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entitled 'Faith-Based and Community Initiative: Improvements in 
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Report to Congressional Requesters: 

United States Government Accountability Office: 

GAO: 

June 2006: 

Faith-Based And Community Initiative: 

Improvements in Monitoring Grantees and Measuring Performance Could 
Enhance Accountability: 

Faith-Based and Community Initiative: 

GAO-06-616: 

GAO Highlights: 

Highlights of GAO-06-616 a report to congressional requesters 

Why GAO Did This Study: 

The Administration’s efforts to improve the federal government’s 
provision of social services through its Faith-Based and Community 
Initiative have sparked considerable interest. GAO was asked to examine 
(1) the activities of the initiative-related centers in five federal 
agencies; (2) the grant award procedures for selected grants; (3) the 
extent to which selected federal and state agencies are providing 
information on and ensuring compliance with safeguards designed to 
protect faith-based organizations (FBO), beneficiaries, and the 
government; and (4) how the progress of the initiative is being 
measured. We interviewed government officials administering 10 grant 
programs and officials from 26 FBOs. 

What GAO Found: 

In 2001 the Administration introduced the Faith-Based and Community 
Initiative and established initiative-related centers in five federal 
agencies. The centers employ a range of activities and resources to 
implement the initiative. Since fiscal year 2002, these centers have 
cumulatively spent more than $24 million on administrative activities. 

In reviewing grant applications and awarding grants, federal and state 
agencies reported using the same process for FBOs as they do for other 
organizations in the 10 grant programs we reviewed. Since 2001, federal 
agencies have awarded over $500 million through new grant programs to 
provide training and technical assistance to faith-based and community 
organizations and to increase the participation of these organizations 
in providing federally funded social services. 

The government agencies administering the programs that we reviewed 
provided grantees with some information on the safeguards designed to 
protect the interests of FBOs, beneficiaries, and the government. Most 
of the agencies provided grantees with an explicit statement on the 
safeguard prohibiting the use of direct federal funds for inherently 
religious activities. If these activities are offered, they must be 
offered separately in time or location from services provided with 
direct federal funds and must be voluntary for the beneficiary. 
However, we found that Justice’s regulation and guidance related to 
these activities is unclear for its correctional programs. We also 
found that only four programs provided a statement on the rights of 
program beneficiaries and only three provided information on 
permissible hiring by FBOs. While officials in all 26 FBOs that we 
visited said that they understood that federal funds cannot be used for 
inherently religious activities, a few FBOs described activities that 
appeared to violate this safeguard. Four of the 13 FBOs that provided 
voluntary religious activities did not separate in time or location 
some religious activities from federally funded program services. 
Government agencies are not required to monitor FBO grantees 
differently than secular organizations. Few of the federal and state 
agencies administering these programs included references in their 
monitoring guidelines on grantee compliance with the safeguards. 

OMB and the White House Office of Faith-Based and Community Initiatives 
assess agencies’ progress in implementing the short-term goals of the 
initiative and highlight this progress through a number of published 
vehicles. However, it is unclear whether the data reported on grants 
awarded to FBOs provide policymakers with a sound basis to assess the 
progress of agencies in meeting the initiative’s long-term goal of 
greater participation of faith-based and community organizations. 
Moreover, little information is available to assess progress toward 
another long-term goal of improving participant outcomes because 
outcome-based evaluations for many pilot programs have not begun. Also, 
OMB faces other challenges in measuring and reporting on agencies’ 
progress in meeting the long-term goals of the initiative. 

What GAO Recommends: 

We recommend that the Director of the Office of Management and Budget 
(OMB) ensure that all agencies with initiative-related centers include 
information on the safeguards in grant documents and in monitoring 
guidelines, improve data on grants awarded to FBOs, and develop a plan 
for reporting on progress toward the initiative’s long-term goals. OMB 
generally agreed but expressed some concerns about the practicality of 
implementing a few of the recommendations. We also recommend that the 
Department of Justice clarify its regulations on allowed activities and 
clarify relevant language in its contracts, and Justice generally 
agreed. 

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-616]. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Andrew Sherrill at (202) 
512-7252 or ASherrill@gao.gov. 

[End of Section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

Centers Employ Different Activities and Resources to Implement the 
Initiative: 

Agencies Use Same Grant Award Procedures for Faith-Based as Other 
Organizations, and Some New Grant Programs Established to Encourage 
More Faith-Based and Community Organization Participation: 

Government Agencies Generally Provide Grantees with Information on 
Safeguards, but Most Do Not Have Procedures in Their Monitoring 
Guidelines for Assessing Compliance: 

OMB and WHOFBCI Assess Agencies' Progress in Implementing Initiative, 
but Data Limitations and a Lack of Information May Hinder Ability to 
Measure Progress toward Achieving Initiative's Long-Term Goals: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments: 

Appendix I: Centers' Estimated Expenditures by Category, Fiscal Year 
2005: 

Appendix II: Selected Characteristics of Faith-Based Organizations GAO 
Visited: 

Appendix III: Best Practices for the Initiative's Standards for 
Success: 

Best Practices for Outreach and Technical Assistance: 

Best Practices for Implementation of Equal Treatment Regulations: 

Appendix IV: Comments from the Department of Justice: 

GAO Comments: 

Appendix V: Comments from the Department of Education: 

Appendix VI: Comments from the Department of Health and Human Services: 

Appendix VII: Comments from the Department of Housing and Urban 
Development: 

Appendix VIII: Comments from the Department of Labor: 

Appendix IX: GAO Contacts and Staff Acknowledgments: 

Tables: 

Table 1: Executive Orders Related to the Faith-Based and Community 
Initiative: 

Table 2: Equal Treatment Safeguards and the Key Parties They Are 
Designed to Protect: 

Table 3: Selected Federal Programs Providing Funding to Various 
Organizations, Including Faith-Based Organizations: 

Table 4: New Grant Programs Intended to Encourage Faith-Based and 
Community Organization Participation in Federally Funded Social 
Efforts: 

Table 5: Extent to Which Safeguards Are Included in Program Grant 
Documents: 

Table 6: OMB's Green and Yellow Standards for Success for Executive 
Agencies with Centers for the Faith-Based and Community Initiative: 

Table 7: Most Required Outcome Evaluations Not Completed, and Some 
Design Plans May Not Support an Evaluation of Program Outcomes: 

Figure: 

Figure 1: Estimated Expenditures of Centers for Faith-Based and 
Community Initiatives, Fiscal Years 2002 through 2005: 

Abbreviations: 

FBCI: Faith-Based and Community Initiatives: 
FBO: faith-based organization: 
HHS: Department of Health and Human Services: 
HUD: Department of Housing and Urban Development: 
OMB: Office of Management and Budget: 
PMA: President's Management Agenda: 
WHOFBCI White House Office of Faith- Based and Community Initiatives: 

United States Government Accountability Office: 
Washington, DC 20548: 

June 19, 2006: 

The Honorable George Miller: 
Ranking Minority Member: 
Committee on Education and the Workforce: 
House of Representatives: 

The Honorable Pete Stark: 
Ranking Minority Member: 
Subcommittee on Health Committee on Ways and Means: 
House of Representatives: 

Each year the federal government provides billions of dollars to 
organizations that provide social services to needy families and 
individuals. In large part, these funds are provided through 
competitive grants and contracts either directly to organizations or 
through formula grants passed through state agencies to local 
organizations. Organizations providing these services have 
traditionally included both secular and faith-based organizations 
(FBO), which include churches and religiously affiliated entities. In 
the past, as a condition of receiving public funds, FBOs were required 
to secularize their services and premises so that their social service 
activities were distinctly separate from their religious 
activities.[Footnote 1] More recently, courts have become less 
concerned with the religious nature of the organization, and in 1996 
Congress enacted "charitable choice" provisions which authorized 
religious organizations[Footnote 2] to compete on the same basis as 
other organizations for federal funding under certain programs without 
having to alter their religious character.[Footnote 3] 

In 2001, the President created the White House Office of Faith-Based 
and Community Initiatives (WHOFBCI) to establish policies, priorities, 
and objectives to further expand the work of faith-based and community 
organizations. In that same year, the President, by executive order, 
created centers for the Faith-Based and Community Initiatives (FBCI) in 
five federal agencies that administer a broad range of social service 
programs.[Footnote 4] Then, through a series of executive orders, the 
President incorporated charitable choice principles in social service 
programs administered by federal agencies, created initiative-related 
centers in six additional federal agencies,[Footnote 5] and established 
fundamental principles for FBOs receiving federal funds. Modeled after 
the charitable choice legislation, these principles included safeguards 
designed to protect the interests of FBOs, beneficiaries receiving 
social services, and government agencies providing federal funds. For 
example, FBOs are allowed to retain religious icons and symbols in the 
facilities where they provide services and generally are not prohibited 
by federal law from making employment decisions based on religious 
grounds, even after receiving federal funds. However, they are not 
permitted to provide "inherently religious" activities such as prayer 
or worship with direct federal funds or discriminate against 
beneficiaries on the basis of religion. 

The Administration's efforts to expand opportunities for these 
organizations and to strengthen their capacity to provide social 
services through its initiative has sparked considerable interest both 
among various parties involved in providing social services and among 
researchers, religious leaders, and other groups. Some have lauded 
efforts to encourage more FBOs to seek federal funds, maintaining that 
these organizations are more in tune with the needs of their 
communities than other organizations and can better serve individuals 
that may need a range of social services. Others have expressed 
concerns about the potential for federal funds to be used for religious 
purposes and the extent to which organizations are monitored to ensure 
the appropriate use of federal funds. Government agencies primarily 
monitor grantees by reviewing grantee documents, conducting site 
visits, and conducting single audits. The Single Audit Act requires 
state and local governments and nonprofit organizations that expend 
$500,000 or more in federal awards in a fiscal year to have a single 
audit, which is an audit of the federal grantee's financial statements 
and compliance with laws and regulations governing federal awards. 
While government agencies are responsible for ensuring that grantees 
comply with grant requirements, little is known about how these 
agencies are working with FBOs to ensure that these organizations 
understand and comply with the safeguards. 

In addition, a sound performance and reporting system for the 
initiative is important in light of claims by some interested parties 
that the initiative has increased participation by faith-based and 
community organizations in providing federally funded social services. 
It is also important as Congress is likely to continue to discuss 
efforts to formalize--by establishing in statute--the WHOFBCI and the 
work activities within the federal centers for the faith-based and 
community initiative. An informed debate about these issues is helped 
by the availability of credible performance information focusing on the 
outcomes achieved with budgetary resources and other tools.[Footnote 6] 

To shed light on how centers and federal agencies are carrying out the 
initiative and how the government is assessing the initiative's 
performance, you asked us to explore the work of the centers and 
agencies in implementing the initiative, including the extent to which 
government entities are providing guidance to, and oversight of, faith- 
based grantees. 

Specifically, you asked: 

1. How do the activities and resources of the initiative-related 
centers in five federal agencies compare? 

2. What are the grant award procedures for selected project and formula 
grants, and are they the same for all grant applicants, including FBOs? 

3. To what extent are selected federal and state agencies providing 
information on and ensuring compliance with the safeguards designed to 
protect the interests of FBOs, beneficiaries, and the government? 

4. How is the federal government measuring the progress of the 
initiative? 

To understand how the centers administer the initiative, we interviewed 
center officials in the five agencies that were the first to establish 
centers for the Faith-Based and Community Initiative. These are the 
Departments of Education (Education), Health and Human Services (HHS), 
Housing and Urban Development (HUD), Justice, and Labor. We analyzed 
data on their expenditures and work activities and, to assess the 
reliability of the data for expenditures, we conducted semistructured 
interviews with agency officials about data quality control procedures 
and reviewed relevant documentation. We determined the data were 
sufficiently reliable for the purposes of this report. Our review 
focused on 10 programs, including at least 1 program from each of these 
five agencies. To obtain information on how these agencies award and 
monitor grants to FBOs, we interviewed program officials administering 
six federal project grants (competitive project grants awarded by a 
federal agency directly to a local organization), and one competitive 
procurement program. We chose programs that awarded grants to numerous 
FBOs and that provided a range of social services, including mentoring 
of children, housing for the homeless, and business development grants 
to refugees.[Footnote 7] We also met with federal program officials 
responsible for overseeing three formula grant programs (program grants 
that are passed through state agencies to local organizations) that 
attract or are likely to attract significant FBO 
participation.[Footnote 8] For the 10 programs included in our review, 
we also analyzed pertinent documents provided to grantees and 
prospective grantees, such as grant applications, contracts, and award 
letters. Our findings pertain to the 10 programs included in our review 
and are not generalizable to all programs administered by these five 
agencies. To understand how the federal government measures the 
progress of the initiative, we spoke with officials from the Office of 
Management and Budget (OMB) and analyzed pertinent documents. 

To obtain more specific information on how the three formula grants are 
awarded by the states to local organizations and how their grantees are 
monitored for compliance with the safeguards, we visited four states-- 
California, Georgia, Ohio, and Texas--and interviewed numerous state 
officials. We also interviewed county officials in California and Ohio 
and several federal regional and field office program staff. We chose 
these states because they each received significant funding from 
federal direct programs in 2003 or 2004 and because FBOs in these 
states received funds from at least 3 or more of our selected programs. 
In addition, we considered geographic dispersion and diversity in terms 
of whether the state established an initiative-related center.[Footnote 
9] 

We also conducted semistructured interviews with 26 selected FBOs in 
these four states to determine their understanding of program 
regulations and the extent to which they have been monitored for 
compliance with the key safeguards related to the initiative. We 
selected FBOs that had received federal project and formula grants in 
2003 or 2004 from the 10 programs included in our review. Finally, we 
interviewed independent auditors in three states who had completed 
single audits for a few of our selected FBOs. Because we used a 
nonprobability sample of FBOs, our findings are not generalizable to 
all FBOs receiving federal funds from the programs included in our 
review. Our work was conducted from March 2005 through June 2006 
according to generally accepted government auditing standards. 

Results in Brief: 

The five centers for faith-based and community initiatives that we 
reviewed employ a range of activities and resources to implement the 
initiative, in part based on what activities center officials 
determined was necessary to fulfill their responsibilities for the 
initiative and differences in center staffing levels and administrative 
costs. One of the centers' first tasks was to identify and eliminate 
barriers to the participation of faith-based and community 
organizations in federally funded services. The centers' ongoing 
efforts include collecting data on FBOs' participation in federal grant 
programs, developing pilot programs, and providing outreach and 
technical assistance to faith-based and community organizations. The 
centers adopted different approaches to technical assistance training 
activities based on what they needed to do to support the initiative. 
In general, HUD's and Education's centers help organizations learn how 
to apply for funds, while Labor's center helps grantees learn how to 
manage grants. Justice's and HHS's centers coordinate with program 
offices that provide training to these organizations. The next phase of 
the centers' work will focus on encouraging partnerships between faith- 
based and community organizations and state and local governments. 
Since fiscal year 2002, the five centers estimated that they had 
cumulatively expended more than $24 million on administrative 
activities, but these estimates generally did not include additional 
funding that agency program offices provided to assist in the 
initiative's implementation, such as administrative costs associated 
with program offices' efforts to assist faith-based and community 
organizations. In fiscal year 2005, four of the centers spent the 
largest proportion of their funding on staff salaries and benefits-- 
ranging from 35 percent to 87 percent--followed by other expenditures 
for such administrative costs as rent, contracts, and travel. Factors 
such as the number of staff and differences in administrative costs 
such as rent and travel account for, in part, the differences in 
resources across centers. 

Federal and state officials told us they do not treat FBOs any 
differently than other organizations during the grant award process in 
the 10 federal programs we examined. Some new programs have been 
established since the beginning of the initiative to provide training 
and technical assistance to faith-based and community organizations and 
increase faith-based and community organization participation in 
delivering federally funded services. In the programs we reviewed, 
agencies used standard criteria and independent reviewers to evaluate 
applications for funding, and reviewers do not necessarily know whether 
an applicant is faith-based because organizations are generally not 
required to identify themselves as FBOs. Funding decisions were 
generally based on applicants' scores that were awarded for various 
criteria, such as the quality of the project plan. While the process to 
award funds is the same for faith-based as for other organizations, 
between fiscal years 2002 and 2005, federal agencies have awarded over 
$500 million through new competitive grant programs that are intended 
to encourage greater participation of faith-based and community 
organizations in providing these social services. Some of these 
programs, such as Labor's Prisoner Reentry Initiative, limit 
eligibility to these organizations, while others, such as HHS's 
Compassion Capital Fund Demonstration Program, fund intermediary 
organizations that provide capacity-building assistance to faith-based 
and community organizations. 

The government agencies administering the programs that we reviewed 
provided grantees with some information on the safeguards designed to 
protect FBOs, their clients, and the government, but few agencies 
included in their monitoring guidelines checks for grantee compliance 
with the safeguards related to nonallowable activities and 
nondiscrimination against beneficiaries. Specifically, 7 of the 10 
federal programs that we reviewed provided a statement to grantees 
regarding the prohibition on the use of direct federal funds for 
inherently religious activities. Officials at Justice told us that they 
believe FBOs in the Community Corrections Contracting program are 
exempt from the prohibition on providing inherently religious 
activities because of an exception specified in the agency's 
regulations. However, we believe that the scope of this exception is 
left unclear and thus could create uncertainty for FBO program staff 
about allowable religious activities using federal funds. Regarding the 
safeguards on nondiscrimination against beneficiaries and permissible 
hiring by FBOs, only 4 provided a statement on nondiscrimination and 
only 3 provided information on permissible hiring by FBOs based on 
religion. While officials in all 26 FBOs that we visited told us that 
they understood that federal funds could not be used for inherently 
religious activities, 4 of the 13 FBOs that offered voluntary religious 
activities--such as prayer or worship--did not appear to understand the 
requirement to separate these activities in time or location from their 
program services funded with federal funds. For example, one FBO 
official told us that she discusses religious issues while providing 
federally funded services if requested by a participant and no other 
participants object, and a few told us that they pray with 
beneficiaries during program time if requested by the beneficiary. 
Government agencies are not required to monitor FBO grantees 
differently than secular organizations. Only 2 of the 7 federal 
agencies providing project and procurement grants, and 5 of the 13 
state agencies administering formula grants included references in 
their monitoring guidelines on grantee compliance with these 
safeguards. Agencies' single audit reviews, which can be used as an 
effective tool to monitor organizations, only apply to those 
organizations expending $500,000 or more in federal funding in a given 
year, and generally do not include specific checks for these 
safeguards. 

OMB and WHOFBCI assess agencies' progress in implementing the short- 
term goals of the initiative, but data limitations--such as the 
difficulty in identifying an FBO--and a lack of publicly available 
information hinder the federal government's efforts to measure 
agencies' progress in achieving the initiative's two long-term goals. 
OMB and WHOFBCI assess agencies' implementation of the initiative and 
grade agencies' efforts to carry out activities in accordance with the 
Standards for Success that outline the centers' responsibilities, such 
as collecting accurate data on the participation of faith-based and 
community organizations and conducting outcome evaluations of all pilot 
programs. OMB and WHOFBCI award a green grade to agencies that meet all 
of the initiative's standards for success. In the first quarter of 
fiscal year 2006, three of the five centers we reviewed received green 
status. OMB established two long-term goals for the initiative--greater 
participation by faith-based and community organizations and improved 
participant outcomes--but data limitations may hinder efforts to assess 
the initiative's progress in achieving these goals. Importantly, there 
are no criteria for what constitutes a faith-based organization that 
all agencies must use to identify FBOs, and FBOs are not required to 
self-identify, leaving individual agencies and states to determine 
which organizations are faith-based. Determining what elements 
constitute an FBO is challenging. Although no method can ensure that 
all data collected are accurate, having consistently applied criteria 
or requiring self-identification would provide greater assurance that 
agencies are collecting accurate data than the current method. 
Moreover, while the WHOFBCI has published data on trends of FBO 
participation in providing federally funded social services, it has not 
reported on the participation of community-based organizations--the 
other group of organizations specified in the long-term goal. 
Consequently, it is unclear whether the reported data by the WHOFBCI 
provides policymakers with a sound basis to assess the progress of 
agencies in meeting the initiative's long-term goal of greater 
participation of faith-based and community organizations. Progress in 
achieving the initiative's long-term goal of improved participant 
outcomes is not yet known because most agencies have not completed the 
OMB-required outcome-based evaluations of their pilot programs. Of the 
15 pilot programs under way, 1 outcome-based evaluation has been 
completed, 6 evaluations are under way, and 6 are planned. Outcome- 
based evaluations are not planned for 2 of the pilot programs. Outcome- 
based evaluations may involve several years of data collection before 
the analysis can take place and several of these pilot programs were 
initiated only a few years ago. OMB also faces other challenges in 
measuring and reporting on how agencies are progressing toward 
accomplishing the initiative's two long-term goals. 

To improve grantee understanding and federal agency oversight of the 
equal treatment regulations for programs in which faith-based 
organizations are eligible for federal funding, we recommend that the 
Director of OMB ensure that all agencies with initiative-related 
centers include information on the equal treatment safeguards in their 
grant documents and direct agencies to include a reference to these 
safeguards in their monitoring tools. To ensure that contractors for 
Justice's correctional programs understand the exception to the 
prohibition on using federal funds for inherently religious activities, 
we recommend that the Attorney General clarify the exception in 
Justice's equal treatment regulations and include a clear explanation 
of the exception and its scope in the contracts for its correctional 
programs. To improve accountability of the Faith-Based and Community 
Initiative, we recommend that the Director of OMB work with agencies to 
improve how federal agencies identify which organizations are faith- 
based and develop a plan for measuring and reporting on agency progress 
in achieving the long-term goals of the initiative. 

We received comments from Education, HHS, HUD, Justice, Labor and OMB 
on a draft of this report. OMB officials stated that they generally 
agreed with the report's recommendations, although they had comments 
pertaining to several of the recommendations. With regard to our 
recommendation that program-specific single audit supplements include a 
reference to the equal treatment safeguards, OMB stated that for some 
programs that already have extensive audit requirements, expanding the 
program-specific audit requirements could pose additional burdens to 
the independent auditors conducting those reviews. In response, we 
modified the recommendation to indicate that it might not be 
appropriate to include a reference to the equal treatment safeguards in 
some program-specific audit supplements. OMB officials raised issues 
with our recommendation pertaining to getting better data, saying that 
while they agreed that obtaining better data would be helpful, there 
are obstacles to obtaining better data and that they are uncertain 
about the extent to which the data could be further improved. While we 
acknowledge the challenges in obtaining data, various agency centers or 
program offices are currently applying criteria--whether explicitly or 
implicitly--that determine whether they categorize an organization as 
an FBO, and we believe that greater consistency in their use of 
criteria could improve the data. With regard to our recommendation that 
OMB develop a plan to measure and report out on long-term goals, OMB 
said it was reasonable for OMB to report out on the results of 
agencies' outcome evaluations of pilot programs but that the White 
House was already reporting data on participation of faith-based 
organizations. OMB proceeded to acknowledge that there is a lack of 
clarity about how the two long-term goals of the initiative are linked 
with OMB's Standards for Success and that it may be appropriate to 
clarify their connection as part of a reassessment of the long-term 
goals. In response, we broadened the wording of our recommendation to 
note that it may be appropriate to clarify the connection of the long- 
term goals to the Standards for Success. In its comments, Justice 
generally agreed with the two recommendations we made to the Attorney 
General. Justice, Education, HHS, HUD, and Labor raised various issues 
with the report, which we discuss and respond to in the agency comments 
section of the report and appendix IV on Justice's comments. Education, 
HHS, HUD, Labor and OMB also provided technical comments, which we 
incorporated where appropriate. 

Background: 

Citing the crucial role faith-based and community organizations play in 
areas such as curbing crime and overcoming addiction, in 2001 the 
President introduced the WHOFBCI with the goal of expanding 
opportunities for these organizations and to strengthen their capacity 
to provide social services. The President issued executive orders that 
created the WHOFBCI, initiative-related centers in several federal 
agencies, and rules to ensure that organizations are treated equally in 
government programs. 

Executive Orders Establish Centers and Responsibilities: 

Beginning in January 2001, the President issued several executive 
orders to implement the Faith-Based and Community Initiative (see table 
1). These executive orders established a WHOFBCI and centers for faith- 
based and community initiatives in a number of federal agencies as well 
as principles for ensuring equal treatment of faith-based and community 
organizations in federal government programs. 

Table 1: Executive Orders Related to the Faith-Based and Community 
Initiative: 

Executive order: Executive Order 13199 January 29, 2001; 
Purpose: Created the White House Office of Faith-Based and Community 
Initiatives; 
Description: The White House Office of Faith-Based and Community 
Initiatives is given lead responsibility to establish policies, 
priorities, and objectives for efforts to expand opportunities for 
faith-based and community organizations to provide social and community 
services. 

Executive order: Executive Order 13198 January 29, 2001; 
Purpose: Created Centers for Faith-Based and Community Initiatives in 
five agencies: Education, HHS, HUD, Justice, and Labor; 
Description: To coordinate agency efforts to eliminate obstacles to the 
participation of faith-based and community organizations in providing 
federally funded social services. 

Executive order: Executive Order 13280 December 12, 2002; 
Purpose: Created centers for Faith-Based and Community Initiatives in 
two additional agencies: Department of Agriculture and Agency for 
International Development; 
Description: To coordinate agency efforts to eliminate obstacles to the 
participation of faith-based and community organizations in providing 
federally funded social and community services. 

Executive order: Executive Order 13279 December 12, 2002; 
Purpose: To provide, among other things, guidance to federal agencies 
in formulating policies regarding faith-based and community 
organizations and to ensure equal protection under the laws for these 
organizations; 
Description: Set out criteria on fundamental principles and 
policymaking that designated federal agencies can use in establishing 
safeguards applicable to FBOs providing services under federal 
programs. 

Executive order: Executive Order 13342 June 1, 2004; 
Purpose: Created centers for Faith-Based and Community Initiatives in 
three additional agencies: Departments of Commerce and Veterans Affairs 
and the Small Business Administration; 
Description: To coordinate agency efforts to eliminate obstacles to the 
participation of faith-based and community organizations in providing 
federally funded social and community services. 

Executive order: Executive Order 13397 March 7, 2006; 
Purpose: Created Center for Faith-Based and Community Initiatives in 
the Department of Homeland Security; 
Description: To coordinate agency efforts to eliminate obstacles to the 
participation of faith-based and community organizations in providing 
federally funded social and community services. 

Source: GAO analysis of White House Office of Faith-Based and Community 
Initiatives Information. 

[End of table] 

These executive orders identify the key responsibilities for each 
center: 

* an agencywide audit of barriers to participation of faith-based and 
community organizations in delivery of social services; 

* removal of barriers to these organizations' participation in 
providing federally funded social and community services; 

* a comprehensive effort to incorporate faith-based and community 
organizations in department programs and initiatives; 

* development of pilot and demonstration programs to increase these 
organizations' participation in federal, state, and local initiatives; 
and: 

* development and coordination of outreach efforts to disseminate 
information more effectively to these organizations. 

The executive orders also direct the centers to coordinate their 
activities with the WHOFBCI. Centers do not award any federal funds to 
faith-based and community organizations. However, they coordinate with 
agency program offices that are responsible for awarding federal funds 
and monitoring grantees. For example they review program funding 
guidance to ensure that the program does not contain barriers to these 
organizations' participation and interact with agency program offices 
to develop and coordinate department efforts to disseminate information 
more effectively to faith-based and community organizations with 
respect to programming changes, contracting opportunities, and other 
department initiatives. 

Equal Treatment Regulations Set Forth Safeguards Applicable to Direct 
and Formula Federal Grants: 

As noted in table 1, Executive Order 13279 of December 12, 2002, 
directed designated federal agencies to establish safeguards for the 
participation of faith-based organizations in a broad set of federal 
social service programs, including mentoring, housing, and job training 
programs. Congress had previously enacted charitable choice provisions 
as part of the Temporary Assistance for Needy Families (TANF) program, 
Community Services Block Grant program, and the Substance Abuse 
Prevention and Treatment Block Grant several years earlier.[Footnote 
10] 

To implement this executive order, federal agencies with centers for 
the faith-based and community initiative subsequently issued "equal 
treatment" rules. These rules apply to project grants awarded by the 
federal government to faith-based and community organizations, formula 
and block grants awarded to states where funds are passed down to these 
organizations, and other financial agreements.[Footnote 11] These rules 
state that FBOs are eligible to participate in federal programs on the 
same basis as other private organizations, and include safeguards to 
protect the interests of FBOs, beneficiaries of social services, and 
government agencies providing funds (see table 2). For example, FBOs 
are not permitted to use direct federal funds for inherently religious 
activities such as prayer, religious instruction, worship, or 
proselytization. If an FBO conducts such activities, the activities 
must be separated by time or location from federally funded services or 
programs and must be voluntary for the beneficiary. However, they are 
allowed to retain religious art, icons, or symbols in the facilities 
where they provide services. In addition, for the programs in our 
review, FBOs generally are not prohibited under federal law from making 
employment decisions based on religious grounds, even after receiving 
federal funds. 

Table 2: Equal Treatment Safeguards and the Key Parties They Are 
Designed to Protect: 

Safeguards: FBOs are eligible to compete for funding on the same basis 
as other nonprofit organizations; 
Government entities: [Empty]; 
FBOs: X; 
Beneficiaries: [Empty]. 

Safeguards: FBOs may not use direct government funds[A] to support 
inherently religious activities such as prayer, worship, religious 
instruction, or proselytization. Any inherently religious activities 
must be offered separately in time or location from services directly 
funded with government assistance and must be voluntary for 
participants; 
Government entities: X; 
FBOs: [Empty]; 
Beneficiaries: X. 

Safeguards: FBOs retain control over their internal governance and do 
not have to remove religious art, icons, and symbols; 
Government entities: [Empty]; 
FBOs: X; 
Beneficiaries: [Empty]. 

Safeguards: FBOs cannot discriminate on the basis of religion or 
religious belief in providing services to clients; 
Government entities: [Empty]; 
FBOs: [Empty]; 
Beneficiaries: X. 

Safeguards: FBOs generally retain the ability to make employment 
decisions on religious grounds, even after receiving federal funds.[B]; 
Government entities: [Empty]; 
FBOs: X; 
Beneficiaries: [Empty]. 

Source: GAO analysis. 

[A] This safeguard does not apply to federal funds provided indirectly 
to religious organizations. For example, it does not apply to funds 
that a provider receives as a result of an independent choice of a 
beneficiary, such as programs that provide vouchers to beneficiaries 
who then redeem the vouchers for services at a provider of their 
choice. Providers may offer voluntary religious activities without 
separation of time or location from the social service if beneficiaries 
are given a genuine choice between faith-based and secular service 
providers as part of indirect funding, such as a voucher program. 

[B] There are exceptions to this protection as some programs, such as 
Workforce Investment Act programs and Head Start, currently contain 
statutory language that prohibits faith-based organizations receiving 
funds from making employment decisions on religious grounds. In 
addition, FBOs may be subject to state or local laws prohibiting 
discrimination in employment based on religion. 

[End of table] 

Charitable choice provisions enacted by Congress for the TANF and 
Substance Abuse Prevention and Treatment programs contain an additional 
safeguard that entitles clients who object to the religious character 
of a provider to receive services from an alternative provider to which 
the client has no religious objection. However, this safeguard is not 
part of the equal treatment rules agencies issued in response to the 
President's 2002 executive order and does not apply to other federal 
programs. 

During the federal rule-making process for the equal treatment 
regulations, some interested parties expressed a need for greater 
clarity and safeguards in the proposed rules. For example, commenters 
stated that it was unclear which activities would be considered 
"inherently religious." Agencies declined to clarify which activities 
would be considered inherently religious apart from the general 
examples provided in the agencies' respective rules, noting the 
difficulty in establishing a list of such activities and that the 
Supreme Court has not comprehensively defined these 
activities.[Footnote 12] Of the agencies we reviewed, most cited the 
Supreme Court decision of Mitchell v. Helms as support for the view 
that aid provided to religious institutions does not necessarily 
advance the institutions' religious purposes and emphasized the secular 
nature of the federally funded services.[Footnote 13] The regulations 
state that if a grantee engages in religious activities such as prayer, 
such activities must be voluntary for the beneficiary and the grantee 
must offer them separately in time or location from the programs funded 
with direct federal financial assistance.[Footnote 14] 

Some commenters on agencies' equal treatment regulations also urged 
agencies to adopt additional assurances to prevent funds from being 
diverted for improper religious purposes.[Footnote 15] However, in 
their final rules, agencies stated they found no basis for requiring 
additional assurances or greater oversight and monitoring of FBOs, as 
all participants must comply with all rules applicable to federal 
grants, including the equal treatment rules. In addition, they stated 
that agencies' current monitoring and oversight practices for all 
grantees would be sufficient to ensure that federal funds are used for 
eligible activities. 

Agencies Monitor Grantees Through Various Means, Including Desk Audits, 
Site Visits, and the Single Audit: 

Federal agencies monitor their grantees for programmatic and financial 
compliance. OMB provides general guidance, through Circular A-110, on 
the administration by federal agencies of grants to and agreements with 
nonprofit organizations.[Footnote 16] OMB guidance also notes that the 
awarding agency may make site visits part of its monitoring procedures, 
but it does not require site visits or prescribe how many grantees 
should be visited or how often. 

Nonfederal entities (i.e., state, or local government, or a nonprofit 
organization) that expend $500,000 or more annually in federal awards 
are required to have a single audit conducted for that year. The Single 
Audit Act, as amended, replaced multiple audits of separate grant 
awards with one organizationwide audit.[Footnote 17] Federal awarding 
agencies are responsible for such tasks as issuing a management 
decision on audit findings within 6 months after receiving the audit 
report and ensuring that the recipient takes appropriate and timely 
corrective action.[Footnote 18] OMB Circular A-133 requires the auditor 
to report on compliance, and include an opinion by the auditor as to 
whether the entity complied with laws, regulations, and grant 
agreements. In addition, federal agencies provide specific audit 
guidelines for selected programs that direct the auditor to check for 
program-specific compliance requirements. For example, program- 
specific compliance requirements include a section on allowable and 
unallowable activities that detail what a grantee can and cannot do 
with federal funds in a particular program. For those programs that do 
not have program-specific guidelines, an auditor is to use the more 
general single audit guidance provided by OMB. 

Centers Employ Different Activities and Resources to Implement the 
Initiative: 

The five centers for faith-based and community initiatives that we 
reviewed employ a range of activities and resources to implement the 
initiative, in part based on what activities center officials believed 
was necessary to fulfill their responsibilities for the initiative and 
differences in staffing levels and administrative costs. Initially, the 
centers' activities focused on identifying and eliminating barriers to 
the participation of faith-based and community organizations in 
federally funded services. The centers' ongoing efforts include 
collecting data on FBOs' participation in agency programs, implementing 
pilot programs, and providing outreach and technical assistance to 
these organizations. The centers adopted different approaches to 
technical assistance training activities. The centers' future work will 
focus on encouraging partnerships between faith-based and community 
organizations and state and local governments, according to center 
officials. The centers estimated that they have cumulatively spent more 
than $24 million on administrative activities, although their resource 
levels and administrative costs varied depending on the number of staff 
members and rent and travel costs. 

Centers Have Acted to Remove Barriers to Faith-Based and Community 
Organizations, Collect Data, and Tailor their Outreach and Assistance 
Efforts to Meet the Agencies' Needs: 

Initially, the centers set out to identify and eliminate barriers to 
the participation of faith-based and community organizations in 
federally funded services. These barriers included regulations, rules, 
and outreach activities that either discriminated against or 
discouraged the participation of these organizations in federal 
programs. To identify barriers, the centers reviewed selected programs 
and gathered information on program eligibility and program 
regulations, among other things. Each center submitted a report to the 
White House with its findings, and in August 2001 the White House 
published the results of the centers' efforts.[Footnote 19] 
Specifically, the report found that the centers identified barriers 
such as programs that excluded FBOs from applying for federal funds, 
confusion on the part of agency officials and FBOs about the ability of 
FBOs to consider religion in employment decisions, complex grant 
applications and agreements, and limited accessibility of federal grant 
information. Each center then issued equal treatment rules in 
2004.[Footnote 20] These rules were intended to help ensure that faith- 
based and community organizations could compete on the same basis as 
other organizations for federal funds while retaining their 
independence and protecting the rights of beneficiaries of social 
services. The adopted rules were largely identical across each agency. 

Since 2003 the centers have collected data on, and WHOFBCI has reported 
on, funds awarded to FBOs in direct grant programs that allow faith- 
based and community organization participation.[Footnote 21] The White 
House published the results for all five agencies for fiscal years 2003 
through 2005, characterizing the information as a snapshot of federal 
grants awarded to FBOs. For the fiscal year 2005 data collection 
effort, the centers also obtained these data from state and local 
governments administering formula grants. The centers we reviewed each 
tracked funding to FBOs for one formula grant program within their 
agencies. The White House notes that because the majority of federal 
social service dollars are awarded through formula grants, such a 
review is critical for understanding the extent of FBO participation. 
Center officials noted that they do not have a standard definition to 
identify FBOs, leaving each center, some working with program offices, 
with the responsibility of identifying FBOs using a combination of 
methods. For example, a nonprofit organization that applies for federal 
funds may self-identify as a faith-based organization or a community- 
based organization as part of a voluntary survey that is included in 
grant application packages.[Footnote 22] In cases where an organization 
elects not to complete this survey, center officials told us that 
program and center staff applied a number of other methods to identify 
organizations, including the review of information from grant 
applications, information provided by program staff familiar with the 
organization, Internet research, or name recognition. 

Each center has also assisted in developing pilot programs within its 
agency to strengthen the partnership between faith-based and community 
organizations and federal agencies. In general, these programs provide 
services related to the policy focus of each agency. For example, Labor 
has pilot programs to build partnerships between faith-based and 
community organizations and the workforce system. Similarly, Education 
implemented a program to educate these organizations on how to become 
providers of supplemental educational services. Most of Labor's and 
HHS's pilot programs, as well as one of HUD's two pilot programs, 
represent new grant programs that either award funds directly to faith- 
based and community organizations or to intermediary organizations that 
help these organizations expand their services. In contrast, HUD's 
second pilot program and most of the pilot programs at Education and 
Justice do not provide funds directly to faith-based and community 
organizations or intermediaries. Education and HUD's programs provide 
information and technical assistance to these organizations to help 
them access federal funds or provide services, while Justice's pilot 
programs promote the participation of faith-based and community 
organizations in areas such as juvenile offender mentoring and fraud 
prevention. 

In addition, the centers provide outreach and technical assistance 
activities to enhance the opportunities of faith-based and community 
organizations to compete for federal funding. To inform these 
organizations about the resources available to them, the centers engage 
in similar outreach activities such as posting grant and funding 
opportunities on center Web sites and disseminating information to 
these organizations via e-mail. However, the centers adopted different 
approaches to their technical assistance training activities. In 
general, HUD's and Education's centers help organizations learn how to 
apply for funds, while Labor's center helps grantees learn how to 
manage grants. Justice's and HHS's centers coordinate with program 
offices that provide these services. Center officials said their 
approaches to technical assistance were based on what they determined 
would best meet needs within their agency and fulfill their 
responsibilities to enhance opportunities for faith-based and community 
organizations. For example, HUD's center--citing the need to educate 
faith-based and community organizations on how to access resources to 
meet needs in their communities--has conducted a series of free grant- 
writing seminars for faith-based and community organizations since 
2004. HUD has also designated staff in each of its regional and field 
offices to serve as faith-based and community liaisons and to provide 
outreach to these organizations. Education's center sponsors technical 
assistance workshops for faith-based and community organizations that 
provide information on the agency's grant opportunities as well as 
information on how organizations can become approved providers of 
supplemental educational services. 

Labor's center reported that the large size of Labor's grant programs 
was an obstacle that prevented small grassroots organizations, 
including those that are faith-based, from participating in its 
programs. As a result, Labor's center officials said they tailored 
their outreach and technical assistance efforts to focus on providing 
assistance to smaller organizations to build their capacity to manage 
grants and to encourage partnerships between small grassroots 
organizations and the workforce system. For example, the Labor center 
sponsors technical assistance training for small faith-based and 
community organization grantees on how to manage grants and measure 
program effectiveness, among other things. In contrast to the centers 
at HUD, Education, and Labor, the Justice and HHS centers coordinate 
efforts with program offices that provide these services. Among these 
services are grant-writing seminars provided through the Substance 
Abuse and Mental Health Services Administration (SAMHSA) in HHS and the 
Office of Juvenile Justice and Delinquency Prevention in Justice. 
Center officials at the Justice and HHS centers told us that they 
adopted this approach to take advantage of efficiencies from working 
with program offices that provided these services prior to the creation 
of the centers. 

According to center officials, the next phase of the centers' work will 
focus on encouraging the establishment of state and local government 
partnerships with faith-based and community organizations, as the 
majority of federal social service funds are distributed through 
formula grant programs administered at the state and local levels. OMB 
has directed each center to help implement an action plan to enhance 
the opportunities of faith-based and community organizations competing 
for federal funds provided through state and local governments, and to 
provide guidance to state and local officials on the equal treatment 
rules. The President has also encouraged states to create offices or 
liaisons to provide information and resources for faith-based and 
community organizations interested in partnering with state and local 
governments to provide social services. Thirty-two states have now 
established state offices or liaisons for faith-based and community 
organizations, according to the White House. 

Five Federal Centers Cumulatively Spent $24 Million since Fiscal Year 
2002, but Their Funding Sources, Staffing Levels, and Administrative 
Costs Varied: 

The five centers that we reviewed estimated that they cumulatively 
spent more than $24 million on administrative activities related to the 
initiative since fiscal year 2002, although the level of resources and 
their application varied across the five centers. As shown in figure 1, 
centers in HHS, HUD and Labor spent between $1 million and $2.3 million 
annually, while centers in Education and Justice spent less than $1 
million annually. HHS, HUD and Labor's centers also had more staff in 
fiscal year 2005 than Education and Justice. In fiscal year 2005, HHS, 
HUD, and Labor had between 7 and 9 staff members, while Education and 
Justice had 5.5 and 3 respectively.[Footnote 23] In Labor, Education, 
and Justice's centers, the majority of the center staff members were 
appointed rather than career staff. 

Figure 1: Estimated Expenditures of Centers for Faith-Based and 
Community Initiatives, Fiscal Years 2002 through 2005: 

[See PDF for image] 

Source: GAO analysis of Education, HHS, HUD, Justice, and Labor data. 

Note: Figures adjusted for inflation. Education's fiscal year 2002 
amount covers the period from May 19, 2002, to September 30, 2002. 

In fiscal year 2005, salaries and benefits of center staff members 
constituted the largest proportion of the funds spent in four of the 
centers,[Footnote 24] ranging from 35 percent to 87 percent of their 
total expenditures.[Footnote 25] The centers' remaining expenditures 
went toward such administrative costs as rent, contractual services, 
travel, printing, and supplies. The centers' estimated expenditures, 
however, do not include other federal initiative-related expenditures, 
such as the administrative costs associated with program offices' 
efforts to assist faith-based and community organizations.[Footnote 26] 
For example, Justice's Office of Juvenile Justice and Delinquency 
Prevention has allocated $1.87 million since fiscal year 2003 to fund 
federal grant application training for community-based, faith-based, 
and other nonprofit organizations. 

Funding for the centers comes from a variety of sources. Education's 
center receives its funding through the Office of the Secretary of 
Education and HUD's center receives its funding through HUD's salaries 
and expenses account, while Justice's and HHS's centers are funded 
through internal agencies such as the Office of Justice Programs in 
Justice and the Administration for Children and Families in HHS. 
Labor's center receives funds from both its agency's departmental 
management account and from program offices. In addition, although not 
required to, HHS has included information on funding for its center as 
part of its congressional budget requests for several years, while HUD 
and Labor have included similar information in past budget requests. 
These agencies have in turn received guidance from Congress in the past 
on the amount of resources to allocate to their centers. In contrast, 
Education and Justice have provided limited or no information on their 
centers' funding to Congress as part of their budget requests. In turn, 
these agencies have not received guidance from Congress on the amount 
of resources to allocate to their centers. 

Differences in staffing levels and administrative costs account for, in 
part, the differences in centers' total expenditures. Staff 
compensation represented the largest category of center spending, and 
the centers with the largest number of staff spent the most on 
activities to implement the initiative.[Footnote 27] Different 
administrative costs also accounted for some of the variation in the 
center resources. For example, in fiscal year 2005, HHS spent more on 
rent, communications, and utilities than HUD's center, while centers in 
Education and Labor did not report any expenses for these 
services.[Footnote 28] Centers in HUD and Education spent more in 
travel expenses for fiscal year 2005 than the other centers we 
reviewed. These higher travel expenses were likely associated with the 
training and technical assistance workshops that these centers 
conducted across the country for faith-based and community 
organizations. 

Agencies Use Same Grant Award Procedures for Faith-Based as Other 
Organizations, and Some New Grant Programs Established to Encourage 
More Faith-Based and Community Organization Participation: 

Federal and state officials administering the 10 programs we examined 
told us that they do not treat FBOs any differently than other 
organizations during the grant award process. They use standard 
criteria to assess all applications for grant funds, and grant 
reviewers do not necessarily know if applicants are FBOs because an 
organization is not generally required to identify itself as an FBO 
when applying for funds. While the grant award process was similar for 
all organizations in the competitive programs we reviewed, since the 
beginning of the initiative, agencies have awarded over $500 million 
through new competitive grant programs to provide training and 
technical assistance to faith-based and community organizations and to 
increase the participation of these organizations in providing 
federally funded social services. In its fiscal year 2007 budget 
request, the Administration requested increased funding for some of 
these programs. 

Faith-Based Organizations Compete for Funds on the Same Basis as Other 
Organizations: 

In the funding programs we examined, federal regulations require 
federal and state agencies to use the same processes to evaluate grant 
applications from FBOs as they do applications from other 
organizations.[Footnote 29] When rating each application, reviewers for 
these programs used standard criteria and assigned numerical scores or 
other ratings to assess how well an application addressed the 
criteria.[Footnote 30] Funding decisions are primarily determined by 
these rating scores, although other factors, such as geographical 
dispersion, may be taken into account. For example, selection criteria 
used to evaluate applications in one program included factors such as 
the quality of the project design, quality of project personnel, and 
quality of the project evaluation, with points assigned to each 
criterion. None of the programs we reviewed awarded points specifically 
for faith-based organizations. One of the programs in our review, 
Education's Mentoring Program, awarded five points to "novice" 
organizations applying for mentoring funds in 2002. Novice 
organizations were defined as ones that had never received a grant from 
the program before and had not received a discretionary grant from any 
federal program for 5 years.[Footnote 31] (See table 3 for a listing of 
the programs covered in our review.) 

Table 3: Selected Federal Programs Providing Funding to Various 
Organizations, Including Faith-Based Organizations: 

Program: Mentoring Programs (Safe and Drug-Free Schools and Communities 
National Programs); Agency: Education; Type of funding: Project grants; 
Purpose of program: To promote mentoring programs for children of 
greatest need. 

Program: Community-Based Abstinence Education Program[ A]; 
Agency: HHS; 
Type of funding: Project grants; 
Purpose of program: To provide funding to public and private 
institutions for community-based abstinence education project grants. 

Program: Mentoring Children of Prisoners Program; 
Agency: HHS; 
Type of funding: Project grants; 
Purpose of program: To award grants to organizations, including 
community and faith-based entities, to provide children of incarcerated 
parents with mentors. 

Program: Microenterprise Development Program (Refugee and Entrant 
Assistance Discretionary Grants); 
Agency: HHS; 
Type of funding: Project grants; 
Purpose of program: To assist refugees in starting or expanding very 
small businesses. 

Program: Abstinence Education Program; Agency: HHS; Type of funding: 
Formula grant program; Purpose of program: To enable states to provide 
abstinence education and mentoring, counseling, and adult supervision 
to promote abstinence from sexual activity. 

Program: Substance Abuse Prevention and Treatment Block Grant; 
Agency: HHS; 
Type of funding: Formula grant program; 
Purpose of program: To provide financial assistance to states and 
territories to support projects for the development and implementation 
of programs directed at the prevention and treatment of alcohol and 
drug abuse. 

Program: Continuum of Care (set of three programs: Supportive Housing 
Program, Shelter Plus Care, and Single Room Occupancy); 
Agency: HUD; 
Type of funding: Project grants; 
Purpose of program: To address the problems of homelessness in a 
comprehensive manner. 

Program: Emergency Shelter Grants Program; 
Agency: HUD; 
Type of funding: Formula grant program; 
Purpose of program: To improve the quality of emergency shelters and 
transitional housing for the homeless, to make additional shelters 
available, and to provide services to the homeless. 

Program: Community Corrections Contracting; 
Agency: Justice; 
Type of funding: Competitive procurement program; 
Purpose of program: To provide assistance to inmates who are near 
release and provide a structured, supervised environment and 
counseling, job placement, and other services. 

Program: Small Grassroots Faith-Based and Community-Based Organizations 
Connecting with the One-Stop Delivery System (Small Grassroots 
Program); 
Agency: Labor; 
Type of funding: Project grants; 
Purpose of program: To expand the access of faith-based and community- 
based organizations' clients and customers to the services offered by 
local one-stop centers. 

Source: GAO analysis based on agency information. 

[A] In 2005, the Community-Based Education Program was moved from HHS's 
Health Resources and Services Administration to HHS's Administration 
for Children and Families. 

[End of table] 

Because applicants in most programs we examined are not required to 
identify themselves as FBOs, the grant reviewers do not necessarily 
know whether an applicant is an FBO.[Footnote 32] A voluntary survey 
that may be submitted with the standard federal grant application asks 
the applicant, among other things, to self-identify whether it is a 
faith-based/religious organization or whether it is a nonreligious 
community-based organization. However, federal officials told us that 
this survey, if submitted by the applicant, is removed from the 
application, and is unavailable to the reviewers. Nonetheless, an 
organization's identity might be reflected in its name, or the 
organization might disclose its identity in its application, for 
example, when describing the history or mission of the organization. 

New Programs Established since Initiative to Provide Training and 
Technical Assistance to Faith-Based and Community Organizations and 
Increase Faith-Based and Community Organization Participation: 

In four of the agencies we reviewed, new programs have been created to 
provide training and technical assistance to faith-based and community 
organizations and to increase the participation of these organizations 
in providing federally funded social services. Some of these programs 
are the pilot programs established by the centers and program offices 
in response to the initiative. Between fiscal years 2002 and 2005, over 
$500 million in competitive grants has been awarded through these 
programs.[Footnote 33] Some of these programs, such as Labor's Prisoner 
Reentry Initiative, limit eligibility to faith-based and community 
organizations, while others, such as HHS's Compassion Capital Fund 
Demonstration Program, fund intermediary organizations that provide 
capacity-building assistance to faith-based and community 
organizations. (See table 4 for a list and description of these 
programs.) 

Table 4: New Grant Programs Intended to Encourage Faith-Based and 
Community Organization Participation in Federally Funded Social 
Efforts: 

Program: Access to Recovery[A]; 
Agency: Health and Human Services; 
Start date of program: 2004; 
Total funds awarded through fiscal year 2005: $198,000,000; 
Grantee/subgrantee eligibility: States, District of Columbia, 
territories, and tribal organizations; 
Grant purpose: To provide client choice among substance abuse treatment 
and support service providers, expand access to an array of treatment 
and recovery support options, and increase substance abuse treatment 
capacity. 

Program: Compassion Capital Fund (CCF) Demonstration Grants[A]; 
Agency: Health and Human Services; 
Start date of program: 2002; 
Total funds awarded through fiscal year 2005: $125,594,965; 
Grantee/subgrantee eligibility: Nongovernmental organizations; Indian 
tribal governmental organizations; nonprofit agencies, including faith-
based organizations, public agencies, state and local governments, 
colleges and universities, and for-profit entities; 
Grant purpose: To help smaller organizations manage their programs 
effectively, access funding, train staff, expand programs in their 
communities, and replicate promising programs. Intermediary 
organizations receiving CCF grants also provide subawards to a diverse 
range of faith-based and community organizations. 

Program: Mentoring Children of Prisoners[A]; 
Agency: Health and Human Services; 
Start date of program: 2003; 
Total funds awarded through fiscal year 2005: $100,047,432; 
Grantee/subgrantee eligibility: States, localities, private, nonprofit, 
community and faith-based entities, and coordinated networks of such 
entities; 
Grant purpose: To support the establishment or expansion and operation 
of programs to provide mentoring services for children of incarcerated 
parents. 

Program: Compassion Capital Fund Targeted Capacity-Building Program[A]; 
Agency: Health and Human Services; Start date of program: 2003; 
Total funds awarded through fiscal year 2005: $22,587,556; 
Grantee/subgrantee eligibility: Nonprofit, faith-based, and community 
organizations; 
Grant purpose: To increase the capacity of faith-based and community 
organizations with a proven track record of serving the needs of at-
risk or low-income individuals and families. 

Program: Ready4Work[A]; 
Agency: Labor/Justice; 
Start date of program: 2003; 
Total funds awarded through fiscal year 2005: $21,700,000; 
Grantee/subgrantee eligibility: Public/Private Ventures (non-profit 
organization) provides subgrants to lead agencies at 18 sites; 
Grant purpose: To assist faith-based and community programs that 
provide mentoring and other transition services for men and women 
returning from prison. 

Program: Prisoner Reentry Initiative[A]; 
Agency: Labor/Justice/ HUD[B]; 
Start date of program: 2005; 
Total funds awarded through fiscal year 2005: $19,840,000; 
Grantee/subgrantee eligibility: Faith-based and community 
organizations; 
Grant purpose: To reduce recidivism and re-incarceration by helping 
inmates find work when they return to their communities. 

Program: Grants for States for FBO/ Community-Based Organization 
Partnerships; 
Agency: Labor; 
Start date of program: 2002; 
Total funds awarded through fiscal year 2005: $11,874,147; 
Grantee/subgrantee eligibility: States; 
Grant purpose: To increase the number of faith- based and community-
based organizations serving as committed and active partners in the One-
Stop delivery system. 

Program: Grants for Workforce Investment Boards for FBO/ Community- 
Based Organization Partnerships[A]; 
Agency: Labor; 
Start date of program: 2004; 
Total funds awarded through fiscal year 2005: $10,706,389; 
Grantee/subgrantee eligibility: Workforce Investment Boards; 
Grant purpose: To encourage the formation of long-term partnerships 
with faith-based and community organizations that meet community needs 
related to hard-to-serve populations. 

Program: Grants for Intermediaries for FBO/Community-Based Organization 
Partnerships; 
Agency: Labor; 
Start date of program: 2002; 
Total funds awarded through fiscal year 2005: $9,661,191; 
Grantee/ subgrantee eligibility: Nonprofit, community, or faith-based 
organizations with connections to faith-based and community grassroots 
organizations; 
Grant purpose: To increase the number of faith-based and community-
based organizations serving as committed and active partners in the One-
Stop delivery system. 

Program: Helping Outreach Programs Expand (HOPE); 
Agency: Justice; 
Start date of program: 2002; 
Total funds awarded through fiscal year 2005: $3,675,000; 
Grantee/subgrantee eligibility: Faith-based and community 
organizations; 
Grant purpose: To foster the development of grassroots crime victim 
service providers to expand both public visibility and outreach to 
victims, thereby increasing the number of available service providers. 

Program: Faith and Community-Based Juvenile Delinquency Treatment 
Initiative[A]; 
Agency: Justice; 
Start date of program: 2003; 
Total funds awarded through fiscal year 2005: $3,500,000; 
Grantee/subgrantee eligibility: One grant awarded to Florida Department 
of Juvenile Justice; 
Grant purpose: To establish a multifaceted faith-based initiative to 
provide positive, caring adult relationships, and greater supervision 
and moral leadership as youthful offenders transition back into their 
communities. 

Program: Small Grassroots Faith-Based and Community-Based Organizations 
Connecting with the One-Stop Delivery System (Small Grassroots 
Program)[ A]; 
Agency: Labor; 
Start date of program: 2002; 
Total funds awarded through fiscal year 2005: $3,408,981; 
Grantee/ subgrantee eligibility: Local nonprofit social service 
organizations with $350,000 or less in annual revenues or fewer than 
six employees; 
Grant purpose: To provide workforce services to specific populations or 
provide particular services not currently provided through the One-Stop 
delivery system; expand the access of faith-based and community-based 
organizations' clients and customers to the services offered by the 
local One-Stops; and establish methods and mechanisms to ensure 
sustainability of these partnerships. 

Program: Helping Outreach Programs to Expand II (HOPE II); 
Agency: Justice; 
Start date of program: 2005; 
Total funds awarded through fiscal year 2005: $3,000,000; 
Grantee/subgrantee eligibility: Faith- based and other community 
organizations that will provide subgrants to grassroots, faith-based, 
and community organizations to serve crime victims while also building 
their capacity; 
Grant purpose: To increase the development and capacity of faith-based 
or community-based organizations to respond to underserved victims in 
high-crime urban areas. 

Program: Rural Domestic Violence and Child Victimization Enforcement 
Grant Program Special Initiative: Faith-based and Community 
Organization Pilot Program[A]; 
Agency: Justice; 
Start date of program: 2005; 
Total funds awarded through fiscal year 2005: $1,024,965; 
Grantee/subgrantee eligibility: Community organizations (nonprofit, 
private entities) of rural states and faith-based organizations of 
rural states (nonprofit, private entities). Private entities of 
nonrural states that are members of or central offices of national 
organizations may consider applying through an affiliated organization 
located within a rural state.[C]; 
Grant purpose: To increase the level of services available to rural 
victims of domestic violence by increasing the number of first-time, 
grassroots faith--and/or community-based organizations receiving Office 
of Violence Against Women funding and technical assistance in rural 
America. 

Program: Enhancement of Public Housing HOPE VI Communities through 
Mentoring Demonstration Program[A]; 
Agency: HUD; 
Start date of program: 2005; 
Total funds awarded through fiscal year 2005: $524,578; 
Grantee/ subgrantee eligibility: Public housing authorities with HOPE 
VI Revitalization grants will partner with grassroots, faith-based and 
other community-based organizations; 
Grant purpose: To determine if providing mentoring services to 
residents already participating in self-sufficiency programs increases 
their likelihood of achieving self- sufficiency. 

Program: Clergy Against Senior Exploitation (CASE)[A]; 
Agency: Justice; 
Start date of program: 2002; 
Total funds awarded through fiscal year 2005: $273,614; 
Grantee/subgrantee eligibility: One grant awarded to Denver, Colorado, 
district attorney's office; 
Grant purpose: To partner with faith communities in addressing the 
issue of elder fraud in Denver County. 

Source: GAO analysis based on information on the White House Office of 
Faith-based and Community Initiatives Website and agency documents. 

Note: This table does not include programs that provide only technical 
assistance and not grant funds to faith-based and community 
organizations, such as Education's Supplemental Educational Services 
and HUD's Grant Writing Training program. 

[A] Denotes a pilot program identified as such by Centers for Faith- 
Based and Community Initiatives staff. 

[B] As of April 2006, Justice and HUD had not disbursed any funding 
under the initiative. 

[C] Grantees act as intermediaries and offer subgrants and technical 
assistance to small, faith-based or community organizations with less 
than 10 full-time employees, an annual domestic violence budget less 
than $100,000, and an overall annual operating budget less than 
$350,000. 

[End of table] 

The President proposes $323 million in funds in his 2007 budget 
submission--a 36 percent increase from what was enacted in fiscal year 
2006--for five programs in order to foster faith-based and community 
organization participation.[Footnote 34] The President's budget 
proposes an increase in funding for the Compassion Capital Fund from 
$64 million to $100 million and the Prisoner Re-entry Initiative 
funding from $26 million to $60 million. In an effort to encourage more 
participation by faith-based and community organizations in combating 
the spread of HIV and AIDS, the President proposed new funding for an 
outreach program to the African-American community. 

Government Agencies Generally Provide Grantees with Information on 
Safeguards, but Most Do Not Have Procedures in Their Monitoring 
Guidelines for Assessing Compliance: 

Most of the 10 federal program offices that we reviewed included an 
explicit statement in their grant documents explaining that FBOs cannot 
use direct federal funds for inherently religious activities[Footnote 
35] However, less than half of program offices provided a similar 
statement explaining that organizations may not discriminate against 
beneficiaries based on religion or explaining the permissible hiring 
practices for FBOs. Most of the grant documents related to these two 
safeguards provided only a reference to federal or program regulations, 
and a few program offices provided no information on the 
nondiscrimination and hiring safeguards. In general, state and county 
offices in the four states we visited provided information on the 
safeguards to their formula grant awardees, although in several cases 
they provided incorrect information on whether FBOs may make hiring 
decisions on the basis of religion. While officials in all 26 of the 
FBOs that we visited told us that they understood that federal funds 
could not be used for inherently religious activities, officials at 
several organizations appeared to have misunderstood the safeguard that 
religious activities may only be conducted at a separate time or in a 
separate location from federally funded services. Few government 
agencies administering the programs we reviewed monitor organizations 
to ensure compliance with these safeguards, and the single audit, which 
is used to monitor organizations receiving a certain level of federal 
funding, generally does not include checks for these safeguards. 

Most of the Federal Programs We Reviewed Provided Grantees with a 
Statement on Nonallowable Activities, but Fewer Provided Information on 
Other Safeguards: 

Seven of the 10 programs that we reviewed provided grantees with an 
explicit statement in one or more of their grant documents that federal 
funds for that program could not be expended for "inherently religious 
activities." Most statements noted that organizations receiving direct 
federal funds cannot engage in inherently religious activities, such as 
worship, religious instruction, or proselytization as part of program 
services directly funded with federal funds. For example, Labor sent 
state workforce agencies a guidance letter in July 2005 reiterating its 
equal treatment rules and directing the agencies to develop policies 
and procedures to implement the safeguards. HUD also issued a 
memorandum to state agencies reiterating its equal treatment rules 
pertaining to Emergency Shelter program grantees. Table 5 summarizes 
the extent to which information on each of the safeguards was included 
in programs' grant documents. 

Table 5: Extent to Which Safeguards Are Included in Program Grant 
Documents: 

Safeguards stated In federal documents to grantee[A]: Agency/program;  
Prohibition on inherently religious activities unless separate in time 
or location from federally funded programs or services: [Empty]; 
Prohibition on discrimination against clients based on religion: 
[Empty]; 
Provision explaining permissible hiring by FBOs: [Empty]. 

Safeguards stated In federal documents to grantee[A]: Federal Project 
and Contract Grants: Education/ Mentoring Programs; 
Prohibition on inherently religious activities unless separate in time 
or location from federally funded programs or services: circle; 
Prohibition on discrimination against clients based on religion: 
circle; 
Provision explaining permissible hiring by FBOs: circle. 

Safeguards stated In federal documents to grantee[A]: Federal Project 
and Contract Grants: HHS/Community- Based Abstinence Education 
Program[B]; 
Prohibition on inherently religious activities unless separate in time 
or location from federally funded programs or services: square; 
Prohibition on discrimination against clients based on religion: 
circle; 
Provision explaining permissible hiring by FBOs: circle. 

Safeguards stated In federal documents to grantee[A]: Federal Project 
and Contract Grants: HHS/Mentoring Children Of Prisoners; 
Prohibition on inherently religious activities unless separate in time 
or location from federally funded programs or services: square; 
Prohibition on discrimination against clients based on religion: 
circle; 
Provision explaining permissible hiring by FBOs: circle. 

Safeguards stated In federal documents to grantee[A]: Federal Project 
and Contract Grants: HHS/ Microenterprise Development Program; 
Prohibition on inherently religious activities unless separate in time 
or location from federally funded programs or services: square; 
Prohibition on discrimination against clients based on religion: empty 
square; 
Provision explaining permissible hiring by FBOs: empty square. 

Safeguards stated In federal documents to grantee[A]: Federal Project 
and Contract Grants: HUD/Continuum of Care Program[C]; 
Prohibition on inherently religious activities unless separate in time 
or location from federally funded programs or services: square; 
Prohibition on discrimination against clients based on religion: 
square; 
Provision explaining permissible hiring by FBOs: square. 

Safeguards stated In federal documents to grantee[A]: Federal Project 
and Contract Grants: Justice/Community Corrections Contracting; 
Prohibition on inherently religious activities unless separate in time 
or location from federally funded programs or services: [D]; 
Prohibition on discrimination against clients based on religion: 
circle; 
Provision explaining permissible hiring by FBOs: circle. 

Safeguards stated In federal documents to grantee[A]: Federal Project 
and Contract Grants: Labor/Small Grassroots Program; 
Prohibition on inherently religious activities unless separate in time 
or location from federally funded programs or services: square; 
Prohibition on discrimination against clients based on religion: 
square; 
Provision explaining permissible hiring by FBOs: square. 

Safeguards stated In federal documents to grantee[A]: Formula Grants: 
HHS/Abstinence Education Program; 
Prohibition on inherently religious activities unless separate in time 
or location from federally funded programs or services: square; 
Prohibition on discrimination against clients based on religion: 
square; 
Provision explaining permissible hiring by FBOs: empty square. 

Safeguards stated In federal documents to grantee[A]: Formula Grants: 
HHS/Substance Abuse Prevention and Treatment Block Grant Program; 
Prohibition on inherently religious activities unless separate in time 
or location from federally funded programs or services: circle; 
Prohibition on discrimination against clients based on religion: 
circle; 
Provision explaining permissible hiring by FBOs: circle]. 

Safeguards stated In federal documents to grantee[A]: Formula Grants: 
HUD/Emergency Shelter Grants; 
Prohibition on inherently religious activities unless separate in time 
or location from federally funded programs or services: square; 
Prohibition on discrimination against clients based on religion: 
square; 
Provision explaining permissible hiring by FBOs: square. 

Key: document 
square = provides statement in one or more of the following documents: 
grant application, announcement, or guidance documents 
circle = cites regulations 
empty square = makes no reference to these safeguards: 

Source: GAO analysis based on review of agency documents. 

[A] Documents include grant announcements, applications, award letters, 
and any additional guidance sent to grantees. 

[B] Safeguards were stated more clearly in HHS's Health Resources and 
Services Administration's 2003 and 2004 applications, which included an 
advisory memo and a questions and answers section. Advisory and 
question section was not included in HHS's Administration for Children 
and Families' 2006 application package. However, the program's 
application and grant award letter include a reference to the 
prohibition on inherently religious activities. 

[C] HUD's notice to agency and field office directors providing 
guidance to Continuum of Care grantees covered by HUD's 2003 equal 
treatment regulations expired September 2005. 

[D] Justice officials told us that this safeguard does not apply to 
Community Correction Contracting programs and therefore the agency did 
not include it in the program's contract documents. See discussion 
below. 

[End of table] 

We found no reference to the prohibition on inherently religious 
activities in Justice's Community Corrections Contracting 
program.[Footnote 36] Justice officials advised us that, under their 
equal treatment regulations, they believe that FBOs providing services 
in Community Corrections Centers (also referred to as halfway houses 
that allow inmates to leave the centers for religious services) are 
exempt from the prohibition related to inherently religious activities 
and therefore the agency does not include any reference to the 
prohibition in the contract documents for this program. The regulations 
provide that the restrictions on inherently religious activities do not 
apply where funds are provided to chaplains or organizations assisting 
chaplains in certain settings such as community correction 
centers.[Footnote 37] According to these officials, given the duty to 
accommodate inmates' rights to religious exercise, all FBOs providing 
services are essentially viewed as "assisting chaplains" and fall 
within the exception. Accordingly, Justice officials believe it is 
appropriate not to include any reference to the restriction on 
inherently religious activities in the contract documents for community 
correction centers. 

We believe that the failure by Justice to include any reference to this 
restriction could create uncertainty for FBOs. For example, the 
omission could be read as allowing all providers of social services in 
these settings to engage in worship, religious instruction, or 
proselytization, regardless of whether the services assist chaplains or 
whether the religious activities are voluntary on the part of the 
participant. In other words, the scope of the exception for assisting 
chaplains is left uncertain and FBO program staff may not understand 
whether, to what extent, or under what circumstances, they may engage 
in religious activities using federal funds. 

As table 5 shows, 4 of the 10 programs that we reviewed included an 
explicit statement in grant documents that grantees must not 
discriminate against beneficiaries on the basis of their religion. In 
contrast, most of the other programs refer applicants and grantees to 
either their agency's equal treatment regulations or program 
regulations that contain this safeguard. For example, HHS's Community- 
Based Abstinence Education program refers the applicant to the agency's 
equal treatment regulations,and SAMHSA's Substance Abuse Prevention and 
Treatment Block Grant Program refers states to its charitable choice 
regulations. The Mentoring Children of Prisoners Program added a 
reference to HHS's equal treatment regulation in its June 2006 
announcement. However, we found that in some instances, the cited 
regulations contained out-of-date information on this safeguard. For 
example, HHS's Mentoring Children of Prisoners and Microenterprise 
Development Programs' Standard Terms and Conditions (attached to the 
grant award) cited a Web address for 2003 regulations that did not 
contain the equal treatment safeguards. 

Programs provided the least information on whether FBOs are permitted 
to make hiring decisions based on religion. Of the 10 federal program 
offices that we reviewed, only 3 provided information in grant 
documents about religious organizations' hiring of employees that share 
their religious beliefs. Five other programs referred applicants or 
grantees to the equal treatment regulations, and 2 provided no 
reference to FBO hiring in their grant documents. In addition, 
Justice's contract for its Community Correction Centers contains a 
reference to a clause that cites an executive order that does not apply 
to FBO contractors and thus provides incorrect information on FBO 
hiring.[Footnote 38] The one program in our review--Labor's Small 
Grassroots Program--that is governed by statutory language prohibiting 
FBOs from making employment decisions on religious grounds, includes 
information in its program grant documents explaining the 
prohibition.[Footnote 39] 

The 7 competitive project and procurement grant programs differed with 
respect to whether they provided any training for new grantees on the 
safeguards. Five program offices provided training to grantees that 
included a discussion of the safeguards, while two did not. Officials 
from 2 of the formula grant programs in our review explained how some 
state officials received training on the safeguards. An HHS official 
with the Abstinence Education formula grant program told us that state 
officials attended the February 2006 conference offered to new grantees 
for the Community-Based Abstinence program and were given the 
opportunity to attend breakout sessions that focus on compliance with 
the equal treatment safeguards. SAMHSA officials told us that they hold 
sessions during the semiannual conference that directly discuss 
charitable choice regulations. Applicants and grantees interested in 
learning about the safeguards could also obtain access information on 
an agency's Center for Faith-Based and Community Initiatives Web sites. 

State and County Agencies Provide Grantees Information on Allowable 
Activities and Nondiscrimination of Clients, but Several Provided 
Grantees with Incorrect Information on FBO Hiring: 

For the three formula grant programs we reviewed, the grant program 
documents that state and county agencies provide to applicants and 
grantees contain information on allowable activities and 
nondiscrimination of beneficiaries and, in general, provide more 
explicit information on these two safeguards than the federal agencies. 
In addition, like federal program offices, state and county program 
offices in the four states we visited provided little information on 
FBO hiring, or in several cases, provided incorrect information. For 
example, we found that state and county offices in two states that 
administer the Substance Abuse Prevention and Treatment Block Grant and 
Abstinence Education program provided documents to grantees that 
included incorrect information on whether FBOs could hire based on 
religion. In one case, county officials acknowledged that they provided 
documents that contradicted one another on FBO hiring. They explained 
that one provision of their state contract says that organizations 
cannot discriminate in hiring, while another provision cites charitable 
choice hiring rules. 

Some FBOs We Visited Did Not Appear to Understand the Requirement for 
Separation in Time or Location for Religious Activities and the 
Safeguard Pertaining to Hiring by Religious Organizations: 

Four of the 13 FBOs that we visited that provided voluntary religious 
activities for beneficiaries did not appear to adhere to the 
requirement to separate in time or location religious activities from 
program services funded with direct federal funds. In addition, 13 of 
the 26 did not understand the safeguard that pertained to permissible 
hiring on the basis of religion. On the basis of our discussions with 
FBO officials, we did not find any indications that FBOs did not serve 
a beneficiary based on a beneficiary's religious beliefs. 

While officials in all 26 FBOs that we visited told us that they 
understood the prohibition on providing inherently religious activities 
with direct federal funds, 4 described engaging in activities that 
appear not to be permissible with federal funds under the equal 
treatment rules. For example, officials from 2 of these FBOs told us 
that that they would pray with beneficiaries at the beneficiary's 
request. While voluntary prayer is permissible as long as it is offered 
separately in time or location from program activities conducted with 
direct federal funds, these officials indicated that they conducted 
prayer at the same time and location as their federally funded 
services.[Footnote 40] In addition, an official from another FBO said 
that he began each program session, which provided services to 
children, with a nonsectarian prayer that at times included a brief 
reading from the Bible. Finally, one FBO program manager told us that 
she discussed religious issues during the same time and at the same 
location as federally funded services if requested by a participant and 
no other participants objected. 

One program office has taken action to better define the separate in 
time or location requirement. Included as part of the settlement of a 
lawsuit that arose from the agency's funding of a faith-based sexual 
abstinence education program was a set of "Safeguards Required" drafted 
by HHS's Community-Based Abstinence Education Program office for the 
grantee. This document was intended to provide guidance to the grantee 
for operation of the program in compliance with existing law and 
regulations, and included a detailed explanation of ways in which the 
grantee's activities might be separated in time or location. As of 
March 2006, HHS was considering providing similar information to all 
grantees to more clearly delineate how an organization could separate 
its religious activities from those provided with federal funds, 
according to the abstinence education program director. 

Some FBOs are also confused about the safeguard related to hiring by 
religious organizations. Only half of the 26 FBOs that we visited 
correctly understood whether they could take religion into account when 
hiring staff. In general, FBOs that were prohibited by program 
legislation or state law from considering religion when making 
employment decisions understood the hiring safeguard. For example, 8 of 
the 9 FBOs that we visited in Ohio understood that the state had a 
statute that prohibits discrimination in employment based on 
religion.[Footnote 41] In addition, Labor's Small Grassroots Program is 
governed by statutory language that prohibits organizations from hiring 
based on religion. Program officials with 3 FBOs that had received 
funding from this program told us that they do not hire based on 
religion, and 2 of the 3 noted that the hiring safeguard was discussed 
during Labor's grantee training. Most of the 13 FBOs that did not 
correctly understand the hiring safeguard were unaware that they could 
consider religion when making employment decisions. 

Program Offices Are Not Required to Monitor FBO Grantees Differently 
than Other Grantees, and Few Program Offices in our Review Include 
References in their Monitoring Guidelines on Compliance With 
Safeguards: 

Federal and state program offices are not required under federal 
requirements to monitor FBO grantees any differently than secular 
organizations, and in our review, few program offices use monitoring 
tools that include checks for compliance with these safeguards. Federal 
agencies monitor grantees for compliance with program regulations 
primarily through such monitoring activities as desk audits, site 
visits, and single audit compliance reviews. However, many faith-based 
and community organizations may not be covered by the single audit 
because they do not expend $500,000 or more in federal funds in a given 
year. Further, for those FBOs that do meet this financial threshold, 
single audit guidelines do not generally instruct auditors to check for 
compliance with the equal treatment safeguards. 

Program Offices Monitor Grantees Primarily through Desk Audits and Site 
Visits: 

Federal program offices monitor grantees by reviewing financial reports 
(standard reports that collect data on grantee disbursements) and 
performance reports that grantees submit. Program officials told us 
that they review these reports to identify any financial or 
programmatic issues that may require them to do additional follow-up 
with the grantees. Performance reports focus on programmatic issues and 
collect information on the number of beneficiaries served and program 
outputs. None of the reports that we reviewed contained any questions 
related to compliance with the safeguards. 

Program offices also monitor grantees for compliance with program rules 
through site visits. Many federal officials told us that they use a 
risk-based approach when determining which sites to visit. Several 
program officials told us that they do not single out FBOs for site 
visits and do not consider them at higher risk for noncompliance than 
other organizations. Grantees often selected for visits include ones 
that receive high dollar grants, novice grantees, grantees that have 
had prior problems, and grantees with high staff turnover. Program 
officials typically use written monitoring guidelines or site visit 
protocols when conducting site visits. 

We found that only 2 of the 7 federal direct programs had monitoring 
guidelines that contained any reference to the equal treatment 
safeguards, and one program--established in 2002--had not yet developed 
a monitoring tool. HHS's Community-Based Abstinence Education Program 
recently developed a monitoring tool that includes a question on 
whether the project is being implemented "in a manner consistent with 
all other Federal requirements (e.g., faith-based issues, civil rights, 
etc.)" and whether the grantee is "aware of the regulations regarding 
the use of federal funding for inherently religious activities." 
Similarly, Labor's monitoring handbook contains a general reference to 
avoiding client discrimination, but does not include a discussion of 
compliance with the safeguards. An HHS Mentoring Children of Prisoners 
program official told us that the program office had not yet developed 
a monitoring tool for its mentoring program. 

The number of site visits conducted by program offices varied widely. 
Officials noted that the number of grantees in a given program affects 
how frequently their staff can conduct site visits. A Labor official in 
a field office told us that Labor officials try to visit all Small 
Grassroots Program grantees at least once during the span of the grant. 
HUD officials noted that visiting 10 percent of all grantees annually 
amounted to about 600 visits in 2004, and an Education official noted 
that visiting 5 percent of grantees had become increasingly difficult 
as the number of grantees grew each year. Since its move to HHS's 
Administration for Children and Families from the agency's Health 
Resources and Services Administration in 2005, the Community-based 
Abstinence Education program has conducted two site visits. The 
program's director said he hopes his office will complete around 20 in 
2006, but that he would like to visit all grantees at least once during 
their 3-year grant period.[Footnote 42] 

State and county agencies are responsible for monitoring grantees of 
federal formula grants. Similar to federal agencies, state and county 
officials in the four states we visited conduct desk audits of grantees 
and conduct site visits to a limited number of organizations. Many use 
risk assessment to determine which grantees to visit while others 
attempt to visit all grantees within a certain time frame. Only 5 of 
the 13 state or county program offices we visited included a reference 
to the prohibition on using direct federal funds for inherently 
religious activities or services. Georgia's monitoring tool for its 
Emergency Shelter Grants program states that housing and services are 
to be provided in a "manner that is free from religious influence," and 
its abstinence education performance and outcome scorecard has a space 
for organizations to indicate that their "curriculum does not teach or 
promote religion." Similarly, Texas' abstinence education on-site 
evaluation report includes as one of its review criteria a check to 
ensure that direct federal funds are not used for sectarian worship, 
instruction, or proselytization. In addition, the monitoring manual for 
Sacramento County, California, includes a check to ensure that grantees 
include in their program policies and procedures information on the 
requirement that FBOs certify that they will comply with all the 
requirements of SAMHSA's charitable choice provisions and implementing 
regulations. 

Single Audits Are Also Used to Monitor Grantees, but Guidelines Do Not 
Consistently Reference Safeguards: 

Program offices also use the single audit to monitor recipients that 
expend $500,000 or more in federal funds in a fiscal year. OMB provides 
specific audit guidelines for some programs. While three programs we 
reviewed--the Substance Abuse Prevention and Treatment Block Grant 
Program, Emergency Shelter Grants, and the Continuum of Care Supportive 
Housing Program--have program-specific guidance, they varied on whether 
and how they included information on the equal treatment 
regulations.[Footnote 43] For example, single audit guidance for the 
Substance Abuse Prevention and Treatment Block Grant Program provided 
the auditor with audit steps related to the equal treatment provision 
prohibiting organizations from expending direct federal funds on 
inherently religious activities, while Emergency Shelter Grant guidance 
refers the auditor to the program regulations that discuss what faith- 
based organizations can and cannot do with direct federal funds. In 
contrast, the single audit guidance on HUD's Supportive Housing Program 
contains no reference to the prohibition on using direct federal funds 
for inherently religious activities. 

The other 7 programs we reviewed do not have OMB program-specific audit 
guidelines. OMB's single audit guidelines used for programs that do not 
have program-specific guidelines also contain no reference to the 
prohibition on using direct federal funds for inherently religious 
activities. Instead, OMB's general guidelines direct auditors to refer 
to grant documents or laws and regulations to determine which 
activities are allowed or unallowed with federal funds. We interviewed 
three independent auditors, who told us that unless these safeguards 
were referenced in the single audit guidelines or included in grant 
documents--which typically outline the key provisions of the grant--an 
auditor would not likely test for compliance with these provisions. Two 
auditors we interviewed noted that they did not check for the 
safeguards because the safeguards were not referenced in the single 
audit guidelines for HUD's Continuum of Care and, at that time, 
SAMHSA's Substance Abuse Prevention and Treatment Block Grant Program, 
the two programs administered by the FBOs they audited. The other 
auditor, who had recently audited an FBO that had received an 
Abstinence Education grant, told us that he had developed his own audit 
plan by reviewing the grant application package. He explained that 
because he readily found a reference in the application to the 
prohibition on providing inherently religious activities, he was able 
to discuss with the program manager how this issue was conveyed to 
program staff and reviewed written feedback from the students to 
ascertain whether any religious discussions had occurred while staff 
were providing federally funded services.[Footnote 44] 

OMB and WHOFBCI Assess Agencies' Progress in Implementing Initiative, 
but Data Limitations and a Lack of Information May Hinder Ability to 
Measure Progress toward Achieving Initiative's Long-Term Goals: 

OMB and the White House Office of Faith-Based and Community Initiatives 
(WHOFBCI) assess agencies' progress in implementing the initiative and 
highlight this progress through a number of published 
vehicles.[Footnote 45] However, the federal government's efforts to 
assess the initiative's progress in achieving its long-term goal of 
greater participation may be hindered by the accuracy of data collected 
on the number of FBOs receiving federal grants because the government 
has not established consistently applied criteria for what constitutes 
a faith-based organization and has not required organizations to self- 
identify as such. Moreover, little information is available to assess 
agencies' progress toward the long-term goal of improving participant 
outcomes because outcome-based evaluations for most pilot programs have 
not yet been completed. In addition, OMB faces other challenges in 
measuring and reporting on agencies' progress in meeting the two long- 
term goals of the initiative. 

OMB and WHOFBCI Grade Agencies' Progress in Implementing the Initiative 
by Assessing Their Progress on Several Activities: 

Through the President's Management Agenda (PMA) issued in 2001, OMB 
identified expected short-term, intermediate, and long-term results or 
goals for the initiative.[Footnote 46] OMB and WHOFBCI assess and track 
agencies' implementation of the initiative by using the Executive 
Branch Management Scorecard, a traffic-light system showing agencies' 
grades on their efforts to carry out activities in accordance with the 
initiative's Standards for Success. Developed in 2003, the initiative's 
Standards for Success describe expectations on the progress agencies 
are making in implementing certain responsibilities for the initiative, 
such as collecting accurate data on the participation of faith-based 
and community organizations and conducting outcome-based evaluations of 
pilot programs. Center officials at the agencies that we reviewed told 
us that they are focusing their efforts on implementing the standards 
for success and achieving the short-term goals of the initiative. 
Specifically, they are working on "leveling the playing field" for 
faith-based and community organizations to compete for federal funds. 
Table 6 specifies OMB's green and yellow standards for success for the 
initiative, and appendix III lists the best practices that are 
referenced in the Standards for Success. 

Table 6: OMB's Green and Yellow Standards for Success for Executive 
Agencies with Centers for the Faith-Based and Community Initiative: 

GREEN Standards for Success; Agency: 

1. Has implemented a comprehensive outreach and technical assistance 
strategy for enhancing opportunities of faith-based and community 
organizations (FBCO) to compete for federal funding, including working 
with state and local officials to expand access to Federal funding 
awarded through them. This strategy employs 12 of 15 best practices; 

2. Regularly monitors compliance with the equal treatment regulations 
at the State and local levels, promptly addresses violations once they 
are detected, and has a process in place to ensure that compliance 
information is used to inform future funding. Compliance monitoring 
activities include 10 of 13 best practices;[A]; 

3. Collects accurate and timely data on participation of FBCO and other 
applicants, including government entities, in selected Federal non-
formula grant programs and has taken steps to expand data collection 
efforts to formula grant programs and make them a routine part of 
program administration. Programs are working to make this information 
accessible to the public; 

4. Implements pilot programs to strengthen the partnership between FBCO 
and the Federal government to deliver services and inform 
implementation of the Initiative, and expands the use of pilots to test 
new strategies when appropriate; AND;

5. Undertakes outcome-based evaluations of its pilot programs where 
FBCO participate, provides quarterly progress reports and interim 
results to the WHOFBCI throughout the life of the program, and builds 
an evaluation component into new pilots. Incorporated FBCO component 
into broader program evaluations when appropriate. 

YELLOW Standards for Success: 

1. Has developed a comprehensive outreach and technical assistance 
strategy for enhancing opportunities of faith- based and community 
organizations (FBCO) to compete for federal funding, including working 
with state and local officials to expand access to Federal funding 
awarded through them, and has begun to implement the plan. This 
strategy employs 8 of 15 best practices; 

2. Has taken steps to ensure barrier free access for FBCO to the 
Federal competitive grants process. These steps include 7 of 15 best 
practices; 

3. Has established procedures to collect data on participation of FBCO 
in selected Federal programs; 

4. Has implemented pilot programs to strengthen the partnership between 
FBCO and the Federal government to deliver services; AND; 

5. Has undertaken outcome- based evaluations of its first set of pilot 
programs and has provided progress reports to WHOFBCI. 

Source: OMB. 

[A] For compliance monitoring activities, only 3 of the best practices 
pertain to monitoring whereas the other 10 best practices involve 
activities to inform faith-based and community organizations, state and 
local officials, and others about the regulations. 

[End of table] 

OMB and WHOFBCI grade agencies both on current status and on progress 
in implementation. OMB and WHOFBCI award an agency with a green status 
if it meets all of the yellow and green standards for success, yellow 
if it has achieved the yellow but not all of the green standards for 
success, and red if the agency fails to meet any one of the yellow 
standards. OMB and WHOFBCI assess each agency's progress on a quarterly 
basis, and according to OMB officials, they use this performance 
information to identify problems and to develop corrective actions. 

Of the five agencies that we reviewed, three agencies have a green 
status (Education, Justice, and HUD), and two have a yellow status 
(Labor and HHS) for current status during the first 2006 rating 
quarter. These agencies received a green status for progress in 
implementation for the rating quarter except HUD, which was downgraded 
to a yellow status from the previous rating quarter. OMB and agencies 
publish these summary scores in a number of places, such as in OMB and 
agency budget and performance documents as well as on their respective 
Web sites. According to OMB and some center officials, OMB negotiates 
with the agencies on a quarterly basis to set milestones that agencies 
must meet to maintain their green status. 

The OMB Web site contains the Standards for Success for achieving the 
PMA's five governmentwide goals,[Footnote 47] as well as the standards 
for the initiative. It lists the agencies that have performed best in 
meeting the individual standards for success (i.e., getting to green) 
for the goals. 

Efforts to Measure Agencies' Progress toward Achieving Initiative's 
Long-term Goals Is Hindered by Data Limitations and Lack of 
Information: 

Although OMB's scorecard highlights agency progress in implementing the 
initiative, there are difficulties in assessing progress towards the 
two long-term goals for the initiative specified in the PMA. Efforts to 
assess the progress in achieving the initiative's long-term goal of 
increasing participation of faith-based and community organizations is 
hindered in part by difficulties agencies encounter in attempting to 
determine whether or not an organization is faith-based. Further, 
assessing achievement toward the other long-term goal of improving 
participant outcomes is hindered because agencies have not completed 
most of the OMB-required outcome-based evaluations of their pilot 
programs. In addition to the issues already noted, OMB and the WHOFBCI 
face other challenges in measuring and reporting on agencies' progress 
in meeting the broad long-term goals of "greater participation of faith-
based and community organizations" and "improved participant outcomes." 

Data Issues Affect Efforts to Measure Progress of Agencies in Meeting 
Long-Term Goals: 

As set forth in the PMA, one of the long-term goals of the initiative 
is for federal agencies to facilitate greater participation of faith- 
based and community organizations in providing federally funded social 
services. Although the Administration has not defined a "faith-based 
and community organization" or a "faith-based organization," it directs 
the centers for faith-based and community initiatives to collect data 
on federal grants awarded to FBOs and community-based organizations. 
The WHOFBCI has published data on FBOs for all five agencies for fiscal 
years 2003-2005. In March 2006, the WHOFBCI reported that in fiscal 
year 2005 the federal government awarded, through seven federal 
agencies, more than $2.1 billion in competitive social service grants 
to FBOs--an increase of 7 percent over the previous year. The WHOFBCI 
also reported that between fiscal years 2003 and 2005, grants to FBOs 
increased by 38 percent and funding increased by 21 percent. 

The WHOFBCI's report states that federal agencies make good-faith 
efforts to collect accurate data on grants awarded to FBOs, and we also 
found that agencies are making significant efforts to collect this 
data. However, they face constraints in collecting accurate data. 
Specifically, the government has not established criteria for what 
constitutes a faith-based organization that all federal agencies must 
use, and federal agencies do not require organizations to self-identify 
as faith-based. Although no method can ensure that all data collected 
are accurate, having consistently applied criteria or requiring self- 
identification would provide greater assurance that agencies are 
collecting accurate data than the current method.[Footnote 48] In 
addition, the WHOFBCI has not reported on grants awarded to community- 
based organizations. Consequently, it is unclear whether the reported 
data provide policymakers with a sound basis to assess the progress of 
agencies in meeting the initiative's long-term goal of increasing 
participation of faith-based and community organizations. 

As we've previously reported, a long-standing challenge for the federal 
government has been producing credible data on outcomes achieved 
through federal programs. Policymakers need credible data to make 
resource allocation decisions on what programs to fund. Concerns about 
the accuracy of the data collected on FBOs have previously been raised 
by others. For example, during a June 2005 House hearing on the centers 
for faith-based and community initiatives, two former officials from 
the WHOFBCI and a former HHS center director questioned the accuracy of 
the data.[Footnote 49] In short, they questioned the methods used to 
collect data on which organizations are faith-based and the credibility 
of the reported data. 

In 2001, the Administration noted that a lack of a standard definition 
for what constitutes a faith-based organization was an obstacle to 
federal agencies in determining how much federal funding FBOs 
receive.[Footnote 50] Without using consistently applied criteria 
across federal agencies or requiring organizations to self-identify, 
each center is responsible for determining which grantees in selected 
programs are faith-based. One vehicle the centers use for identifying 
FBOs is a voluntary survey that is sent to all grant applicants and 
which asks, among other questions, whether the applicant is a "faith- 
based/religious" organization. However, the extent to which applicants 
return the survey varies across the centers, and several center 
officials reported that the response rate for this survey has been low. 

In cases in which applicants do not complete the voluntary survey, 
agencies rely on other methods of identification, such as 
administrative reports, Web sites, and phone inquiries by center and 
program staff. Moreover, a variety of agency staff collects this data 
without consistently applied criteria. Some agencies rely on center 
officials to collect this data, while others rely on either program 
staff or contractors. For example, one center official said that 
because there is no established definition of an FBO, officials are 
careful not to direct the program office staff on what characteristics 
to look for when identifying these organizations. Such methods involve 
considerable work on the part of program and center officials and, in 
some cases, discretion in determining which organizations are faith- 
based. Another document that collects information on organizations' 
characteristics is OMB's mandatory application for federal financial 
assistance that all applicants must complete. Although the application 
instructs applicants to identify themselves from a list of 
organizational categories, no category for faith-based organization is 
included.[Footnote 51] 

Some center officials told us that they believed that many FBOs may be 
reluctant to identify themselves as such on the voluntary survey 
because of concerns that being labeled faith-based might work against 
them in the grant process. However, it is unclear the extent to which 
FBOs are reluctant to self-identify. Some FBOs may not be concerned as 
indicated by the fact that they have religious organizational names and 
their mission statements include religious references. In addition, 
according to HUD officials, since 1997 HUD has asked organizations 
applying for Continuum of Care programs to self-identify whether or not 
they are "a religious organization, or a religiously-affiliated or 
motivated organization." HUD officials reported a high response rate 
from its applicants on this question and noted that for this program, 
they rely on these data rather than the voluntary survey to identify 
grantees that are FBOs. Finally, most of the 26 FBOs we visited said 
they filled out the voluntary survey, and almost all said they would 
not be hesitant to self-identify as faith-based if asked. 

Developing criteria for what constitutes an FBO is a challenging task. 
Some organizations have a historical religious connection but only 
provide secular social services, while other organizations are churches 
where faith permeates the nonfederal services provided. The problem of 
determining, without consistently applied criteria across federal 
agencies whether an organization is faith-based or not is illustrated 
by one center official telling us that his agency considers all of the 
local Young Men's Christian Association (YMCA) and the Young Women's 
Christian Association (YWCA) entities to be FBOs on the basis of the 
religious affiliation contained in their organizational names and 
mission statements of the national organizations. Meanwhile, an 
official at another agency said that his agency looked beyond the 
national organization to see if the local entities consider themselves 
to be faith-based. 

An official at one local YWCA in Texas told us that the organization 
does not consider itself to be an FBO. Similarly, several California 
organizations listed by the WHOFBCI as FBOs told us that despite their 
religious-sounding names, they did not consider themselves to be FBOs. 
This issue will also be a concern as centers seek to collect additional 
data on FBOs receiving state-administered formula grant programs. 
Several state officials said that they believed that having a standard 
definition for FBOs would help them if they are asked to collect data 
on which of their grantees are FBOs. 

Other attempts have been made to develop criteria for what constitutes 
an FBO for collecting data on federal funding to FBOs. A February 2006 
study by the Roundtable on Religion and Social Welfare Policy sought to 
assess the extent of federal support of faith-based social service 
providers by examining the direct recipients of discretionary grant 
awards made by the federal agencies that have initiative-related 
centers. Drawing on past research on key characteristics of the faith 
character of organizations, the study developed five characteristics by 
which to define an organization as an FBO. These characteristics 
include whether the organization used overt religious words or symbols 
in its name and whether religious or spiritual references were 
contained in the organization's mission or value statement.[Footnote 
52] 

Outcome Evaluations of Many Pilot Programs Have Not Begun: 

Progress in achieving the initiative's second long-term goal of 
improved participant outcomes cannot yet be determined because agencies 
have not completed most of the outcome-based evaluations for their 
ongoing pilot programs. OMB's Standards for Success for the initiative 
requires agencies to undertake outcome-based evaluations of their pilot 
programs and build an evaluation component into new pilots. Outcome- 
based evaluations may involve several years of data collection before 
the analysis can take place, and several of these pilot programs were 
initiated only a few years ago. 

Generally, pilot programs help agencies demonstrate actual benefits 
that may be achieved using a particular approach. While outcome 
evaluations are an important component of program management in that 
they assess whether a participant is achieving an intended outcome-- 
such as obtaining employment or completing high school--they cannot 
measure whether the outcome is a direct result of program 
participation. Other influences, such as the state of the local 
economy, may affect an individual's ability to find a job as much as or 
more than participation in an employment and training program. Many 
researchers consider impact evaluations--a form of outcome evaluation-
-to be the best method for determining the effectiveness of a program; 
that is, whether the program itself rather than other factors leads to 
participant outcomes. However, impact evaluations can be time-consuming 
and expensive and may not be appropriate in all circumstances.[Footnote 
53] 

As shown in table 7, an outcome evaluation was completed or evaluations 
were under way for 7 of the 15 pilot programs for faith-based and 
community organizations. Justice completed an outcome-based evaluation 
for the Clergy Against Senior Exploitation pilot program in Denver. The 
evaluation suggests that the participants who completed the survey 
believe that they were more knowledgeable about types of fraud and 
fraud prevention and were better prepared to report fraud after 
completing the program than prior to the program. While such results 
are promising, the evaluation design does not allow for complete 
confidence that the pilot achieved its intended outcome of helping 
participants avoid becoming victims of fraud. For one of the six 
evaluations underway, we could not determine from the design plan 
provided to us on the Faith and Community-Based Juvenile Delinquency 
Treatment Initiative whether the evaluation would be outcome-based. 
While officials at Justice provided us with a list of research 
questions related to the process and outcome evaluation under way, no 
specific information about the research design was provided. 

Table 7: Most Required Outcome Evaluations Not Completed, and Some 
Design Plans May Not Support an Evaluation of Program Outcomes: 

Agency: Justice; 
Pilot and date established: Life Connections-2002; 
Outcome evaluation completed: [Empty]; 
Evaluation underway: X; 
Intend to conduct outcome evaluation: [Empty]; 
No outcome evaluation planned: [Empty]. 

Agency: Justice; 
Pilot and date established: Faith and Community-Based Juvenile 
Delinquency Treatment Initiative-2003; 
Outcome evaluation completed: [Empty]; 
Evaluation underway: X; 
Intend to conduct outcome evaluation: [Empty]; 
No outcome evaluation planned: [Empty]. 

Agency: Justice; 
Pilot and date established: CASE-2003; 
Outcome evaluation completed: X; 
Evaluation underway: [Empty]; 
Intend to conduct outcome evaluation: [Empty]; 
No outcome evaluation planned: [Empty]. 

Agency: Justice; 
Pilot and date established: Rural Domestic Violence and Child 
Victimization Enforcement Grant Program: Special Initiative Faith- 
Based and Community Organizations Pilot Program-2005; 
Outcome evaluation completed: [Empty]; 
Evaluation underway: ; X; 
Intend to conduct outcome evaluation: [Empty]; 
No outcome evaluation planned: [Empty]. 

Agency: Labor; 
Pilot and date established: Small Grassroots Program- 2002; 
Outcome evaluation completed: [Empty]; 
Evaluation underway: [Empty]; 
Intend to conduct outcome evaluation: X; 
No outcome evaluation planned: [Empty]. 

Agency: Labor; 
Pilot and date established: Ready4Work-2003; 
Outcome evaluation completed: [Empty]; 
Evaluation underway: X; 
Intend to conduct outcome evaluation: [Empty]; 
No outcome evaluation planned: [Empty]. 

Agency: Labor; 
Pilot and date established: Grants for Workforce Investment Boards- 
2004; 
Outcome evaluation completed: [Empty]; 
Evaluation underway: [Empty]; 
Intend to conduct outcome evaluation: [Empty]; 
No outcome evaluation planned: X. 

Agency: Labor; 
Pilot and date established: Prisoner Reentry Initiative-2005; 
Outcome evaluation completed: [Empty]; 
Evaluation underway: X; 
Intend to conduct outcome evaluation: [Empty]; 
No outcome evaluation planned: [Empty]. 

Agency: Education; 
Pilot and date established: Supplemental Educational Services-2004; 
Outcome evaluation completed: [Empty]; 
Evaluation underway: X; 
Intend to conduct outcome evaluation: [Empty]; 
No outcome evaluation planned: [Empty]. 

Agency: HHS; 
Pilot and date established: Compassion Capital Fund Demonstration 
Program-2002; 
Outcome evaluation completed: [Empty]; 
Evaluation underway: [Empty]; 
Intend to conduct outcome evaluation: X; 
No outcome evaluation planned: [Empty]. 

Agency: HHS; 
Pilot and date established: Compassion Capital Fund Targeted Capacity- 
Building Program-2003; 
Outcome evaluation completed: [Empty]; 
Evaluation underway: [Empty]; 
Intend to conduct outcome evaluation: X; 
No outcome evaluation planned: [Empty]. 

Agency: HHS; 
Pilot and date established: Mentoring Children of Prisoners-2003; 
Outcome evaluation completed: [Empty]; 
Evaluation underway: [Empty]; 
Intend to conduct outcome evaluation: X[A]; 
No outcome evaluation planned: [Empty]. 

Agency: HHS; 
Pilot and date established: Access to Recovery-2004; 
Outcome evaluation completed: [Empty]; 
Evaluation underway: [Empty]; 
Intend to conduct outcome evaluation: X; 
No outcome evaluation planned: [Empty]. 

Agency: HUD; 
Pilot and date established: Unlocking Doors Initiative- 2005; 
Outcome evaluation completed: [Empty]; 
Evaluation underway: [Empty]; 
Intend to conduct outcome evaluation: [Empty]; 
No outcome evaluation planned: X. 

Agency: HUD; 
Pilot and date established: Mentoring Pilot Project-2005; 
Outcome evaluation completed: [Empty]; 
Evaluation underway: [Empty]; 
Intend to conduct outcome evaluation: X; 
No outcome evaluation planned: [Empty]. 

Agency: Total; 
Pilot and date established: [Empty]; 
Outcome evaluation completed: 1; 
Evaluation underway: 6; 
Intend to conduct outcome evaluation: 6; 
No outcome evaluation planned: 2. 

Source: Education, HHS, HUD, Justice, and Labor program documents and 
interviews with agency officials. 

[A] Center officials at HHS said they intend to conduct an impact 
evaluation of the Mentoring Children of Prisoners program that includes 
outcome data and analysis. 

[End of table] 

Of the six pilot programs in which center officials said they intend to 
conduct outcome-based evaluations, HHS and HUD provided to us a total 
of five design plans. Three of the five design plans appear to support 
outcome-based evaluations.[Footnote 54] However, for two of the five 
design plans, we could not determine whether the evaluations would be 
outcome-based because the plans lacked clarity and specificity about 
how the agency would conduct these evaluations. Specifically, for HHS's 
Access to Recove