The Office of Community Oriented Policing Services Methamphetamine Initiative
Audit Report 06-16
Office of the Inspector General
Congress appropriated over $385.6 million for the Meth Initiative between FYs 1998 and 2005, of which the COPS Office received about $214.1 million for grants to state and local entities. Congress earmarked approximately 84 percent of the $214.1 million for specific entities or locales. Therefore, the COPS Office has discretion to select only a small number of the grant recipients and projects. Further, the COPS Office did not expect to receive the Meth Initiative funding from Congress. As a result, there are separate entities within the COPS Office and in OJP awarding and monitoring Meth Initiative grants with no overall coordination between them.
According to COPS personnel, the initial FY 1998 appropriation for the Meth Initiative was unexpected. They further stated that they originally did not anticipate any funding beyond that initial year for the program. The COPS Office formed a Meth Team under the Grant Administration Division to monitor the majority of meth awards being made to grantees who were not already covered by its existing structure, which included the Training and Technical Assistance Division and the Program, Policy Support, and Evaluation Division. Subsequent awards to grantees previously assigned to these other Divisions remained under their administration. As a result, three separate and distinct organizational units within the COPS Office processed the first Meth Initiative awards. Assignment of grants among these Divisions was dependent upon the type or purpose of the award. For example, the COPS Office assigned a grant for a training center to the Training and Technical Assistance Division.
We interviewed representatives from each of the organizational units and were told that each oversight group acted independently. There has been no regular communication among individuals in the various units to foster uniform administration of the meth awards, or to share information on matters such as policies, procedures, concerns, and best practices.
Moreover, in FY 2000 officials from the COPS Office and OJP met and executed a reimbursement agreement to transfer certain Meth Initiative grants from the COPS Office to OJP. In general, the transferred grants were for awardees that were already receiving funds from OJP but were not an active COPS grantee in FY 2000. OJP and the COPS Office have signed reimbursement agreements each year since FY 2000, and a total of 43 awards amounting to about $46.6 million has been transferred to OJP. According to both OJP and the COPS Office, there is limited communication between the two agencies regarding the administration, monitoring, or oversight of the transferred Meth Initiative grants.
As a result, the four separate entities currently are awarding and monitoring Meth Initiative grants with no overall coordination among them. The former Meth Team leader stated that in 2004 the Meth Team attempted to coordinate the Meth Initiative by meeting quarterly with external partners, such as DEA and OJP. However, these meetings were not successful because attendance was not consistent and the endeavor fell by the wayside.
Congress has appropriated over $385.6 million for the Meth Initiative between FYs 1998 and 2005, of which the COPS Office received about $214.1 million. Most of the money that the COPS Office receives comes in the form of congressional earmarks. Generally, the congressional conference or committee reports that accompany the approved appropriations bill list the earmarked projects. The reports typically list only the entity, a very general description of the project, and the amount allocated.
More than $179 million of the $214.1 million of the COPS Meth Initiative funds, approximately 84 percent, has been designated by Congress for specific entities or locales. The earmarking process does not require projects to be vetted for duplication, necessity, fiscal accountability, or any other factor normally reviewed by a granting agency through the solicitation and selection process.
Although Congress has earmarked the majority of Meth Initiative funding, the COPS Office does administer some discretionary funds, where it designates both the recipient and the amount of the award within the amount of discretionary funding available. However, the amount of discretionary funding available to the COPS Office from year-to-year has been limited and has not been certain or predictable.
Congress directly appropriated discretionary funding only in FY 2002. In the other years, discretionary funds administered under the Meth Initiative became available when a grantee did not accept an earmark award or when an earmarked grantee’s proposed budget or total expenditures totaled less than the earmarked amount. Discretionary funding over the years has ranged from zero to $20 million, as shown in the following table.
DISCRETIONARY METH FUNDING
Because the COPS Office does not know each year if discretionary funding will be available, officials wait until the conclusion of the appropriation and earmark award process to decide how any such money will be used. In FYs 1998 and 1999, according to the former COPS Meth Team Leader, the COPS Office used the discretionary monies to fund projects very similar to the earmarked awards, but the awards were not focused on any particular aspect of the meth drug problem.
However, since FY 2002 the COPS Meth Team has attempted, on a year-by-year basis, to focus funding on a particular aspect of the meth problem. Generally, the Meth Team did not utilize the funds for the same purpose every year, nor did they receive additional discretionary funding to continue these projects from year-to-year. The discretionary projects included those described below.
In administering the discretionary grant projects, the Meth Team develops an application package and sends out a notice of fund availability to targeted grantees soliciting them to submit a grant application. According to the former Meth Team leader, they base their rankings and funding decisions on a variety of factors. For example, Meth Team members stated that (1) they determine whether the objectives of the proposed project will support the overall focus that the Meth Team developed for that year; (2) they attempt to ensure that the awards are geographically dispersed and that funding is not unduly concentrated in a particular area; (3) they confirm that the proposal does not include unallowable costs; and (4) they attempt to determine the likelihood that the proposed endeavor will succeed. Once all of these steps are completed, the COPS Office awards the discretionary grants. However, due to the uncertainty of discretionary funding there is no ongoing, coordinated use of discretionary monies, and the bulk of available funds have gone into different programs in the last several years. Further, the COPS Office decides on a year-to-year basis how the funds will be used.
The COPS Management System (CMS) is a database used by COPS staff to manage and track grants throughout their life cycle. Our review identified weaknesses in this system related to security and data accuracy and reliability.
The CMS contains different modules for different types of grants (e.g., meth grants, hiring grants, technical grants). The records in the modules contain specific information about each of the grants, such as award dates, grant status (open or closed), dollar amount of funds awarded, and administrative issues. Consequently, COPS officials stated that all COPS Office staff depend upon the CMS for grant data.
In the early stages of our audit, we requested that the COPS Office provide a list of all of the Meth Initiative grants awarded from the inception of the program in FY 1998 through FY 2004. The COPS Office provided a listing generated from the CMS. Our cursory review of this initial universe revealed that it contained numerous errors and omissions. For example, we determined that the COPS Office had omitted at least six grants from the list.
We brought these discrepancies to the attention of officials in the COPS Office. Subsequently, the COPS Office provided new universe listings. However, we continued to identify errors and omissions, such as missing grant descriptions, grants with incorrect award amounts, and an open grant identified as closed. We repeated this process several times until we obtained a complete listing containing all 267 Meth Initiative awards that accounted for all appropriations through FY 2004.
Working with officials in the COPS Office, we sought to identify the extent of the discrepancies and determine why the errors persisted. We found that, in general, the controls over the CMS were inadequate or non‑existent. Specifically, we found: (1) a lack of standardization in data entry, (2) a CMS user manual that was relatively unknown and out-of-date, and (3) a lack of a policy requiring periodic review of grant data for accuracy and completeness.
Standardization – As noted previously, various organizational units within the COPS Office were responsible for administering Meth Initiative grants. When individuals within these units entered information on individual grants into the CMS, they used different terms and descriptions. For example, the Program, Policy Support, and Evaluation Division and the Training and Technical Assistance Division titled their Meth Initiative grants as “PPSEGRANT”, or “PPSECA” or “OTHER-METH” or “TRAINING.” The COPS Meth Team consistently titled its grants as “COPS Meth.” In addition, staff in the COPS Office did not use consistent terms to identify the status of grants in the CMS. For example, individuals used the terms “pending” and “hold” to identify the same grant application status.
Because of these inconsistencies, overall program information was not easily retrievable from the CMS. The inconsistencies also caused many of the omissions in the early versions of the universe listings that the COPS Office provided to us.
User Manual – We determined that a CMS user manual existed and was available electronically. However, our interviews with staff in the COPS Office revealed that knowledge and use of the manual varied from individual to individual. Our review of the manual showed that there was no guidance on how to use the CMS for managing Meth Initiative grants, including the establishment of consistent terms to define grant status. Further, the COPS Office had not updated the manual since 1999 even though the system had undergone significant revisions since that time, including the creation of a module dedicated to the Meth Initiative. We believe that the lack of information about the Meth Initiative module and the failure to include explanations of common terms limited the manual’s usefulness to the Meth Team.
Review of Data Accuracy – Meth Team members were responsible for reviewing their assigned grants and checking the accuracy of the data entered into the CMS. The Meth Team leader told us that he and the deputy team leader reviewed individual grant information after the Control Desk initially entered a grant into the system. However, the Meth Team leader stated that the COPS Office had not performed an overall review of the grant information in CMS for accuracy and completeness.
The CMS is the primary system for the maintenance of information on COPS Office grants. Therefore, this system should be adequately protected to ensure system integrity and reduce the risk of unauthorized access, modification, disclosure, or loss. However, we found that the CMS lacked adequate controls related to system security. Specifically, the COPS Office had not sufficiently restricted users’ ability to overwrite data or properly regulated employee log-out practices, as detailed below.
Write-access – All employees and contractors who work at the COPS Office have, at a minimum, read-only access to the CMS, which allows the user to view information in each module or program but not the ability to add or change data. However, in our opinion, only select employees should have write-access, which allows the user to add or change information in the various modules in the system.
COPS Office Information Technology (IT) staff told us that no one could delete an entire grant record from the CMS, but anyone with write-access could change data in a record. For example, an individual with write-access could extend an end date of a grant or change the status without the proper authority or the need to do so. Additionally, the system does not leave a complete audit trail that tracks record changes and the user that made them.
In addition to the lack of audit trails, we found that the COPS Office had not sufficiently limited the number of personnel with write-access to Meth Initiative grants. In January 2005, the COPS Office provided us with a listing of staff with write-access to the COPS Meth Initiative grant module in the CMS. The list contained 61 names and we reviewed each individual’s employment status and area of responsibility for the applicable period. Our results revealed that 29 of the 61 persons on the list required write-access to the Meth Initiative module because they were on the Meth Team or worked in the COPS Finance, IT, Training and Technical Assistance, or Legal Divisions. Conversely, the COPS Office confirmed that the remaining 32 users did not have a legitimate need for write-access to the entire Meth Initiative module in the CMS. Three of these individuals were no longer employed by the COPS Office. However, COPS officials confirmed at the exit conference that access to the COPS network system for the three individuals had been removed in a timely manner.
We discussed our exceptions with COPS officials who agreed with our assessments. They explained that the COPS Office updated the CMS software in July 2004, which enabled the COPS IT staff to restrict write-access of individual users to particular areas, such as the grant closeout modules. At the outset of our audit, employees on the grant closeout team and in other areas still had full write-access to the COPS Meth Initiative module and their access had not been appropriately limited to the areas for which they were responsible.
Between February and September 2005, COPS Office staff took action to correct some of the weaknesses we identified. Specifically, COPS officials modified the contract employee departure checklist to ensure that the departing user’s name would be removed from the general operating and CMS systems. In addition, for the 32 users that we identified in January 2005 as not requiring write-access, the COPS Office performed the following corrections:
However, managers in the COPS Office stated that they did not have a written policy requiring periodic review of users with write-access to the CMS. In our opinion, good internal controls dictate keeping the number of users with write-access to each module at a minimum and allowing individuals to have write-access pertaining only to their areas of responsibility. We believe that the COPS Office should adopt measures to prevent personnel without a legitimate need from having access to information systems and ensure that there are procedures covering user accounts, including policies for requesting, setting up, suspending, or closing user accounts. In addition, management should periodically review access rights.
Employee Log-out Practices – During our review of the CMS write-access controls discussed above, we found that the COPS Office had not properly regulated the log-out practices of its employees. As noted in the previous section, the COPS Office had not discontinued CMS access for employees who were no longer employed by COPS. When we discussed this issue with COPS IT officials, we learned that system records showed that two individuals who no longer worked for the COPS Office had not properly logged out of the system. These former employees had last logged on the system 8 months prior to their separation from the agency. These log-ons remained active until we brought the issue to the attention of COPS IT staff. According to COPS IT officials, COPS Office employees have been told to log out, but were aware that employees often choose not to log out of the CMS at the end of the day.
COPS IT officials recognized that these log-out practices were improper but did not present a bona fide security risk to the system. However, these officials stated that the system currently does not have the ability to automatically log individuals out of the system if their machine is left on over a significant period of time.
Good grant management practices require sufficient oversight and review of the grantee’s reports and activities to determine the status of the grantee’s achievement of the grant objectives. We found that the COPS Office did not have written procedures for general oversight of the Meth Initiative grants and individual Meth Team members were not monitoring the grantees consistently.
COPS Grant Program Specialists are responsible for managing and overseeing individual grant awards assigned to them. As noted on page 10, three separate groups in the COPS Office have responsibility for the various Meth Initiative grants. Since its creation in FY 1998, the COPS Meth Team has been responsible for the majority of Meth Initiative grants.
Interviews with members of the COPS Meth Team revealed that their methods of overseeing the grants on a day-to-day basis consisted of actions such as telephone discussions with grantee officials; desk reviews of submitted reports; and responding to e-mails, letters, and other correspondence. Discussion areas included programmatic issues such as award modifications, grant extensions, and the completion of required reports. We examined the COPS Office’s oversight of Meth Initiative grants and found significant differences in the guidance and oversight provided by the various grant specialists responsible for the grants. The individual grant specialists did not have a standard method, format, or location for documenting their monitoring activities. Moreover, formal guidance issued by the COPS Office was inconsistent and contradictory, as described below.
COPS Meth Grant Manuals – COPS informed us that guidance for Meth Initiative grantees can be found in grant manuals issued specifically for the program. In 1999, the COPS Office issued its first manual for meth grants, entitled the “Methamphetamine Initiative Grant Owners Manual” (Meth Grant Manual). The COPS Office revised the manual in 2001, 2002 and again in 2005.
We found that COPS grant program specialists outside of the Meth Team were not aware of the manuals. Therefore, these grant program specialists did not provide them to their grantees. During our audits of 13 individual Meth Initiative grantees, we found 3 grantees (the Mississippi Bureau of Narcotics; Prairie View Prevention Services of South Dakota; and the Sioux City, Iowa, Police Department) had not been informed of the Meth Grant Manuals. Consequently, the various COPS grant program specialists managing Meth Initiative grants were using different standards and providing inconsistent guidance to grantees under the same program.
Moreover, several COPS officials told us that congressionally earmarked grants were stand-alone grants and that such grantees were not required to comply with the Meth Grant Manual requirements. However, this is contradicted by the standard grant acceptance documents, which the COPS Office used for both discretionary and earmarked awards that include a provision requiring the grantees to adhere to the grant manuals. For example, although Prairie View Prevention Services of South Dakota (a for-profit group) signed formal assurances statements agreeing to comply with the manuals’ provisions, officials in the COPS Office told us that this grantee was not required to comply with the Meth Grant Manuals because of their for-profit status.13 In addition, COPS officials stated that they believed that Congress expected the COPS Office to approve funding to earmarked grantees.
During our audits of specific Meth Initiative grants, we found that several grantees had used grant funds to purchase items generally prohibited by the Meth Grant Manuals. In these cases, however, the COPS Office had authorized the use of funds by approving the grant application, which clearly stipulated how the funds would be used.
For example, according to the Meth Grant Manuals and a list of unallowable costs provided to grantees by the COPS Office, costs for furniture, photocopiers, telecommunications equipment, and vehicles were unallowable. However, with the approval of the COPS Office, earmarked grantees used Meth Initiative funds for expenditures related to these types of items. Specifically, the Alabama Department of Public Safety spent approximately $27,000 on several unallowable items, such as personal data assistant units, mobile radios, and a television. The Sioux City, Iowa, Police Department used Meth Initiative grant funds for costs related to furniture and vehicles. In these instances, the COPS Office approved the submitted budget, which stipulated that each of the grantees intended to use Meth Initiative funds for the types of items normally prohibited by the Meth Grant Manuals.
The COPS Office also approved itemized grant budgets for the Vermont State Police that included salary and benefits for existing officers, which is prohibited under the Meth Grant Manuals.14 The Program Manager was unable to explain why the COPS Office approved budgets that were clearly contrary to the guidance in the manuals.
Similarly, the Meth Grant Manuals stated that meals and refreshments associated with meetings were unallowable costs and therefore could not be charged to the Meth Initiative grants. However, our audit of Prairie View Prevention Services of South Dakota identified that the COPS Office allowed this grantee to provide meals and refreshments totaling $2,688 for meetings associated with the dissemination of information on meth, and to charge the expense to the grant. Additionally, the COPS Office approved the grantee’s purchase of three photocopiers.
In our judgment, there is nothing inherent in a congressional earmark that would exempt either an administering agency from applying program guidelines consistently or a grantee from adhering to such guidelines. Further, we believe there is nothing in the nature of earmarked grants that prohibits the agency administering such grants from reviewing grant applications and budgets to ensure they meet the stated requirements of the program. In fact, since FY 2002 the congressional reports containing the Meth Initiative earmarks have explicitly stated that Congress expected the COPS Office to examine each of the proposals and to provide grants only if warranted. Consequently, we believe that the COPS Office has a responsibility to provide consistent oversight of grantees in the administration of grant awards, which includes requiring that both earmarked and discretionary grantees adhere to the same guidelines.15
Grantee Reporting Requirements - The first three versions of the COPS Meth Grant Manuals stated that the COPS Office will distribute program progress reports on a periodic basis throughout the grant period, but do not define periodic, while the most recent 2005 version stated they will be due upon request but does not include specific timeframes as to when, if at all, these reports will be requested. We examined the Meth Initiative grant reporting practices and found inconsistencies in reporting requirements between different types of grants. In addition, we identified that the COPS Office lacked a formal process for distributing and collecting program progress reports.
For example, the application documentation for the discretionary Meth Initiative awards under COPS’ Drug Endangered Children program and the FY 1999 grant application for earmarked Meth Initiative grants stated that program progress reports were due semiannually with a final report due at the end of the grant. Further, the application for discretionary awards under the Small Rural Communities program required annual program progress reports and a final program progress report upon completion of the grant. Finally, the application for FY 2004 earmarks merely states that program progress reports are due on a periodic basis.
Several Meth Team members stated they were responsible for sending out the reports and obtaining feedback from grantees. However, the former Meth Team leader told us that a contract employee sent the mid-grant program progress reports around the middle of a grant period. Finally, two grant program specialists stated they sent the report to their grantees every quarter, while another grant program specialist stated that the reports were sent annually.
The different reporting requirements coupled with the lack of a formal process is confusing and may have contributed to the inconsistent reporting practices of grantees. During our audits of 13 individual Meth Initiative grantees, we identified weaknesses attributed primarily to the grantees (such as the failure to submit requested reports) and these are detailed in Finding 2. However, these reviews also revealed that the COPS Office failed to gather adequate grant implementation information because it did not require grantees to report on their progress.
To examine the COPS Office’s practices related to grantee reporting of project implementation, we examined its efforts to collect grant program progress reports from the 13 grantees that we audited. For each grantee, we examined the number of awards received, the grant award periods, and the number of program progress reports that the COPS Office required the grantee to submit.
We determined that the COPS Office failed to obtain written program progress information from 5 of 13 grantees. Specifically, the Mississippi Bureau of Narcotics received four grants with award periods lasting from 21 to 42 months between May 2001 and June 2005. However, at the time we conducted our audit in the spring of 2005, the COPS Office had obtained only one program progress report from this grantee. Similarly, the COPS Office received only one program progress report from the Arkansas State Police even though the entity received 2 grants with award periods lasting from 23 to 29 months between May 2001 and June 2004. In addition, the Sioux City, Iowa, Police Department, received 6 grants with award periods lasting from 15 to 23 months between October 1997 and September 2004, but did not obtain written reports covering the final four grants. Moreover, the Pierce County, Washington, Alliance received three grants between May 2002 and January 2006 and the COPS Office required the grantee to submit only two program progress reports during that timeframe. Finally, the California Department of Justice received 6 grants with award periods lasting from 24 to 48 months between May 2001 and June 2006. However, the COPS Office had not obtained any program progress reports as of March 2005 from this grantee. According to grantee officials, the COPS Office requested that they submit a program progress report for each of its six grants less than 1 week before we began our on-site work in California in April 2005.
Without sufficient documentation of grantee activities, the COPS Office cannot effectively monitor grant activities or grantee compliance with grant conditions. Because of the large amount of funds awarded under the Meth Initiative and the deficiencies in the COPS Office’s practices for requesting program progress reports, we believe that the COPS Office needs to clarify and strengthen its reporting requirements and ensure that grantees are required to report on their activities at least annually. The COPS Meth Team leader concurred with this finding and told us in September 2005 that he had instructed team members to require semiannual program progress reports for all currently open awards.
Lessons Learned/Best Practices – In addition to the deficiencies cited above, we noted that the COPS Meth Team did not take full advantage of the information it learned through its administration of grant awards, and failed to share this information with others. For example, Meth Team members did not compile a list of common weaknesses they identified through their reviews of program progress reports, audits, site visits, and phone contacts with grantees. Such a compilation could alert other Meth Team members and new employees of specific matters to be aware of and could assist in the timely correction of deficiencies.
Further, we believe that the Meth Team members could be more proactive in the sharing of information about best practices and successful strategies employed by various grantees. Numerous grantees told us that the Meth Initiative conferences sponsored by the COPS Office afforded them a good opportunity to network and share information with other grantees in the program. However, we noted that these conferences occur somewhat irregularly and COPS Office officials stated that not all interested parties could attend due to limited availability of space. For these individuals and others searching for information on a more regular basis, the COPS Office has funded the creation of a website for sharing information on successful grant strategies for all grant programs. However, grantees input information voluntarily and this website has had very little information on Meth Initiative programs. We believe that the COPS Office could also provide input and should encourage grantees to use the website for sharing their best practices.
The COPS Office could also look for additional ways to provide information and training to its Meth Initiative grantees and others in the law enforcement community through pre-established sources. For example, through other grant programs that it administers, the COPS Office provides funding to 27 training centers known as Regional Community Policing Institutes. These training centers teach various law enforcement courses, such as community policing, reducing domestic violence, and ethics. However, we reviewed a list of the types of courses provided and noted that only one of the training centers offers any classes specifically related to meth (the institute in Colorado offers classes on identifying and handling clandestine meth laboratories). Because the meth problem appears to be growing in the United States and not all interested parties can attend the COPS meth conferences, we believe that the COPS Office should examine the possibility of encouraging the COPS-funded training centers to provide additional meth-related coursework.
COPS Office staff stated that the Grant Monitoring Division was created in 1998 to perform site visits and review the activities of COPS grantees. According to the COPS Office, the Grant Monitoring Division selected grantees for on-site visits by focusing on dollar amount, as well as grantees who were not previously reviewed, grantees having multiple grants, and grantees with compliance issues. Meth awards were not the focus during the selection process.
After the COPS Grant Monitoring Division chose the sites, the individual grant monitors notified the grantee and requested that the grantee have grant documents ready for review. When conducting the reviews, the Grant Monitoring Division staff were to be on-site 1 to 3 days and examine the grantee’s progress toward grant objectives and compliance with regulations, laws, and conditions of the grants. According to the Monitoring Operations Manual, the monitors were mainly concerned with retention of officers, community policing, redeployment, support for expenses, and programmatic and financial reporting.16 If the grantee has a Meth Initiative grant, the Monitoring Division instructs the grantee to make photocopies of all supporting documentation for the expenses claimed under the grant, performs a cursory review of the documents, and then forwards the total package to the Meth Team. Following the completion of the review, the Meth Team is responsible for all required follow-up related to the Meth Initiative grants.
We found that since FY 1998, only 9 of the 179 Meth Initiative grantees have received an on-site review by the COPS Office. In addition, the reports for the nine grantees that received on-site reviews were limited in nature and did not contain much detailed information regarding the Meth Initiative grants. The reports generally listed grant number, period covered, award amount, objectives, dollars approved by budget category, and a comments section. Also, the reports usually asked the following three “yes” or “no” questions: (a) Was the grantee pursuing at least one of the noted activities? (b) Were crime scene and analysis activities consistent with the application? and (c) Was the grantee delinquent in filing financial reports? A Grant Monitoring Division supervisor stated that while past reviews were cursory in nature, the COPS Office is currently in the process of developing a more in-depth monitoring strategy.
Subsequent to our field work, we were provided with six reports from site visits to Meth Initiative grantees that were conducted by the Meth Team. Three of these site visits were conducted during FY 2000; the remaining three were performed during FY 2002. We reviewed the reports and noted that they were more program-oriented, and one-half of the reviews included information about non-meth related grants. The reports provided a general overview of the Meth Team’s visit and the FY 2002 reports included a discussion on how the grantees’ community policing efforts had been enhanced due to the meth funding. The Meth Team generally conducted the reviews over a 1- or 2-day period and reported on the grantees’ progress toward grant objectives. Based on our review of the reports, it appears that a detailed financial review of grant expenditures was not performed.
We believe that proactive on‑site monitoring identifies grant management deficiencies and provides an early intervention opportunity for entities that may not be complying with grant requirements or struggling to achieve the grant objectives. Considering that about 8 percent of Meth Initiative grantees have received a COPS Office on-site review, we believe that the COPS Office could improve its efforts to monitor these grantees.
The 1999, 2001, and 2002 Meth Grant Manuals required grantees to make final drawdowns and provide final grant Program Progress Reports and Financial Status Reports (FSRs) within 90 days of the award end date. The 2005 Meth Grant Manual contained similar language. The OJP Financial Guide also requires these final reports. COPS officials informed us that during the closeout process, COPS Meth Team members were to complete checklists to ensure that there were no open issues with the COPS Monitoring or Legal Divisions and that there were no other administrative issues with the grant. The closeout process also required the COPS Finance Staff to document on the checklist that the grantee had submitted the final FSR and to deobligate any unspent funds. The COPS Office’s grant files were then to be marked “closed” and the COPS Office was to notify the grantee by letter that the grant was officially closed.
At the outset of our review, we reviewed the files of the 267 Meth grants awarded between FYs 1998 and 2004 and found that the COPS Office had only closed 36 of the 72 grants (50 percent) eligible for closure. The remaining 36 expired grants were, on average, about 26 months past the award end date. We determined that as of March 2005, 16 of the 36 open expired grants had $824,517 in funding that grantees had not utilized and the COPS Office should have deobligated; the remaining grants had no unspent funds.
We also noted that 2 of the 16 open, expired grants with funds on hand were to entities receiving Meth Initiative awards under the Small Rural Community discretionary grant program and had never utilized the awards. Specifically, the COPS Office verified that the Montgomery County, Kansas, Sheriff’s Department never submitted an award acceptance document for its $222,222 grant, which COPS awarded in FY 2002. COPS also verified that the Creek County, Oklahoma, Sheriff’s Department submitted a letter to the COPS Office stating that it was withdrawing, as of June 15, 2005, from its FY 2002 Meth Initiative award of $222,222.
In November 2005 COPS officials informed us that they had taken action on 8 of the 16 expired awards with funds remaining on hand. Specifically, the COPS Office deobligated $324,149 from five of the expired grants. As a result, we have calculated $500,368 as the balance of monies not deobligated ($824,517 - $324,149) in 11 awards.17 In addition, they informed us that they had subsequently paid out funds totaling $158,323 in three awards. According to the Meth Team leader, $153,869 of the $158,323 was paid out to two grantees after the grantees were approved no-cost extensions. The COPS Office could not provide us with a reasonable explanation as to why the third grantee was permitted to draw down the remaining balance of $4,454. In our opinion, retroactive no-cost extensions made years after a grant has expired is not a fiscally responsible practice.
The lack of prompt closure and deobligation of funds prevents the COPS Office from making these funds available to other grantees or returning it to the U.S. Treasury. The failure to close grants promptly also affects the grantees. DOJ Guidelines require grantees to retain records for a minimum of 3 years after the end of the grant. Further, the 2002 Meth Grant Manual, Chapter IV, requires grantees to retain records for 3 years after the COPS Office notifies the grantee that the grant is officially closed. If the grantee is complying with these requirements and grants are not closed in a timely manner, grantees must unnecessarily retain records for extended lengths of time. For example, if an FY 1998 grant expired in FY 2000 and the COPS Office had not formally closed it in FY 2005, the grantee would have kept records for up to 7 years and would be required to keep them for at least 3 additional years.
The COPS Office does not have a written policy mandating prompt closure of grants past their end dates. Additionally, COPS officials stated that closing grants was not an agency priority until FY 2002. They added that the over the past 3 years the COPS Office has made a concerted effort to close expired grants, starting with the oldest awards. However, the COPS Office had not started addressing grants awarded in FY 1998, which was when COPS executed the first meth grants. In June 2005, the Meth Team leader told us that his team was currently reviewing Meth Initiative grants on a monthly basis to determine which ones the COPS Office should close.
The Office of Management and Budget Circular A‑123, entitled “Management Accountability and Control,” provides guidance to federal managers on improving the accountability and effectiveness of federal programs and operations by establishing, assessing, correcting, and reporting on management controls. In addition, the Government Accountability Office has stated that “all personnel need to possess and maintain a level of competence that allows them to accomplish their assigned duties, as well as understand the importance of developing and implementing good internal control. Management needs to identify appropriate knowledge and skills needed for various jobs and provide needed training, as well as candid and constructive counseling, and performance appraisals.”18
The former Meth Team leader stated that the principal means of training grant program specialists on the Meth Team was to assign new employees to a mentor and use on-the-job training. He added that many Meth Team members have taken grant management courses. However, we found that this training is not required, and the COPS Office has not identified any core courses new employees should take. Further, the COPS Office has not documented specific topics and areas that must be included in the on-the-job training provided to new Meth Team grant specialists.
This ad-hoc approach to the training of new staff relies heavily on the knowledge and competency levels of current staff. Mentors’ comprehension of various grant functions will vary depending on their own grant-administering experiences, which in turn will affect what they teach and how much detail they provide. As a result, the information passed on to new staff may be inconsistent and could be inaccurate. We believe that the COPS Office should develop a written description of the duties and responsibilities of Meth Team members and establish guidance for the training of these individuals.
We identified significant weaknesses in the COPS Office’s management and administration of grants awarded under the Meth Initiative. Specifically, four separate entities were awarding and monitoring Meth Initiative grants with no overall coordination among them. We also found that the COPS Office did not have readily available information on the universe of Meth Initiative grantees because its IT system lacked basic controls over data accuracy and consistency. Further, the COPS Office should improve system security to ensure that write-access to its grant database is limited to those with clear need and that access for former employees is discontinued in a timely manner.
In addition, our audit revealed significant deficiencies in the COPS Office’s oversight of Meth Initiative grants. We identified differences in the guidance and oversight provided by the various grant specialists responsible for the grants. Further, formal guidance issued by the COPS Office has been inconsistent and contradictory. As a result, the COPS Office has held different grantees to different standards, and some grantees have been allowed to use Meth Initiative funds for items generally prohibited by the Meth Grant Manuals.
Moreover, the COPS Office has not proactively worked to close expired meth awards. This practice has resulted in our identification of $365,639 in funds put to better use in expired grants.19 Finally, COPS should develop a written description of the duties and responsibilities of Meth Team members and establish guidance for the training of these individuals.
We recommend that the COPS Office:
As part of our review, the OIG reviewed 44 grants totaling approximately $56 million that the COPS Office awarded between FYs 1998 and 2004 to 13 grantees under the Meth Initiative.20 Our audits encompassed 16 percent of the number of Meth Initiative awards and 26 percent of the total funds awarded by the COPS Office under the program. The OIG conducted these audits to test whether the grantees complied with requirements regarding grantee financial reporting, grant drawdowns, and budget management and control. We also determined whether costs charged to the grant were allowable, supported, and in accordance with applicable regulations, guidelines, and terms and conditions of the grants. Primarily, the criteria we audited against was the guidance provided in the COPS Meth Grant Manuals, OMB Circulars, and the OJP Financial Guide.
The audits revealed a total of $9,806,053 in dollar-related findings that included $9,523,622 in questioned costs and $282,431 in funds put to better use.21 Further, our review of awards revealed numerous deficiencies pertaining to internal controls, compliance, and the ability of grantees to realize a variety of program objectives. Appendix VI provides a detailed breakdown of our audit report findings by grantee. The following table summarizes the grantees audited, the amount awarded, and the dollar-related findings.22
SUMMARY OF OIG GRANT REPORTS
The OJP Financial Guide requires that grantees obtain prior approval from the awarding agency if the transfer of funds between budget categories exceeds 10 percent of the total amount awarded. These changes may be within a budget category, such as personnel, as well as between budget categories, such as personnel and equipment. Our audits revealed that 3 of 13 grantees (Kansas Bureau of Investigation; Oklahoma State Bureau of Investigation; and the Sioux City, Iowa, Police Department) did not properly monitor expenditures by budget category and exceeded the 10-percent limitation without prior approval from the COPS Office. The failure of these grantees to obtain prior approval for budget deviations in excess of 10 percent of the grant award resulted in $1,240,042 in questioned costs ($46,451, $692,414, and $501,177, respectively).
In addition, we could not properly assess budget deviations in two instances (Mississippi Bureau of Narcotics and Arkansas State Police) because the grantee lacked adequate supporting documentation to account for grant expenditures.
The remaining eight grantees (Alabama Department of Public Safety; California Department of Justice; Indiana State Police; Marion County, Oregon, Sheriff’s Office; Pierce County, Washington, Alliance; Prairie View Prevention Services of South Dakota; Vermont State Police; and Virginia State Police) generally were in compliance with the regulations regarding budget deviations.
According to the OMB Circular A‑87, entitled “Cost Principles for State, Local, and Indian Tribal Governments,” grantees are only allowed reimbursement for those costs that are reasonable in nature and permissible under the specific guidance of the grant. Further, the allowability of costs is discussed in the 1999, 2001, and 2002 Meth Grant Manuals and the OJP Financial Guide. For each of the audited grants, we determined whether costs charged to the program were allowable and in accordance with applicable regulations, guidelines, and terms and conditions of the grants. According to the Meth Grant Manuals, allowable costs include only approved salaries, overtime, and fringe benefits for support personnel and approved overtime for sworn law enforcement officers; equipment and technology purchases; training; and travel.23
Our audits revealed almost $8.3 million in grant expenditures that were either unsupported or unallowable.24 The bulk of these exceptions were due to grant expenditures for which the grantee did not have adequate support, unallowable charges for salaries and equipment, and excess drawdowns. Appendix VI contains a detailed breakdown of our questioned costs. Examples of the grant expenditures that we questioned are as follows:
Our audits also identified several instances, totaling $282,431, in which the grantees did not use the totality of their grant funds, and we recommended that these funds be deobligated.25
The Meth Grant Manuals state that grantees are to submit two types of reports to the COPS Office: Financial Status Reports (FSRs) and program progress reports. In each of the individual grant audits, we determined if the grantee was in compliance with financial and program progress reporting requirements.
Financial Status Reports (FSRs) provide information on grant funds spent and unobligated amounts remaining on hand. The reports are due within 45 days of the end of each calendar quarter. Six grantees (the California Department of Justice; Kansas Bureau of Investigation; the Mississippi Bureau of Narcotics; the Oklahoma State Bureau of Investigation; the Pierce County, Washington, Alliance; and the Virginia State Police) submitted all of the required FSRs in a timely manner. However, our audits revealed that 7 of 13 grantees did not submit a total of 11 required financial reports and submitted a total of 30 reports late. The following table identifies, by grantee, the total number of required FSRs, the number of reports submitted in a timely manner, and the exceptions noted.
FINANCIAL STATUS REPORT DEFICIENCIES
Program progress reports are intended to describe the information relevant to the performance of the grant objectives in a narrative fashion. Program progress reports provide information on the status of funded activities and the purchase and installation of equipment and technology. The Meth Grant Manuals state “Program progress reports will be distributed on a periodic basis throughout the grant period.”26
Eight grantees (the California Department of Justice; the Kansas Bureau of Investigation; Marion County, Oregon, Sheriff’s Office; the Mississippi Bureau of Narcotics; the Pierce County, Washington, Alliance; the Sioux City, Iowa, Police Department; the Virginia State Police; and the Vermont State Police) filed their requested reports in a timely fashion. In addition, our audits revealed that 5 of 13 grantees either submitted reports late or did not submit a report as requested. The following table identifies, by grantee, the total number of requested reports, number submitted in a timely manner, and the number and type of exceptions noted.
PROGRAM PROGRESS REPORT DEFICIENCIES
Our audits of the 13 grantees’ activities identified various internal control weaknesses. These weaknesses included weak controls over accounting systems and financial records, poor inventory controls, and non-compliance with OMB Circular A‑133 single audit requirements, as summarized below.
The OJP Financial Guide states that grantees are required to establish and maintain an accounting system and financial records to accurately account for funds awarded to them. The Meth Grant Manuals state that accounting systems and financial records must reflect expenditures for each project separately. In addition to the grant requirements related to the accounting system, the OJP Financial Guide requires grant recipients to establish and maintain an adequate system of internal controls. Effective internal controls help to ensure the reliability of financial reports as well as compliance with applicable laws and regulations. However, our audits revealed that three grantees did not maintain adequate controls over their accounting system and financial records. Specifically:
Pursuant to OMB Circular A-87 grantees must maintain property records for equipment with a value in excess of $5,000. Further, the OJP Financial Guide states that the records must contain the serial or identification number, acquisition date, and the cost and location of the property. In addition, the Guide states that a system of controls must exist to ensure safeguards to prevent loss, damage, and theft of the property and that inventories must be taken every 2 years and reconciled to property records. Moreover, Circular A‑87 states that the grantee should conduct a physical inventory at least once every 2 years to ensure the items exist and are in use. Our audits revealed weaknesses with the inventory controls for two grantees. Specifically:
OMB Circular A‑133 requires that grantees whose federal expenditures exceed $500,000 in a year obtain a single audit.27 In addition, Circular A-133 requires an audit of expenditures of federal awards and an audit of internal controls over compliance with the laws, regulations, contracts, and grants applicable to federal programs. In general, grantees obtained single audits as required. However, although Prairie View Prevention Service’s FY 2003 federal expenditures exceeded $300,000, the grantee did not have a single audit performed as required.28 According to the grantee, they did not know that they were required to comply with the provisions of Circular A‑133. However, we noted that the requirement was included in the grant assurances documents signed by Prairie View officials throughout the life of the grants awarded between FY 2001 and FY 2004.
The COPS Office funded all 13 audited grantees through the COPS Meth Initiative by way of earmarked funds. Some of the grantees also received discretionary grant awards. Each of the grantees submitted an application package that included the overall purpose of its project. In addition, the grantees established general objectives to guide their activities. However, 3 of the 13 audited grantees could not provide support that their awards met their objectives or adequately measured project outputs, outcomes, and milestones. The remaining 10 grantees provided support that showed they appeared to be meeting their individual grant award objectives. Specifically, we found that:
Our audit determined that the grantee tracked meth arrests and lab seizures through the statewide Criminal Justice Information Center system. However, the grantee failed to ensure that the law enforcement agencies it assisted provided information to the system as well. A state official told us that, as a result, meth incidents were grossly under-reported. In addition, the planned database implementation was halted due to a disagreement with the vendor and the storage containers program was not operational at the time of our review in May 2005.
We conducted individual grant audits of Meth Initiative grantees and found that in some cases essential grant requirements were not being met. Our audits examined over $56 million of the $214.1 million in COPS Meth Initiative grants awarded through FY 2004 and identified over $9.8 million in dollar-related findings (17.5 percent of the funds reviewed). In addition, we identified weaknesses related to progress and financial reporting and budget deviations.
In our judgment, the COPS Office is not adequately managing and administering the Meth Initiative. Grant monitoring is a critical management tool to ensure that grant programs are accomplished, grant objectives are achieved, and grantees are properly expending funds. We believe the COPS Office can do more to institute stronger oversight and ensure that the grantees adhere to regulations, guidelines, and terms and conditions of the grants. We are not offering any recommendations related to individual grant audits since the recommendations were included in the separate audit reports. However, recommendations related to the failure of the COPS Office to adequately administer the Meth Initiative are included in Finding 1.
More than $179 million of the $214.1 million of the COPS Meth Initiative funds has been designated as congressional earmarks. Generally, the congressional conference or committee reports that accompany the approved appropriations bill list the earmarked projects and identify the entity, a very general description of the project, and the amount allocated. The earmarking process does not require projects to be vetted for duplication, necessity, fiscal accountability, or any other factor normally reviewed by a granting agency through the solicitation and selection process.
For FYs 1998 through 2001, each of the congressional reports that identified the earmarked projects was preceded with an instruction that the conferees expected the COPS Office “to award grants for the following programs.” However, for FYs 2002 through 2005, each of the congressional reports that identified the earmarks included similar instructions about the actions to be taken in administering the program. The FY 2002 instruction stated the following:
Within the amounts provided, the Department is expected to review, in consultation with the DEA, the following proposals, provide grants if warranted, and report to the committees on its intentions….
We found that the COPS Office had not consulted with the DEA and was not reviewing the earmarked proposals to determine if grants were warranted. COPS officials told us they do not possess the same degree of control over earmarked funds that they do with discretionary grant funds. According to 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, 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.
We asked COPS Office personnel for a description of the steps that they take in awarding grants. We were told that when necessary, External Affairs had contacted congressional staff for further clarification on ambiguously worded appropriations language as to who the grantee actually should be, to ascertain what type of project was envisioned, or to clarify the purpose of the grant to be awarded. According to these individuals, following the passage of the annual appropriation, the COPS Office sends grant application materials to the earmarked entities with instructions to complete and submit an application for the appropriated funds. While the earmark within the congressional report generally contains only limited information, the application provides a more specific and detailed description of the project and how the entity intends to use its anticipated funding. According to COPS officials, upon receipt of the applications, the COPS Office reviews the submitted package to ensure that the amount requested is not more than the congressional allocation for the project. If the COPS Office determines that the proposed project contains a request for unallowable costs or is not related to meth or a drug hot spot, COPS officials are to follow up with the applicant to encourage the entity to refocus the proposal. In some instances the issues are brought before an earmark working group, which the COPS Office formally established in FY 2004.
A COPS official told us that the purpose of the earmark working group was to coordinate all of its earmark grants for meth and other programs and ensure that both the appropriations language and COPS office statutory and the programmatic goals, if applicable, are met. This group includes representatives from the Meth Team, and the Training and Technical Assistance, Finance, Legal, Monitoring, External Affairs, and the Program, Policy, Support and Evaluation Divisions. OJP, which administers some meth grants on behalf of COPS, is not a member of the working group. If a particular earmark is unique, or issues such as grant focus or requests for unallowable items cannot be reconciled easily, representatives can bring the issue up for discussion to the working group. The group gives guidance on how to resolve the issue or in some cases the Externals Affairs staff may contact the appropriate congressional staff to further discuss an issue.
According to COPS officials, each time that the External Affairs Division has become involved, the COPS Office ultimately awarded the grant in accordance with the submitted application or after refocusing the application. COPS officials also stated that since the program’s inception, no earmark grantee had been denied grant funding, and that the COPS Office works with a grantee to help them change the project scope and to identify allowable items that can be funded under the Meth Initiative.
The Meth Initiative grants to Sioux City, Iowa, provide an example of the interaction between the grantee, the COPS Office, and Congress. Every year since FY 1998 Congress has earmarked methamphetamine funds for a law enforcement training center located in Sioux City. We audited the Meth Initiative grants this entity received and found that the curriculum at the training center is not focused on meth or any other drug. At the time of our audit, we noted no classes focusing on hazardous waste disposal, environmental issues, truck searches, children who were exposed to meth lab sites, medical protocols, or meth case law. Rather, classes focused on enhancing general law enforcement skills, such as interviewing and self-defense. According to the responsible program manager, the COPS Office has questioned some of the training curriculum at the Sioux City site, and an official from the COPS External Affairs Division discussed the matter with the responsible congressional staff member and was informed that the proposed training curriculum, which was general and not focused on meth or drugs, was the type of training that the region needed. Consequently, the COPS Office awarded the Meth Initiative grant for the project.
OMB Circular A-11, Part 6, requires that strategic goals and objectives be quantitative, directly measurable, or assessment-based to allow for future evaluation of achievement. We found that the COPS Office has not developed an overall plan for strategically implementing the Meth Initiative and has not established specific goals for the overall program. In addition, the COPS Office has not identified other related efforts in the DOJ and has not determined how the COPS Office’s efforts fit in with the DOJ’s Plan. Officials in the COPS Office told us that they have not performed any strategic planning for the program because the Meth Initiative began as a congressional undertaking and the COPS Office has only minimal control over its execution.
Because of the lack of strategic planning, the COPS Office is unable to ensure that the objectives of individual grant applications will contribute to an overall effort for combating meth or other drugs. Consequently, awards under the Meth Initiative, particularly earmarked grants, have had widely differing approaches. One example is the previously mentioned law enforcement training center in Sioux City, Iowa, which has received over $10 million in Meth Initiative funding since the inception of the program to operate a general law enforcement training academy. Another example is the Vermont State Police, which utilized the majority of its $2.4 million in Meth Initiative funding for a multi-jurisdictional task force to combat heroin. Moreover, a non-profit organization in Hawaii received over $8.4 million in Meth Initiative funding for a variety of multi-drug related endeavors such as after-school programs, treatment services, law enforcement activities, and public awareness campaigns.
In sum, we believe that establishing measurable goals and objectives is a necessary prerequisite for ensuring that Meth Initiative funds will be used in the most effective and efficient manner to address the meth problem in America.
We reviewed the distribution of awards from the inception of the program in FY 1998 through FY 2004 and compared the level of funding to the number of meth-related incidents reported to EPIC over the same period. We found that although certain states with high numbers of reported meth incidents have received significant funding through the Meth Initiative, other states with similar levels of reported meth incidents have not received similar funding. Moreover, states with little to no reported meth seizures or arrests have received considerable resources through the Meth Initiative.
States where there is a high number of reported incidents, along with a high level of Meth Initiative funding for the period of FYs 1998 through 2004, include California, Iowa, Washington, Oklahoma, and Missouri. California, which ranked first in the nation with 13,377 laboratory seizures over the period reviewed, received over $76.9 million in Meth Initiative funding, placing it first in a ranking of states awarded funds. Also, Iowa was second with grant funding of almost $16.2 million and had 4,488 seizures, which ranked them fourth overall. Similarly, the state of Washington ranked third in reported seizures with 6,356 seizures. Washington also was third in a ranking of funds awarded and received more than $11.8 million in grants. Oklahoma ranked fifth in both lab seizures and funding with 4,403 reported incidents and received almost $6.9 million in grants. Missouri had the second largest number of reported lab seizures with 11,859 and ranked 10th in funds awarded with nearly $3.7 million.
However, there are imbalances in funding levels and reported incidents in other locations. For example, between FYs 1998 and 2004, Vermont reported only one lab seizure; however, the state has received almost $1.3 million in Meth Initiative funding. Likewise, Hawaii reported only 76 seizures for the 7‑year period, but received nearly $8.8 million in funding, ranking the state fourth in dollars received. Other examples of imbalances that we identified are Texas and Illinois. The state of Texas ranked 10th in the number of seizures with 2,924 and was awarded over $1.3 million, ranking it 23rd in the nation in funds received from the Meth Initiative. Illinois was ranked 11th in reported lab seizures with 2,833; however, the state ranked 25th in funds received over $1.3 million. A comparison of the funds awarded and the reported seizures appears in the following chart.30
According to COPS officials, the high proportion of earmarked funds in the $214.1 million they received through the Meth Initiative hampered their ability to ensure that funds go to the states that have the largest meth problem and thus provided the COPS Office with very little control over the program. The current approach has resulted in significant imbalances between the reported meth problem and the amount of money a location receives through the Meth Initiative. Moreover, we believe the current approach impairs the ability of the program as a whole to have a noticeable impact on meth or any other specific drug problem in the United States. However, a s noted on page 42, congressional guidance since FY 2002 has instructed the COPS Office to consult with the DEA on the earmarked projects and to grant funds only if warranted. Therefore, the COPS Office should be consulting with the DEA to help ensure that funds are awarded appropriately.
According to COPS officials and local law enforcement personnel interviewed, at the inception of the Meth Initiative in FY 1998, meth was mainly a problem in Western states. Officials indicated that the problem then spread throughout the Midwest and South and is now making inroads in the East. As evidenced by statistics reported to EPIC, in FY 1998, California reported the most laboratories seized with 1,921. Missouri was next with 322, and Oregon was third with 211. By FY 2004, the largest number of lab seizures had moved to the middle section of the country. At the end of FY 2004, Missouri had the most reported seizures with 2,784, followed by Iowa with 1,513, and Tennessee was third with 1,369. The following set of maps show the meth incidents reported to EPIC in FY 1998 and in FY 2004.31
In FY 1999, the COPS Office used discretionary monies to fund an evaluation of 6 of the 10 initial Meth Initiative awards.32 The resulting evaluation report presented an introduction to meth, its history, production methods, and its impact on people’s health and the environment. The report also included individual chapters for each of the six sites and described their implementation efforts, challenges, and successes. In addition, it contained general observations on community policing strategies used to help reduce meth abuse and focused on intervention, prevention, treatment, and trends. Finally, the report provided a series of recommendations on how grantees can successfully fight meth. However, the evaluators stated that several constraints, including funding, time, and data, prohibited them from examining the impact of the Meth Initiative. The former Meth Team leader was aware of the study, but did not know if the recommendations had been implemented.
The Meth Initiative is now in its eighth year of funding and at least 5 years have elapsed since the above-described initial evaluation of only a limited number of individual projects. However, the COPS Office has not performed or commissioned a full evaluation of the program as a whole. This lack of program review and evaluation, combined with the lack of established program goals and milestones, has resulted in the COPS Office being unable to gauge the effectiveness of the millions of dollars awarded under the Meth Initiative.
The COPS Office has information already available to it in quantitative and narrative form that COPS could use to help in evaluating the overall effectiveness of the program. For example, the COPS Office could periodically review the quantitative data that state and local law enforcement agencies report to EPIC. This approach could identify and track trends in meth and other drug-related crime. The COPS Office also could review grantees’ program progress reports to identify successful approaches and projects and disseminate this type of information to other grantees.33
Congressional earmarks have heavily influenced the Meth Initiative since its inception in 1998. However, the significant use of earmarks in this endeavor has not ensured that grant funds are directed to locations with the greatest need. Because the COPS Office has been reactive to the spending specifications of Congress, it has not been in the position to assert full control over the program, including the establishment of program goals and measurements. However, without a more strategic plan for the use of the significant funding available through this program, the COPS Office’s attempts to address the meth crisis likely will continue to yield variable results.
We recommend that the COPS Office:
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