This is the accessible text file for GAO report number GAO-10-661R entitled 'Oversight of DOJ Funds for Recreational Activities' which was released on July 19, 2010. This text file was formatted by the U.S. Government Accountability Office (GAO) to be accessible to users with visual impairments, as part of a longer term project to improve GAO products' accessibility. Every attempt has been made to maintain the structural and data integrity of the original printed product. Accessibility features, such as text descriptions of tables, consecutively numbered footnotes placed at the end of the file, and the text of agency comment letters, are provided but may not exactly duplicate the presentation or format of the printed version. The portable document format (PDF) file is an exact electronic replica of the printed version. We welcome your feedback. Please E-mail your comments regarding the contents or accessibility features of this document to Webmaster@gao.gov. This is a work of the U.S. government and is not subject to copyright protection in the United States. It may be reproduced and distributed in its entirety without further permission from GAO. Because this work may contain copyrighted images or other material, permission from the copyright holder may be necessary if you wish to reproduce this material separately. GAO-10-661R: United States Government Accountability Office: Washington, DC 20548: June 18, 2010: The Honorable Tom Coburn, M.D. United States Senate: Subject: Oversight of DOJ Funds for Recreational Activities: Dear Senator Coburn: The Department of Justice (DOJ) awards an array of law enforcement and criminal justice grants to states, localities, and private and not-for- profit organizations to help prevent crime in their communities. From fiscal years 2008 through 2009, DOJ's Office of Justice Programs (OJP) awarded over 7,900 grants totaling over $4.2 billion.[Footnote 1] Some DOJ grant programs emphasize the prevention of crime and juvenile delinquency, and in some instances, DOJ's grant funds have been used, in part, to support recreational activities for youth involving various sports programs and field trips. In addition, DOJ grant recipients, such as a state's department of juvenile justice services, may provide grant funds to a subgrantee, like the Boys and Girls Club of America, to carry out various activities, such as mentoring or antigang initiatives, within the overall parameters of the grant program. However, no DOJ grant programs are designed to fund recreational activities exclusively. This letter responds to your request to determine (1) the extent to which DOJ tracks grant funds spent on recreational activities, and how, if at all, DOJ assesses the impact of federally funded recreational activities on crime prevention and reduction; and (2) how much DOJ grant funding has been used to support recreational activities. As discussed with your staff in March 2010, DOJ does not maintain, and is not required to maintain, the information necessary to consistently determine (a) if recreational activities were funded through a DOJ grant program, and the impact of those activities, or (b) specific funding amounts used to support such activities. Such determinations would require a baseline definition of what a "recreational activity" would encompass, and a requirement and method for grant recipients to document the specific scope, nature, associated costs, and impact of each specific activity carried out under the grant. Absent this information from DOJ, we sought to independently identify and isolate recreational activities that were funded through various DOJ grant programs, but were unable to identify their scope, nature, cost, and impact due to various challenges. In particular, when reviewing selected grant recipients' program descriptions, we experienced difficulty distinguishing between the recreational and nonrecreational activities grant recipients implemented. Moreover, in cases where program descriptions identified activities that could be considered recreational in nature, we were consistently unable to determine the specific costs of these activities. Thus, as agreed with your staff in March 2010, given the limitations in available data on the nature and costs of grants awarded for recreational activities, this letter (1) elaborates on the extent to which DOJ gathers and maintains information on grant recipients recreational activities, and (2) discusses challenges and limitations we encountered in analyzing a sample of DOJ grant documents. To conduct our work, we interviewed officials from DOJ's Office of Justice Programs, Bureau of Justice Assistance (BJA), Office of Juvenile Justice and Delinquency Prevention (OJJDP), and Community Capacity Development Office (CCDO).[Footnote 2] Specifically, we gathered details on their grant management and reporting requirements and discussed which specific DOJ grant programs officials believed may allow for grant recipients to fund activities that could be considered recreational, given the authorized purposes of the program. These generally consisted of programs that focused on crime prevention and reduction strategies within the juvenile population. We consulted with DOJ and drew a nongeneralizable sample of eight DOJ grant programs that we believed were the most likely to fund activities that could be considered recreational. We reviewed the department's solicitations for these programs, as well as grant recipients' applications--including narratives outlining how they plan to implement the award--and budget reports.[Footnote 3] In addition, we reviewed applicable laws and regulations concerning DOJ grant management requirements. For additional details of our scope and methodology, as well as the list of grant programs we selected and the individual grant files we reviewed, please see enclosure I. We conducted our work from November 2009 through June 2010 in accordance with all sections of GAO's Quality Assurance Framework that are relevant to our objectives. The framework requires that we plan and perform the engagement to obtain sufficient and appropriate evidence to meet our stated objectives and to discuss any limitations in our work. We believe that the information and data obtained, and the analysis conducted, provide a reasonable basis for any findings and conclusions in this product. While Some DOJ Grant Programs May Allow Funding for Recreational Activities, DOJ Does Not Gather or Maintain Specific Information on These Activities: According to DOJ officials, grant recipients may use grant funding to support activities that could be considered recreational, where allowable under the terms of the grant. However, the department does not fund any grant programs that support recreational activities exclusively nor does it define or track "recreational activities" among the various initiatives that grant recipients are implementing to execute their overall grant program objectives. For example, DOJ officials explained that grant recipients may be funded to target activities toward a particular purpose, such as crime prevention. While executing its program, the grant recipient may decide that an after-school sports program might support its overall objectives. Although a sports program may be permissible under the grant, DOJ is not required to maintain information--nor does it require reporting by grant recipients--on specific expenditures for recreational activities or the outcomes associated with those activities. Instead, DOJ requires that grant recipients report in the aggregate about the effectiveness of their overall strategies. Specifically, while DOJ requires grant recipients to report on the degree to which certain performance metrics are met, these metrics are tied to the overall purpose of the grant program--crime prevention, for example--and do not drill down to detect the significance or effectiveness of each individual activity. For example, BJA's Gang Resistance Education and Training Program (G.R.E.A.T.) requires grant recipients to report outcome data to measure: (1) the increase in the number of school-aged children who graduate from G.R.E.A.T. over the prior year; and (2) the increase in the number of middle school youth who improve their positive perception of law enforcement over the prior year. However, G.R.E.A.T grant recipients that may be funding specific activities, such as field trips, with their award are not required to delineate the specific purpose or impact of the field trip because the overall G.R.E.A.T reporting requirements are associated only with high-level grant program goals and performance measures. Because DOJ does not require grant recipients to report on specific expenditures associated with particular activities, such as an after- school sports program, and because it does not maintain or monitor any data on recreational activities, department officials told us that their overall grant management system was not designed to capture either their contributions to the overall program's effectiveness or the individual costs of particular activities like an after-school sports program. As a result, DOJ is not positioned to determine how much money has been spent on recreational activities. DOJ officials told us that any funding grant recipients used for recreational activities that support the overall objectives of the grant program would likely be combined with other activities in their grant files, such that it would be challenging to separate out dollars spent on recreational activities from other funded activities. In addition, even if information of this kind were more readily available in grant recipients' grant files, because DOJ does not have the software or databases to extract it in an automated manner, DOJ officials told us the department would have to collect it manually, which they reported would be labor-intensive and time-consuming, involving a content analysis of thousands of documents submitted by hundreds of grantees. Challenges and Limitations We Encountered When Analyzing a Sample of DOJ Grant Documents: We independently reviewed a nongeneralizable sample of DOJ grant recipients' reporting documents, including financial statements, and encountered challenges attempting to isolate activities that were recreational in nature. Specifically, we experienced difficulties distinguishing recreational from nonrecreational activities because some documents we reviewed lacked necessary detail. For example, one grant recipient's narrative statement about the use of its grant funds indicated that some of its funding was to be used for a crime- prevention program designed to occupy children during the early evening hours after school. However, the document did not include a description of what specific activities the program included and, as a result, we could not verify whether recreational activities were or were not funded through the grant. In other cases, it was difficult to determine if a funded activity was recreational in nature or not. For example, the documentation we reviewed for a grant to an Indian reservation indicated approval to use DOJ funds for what the tribe called a "restitution craft project," whereby children made crafts they later gave to the victims of their crimes. While craft-making could be considered a recreational activity, because the intent of the tribal activity was to provide a therapeutic and delinquency- prevention benefit to those involved, it is unclear whether or not it should be considered recreational in nature.[Footnote 4] Moreover, in cases where grant recipients' program narratives identified activities that could be considered recreational in nature, such as trips to bowling alleys and water parks, we were consistently unable to determine funding amounts spent on these activities. DOJ does not require grant recipients to itemize and associate costs with each individual activity in their quarterly financial reports and budget narratives. In particular, DOJ's budget reporting guidance stipulates that grant recipients report their expenditures by specific categories, such as travel, consultants/contracts, construction, supplies, and equipment. Because grant recipients whose reports we reviewed did not itemize their expenses by each individual activity, we were unable to determine specific funding spent on a recreational activity versus other funded activities. As a result, a review of additional DOJ grant files is unlikely to provide any more specific information on the nature of and costs associated with recreational activities funded through DOJ grant programs. Agency Comments: We requested comments on a draft of this report from DOJ on June 1, 2010. However, in an e-mail received on June 7, 2010, DOJ's liaison stated that DOJ did not have any written or technical comments to our report. Based on our discussion of these issues with your staff in March, this correspondence reflects the agreement we reached to not do any further work on this request. Also, as agreed with your offices, unless you publicly announce the contents of this report earlier, we plan no further distribution until 30 days from the report date. At that time, we will send copies of this report to the Department of Justice's Attorney General and interested congressional committees. In addition, this report will be available at no charge on GAO's Web site at [hyperlink, http://www.gao.gov]. If you or your staff have any further questions on this correspondence or wish to discuss this further, please do not hesitate to contact me at (202) 512-9627 or MaurerD@gao.gov: Sincerely yours, Signed by: David C. Maurer: Director, Homeland Security and Justice Issues: [End of section] Enclosure I: Sample Selection Process: To select a nongeneralizable sample of Department of Justice (DOJ) grant programs to review, we identified all the various grant programs within the Bureau of Justice Assistance, Office of Juvenile Justice and Delinquency Prevention (OJJDP), and Community Capacity Development Office (CCDO) for the 2008 award year. We chose 2008 because according to DOJ officials, grant recipients receiving awards in that year would have submitted several progress reports to DOJ that we could obtain to facilitate our review.[Footnote 5] To confirm our understanding, we then consulted with DOJ to select grant programs that based on the award solicitation description, could have funded the types of activities that could be considered recreational; however, we did not apply a specific definition for "recreational activities" to our analysis, given the subjective nature of the term. These programs generally focused on juveniles and crime prevention and reduction strategies. From these grants programs, we then identified and selected those that we believed had the greatest likelihood of funding activities that could be considered recreational in nature. As a result, our sample consisted of eight grant programs, from which we then selected the grant recipients within each program that received the largest amounts of funding in 2008.[Footnote 6] In cases where multiple grant recipients received equal amounts of funding, we selected grant recipients that were geographically dispersed. In total, from the eight grant programs in our sample, we selected 16 individual grant recipients. We then reviewed their grant file documentation. These documents included individual grant program solicitations, grantee applications, quarterly financial reports, grantee budget documents and performance reports, and any available assessments conducted.[Footnote 7] Table 1 provides a brief description for each of the DOJ grant programs and individual grantees we selected. Table 1: DOJ Grant Programs and Grantees Selected: Bureau of Justice Assistance: Gang Resistance Education and Training Program (G.R.E.A.T.): The G.R.E.A.T. Program is a school-based, law enforcement officer- instructed classroom curriculum with prevention as its primary objective. The program is intended as an immunization against delinquency, youth violence, and gang membership; Grantees: New York City Police Department, New York; and Phoenix Police Department, Arizona. Office of Juvenile Justice and Delinquency Prevention Formula and Block Grants: Title II Formula Grants: This program provides funding to states to develop programs to address juvenile delinquency and improve the juvenile justice system; Grantees: New York Division of Criminal Justice Services, New York; and Texas Office of the Governor, Criminal Justice Division, Texas. Title V Community Prevention Grants Program: This program funds local efforts to reduce risk factors for juvenile delinquency and to enhance factors to prevent youth at risk of becoming delinquent and entering the juvenile justice system. Specifically authorized activities include, among other things, "recreation services;" Grantees: Florida Department of Juvenile Justice, Florida; and Idaho Department of Juvenile Corrections, Idaho. Office of Juvenile Justice and Delinquency Prevention Discretionary Grants: National Mentoring Programs: This program supports mentoring programs that have national scope and impact on combating juvenile delinquency, reducing the victimization of children, and improving the juvenile justice system. It establishes programs that offer a mixture of core services and engage youth with activities that enable them to practice healthy behaviors. The target population is youth at risk for gang activity, delinquency, and youth violence; Grantees: Boys and Girls Club of America; and Big Brother Big Sisters of America. Tribal Youth Program: This program supports and enhances tribal efforts to prevent and control delinquency and improve the juvenile justice system for American Indian/American Native youth. Awards are for direct service prevention programs to federally recognized tribes to develop and implement culturally sensitive delinquency prevention programs, alcohol and substance abuse prevention programs, and mentoring program services; Grantees: Red Lake Band of Chippewa Indians; and White Earth Reservation Tribal Council. Part E Congressionally Directed Grants: While no solicitation description was given, OJJDP told us that they believed some congressionally directed grantees funded recreational activities, and also addressed juvenile delinquency and crime prevention; Grantees: Abyssinian Development Corporation; Big Brothers Big Sisters of Alaska; and Midnight Basketball League of Richmond, Virginia. Community Capacity Development Office: Weed and Seed Program Guide and Application Kit: Continuation Sites: The Weed and Seed strategy aims to prevent, control, and reduce violent crime, criminal drug-related activity, and gang activity. It is a community-based, comprehensive multi-agency approach that focuses on: (1) Law Enforcement; (2) Community Policing; (3) Prevention, Intervention, and Treatment; and (4) Neighborhood Restoration. A Weed and Seed Community (WSC) must be developed in partnership with a variety of key local organizations and the local United States Attorney's Office. A WSC must work to improve the quality of life for residents by redeploying existing public and private resources to address crime and social related problems that may lead to violent crime, drug abuse, and gang activity; Grantees: Modesto Paradise South, Modesto, California. Weed and Seed Communities Competitive Program Guide and Application Kit: This program's mission is also to prevent, control, and reduce violent crime, drug abuse, and gang activity. It is a community-based, comprehensive multi-agency approach to law enforcement, crime prevention, and neighborhood restoration. It is designed for communities with persistent high levels of serious violent crime and corresponding social problems; Grantees: Urban Rock Hill, Rock Hill, South Carolina; and Ferguson Road Initiative, Dallas, Texas. Source: GAO analysis of DOJ data. [End of table] [End of section] Footnotes: [1] In fiscal year 2009, OJP also awarded an additional 3,883 grants under the American Recovery and Reinvestment Act of 2009, Pub. L. No. 111-5, 123 Stat. 115 totaling more than $2.74 billion to state, local, and tribal law enforcement and community organizations. [2] We focused on these three DOJ components because DOJ agreed with our initial determination that BJA, OJJDP, and CCDO would be the most likely to have grant programs funding recreational activities. Specifically, BJA's grant programs aim to, among other things, provide training and technical assistance to prevent crime, drug abuse, and violence at the national, state, and local levels and develop state and local collaborations and partnerships. OJJDP's grants support states and communities that seek to develop and implement effective and coordinated prevention and intervention programs and improve the juvenile justice system to protect public safety, hold offenders accountable, and provide treatment and rehabilitative services tailored to the needs of juveniles and their families. Lastly, CCDO's grants support local communities in the pursuit of deterring crime, promoting economic growth, and enhancing quality of life. [3] The department issues grant solicitations to provide information on grant recipient eligibility requirements, including reporting requirements and application procedures. Grant recipients' budget documents provide information on their planned expenditures, quarterly financial outlays, and obligations for the reporting period. [4] As DOJ does not have a baseline definition for recreational activities, we did not apply a specific definition for the term recreational activities to our analysis, but rather used our own judgment as to what a recreational activity may encompass. [5] Specifically, DOJ officials said that some grant funding for 2009 was not awarded until later in that year. As a result, they told us that some 2009 grantees had not likely expended their funds or submitted progress reports to DOJ to date that we could obtain and evaluate during the period of our review. [6] Because OJJDP officials informed us that some activities that could be considered recreational in nature may have been funded by congressionally directed grants, we selected several of these grants from 2008 to include in our sample. [7] Grant program solicitations provide information on grant recipient requirements, including reporting requirements, application procedures, etc.; Grantee applications include a narrative outlining how the grant recipient plans to implement the grant program award. Quarterly financial reports provide information on total outlays and obligations for each recipient for the reporting period. Performance reports provide information on how the grant recipient achieved the metrics included in the original solicitation. 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