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

The OIG has identified several issues in the OJP response to our draft report, (see Appendix XXI), that we believe should be addressed. As a result, we are providing the following comments on the OJP response to the draft report. In Appendix XXI, page 143, OJP provided the following statement in response to recommendation: Ensure that grantees do not draw down grant funds if required financial or progress reports are not filed. 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. The OIG disagrees with the OJP assertion that grant recipients are restricted from drawing down on grants through PAPRS system when a current financial report has not been submitted. As shown in Appendix I of OJP’s response on page 147, the OJP acknowledges that a financial report date submitted for the quarter ended September 30, 2003, was entered into its system when the grantee had not submitted the required report. In this instance an OJP official overrode the controls in the PAPRS system that should have prevented the grantee from drawing down funds during a period when the current financial report had not been submitted. As a result, OJP allowed this grantee to draw down $1,094,641 during the period for which a current financial report had not been submitted. Additionally, our analysis was based on financial reports provided by OJP officials. In some instances, it appears that OJP did not provide all requested financial reports; as a result, the OIG was not provided the complete information necessary to conduct our analysis. In Appendix XXI, page 145, OJP provided the following statement in response to recommendations: 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. Grant recipients are permitted to drawdown grant funds until the 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. The OIG disagrees with the OJP assertion that grant recipients are permitted to drawdown grant funds until the grant is closed out. Specifically, 28 CFR 66.23 (b) states that, A grantee must liquidate all obligations incurred under the award not later than 90 days after the end of the funding period (or as specified in a program regulation) to coincide with the submission of the annual Financial Status Report (SF–269). The Federal agency may extend this deadline at the request of the grantee. Although OJP may extend the 90 day liquidation period, the extension must be at the request of the grantee. We found that extensions had not been granted in any of the grants reviewed. We also found no evidence that grantees had requested an extension of the 90-day liquidation period. It should also be noted that 15 of these grants had been expired for more than 2 years. In our judgment, the OJP response does not adequately address how they will ensure that remaining grant funds are deobligated in a timely manner. Additionally, the OJP response does not adequately address the $2,305,298 in questioned costs related to drawdowns occurring more than 90 days past the grant end date. We found no evidence that the grantees requested extensions of the 90-day liquidation period for these grants and no extensions were provided. The OJP response also does not adequately address the $3,006,770 in funds to better use related to remaining funds for grants that are more than 90 days past the grant end date. Again, we found no evidence that the grantees requested extensions of the 90-day liquidation period for these grants and no extensions were provided.