Administration of Department of Justice Grants Awarded to
Native American and Alaska Native Tribal Governments

Audit Report 05-18
March 2005
Office of the Inspector General


Appendix II

Objectives, Scope, and Methodology


We reviewed the administration of DOJ grants awarded to tribal governments. Our audit included the COPS Office, OJP, and OVW.42 The objectives of the audit were to evaluate: 1) the adequacy of monitoring and administration of tribal-specific grant programs; 2) whether costs charged to the tribal-specific grants are allowable and in accordance with applicable laws, regulations, guidelines, and terms and conditions of the grants; and 3) the effectiveness of the DOJís overall strategy for awarding grants to tribal governments.

We conducted our audit in accordance with Government Auditing Standards. We included such tests as were necessary to accomplish the audit objectives. The audit generally covered, but is not limited to, tribal specific grants awarded during the period of FYs 2000 through 2003. Audit work was conducted at the COPS Office, OJP, and OVW, and selected tribal grantees.

To determine whether the COPS Office, OJP, and OVW were adequately monitoring their tribal-specific grant programs, we judgmentally selected a sample of tribal-specific grants in order to examine the grant files for compliance with reporting requirements and monitoring activities. For each grant selected, we reviewed the grant file to determine whether: 1) all required financial and progress reports were submitted, 2) financial and progress reports were submitted in a timely manner, 3) the granting agency followed-up with grantees to request missing and late financial and progress reports, 4) progress reports were annotated to document that the report was reviewed by the grant manager, 5) a monitoring plan was developed, 6) telephone monitoring was documented, 7) office-based desk reviews were conducted, and 8) on-site program monitoring visits were conducted. It should be noted that the COPS Office did not provide timely access to its grant monitoring files. After repeated requests the COPS Office finally provided its grant monitoring files; however, it was clear that the COPS Office had updated the files during the period that access was withheld from the OIG. Information that was added to the files included: 1) Issues Reports, 2) Site Visit Checklists, and 3) other information related to work that was conducted up to 2 years previously. This matter was addressed in a memorandum from the OIG to the COPS Office, dated March 3, 2004.

To determine whether the COPS Office, OJP, and OVW were ensuring that grant funds were made available to grantees in a timely manner, we compared the award start date to the date the grant funds were obligated as shown on the grant payment history to determine whether grant funds were being obligated within 6 months of the award start date. For a sample of tribal-specific grants for which funds were not obligated more than 6 months after the award start date, we requested: 1) copies of all documentation related to the grant budget from the initial budget review memorandum through the final financial clearance memorandum, 2) documentation supporting any issues that may have caused delays in obligating the grant funds, and 3) any explanation as to why the obligation of grant funds was delayed.

To determine whether the COPS Office, OJP, and OVW were monitoring the utilization of grant funds awarded to tribal governments, we analyzed the total payments for each tribal-specific grant as shown on the grant payment history in order to determine all tribal-specific grants for which no grant funds had been drawn down. For a sample of tribal-specific grants for which no grant funds had been drawn down within 1 year of the award start date, we requested all financial and progress reports for the tribal-specific grants to determine whether the grantees had reported financial or programmatic activity.

To determine whether the COPS Office, OJP, and OVW were monitoring the utilization of grant funds awarded to tribal governments, we compared the award start date to the date of the initial drawdown to determine the length of time between the date the grant funds were obligated and the date of the initial drawdown. For a sample of tribal-specific grants where the initial drawdown occurred 1 year from the date grant funds were obligated, we requested all financial and progress reports submitted prior to the initial drawdown to determine whether the grantees reported financial or programmatic activity prior to the initial drawdown.

Additionally, we compared the date of the last drawdown to the date of the grant payment history to determine the length of time between the date of the last drawdown and the date of our review. For a sample of tribal specific grants where the last drawdown occurred 1 year prior to our review, we requested all financial and progress reports submitted after the last drawdown to determine whether the grantee reported financial or programmatic activity since the last drawdown.

To determine whether grantees were drawing down funds in excess of grant expenditures, for a sample of grants we compared the most recent financial report to the grant payment history. For each grant with excess drawdowns, we reviewed the grant end date to determine if the grant had been expired. For all expired tribal-specific grants, we questioned the excess drawdown amount.

To determine the effectiveness of the COPS Office, OJP, and OVW closeout process for tribal-specific grant programs we requested a listing of grants that had been closed. We compared the listing of closed grants to expired grants to determine whether grants had been closed. For grants which had been closed, we reviewed the closeout date to determine whether the grant was closed within 6 months of the grant expiration. For a sample of tribal-specific grants where the grant had been expired for more than 6 months that had not been closed, we requested the final financial and progress report in order to determine whether the final reports had been submitted.

To determine whether the COPS Office, OJP, and OVW allowed tribal grantees to draw down funds more than 90 days past the grant end date, we compared the grant end date with the date of the last drawdown as reported on the grant payment history. For all tribal-specific grants where the date of the last drawdown was made after the grant end date, we reviewed the grant payment history to determine the number of grant drawdowns made and the amount of those drawdowns. We questioned all grant drawdowns occurring more than 90 days after the grant end date.

To determine whether any grant funds remained on expired tribal specific grants administered by the COPS Office, OJP, and OVW, we compared the grant end date with the date of the grant payment history to determine all tribal-specific grants that had been expired for more than 90 days. For all expired tribal-specific grants more than 90 days past the grant end, we reviewed the grant payment history to determine the amount of remaining grant funds. We recommended that all remaining tribal-specific grant funds be deobligated and be put to better use.

We also conducted external audits of the grantees and grants shown in the following chart.

MISSISSIPPI BAND OF CHOCTAW INDIANS, PHILADELPHIA, MISSISSIPPI
  • Correctional Facilities on Tribal Lands Program, Grant No. 1999IPVX0001
  • Tribal Victims Assistance Program, Grant No. 1999VRGX0011
  • Tribal Youth Program, Grant No. 2001TYFX0038
  • S•T•O•P Violence Against Indian Women Program, Grant No. 97WIVX0024
EASTERN BAND OF CHEROKEE INDIANS, CHEROKEE, NORTH CAROLINA
  • Tribal Youth Program, Grant No. 2000TYFX0030
  • Tribal Youth Program, Grant No. 2002TYFX0069
  • S•T•O•P Violence Against Indian Women Program, Grant No. 1997WIVX0028
WHITE EARTH RESERVATION TRIBAL COUNCIL, WHITE EARTH, MINNESOTA
  • Tribal Hiring Renewal Grant Program, Grant No. 2003HRWX0005
  • Tribal Resource Grant Program - Equipment, Grant No. 2000HEWX0041
  • Tribal Resource Grant Program - Equipment, Grant No. 2002HEWX0043
  • Tribal Resource Grant Program - Hiring, Grant No. 2000HHWX0019
SAULT STE. MARIE TRIBE OF CHIPPEWA INDIANS, SAULT STE. MARIE, MICHIGAN
  • Correctional Facilities on Tribal Lands Program, Grant No. 2001IPBX0004
  • Tribal Victim Assistance Program, Grant No. 1999VRGX0006
  • Drug Court Program, Grant No. 2000DCVX0111
  • Tribal Courts Assistance Program, Grant No. 2002ICBX0027
  • Tribal Youth Program, Grant No. 2001TYFX0047
  • S•T•O•P Violence Against Indian Women Program, Grant No. 1996WINX0010
ChocTaw Nation Law Enforcement, Durant, Oklahoma
  • Tribal Resource Grant Program - Equipment, Grant No. 1999HEWX0120
  • Tribal Resource Grant Program - Equipment, Grant No. 2001HEWX0078
  • Tribal Resource Grant Program - Equipment, Grant No. 2003HEWX0084
  • Tribal Resource Grant Program - Equipment, Grant No. 2002HEWX0079
  • Tribal Resource Grant Program - Equipment, Grant No. 2000HEWX0077
  • Tribal Resource Grant Program - Hiring, Grant No. 2002HHWX0032
CHICKASAW NATION, ADA, OKLAHOMA
  • Tribal Courts Assistance Program, Grant No. 2002ICBX0011
  • Tribal Youth Program, Grant No. 2001TYFX0007
  • S•T•O•P Violence Against Indian Women Program, Grant No. 1996WINX0042
ST. REGIS MOHAWK TRIBE, AKWESASNE, NEW YORK
  • Tribal Resource Grant Program - Equipment, Grant No. 2003HEWX0021
  • Tribal Resource Grant Program - Equipment, Grant No. 2002HEWX0072
  • Tribal Hiring Renewal Grant Program, Grant No. 2001HRWX0001
  • Tribal Resource Grant Program - Equipment, Grant No. 2001HEWX0074
  • Tribal Resource Grant Program - Equipment, Grant No. 2000HEWX0069
COLUMBIA RIVER INTER-TRIBAL FISHERIES ENFORCEMENT, HOOD RIVER, OREGON
  • Tribal Resource Grant Program - Equipment, Grant No. 1999HEWX0126
  • Tribal Resource Grant Program - Equipment, Grant No. 2000HEWX0079
  • Tribal Resource Grant Program - Equipment, Grant No. 2001HEWX0084
  • Tribal Resource Grant Program - Equipment, Grant No. 2002HEWX0087
LUMMI INDIAN NATION, BELLINGHAM, WASHINGTON
  • Tribal Victim Assistance Program, Grant No. 2001VRGX0001
  • Tribal Victim Assistance Program, Grant No.1999VRGX0012
  • Childrenís Justice Act Partnerships for Indian Communities Program, Grant No. 2001VIGX0002
  • Drug Court Program, Grant No. 2002DCBX0066
  • Tribal Courts Assistance Program, Grant No. 2002ICBX0019
  • Tribal Youth Program, Grant No. 2002TYFX0004
  • S•T•O•P Violence Against Indian Women Program, Grant No. 1996WINX0007
PASSAMAQUODDY TRIBE AND PLEASANT POINT RESERVATION, PERRY, MAINE
  • Tribal Resource Grant Program - Hiring, Grant No. 1999HHWX0018
  • Tribal Resource Grant Program - Equipment, Grant No. 1999HEWX0018
  • Tribal Resource Grant Program - Equipment, Grant No. 2000HEWX0033
  • Tribal Resource Grant Program - Equipment, Grant No. 2003HEWX0116
  • Tribal Resource Grant Program - Equipment, Grant No. 2002HEWX0030
  • Tribal Resource Grant Program - Hiring, Grant No. 2003HHWX0040
  • Tribal Resource Grant Program - Hiring, Grant No. 2002HHWX0013
BLACKFEET TRIBAL BUSINESS COUNCIL, BROWNING, MONTANA
  • Tribal Resource Grant Program - Hiring, Grant No. 1999HHWX0025
  • Tribal Resource Grant Program - Equipment, Grant No. 1999HEWX0025
  • Tribal Resource Grant Program - Hiring, Grant No. 2000HHWX0031
  • Tribal Resource Grant Program - Equipment, Grant No. 2000HEWX0071
  • Tribal Resource Grant Program - Equipment, Grant No. 2001HEWX0059
  • COPS In Schools, Grant No. 2002SHWX0671
BLACKFEET FISH AND WILDLIFE DEPARTMENT, BROWNING, MONTANA
  • Tribal Resource Grant Program - Hiring, Grant No. 2002HHWX0021
  • Tribal Resource Grant Program - Equipment, Grant No. 2002HEWZ0051
NAVAJO NATION DIVISION OF PUBLIC SAFETY, WINDOW ROCK, ARIZONA
  • Tribal Resource Grant Program - Equipment , Grant No. 1999HEWX0076
  • Tribal Resource Grant Program - Equipment, Grant No. 2000HEWX0011
  • Tribal Resource Grant Program - Equipment, Grant No. 2001HEWX0015
  • Tribal Resource Grant Program - Equipment, Grant No. 2002HEWX0008
NAVAJO NATION DEPARTMENT OF RESOURCE ENFORCEMENT, WINDOW ROCK, ARIZONA
  • Tribal Resource Grant Program - Hiring, Grant No. 2002HHWX0010
  • Tribal Resource Grant Program - Hiring, Grant No. 2003HHWX0021
  • Tribal Resource Grant Program - Equipment, Grant No. 2002HEWX0016
  • Tribal Resource Grant Program - Equipment, Grant No. 2003HEWX0043
OGLALA SIOUX TRIBE, PINE RIDGE, SOUTH DAKOTA
  • Tribal Youth Program, Grant No. 2002TYFX0002
  • Correctional Facilities on Tribal Lands Program, Grant No. 2002IPBX0002
  • Tribal Victim Assistance Program, Grant No. 2002VRGX0011
  • S•T•O•P Violence Against Indian Women Program, Grant No. 95WINX0007

For each of these audits listed above, we assessed compliance with the critical grant requirements to ensure that costs charged to the grant programs were allowable and in accordance with applicable laws, regulations, guidelines, and terms and conditions of the grants. Additionally, we interviewed tribal officials to determine any concerns regarding the DOJís current funding strategy meeting their short term and long term criminal justice needs.

Finally, to determine the effectiveness of the DOJís overall strategy for awarding grants to tribal governments and the extent to which the DOJ components coordinate and share information about program activities, we interviewed program officials from the COPS Office, OJP, including the AI/AN Affairs Desk, OVW, and OTJ.


Footnotes

  1. Under a provision in the 2002 Justice Department reauthorization bill, passed in October 2002, OVW became a permanent, separate and independent office within the DOJ.



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