Human trafficking is a form of modern-day slavery in which traffickers lure victims, predominantly women and children, with false promises of good jobs and better lives and then force the victims to work under brutal and inhumane conditions.

In 1998, the President directed federal agencies to combat human trafficking through a three-pronged approach to prevent trafficking, protect victims, and prosecute traffickers. In 2000, Congress enacted the Trafficking Victims Protection Act (TVPA) to combat human trafficking.

Responsibility for implementing U.S. anti-trafficking efforts domestically and abroad is shared by the Departments of Justice, State, Labor, Health and Human Services, and Homeland Security, as well as the United States Agency for International Development. Each agency’s efforts focuses on one or more of the three prongs of the government’s anti-trafficking strategy. As shown in the following table, the Department of Justice’s (Department) efforts involve all three prongs – prevention, protection, and prosecution.

Department of Justice Efforts to
Combat Human Trafficking

Prevention Efforts
Prosecutors and other Department personnel assist in training local law enforcement agencies, non-governmental organizations, and international representatives on human trafficking issues.
The National Institute of Justice’s International Center supports research and exchange of information by offering grants for academic research on trafficking in persons and child exploitation.
The Office of Justice Programs’ (OJP) National Criminal Justice Reference Service offers information to support research, policy, and program development worldwide on various criminal justice issues, including international trafficking.
Protection Efforts
OJP’s Office for Victims of Crime (OVC) awards cooperative agreements to service providers to supply direct services to victims of trafficking.
OJP’s Bureau of Justice Assistance awards grants to state and local law enforcement agencies to develop task forces that: (1) identify and rescue victims of human trafficking, and (2) collaborate with service providers to provide assistance to victims of trafficking.
The OVC offers victim support and education resources to trafficking victims and victim service providers.
The OVC maintains a resource center that victim advocates and caregivers can contact to obtain publications and tools to assist them in working with trafficking victims.
Prosecution Efforts
The Civil Rights Division's Criminal Section enforces the involuntary servitude and peonage statutes by working with the Federal Bureau of Investigation, the United States Attorneys Offices, and the Criminal Division’s Child Exploitation and Obscenity Section to investigate and prosecute cases of trafficking in persons and worker exploitation.
The Civil Rights Division funds and staffs the national complaint line for reporting of trafficking crimes.

As shown above, the Office of Justice Programs’ (OJP) responsibility related to human trafficking primarily involves awarding grants to establish task forces that identify and rescue trafficking victims, and awarding cooperative agreements to service providers that provide assistance such as food, clothing, and shelter to trafficking victims. OJP’s Bureau of Justice Assistance (BJA) provides grants for task forces and OJP’s Office for Victims of Crime (OVC) awards the service-provider agreements.

OIG Audit Approach

The Department of Justice Office of the Inspector General (OIG) initiated this audit to: (1) assess the adequacy of OJP’s design and management of the human trafficking grant programs; (2) evaluate the extent to which grantees have administered the grants in accordance with applicable laws, regulations, guidelines, and terms and conditions of the grant awards; and (3) assess the effectiveness of the grant programs in assisting trafficking victims.

This audit also examined the Department’s protection efforts – specifically the OVC’s program for awarding cooperative agreements to provide direct services to trafficking victims and the BJA’s program for awarding grants to develop task forces to identify and rescue trafficking victims.

We performed audit work at OJP’s Office for Victims of Crime, the Bureau of Justice Assistance, the Department’s Civil Rights and Criminal Divisions, and at the OVC service providers and associated BJA task forces listed in the following table.

OJP Service Provider Grantees	BJA Task Force Grantees
Boat People S.O.S., Inc., Falls Church, Virginia	Metropolitan Police Department of the District of Columbia, Washington, D.C.
Coalition to Abolish Slavery and Trafficking, Los Angeles, California	City of Los Angeles, California
Heartland Alliance, Chicago, Illinois	Chicago, Illinois Police Department City of Milwaukee, Wisconsin
International Rescue Committee, Miami, Florida	Collier County, Florida Miami Dade County, Florida
Mosaic Family Services, Inc., Dallas, Texas	Dallas, Texas Police Department City of Fort Worth, Texas
Refugee Women’s Network, Inc., Decatur, Georgia	City of Atlanta, Georgia Cobb County, Georgia Board of Commissioners
YMCA of the Greater Houston Area, Inc., Houston, Texas	Harris County, Texas

Appendix I describes in more detail our audit objectives, scope, and methodology.

This audit report contains three finding sections. The first finding discusses the design and management of the OJP grant programs. The second finding discusses whether grantees administered the grants in accordance with applicable laws, regulations, guidelines, and the terms and conditions of the grant awards. The third finding discusses our assessment of the effectiveness of the grant programs in aiding trafficking victims.

OIG Results in Brief

OJP’s human trafficking grant programs have built significant capacities to serve victims, but have not identified and served significant numbers of victims. As initially designed, the program awarded cooperative agreements to non-profit service providers that furnished victims with services such as food, clothing, shelter, and legal assistance. OJP’s Office for Victims of Crime began awarding agreements to service providers in January 2003, and we found that service providers supplied services to fewer than 500 victims during calendar years 2003 and 2004. As part of an expansion of the program, in FY 2005 the BJA began awarding grants to establish task forces to identify trafficking victims and refer them to service providers. The task forces identified 490 additional victims during the 6-month period ending December 2005, and the number of victims reported by the service providers as being served increased accordingly to 465 victims.

However, by the next year the number of victims reported served declined to the pre-task force levels, with 196 victims served for the 6-month period ending December 2006. In addition, the OVC’s grant award process for service providers resulted in a wide disparity in the amount of funds awarded for the number of anticipated victims to be served. Further, we found that both the service providers and task forces overstated to OJP the number of victims reportedly served and identified.

We also analyzed OJP’s administration of human trafficking grants and found systemic weaknesses in its grant implementation. From April 2007 to March 2008, the OIG issued five audit reports on individual OVC service provider cooperative agreements, one audit report on multiple cooperative agreements, and one audit report on a BJA task force grant. Those audits demonstrated weaknesses in the areas of the established goals and accomplishments for grantees, grant reporting, fund drawdowns, local matching funds, expenditures, indirect costs, and monitoring of subrecipients. The OVC and BJA agreed to take corrective action in response to each of our individual grant audits, but we believe that these audits show that the OVC and BJA need to take additional actions to ensure that these weaknesses are addressed by all OVC service providers and BJA task forces, not just the subjects of the individual audits we conducted.

Finally, as noted above we concluded that OJP’s human trafficking grant programs have built significant capacities to serve victims, but have not been effective at identifying and serving significant numbers of alien trafficking victims. The OVC service providers were generally effective at conducting human trafficking-related outreach, training, and service activities. However, the agreements and grants awarded to service providers and task forces have not resulted in services to a significant number of victims. In addition, we found that the OVC and BJA had not established an effective system for monitoring the OVC service providers and the BJA task forces to ensure that: (1) performance data reported by the service providers and task forces is accurate, (2) the service providers and task forces are meeting performance goals, and (3) service providers can show the amount of grant funds that are used to directly assist victims of human trafficking.

At the conclusion of our audit, OJP officials provided us an update on changes to OJP’s grant monitoring and assessment efforts. According to an OJP official, they created the Program Assessment Division in FY 2007 to conduct grant program assessments, create common monitoring policies, and ensure monitoring efforts are effective. In addition, at the beginning of FY 2008, OJP released the “Grant Monitoring Tool” to enhance documentation of monitoring reviews, provide improved tools and guidance for monitoring, and improve the tracking of monitoring findings and grantee corrective actions. OJP also expanded the use of the Trafficking Information Management System to accumulate and report data related to the number of trafficking victims identified and served. While we could not evaluate these actions, if fully implemented they could address some of the weaknesses we found during this audit.

In our report, we make 15 recommendations to assist OJP in improving the management of its human trafficking grants to the OVC service providers and BJA task forces.

Our report contains detailed information on the full results of our review of OJP’s human trafficking grant programs. The remaining sections of the Executive Summary summarize in more detail our major audit findings.

OJP’s Design and Management of Grant Programs

Our audit found that OJP’s human trafficking grant programs have built significant capacities to serve victims, but have not identified and served significant numbers of victims. As initially designed, the program awarded cooperative agreements to non-profit service providers that furnished food, clothing, shelter, and legal assistance. OJP’s Office for Victims of Crime began awarding agreements to service providers in January 2003, and the service providers reported serving a total of 480 victims during calendar years 2003 and 2004.

Because of the low number of victims assisted by the service providers, OJP determined that it needed a more comprehensive detection and investigation strategy that was linked to the rescue and recovery of human trafficking victims. In 2004, OJP assigned the BJA to reach out to local law enforcement agencies to explore opportunities for collaboration among federal, state, and local entities with the goal of improving the identification of trafficking victims. The result was the implementation of the BJA’s Anti-Human Trafficking Task Force Initiative. This initiative provides grant funds to state and local law enforcement agencies to establish anti-trafficking task forces that implement victim identification and rescue operations and refer the victims to service providers usually funded by OJP grants.

From FYs 2005 through 2007, the BJA awarded 42 grants and supplements totaling about $19.2 million to establish anti-trafficking task forces. As shown in the following graph, the task forces appeared initially to identify significant numbers of potential trafficking victims, and this more than doubled the number of victims assisted by the service providers. However, while the task forces continued to identify potential victims, the actual number of victims served has dropped off dramatically since calendar year 2005.

Trafficking Victims Reported as Assisted by
OVC Service Providers and Identified by BJA
Task Forces from January 2003 through June 2007

Source: Victim data maintained by the Office for Victims of Crime and the Bureau of Justice Assistance

Even with the work of the task forces, the service providers are reaching a small fraction of the victims believed to be trafficked into the United States each year. According to the Trafficking Victims Protection Act of 2000, an estimated 50,000 victims were trafficked into the United States annually. This initial estimate has significantly decreased. The Department’s July 2005 report on U.S. Government Efforts to Combat Human Trafficking in Persons in Fiscal Year 2004, indicates there are an estimated 14,500 to 17,500 human trafficking victims brought into the United States annually. Based on the reported data, the task force operations have not resulted in a large number of trafficking victims being served by the service providers.

Additionally, we found that the OVC’s agreement award process for service providers resulted in a wide variation in the amount of funds awarded per anticipated victim to be served by each agreement. From FYs 2003 through 2007, the OVC awarded service providers 41 initial cooperative agreements and 28 supplements totaling about $31.7 million. We analyzed 19 initial agreements and supplements awarded to 7 service providers and found a wide variation in the amount of funds awarded compared to the number of victims each agreement recipient anticipated serving. For example, one service provider received $1,896,535 to supply services to an estimated 100 victims over the 3-year agreement period, or $18,965 per estimated victim. Another provider received $490,829 to service an estimated 100 victims over the 3-year agreement period, or $4,908 per estimated victim. For the 19 agreements and supplements we tested, the amount awarded per anticipated victim ranged from a high of $33,333 to a low of $2,500.

We found that OVC officials generally relied on the service provider’s estimates of the number of victims who would benefit but did not make an independent assessment of the reasonableness of the costs compared to the anticipated number of victims. According to an OVC official, very little was known about the nature and scope of human trafficking into the United States in 2002 when the program was being developed. The initial OVC grant solicitation was issued based on information from the State Department that estimated large numbers of trafficking victims were brought into the United States each year. The OVC official also told us that no one really knew the number of victims that would be found in a specific locale, and therefore the OVC had expected applications that covered large geographic regions. However, the official said that this did not happen and instead the OVC received applications for smaller geographic areas. As a result, grant funds awarded to service providers for victim services varied greatly, and OJP could not provide us with evidence to show that the wide variance in award amounts per victim were reasonable.

At the conclusion of the audit, an OVC official told us that the service provider budgets were reviewed in detail and were often changed, sometimes significantly, as a result of the financial reviews of the budgets. However, the OVC official indicated that the budget review did not specifically analyze the costs in relation to the victims that the grant applicant anticipated serving. The OVC official said that the OVC never awarded any grant based on the number of victims, but based the awards on the costs associated with starting the grant program, building a community-wide effort to address trafficking, and providing services to all victims identified.

Inaccurate Data Regarding Victims Assisted by Service Providers

Our audit work identified significant inaccuracies in the performance data reported by the service providers. Beginning in May 2004, the Department submitted annual reports to Congress regarding the government’s actions to combat human trafficking.¹ In each report, the Department reported on the number of trafficking victims who benefited from the OVC service providers. We analyzed the data on victims served in the four annual reports submitted to Congress between FYs 2004 and 2007, and our analysis indicates that the actual number of eligible victims served was usually significantly less than reported. The following table shows:

• the victim data reported to Congress each year,
  
  
• the victim data maintained by the OVC for each year,
  
  
• the number of reported victims for which we performed tests to determine if the reported data was accurate, and
  
  
• the number of reported victims for which the service providers could furnish documentation to verify that the victims were eligible for services based on the Trafficking Victims Protection Act.

OIG Analysis of Trafficking Victims Reported as
Assisted by the OVC Service Providers from
January 2003 through June 2007

Calendar Year Covered by Report to Congress	Reported Number of Trafficking Victims
	Sent To Congress	Recorded in OVC’s Records	Tested by the OIG	Verified by the OIG
2003	200	174	86	34
2004	357	306	164	71
2005	692	661	256	187
2003 - 2006	1,775	1,618	684	435
2003 - June 2007	Not Yet Reported2	1,924	685	445

As shown in the preceding table, our tests of the number of victims reported indicated that the OVC has significantly overstated the number of victims actually served in its reports to Congress.

Causes for Inaccurate Data Regarding Victims Served

To determine the causes for the Department’s reporting of inaccurate data regarding victims served, we interviewed OVC and service provider officials and reviewed documentation related to victims served. We determined that the reasons for the inaccurate data included the following:

• Three service providers reported existing and new victims each reporting period, and therefore the existing victims were counted multiple times.
  
  
• Two service providers reported victims who either disappeared or were found to be ineligible by either the service provider or law enforcement after being interviewed by the service provider.
  
  
• One service provider reported victims who had been certified by the Department of Health and Human Services (HHS) as trafficking victims prior to the OVC grant award.
  
  
• Two service providers reported victims who had been certified by HHS after the OVC grant was awarded but before they came to the service provider for help.
  
  
• Three service providers did not maintain documentation to support some of the victims it reported as served.

Inaccurate Data Regarding Victims Identified by Task Forces

As with the service providers, we identified significant inaccuracies in the number of victims identified by the task forces. The Department’s May 2007 report to Congress was the first annual report to include data on the potential trafficking victims identified by the BJA task forces. In that report, the Department stated that the BJA task forces had identified 1,513 potential trafficking victims as of December 31, 2006. We performed testing on records for 510 of the 1,513 reported victims and could verify only 157 of the 510 as being victims as defined by the Trafficking Victims Protection Act.

Subsequent to the Department’s May 2007 report to Congress, the BJA task forces submitted updated performance data to the BJA for the 6-month period ending June 30, 2007. The BJA data showed that the task forces had identified 2,128 potential trafficking victims as of June 30, 2007. We performed testing on records for 620 of the 2,128 reported victims and could verify only 234 of the 620 as being victims as defined by the Trafficking Victims Protection Act.

Causes for Inaccurate Data Regarding Victims Identified by Task Forces

To determine the causes for the Department’s reporting of inaccurate data regarding victims identified by the task forces, we interviewed the BJA and task force officials and reviewed documentation related to victims identified. We found the reasons for the inaccurate data included the following:

• For one task force, the BJA inadvertently recorded the cumulative amount of victims served since the beginning of the agreement in January 2003 instead of recording just the number of victims served during the 6-month period ending June 30, 2006.
  
  
• One task force under-reported the victims identified because of a lack of communication between different members of the task force.
  
  
• One task force had initially identified multiple victims in a case, but only one victim was actually found by the police department. The task force mistakenly reported the multiple victims initially identified.

Administration of Grants

From April 2007 to March 2008, the OIG issued five audit reports on individual OVC service provider cooperative agreements, one audit report on multiple cooperative agreements awarded to one service provider, and one audit report on a BJA task force grant.³ The OIG’s individual audits found that the service providers and task force did not comply with the essential grant requirements in 9 of the 10 areas tested. OJP and the grantees had initiated, or agreed to initiate, corrective actions to address most of the weaknesses found in the individual audits. However, we determined that the weaknesses identified in the following seven areas were systemic and warrant additional guidance and direction by the OVC and BJA for all its human trafficking program grantees. In these audits we found the following:

• Goals and Accomplishments – Six of the seven grantees had not met or were not accomplishing one or more project goals.
  
  
• Reporting – Only one of the seven grantees had a significant problem in submitting Financial Status Reports (FSR) in a timely manner. However, three of the seven grantees submitted FSRs containing inaccurate financial data. In addition, three of the seven grantees had a significant problem in submitting program progress reports in a timely manner.
  
  
• Fund Drawdowns – Three of the seven grantees drew down funds too early to meet immediate needs, and one grantee did not maintain adequate accounting records to determine if the funds were drawn down appropriately.
  
  
• Local Match – Four of the seven grantees had significant deficiencies related to supporting the matching funds claimed against the agreements.
  
  
• Expenditures – Six of the seven grantees claimed expenditures totaling $1,488,956 that, at the time of the audits, were either not authorized; not properly classified and supported; not accurately recorded; not reasonable, allocable, or allowable; not necessary to the project; or not in accordance with applicable laws, regulations, guidelines, and terms and conditions of the cooperative agreements. As of June 19, 2008, OJP and the grantees had completed actions to remedy only $56,710 of the $1,488,956 in questioned direct expenditures.
  
  
• Indirect Costs – At the time of the audits, three of the seven grantees claimed $271,071 in unallowable or unsupported indirect costs. As of June 19, 2009, the grantees had not provided documentation to support any of the questioned indirect costs.
  
  
• Monitoring of Subrecipients – Three of the five grantees with grant subrecipients did not properly monitor the subrecipients.

These systemic deficiencies existed despite past OIG reviews of OJP grant programs that found similar grant administration deficiencies. For example, previous OIG audits have identified the following issues related to OJP grant administration:

• A significant number of grantees either did not submit required financial and progress reports or did not submit them in a timely manner.
  
  
• OJP’s monitoring of grantee activities were deficient in various areas, such as not sufficiently reviewing supporting documentation for grant expenditures, not establishing performance goals for its programs, not ensuring that grantees submit performance data to demonstrate that grant monies were being used effectively and as intended, and not properly closing grants in a timely manner.
  
  
• Grant funds were not regularly awarded in a timely manner and grantees were slow to spend available monies.
  
  
• OIG audits of grants have resulted in significant dollar‑related findings.

As a result of the continued deficiencies identified by the OIG audits of OJP grants, the OIG identified grant management as one of the Department’s top management challenges for the past 6 years. As the OIG noted in our November 2007 top management challenges report, while it is important to efficiently award the billions of dollars in grant funds appropriated annually by Congress, it is equally important that the Department maintains proper oversight over the grantees’ use of these funds to ensure accountability and to ensure that these funds are used as intended.

Effectiveness of the Grant Programs

We found that the OVC service providers were generally effective at conducting human trafficking-related outreach, training, and service activities. Similarly, the grant programs have built significant capacities to serve victims, but have not been effective at identifying and serving significant numbers of alien trafficking victims. As previously discussed, we found that performance data for the OVC service providers showed they served only 480 trafficking victims during calendar years 2003 and 2004. OJP recognized that few victims were being served and, to address the problem, awarded grants to law enforcement agencies to establish task forces to identify more victims and refer them to the service providers. While the identification of victims by the task forces initially led to an increase in the number of victims helped by the service providers, subsequent data showed that the task forces have not been effective at consistently increasing the number of victims served.

In addition, at the time of our audit, the OVC and BJA had not established an effective system for monitoring the OVC service providers and the BJA task forces to ensure that: (1) performance data reported by the service providers and task forces is accurate, (2) service providers and task forces are meeting performance goals, and (3) service providers can show the amount of grant funds used to directly assist victims of human trafficking. For example, our audit found that:

• The OVC service providers we tested overstated the number of trafficking victims serviced through June 2007 by 54 percent.
  
  
• The BJA task forces we tested overstated the number of trafficking victims identified through June 2007 by 165 percent.
  
  
• The BJA task forces inaccurately reported performance data to the BJA for three additional performance measures used by the BJA to measure program effectiveness.
  
  
• Four of the six service providers tested had not assisted the number of victims that they anticipated serving.
  
  
• Four of the seven service providers used less than 10 percent of the awarded funds to provide direct assistance to trafficking victims. Service provider officials said that much of the direct services they supply to victims are consultations, legal assistance, and other services provided by in-house staff or by outside consultants and contractors. However, the service providers were not required to and consequently did not account for how much of the grant funds used for these purposes directly assisted victims.

Conclusion and Recommendations

In general, we found that the design and management of OJP’s human trafficking grant programs were effective in building capacities to serve victims of human trafficking, but were not effective in: (1) identifying and serving significant numbers of alien trafficking victims, (2) ensuring that award amounts were consistent with the anticipated number of victims to be served, and (3) ensuring that service providers and task forces reported accurate performance data on victims identified and served.

In addition, in individual audits of 6 OVC service providers and 1 BJA task force, the OIG found that they did not comply with the essential grant requirements in 9 of the 10 areas tested. The deficiencies identified in these audits are similar to the deficiencies found repeatedly in past audits of OJP grants. While OJP and the grantees had initiated or agreed to initiate corrective action to address most of the weaknesses we found in the individual audits, we believe the weaknesses we identified were systemic and warrant additional guidance and direction from the OVC and BJA to all human trafficking grantees.

Finally, at the time of the audit the OVC and BJA had not established an effective system for monitoring the OVC service providers and the BJA task forces to ensure that: (1) service providers and task forces are meeting performance goals, and (2) service providers can show the amount of grant funds used to directly assist victims of human trafficking. However, at the conclusion of the audit, an OJP official told us that they had implemented actions to improve monitoring of the service providers and task forces. While we did not evaluate these actions, we believe that, if fully implemented, they could address some of the weaknesses we identified during this audit.

Our audit work and findings resulted in 15 recommendations to improve the management of the OVC service provider cooperative agreements and the BJA task force grants. Our recommendations include the following:

• Ensure that the BJA task forces either report only actual trafficking victims identified, or report both actual and potential victims identified.
  
  
• Ensure that the task forces and service providers can support the trafficking victims reported as identified and served.
  
  
• Develop a system to ensure that: (1) performance data reported by the service providers and task forces is accurate, (2) the service providers and task forces are meeting the performance goals, and (3) the service providers track the amount of grants funds used to assist victims of human trafficking.
  
  
• Provide additional training and oversight of service providers and task forces to help them: (1) accomplish unmet grant goals, (2) submit accurate financial reports, (3) submit timely progress reports, (4) draw down funds to meet immediate needs, (5) maintain support for matching funds, (6) claim only allowable and supported costs, (7) calculate indirect costs, and (8) monitor subrecipients.

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1. U.S. Department of Justice, Report to Congress from Attorney General John Ashcroft on U.S. Government Efforts to Combat Trafficking in Persons in Fiscal Year 2003, (May 1, 2004).

   U.S. Department of Justice, Report to Congress from Attorney General Alberto R. Gonzales on U.S. Government Efforts to Combat Trafficking in Persons in Fiscal Year 2004, (July 2005).

   U.S. Department of Justice, Attorney General’s Annual Report to Congress on U.S. Government Efforts to Combat Trafficking in Persons Fiscal Year 2005, (June 2006).

   U.S. Department of Justice, Attorney General’s Annual Report to Congress on U.S. Government Efforts to Combat Trafficking in Persons Fiscal Year 2006, (May 2007).

2. The next annual report to Congress is not due to be submitted until the Fall of 2008 and will cover performance data through December 2007.

3. A list of the OIG audits of the service provider agreements and task force grant can be found in the table on pages 38 and 39 of this report.