not able 
to conduct further follow-up activities to improve the response rate 
in the limited time remaining for us to complete our data collection 
field work. We reviewed responses to questions on guidance and 
experiences in obligating and spending funds, oversight and monitoring 
efforts, and reporting outcomes as well as best practices and 
challenges faced in managing and monitoring projects. 

The recipient reporting section of this report responds to the 
Recovery Act's mandate that we comment on the estimates of jobs 
created or retained by direct recipients of Recovery Act funds. For 
our review of the sixth submission of recipient reports, covering the 
period from October 1, 2010, through December 31, 2010, we built on 
findings from our five prior reviews of the reports, covering the 
period from February 2009 through September 30, 2010. To understand 
how the quality of jobs data reported by EECBG grant recipients has 
changed over time, we compared the six quarters of recipient reporting 
data that were publicly available at Recovery.gov on February 2, 2011. 
We performed edit checks and other analyses on EECBG grant recipient 
reports, which included matching DOE-provided data from iPortal and 
PAGE information systems on EECBG recipients. As part of that matching 
process, we also examined the reliability of recipient data contained 
in these DOE information systems. Our assessment activities included 
reviewing documentation of system processes, Inspector General reviews 
of the systems and conducting logic tests for key variables. Our 
matches showed a high degree of agreement between DOE recipient 
information and the information reported by recipients directly to 
FederalReporting.gov. However, the magnitude of the differences or 
lack of agreement with regard to the full-time equivalents (FTE) are 
not insignificant.[Footnote 39] In general, we consider the data used 
to be sufficiently reliable, with attribution to official sources for 
the purposes of providing background information and a general sense 
of the status of EECBG recipient reporting. 

To update the status of open recommendations from previous bimonthly 
and recipient reporting reviews, we obtained information from agency 
officials on actions taken in response to the recommendations. 

We conducted this performance audit from September 2010 to April 2011 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: Comments from the Department of Energy: 

Department of Energy: 
Washington, DC 20585: 
	
March 17, 2011: 

Mark Gaffigan: 
Managing Director: 
Natural Resources and Environment: 
US Government Accountability Office: 
441 G Street Room 2P47: 
Washington DC 20548: 

Dear Mr. Gaffigan: 

The Office of Energy Efficiency and Renewable Energy (EERE) 
appreciates the opportunity to review and comment on the results of 
the GAO Report to Congress "Energy Efficiency and Conservation Block 
Grant	Recipients Face Challenges Meeting Legislative and Program Goals 
and Requirements".	EERE	management is committed to continuing to 
improve the Energy Efficiency and Conservation Block Grant	(EECBG) 
Program. 

Energy efficiency and conservation measures implemented at the local 
level are important ways to save taxpayer dollars and reduce demand 
for polluting sources of energy and reduce America's dependence on 
fossil fuel. Our partnership with local communities in executing 
Energy Block Grants is creating clean energy jobs that are 
contributing to the country's economic growth and recovery. Thanks to 
this	program, new alliances have been forged between local businesses, 
non-profits and governments as we transition into a new clean energy 
economy. Through the adoption of renewable energy and energy 
efficiency technologies, communities of every size are addressing 
local energy challenges and saving money by saving energy. 

The EECBG program has seen enormous success: to date, we have injected 
nearly $1 billion into the economy. The direct jobs count continues to 
rise—over 3,400 hundred jobs in Q3 of CY 2010 and over	5,700 jobs in 
Q4 of CY 2010, a 70% increase over the previous quarter. Grantees are 
reporting significant impacts on their community through 
implementation of their EECBG sustainability strategies. 

According to initial grantee self-reporting through December 2010, 
communities have upgraded the energy efficiency of over 10,000 
buildings; installed 40,000 efficient street lights; and upgraded more 
than 100,000 traffic signals.[Footnote 1] 

Americans are at work making schools, court houses and police stations 
run more efficiently, developing electric charging station networks, 
upgrading homes and businesses, and installing clean energy	solutions 
like solar panels and waste-to-energy power plants. This translates to 
millions of dollars of savings for taxpayers today and billions into 
the future. Over 2,300 communities from America's rural counties and 
tribal organizations to our largest cities and every state and U.S. 
Territory are moving to a more secure economic and energy future. 

EERE would also like to comment on the reporting requirements that GAO 
discusses in the report. Across the Recovery Act, programs are being 
implemented with unprecedented transparency, and each program must 
balance the need for detailed reporting to ensure that taxpayer 
dollars are effectively put to work with the level of burden on 
grantees. The EECBG program is one of the largest grant programs ever 
run by the federal government (as measured by the number of grantees), 
with 2,300 recipients and over 10,000 sub-recipients. Many of these 
recipients and sub-recipients are receiving federal grant money for 
the first time. While DOE does not have the resources to visit each 
recipient, sub-recipient, and project site, we do require recipients 
to file short but detailed reports on project activities to ensure 
compliance with EECBG grant terms and conditions. This allows DOE to 
track and monitor a wide breadth of recipients to ensure they are 
effectively spending taxpayer dollars and complying with requirements. 

There are many reporting requirements that are independent of the 
EECBG-specific requirements. For example, GAO notes the case of an 
EECBG recipient who canceled a geothermal project because of
"reporting requirements" (p. 14). In general, geothermal projects 
funded with Federal dollars, particularly ARRA funds, may trigger a 
variety of requirements that necessitate documentation or reporting by 
the recipient—for example, NEPA, Davis-Bacon, and Buy American 
requirements. The additional EECBG reporting requirements are nominal 
and do not differ based on the activity type, so this particular 
project would not have required any more EECBG reporting than any 
other activity. 

For reporting requirements specific to the EECBG program, EERE 
solicits regular feedback from grantees, stakeholders and project 
officers with the aim of continuously improving our operations, 
including reporting. Such feedback led EERE to make changes that 
lowered the reporting burden on grantees, while improving the quality 
of reports the program received. For example, EERE scaled back 
significantly our monthly reporting requirements.	EERE also 
incorporated lessons learned from formula grant recipients into the 
reporting requirements for competitive grant recipients. 

Below are EERE's responses to GAO's two recommendations. 

Recommendation 1: Explore means to capture information processes of 
all recipients to make certain that recipients have effective 
monitoring practices. 

The EECBG program manages an unprecedented number of grantees in what 
is essentially a startup program, with grants ranging in size from 
$25,000 to $80 million. We agree with GAO's position that EECBG should 
establish effective monitoring practices that ensure funds are 
properly spent and controls are in place to prevent waste, fraud and 
abuse. However, information gathering and review must be balanced with 
agency resources. EECBG adopted standard, well-accepted, audit 
sampling practices to achieve the most effective coverage in verifying 
monitoring practices. These practices include 100% sampling of reviews 
for the high dollar value (allocation greater than or equal to $1 
million) grantees. These are typically our most complex grants, with 
multiple sub-recipients. EECBG monitors the remaining set of grantees 
based on the size, complexity and risk profile of the grantees. 
Additional on-site reviews are undertaken for grants that have/are 
demonstrating potential at-risk behaviors, such as not filing 
quarterly reports, demonstrating reporting errors or inconsistencies, 
show a lack of responsiveness to project officers and other EERE 
personnel, and/or through desktop reviews, which are conducted on 100% 
of grantees quarterly. 

As of March 7, 2011, EERE has conducted onsite monitoring of 483 grant 
recipients with a combined allocation of just over $2 billion, or 
approximately 75% of the EECBG formula program's total $2.7 billion 
allocation. EERE plans to conduct at least one onsite visit to each 
recipient with an allocation of $1 million or greater, which accounts 
for 79% of EECBG's total allocation. The number will increase to over 
80% as EERE monitors conduct additional onsite visits. EERE performs 
onsite monitoring of $2 million or greater grantees at least once per 
year. 

EERE project officers complete a monitoring checklist and file a 
narrative report after each onsite monitoring visit. These monitoring 
checklists and narrative reports provide EERE with information on 
recipient monitoring practices. During the 483 onsite visits conducted 
to-date, EERE identified a handful of cases where recipients' 
monitoring of sub-recipients/subcontractors needed improvement. In 
these cases, EERE informed the recipients of the need to improve, and—
where appropriate—instituted a Corrective Action Plan (CAP) to help 
ensure that recipients take the necessary steps to remediate issues. 
We then continue to track the status of the CAPs at a program level to 
ensure that issues are driven to resolution. 

EERE also has issued guidance on sub-recipient monitoring (EECBG 
Program Notice 10-019, October 26, 2010).	DOE's guidance includes both 
general principles and specific examples of tools and best practices 
developed by EECBG recipients. Recipients were encouraged to 
incorporate both the general principles and the specific tools/best 
practices into their own monitoring activities. 

As part of EERE's comprehensive oversight and monitoring approach, we 
will continue to rely on the results of audits performed in accordance 
with Office of Management and Budget (OMB) Circular A-133 (single 
audits). All of the larger EECBG recipients are subject to the A-133 
audit requirement, the scope of which includes a review of sub-
recipient monitoring practices. For the current fiscal year, EERE is 
actively working with OMB to include a specific discussion of
EECBG program requirements in OMB's annual guidance for the A-133 
program in order the strengthen the audit oversight of the EECBG 
program. 

Recommendation 2: Solicit information from recipients regarding the 
methodology they used to calculate their energy-related impact metrics 
and verify that recipients who use DOE's estimation tool use the most 
recent version when calculating these metrics. 

The Department of Energy and recipients use a variety of tools and 
scientific approaches to estimate the energy savings of specific 
activities. These tools and approaches include engineering estimates, 
individually metered equipment, utility bill tracking, and estimation 
tools such as the calculator made available to grantees by EECBG. 
EECBG grants represent over 10,000 unique activities, ranging in 
geography, approach, technology, and size. Due to the diversity of 
these grants, it is not practical to prescribe one form of measurement 
and verification to all grantees. 

EERE has issued guidance that provides grantees with suggested 
guidelines to plan and conduct appropriate Evaluation, Measurement & 
Verification (EM&V) efforts for their Recovery-Act-funded EECBG 
programs and activities.[Footnote 2] It is important that the results 
achieved with funds provided by the Recovery Act be documented and 
assessed to the extent practicable for grantees. In order to provide a 
reasonable estimate of energy savings, the program reviews energy 
process and impact metrics submitted each quarter for reasonableness, 
works with grantees to correct unreasonable metrics, and continues to 
work
with grantees through closeout to refine metrics. EECBG will take a 
scientific approach to overall program evaluation during the formal 
evaluation process at the conclusion of the program. 

EERE is deeply committed to the success of the Energy Efficiency and 
Conservation Block Program and believes that implementing the report's 
recommendations will help ensure that the Program continues to be well 
managed and executed. The Department will be pleased to provide any 
additional documentation upon request. 

Thank you for the opportunity to comment on the report. We look 
forward to working with GAO to help achieve the goals of the American 
Reinvestment and Recovery Act. 

If you have any questions, please contact Ms. Martha Oliver, Office of 
Congressional and Intergovernmental Affairs, at (202) 586-2229. 

Sincerely, 

Signed by: 

[Illegible] for: 
Kathleen B. Hogan: 
Deputy Assistant Secretary for Energy Efficiency: 
Office of Technology Development: 
Energy Efficiency and Renewable Energy: 

Appendix II Footnotes: 

[1] These numbers reflect preliminary grantee reported metrics that 
have not necessarily been audited by a third party or the US 
Department of Energy. 

[2] EECBG Program Notice 10-017. 

[End of section] 

Appendix III: Status of Prior Open Recommendations and Matters for 
Congressional Consideration: 

In this appendix, we update the status of agencies' efforts to 
implement the 26 open recommendations, and 5 newly implemented 
recommendations from our previous bimonthly and recipient reporting 
reviews.[Footnote 40] New recommendations and agency responses to 
those recommendations are included in the program section of this 
report. Recommendations that were listed as implemented or closed in a 
prior report are not repeated here. Lastly, we address the status of 
our Matters for Congressional Consideration. 

Department of Energy: 

Open Recommendations:[Footnote 41] 

Given the concerns we have raised about whether program requirements 
were being met, we recommended in May 2010 that the Department of 
Energy (DOE), in conjunction with both state and local weatherization 
agencies, develop and clarify weatherization program guidance that: 

* clarifies the specific methodology for calculating the average cost 
per home weatherized to ensure that the maximum average cost limit is 
applied as intended. 

* accelerates current DOE efforts to develop national standards for 
weatherization training, certification, and accreditation, which is 
currently expected to take 2 years to complete. 

* develops a best practice guide for key internal controls that should 
be present at the local weatherization agency level to ensure 
compliance with key program requirements. 

* sets time frames for development and implementation of state 
monitoring programs. 

* revisits the various methodologies used in determining the 
weatherization work that should be performed based on the 
consideration of cost-effectiveness and develops standard 
methodologies that ensure that priority is given to the most cost-
effective weatherization work. To validate any methodologies created, 
this effort should include the development of standards for accurately 
measuring the long-term energy savings resulting from weatherization 
work conducted. 

In addition, given that state and local agencies have felt pressure to 
meet a large increase in production targets while effectively meeting 
program requirements and have experienced some confusion over 
production targets, funding obligations, and associated consequences 
for not meeting production and funding goals, we recommended that DOE 
clarify its production targets, funding deadlines, and associated 
consequences while providing a balanced emphasis on the importance of 
meeting program requirements. 

Agency Actions: 

DOE generally concurred with all of our recommendations and has begun 
to take some actions to implement them. With regard to clarifying the 
methodology to calculate the average cost per home weatherized, DOE 
has taken some action but has not yet provided specific guidance to 
clarify this methodology. In response to our recommendation to develop 
and clarify guidance on developing national standards for 
weatherization training, certification, and accreditation, according 
to DOE officials, DOE is making progress toward advancing such 
standards. For example, DOE and the Department of Labor released the 
draft "Workforce Guidelines for Home Energy Upgrades" for single-
family homes in November 2010. DOE officials expect to finalize the 
guidelines by early spring 2011. 

DOE has taken some steps to address our recommendation that it develop 
and clarify guidance to generate a best practice guide for key 
internal controls. According to officials, the Weatherization 
Assistance Program Technical Assistance Center Web site provides a 
variety of best practices on program management, administrative 
procedures, and technical standards. However, while the Web site is a 
central repository for all relevant resource documents, DOE has not 
created a dedicated guide on best practices for key internal controls. 
In response to our recommendation to develop and clarify guidance to 
set time frames for development and implementation of state monitoring 
programs, DOE has taken limited action. DOE officials provided current 
guidance available on state monitoring efforts but did not identify 
any time frames for development or implementation of state monitoring 
programs. 

With regard to our recommendation on developing and clarifying 
guidance for prioritizing cost-effective weatherization work, DOE has 
taken some actions. For example, DOE contracted with the Oak Ridge 
National Laboratory in 2010 to conduct an assessment of aspects of 
program performance such as costs and benefits for program years 2008 
to 2010. The assessment will cover both Recovery Act funds and annual 
appropriation funds. Preliminary results may be available in late 
spring 2011. In response to our recommendation that DOE clarify its 
production targets, funding deadlines, and associated consequences, 
DOE has taken steps to address this recommendation. According to 
officials, DOE has communicated directly with recipients about 
funding, production, and other priorities. For example, the Green 
Light program is in its fourth round of communications between two DOE 
offices and recipients. DOE officials cited these calls as assisting 
in the identification of barriers preventing grantees from increasing 
production and expenditures. In addition, DOE officials stated that 
grantees were notified of the requirement to spend all Recovery Act 
funds by March 31, 2012. However, DOE provided no evidence that it has 
clarified the consequences. 

Newly Implemented Recommendations:[Footnote 42] 

We recommended that DOE, in conjunction with both state and local 
weatherization agencies, develop and clarify weatherization program 
guidance that: 

* establishes best practices for how income eligibility should be 
determined and documented and issues specific guidance that does not 
allow the self-certification of income by applicants to be the sole 
method of documenting income eligibility. 

* considers and addresses how the weatherization program guidance is 
impacted by the introduction of increased amounts of multifamily units. 

Agency Actions: 

DOE agreed with both of our recommendations and has taken action to 
implement them. In response to our recommendation on issuing guidance 
and establishing best practices to determine income eligibility, DOE 
issued guidance--Weatherization Program Notice 10-18, 2010 Poverty 
Income Guidelines and Definition of Income--on September 20, 2010. In 
this guidance, DOE clarified the definition of income and strengthened 
income eligibility requirements. For example, the guidance clarified 
that self-certification of income would only be allowed after all 
other avenues of documenting income eligibility are exhausted. 
Additionally, for individuals to self-certify income, a notarized 
statement indicating the lack of other proof of income is required. 

Regarding our recommendation on weatherization program guidance for 
multifamily units, DOE officials identified several issues that impact 
the increased number of multifamily buildings to be weatherized and 
issued several guidance documents addressing multifamily buildings. 
For example, DOE issued Weatherization Program Notice 11-1, Program 
Year 2011 Weatherization Grant Guidance in December 2010, which 
contained two sections related to multifamily units. One section 
covered the eligibility of multifamily units for the weatherization 
program and the other section provided guidance on conducting energy 
audits on multifamily units. In reviewing the recently issued program 
guidance for both recommendations, we have concluded that DOE 
addressed the intent of these recommendations. 

Environmental Protection Agency: 

Open Recommendation:[Footnote 43] 

We recommended that the Environmental Protection Agency (EPA) 
Administrator work with the states to implement specific oversight 
procedures to monitor and ensure subrecipients' compliance with the 
provisions of the Recovery Act-funded Clean Water and Drinking Water 
State Revolving Fund (SRF) program. 

Agency Actions: 

In response to our recommendation, EPA provided additional guidance to 
the states regarding their oversight responsibilities, with an 
emphasis on enhancing site-specific monitoring and inspections. 
Specifically, in June 2010, the agency developed and issued an 
oversight plan outline for Recovery Act projects that provides 
guidance on the frequency, content, and documentation related to 
regional reviews of state Recovery Act programs and regional and state 
reviews of specific Recovery Act projects. For example, EPA's guidance 
states that regions and states should be reviewing the items included 
on the EPA "State ARRA Inspection Checklist" or use a state equivalent 
that covers the same topics. The plan also describes EPA headquarters' 
role in ongoing Recovery Act oversight and plans for additional 
webcasts. EPA also reiterated that contractors are available to 
provide training and to assist with file reviews and site inspections. 
We are undertaking further review of the states' use of Recovery Act 
funds for the Clean Water and Drinking Water programs. As part of that 
work, we will consider EPA's and the states' oversight of Recovery Act 
funds and, more specifically, progress in implementing EPA's guidance. 

Department of Health and Human Services: Office of Head Start: 

Open Recommendation:[Footnote 44] 

To facilitate understanding of whether regional decisions regarding 
waivers of the program's matching requirement are consistent with 
Recovery Act grantees' needs across regions, we recommended that the 
Director of the Office of Head Start (OHS) should regularly review 
waivers of the nonfederal matching requirement and associated 
justifications. 

Agency Actions: 

OHS has not conducted a review of waivers of the nonfederal matching 
requirement, but OHS officials stated that the variation is largely 
due to differences in regions' policy in timing: some regional offices 
grant waivers at the same time that the grant is made official, 
whereas other regions grant waivers later. OHS officials stated that 
although the OHS central office has not regularly reviewed grantees' 
justifications for waiver applications for regional variability in the 
past, they are looking into tracking this data in their Web-based 
system consistently across regions. The process of tracking waivers is 
not yet complete. 

Open Recommendation:[Footnote 45] 

To oversee the extent to which grantees are meeting the program goal 
of providing services to children and families and to better track the 
initiation of services under the Recovery Act, we recommended that the 
Director of OHS should collect data on the extent to which children 
and pregnant women actually receive services from Head Start and Early 
Head Start grantees. 

Agency Actions: 

The Department of Health and Human Services (HHS) disagreed with our 
recommendation. OHS officials stated that attendance data are 
adequately examined in triennial or yearly on-site reviews and in 
periodic risk management meetings. Because these reviews and meetings 
do not collect or report data on service provision, we continue to 
believe that tracking services to children and families is an 
important measure of the work undertaken by Head Start and Early Head 
Start service providers. 

Open Recommendation:[Footnote 46] 

To help ensure that grantees report consistent enrollment figures, we 
recommended that the Director of OHS should better communicate a 
consistent definition of "enrollment" to grantees for monthly and 
yearly reporting and begin verifying grantees' definition of 
"enrollment" during triennial reviews. 

Agency Actions: 

OHS issued informal guidance on its Web site clarifying monthly 
reporting requirements, but has not clarified yearly reporting 
requirements. 

Open Recommendation:[Footnote 47] 

To provide grantees consistent information on how and when they will 
be expected to obligate and expend federal funds, we recommended that 
the Director of OHS should clearly communicate its policy to grantees 
for carrying over or extending the use of Recovery Act funds from one 
fiscal year into the next. 

Agency Actions: 

HHS indicated that OHS will issue guidance to grantees on obligation 
and expenditure requirements, as well as improve efforts to 
effectively communicate the mechanisms in place for grantees to meet 
the requirements for obligation and expenditure of funds. 

Open Recommendation:[Footnote 48] 

To better consider known risks in scoping and staffing required 
reviews of Recovery Act grantees, we recommended that the Director of 
OHS should direct OHS regional offices to consistently perform and 
document Risk Management Meetings and incorporate known risks, 
including financial management risks, into the process for staffing 
and conducting reviews. 

Agency Actions: 

HHS reported OHS is reviewing the risk management process to ensure it 
is consistently performed and documented in its centralized data 
system and that it has taken related steps, such as requiring the 
grant officer to identify known or suspected risks prior to an on-site 
review. 

Department of Housing and Urban Development: 

Open Recommendation:[Footnote 49] 

Because the absence of third-party investors reduces the amount of 
overall scrutiny Tax Credit Assistance Program (TCAP) projects would 
receive and the Department of Housing and Urban Development (HUD) is 
currently not aware of how many projects lacked third-party investors, 
we recommended that HUD should develop a risk-based plan for its role 
in overseeing TCAP projects that recognizes the level of oversight 
provided by others. 

Agency Actions: 

HUD responded to our recommendation by saying it will identify 
projects that are not funded by the HOME Investment Partnerships 
Program funds and projects that have a nominal tax credit award. 
However, HUD said it will not be able to identify these projects until 
it could access the data needed to perform the analysis, and it does 
not receive access to those data until after projects have been 
completed. HUD currently has not taken any action on this 
recommendation because it only has data on the small percentage of 
projects completed to date. It is too early in the process to be able 
to identify projects that lack third-party investors. The agency will 
take action once they are able to collect the necessary information 
from the project owners and the state housing finance agencies. 

Department of Labor: 

Open Recommendations:[Footnote 50] 

To enhance the Department of Labor's (Labor) ability to manage its 
Recovery Act and regular Workforce Investment Act (WIA) formula grants 
and to build on its efforts to improve the accuracy and consistency of 
financial reporting, we recommended that the Secretary of Labor take 
the following actions: 

* To determine the extent and nature of reporting inconsistencies 
across the states and better target technical assistance, conduct a 
one-time assessment of financial reports that examines whether each 
state's reported data on obligations meet Labor's requirements. 

* To enhance state accountability and to facilitate their progress in 
making reporting improvements, routinely review states' reporting on 
obligations during regular state comprehensive reviews. 

Agency Actions: 

Labor agreed with both of our recommendations and has begun to take 
some actions to implement them. To determine the extent of reporting 
inconsistencies, Labor awarded a contract in September 2010 to perform 
an assessment of state financial reports to determine if the data 
reported are accurate and reflect Labor's guidance on reporting of 
obligations and expenditures. Labor plans to begin interviewing states 
in February 2011 and will issue a report after the interviews are 
completed and analyzed. To enhance states' accountability and 
facilitate their progress in making improvements in reporting, Labor 
has drafted guidance on the definitions of key financial terms such as 
obligations, which is currently in final clearance. After the guidance 
is issued, Labor plans to conduct a systemwide webinar on this topic. 

Open Recommendation:[Footnote 51] 

Our September 2009 bimonthly report identified a need for additional 
federal guidance in defining green jobs and we made the following 
recommendation to the Secretary of Labor: 

* To better support state and local efforts to provide youth with 
employment and training in green jobs, provide additional guidance 
about the nature of these jobs and the strategies that could be used 
to prepare youth for careers in green industries. 

Agency Actions: 

Labor agreed with our recommendation and has begun to take several 
actions to implement it. Labor's Bureau of Labor Statistics has 
developed a definition of green jobs which was finalized and published 
in the Federal Register on September 21, 2010. In addition, Labor 
continues to host a Green Jobs Community of Practice, an online 
virtual community available to all interested parties. As part of this 
effort, in December 2010, Labor hosted its first Recovery Act Grantee 
Technical Assistance Institute, which focused on critical success 
factors for achieving the goals of the grants and sustaining the 
impact into the future. The department also plans to host a symposium 
in late Spring 2011 with the green jobs state Labor Market Information 
Improvement grantees. The symposium will share recent research and 
other promising practices to inform workforce development and training 
strategies. In addition, the department anticipates releasing its 
Internet-based Occupational Information Network (O*NET) Career 
Profiler tool in the winter of 2011 for those new to the workforce. 
This tool includes the O*NET green leaf symbol to highlight green 
occupations. Furthermore, the department's implementation study of the 
Recovery Act-funded green jobs training grants is still ongoing. The 
interim report is expected in late 2011. 

Newly Implemented Recommendation:[Footnote 52] 

Our September 2009 bimonthly report identified a need for additional 
federal guidance in measuring the work readiness of youth and we made 
the following recommendation to the Secretary of Labor: 

* To enhance the usefulness of data on work readiness outcomes, 
provide additional guidance on how to measure work readiness of youth, 
with a goal of improving the comparability and rigor of the measure. 

Agency Actions: 

Labor agreed with our recommendation and has taken steps to implement 
it. Labor issued guidance in May and August 2010 to identify 
requirements for measuring the work readiness of youth and the 
methodology for implementing the work readiness indicators for the WIA 
Youth Program. The guidance clarified the changes to the definition of 
work readiness by requiring a worksite evaluation conducted by the 
employer. 

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

Open Recommendation: 

To leverage Single Audits as an effective oversight tool for Recovery 
Act programs, we recommended that the Director of the Office of 
Management and Budget (OMB): 

1. provide more direct focus on Recovery Act programs through the 
Single Audit to help ensure that smaller programs with higher risk 
have audit coverage in the area of internal controls and 
compliance;[Footnote 53] 

2. take additional efforts to provide more timely reporting on 
internal controls for Recovery Act programs for 2010 and beyond; 
[Footnote 54] 

3. evaluate options for providing relief related to audit requirements 
for low-risk programs to balance new audit responsibilities associated 
with the Recovery Act;[Footnote 55] 

4. issue Single Audit guidance in a timely manner so that auditors can 
efficiently plan their audit work;[Footnote 56] 

5. issue the OMB Circular No. A-133 Compliance Supplement no later 
than March 31 of each year;[Footnote 57] 

6. explore alternatives to help ensure that federal awarding agencies 
provide their management decisions on the corrective action plans in a 
timely manner;[Footnote 58] and: 

7. shorten the timeframes required for issuing management decisions by 
federal agencies to grant recipients.[Footnote 59] 

Agency Actions: 

(1) To provide more direct focus on Recovery Act programs to help 
ensure that smaller programs with higher risk have audit coverage in 
the area of internal controls and compliance through the Single Audit, 
OMB updated its single audit guidance in the OMB Circular A-133, 
Audits of States, Local Government, and Non-Profit Organizations 
Compliance Supplement in July 2010.[Footnote 60] This compliance 
supplement requires auditors to consider all federal programs with 
expenditures of Recovery Act awards to be considered programs with 
higher risks when performing standard risk-based tests to select 
programs to be audited. The compliance supplement also clarified 
information to assist auditors in determining the appropriate risk 
levels for programs with Recovery Act expenditures. OMB officials have 
stated that they are in the process of completing the 2011 Compliance 
Supplement which they expected to issue by March 31, 2011. As of April 
4, 2011, the 2011 Compliance Supplement had not yet been issued. They 
also stated that this compliance supplement will continue to provide 
guidance that addresses some of the higher risks inherent in Recovery 
Act programs. The most significant of these risks are associated with 
newer programs that may not yet have the internal controls and 
accounting systems in place to help ensure that funds are distributed 
and used in accordance with program regulations and objectives. 

Since Recovery Act spending is projected to continue through 2016, we 
believe that it is essential that OMB provide direction in Single 
Audit guidance so that some smaller programs with higher risk would 
not be automatically excluded from receiving audit coverage based upon 
the requirements in the Single Audit Act. In recent discussions with 
OMB officials, we communicated our concern that future Single Audit 
guidance provide instruction that helps to ensure that smaller 
programs with higher risk have audit coverage in the area of internal 
controls and compliance. OMB officials agreed and stated that they 
plan to continue including similar language in the Compliance 
Supplement and performing outreach training throughout the duration of 
the Recovery Act. 

(2) To address the recommendation for taking additional efforts to 
encourage more timely reporting on internal controls for Recovery Act 
programs for 2010 and beyond, OMB commenced a second voluntary Single 
Audit Internal Control Project (project) in August 2010 for states 
that received Recovery Act funds in fiscal year 2010.[Footnote 61] 
Similar to the prior project (which did not get started until October 
2009), one of the project's goals is to achieve more timely 
communication of internal control deficiencies for higher-risk 
Recovery Act programs so that corrective action can be taken more 
quickly. Specifically, the project encourages participating auditors 
of states that received Recovery Act funds to identify and communicate 
deficiencies in internal control to management 3 months sooner than 
the 9-month time frame currently required under OMB Circular No. A-
133. The project also requires that management provide, 2 months 
earlier than required under statute, plans for correcting internal 
control deficiencies to the cognizant agency for audit for immediate 
distribution to the appropriate federal agencies.[Footnote 62] The 
federal agency is then to have provided its concerns relating to 
management's plan of corrective actions in a written decision as 
promptly as possible and no later than 90 days after the corrective 
action plan is received by the cognizant agency for audit. According 
to OMB officials, 14 states volunteered to participate in the second 
project. Each participating state was to select a minimum of four 
Recovery Act programs for inclusion in the project. 

We assessed the results of the first OMB Single Audit Internal Control 
Project for fiscal year 2009 and found that it was helpful in 
communicating internal control deficiencies earlier than required 
under statute. We reported that 16 states participated in the first 
project and that the states selected at least two Recovery programs 
for the project. We also reported that the project's dependence on 
voluntary participation limited its scope and coverage and that 
voluntary participation may also bias the project's results by 
excluding from analysis states or auditors with practices that cannot 
accommodate the project's requirement for early reporting of control 
deficiencies. Overall, we concluded that although the project's 
coverage could have been more comprehensive, the analysis of the 
project's results provided meaningful information to OMB for better 
oversight of the Recovery Act programs selected and information for 
making future improvements to the Single Audit guidance. 

OMB's second Single Audit Internal Control Project is in progress and 
its planned completion date is June 2011. OMB plans to assess the 
project's results after its completion date. As of February 9, 2011, 
OMB officials have stated that the 14 participating states have met 
the milestones for submitting interim internal control reports by 
December 31, 2010 and their corrective action plans by January 31, 
2011. We believe that OMB needs to continue taking steps to encourage 
timelier reporting on internal controls through Single Audits for 
Recovery Act programs. 

(3) OMB officials have stated that they are aware of the increase in 
workload for state auditors who perform Single Audits due to the 
additional funding to Recovery Act programs and corresponding 
increases in programs being subject to audit requirements. OMB 
officials stated that they solicited suggestions from state auditors 
to gain further insights to develop measures for providing audit 
relief. However, OMB has not yet identified viable alternatives that 
would provide relief to all state auditors that conduct Single Audits. 
For state auditors that are participating in the second OMB Single 
Audit Internal Control Project, OMB has provided some audit relief in 
that they have modified the requirements under Circular No. A-133 to 
reduce the number of low-risk programs that are to be included in some 
project participants' risk assessment requirements. As expenditures of 
Recovery Act funds are expected to continue through 2016, it is 
important that OMB look for opportunities and implement various 
options for providing audit relief in future years. 

(4)(5) With regard to issuing Single Audit Guidance in a timely 
manner, and specifically the OMB Circular A-133 Compliance Supplement, 
we previously reported in December 2010 that OMB officials stated that 
they intended to issue the 2011 Compliance Supplement by March 31, 
2011.[Footnote 63] In January 2011, OMB officials reported that the 
production of the 2011 Compliance Supplement was on schedule for 
issuance by March 31, 2011. As of April 4, 2011, the 2011 Compliance 
Supplement had not yet been issued, and we will continue to monitor 
OMB's progress to achieve this objective. 

(6)(7) In October 2010, OMB officials stated that, based on their 
assessment of the results of the project, they have discussed 
alternatives for helping to ensure that federal awarding agencies 
provide their management decisions on the corrective action plans in a 
timely manner, including possibly shortening the time frames required 
for federal agencies to provide their management decisions to grant 
recipients.[Footnote 64] However, OMB officials have yet to decide on 
the course of action that they will pursue to implement our related 
recommendations. OMB officials acknowledged that the results of the 
2009 OMB Single Audit Internal Control Project confirmed that this 
issue continues to be a challenge. They stated that they have met 
individually with several federal awarding agencies that were late in 
providing their management decisions in the 2009 project to discuss 
the measures that the agencies will take to improve the timeliness of 
their management decisions. 

In March 2010, OMB issued guidance under memo M-10-14, item 7, 
[hyperlink, 
http://www.whitehouse.gov/sites/default/files/omb/assets/memoranda_2010/
m10-14.pdf] that called for federal awarding agencies to review 
reports prepared by the Federal Audit Clearinghouse regarding Single 
Audit findings and submit summaries of the highest-risk audit findings 
by major Recovery Act programs by September 30, 2010, as well as other 
relevant information on the federal awarding agency's actions 
regarding these areas. OMB officials have stated that they plan to use 
this information to identify trends that may require clarification or 
additional guidance in the compliance supplement. OMB officials also 
stated that they are working with the Recovery Act Accountability and 
Transparency Board to develop metrics for determining how federal 
awarding agencies are to use information available in the Single 
Audit. As of January 2011, according to OMB officials, the metric 
project is progressing. OMB officials have stated that they anticipate 
that the metrics will be available in early spring 2011 and that the 
metrics could be applied at the agency level, by program, to allow for 
analysis of Single Audit findings and other uses to be determined. One 
goal of the metrics project is to increase the effectiveness and 
timeliness of federal awarding agencies' actions to resolve Single 
Audit findings. We will monitor the progress of these efforts to 
determine the extent that it improves the timeliness of federal 
agencies' actions to resolve audit findings so that risks to Recovery 
Act funds are reduced and internal controls in Recovery Act programs 
are strengthened. 

Department of Transportation: 

Open Recommendations:[Footnote 65] 

To ensure that Congress and the public have accurate information on 
the extent to which the goals of the Recovery Act are being met, we 
recommended that the Secretary of Transportation direct the Federal 
Highway Administration (FHWA) to take the following two actions: 

1. Develop additional rules and data checks in the Recovery Act Data 
System, so that these data will accurately identify contract 
milestones such as award dates and amounts, and provide guidance to 
states to revise existing contract data. 

2. Make publicly available--within 60 days after the September 30, 
2010, obligation deadline--an accurate accounting and analysis of the 
extent to which states directed funds to economically distressed 
areas, including corrections to the data initially provided to 
Congress in December 2009. 

Agency Actions: 

As of the time of this report, the Department of Transportation (DOT) 
was in the process of developing its plans in response to these 
recommendations. 

Open Recommendation:[Footnote 66] 

To better understand the impact of Recovery Act investments in 
transportation, we believe that the Secretary of Transportation should 
ensure that the results of these projects are assessed and a 
determination made about whether these investments produced long-term 
benefits. Specifically, in the near term, we recommended that the 
Secretary direct FHWA and the Federal Transit Administration (FTA) to 
determine the types of data and performance measures they would need 
to assess the impact of the Recovery Act and the specific authority 
they may need to collect data and report on these measures. 

Agency Actions: 

In its response, DOT noted that it expected to be able to report on 
Recovery Act outputs, such as the miles of road paved, bridges 
repaired, and transit vehicles purchased, but not on outcomes, such as 
reductions in travel time, nor did it commit to assessing whether 
transportation investments produced long-term benefits. DOT further 
explained that limitations in its data systems, coupled with the 
magnitude of Recovery Act funds relative to overall annual federal 
investment in transportation, would make assessing the benefits of 
Recovery Act funds difficult. DOT indicated that, with these 
limitations in mind, it is examining its existing data availability 
and, as necessary, would seek additional data collection authority 
from Congress if it became apparent that such authority were needed. 
DOT plans to take some steps to assess its data needs, but it has not 
committed to assessing the long-term benefits of Recovery Act 
investments in transportation infrastructure. We are therefore keeping 
our recommendation on this matter open. 

Newly Implemented Recommendation:[Footnote 67] 

We recommended that the Secretary of Transportation should gather 
timely information on the progress they are making in meeting the 
maintenance-of-effort requirement and to report preliminary 
information to Congress within 60 days of the certified period 
(September 30, 2010), (1) on whether states met required program 
expenditures as outlined in their maintenance-of-effort 
certifications, (2) the reasons that states did not meet these 
certified levels, if applicable, and (3) lessons learned from the 
process. 

Agency Actions: 

On January 27, 2011, the Secretary of Transportation sent a report to 
Congress that addressed each reporting element we recommended. DOT 
reported that 29 states and the District of Columbia met their planned 
level of expenditure and 21 states did not. It also summarized reasons 
states did not meet the certified levels, such as a reduction in 
dedicated revenues for transportation or a state legislature approving 
a lower-than-expected level of transportation funding in the state 
budget. Finally, DOT's report provided its perspectives on lessons 
learned from the process, including identifying barriers to 
effectively implementing the maintenance-of-effort requirement. For 
example, it noted that the lack of clarity around statutory 
definitions regarding what constituted "state funding" and the 
substantial decreases in state dedicated transportation revenues were 
barriers to states producing an accurate certification and meeting the 
certified level. 

Department of the Treasury: 

Newly Implemented Recommendation:[Footnote 68] 

The Department of the Treasury (Treasury) should expeditiously provide 
Housing Finance Agencies (HFA) with guidance on monitoring project 
spending and develop plans for dealing with the possibility that 
projects could miss the spending deadline and face further project 
interruptions. 

Agency Actions: 

Treasury officials told us that after they provided additional 
guidance, every state HFA and the respective property owners complied 
with the 30 percent spending rule by the end of calendar year 2010. We 
concluded that Treasury and the state HFAs have addressed the intent 
of this recommendation. 

Matters for Congressional Consideration: 

Matter:[Footnote 69] 

To the extent that appropriate adjustments to the Single Audit process 
are not accomplished under the current Single Audit structure, 
Congress should consider amending the Single Audit Act or enacting new 
legislation that provides for more timely internal control reporting, 
as well as audit coverage for smaller Recovery Act programs with high 
risk. 

We continue to believe that Congress should consider changes related 
to the Single Audit process. 

Matter:[Footnote 70] 

To the extent that additional coverage is needed to achieve 
accountability over Recovery Act programs, Congress should consider 
mechanisms to provide additional resources to support those charged 
with carrying out the Single Audit Act and related audits. 

We continue to believe that Congress should consider changes related 
to the Single Audit process. 

Matter:[Footnote 71] 

To provide HFAs with greater tools for enforcing program compliance, 
in the event the Section 1602 Program is extended for another year, 
Congress may want to consider directing Treasury to permit HFAs the 
flexibility to disburse Section 1602 Program funds as interest-bearing 
loans that allow for repayment. 

We continue to believe that Congress should consider directing 
Treasury to permit HFAs the flexibility to disburse Section 1602 
Program funds as interest-bearing loans that allow for repayment. 

[End of section] 

Appendix IV: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

Mark E. Gaffigan, (202) 512-3841 or gaffiganm@gao.gov: 

Yvonne D. Jones, (202) 512-6806 or jonesy@gao.gov: 

Staff Acknowledgments: 

In addition to the contacts above, Joshua Akery, Thomas Beall, Andrew 
Ching, Holly Dye, Kim Gianopoulos, Sharon Hogan, Thomas James, 
Jonathan Kucskar, Kristen Massey, Karine McClosky, Alison O'Neill, 
Carol Patey, Brenda Rabinowitz, Beverly Ross, Kelly Rubin, Ben Shouse, 
Jonathan Stehle, Kiki Theodoropoulos, Nick Weeks, and Ethan Wozniak 
made key contributions to this report. 

[End of section] 

Related GAO Products: 

The following is a list of 10 related products published since the 
last mandated GAO report on the Recovery Act. [hyperlink, 
http://www.gao.gov/products/GAO-11-166], December 15, 2010. For a full 
list of products related to the Recovery Act, see [hyperlink, 
http://gao.gov/recovery/related-products/]. 

Medicaid: Improving Responsiveness of Federal Assistance to States 
during Economic Downturns. [hyperlink, 
http://www.gao.gov/products/GAO-11-395]. Washington, D.C.: March 31, 
2011. 

State and Local Governments: Knowledge of Past Recessions Can Inform 
Future Federal Fiscal Assistance. [hyperlink, 
http://www.gao.gov/products/GAO-11-401]. Washington, D.C.: March 31, 
2011. 

Recovery Act: Status of Department of Energy's Obligations and 
Spending. [hyperlink, http://www.gao.gov/products/GAO-11-483T]. 
Washington, D.C.: March 17, 2011. 

Recovery Act: Broadband Programs Awards and Risks to Oversight. 
[hyperlink, http://www.gao.gov/products/GAO-11-371T]. Washington, 
D.C.: February 10, 2011. 

Department of Education: Improved Oversight and Controls Could Help 
Education Better Respond to Evolving Priorities. [hyperlink, 
http://www.gao.gov/products/GAO-11-194]. Washington, D.C.: February 
10, 2011. 

Rail Transit: FTA Programs Are Helping Address Transit Agencies' 
Safety Challenges, but Improved Performance Goals and Measures Could 
Better Focus Efforts. [hyperlink, 
http://www.gao.gov/products/GAO-11-199]. Washington, D.C.: January 31, 
2011. 

Defense Infrastructure: High-Level Federal Interagency Coordination Is 
Warranted to Address Transportation Needs beyond the Scope of the 
Defense Access Roads Program. [hyperlink, 
http://www.gao.gov/products/GAO-11-165]. Washington, D.C.: January 26, 
2011. 

Summary of GAO's Performance and Financial Information Fiscal Year 
2010. [hyperlink, http://www.gao.gov/products/GAO-11-3SP]. Washington, 
D.C.: January 24, 2011. 

Child Support Enforcement: Departures from Long-term Trends in Sources 
of Collections and Caseloads Reflect Recent Economic Conditions. 
[hyperlink, http://www.gao.gov/products/GAO-11-196]. Washington, D.C.: 
January 14, 2011. 

Multiple Employment and Training Programs: Providing Information on 
Colocating Services and Consolidating Administrative Structures Could 
Promote Efficiencies. [hyperlink, 
http://www.gao.gov/products/GAO-11-92]. Washington, D.C.: January 13, 
2011. 

[End of section] 

Footnotes: 

[1] This amount is current as of March 18, 2011. For updates see 
[hyperlink, http://gao.gov/recovery]. 

[2] Recovery Act, Pub. L. No. 111-5, § 3, 123 Stat. 116 (2009). 

[3] Recovery Act, div. A, § 1512(e), 123 Stat. 288. In this report, we 
refer to the quarterly reports required by Section 1512 as recipient 
reports. 

[4] GAO, Recovery Act: States' and Localities' Uses of Funds and 
Actions Needed to Address Implementation Challenges and Bolster 
Accountability, [hyperlink, http://www.gao.gov/products/GAO-10-604] 
(Washington, D.C.: May 26, 2010). 

[5] The Energy Independence and Security Act of 2007 (EISA) was signed 
into law on December 19, 2007. Pub. L. No. 110-140, 121 Stat. 1492. 

[6] The first quarter that recipients began reporting grant 
information through PAGE was July 1, 2009, to September 30, 2009. 

[7] DOE, Financial Assistance Funding Opportunity Announcement: 
Recovery Act - Energy Efficiency and Conservation Block Grants - 
Formula Grants, DE-FOA-0000013 (Mar. 26, 2009). 

[8] According to EECBG statutory requirements for formula grants, "A 
State that receives a grant under the program shall use not less than 
60 percent of the amount received to provide subgrants to units of 
local government in the State that are ineligible" for direct formula 
grants. This means that 60 percent of EECBG funds awarded to states 
must be distributed to local units of government within the state that 
are not eligible to receive direct formula grants through the EECBG 
program. 

[9] DOE, Office of Inspector General, The Department of Energy's 
Implementation of the Energy Efficiency and Conservation Block Grant 
Program under the Recovery and Reinvestment Act: A Status Report, OAS- 
RA-10-16 (Aug. 11, 2010). 

[10] DOE defines the effective date of award as the date that the DOE 
contracting officer signed the award document. 

[11] DOE, Financial Assistance Funding Opportunity Announcement: 
Recovery Act - Energy Efficiency and Conservation Block Grants - 
Formula Grants, DE-FOA-0000013 (Mar. 26, 2009) and DOE, Energy 
Efficiency and Conservation Block Grant Program Notice 10-011 (Apr. 
21, 2010). 

[12] DOE, Office of Inspector General, The Department of Energy's 
Implementation of the Energy Efficiency and Conservation Block Grant 
Program under the Recovery and Reinvestment Act: A Status Report, OAS- 
RA-10-16 (Aug. 11, 2010). 

[13] The Buy American requirement of the act generally requires that 
grant recipients use iron, steel, and manufactured goods produced in 
the United States on all Recovery Act-funded projects. 

[14] Under Division A, Section 1606 of the Recovery Act, contractors 
and subcontractors hired with Recovery Act funds are required to pay 
prevailing wages to laborers and mechanics. 

[15] Duties and position titles for monitoring staff vary somewhat by 
DOE office location. For the purposes of this report, contract 
specialists and technical monitors will also be referred to as project 
officers. 

[16] DOE defines subrecipients as those recipients that receive pass- 
through funds from recipients but are not the ultimate beneficiary of 
the funds, such as the vendor or contractor who provided the good or 
service. 

[17] Internal controls include organization, policies, and procedures 
and are tools to help program and financial managers achieve results 
and safeguard the integrity of their programs. 

[18] A full-time equivalent (FTE) is calculated as the total hours 
worked divided by the number of hours in a full-time schedule. 

[19] DOE, Office of Inspector General, The Department of Energy's 
Implementation of the Energy Efficiency and Conservation Block Grant 
Program under the Recovery and Reinvestment Act: A Status Report, OAS- 
RA-10-16 (Aug. 11, 2010). 

[20] DOE, Office of Inspector General, Management Controls over the 
Development and Implementation of the Office of Energy Efficiency and 
Renewable Energy's Performance and Accountability for Grants in Energy 
System, OAS-RA-10-14 (July 22, 2010). 

[21] 31 U.S.C. § 7502(f)(2). OMB's implementing guidance, OMB Circular 
No. A-133, Audits of States, Local Governments, and Non-Profit 
Organizations (June 2007), also imposes additional monitoring 
oversight requirements. 

[22] In addition to PAGE reporting, under Section 1512 of the Recovery 
Act, recipients of Recovery Act funds must also report--via 
FederalReporting.gov--on key project metrics such as job creation and 
total funds spent. 

[23] GAO, Recovery Act: Opportunities to Improve Management and 
Strengthen Accountability over States' and Localities' Uses of Funds, 
[hyperlink, http://www.gao.gov/products/GAO-10-999] (Washington, D.C.: 
Sept. 20, 2010). 

[24] GAO, Geostationary Operational Environmental Satellites: 
Improvements Needed in Continuity Planning and Involvement of Key 
Users, [hyperlink, http://www.gao.gov/products/GAO-10-799] 
(Washington, D.C.: Sept. 1, 2010). 

[25] Under the Single Audit Act, as amended, a non-federal entity that 
expends more than $500,000 of federal awards is required to have 
either a single audit or a program-specific audit for the fiscal year 
and report the results of the audit, among other things, to the 
federal clearinghouse designated by OMB. 

[26] DOE guidance encourages recipients who have the resources to 
voluntarily capture actual energy-savings data once they become 
available and conduct an evaluation, measurement, and verification 
effort to measure energy savings and usage. 

[27] In order to establish reasonableness, DOE officials said that DOE 
expects project officers to use their own knowledge and expertise, as 
well as leverage the knowledge and expertise of other program staff, 
to identify data outliers and spot inconsistencies. DOE is also 
developing online tools (in conjunction with project officers) to help 
make these determinations, according to DOE officials. 

[28] DOE allows recipients to use the Environmental Protection 
Agency's ENERGY STAR "Portfolio Manager" tool to measure and track 
energy performance. 

[29] DOE guidance states that outputs from DOE-supplied calculators 
and tools should only be used for reporting if site specific estimates 
are not available. The instructions for the DOE "ARRA Benefit 
Reporting Calculator" state: "This tool is designed to provide high 
level estimates of energy savings and resulting emission reductions. 
This tool is not intended to replace contractor or engineering 
supplied estimates of your project savings." 

[30] Under the continuous corrections period, recipients were allowed 
to modify submissions from February 2, 2011, to March 21, 2011. The 
final update of this round of recipient reported data should occur on 
March 23, 2011. 

[31] Prime recipients are nonfederal entities that receive Recovery 
Act funding as federal awards in the form of grants, loans, or 
cooperative agreements directly from the federal government. 

[32] Under the Recovery Act, recipients are to file reports for any 
quarter in which they receive Recovery Act funds directly from the 
federal government. Reporting requirements apply to nonfederal 
recipients of funding, including entities such as state and local 
governments, educational institutions, nonprofits, and other private 
organizations. These requirements apply to recipients who receive 
funding through the Recovery Act's discretionary appropriations, not 
recipients receiving funds through entitlement programs, such as 
Medicaid, or tax provisions. Certain other exceptions apply, such as 
for individuals. Recovery Act, div. A, § 1512, 123 Stat. at 287-288. 

[33] For further discussion of FTE data limitations, see GAO, Recovery 
Act: Recipient Reported Jobs Data Provide Some Insight into Use of 
Recovery Act Funding, but Data Quality and Reporting Issues Need 
Attention, [hyperlink, http://www.gao.gov/products/GAO-10-223] 
(Washington, D.C.: Nov. 19, 2009), 6-9. 

[34] [hyperlink, http://www.gao.gov/products/GAO-10-999]. 

[35] See further discussion regarding our scope and methodology in 
appendix I. 

[36] FederalReporting.gov is the nationwide data collection system for 
recipient reporting data requirements, while the data reported by 
recipients are available to the public for viewing and downloading in 
Recovery.gov. 

[37] See OMB Memorandum M-10-34. This memorandum included updated 
guidance on when a recipient should mark a record as final and stated 
that changes to prior reports may not be initiated for the number of 
jobs field. Further, the memorandum noted that previous OMB 
memorandums (M-09-21 and M-10-08) require recipients to provide 
narrative descriptions that are sufficiently clear to facilitate 
understanding by the general public. 

[38] We selected a mix of large, medium and small grants defined as 
grants greater than $2 million, grants between $250,000 and $2 
million, and grants less than $250,000, respectively. 

[39] In matching 2010 third quarter recipient reports against DOE- 
provided data, we could not match 2 percent of the recipient reports 
with the DOE data. For the recipient reports that we did match, 21 
percent of the matched records were not congruent with regard to 
whether they reported any FTE value or not. An example of the mismatch 
would be a DOE-provided record that showed some FTE value while the 
matching recipient report showed zero or no FTE value at all. 

[40] GAO, Recovery Act: As Initial Implementation Unfolds in States 
and Localities, Continued Attention to Accountability Issues Is 
Essential, [hyperlink, http://www.gao.gov/products/GAO-09-580] 
(Washington, D.C.: Apr. 23, 2009); Recovery Act: States' and 
Localities' Current and Planned Uses of Funds While Facing Fiscal 
Stresses, [hyperlink, http://www.gao.gov/products/GAO-09-829] 
(Washington, D.C.: July 8, 2009); Recovery Act: Funds Continue to 
Provide Fiscal Relief to States and Localities, While Accountability 
and Reporting Challenges Need to Be Fully Addressed, [hyperlink, 
http://www.gao.gov/products/GAO-09-1016] (Washington, D.C.: Sept. 23, 
2009); Recovery Act: Recipient Reported Jobs Data Provide Some Insight 
into Use of Recovery Act Funding, but Data Quality and Reporting 
Issues Need Attention, [hyperlink, 
http://www.gao.gov/products/GAO-10-223] (Washington, D.C.: Nov. 19, 
2009); Recovery Act: Status of States' and Localities' Use of Funds 
and Efforts to Ensure Accountability, [hyperlink, 
http://www.gao.gov/products/GAO-10-231] (Washington, D.C.: Dec. 10, 
2009); Recovery Act: One Year Later, States' and Localities' Uses of 
Funds and Opportunities to Strengthen Accountability, [hyperlink, 
http://www.gao.gov/products/GAO-10-437] (Washington, D.C.: Mar. 3, 
2010); Recovery Act: States' and Localities' Uses of Funds and Actions 
Needed to Address Implementation Challenges and Bolster 
Accountability, [hyperlink, http://www.gao.gov/products/GAO-10-604] 
(Washington, D.C.: May 26, 2010); Recovery Act: Opportunities to 
Improve Management and Strengthen Accountability over States' and 
Localities' Uses of Funds, [hyperlink, 
http://www.gao.gov/products/GAO-10-999] (Washington, D.C.: Sept. 20, 
2010); and Recovery Act: Head Start Grantees Expand Services, but More 
Consistent Communication Could Improve Accountability and Decisions 
about Spending, [hyperlink, http://www.gao.gov/products/GAO-11-166] 
(Washington, D.C.: Dec. 15, 2010). 

[41] [hyperlink, http://www.gao.gov/products/GAO-10-604], 245-246. 

[42] [hyperlink, http://www.gao.gov/products/GAO-10-604], 245-246. 

[43] [hyperlink, http://www.gao.gov/products/GAO-10-604], 246-247. 

[44] [hyperlink, http://www.gao.gov/products/GAO-10-604], 184. 

[45] [hyperlink, http://www.gao.gov/products/GAO-10-604], 184. 

[46] [hyperlink, http://www.gao.gov/products/GAO-11-166], 39. 

[47] [hyperlink, http://www.gao.gov/products/GAO-11-166], 39. 

[48] [hyperlink, http://www.gao.gov/products/GAO-11-166], 39. 

[49] [hyperlink, http://www.gao.gov/products/GAO-10-999], 189. 

[50] [hyperlink, http://www.gao.gov/products/GAO-10-604], 244. 

[51] [hyperlink, http://www.gao.gov/products/GAO-09-1016], 78. 

[52] [hyperlink, http://www.gao.gov/products/GAO-09-1016], 78. 

[53] [hyperlink, http://www.gao.gov/products/GAO-09-829], 127. 

[54] [hyperlink, http://www.gao.gov/products/GAO-10-604], 248. 

[55] [hyperlink, http://www.gao.gov/products/GAO-09-829], 127. 

[56] [hyperlink, http://www.gao.gov/products/GAO-10-604], 247. 

[57] [hyperlink, http://www.gao.gov/products/GAO-10-999], 194. 

[58] [hyperlink, http://www.gao.gov/products/GAO-10-604], 247-248. 

[59] [hyperlink, http://www.gao.gov/products/GAO-10-999], 194. 

[60] Congress passed the Single Audit Act, as amended, 31 U.S.C. ch. 
75, to promote, among other things, sound financial management, 
including effective internal controls, with respect to federal awards 
administered by nonfederal entities. The Single Audit Act requires 
states, local governments, and nonprofit organizations expending 
$500,000 or more in federal awards in a year to obtain an audit in 
accordance with the requirements set forth in the act. A Single Audit 
consists of (1) an audit and opinions on the fair presentation of the 
financial statements and the Schedule of Expenditures of Federal 
Awards; (2) gaining an understanding of and testing internal control 
over financial reporting and the entity's compliance with laws, 
regulations, and contract or grant provisions that have a direct and 
material effect on certain federal programs (i.e., the program 
requirements); and (3) an audit and an opinion on compliance with 
applicable program requirements for certain federal programs. 

[61] OMB's second project is similar to its first Single Audit 
Internal Control project which started in October 2009. Sixteen states 
participated in the first project. We assessed the results of the 
project and reported them in [hyperlink, 
http://www.gao.gov/products/GAO-10-999]. 

[62] Each award recipient expending more than $50 million is assigned 
a cognizant agency for audit. Generally, the cognizant agency for 
audit is the federal awarding agency that provides the predominant 
amount of direct funding to a recipient unless OMB assigns this 
responsibility to another agency. Some of the responsibilities of the 
cognizant agency include performing quality control reviews, 
considering auditee requests for extensions, and coordinating a 
management decision for audit findings that affect federal programs of 
more than one agency. For the states participating in the project, HHS 
is the cognizant agency for audit. 

[63] The Compliance Supplement is updated annually. The 2010 
Compliance Supplement was issued in July 2010 and is applicable to 
audits of fiscal years beginning after June 30, 2009. 

[64] The project's guidelines called for the federal awarding agencies 
to complete (1) performing a risk assessment of the internal control 
deficiency and identify those with the greatest risk to Recovery Act 
funding and (2) identifying corrective actions taken or planned by the 
auditee. OMB guidance requires this information to be included in a 
management decision that the federal agency was to have issued to the 
auditee's management, the auditor, and the cognizant agency for audit. 

[65] [hyperlink, http://www.gao.gov/products/GAO-10-999], 187-188. 

[66] [hyperlink, http://www.gao.gov/products/GAO-10-604], 241-242. 

[67] [hyperlink, http://www.gao.gov/products/GAO-10-437], 29. 

[68] [hyperlink, http://www.gao.gov/products/GAO-10-999], 194. 

[69] [hyperlink, http://www.gao.gov/products/GAO-09-829], 128. 

[70] [hyperlink, http://www.gao.gov/products/GAO-09-829], 128. 

[71] [hyperlink, http://www.gao.gov/products/GAO-10-604], 251. 

[End of section] 

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