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United States Government Accountability Office: 
Washington, DC 20548: 

June 18, 2010: 

The Honorable Tom Coburn, M.D.
United States Senate: 

Subject: Oversight of DOJ Funds for Recreational Activities: 

Dear Senator Coburn: 

The Department of Justice (DOJ) awards an array of law enforcement and 
criminal justice grants to states, localities, and private and not-for-
profit organizations to help prevent crime in their communities. From 
fiscal years 2008 through 2009, DOJ's Office of Justice Programs (OJP) 
awarded over 7,900 grants totaling over $4.2 billion.[Footnote 1] Some 
DOJ grant programs emphasize the prevention of crime and juvenile 
delinquency, and in some instances, DOJ's grant funds have been used, 
in part, to support recreational activities for youth involving 
various sports programs and field trips. In addition, DOJ grant 
recipients, such as a state's department of juvenile justice services, 
may provide grant funds to a subgrantee, like the Boys and Girls Club 
of America, to carry out various activities, such as mentoring or 
antigang initiatives, within the overall parameters of the grant 
program. However, no DOJ grant programs are designed to fund 
recreational activities exclusively. 

This letter responds to your request to determine (1) the extent to 
which DOJ tracks grant funds spent on recreational activities, and 
how, if at all, DOJ assesses the impact of federally funded 
recreational activities on crime prevention and reduction; and (2) how 
much DOJ grant funding has been used to support recreational 
activities. As discussed with your staff in March 2010, DOJ does not 
maintain, and is not required to maintain, the information necessary 
to consistently determine (a) if recreational activities were funded 
through a DOJ grant program, and the impact of those activities, or 
(b) specific funding amounts used to support such activities. Such 
determinations would require a baseline definition of what a 
"recreational activity" would encompass, and a requirement and method 
for grant recipients to document the specific scope, nature, 
associated costs, and impact of each specific activity carried out 
under the grant. 

Absent this information from DOJ, we sought to independently identify 
and isolate recreational activities that were funded through various 
DOJ grant programs, but were unable to identify their scope, nature, 
cost, and impact due to various challenges. In particular, when 
reviewing selected grant recipients' program descriptions, we 
experienced difficulty distinguishing between the recreational and 
nonrecreational activities grant recipients implemented. Moreover, in 
cases where program descriptions identified activities that could be 
considered recreational in nature, we were consistently unable to 
determine the specific costs of these activities. Thus, as agreed with 
your staff in March 2010, given the limitations in available data on 
the nature and costs of grants awarded for recreational activities, 
this letter (1) elaborates on the extent to which DOJ gathers and 
maintains information on grant recipients recreational activities, and 
(2) discusses challenges and limitations we encountered in analyzing a 
sample of DOJ grant documents. 

To conduct our work, we interviewed officials from DOJ's Office of 
Justice Programs, Bureau of Justice Assistance (BJA), Office of 
Juvenile Justice and Delinquency Prevention (OJJDP), and Community 
Capacity Development Office (CCDO).[Footnote 2] 

Specifically, we gathered details on their grant management and 
reporting requirements and discussed which specific DOJ grant programs 
officials believed may allow for grant recipients to fund activities 
that could be considered recreational, given the authorized purposes 
of the program. These generally consisted of programs that focused on 
crime prevention and reduction strategies within the juvenile 
population. We consulted with DOJ and drew a nongeneralizable sample 
of eight DOJ grant programs that we believed were the most likely to 
fund activities that could be considered recreational. We reviewed the 
department's solicitations for these programs, as well as grant 
recipients' applications--including narratives outlining how they plan 
to implement the award--and budget reports.[Footnote 3] In addition, 
we reviewed applicable laws and regulations concerning DOJ grant 
management requirements. For additional details of our scope and 
methodology, as well as the list of grant programs we selected and the 
individual grant files we reviewed, please see enclosure I. We 
conducted our work from November 2009 through June 2010 in accordance 
with all sections of GAO's Quality Assurance Framework that are 
relevant to our objectives. The framework requires that we plan and 
perform the engagement to obtain sufficient and appropriate evidence 
to meet our stated objectives and to discuss any limitations in our 
work. We believe that the information and data obtained, and the 
analysis conducted, provide a reasonable basis for any findings and 
conclusions in this product. 

While Some DOJ Grant Programs May Allow Funding for Recreational 
Activities, DOJ Does Not Gather or Maintain Specific Information on 
These Activities: 

According to DOJ officials, grant recipients may use grant funding to 
support activities that could be considered recreational, where 
allowable under the terms of the grant. However, the department does 
not fund any grant programs that support recreational activities 
exclusively nor does it define or track "recreational activities" 
among the various initiatives that grant recipients are implementing 
to execute their overall grant program objectives. For example, DOJ 
officials explained that grant recipients may be funded to target 
activities toward a particular purpose, such as crime prevention. 
While executing its program, the grant recipient may decide that an 
after-school sports program might support its overall objectives. 
Although a sports program may be permissible under the grant, DOJ is 
not required to maintain information--nor does it require reporting by 
grant recipients--on specific expenditures for recreational activities 
or the outcomes associated with those activities. Instead, DOJ 
requires that grant recipients report in the aggregate about the 
effectiveness of their overall strategies. 

Specifically, while DOJ requires grant recipients to report on the 
degree to which certain performance metrics are met, these metrics are 
tied to the overall purpose of the grant program--crime prevention, 
for example--and do not drill down to detect the significance or 
effectiveness of each individual activity. For example, BJA's Gang 
Resistance Education and Training Program (G.R.E.A.T.) requires grant 
recipients to report outcome data to measure: (1) the increase in the 
number of school-aged children who graduate from G.R.E.A.T. over the 
prior year; and (2) the increase in the number of middle school youth 
who improve their positive perception of law enforcement over the 
prior year. However, G.R.E.A.T grant recipients that may be funding 
specific activities, such as field trips, with their award are not 
required to delineate the specific purpose or impact of the field trip 
because the overall G.R.E.A.T reporting requirements are associated 
only with high-level grant program goals and performance measures. 

Because DOJ does not require grant recipients to report on specific 
expenditures associated with particular activities, such as an after- 
school sports program, and because it does not maintain or monitor any 
data on recreational activities, department officials told us that 
their overall grant management system was not designed to capture 
either their contributions to the overall program's effectiveness or 
the individual costs of particular activities like an after-school 
sports program. As a result, DOJ is not positioned to determine how 
much money has been spent on recreational activities. DOJ officials 
told us that any funding grant recipients used for recreational 
activities that support the overall objectives of the grant program 
would likely be combined with other activities in their grant files, 
such that it would be challenging to separate out dollars spent on 
recreational activities from other funded activities. In addition, 
even if information of this kind were more readily available in grant 
recipients' grant files, because DOJ does not have the software or 
databases to extract it in an automated manner, DOJ officials told us 
the department would have to collect it manually, which they reported 
would be labor-intensive and time-consuming, involving a content 
analysis of thousands of documents submitted by hundreds of grantees. 

Challenges and Limitations We Encountered When Analyzing a Sample of 
DOJ Grant Documents: 

We independently reviewed a nongeneralizable sample of DOJ grant 
recipients' reporting documents, including financial statements, and 
encountered challenges attempting to isolate activities that were 
recreational in nature. Specifically, we experienced difficulties 
distinguishing recreational from nonrecreational activities because 
some documents we reviewed lacked necessary detail. For example, one 
grant recipient's narrative statement about the use of its grant funds 
indicated that some of its funding was to be used for a crime- 
prevention program designed to occupy children during the early 
evening hours after school. However, the document did not include a 
description of what specific activities the program included and, as a 
result, we could not verify whether recreational activities were or 
were not funded through the grant. In other cases, it was difficult to 
determine if a funded activity was recreational in nature or not. For 
example, the documentation we reviewed for a grant to an Indian 
reservation indicated approval to use DOJ funds for what the tribe 
called a "restitution craft project," whereby children made crafts 
they later gave to the victims of their crimes. While craft-making 
could be considered a recreational activity, because the intent of the 
tribal activity was to provide a therapeutic and delinquency-
prevention benefit to those involved, it is unclear whether or not it 
should be considered recreational in nature.[Footnote 4] 

Moreover, in cases where grant recipients' program narratives 
identified activities that could be considered recreational in nature, 
such as trips to bowling alleys and water parks, we were consistently 
unable to determine funding amounts spent on these activities. DOJ 
does not require grant recipients to itemize and associate costs with 
each individual activity in their quarterly financial reports and 
budget narratives. In particular, DOJ's budget reporting guidance 
stipulates that grant recipients report their expenditures by specific 
categories, such as travel, consultants/contracts, construction, 
supplies, and equipment. Because grant recipients whose reports we 
reviewed did not itemize their expenses by each individual activity, 
we were unable to determine specific funding spent on a recreational 
activity versus other funded activities. 

As a result, a review of additional DOJ grant files is unlikely to 
provide any more specific information on the nature of and costs 
associated with recreational activities funded through DOJ grant 

Agency Comments: 

We requested comments on a draft of this report from DOJ on June 1, 
2010. However, in an e-mail received on June 7, 2010, DOJ's liaison 
stated that DOJ did not have any written or technical comments to our 

Based on our discussion of these issues with your staff in March, this 
correspondence reflects the agreement we reached to not do any further 
work on this request. Also, as agreed with your offices, unless you 
publicly announce the contents of this report earlier, we plan no 
further distribution until 30 days from the report date. At that time, 
we will send copies of this report to the Department of Justice's 
Attorney General and interested congressional committees. In addition, 
this report will be available at no charge on GAO's Web site at 
[hyperlink,]. If you or your staff have any further 
questions on this correspondence or wish to discuss this further, 
please do not hesitate to contact me at (202) 512-9627 or 

Sincerely yours, 

Signed by: 

David C. Maurer:
Director, Homeland Security and Justice Issues: 

[End of section] 

Enclosure I: Sample Selection Process: 

To select a nongeneralizable sample of Department of Justice (DOJ) 
grant programs to review, we identified all the various grant programs 
within the Bureau of Justice Assistance, Office of Juvenile Justice 
and Delinquency Prevention (OJJDP), and Community Capacity Development 
Office (CCDO) for the 2008 award year. We chose 2008 because according 
to DOJ officials, grant recipients receiving awards in that year would 
have submitted several progress reports to DOJ that we could obtain to 
facilitate our review.[Footnote 5] 

To confirm our understanding, we then consulted with DOJ to select 
grant programs that based on the award solicitation description, could 
have funded the types of activities that could be considered 
recreational; however, we did not apply a specific definition for 
"recreational activities" to our analysis, given the subjective nature 
of the term. These programs generally focused on juveniles and crime 
prevention and reduction strategies. From these grants programs, we 
then identified and selected those that we believed had the greatest 
likelihood of funding activities that could be considered recreational 
in nature. As a result, our sample consisted of eight grant programs, 
from which we then selected the grant recipients within each program 
that received the largest amounts of funding in 2008.[Footnote 6] In 
cases where multiple grant recipients received equal amounts of 
funding, we selected grant recipients that were geographically 
dispersed. In total, from the eight grant programs in our sample, we 
selected 16 individual grant recipients. We then reviewed their grant 
file documentation. These documents included individual grant program 
solicitations, grantee applications, quarterly financial reports, 
grantee budget documents and performance reports, and any available 
assessments conducted.[Footnote 7] Table 1 provides a brief 
description for each of the DOJ grant programs and individual grantees 
we selected. 

Table 1: DOJ Grant Programs and Grantees Selected: 

Bureau of Justice Assistance: 

Gang Resistance Education and Training Program (G.R.E.A.T.): The 
G.R.E.A.T. Program is a school-based, law enforcement officer- 
instructed classroom curriculum with prevention as its primary 
objective. The program is intended as an immunization against 
delinquency, youth violence, and gang membership; 
Grantees: New York City Police Department, New York; and Phoenix 
Police Department, Arizona. 

Office of Juvenile Justice and Delinquency Prevention Formula and 
Block Grants: 

Title II Formula Grants: This program provides funding to states to 
develop programs to address juvenile delinquency and improve the 
juvenile justice system; 
Grantees: New York Division of Criminal Justice Services, New York; 
and Texas Office of the Governor, Criminal Justice Division, Texas. 

Title V Community Prevention Grants Program: This program funds local 
efforts to reduce risk factors for juvenile delinquency and to enhance 
factors to prevent youth at risk of becoming delinquent and entering 
the juvenile justice system. Specifically authorized activities 
include, among other things, "recreation services;" 
Grantees: Florida Department of Juvenile Justice, Florida; and Idaho 
Department of Juvenile Corrections, Idaho. 

Office of Juvenile Justice and Delinquency Prevention Discretionary 

National Mentoring Programs: This program supports mentoring programs 
that have national scope and impact on combating juvenile delinquency, 
reducing the victimization of children, and improving the juvenile 
justice system. It establishes programs that offer a mixture of core 
services and engage youth with activities that enable them to practice 
healthy behaviors. The target population is youth at risk for gang 
activity, delinquency, and youth violence; 
Grantees: Boys and Girls Club of America; and Big Brother Big Sisters 
of America. 

Tribal Youth Program: This program supports and enhances tribal 
efforts to prevent and control delinquency and improve the juvenile 
justice system for American Indian/American Native youth. Awards are 
for direct service prevention programs to federally recognized tribes 
to develop and implement culturally sensitive delinquency prevention 
programs, alcohol and substance abuse prevention programs, and 
mentoring program services; 
Grantees: Red Lake Band of Chippewa Indians; and White Earth 
Reservation Tribal Council. 

Part E Congressionally Directed Grants: While no solicitation 
description was given, OJJDP told us that they believed some 
congressionally directed grantees funded recreational activities, and 
also addressed juvenile delinquency and crime prevention; 
Grantees: Abyssinian Development Corporation; Big Brothers Big Sisters 
of Alaska; and Midnight Basketball League of Richmond, Virginia. 

Community Capacity Development Office: 

Weed and Seed Program Guide and Application Kit: Continuation Sites: 
The Weed and Seed strategy aims to prevent, control, and reduce 
violent crime, criminal drug-related activity, and gang activity. It 
is a community-based, comprehensive multi-agency approach that focuses 
on: (1) Law Enforcement; (2) Community Policing; (3) Prevention, 
Intervention, and Treatment; and (4) Neighborhood Restoration. A Weed 
and Seed Community (WSC) must be developed in partnership with a 
variety of key local organizations and the local United States 
Attorney's Office. A WSC must work to improve the quality of life for 
residents by redeploying existing public and private resources to 
address crime and social related problems that may lead to violent 
crime, drug abuse, and gang activity; 
Grantees: Modesto Paradise South, Modesto, California. 

Weed and Seed Communities Competitive Program Guide and Application 
Kit: This program's mission is also to prevent, control, and reduce 
violent crime, drug abuse, and gang activity. It is a community-based, 
comprehensive multi-agency approach to law enforcement, crime 
prevention, and neighborhood restoration. It is designed for 
communities with persistent high levels of serious violent crime and 
corresponding social problems; 
Grantees: Urban Rock Hill, Rock Hill, South Carolina; and Ferguson 
Road Initiative, Dallas, Texas. 

Source: GAO analysis of DOJ data. 

[End of table] 

[End of section] 


[1] In fiscal year 2009, OJP also awarded an additional 3,883 grants 
under the American Recovery and Reinvestment Act of 2009, Pub. L. No. 
111-5, 123 Stat. 115 totaling more than $2.74 billion to state, local, 
and tribal law enforcement and community organizations. 

[2] We focused on these three DOJ components because DOJ agreed with 
our initial determination that BJA, OJJDP, and CCDO would be the most 
likely to have grant programs funding recreational activities. 
Specifically, BJA's grant programs aim to, among other things, provide 
training and technical assistance to prevent crime, drug abuse, and 
violence at the national, state, and local levels and develop state 
and local collaborations and partnerships. OJJDP's grants support 
states and communities that seek to develop and implement effective 
and coordinated prevention and intervention programs and improve the 
juvenile justice system to protect public safety, hold offenders 
accountable, and provide treatment and rehabilitative services 
tailored to the needs of juveniles and their families. Lastly, CCDO's 
grants support local communities in the pursuit of deterring crime, 
promoting economic growth, and enhancing quality of life. 

[3] The department issues grant solicitations to provide information 
on grant recipient eligibility requirements, including reporting 
requirements and application procedures. Grant recipients' budget 
documents provide information on their planned expenditures, quarterly 
financial outlays, and obligations for the reporting period. 

[4] As DOJ does not have a baseline definition for recreational 
activities, we did not apply a specific definition for the term 
recreational activities to our analysis, but rather used our own 
judgment as to what a recreational activity may encompass. 

[5] Specifically, DOJ officials said that some grant funding for 2009 
was not awarded until later in that year. As a result, they told us 
that some 2009 grantees had not likely expended their funds or 
submitted progress reports to DOJ to date that we could obtain and 
evaluate during the period of our review. 

[6] Because OJJDP officials informed us that some activities that 
could be considered recreational in nature may have been funded by 
congressionally directed grants, we selected several of these grants 
from 2008 to include in our sample. 

[7] Grant program solicitations provide information on grant recipient 
requirements, including reporting requirements, application 
procedures, etc.; Grantee applications include a narrative outlining 
how the grant recipient plans to implement the grant program award. 
Quarterly financial reports provide information on total outlays and 
obligations for each recipient for the reporting period. Performance 
reports provide information on how the grant recipient achieved the 
metrics included in the original solicitation. 

[End of section] 

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