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 XXV


Analysis and Summary of Actions
Necessary to Close the Report


  1. Resolved (COPS). This recommendation can be closed when we receive documentation supporting that the COPS Office has developed and implemented a monitoring plan which includes the enhanced risk based criteria for determining the population of eligible grantees for site visits and office-based grant reviews and a monitoring plan that includes the number of site-visits and office-based desk reviews that will be conducted for tribal grantees.

  2. Unresolved (COPS). This recommendation can be resolved when the COPS Office provides an acceptable corrective action plan that addresses the recommendation to ensure that required financial and progress reports are submitted in a timely manner. The COPS Office response to the recommendation states that its current practices are sufficient to address the recommendation. However, as stated on page 20 of our report, we found that 83 percent of the grant files reviewed were missing one or more financial reports and 97 percent had financial reports that were not submitted in a timely manner. Further, as stated on page 23 of our report, we found that 62 percent of the grant files reviewed were missing one or more progress reports and 76 percent had progress reports that were not submitted in a timely manner. Therefore, the current COPS Office practices are not sufficient to address our recommendation.

  3. Unresolved (COPS). This recommendation can be resolved when the COPS Office provides an acceptable corrective action plan that addresses the recommendation to 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. The COPS Office response to the recommendation states that its current practices are sufficient to address the recommendation. However, as stated on page 20 of our report, only 21 percent of the grant files reviewed contained documentation requesting missing or late financial reports. Further, as stated on page 23 of our report, only 33 percent of the grant files reviewed contained documentation requesting missing or late progress reports. Therefore, the current COPS Office practices are not sufficient to address our recommendation.

  4. Unresolved (COPS). This recommendation can be resolved when the COPS Office provides an acceptable corrective action plan that addresses the recommendation to ensure that grantees do not draw down grant funds if required progress reports are not filed. The COPS Office response to the recommendation states that its current practices are sufficient to address the recommendation. However, as stated on page 24 of our report, we found that grantees were able to draw down grant funds totaling $484,975 during periods for which a current progress report had not been submitted. Therefore, the current COPS Office practices are not sufficient to address our recommendation.

  5. Unresolved (COPS). This recommendation can be resolved when the COPS Office provides an acceptable corrective action plan that addresses the recommendation to ensure that periodic progress are required to be submitted annually for the 3-year hiring grants and semi-annually for the 1-year equipment grants. The COPS Office response states that they disagree with our recommendation to require semi-annual progress reports for the 1-year equipment grants. However, the OIG disagrees with the COPS Office assertions that requiring semi annual progress reports would increase the reporting burden on the grantee and that the semi-annual reports would not supply the COPS Office with enough substantive information on grants to warrant the increased reporting. In our judgment, if progress reports are not required on a semi-annual basis for the 1-year equipment grants these grants could expire before the COPS Office receives any information on issues that may impede the effective and timely implementation of these grants.

  6. Resolved (OJP). This recommendation can be closed when we receive documentation supporting that OJP has revised its Grant Managerís Manual incorporating appropriate procedures to ensure that risk based monitoring plans are developed and implemented for each grantee.

  7. Resolved (OJP). This recommendation can be closed when we receive documentation supporting that OJP has revised its Grant Managerís Manual incorporating appropriate procedures to ensure that grantees submit required financial and progress reports in a timely manner.

  8. Resolved (OJP). This recommendation can be closed when we receive documentation supporting that OJP has revised its Grant Managerís Manual incorporating appropriate procedures to 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.

  9. Unresolved (OJP). This recommendation can be resolved when OJP provides an acceptable corrective action plan to ensure that the controls in its PAPRS system are not circumvented by OJP staff allowing grantees to draw down funds when required financial reports have not been filed and ensure that grantees do not draw down funds if required progress reports have not been filed. The OJP response states that grant recipients are restricted from drawing down on grants through the PAPRS system if a current financial report has not been submitted. However, as shown in Appendix I of OJPís response on page 147, the OJP acknowledges that a financial report date 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. Further, the OJP response states that grant managers can request that drawdowns be withheld if required progress reports are not submitted. However, the OJP response does not address how it will ensure that grantees do not draw down funds if required progress reports have not been filed.

  10. Resolved (OVW). This recommendation can be closed when we receive documentation supporting that OVW has developed and implemented a risk assessment tool to determine the timing and frequency of office based and on-site monitoring and that grant managers are required to include their monitoring plans in the Grant Managerís Memorandum.

  11. Resolved (OVW). This recommendation can be closed when we receive documentation supporting that OVW has developed a strategy to ensure that required financial and progress reports are submitted in a timely manner.

  12. Resolved (OVW). This recommendation can be closed when we receive documentation supporting that OVW has established procedures to follow up with grantees if financial and progress reports are not submitted or are not submitted in a timely manner.

  13. Resolved (OVW). This recommendation can be closed when we receive documentation supporting that OVW has implemented a Memorandum of Understanding with OJPís OC to ensure that grantees do not draw down funds if required financial reports are not filed and that OVW has assessed the viability of putting into place a mechanism that would automatically freeze funds as a result of late progress reports once its new system for submitting on-line progress reports is working.

  14. Unresolved (COPS). This recommendation can be resolved when the COPS Office provides an acceptable corrective action plan that addresses the recommendation to ensure that grant drawdowns are monitored to determine if grant funds are being utilized in a timely manner. The COPS Office response to the recommendation states that its current practices are sufficient to address the recommendation. However, as stated on page 30 of our report, no funds had been drawn down for more than 2 years after the obligation date for 52 COPS Office grants totaling $17.22 million. Additionally, the initial drawdown did not occur for over one year after the funds were obligated for 200 COPS Office grants totaling $31.90 million. Finally, page 33 of our report states that the last drawdown occurred more than one year prior to our review for 126 COPS Office grants with remaining funds totaling $2.80 million. Therefore, the current COPS Office practices are not sufficient to address our recommendation.

  15. Unresolved (COPS). This recommendation can be resolved when the COPS Office provides an acceptable corrective action plan that addresses the recommendation to 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. The COPS Office response to the recommendation states that its current practices are sufficient to address the recommendation. However, as stated on page 30 of our report, no funds had been drawn down for more than 2 years after the obligation date for 52 COPS Office grants totaling $17.22 million. Additionally, under the current COPS Office policy, follow up with grantees would only occur for those grantees that did not submit a financial report. Therefore, the current COPS Office practices are not sufficient to address our recommendation.

  16. Unresolved (COPS). This recommendation can be resolved when the COPS Office provides an acceptable corrective action plan that addresses the recommendation to 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. The COPS Office response to the recommendation states that its current practices are sufficient to address the recommendation. However, as stated on page 30 of our report, no funds had been drawn down for more than 2 years after the obligation date for 52 COPS Office grants totaling $17.22 million. Additionally, the initial drawdown did not occur for over one year after the funds were obligated for 200 COPS Office grants totaling $31.90 million. Finally, page 33 of our report states that the last drawdown occurred more than one year prior to our review for 126 COPS Office grants with remaining funds totaling $2.80 million. Therefore, the current COPS Office practices are not sufficient to address our recommendation.

  17. Unresolved (COPS). This recommendation can be resolved when the COPS Office provides an acceptable corrective action plan that addresses the recommendation to ensure that grantees are not allowed to draw down grant funds in excess of reported cumulative grant expenditures. The COPS Office response to the recommendation states that its current practices are sufficient to address the recommendation and that grantees do not have excess cash but rather a reporting issue due to a timing difference. However, as stated on page 34 of our report, excess grant funds totaling $713,567 were drawn down by 18 COPS Office grantees on expired grants. Additionally, our audit took into account any timing differences noted by the COPS Office by eliminating all grants which had not expired. Therefore, the current COPS Office practices are not sufficient to address our recommendation.

  18. Resolved (COPS). This recommendation can be closed when we receive documentation supporting that the COPS Office has remedied the $713,567 in questioned costs related to excess drawdowns on expired grants.

  19. Resolved (OJP). This recommendation can be closed when we receive documentation supporting that OJP has revised and implemented appropriate procedures incorporated into its Grant Managerís Manual to monitor grants and to ensure that grant funds are obligated in a timely manner.

  20. Resolved (OJP). This recommendation can be closed when we receive documentation supporting that OJP has revised and implemented appropriate procedures incorporated into its Grant Managerís Manual to restrict part or all grant funds if certain conditions have not been met on current grants.

  21. Resolved (OJP). This recommendation can be closed when we receive documentation supporting that OJP has reviewed its current business processes to determine how to better assist grant recipients in responding to budget revision requests.

  22. Resolved (OJP). This recommendation can be closed when we receive documentation supporting that OJP has implemented appropriate procedures incorporated into its Grant Managerís Manual to ensure that grant drawdowns are monitored to determine if grant funds are utilized in a timely manner.

  23. Resolved (OJP). This recommendation can be closed when we receive documentation supporting that OJP has implemented appropriate procedures incorporated into its Grant Managerís Manual to 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 provided assistance as necessary.

  24. Resolved (OJP). This recommendation can be closed when we receive documentation supporting that OJP has implemented appropriate procedures incorporated into its Grant Managerís Manual to ensure that grant funds are deobligated and grants are closed if grantees are unable or unwilling to implement grant programs in a timely manner.

  25. Resolved (OJP). This recommendation can be closed when we receive documentation supporting that OJP has implemented revised procedures for its quarterly ďexcess cashĒ reviews to ensure that grantees are not allowed to draw down grant funds in excess of reported cumulative grant expenditures.

  26. Resolved (OJP). This recommendation can be closed when we receive documentation supporting that OJP has remedied the $145,818 in questioned costs related to excess drawdowns on expired grants.

  27. Resolved (OVW). This recommendation can be closed when we receive documentation supporting that OVW has established and implemented guidelines which limit the amount of time allowed for reconciling budget issues to ensure that grant funds are obligated in a timely manner.

  28. Resolved (OVW). This recommendation can be closed when we receive documentation supporting that OVW has implemented procedures to withhold grant awards if the applicant is delinquent in complying with prior grant requirements.

  29. Resolved (OVW). This recommendation can be closed when we receive documentation supporting that OVW has established and implemented guidelines which limit the amount of time allowed for reconciling budget issues and limit the amount of time it should take to respond to budget revision requests.

  30. Resolved (OVW). This recommendation can be closed when we receive documentation supporting that OVW has developed and implemented procedures for reviewing quarterly financial reports submitted by grantees to determine if grant funds are being utilized in a timely manner in accordance with grant goals and objectives.

  31. Resolved (OVW). This recommendation can be closed when we receive documentation supporting that OVW has developed and implemented procedures for reviewing quarterly financial reports submitted by grantees to determine if grant funds are being utilized in a timely manner in accordance with grant goals and objectives and follow up with grantees if grant funds have not been drawn down, and provide assistance as necessary.

  32. Resolved (OVW). This recommendation can be closed when we receive documentation supporting that OVW has developed and implemented procedures to ensure that grant funds are deobligated and the grants are closed if the grantees are unable or unwilling to implement grant programs in a timely manner.

  33. Resolved (OVW). This recommendation can be closed when we receive documentation supporting that OVW has developed and implemented procedures for monitoring drawdowns to ensure that grantees are not allowed to draw down grant funds in excess of reported cumulative reported grant expenditures.

  34. Resolved (OVW). This recommendation can be closed when we receive documentation supporting that OVW has remedied the $70,863 in questioned costs related to excess drawdowns on expired grants.

  35. Resolved (COPS). This recommendation can be closed when we receive documentation supporting that the COPS Office has developed and implemented an Expired Grant Policy to ensure that expired grants are closed in a timely manner and that remaining grant funds are deobligated prior to closing the grants.

  36. Resolved (COPS). This recommendation can be closed when we receive documentation supporting that the COPS Office has deobligated and put to better use the $200,380 in remaining funds related to grants that have been closed.

  37. Unresolved (COPS). This recommendation can be resolved when the COPS Office provides an acceptable corrective action plan that addresses the recommendation to review grant drawdowns prior to the end of the grant period to determine if all grant funds have been drawn down, and follows 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. The COPS Office response to the recommendation states that its current practices are sufficient to address the recommendation. However, as stated on page 39 of our report, we identified $6,487,356 in remaining funds related to expired grants. Therefore, the current COPS Office practices are not sufficient to address our recommendation.

  38. Unresolved (COPS). This recommendation can be resolved when the COPS Office provides an acceptable corrective action plan that addresses the recommendation to 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 more than 90 days are deobligated. The COPS Office response to the recommendation states that the COPS Office may extend the 90-day liquidation period at the request of the grantee. However, we found no evidence that the grantees requested extensions of the 90-day liquidation period for the grants we reviewed and no extensions were provided. Therefore, the COPS Office response does not adequately address our recommendation.

  39. Unresolved. This recommendation can be resolved when the COPS Office provides an acceptable corrective action plan that addresses the recommendation to remedy the $3,077,157 in questioned costs related to drawdowns occurring more than 90 days past the grant end date. The COPS Office response to the recommendation states that the COPS Office may extend the 90 day liquidation period at the request of the grantee. However, we found that no evidence that the grantees requested extensions of the 90 day liquidation period for these grants and no extensions were provided. Therefore, the COPS Office response does not adequately address our recommendation.

  40. Unresolved (COPS). This recommendation can be resolved when the COPS Office provides an acceptable corrective action plan that addresses the recommendation to deobligate and put to better use the $6,487,356 in remaining funds related to expired grants that are more than 90 days past the grant end date. The COPS Office response to the recommendation states that the COPS Office may extend the 90-day liquidation period at the request of the grantee. However, we found no evidence that the grantees requested extensions of the 90-day liquidation period for these grants and no extensions were provided. Therefore, the COPS Office response does not adequately address our recommendation.

  41. Resolved (OJP). This recommendation can be closed when we receive documentation that OJP has implemented a formal process to close expired grants in a timely manner.

  42. Resolved (OJP). This recommendation can be closed when we receive documentation supporting that OJP has implemented appropriate procedures incorporated into its Grant Managerís Manual to 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.

  43. Unresolved (OJP). This recommendation can be resolved when OJP provides an acceptable corrective action plan that addresses the recommendation to 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 more than 90 days are deobligated. The OJP Response states that grant recipients are permitted to draw down funds until a grant is closed. However, this statement contradicts 28 CFR 66.23 (b), which states that grantees must liquidate all obligations incurred under the award not later than 90 days after the end of the funding period. Although the granting agency may extend the 90-day liquidation period, we found no evidence that the grantees requested extensions of the 90-day liquidation period for the grants we reviewed and no extensions were provided.

  44. Resolved (OJP). This recommendation can be closed when we receive documentation supporting that OJP has remedied the $2,305,298 in questioned costs related to drawdowns occurring more than 90 days past the grant end date.

  45. Resolved (OJP). This recommendation can be closed when we receive documentation supporting that OJP has deobligated 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.

  46. Resolved (OVW). This recommendation can be closed when we receive documentation supporting that the OVW has developed and implemented procedures to ensure that expired grants are closed in a timely manner and that remaining grant funds are deobligated prior to closing the grants.

  47. Resolved (OVW). This recommendation can be closed when we receive documentation supporting that OVW has deobligated and put to better use the $6,869 in remaining funds related to grants which have been closed.

  48. Resolved (OVW). This recommendation can be closed when we receive documentation supporting that OVW has developed and implemented procedures for reviewing quarterly financial reports submitted by grantees to determine if all grant funds have been drawn down, and follows 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.

  49. Resolved (OVW). This recommendation can be closed when we receive documentation that OVW has developed and implemented procedures to 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.

  50. Resolved (OVW). This recommendation can be closed when we receive documentation supporting that OVW has remedied the $681,016 in questioned costs related to drawdowns occurring more than 90 days past the grant end date.

  51. Resolved (OVW). This recommendation can be closed when we receive documentation supporting that OVW has deobligated and put to better use the $1,250,922 in remaining funds related to expired grants that are more than 90 days past the grant end date.

  52. Resolved (COPS, OJP, and OVW). This recommendation can be closed when we receive documentation that the COPS Office, OJP, and OVW, in conjunction with OTJ, have developed a formalized mechanism for coordinating and sharing information, including monitoring reports.

  53. Resolved (COPS, OJP, and OVW). This recommendation can be closed when we receive documentation that the COPS Office, OJP, and OVW, in conjunction with OTJ, have developed a formalized process for training staff responsible for administering and monitoring tribal-specific grant programs.



Previous Page Back to Table of Contents Next Page