|
MEMORANDUM
VIA FACSIMILE and U.S. MAIL
| To: |
Guy K. Zimmerman
Assistant Inspector General
for Audit
Office of the Inspector General |
| |
| From: |
Carl R. Peed
Director
Office of Community Oriented Policing Services (COPS) |
| |
| Date: |
March 7, 2006 |
| |
| Subject: |
Draft Audit Report of the Office of Community Oriented Policing Services Methamphetamine Initiative |
| |
This memorandum is in response to the Office of the Inspector General’s (OIG) above-referenced draft audit report dated February 14, 2006. The COPS Office thanks the OIG for the opportunity to respond to the auditors’ recommendations.
Since 1998, Congress has appropriated over $385 million to the COPS Office to address Methamphetamine problems. The COPS Office – after coordinating with the Drug Enforcement Administration (DEA) and the Office of Justice Programs (OJP) to support additional Meth initiatives – has directly invested $214 million to support state and local law enforcement agencies in the areas of child endangerment, enforcement, intelligence gathering, drug courts, partnership development, precursor chemicals, prevention, production, training, treatment, and clean-up.
In providing funding assistance, the COPS Office reviews grantee applications received from (1) specific projects designated by Congress and (2) solicited or targeted applicants, referred to in the OIG audit report as “earmark” or “discretionary” awards, respectively. Regardless of the source, it is important to emphasize that all applications are subject to the same funding process. First, each project is analyzed to ensure the objectives meet the statutory and programmatic intent. Second, every item for which funding is requested is reviewed to determine whether, depending on the circumstances, it contributes to the success of the grantee’s project objective. The COPS Office undertakes funding decisions on a case-by-case review because state and local law enforcement agencies are on the front line and know better what their communities need in order to address their emerging law enforcement issues. The COPS Office rightfully looks to the individual grantee to identify what its most pressing needs are, and is flexible to respond to the most beneficial use for available funds.
The COPS Office will fund any lawfully allowable item based on the grantee demonstrating need. COPS guidance does contain a list of certain items that are generally acceptable to buy with COPS funds – equipment, supplies, training, travel, contract/consultants, personnel, laboratory clean-up – if they are shown to contribute to the project objectives. The list was compiled based on our experience that those items are typically needed for a community-oriented project aimed at Meth interdiction. The guidance also contains a list of certain items that are generally not acceptable to buy with COPS funds – such as furniture, weapons, vehicles or photocopiers – unless the circumstances show they are critical to the implementation of the grantee’s specific Meth project. That list was compiled based on our experience that those types of basic, day-to-day policing items, albeit necessary for general policing, may not be aimed specifically at Meth. As the COPS Office makes absolutely clear, however, the lists are of general guidance, subject to the exception of justifying a link to the grantee’s particular circumstances.
Although we explained that our funding criteria was flexible to meet the needs of the grantee’s project and consistently applied to all grants, the OIG nevertheless interpreted our program guidelines to not allow for exceptions. Thus, it concluded that “generally prohibited” items are allowed “because of the grantees’ earmarked status” and that “earmarks” are not subject to program guidelines. To the contrary, the awards consistently adhere to our protocol that each funded item must support the overall objective of the grantee’s project under the circumstances. Indeed, in each of the examples where the OIG claims that grantees used grant funds “to purchase items generally prohibited” – such as mobile radios, vehicles, furniture and photocopiers – the items legitimately correlated to the project objective. Significantly, numerous requests for “generally prohibited” items have been denied under “earmark” grants based on the lack of such sufficient correlation. Moreover, numerous requests for “generally prohibited” items have also been allowed under “discretionary” grants based on sufficient justification. Again, this case-by-case review of funding requests is necessary to respect the grantee’s individual community needs and extenuating circumstances. It results in the COPS Office’s workable strategy of encouraging grantees to engage in proactive, innovative community policing and problem-solving approaches, specifically tailored to address the complex nature of Meth markets in the grantee’s community. In short, (1) what the OIG calls “generally prohibited” items are not prohibited under program guidelines if they correlate to the project objective, and (2) the same process is applied to all awards.
Consistent with this strategy, COPS Office support has resulted in valuable and successful projects that are establishing and enhancing a variety of problem-solving strategies to combat Meth. Numerous communities have used COPS funding to establish and expand their efforts in addressing this public safety need and benefited from this grant program, including the following examples:
The Andalusia Police Department in Alabama formed a partnership with the Covington County Drug Task Force to address the multifaceted challenges of Meth use and production in Covington County. As a result of COPS funding, the Drug Task Force developed a mass media campaign to educate the public about the dangers of Meth, including an informational program that has been presented to over 2,000 area citizens, retailers, civic groups, church groups and students. The program has resulted in a strong relationship between law enforcement and the community, which has led to the discovery of several labs. The Tuscaloosa County Sheriff’s Office (AL) was facing an increased number of Meth laboratories and lacked trained personnel. While three laboratories were identified in 2001, 75 labs were identified by 2003. The COPS Office provided funding to train 75 officers to investigate, seize and process labs and to buy protective outerwear. The Poplar Bluff City Police Department in Missouri has received COPS funding to support the Southeast Missouri (SEMO) Drug Task Force, which focuses on investigating individuals that manufacture and distribute Meth. With the additional resources, investigators have proactively established relationships with retailers that supply precursor materials and provided training to citizens and law enforcement on Meth-related trends and issues. Since 2003, the Drug Task Force has identified and seized 174 clandestine laboratories and made 415 Meth-related arrests. Beginning in 2001, the COPS Office provided funding to the Pierce County Alliance, a coalition of law enforcement, treatment, prevention and business entities, to address the Meth crisis in Washington State. Among other things, the Alliance established a Meth Family Services Program, a model treatment program and family drug court program to address drug dependency issues of addicted parents. Alliance work has resulted in state legislation restricting the availability of precursor products and developing a statewide Meth Watch Program to educate retailers and citizens about reducing access to precursors and property managers and realtors about Meth production. To date, the Alliance has trained over 20,000 people and achieved a 61.3% reduction in the number of labs and a 20% increase in the numbers seeking treatment for Meth dependency. In 2001, the California Department of Justice established a Western Regional Training Center to instruct law enforcement personnel on all aspects of safely and effectively investigating drug labs. It currently serves law enforcement agencies from thirteen Western states. In 1999, these thirteen states had combined lab seizures representing 60% of all lab seizures in the U.S.
These initiatives are in addition to the valuable projects highlighted in the OIG audit report – the Small Rural Communities Meth Project targeting agencies without sufficient resources to adequately respond to the spread of Meth; the Drug Endangered Children Project addressing the children affected by Meth production; and the commended Annual National Methamphetamine Initiative Conference – all of which resulted from coordinating with the DEA, OJP and other federal agencies in order to determine the best uses for the limited funds available. The COPS Office is pleased that, as a result of our grant-making processes, these projects have realized significant achievements.
For ease of review, the draft audit recommendations are stated in bold and underlined, followed by the COPS Office’s response to each recommendation.
Recommendation 1: Develop an agency-wide plan with policies and procedures to implement the Meth Initiative.
The COPS Office concurs that an agency-wide plan with policies and procedures is necessary to implement all COPS grant programs, including the Meth Initiative.
As part of our ongoing effort to implement the Methamphetamine Initiative effectively, the COPS Office will:
- Continue to ensure that our organization coordinates with other key agencies in determining the most valuable and beneficial purposes for the limited discretionary funding appropriated for Meth-related activities.
- Strengthen our internal policies and procedures for grant management and administration, including increased interdivisional coordination, standardization of reporting procedures, and enhanced database reviews for accuracy and completeness. These efforts are described more fully in each of the responses to the recommendations listed below.
Recommendation 2: Ensure that all the groups that monitor Meth Initiative grants develop and implement a method to communicate with each other on a regular basis to promote consistency in grant oversight.
The COPS Office concurs.
While the majority of the Meth funding appropriated to the COPS Office has been awarded and administered through the Grants Administration Division (GAD), there have been a very small number of grants awarded since 1998 that were best suited, due to either the nature of the grant or the recipient agency, to be managed through either the Program, Policy Support and Evaluation (PPSE) or Training and Technical Assistance (T&TA) Divisions. These three separate divisions that manage and administer Meth Initiative grants currently work together through a variety of meeting groups in an effort to coordinate our grant-making, monitoring, and closeout efforts. For example, representatives from each division attend a formal weekly cross-divisional meeting, during which topics such as allowable costs, the application review process, and discretionary funding decisions are discussed. As another example, a series of interdivisional meetings takes place at the end of each fiscal year to discuss funding obligations and award announcements.
In order to further strengthen and enhance these interdivisional coordination and oversight efforts, representatives of all relevant divisions will now be formally assigned as members of the Meth Program Team, which, until this point, has consisted primarily of GAD employees. Members of other COPS divisions responsible for managing and administering COPS grants will also participate in team meetings. In addition, the Grant Owner’s Manual for the Methamphetamine Initiative will henceforth be distributed to all program grantees, regardless of awarding division, and agency reporting requirements will also be standardized across the COPS divisions (please refer to the COPS response to Recommendation #11 for additional information on such reports).
Based on the above management action, the COPS Office requests closure of Recommendation 2.
Recommendation 3: Institute procedures to verify periodically the completeness and accuracy of grant information in CMS.
The COPS Office concurs that completeness and accuracy of grant information in CMS should be verified periodically.
In fact, the COPS Office does indeed perform a review of grant information in CMS. In fact, when the appropriate COPS staff were contacted and the approved COPS policy (COPS Query Protocol) was followed, the correct information was provided to the OIG auditors while conducting their field work. However, the COPS Office will initiate additional procedures to ensure the completeness and accuracy of grant information in the system. Currently, when an award is data-entered into CMS, the information must be “quality control” reviewed by the program team leader or designee to insure that the data that has been entered matches the award information submitted by the grantee. The same procedure is followed for budget data within CMS. In addition, quality control of award data is performed when any grant award goes through an administrative function (extension, modification, withdrawal, or closeout) in CMS, as the Grant Program Specialist responsible for that administrative function reviews key data fields to ensure that the data is populated and accurate. Any discrepancies are to be reported to the program team leader, as well as any changes that occurred to the record when processing the administrative function.
To further strengthen our efforts in maintaining data accuracy, several new checks will be instituted to assess the data for completeness and reliability. When any award gets switched to an “ACCEPTED” status (from “PENDING”) in CMS, the database administrator will perform an additional quality control review of that newly accepted record to ensure that the following key record fields have been populated: total award, project start date, project end date, and project description (if applicable). Any discrepancies will be immediately referred to the program team leader for resolution and correction. Furthermore, when all ACCEPTED awards have been obligated within our financial database systems, the program team leader and the divisional database manager will perform another quality control review to ensure that the obligated amounts match the CMS total award amounts.
Based on the management action described above, the COPS Office requests closure of Recommendation 3.
Recommendation 4: Develop and distribute a user’s manual for CMS, including the Meth Initiative module.
The COPS Office concurs that policies and procedures relative to the Meth Initiative should be included in the CMS user manual.
The COPS Office currently has a CMS user manual for employees to use when familiarizing themselves with the functions of the system. Although the guide’s last update predates the implementation of the Meth module, the CMS manual discusses several global characteristics that are native to all CMS modules, including the Meth module. However, the COPS Office recognizes the need to update the user manual to include the Meth module, and intends to have this module updated, added to the CMS Users Manual, and distributed in 45-60 days.
The IT staff will work with Meth program staff to properly document the policies and procedures required to successfully use the Meth module of CMS in the overall support of the Meth Initiative.
Additionally, it is essential to note that CMS routinely passes DOJ security standards and has received an Authority to Operate that is based on security standards and guidelines.
When staff (both contractual and federal) leave the employment of the COPS Office, there are check-out procedures that must be followed. These check-out procedures ensure timely notice to the IT staff to disable all network access for the departing employee. Therefore, even if a departed employee’s name is left on a group listing, the individual has no way to access the network.
Recommendation 5: Modify the access status of COPS Office staff who do not need write-access to the Meth grant module, or portions thereof, in CMS.
The COPS Office concurs that the access status to the Meth grant module required updating.
On pages 17 and 18 of the draft audit report, the OIG indicated that the COPS Office had not sufficiently limited the number of personnel with write-access to Meth Initiative grants. However, the OIG also acknowledged that between February and September 2005 the COPS Office took action to correct the weaknesses that were identified. Individuals who are no longer on the Meth team and individuals no longer employed by the COPS Office have now been removed by the COPS Office. The most recent listing of users is limited to current Meth team members, the GAD database administrator, and IT staff.
Additionally, it is essential to note that CMS routinely passes DOJ security standards and has received an Authority to Operate that is based on security standards and guidelines.
When staff (both contractual and federal) leave the employment of the COPS Office, there are check-out procedures that must be followed. These check-out procedures ensure timely notice to the IT staff to disable all network access for the departing employee. Therefore, even if a departed employee’s name is left on a group listing, the individual has no way to access the network.
Based on the above management action, the COPS Office requests closure of Recommendation 5.
Recommendation 6: Develop procedures regarding the periodic review and update of user status by the Meth Team leader.
The COPS Office concurs that procedures regarding periodic review and update of user status by the Meth Team Leader should be in place.
On page 18 of the draft audit report, the OIG indicates that the COPS Office did not have a written policy requiring periodic review of users with write-access to CMS. Currently, the Meth program team leader notifies the GAD database administrator when a user is to be removed or added to have write-access to the Meth CMS module. The GAD database manager, in turn, forwards this request to COPS IT staff. Once IT staff has granted write-access permission, the GAD database manager is notified, who in turn notifies the program team leader.
In the future, to ensure that the write-access list is current, the GAD database administrator will, on a quarterly basis, request from IT staff a list of users that have write-access to a particular CMS module. This list will be forwarded to the program team leader for review to ensure the accuracy of the list, and will also provide the team leader with the opportunity to either add or remove the names of individuals who now require (or no longer require) write-access to CMS. Once the team leader has reviewed the list and provided comments, the list will be forwarded back to the GAD database manager. The GAD database manager will review the list and send it to IT to update users with write-access. Once the list has been updated, the GAD database administrator will notify the program team leader that the revisions have been implemented.
Based on the above management action, the COPS Office requests closure of Recommendation 6.
Recommendation 7: Require IT staff to periodically monitor log-out practices of staff and provide reminders as necessary.
The COPS Office concurs that log-out practices should be monitored periodically by IT staff.
Presently, the COPS Office has policies and procedures in place that assist in monitoring log-out practices of staff in addition to account maintenance when employees leave. Primarily, each COPS staff member must sign and abide by a “Rules of Behavior” document (ROB) when receiving a network account and then a subsequent renewal is required annually. This ROB clearly defines that users are required to log off of their system when leaving for the day or any extended period of time. Instructions on how to perform a proper log-out are included in the ROB. Violations of the rules articulated in the ROB may result in disciplinary action commensurate with the infraction. Furthermore, COPS staff are tested annually on IT security procedures related to the ROB.
Additionally, it is essential to note that CMS routinely passes DOJ security standards and has received an Authority to Operate that is based on security standards and guidelines.
When staff (both contractual and federal) leave the employment of the COPS Office, there are check-out procedures that must be followed. These check-out procedures ensure timely notice to the IT staff to disable all network access for the departing employee. Therefore, even if a departed employee’s name is left on a group listing, the individual has no way to access the network.
Additionally, when the IT staff performs patches and upgrades, emails are sent to users requesting that each user log off at the end of the day. IT staff members are able to determine if users did not log off by reviewing which workstations did not receive the patches. Recently, with the addition of Active Directory (software which allows any object on a network to be tracked and located) into our IT environment, improvements have been made to the way the COPS Office is able to review the current log status for all users. These reports will be reviewed weekly and any oddities and/or extended log-in times will be addressed with the user.
Based on the above management action, the COPS Office requests closure of Recommendation 7.
Recommendation 8: Require audit trail capability in the next upgrade of the CMS software.
The COPS Office concurs that audit trail capability is critical in managing CMS and will address this in the next upgrade.
While CMS does not have a fully automated audit trail capability, a full audit trail could be constructed by interrogating/querying the SQL Server transaction log.
The fields and modules where we currently track each change by date and user are the following:
- Award- Current value, previous value, date the record changed, and the name of the user performing the change are all tracked for each award amount and obligated date.
- Adjustment History- All information relating to each award adjustment including user and date information is stored.
- Agency Information- Contact data for grantees is stored for each change, including current and previous information, name of user performing the change and the date for each transaction.
- Sworn Force Strength- Actual force level is stored and tracked for each change including user performing the changes and date changed.
- Extensions- Each extension to an award end date is tracked by extension time, user performing the change and the date for each transaction.
- Population- same as above.
- Other items tracked in this audit trail manner include DUNS numbers, holds put on grantee drawdowns, Grants.gov reviewer information, Audit Management System milestone dates, and file room status.
- Application status- CMS tracks the changes to application status by user and date.
Currently, the DOJ CIO has issued guidance to explore the possibility of a single grants management system for all DOJ grants. As the COPS Office participates in these discussions and eventual system consolidation or building a new system, audit trail capability will be a requirement for the system.
Recommendation 9: Standardize grant oversight procedures to ensure that all Meth Initiative grants are monitored in a consistent fashion and that these monitoring activities are documented in the grant records.
The COPS Office concurs that all Meth Initiative grants should be monitored in a consistent fashion and documented in the grant records.
As explained in our response to Recommendation #2, in order to further strengthen and enhance our interdivisional monitoring and oversight efforts, representatives from both PPSE and T&TA will now be formally assigned as members the Meth Program team, and will regularly attend meetings of the Meth Program team. Members of other COPS divisions responsible for managing and administering COPS grants will also participate in team meetings. In addition, the Grant Owner’s Manual for the Methamphetamine Initiative will henceforth be distributed to all program grantees, regardless of awarding division, and agency reporting requirements will also be standardized across the COPS divisions (please refer to the COPS response to Recommendation #11 for additional information on such reports).
Recommendation 10: Review and update the Meth Grant Manual (including standardization of submission dates for program progress reports) and ensure that all Meth Initiative grants are administered consistently and grantees are required to adhere to the same guidelines.
The COPS Office concurs.
As noted in the audit report, the Methamphetamine Initiative Grant Owner’s Manual was most recently updated and revised in September 2005. The manual will henceforth be distributed to all program grantees, regardless of awarding division. The grant conditions listed in the Grant Owner’s Manual also appear on the reverse side of each award document mailed to grantees, and by signing the award document, grantees thereby agree to adhere to all administrative requirements set forth in the manual.
Because award mailout dates and end dates vary greatly between grantees, it is impossible to list within the Grant Owner’s Manual a fixed calendar schedule that would apply to all grantees as to when programmatic Status Update Reports and Final Update Reports may be sent out. Rather, as explained in greater detail in our response to Recommendation #11 (see below), an initial Status Update Report will first be sent to grantees approximately six months after their award documents are mailed out to them, and will continue to be sent every six months thereafter until the conclusion of the grant period. At that time, a Final Update Report will be mailed out to obtain information on the overall implementation and success of the project.
Based on the above management action, the COPS Office requests closure of Recommendation 10.
Recommendation 11: Increase monitoring of grantee compliance with reporting requirements to ensure that all required reports are submitted.
The COPS Office concurs.
The COPS Office and the Meth Program team are committed to ensuring consistent formalized reporting practices for all grantees with regard to the submission of required progress reports under the program. Accordingly, the team developed a programmatic Status Update Report (SUR) to be sent to grant recipients semi-annually to monitor the progress of project implementation (See Attachment #A-1). The first SUR will be sent to grantees approximately six months after their award documents are mailed out to them, and will continue to be sent every six months thereafter until the conclusion of the grant period. At that time, a Final Update Report (FUR) will be mailed out to obtain information on the overall implementation and success of the project (See Attachment#A-2).
In the past, grantees that failed to submit their required Status Update or Final Update Reports by the required deadlines were contacted via telephone to obtain the missing reports. This method has proven successful in the past, as evidenced by a 99% compliance rate for SURs mailed out to grantees in October 2005. However, in an effort to further enhance our report collection procedures, the COPS Office is in the process of developing initial and secondary delinquency notification letters to send to those grantees who have failed to submit their required reports. Failure to submit a report following the second notification letter will lead to the creation of a compliance issue and formal referral to the COPS Grant Monitoring Division for resolution, which may involve the suspension and/or possible termination of grant funding.
These SUR/FUR reports and collection procedures will be utilized by all divisions within COPS (GAD, PPSE, and T&TA) that manage Meth awards.
Based on the above management action, the COPS Office requests closure of Recommendation 11.
Recommendation 12: Periodically update “Best Practices” on the COPS Office Website with information developed by the Meth Team.
The COPS Office concurs that it is in the best interests of both COPS Office staff and our grantees to take advantage of the valuable information learned through the administration of our grant awards and to distribute it to internal staff members and external customers. As indicated by the OIG, one of the most efficient ways to proactively share such information is through the Internet via the Meth Program page of the COPS Office web site. At present, the web site posts information on a variety of topics such as upcoming Meth-related conferences and summits, environmental assessment assistance, Internet links to other Meth-related sites, and Problem Oriented Policing guides and other publications related to combating the production and use of Methamphetamine and other drugs. For example, the “Tools for Combating Meth” kit currently posted on the COPS web site includes downloadable copies of publications such as “Clandestine Drug Labs,” “Combating Methamphetamine Laboratories and Abuse: Strategies for Success,” and “Drug Dealing in Open Air Markets.” In addition, grantees can download useful documents regarding the management and administration of their Meth award, such as the Grant Owner’s Manual and the “Helpful Hints Guide for Completing a Financial Status Report.”
The COPS Office will continue to enhance our dissemination of valuable Meth-related information by posting at least one new Internet link or document on our web site on a semi-annual basis, with special focus to be placed on information falling under the category of “best practices.”
Based on the above management action, the COPS Office requests closure of Recommendation 12.
Recommendation 13: Remedy the $365,639 balance of monies not deobligated for the grants that had funds available past the expiration dates.
We concur with this recommendation and have remedied the recommendation by deobligating the funds available past the expiration dates on seven grants and extending the expiration date on one grant (See Attachments #B-1 - #B-9).
Based on the above management action, the COPS Office requests closure of Recommendation 13.
Recommendation 14: Institute procedures to immediately deobligate grants when a grant is completed, when a grantee withdraws, or when a grantee does not accept a grant.
The COPS Office concurs with this recommendation. The COPS Office implemented a written Expired Grant Policy on March 31, 2005, to ensure the timely deobligation of grants. Under this policy, on a quarterly basis grants due to expire are identified and a list is sent to program offices for review. If the grantee does not request and is not granted a no-cost extension of time to complete implementation of the grant, or if the grant is terminated or withdrawn, the program offices notify the Finance Office when it can proceed to deobligate unliquidated balances. The grantee has 90 days from expiration in which to submit its final reports, unless it requests and is granted more time to do so, and the agency has 90 days from that time to make final cost adjustments before deobligating remaining balances. The policy is based upon 28 C.F.R. Section 66.50, which generally allows the grantee 90 days to submit its final reports and the agency an additional 90 days to make adjustments. We believe this meets the intent of this recommendation, and therefore request closure.
Recommendation 15: Identify minimum training standards for grant program specialists and develop a Meth Initiative grant procedures manual for the Meth Team.
The COPS Office concurs that minimum training standards need to be identified and adhered to. The COPS Office has always been committed to providing all Grant Program Specialists (GPSs) with sufficient training to ensure the successful completion of their assigned duties, and recognizes the need to continually enhance, further develop, and implement proficient internal controls. All new GPSs are trained first and foremost on the general tasks, concepts, policies, and procedures common throughout the program teams within the Grants Administration Division. Staff members attend a mandatory two-day “New Staff Training” session to learn about the history of each grant initiative managed by the division, as well as to receive an overview of the day-to-day management and administration of each program. The presentation also includes a detailed description of the function of each division within the COPS Office, which prepares employees to be aware of the agency-wide coordination efforts necessary to ensure the successful administration of grant funding (See “New Staff Training” agenda, Attachment #C-1). Each new GPS is also assigned a veteran “mentor,” who provides in-depth and on-the-job training on a daily basis regarding the grant life cycle and the entire range of divisional tasks and assignments. Checklists are used by the mentors to keep track of which topics and procedures have been successfully covered.
In addition, the Meth program team is dedicated to providing the employees assigned to that team with opportunities to increase their operational knowledge on the subject of Methamphetamine. The team holds regular meetings to discuss grant application submissions, administrative or procedural changes, and suggestions for process improvements, and assigns team-based mentors to new employees in need of additional program guidance. Periodically, the team invites guest speakers with expertise in the subject of Methamphetamine to the COPS Office to host informational sessions on a variety of issues. In addition, Meth team members occasionally attend working conferences, visit drug training facilities, review publications, and conduct site visits to acquire an ongoing working knowledge of the dangers associated with the use and distribution of the drug.
The development of a formalized Meth team-based procedures manual was not deemed necessary for team members to comprehensively understand the tasks for which they are responsible, as team leadership has developed and disseminated a large number of guidance documents and written protocols to assist employees in the day-to-day oversight and management of the Meth awards. These documents cover processes and grant life cycle stages such as initial data entry; Control Desk duties; re-prints of lost or missing award documents; extensions; collection of progress reports; and handling of expired awards (See Attachments #C-2 – #C-5). Team members also receive training on and act in accordance with all agency-wide policies and procedures, such as the Grant Obligation Process flowchart, Closeout Policy and Procedures Manual, and Expired Grants Policy.
Based on the above management action, the COPS Office requests closure of Recommendation 15.
Recommendation 16: Review all grant applications from earmarked entities, consult with the DEA, and as necessary coordinate with Congress when grant applications do not appear to be warranted or are not consistent with the intent of the Meth Initiative.
The COPS Office concurs.
The COPS Office thoroughly reviews every application received. When applications request items that are not consistent with the intent of the Meth Initiative, or are not warranted, COPS works closely with the applicant to redirect their proposal.
The COPS Office routinely contacts Congress to notify them when grant applications are not warranted or are not consistent with the intent of the Meth Initiative. The COPS Office also contacts Congress to inform them about progress with individual projects and reports on every Meth grant at the end of the fiscal year. COPS will also contact outside agencies (such as OJP and DEA), as necessary, to determine if particular grants are warranted.
In FY 2004, the COPS Office formalized the coordination of all congressionally designated project grants with a new cross-divisional working group. Representatives from GAD (including the Tech, Meth, and SSI teams), T&TA, PPSE, GMD, Legal Division, External Affairs Division, Management and Budget, and Finance participate in the group. This group meets weekly to coordinate all of these distinctive COPS grants to ensure that both the Appropriations language and our statutory and programmatic goals are met. This group has been particularly important as the number of congressionally designated grants for which the COPS Office is responsible increases each year.
Recommendation 17: To assist in measuring program effectiveness on a regular basis, periodically review and assess individual grant outcomes and results, as well as Meth-related statistics and research and disseminate this type of information to Meth Initiative grantees.
The COPS Office concurs that program effectiveness and outcomes, as well as Meth-related statistics and research, should be disseminated to Meth Initiative grantees.
As noted earlier in our response to Recommendation #12, the COPS Office currently makes a wide range of Meth-related statistics and research available to grantees and other law enforcement agencies through our web site and other publications. For example, all agencies awarded a Meth grant in 2005 were recently sent a package of materials and information related to the drug and its prevention.
In an effort to further gauge the effectiveness of the Meth program and how it has assisted state and local law enforcement communities in successfully combating the production, use, and distribution of Meth nationwide, the COPS Office will periodically review and evaluate the semi-annual progress reports (Status Update Reports) submitted by grant recipients. The information retrieved from the reports will assist the program team in identifying areas in need of improvement, as well as provide limited quantitative data of successful activities that may then be posted on the program web site for use by external customers.
The program team will also periodically review Meth-related statistics provided by state and local law enforcement departments through the DEA’s El Paso Intelligence Center (EPIC) to assess the growing needs of various populations for additional funding, should such funding become available.
Based on the above management action, the COPS Office requests closure of Recommendation 17.
The COPS Office would like to thank you for the opportunity to review and respond to the draft audit report. If you have any questions, please contact me at (202) 616-3291 or Cynthia Bowie, Assistant Director for the Audit Liaison Division, at (202) 616-3645.
Attachments
| cc: |
Richard P. Thies
Director
DOJ/JMD Audit Liaison Office
Carol Taraszka
Regional Audit Manager
OIG Chicago Regional Office |
|