The U.S. Department of Justice (DOJ) Office of the Inspector General (OIG), Audit Division, has completed an audit of three Technology Initiative Grants awarded by the Office of Community Oriented Policing Services (COPS) to the Morris County, New Jersey, Sheriff’s Office (Morris County).¹ Between February 2003 and December 2004, COPS awarded Morris County a total of $3,961,109, distributed through three grants awarded successively in fiscal years 2003, 2004, and 2005. The purposes of the three grants, respectively, were to:  (1) replace a 40-year old voice 2-way radio system with a new 22-channel trunked radio system; (2) purchase new mobile and portable radios; and (3) purchase a computer system to connect all 40 law enforcement agencies in Morris County.²

The objective of our audit was to determine whether reimbursements claimed for costs under the grants were allowable, supported, and in accordance with applicable laws, regulations, guidelines, and terms and conditions of the grants. We also assessed the grantee’s performance in meeting grant objectives and overall accomplishments.

We found that Morris County was in material non-compliance with the grant requirements we tested. We reviewed its compliance with five essential grant conditions and found material weaknesses in three of the five areas we tested:  (1) grant expenditures, (2) Financial Status Reports (FSR), and (3) budget management and control. Because of the deficiencies identified, we question all of the funds received by Morris County, totaling $3,960,643. This amount is 100 percent of the federal grant funding expended.³

We found that Morris County’s expenditures for the communications equipment did not meet grant requirements in three ways:  (1) grant funds were used to supplant, rather than supplement the county budget; (2) the expenditures that Morris County reimbursed with grant funds were not made within the grant period; and (3) documentation supporting the expenditures was inadequate. The first two deficiencies resulted from Morris County paying for the project with county funds and then reimbursing the county with grant funds. Specifically, Morris County obtained funding for its county-wide communications upgrade project through a series of bonds. The county then purchased the communications equipment, including various types of radios and computer hardware, with the funds obtained through the bonds. After the communications equipment was already purchased, the county applied for and was awarded the three grants, and then drew down the grant funds as a reimbursement for the purchases made prior to the awarding of the grants. The funds for each grant were deposited directly into the county’s capital account to reimburse the county’s previous expenditures.

We found that Morris County supplanted county funds with grant funds. According to the 1994 Crime Act, federal funds may not be used to supplant state or local funds but instead are to be used to increase the amount of funds available from state or local sources.⁴ Further, in the assurances section of each of the grant agreements signed by Morris County officials, Morris County acknowledged that Technology Initiative Grant funds would not be used to supplant (replace) state or local funds that otherwise would be made available for the purposes of the grants. Morris County used grant funds to reimburse, or replace county funds that had already been spent on the project. By doing so, the grant funds were not used to increase the amount of funding available for the project, as required in the 1994 Crime Act, and the assurances signed by Morris County officials.

In addition to supplanting its budget, Morris County failed to provide documentation demonstrating that the expenditures it made in support of its communications upgrade were made within the approved grant period. According to the OJP Financial Guide, a grantee is prohibited from expending grant funds either prior to the grant start date or after the ending date of the grant. We asked Morris County to show us how money from the three grants was spent. In response, it provided documentation for equipment that was purchased with county funds prior to the grant award dates. Morris County officials told us that the grant funds were used to reimburse those expenditures made before the grant period. Thus, the purchases were unallowable because they were made prior to the grant start date.

We also analyzed the documentation submitted by Morris County, and found that it did not support the specific costs of the equipment purchased with county funds, because it did not provide the per-unit cost of the equipment purchased or the number of items purchased.

In the second finding area, Financial Status Reports (FSR), we found that Morris County did not submit all 20 quarterly Financial Status Reports for the grants as required by the Office of Justice Programs (OJP) Financial Guide. Further, we found that the two FSRs that Morris County did complete were not submitted in a timely manner and did not accurately reflect activities associated with the grants.

The documentation Morris County provided was also insufficient to allow us to assess budget management and control. As noted above, Morris County did not provide supporting documentation for the per-unit cost of the equipment purchased or the number of items purchased with county funds. As a result, we were unable to correlate expenditures with the approved budget amounts for each of the three grants.

In addition to the issues of material non-compliance noted above, we also determined that Morris County did not create or maintain separate program accounts for the three grants it received. We found that the grantee’s accounting records did not link grant expenditures to grant receipts. Finally, we found that the county’s accounting records were insufficient to allow us to assess inventory control over the equipment purchased for the communications upgrade project.

In assessing Morris County’s performance in meeting grant objectives and overall accomplishments, we found that the communications system met expectations and was being utilized by public safety organizations throughout the county.

These items are discussed in detail in the Findings and Recommendations section of the report. Our audit objectives, scope, and methodology appear in Appendix I.

We discussed the results of our audit with Morris County and have included their comments in the report as applicable. In addition, we requested a response to our draft audit report from COPS, and their response is appended to this report. We did not request a response to our draft audit report from Morris County at the time the draft report was issued.