We audit primarily on the basis of criteria that COPS has developed to ensure that essential grant conditions are met. Grant requirements are contained in an "Owners Manual" for each type of COPS hiring and redeployment grant. The applicable manuals are provided to each grantee receiving a grant and are also posted on the COPS' internet site. We group COPS criteria into the following categories:

COPS grant funds must not be used to replace funds that eligible agencies otherwise would have devoted to future officer hiring. In other words, any hiring under the COPS program must be in addition to, and not in lieu of, previous hiring plans.

COPS guidelines require that grantees continue to hire as many new, locally-funded officers as it would have absent receipt of the grant. Grantees must also take positive and timely steps to fill any vacancies created on or after the grant award. Failure to hire the required number of officers is a potential indicator of supplanting. By way of example, the following practices would likely be regarded as supplanting:

  1. A department with vacant positions at the start of the grant period, or at any time thereafter, hires no new officers other than COPS grant-funded hires.

  2. No timely hiring, other than COPS-grant funded hiring, is done by a department to replace vacancies created by attrition existing at or after the beginning of the grant period.

  3. Grant funds are used to replace, or to allow the reallocation of, funds already committed in a local budget for law enforcement purposes.

Grant recipients are required to complete and submit an Annual Department Report updating the information reported in the Initial Report. The Annual Department Report should demonstrate whether the grantees decreased the number of locally funded positions after receiving the COPS grants. By reviewing these reports, COPS can identify potential supplanting issues needing further study. In addition, recipients are required to submit a Hiring Officer Progress Report that solicits specific information pertaining to the officers hired under the COPS Hiring grants. Information gathered includes demographic information on the officers, duties and responsibilities of the officers, and dates of key events (such as date of hire, graduation from academy and when training began and concluded). Recipients of MORE redeployment grants must submit the MORE Annual Progress Report that requires the grantee to provide information about the increased levels of community policing that have resulted from the purchase of equipment and/or the hiring of civilian personnel funded under the COPS MORE grant program.


Our findings and recommendations for all grant audit reports issued between October 1, 1996, and September 30, 1998, are presented in Appendix I. During this period, we issued 149 audit reports of grantees that were awarded $511 million. This amount represents about 10 percent of the funds COPS has obligated for the program. We grouped our findings and recommendations by category as well as the size or type of grantee. Because all issues were not of the same magnitude, we color-coded each issue to show whether, in our judgment, it was serious, moderate, or minor. Where appropriate, we also quantify our results and categorize them as either "questioned costs" or "funds to better use."(12)

For the 149 grant audits, we identified about $52 million in questioned costs and about $71 million in funds that could be better used. Our dollar-related findings amount to 24 percent of the total funds awarded to the 149 grantees. The following are examples of when we would question costs or recommend funds to better use.

In considering our COPS audit results, it should be kept in mind that they:

  1. Are as of the grant report's issuance date (See Appendix II for the dates each report was issued). Subsequent communication between the auditee and COPS/OJP may result in correction to, or elimination of, the issue we noted during our audit; and

  2. May well not be representative of the overall universe of grantees because, as a matter of policy, COPS has referred to us for review what it believes to be its riskiest grantees.(13) During FY 1998, we began supplementing COPS requests for audits by selecting about one-half of the grantees ourselves. Our results to date, however, may still be skewed because of the number of audits conducted on COPS-requested grantees and because our selections were not entirely random. Some of our audits were also intended to reach suspected problem grantees.(14) Also note that COPS and OJP do not always agree with our findings and recommendations. Upon further review and follow-up, COPS and/or OJP may conclude that, in their judgment, a grant violation did not occur.(15)

Notwithstanding the above, our results indicate that significant numbers of jurisdictions that we audited are: (1) overestimating officer salaries and benefits in their initial requests for funding or including unallowable costs in reimbursement requests; (2) not documenting efforts to redeploy officers to community policing; (3) using federal funds to supplant local funds; (4) not making a good-faith effort to fill locally-funded sworn officer positions; (5) not submitting or submitting late status reports to COPS and OJP; and (6) not fully implementing community policing. Additionally, we are concerned that some jurisdictions may have difficulty retaining COPS officer positions with local funds at the conclusion of the grants.

The following weaknesses appear to cut across all types of grantees that we audited regardless of size or location.(16)


After we issue our grant reports, COPS, OJP, and the grantee are responsible for ensuring that corrective action is taken. By agreement with COPS, OJP is our primary point-of-contact on follow-up activity for the grants, although COPS works with OJP to address our audit findings and recommendations, particularly those that indicate supplanting has occurred.

The options available to COPS and OJP to resolve our dollar-related findings and recommendations include: (1) collection or offset of funds, (2) withholding funds from grantees, (3) bringing the grantee into compliance with grant terms, or (4) concluding that our recommendations could not or should not be implemented. To address our non dollar-related findings and recommendations, COPS and OJP can, in addition to other options, bring the grantee into compliance with grant requirements or waive certain grant requirements. When OJP submits documentation to us showing that it has addressed our recommendations, the audit report is closed.


As stated previously, our universe of grantees was not selected randomly. Indeed, COPS has referred to us many of the audits we have conducted because it believed the grantees may be problematic. We credit COPS with this proactive approach to grant management. Nonetheless, the frequency and magnitude of issues identified in our grant audits conducted through September 30, 1998, indicate that significant numbers of jurisdictions that we audited are: (1) overestimating salaries and benefits or including unallowable costs in reimbursement requests; (2) using federal funds to supplant local funds; (3) not making a good-faith effort to fill locally-funded sworn officer positions; (4) not submitting or submitting late status reports to COPS and OJP; and (5) not fully implementing community policing.

In addition to the above, we have significant concerns in the areas of officer retention and redeployment.

In addition to continuing with our audits of grantees as resources permit, we are currently performing a comprehensive program audit of COPS' and OJP's administration of the overall $8.8 billion Community Policing Grant Program. In addition to expanding upon the issues contained in this report, we will report on: (1) COPS' ability to meet the President's goal to put 100,000 additional police officers on the street by 2000, (2) COPS and OJP's monitoring efforts over grantees, and (3) the quality of guidance provided to grantees to assist them in implementing essential grant requirements. We expect to issue the program audit report later this year.

11 COPS retention requirements have evolved. According to COPS, the PHS and Phase I grants did not formally require retention. The COPS AHEAD, FAST, UHP, and all MORE grants required applicants to plan in "good-faith" for continuation of the program following the conclusion of federal support; however, the retention period was not specified. In our judgment, however, the intent of the overall program appears to be that all officer positions should be retained. In August 1998, COPS established a policy that grantees are only required to maintain the COPS funded officer positions for a minimum of "one budget cycle" after the budget cycle in which COPS funding ends, (i.e. usually one additional year).

12 The Inspector General Act of 1988 contains relevant reporting requirements for questioned costs and funds to better use. However, not all of our findings and recommendations are dollar-related. Questioned costs are monies spent that, at the time of the audit, do not comply with legal requirements, or are unsupported, or are unnecessary or unreasonable. They can be recoverable or unrecoverable. Funds to better use are future funds that could be used more efficiently if management took actions to implement and complete audit recommendations. See Appendix II for the detail of dollar findings by grantee.

13 Of the 149 audits we performed through September 30, 1998, 103 were referred to us by COPS or OJP.

14 It should be noted that although we selected only 46 of the 149 audits summarized in this report ourselves, our results to date do not differ markedly from the results in the COPS/OJP referred audits.

15 See Section H for options available to COPS and OJP for addressing our audit report findings and recommendations during report follow-up.

16We did not test each attribute for all grantees because several of our audits were either limited scope special requests or the test was not applicable because of the type of grant being audited. Therefore, our universe of potential weaknesses was not always 149 audits.

17 The numbers in parentheses exceed 60 because several grantees had multiple findings relating to supplanting.

18 Because COPS grant criteria on retention has been vague (see footnote 11), we applied the following test for retention. We reviewed documentation, when available, and asked grantees what efforts they had made to retain the positions. If we concluded the grantee was not making a good-faith effort to retain the officer positions, we made recommendations to develop a written retention plan although it was not always a formal grant requirement.

19 COPS counts 1,824 hours in time savings as the equivalent of one full-time officer redeployed to community policing.