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The COPS Office concurred with our recommendations and discussed the actions it has already taken and others it will implement in response to our recommendations. However, before addressing each response to the OIG recommendations, we are providing the following comments on the COPS Office’s response to the draft report.
In Appendix X, pages 68 and 69, the COPS Office provided the following general comments:
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 will fund any lawfully allowable item based on the grantee demonstrating need. COPS guidance contains a list of certain items that are generally not acceptable to buy with COPS funds…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. 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.
We believe that we have characterized this issue appropriately in our report. Our report noted that about a third of the grantees reviewed in our audit received permission to fund items on the list of generally unallowable costs. Moreover, this list is contained within the 1999, 2001, and 2002 COPS Meth Grant Manuals, which we found were not provided to several Meth Initiative grantees. Therefore, some grantees may not have been aware of what items were generally prohibited. We believe that this creates the perception of a double standard. Further, the high percentage of grantees provided with an exception for the purchase of generally allowable items indicates that the approval of exceptions has become a regular occurrence and is no longer used under extremely limited and extenuating circumstances, as stated directly on the “FY 2005 Meth Program List of Unallowable Costs” that was provided to grant monitors.
In Appendix X, pages 68 through 82, the COPS Office provided responses to the OIG recommendations, which we analyze in turn:
Recommendation Number:
Resolved. The COPS Office concurred with our recommendation and agreed that an agency-wide plan with policies and procedures is necessary to implement all COPS grant programs, including the Meth Initiative. This recommendation can be closed when the COPS Office provides a formal plan with policies and procedures for implementing the Meth Initiative. The plan should include goals, objectives, and performance measures for the initiative, including both earmarked and discretionary funding. Further, please provide us with evidence of coordination with other key agencies, including the DEA, in determining the most valuable and beneficial purposes for using funds appropriated to the Meth Initiative. Resolved. The COPS Office concurred with our recommendation to develop an improved communication method to promote consistency in grant oversight. As noted in our report, meth grant monitors (from various divisions within the COPS Office) were not administering awards in a consistent manner. To address these inconsistencies, the COPS Office stated that the Meth Team will now include representatives from the other divisions with responsibility for Meth Initiative grants. However, in order to ensure policies and procedures are adequately communicated, we believe that the representatives assigned to the Meth Team should be actual meth grant monitors. This recommendation can be closed when we receive a copy of the notice given to the Meth Team leader to ensure that all meth awards, including those assigned to other divisions, are administered in a consistent manner. Also, please provide evidence (such as an updated Meth Team listing) of the assignment of meth grant monitors from other divisions to the Meth Team, notification to the new members of the requirement to participate and meet regularly with the Meth Team, and documentation to support the provision of the Meth Grant Manual to all Meth Initiative grant monitors.
Resolved. The COPS Office concurred with our recommendation and stated it has implemented additional steps to ensure the accuracy and completeness of grant information in the CMS. In its response, the COPS Office stated that the program team leader or designee reviewed the grant data entered to ensure it matched the award information and that an additional quality control review was performed when the grant went through an administrative function (extension, modification, withdrawal, or closeout). Our review noted numerous errors, omissions, and discrepancies in the CMS data originally provided, which had to be entered or corrected to provide an accurate and complete listing of meth award grantees and other information. This indicated that prior quality control procedures were not being followed or the existing controls were inadequate. In its response, the COPS Office stated it will institute the following quality control steps: (a) upon obligation of all accepted awards, the program team leader and database administrator will reconcile the obligated amounts to total award amounts in the CMS; and (b) the database administrator will review newly accepted records to ensure that certain key record fields have been populated and report discrepancies to the program team leader for resolution and correction. While the reconciliation and resolution of funding discrepancies will identify funding errors in specific awards, and the database administrator’s review should identify missing data in key data fields, it does not appear to address the accuracy of data entry not related to award amounts. This recommendation can be closed when we receive evidence that the proposed quality control steps were implemented, as well as formalized procedures detailing how and when the program team leader’s review will be conducted and verified to ensure that CMS data is accurate and complete.
Resolved. The COPS Office concurred with our recommendation that an updated CMS User’s Manual, including the Meth Initiative module, should be prepared and distributed to staff. According to its response, the COPS Office expects this manual to be distributed in 45-60 days, with the portion devoted to the Meth module containing the input of Meth program staff. This recommendation can be closed when we receive a copy of the updated manual and documentation to support that it has been distributed to all staff. Resolved. The COPS Office concurred with our recommendation to modify the access status of staff that do not require write-access to the Meth grant module in the CMS. Further, the COPS Office response stated that such access has been reviewed and modified and the most recent listing of users is limited to current Meth Team members, the GAD database administrator, and IT staff. This recommendation can be closed with we receive a current, approved listing of staff with write-access to the meth module that includes the reason access is necessary. Resolved. The COPS Office concurred with our recommendation that the user access listing should be periodically reviewed and updated. This recommendation can be closed when we receive the policy that formalizes the requirement for quarterly review of user status and evidence that the quarterly review for the period ending March 2006 has been performed. Resolved. The COPS Office concurred that IT staff should periodically monitor staff log-out practices and provide reminders as necessary. The COPS Office cited several policies and procedures previously in effect which should have identified and corrected untimely employee log-off. However, because we found that the CMS identified Meth Team members who remained logged onto the system for at least 8 months at a time while employed by the COPS Office, it appears that COPS Office staff were not following the established procedures. In its response, the COPS Office stated it will begin to receive and review a weekly report regarding all users and their log-on status. This recommendation can be closed when we receive a copy of the weekly log-in status reports for all users for the months of March, April, and August 2006. The COPS Office should highlight those instances where daily log-off did not occur, and confirm that it has taken action to address the issue. Resolved. The COPS Office concurred that audit trail capability will be included in the next upgrade of the CMS software. While the COPS Office response stated that a full audit trail could be constructed by querying the SQL Server transaction log, the COPS Office IT staff informed auditors during fieldwork that only the most recent change data and user was tracked in the system. This recommendation can be closed when we receive information regarding the next system upgrade, expected timeframes, and audit trail capability. Resolved. The COPS Office concurred with our recommendation that all meth awards should be monitored in a consistent fashion and that monitoring activities should be documented in the grant files. As noted in recommendation number 2, the COPS Office will now require representatives from both the Program, Policy Support, and Evaluation Division and the Training and Technical Assistance Division to regularly attend Meth Team meetings. The COPS Office will also distribute the Meth Grant Manual to all Meth Initiative grantees regardless of the awarding division. This recommendation can be closed when we receive a copy of the notice sent to all current meth grantees requiring them to comply with the Meth Grant Manual. In addition, please provide copies of any documents created to standardize the grant-monitoring process, such as during the application review process, semi-annual progress report form, delinquency letters, grant closeout review, and timeframes. Further, please provide us with a copy of the instruction issued to the grant monitors requiring them to document in the official grant file their monitoring activities in a more consistent fashion and on a more regular basis.
Resolved. The COPS Office concurred with our recommendation to review and update the Meth Grant Manual, including standardization of submission dates for program progress reports and to ensure that all meth grants are administered consistently and grantees are required to adhere to the same guidelines. In its response, the COPS Office noted that a new manual was recently released. However, the COPS Office stated that it would be impossible to list within the grant manual a fixed schedule that would apply to all grantees as to when progress and final reports were due. Instead, the COPS Office stated it will begin to send out and request progress reports every 6 months using the date the award documents are mailed out. We believe that it is possible for the Meth Grant Manual to specify timeframes for progress reports because award start and end dates vary greatly between grantees. It is possible to set a fixed calendar schedule by stating progress reports are due, for example, every June and December until the grant ends. The grantees should also be given a timeframe specifying when the report is due, such as within 30 days after the report period’s end date. We believe that this is necessary because, as noted in our report, the lack of grant progress reports was substantially the result of the COPS Office’s failure to request reports be completed. Further, the COPS Office also noted that it telephoned contacts to obtain missing reports and was 99 percent successful for the program progress reports mailed out to grantees in October 2005. However, the timeliness of report submissions was not discussed. Our report noted that grant monitors were not routinely sending out progress report requests to grantees nor ensuring that missing reports were filed in those instances where they had originally been requested. Again, we believe that the program progress report form should be provided to grantees at the start of the award and that grantees should be required to file them automatically, and not wait for a request from the grant monitor.
In order to close this recommendation, please provide us with evidence that the grant progress report submission process has been standardized and improved.
Resolved. The COPS Office concurred with our recommendation to increase monitoring to ensure grantee compliance with reporting requirements. The COPS Office developed a standardized progress report, which will be sent to all meth grantees on a semi-annual basis to monitor the progress of the project until its completion. In addition, the COPS Office is in the process of developing initial and secondary delinquency notification letters to send out to grantees who have failed to submit their required reports. In order to close this recommendation, please provide us with a listing of all awards open as of March 31, 2006, the dates the most recent progress report was due and received, the dates of their expected progress reports for the next two semi-annual periods, as well as the final report due date, if applicable, along with copies of the pro-forma delinquency notification letters. Resolved. The COPS Office concurred with our recommendation and stated that it will continue to enhance its dissemination of valuable meth-related information by posting at least one new Internet link or document on its website on a semi-annual basis, with special focus on information falling under the category of “best practices.” To close this recommendation, please provide us with information on who will be designated with these responsibilities and how this process will be monitored by the COPS Office to ensure it occurs. Resolved. The COPS Office concurred with our recommendation to remedy $365,639 remaining on hand in expired grants and stated it deobligated funds in seven of eight awards and granted an extension for the remaining grant. Based on our review of the supporting documentation provided for these grants, the COPS Office deobligated $295,558 in six awards and granted an extension for $65,627 in one instance. In the remaining grant, it appears the COPS Office allowed the grantee to draw down $4,454 in grant funds 13 months after the grant expired, without an extension. The OJP Financial Guide states that grantees must obligate funds prior to the grant expiration date and should request their final drawdown no more than 90 days after the grant-end date. During fieldwork, we reviewed this file and noted no documented contact in the grant file by the grant monitor in the 9 months following grant expiration. In order to close this recommendation, please provide a written explanation, including supporting documentation, for allowing the grantee to draw down the $4,454. The explanation should include copies of any contemporaneous correspondence that discusses the drawdown. Resolved. The COPS Office concurred with our recommendation and stated that it has instituted an Expired Grant Policy to ensure the timely deobligation of grant funds. In order to close this recommendation, please provide us with: (a) a copy of the issued Expired Grant Policy; and (b) a listing of open expired grants as of March 31, 2006, and funds on hand as of that date. The listing should include grantee name, grant number, award end date, and its fund balance on that date. For expired grants over 90 days old with a remaining fund balance, please provide a description, along with any supporting documentation available, of the actions taken regarding deobligation. Resolved. The COPS Office concurred with our recommendation that minimum training standards for grant program specialists need to be identified and adhered to and that internal controls should be continually enhanced. According to its response, the COPS Office has developed a checklist for use by mentors during on-the-job training for grant program specialists. Further, the COPS Office stated that the Meth Team leadership has developed and disseminated a large number of guidance documents and written protocols to assist employees in their oversight and management of meth awards. Therefore, to close this recommendation, please provide the mentoring checklist that illustrates that the COPS Office has identified the minimum training standards for grant program specialists. In addition, please provide evidence that the body of guidance for Meth Team members is no longer maintained in an ad-hoc manner, has been centralized for easy reference, and has been provided to each member. Resolved. The COPS Office concurred with our recommendation and stated that it consults with outside agencies, including the DEA, and as necessary coordinates with Congress when grant applications do not appear warranted or are not consistent with the intent of the Meth Initiative. Our review noted that the COPS Office will work with an earmarked grantee to refocus its grant application in a direction more consistent with the Meth Initiative. However, the COPS Office did not consult with the DEA and did not review the earmarked proposals to determine if grants were warranted. COPS officials told us they do not believe they possess the same degree of control over earmarked funds that they do with discretionary grant funds. According to an official with the External Affairs Division, the COPS Office does not question the direction of Congress, including the grantees identified, the purpose of the programs indicated, or the amounts stipulated for earmarked entities. Therefore, as stated in our report, we believe the COPS Office does not strategically analyze or assess the necessity or benefit of awarding funds to the earmarked entities, or compare the congressionally identified projects to those of other entities. In order to close this recommendation, please provide us with documentation supporting that the DEA has been consulted regarding the proposals, and evidence of the COPS Office’s attempts to coordinate with Congress when grant applications do not appear to be warranted or consistent with the intent of the Meth Initiative. Resolved. The COPS Office concurred with our recommendation that information related to program effectiveness and outcomes, as well as meth-related statistics and research, should be disseminated to Meth Initiative grantees. The COPS Office stated that it will periodically review and evaluate the semi-annual progress reports and use this information to identify areas in need of improvement, and provide limited quantitative data of successful activities on its website. In addition, the program team will periodically review meth-related statistics to assess the growing needs of various populations for additional funding. In order to close this recommendation, please provide us with evidence that the COPS Office has reviewed, evaluated, and analyzed: (1) progress reports submitted by the grant recipients, (2) meth‑related statistics provided by state and local law enforcement departments to EPIC, and (3) the contribution of grantee accomplishments towards the achievement of overall program goals.
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