Office Of Justice Programs Technical Assistance And Training Program

Audit Report No. 04-40
September 2004
Office of the Inspector General

Monitoring by the Office of the Comptroller The OC annually develops a risk-based monitoring plan that considers inherent programmatic and recipient risks.41 The OC applies the risk-based criteria to the universe of grants to develop a sample for each fiscal year’s monitoring plan. The reviews conducted include both on-site and in-house work. According to OJP officials, the purpose of the in-house reviews is to provide as much of a comprehensive financial review as possible without going on-site. The OC’s Monitoring Division is comprised of two branches that conduct financial monitoring of grantees, provide on-site technical assistance to grantees and program offices, conduct audit follow-up, and perform reviews of the OJP financial administration and controls. The Quality Review Branch (QRB) conducts internal OJP and external grantee audit follow-up. As the OJP’s Audit Liaison, the QRB coordinates Single Audit Act findings and recommendations on a Department wide basis. The QRB also: coordinates with the Office of Management and Budget (OMB) and other federal agencies in developing, modifying, and implementing government-wide audit-related rules and regulations; and, conducts internal quality control-based reviews to provide assurance that the OJP’s assets are safeguarded and its financial management system conforms to government-wide internal control requirements under the Federal Managers Financial Integrity Act and the Chief Financial Officers Act. The Monitoring Branch (MB) provides external financial oversight of award recipients’ financial operations through risk-based financial monitoring. The staff conducts nationwide on-site financial reviews of grantee organizations to assess financial systems and records, provides financial advice, and recommends changes in the grantee’s financial policies and procedures. The MB also performs in-house reviews of various program and financial documents contained in the official grant files. These reviews are conducted to ensure that the official grant file is complete and the grant application, review, and award processes were properly conducted. The collective results are then available for analysis to identify activities within the OJP that can be improved. The OC maintains the official grant files and is responsible for tracking the receipt of all grant documents. The OC receives the Progress Reports, files the original in the official grant file, and forwards a copy to the relevant bureau. The grant manager is responsible for the timely acceptance, review, and analysis of Progress Reports. Monitoring by the Bureaus and Program Offices The five bureaus and two program offices are also responsible for monitoring grantees and related activities, and documenting the results in the grant manager’s program files and the OC’s official grant files. The bureaus and program offices conduct monitoring to ensure: Compliance with relevant statutes, regulations, policies, and guidelines; Responsible oversight of awarded funds; Implementation of required programs, goals, objectives, tasks, products, timelines, and schedules; Identification of issues and problems that may impede grant implementation; and Adjustments required by the grantee as approved by the OJJDP and the BJA. The grant managers’ primary responsibility is project monitoring. Each grant manager prepares a monitoring plan or Grant Manager’s Memorandum (GMM). The GMM is an evolving document used throughout the life of a grant to ensure that goals and objectives are being met and that activities and products are completed in a timely fashion. The level of monitoring required is based upon the stated monitoring plan in the GMM, which includes: An overview of the project; A detailed description of what type of activities the grantee plans to implement; A discussion of past monitoring activities and assessments, if the grant is a multi-year grant that is awarded yearly; An identification of monitoring activities to be performed for the current project period; and A discussion of the financial justification for the grant funds and of the cost-effectiveness evaluation of the application. The OJP has given monitoring priority to sites in which problems have been identified, implementation has been problematic, or where the grantee has specifically requested technical or other assistance. In addition to on-site visits, grant managers conduct periodic desk reviews and monitor grants telephonically. Monitoring may also be conducted as part of conferences and cluster meetings with grantees. Telephonic and/or e-mail monitoring is done to communicate time-sensitive information, or when on-site visits are not feasible. The Grant Manager compiles a list of issues and familiarizes him or herself with the objectives of the grant. The Grant Manager then arranges a scheduling of calls to project and grantee staff to document and resolve issues and/or assess the implementation status of a project, according to stated objectives and time lines. Frequency of Monitoring Federal grant management entails both program management and financial management. For the TA&T grants that we reviewed, these responsibilities were split between the OC, which is responsible for financial management, and the respective bureaus, which are responsible for program management. According to the OJP grant managers whom we interviewed, all grants are monitored to "some degree." The number of times a grant manager conducts an on-site visit is determined by each bureau or program office and depends on problems encountered during the course of the grant, budget resources, and level of grant activity. The OJP’s past practice, however, has encouraged grant managers to conduct one monitoring visit per fiscal year, if time and resources permit, and to require quarterly telephone conversations and desk monitoring activities. Each grant manager establishes a monitoring schedule, which permits him or her to add issue-driven monitoring visits and technical assistance, if the need arises. The OJP management and grant managers stated that they attempt to identify projects that appear to need the most assistance (for example, grantees that have not previously received an OJP grant, and new planning grants) and prioritize travel schedules to include these sites. Footnotes Risk-based criteria include: grants with confidential funds; grants to Indian tribes; OJP discretionary grants of $1 million; new grantees with discretionary grants; Local Law Enforcement Block Grants; randomly sampled grants; and, one-third of the formula/block grants. The OC excludes from its sample any grantee organizations that were subject to its other on-site financial monitoring, or to audit by the OIG during the last two years.