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| MEMORANDUM TO: |
Guy K. Zimmerman
Assistant Inspector General for Audit
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| FROM: |
Tracy A. Henke
Acting Assistant Attorney General
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| SUBJECT: |
Draft Audit Report on the Administration of Department of Justice Grants Awarded to Native American and Alaska Native Tribal Governments |
This memorandum responds to report recommendations directed to the Office of Justice Programs (OJP) for action, included in the Office of the Inspector General's ("OIG's") draft audit report entitled "Administration of Department of Justice Grants Awarded to Native American and Alaska Native Tribal Governments." The draft report contains 53 recommendations and $6.9 million in questioned costs; however, only Recommendations 6 through 9, 19 through 26, 41 through 45, 52 and 53 are applicable to OJP.
For ease of review, the 18 recommendations included in the draft report are restated in bold, followed by our response to the recommendation. In some cases, the recommendations were grouped together as our responses to those recommendations were similar.
- Ensure that monitoring plans are developed for each grantee that includes a risk assessment of each grantee based on past performance and compliance with grant requirements to determine the timing and frequency of office-based and on-site monitoring.
- Ensure that required financial and progress reports are submitted in a timely manner.
- Ensure that grant managers follow up with grantees if required financial and progress reports are not submitted or are not submitted in a timely manner.
We agree with the recommendations. The Office of Justice Programs is in the process of revising its Grant Manager's Manual (Manual), which details OJP's standard procedures for grant administration. We will incorporate appropriate procedures in the Manual to ensure that risk-based monitoring plans are developed for each grantee, grantees timely submit required financial and progress reports, and grant managers follow up with grantees when reports are not submitted timely. To enhance grant monitoring efforts, OJP encourages grant recipients to use the Grant Management System (GMS) to submit semi-annual progress reports and the web-based SF-269 System to submit Financial Status Reports. Online submission of these reports will streamline the reporting process for grantees and the monitoring process for grant managers.
The Bureau of Justice Assistance's (BJA's) specific monitoring guidelines are detailed in their Monitoring Guide. BJA requires all grant managers to conduct semi-annual desk reviews for each grantee. The desk reviews include a risk assessment based on award amount, prior monitoring, past performance, and compliance. The desk reviews assist the grant managers in determining the level of monitoring necessary for that particular grant. Monitoring plans are developed post award based on the desk reviews. The monitoring plans include the grant programs that will be visited on site.
The Office for Victims of Crime (OVC) is in the process of developing new and updated monitoring procedures for Indian country grants and training grant managers in the use of the procedures. The updated procedures will be used to ensure that appropriate monitoring plans are developed for each grantee. The updated procedures will be developed and implemented by April 2005.
The Office of Juvenile Justice and Delinquency Prevention (OJJDP) will develop monitoring procedures that will include an assessment instrument that will be used to evaluate compliance with grant requirements and determine the timing and frequency of office-based and on-site monitoring. The new procedures will be developed and implemented by February 2006.
- Ensure that grantees do not draw down grant funds if required financial or progress reports are not filed.
We agree with the recommendation. However, grant recipients are restricted from drawing down on grants through the Phone Activated Paperless Request System (PAPRS) if a current Financial Status Report (SF-269) has not been submitted. Based on our review of the drawdowns where it appeared that grantees were able to drawdown without a current SF-269 on file, we determined that the OIG did not use the correct submission date in some cases. In other cases, the drawdown occurred prior to the due date of the SF-269, but the drawdown was posted in the Integrated Financial Management Information System (IFMIS) after the due date of the SF-269. Appendix I details our analysis of the drawdowns. At the request of the grant managers, drawdowns may be withheld if progress reports are not filed.
- Ensure that grant funds are obligated in a timely manner.
We agree with the recommendation. As stated in response to Recommendations 6-9, we are in the process of revising our Grant Manager's Manual, which details OJP's standard procedures for grant administration. We will incorporate appropriate procedures to monitor grants to ensure that grant funds are obligated by grant recipients in a timely manner.
- Withhold grant awards if the applicant is delinquent in complying with prior grant requirements.
We agree with the recommendation. OJP already has procedures in place to restrict part or all grant funds if certain conditions have not been met on current grants. We will ensure that our current procedures are detailed in the revised Grant Manager's Manual.
- Establish procedures to ensure that adjustments to the grant application budget are completed timely, including revoking grant awards if the applicant is delinquent in complying with budget revision requests.
We agree with the recommendation. We will review our current business processes to determine how to better assist grant recipients in responding to budget revision requests.
- Ensure that grant drawdowns are monitored to determine if grant funds are being utilized in a timely manner.
- Follow up with grantees that have not drawn down any grant funds to determine whether the grantees have encountered difficulties in implementing the grant program, and provide assistance as necessary.
- Ensure that grant funds are deobligated and the grants are closed if grantees are unable or unwilling to implement grant programs in a timely manner.
We agree with the recommendations. As stated in response to Recommendations 6-9, we are in the process of revising our Grant Manager's Manual, which details OJP's standard procedures for grant administration. We will incorporate appropriate procedures to enhance our efforts to ensure that grant drawdowns and the progress of grants projects are monitored to determine if grant funds are being utilized in a timely manner.
- Ensure that grantees are not allowed to draw down grant funds in excess of reported cumulative grant expenditures.
We agree with the recommendation. In addition to the monitoring conducted by the grant managers, OJP's Office of the Comptroller conducts quarterly "excess cash" reviews. The "excess cash" review procedures are in the process of being revised. The revised procedures will be finalized by April 2005.
- Remedy the $145,818 in questioned costs related to excess drawdowns on expired grants.
We agree with the recommendation. We will review the grants identified in the draft report, and provide appropriate technical assistance to the grant recipients, to remedy the questioned costs identified.
- Ensure that expired grants are closed in a timely manner.
- Review grant drawdowns prior to the end of the grant period to determine if all grant funds have been drawn down, and follow up on any grants with remaining funds to determine if the grantee has expended or plans to expend remaining funds prior to the grant end date.
We agree with the recommendations. OJP's business process improvement teams are in the process of redesigning the business rules for grant closeouts. We anticipate implementing a module in our Grants Management System (GMS) in Fiscal Year 2006 to streamline the grant closeout process and ensure that expired grants are closed in a timely manner. In addition, we will incorporate appropriate procedures in the revised Grant Manager's Manual to enhance our efforts to monitor the progress of grants projects to determine if grant funds are being utilized in a timely manner.
- Ensure that grantees are not allowed to draw down funds more than 90 days after the grant end date and that all funds remaining on grants that have been expired for more than 90 days are deobligated.
- Remedy the $2,305,298 in questioned costs related to drawdowns occurring more than 90 days past the grant end date.
- Deobligate and put to better use the $3,006,770 in remaining funds related to expired grants that are more than 90 days past the grant end date.
We agree in part with the recommendations. We will review the grants identified in the draft report, and provide appropriate technical assistance to the grant recipients, to remedy the questioned costs identified. However, grant recipients are permitted to drawdown grant funds until a grant is closed out. At grant closeout, the Office of the Comptroller reconciles the expenditures reported on the final SF-269 to grant drawdowns. Before a grant can be closed out, drawdowns must be equal to or greater than the Federal share of expenditures reported on the final SF-269.
- Work with OTJ to develop a formalized mechanism for coordinating and sharing information, including monitoring reports, related to a DOJ strategy, administration, and monitoring of grants awarded to tribal governments.
- Work with OTJ to develop a formalized process for training staff responsible for administering and monitoring tribal-specific grant programs.
We agree in part with the recommendation and will work with the Office of Tribal Justice to develop a manner to share information on grants awarded to tribal governments. OJP will work to improve training for staff responsible for administering and monitoring tribal-specific grant programs.
We appreciate the opportunity to comment on the draft report. If you have any questions, please feel free to contact me on 202-307-5933, or LeToya A. Johnson, OJP Audit Liaison, on 202-514-0692.
Attachment
| cc: |
Beth McGarry
Senior Counsel to the Assistant Attorney General
Domingo R. Herraiz, Director
Bureau of Justice Assistance
John W. Gillis, Director
Office for Victims of Crime
J. Robert Flores, Administrator
Office of Juvenile Justice and Delinquency Prevention
LeToya A. Johnson
OJP Audit Liaison
Richard P. Thies
Acting Director
DOJ Audit Liaison Office |
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