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Testimony:

Before the Subcommittee on Water Resources and Environment, Committee 
on Transportation and Infrastructure, House of Representatives:

United States General Accounting Office:

GAO:

For Release on Delivery Expected at 2:00 p.m. EDT:

Wednesday, October 1, 2003:

Grants Management:

EPA Needs to Strengthen Oversight and Enhance Accountability to Address 
Persistent Challenges:

Statement of John B. Stephenson, Director, Natural Resources and 
Environment:

GAO-04-122T:

GAO Highlights:

Highlights of GAO-04-122T, testimony before the Subcommittee on Water 
Resources and Environment, Committee on Transportation and 
Infrastructure, House of Representatives 

Why GAO Did This Study:

The Environmental Protection Agency (EPA) has faced persistent 
challenges in managing its grants, which, at about $4 billion annually 
constitute over one-half of the agency’s total budget. EPA awards 
grants to thousands of recipients to implement its programs to protect 
human health and the environment. Given the size and diversity of 
EPA’s programs, its ability to efficiently and effectively accomplish 
its mission largely depends on how well it manages its grant resources 
and builds accountability into its efforts. 

In our comprehensive report on EPA’s management of its grants, 
released last week, we found that EPA continues to face four key 
grants management challenges despite past efforts to address them—(1) 
selecting the most qualified grant applicants, (2) effectively 
overseeing grantees, (3) measuring the results of grants, and (4) 
effectively managing its grant staff and resources. The report also 
discusses EPA’s latest competition and oversight policies and its new 
5-year plan to improve the management of its grants.

This testimony, based on our report, focuses on the extent to which 
EPA’s latest policies and plan address (1) awarding grants 
competitively, (2) improving oversight of grantees, and (3) holding 
staff and managers accountable for fulfilling their grants management 
responsibilities.

What GAO Found:

Late in 2002, EPA launched new efforts to address some of its long-
standing grants management problems. It issued two policies—one to 
promote competition in awarding grants and one to improve its 
oversight of grants. Furthermore, in April 2003, EPA issued a 5-year 
grants management plan to address its long-standing grants management 
problems. These policies and plan focus on the major grants management 
challenges we identified but will require strengthening, enhanced 
accountability, and sustained commitment to succeed. 

EPA’s September 2002 competition policy should improve EPA’s ability 
to select the most qualified applicants by requiring competition for 
more grants. However, effective implementation of the policy will 
require a major cultural shift for EPA managers and staff because the 
competitive process will require significant planning and take more 
time than awarding grants noncompetitively.

EPA’s December 2002 oversight policy makes important improvements in 
monitoring grantees, but it does not build in a process for 
effectively and efficiently analyzing the results of its monitoring 
efforts to address systemic grantee problems. Specifically, EPA does 
not (1) use a statistical approach to selecting grantees for review, 
(2) collect standard information from the reviews, and (3) analyze the 
results to identify and resolve systemic problems with grantees. As a 
result, EPA may not be using its oversight resources as efficiently as 
it could. With improved analysis, EPA could better identify problem 
areas and assess the effectiveness of its corrective actions to more 
efficiently target its oversight efforts.

EPA’s 5-year grants management plan recognizes the importance of 
accountability, but it does not completely address how the agency will 
hold all managers and staff accountable for successfully fulfilling 
their grants management responsibilities. For example, the plan calls 
for developing performance standards for staff overseeing grantee 
performance, but it does not call for including grants management 
performance standards in their managers’ and supervisors’ performance 
agreements. Unless all managers and staff are held accountable for 
grants management, EPA cannot ensure the sustained commitment required 
for the plan’s success. 

Our report, Grants Management: EPA Needs to Strengthen Efforts to 
Address Persistent Challenges, GAO-03-846, details EPA’s historically 
uneven performance in addressing its grants management challenges. 
Over the years, EPA’s past actions to improve grants management have 
had mixed results because of the complexity of the problems, 
weaknesses in policy design and implementation, and insufficient 
management attention to overseeing grants. While EPA’s latest policies 
and new 5-year grants management plan show promise, it is too early to 
tell if these will succeed more than past actions. If EPA is to better 
achieve its environmental mission, it must more effectively manage its 
grants. Our report contains specific recommendations to address 
critical weaknesses in EPA’s new oversight policy and plan. EPA stated 
that it agreed with GAO’s recommendations and it will implement them 
as part of its 5-year grants management plan. 

What GAO Recommends:

www.gao.gov/cgi-bin/getrpt?GAO-04-122T.

To view the full product, including the scope And methodology, click 
on the link above. For more information, contact John B. Stephenson at 
(202) 512-3841 or stephensonj@gao.gov.

[End of section]

Mr. Chairman and Members of the Subcommittee:

We are pleased to be here to discuss the Environmental Protection 
Agency's (EPA) management of its grants. My testimony is based on our 
report released in September 2003, which was requested by the Chairman 
of the House Committee on Transportation and Infrastructure and 
Representative Anne Northup.[Footnote 1]

To support its mission of protecting human health and the environment, 
in fiscal year 2002, EPA awarded grants to a variety of recipients, 
including state and local governments, tribes, universities, and 
nonprofit organizations. Given the size and diversity of EPA's 
programs, its ability to efficiently and effectively accomplish its 
mission largely depends on how well it manages its grant resources and 
builds accountability into its efforts. As of September 30, 2002, EPA 
had 4,100 grant recipients.

As you know, over the years, EPA has faced persistent challenges in 
managing its grants, which at about $4 billion annually, constitute 
over one-half of its total budget. In our June 2003 testimony before 
this Subcommittee and in our report, we identified four key management 
challenges EPA continues to face, despite past efforts to address 
them.[Footnote 2] These challenges are (1) selecting the most qualified 
grant applicants, (2) effectively overseeing grantees, (3) measuring 
the results of grants, and (4) effectively managing grant staff and 
resources. We also reported that EPA's past efforts to improve its 
management had mixed results because of the complexity of the problems, 
weaknesses in design and implementation, and insufficient management 
attention. EPA must resolve these problems in order to improve its 
management of grants.

Late in 2002, EPA launched new efforts to address some of its long-
standing grants management problems. Specifically, it issued two new 
policies--one in September 2002 to promote competition in awarding 
grants and one in December 2002 to improve its oversight of grants. 
Furthermore, in April 2003, EPA issued a 5-year grants management plan 
to address its long-standing grants management problems. We found that 
these policies and plan focus on the major grants management challenges 
we identified but will require strengthening, enhanced accountability, 
and sustained commitment to succeed.

For our testimony today, you asked us to comment on the extent to which 
EPA's new policies and plan address the challenges concerning (1) 
awarding grants competitively, (2) improving oversight of grantees, and 
(3) holding staff and managers accountable for fulfilling their grants 
management responsibilities. For our report, we, among other things, 
obtained and analyzed EPA's 1,232 in-depth reviews of grantee 
performance conducted in calendar year 2002 to identify the challenges 
EPA faces in managing its grants. We also examined EPA's new policies 
and plan and interviewed EPA officials responsible for key aspects of 
the plan.

In summary, we found the following:

* EPA's September 2002 competition policy should improve EPA's ability 
to select the most qualified applicants by requiring competition for 
more grants. However, effective implementation of the policy will 
require a major cultural shift for EPA managers and staff because the 
competitive process will require significant planning and take more 
time than awarding grants noncompetitively.

* EPA's December 2002 oversight policy makes important improvements in 
monitoring grantees, but it does not build in a process for effectively 
and efficiently analyzing the results of its monitoring efforts to 
address systemic grantee problems. Specifically, EPA does not (1) use a 
statistical approach to selecting grantees for review, (2) collect 
standard information from the reviews, and (3) analyze the results to 
identify and resolve systemic problems with grantees. As a result, EPA 
may not be using its oversight resources as efficiently as it could. 
With improved analysis, EPA could better identify problem areas and 
assess the effectiveness of its corrective actions to more efficiently 
target its oversight efforts.

* EPA's April 2003 grants management plan recognizes the importance of 
accountability but it does not completely address how the agency will 
hold all managers and staff accountable for successfully fulfilling all 
their grants management responsibilities. For example, the plan does 
not call for including grants management performance standards in 
managers' and supervisors' performance agreements. Unless all managers 
and staff are held accountable for grants management, EPA cannot ensure 
the sustained commitment required for the plan's success.

We made recommendations in our report to the EPA Administrator to 
strengthen grants management by more systematically overseeing grantees 
and by holding all managers and staff in headquarters and the regions 
accountable for fulfilling their grants management responsibilities. We 
also recommended that EPA report on the progress of its efforts in its 
annual report to Congress. EPA agreed with our recommendations and 
stated it will implement them as part of its 5-year grants management 
plan.

Background:

EPA administers and oversees grants primarily through the Office of 
Grants and Debarment, 10 program offices in headquarters,[Footnote 3] 
and program offices and grants management offices in EPA's 10 regional 
offices. Figure 1 shows EPA's key offices involved in grants activities 
for headquarters and the regions.

Figure 1: EPA's Key Offices Involved in Grant Activities:

[See PDF for image]

[End of figure]

The management of EPA's grants program is a cooperative effort 
involving the Office of Administration and Resources Management's 
Office of Grants and Debarment, program offices in headquarters, and 
grants management and program offices in the regions. The Office of 
Grants and Debarment develops grant policy and guidance. It also 
carries out certain types of administrative and financial functions for 
the grants approved by the headquarters program offices, such as 
awarding grants and overseeing the financial management of these 
grants. On the programmatic side, headquarters program offices 
establish and implement national policies for their grant programs, and 
set funding priorities. They are also responsible for the technical and 
programmatic oversight of their grants. In the regions, grants 
management offices carry out certain administrative and financial 
functions for the grants, such as awarding grants approved by the 
regional program offices,[Footnote 4] while the regional program staff 
provide technical and programmatic oversight of their grantees.

As of June 2003, 109 grant specialists in the Office of Grants and 
Debarment and the regional grants management offices were largely 
responsible for administrative and financial grant functions. 
Furthermore, 1,835 project officers were actively managing grants in 
headquarters and regional program offices. These project officers are 
responsible for the technical and programmatic management of grants. 
Unlike grant specialists, however, project officers generally have 
other primary responsibilities, such as using the scientific and 
technical expertise for which they were hired.

In fiscal year 2002, EPA took 8,070 grant actions[Footnote 5] totaling 
about $4.2 billion.[Footnote 6] These awards were made to six main 
categories of recipients as shown in figure 2.

Figure 2: Percentage of EPA Grant Dollars Awarded by Recipient Type, 
Fiscal Year 2002:

[See PDF for image]

[End of figure]

EPA offers two types of grants--nondiscretionary and discretionary:

* Nondiscretionary grants support water infrastructure projects, such 
as the drinking water and clean water state revolving fund programs, 
and continuing environmental programs, such as the Clean Air Program 
for monitoring and enforcing Clean Air Act regulations. For these 
grants, Congress directs awards to one or more classes of prospective 
recipients who meet specific eligibility criteria; the grants are often 
awarded on the basis of formulas prescribed by law or agency 
regulation. In fiscal year 2002, EPA awarded about $3.5 billion in 
nondiscretionary grants. EPA has awarded these grants primarily to 
states or other governmental entities.

* Discretionary grants fund a variety of activities, such as 
environmental research and training. EPA has the discretion to 
independently determine the recipients and funding levels for grants. 
In fiscal year 2002, EPA awarded about $719 million in discretionary 
grants. EPA has awarded these grants primarily to nonprofit 
organizations, universities, and government entities.

The grant process has the following four phases:

* Preaward. EPA reviews the application paperwork and makes an award 
decision.

* Award. EPA prepares the grant documents and instructs the grantee on 
technical requirements, and the grantee signs an agreement to comply 
with all requirements.

* Postaward. After awarding the grant, EPA provides technical 
assistance, oversees the work, and provides payments to the grantee; 
the grantee completes the work, and the project ends.

* Closeout of the award. EPA ensures that all technical work and 
administrative requirements have been completed; EPA prepares closeout 
documents and notifies the grantee that the grant is completed.

As part of its oversight of grantee performance, EPA conducts in-depth 
reviews to analyze grantees' compliance with grant regulations and 
specific grant requirements.[Footnote 7] EPA conducts two types of in-
depth reviews. Administrative reviews, conducted by the grants 
management offices, are designed to evaluate grantees' financial and 
administrative capacity. In contrast, programmatic reviews, conducted 
by the program offices, are designed to assess the grantees' activities 
in five key areas: (1) assessing progress of work, (2) reviewing 
financial expenditures, (3) meeting the grant's terms and conditions, 
(4) meeting all programmatic, statutory, and regulatory requirements, 
and (5) verifying that equipment purchased under the award is managed 
and accounted for. Both administrative and programmatic reviews are 
conducted either at the grantee's location (on-site) or at EPA's office 
or another location (off-site). Furthermore, to determine how well 
offices and regions oversee grantees, EPA conducts internal management 
reviews of headquarters and regional offices.

EPA's Competition Policy Shows Promise but Requires a Major Cultural 
Shift:

EPA's September 2002 competition policy requires that most 
discretionary grants be competed. These grants totaled about $719 
million of the $4.2 billion in grants awarded in fiscal year 2002. The 
policy applies to most discretionary grant programs or individual 
grants of more than $75,000.[Footnote 8] The policy also promotes 
widespread solicitation for competed grants by establishing specific 
requirements for announcing funding opportunities in, for example, the 
Federal Register and on Web sites. EPA has also appointed a grant 
competition advocate to coordinate this effort.

EPA's competition policy faces implementation barriers because it 
represents a major cultural shift for EPA staff and managers, who 
historically awarded most grants noncompetitively and thereby have had 
limited experience with competition, according to the Office of Grants 
and Debarment. The policy requires EPA officials to take a more 
planned, rigorous approach to awarding grants. That is, EPA staff must 
determine the evaluation criteria and ranking of these criteria for a 
grant, develop the grant announcement, and generally publish it at 
least 60 days before the application deadline. Staff must also evaluate 
applications--potentially from a larger number of applicants than in 
the past--and notify applicants of their decisions. These activities 
will require significant planning and take more time than awarding 
grants noncompetitively. Office of Grants and Debarment officials 
anticipate a learning curve as staff implement the policy and will 
evaluate the policy's effectiveness in 2005, including the $75,000 
threshold level. While the policy and subsequent implementing guidance 
have been in effect for a number of months, it is too early to tell if 
the policy has resulted in increased competition over the entire fiscal 
year. EPA officials believe that preliminary results indicate that the 
policy is increasing the use of competition.

EPA Needs A More Systematic Approach to Strengthen Oversight:

EPA's December 2002 oversight policy makes important improvements in 
monitoring grantees, but it does not enable the agency to identify and 
address systemic problems with grant recipients. Specifically, EPA 
cannot develop systemic information because the policy does not (1) 
incorporate a statistical approach to selecting grantees for review; 
(2) require a standard reporting format for in-depth reviews to ensure 
consistency and clarity in reporting review results; and (3) identify 
needed data elements or develop a plan for analyzing data in its 
grantee compliance database to identify and act on systemic grantee 
problems. Therefore, EPA cannot use data from these reviews to 
determine the overall compliance of grantees or be assured that it is 
using its resources to effectively target its oversight efforts. With a 
more rigorous statistical approach to selecting grantees, standard 
reporting format, and a plan for using information from in-depth and 
other reviews, EPA could identify problem areas and develop trends to 
assess the effectiveness of corrective actions in order to better 
target its oversight efforts.

EPA Needs to Incorporate a Statistical Approach to Selecting Grantees 
for Review:

EPA's new policy allows each office to determine what criteria it will 
use to select at least 10 percent of its grant recipients for in-depth 
review. However, because this policy does not employ a statistical 
method to selecting grantees for review, it limits the usefulness of 
these reviews as a tool to determine the overall compliance of grant 
recipients. Furthermore, EPA cannot determine whether 10 percent or any 
other percentage is the appropriate number of reviews. With a 
statistical approach, EPA could increase the efficiency and 
effectiveness of its oversight of grantees by (1) adjusting the number 
and allocation of its in-depth reviews to match the level of risk 
associated with each type of grant recipient and (2) projecting the 
results of its reviews to all EPA grantees.

EPA Needs to Require a Standard Reporting Format for In-depth Reviews:

EPA's in-depth reviews can provide valuable information that the agency 
can use to identify problems and implement corrective actions. However, 
EPA does not have a standard reporting format to ensure consistency, 
clarity, and usefulness in reporting review results. Consequently, EPA 
is not able to effectively and efficiently analyze these data to 
determine systemic grantee problems.

Although EPA was requiring offices to conduct in-depth review of 
grantees in 2002, it did not systematically collect and analyze 
information from these reviews as part of its oversight efforts. We 
requested that EPA provide us with its in-depth reviews conducted in 
2002 so we could do the analysis. Many of the documents EPA provided 
were, not in fact, in-depth reviews, but various types of other 
oversight documents. We sorted through these documents to identify the 
in-depth reviews using a data collection instrument. Through this 
approach, we identified 1,232 in-depth reviews. Using a data collection 
instrument, we collected and analyzed information from each of these 
in-depth reviews on, among other things, problems with grantees, and 
significant actions taken against grantees. The full results of our 
analysis are presented in our report.

According to our analysis of EPA's 1,232 in-depth reviews in 2002, EPA 
grant specialists and project officers identified 1,250 problems in 21 
areas. Tables 1 and 2 show the most frequently identified problems for 
the 189 administrative and 1,017 programmatic reviews we examined. For 
example, 73 of 189 administrative reviews found problems with grantees' 
written procedures, while 308 of the 1,017 programmatic reviews 
identified technical issues.

Table 1: Most Frequently Identified Problems, by Problem Area for 
Administrative Reviews, 2002:

Type of problem: Written procedures; Number of reviews with reported 
problem: 73.

Type of problem: Procurement; Number of reviews with reported problem: 
70.

Type of problem: Personnel/payroll; Number of reviews with reported 
problem: 51.

Type of problem: Accounting; Number of reviews with reported problem: 
37.

Source: GAO analysis of EPA's in-depth reviews.

[End of table]

Table 2: Most Frequently Identified Problems, by Problem Area for 
Programmatic Reviews, 2002:

Type of problem: Technical issues; Number of reviews with reported 
problem: 308.

Type of problem: Progress reports; Number of reviews with reported 
problem: 167.

Type of problem: Personnel/payroll; Number of reviews with reported 
problem: 92.

Type of problem: Quality assurance; Number of reviews with reported 
problem: 71.

Source: GAO analysis of EPA's in-depth reviews.

[End of table]

The differences in types of problems frequently identified, as shown in 
tables 1 and 2, reflect differences in the focus of administrative and 
programmatic reviews. Table 3 describes the nature of these problems.

Table 3: Description of Most Frequently Identified Problems in EPA's 
In-depth Reviews:

Problem: Accounting; Types of problems included in EPA's in-depth 
reviews: Any failure of a grantee's financial management system or 
shortcomings in the procedures it used to ensure the proper accounting 
of federal funds. For example, EPA found cases in which a grantee: * 
could not compare budgeted amounts to actual expenditures, * did not 
properly reconcile report balances to the general ledger, or; * did not 
separately track funds for different grants.

Problem: Personnel/payroll; Types of problems included in EPA's in-
depth reviews: Problems varied depending on the type of review 
conducted. Administrative reviews included cases in which a grantee did 
not track the amount of time its employees spent on specific grant 
activities. Programmatic reviews included cases in which grantees did 
not have sufficient staff resources to perform the grant activities.

Problem: Procurement; Types of problems included in EPA's in-depth 
reviews: Grantees lacked documentation to support sole-source 
contracts, and grantees did not report their efforts to encourage 
procurement from minority-and woman-owned businesses.

Problem: Progress reports; Types of problems included in EPA's in-depth 
reviews: A grantee's progress report was missing, late, or did not 
include all the necessary information.

Problem: Quality assurance; Types of problems included in EPA's in-
depth reviews: A grantee needed to revise its quality assurance plan, 
which is required to ensure the quality of data collected during the 
grant work.

Problem: Technical issues; Types of problems included in EPA's in-depth 
reviews: A grantee was behind in the progress of his or her work.

Problem: Written procedures; Types of problems included in EPA's in-
depth reviews: A grantee's written policies or procedures were either 
missing or inadequate.

Source: GAO analysis of EPA's in-depth reviews.

[End of table]

Despite the importance of standard information, our analysis of EPA's 
2002 in-depth reviews shows that EPA officials across the agency report 
in various formats that do not always clearly present the results of 
the review. For example, some EPA officials provided a narrative report 
on the results of their reviews, while others completed a protocol that 
they used in conducting their review. In 349 instances, the project 
officer or grant management specialist did not clearly explain whether 
he or she had discovered a problem.

EPA Needs to Develop a Plan for Using Information in Its Grantee 
Compliance Database:

EPA has recognized the importance of the information in its in-depth 
reviews by establishing a grantee compliance database to store the 
reviews, forming a database work group, and collecting a limited amount 
of data from its in-depth reviews. However, as of August 29, 2003, EPA 
had not yet developed data elements or a plan for using data from all 
its oversight efforts--in-depth reviews, corrective actions, and other 
compliance efforts--to fully identify systemic problems and then inform 
grants management officials about oversight areas that need to be 
addressed.

As our analysis of EPA's 2002 in-depth reviews showed, valuable 
information could be collected from them for assessing such issues as 
the (1) types of grantees having problems, (2) types of problem areas 
needing further attention, (3) types of reviews--on-site or off-site--
that provide the best insights into certain problems areas, and (4) 
corrective actions required or recommended to resolve problems.

A Systematic Approach to Collection and Analysis of Compliance 
Information Would Enhance Oversight:

With a statistical approach to selecting grantees for review, standard 
reporting format, and a plan for using information from in-depth and 
other reviews, EPA could identify problem areas and develop trends to 
assess the effectiveness of corrective actions to better target its 
oversight efforts. In particular, according to our analysis of EPA's 
2002 in-depth reviews, administrative reviews identify more problems 
when conducted on site, while the number of problems identified by 
programmatic reviews does not differ by on-site or off-site reviews. 
However, nearly half of the programmatic reviews, which constituted 
more than 80 percent of the 2002 reviews, were conducted on-site. Since 
on-site reviews are resource intensive because of travel costs and 
staff used, a systematic analysis could enable EPA to better target its 
resources. Similarly, EPA could incorporate other information into its 
grantee compliance database, such as Inspector General reports, to 
identify problem areas, and target oversight resources. In addition, 
EPA could use the database to track the resolution of problems.

EPA Faces Challenges to Enhancing Accountability:

Successful implementation of EPA's 5-year grants management plan 
requires all staff--senior management, project officers, and grant 
specialists--to be fully committed to, and accountable for, grants 
management. Recognizing the importance of commitment and 
accountability, the plan has as one of its objectives the establishment 
of clear lines of accountability for grants oversight. The plan, among 
other things, calls for (1) ensuring that performance standards 
established for grant specialists and project officers adequately 
address grants management responsibilities in 2004; (2) clarifying and 
defining the roles and responsibilities of senior resource officials, 
grant specialists, project officers, and others in 2003; and (3) 
analyzing project officers' and grant specialists' workload in 2004.

In implementing this plan, however, EPA faces challenges to enhancing 
accountability. First, although the plan calls for ensuring that 
project officers' performance standards adequately address their grants 
management responsibilities, agencywide implementation may be 
difficult. Currently, project officers do not have uniform performance 
standards, according to officials in EPA's Office of Human Resources 
and Organizational Services. Instead, each supervisor sets standards 
for each project officer, and these standards may or may not include 
grants management responsibilities. It could take up to a year to 
establish and implement a uniform performance standard, according to 
these officials. Instead, the Assistant Administrator for the Office of 
Administration and Resources Management is planning to issue guidance 
this month including grants management responsibilities in individual 
performance agreements for the next performance cycle beginning in 
January 2004. Once individual project officers' performance standards 
are established for the approximately 1,800 project officers, strong 
support by managers at all levels, as well as regular communication on 
performance expectations and feedback, will be key to ensuring that 
staff with grants management duties successfully meet their 
responsibilities.

Although EPA's current performance management system can accommodate 
the development of performance standards tailored to each project 
officer's specific grants management responsibilities, the current 
system provides only two choices for measuring performance--
satisfactory or unsatisfactory--which may make it difficult to make 
meaningful distinctions in performance. Such an approach may not 
provide enough information and dispersion in ratings to recognize and 
reward top performers, help everyone attain their maximum potential, 
and deal with poor performers. GAO has identified key practices that 
federal agencies can use to establish effective performance management 
systems, which include making distinctions in performance.[Footnote 9]

Furthermore, it is difficult to implement performance standards that 
will hold project officers accountable for grants management because 
(1) grants management is often a small part of a wide range of project 
officers' responsibilities, (2) some project officers manage few 
grants, and (3) project officers' grants management responsibilities 
often fall into the category of "other duties as assigned." To address 
this issue, EPA officials are considering, among other options, whether 
the agency needs to develop a smaller cadre of well-trained project 
officers to oversee grantees, rather than rely on the approximately 
1,800 project officers with different levels of grants management 
responsibilities and skills. Some EPA officials believe that having a 
cadre may help the agency more effectively implement revised grants 
management performance standards because fewer officers with greater 
expertise would oversee a larger percentage of the grants.

Second, EPA will have difficulty achieving the plan's goals unless, not 
only project officers, but all managers and staff are held accountable 
for grants management. The plan does not call for including grants 
management standards in all managers' and supervisors' agreements. 
Senior grants managers in the Office of Grants and Debarment as well as 
other Senior Executive Service managers have performance standards that 
address grants management responsibilities,[Footnote 10] but middle-
level managers and supervisors, who oversee many of the staff that have 
important grants management responsibilities, do not. According to 
Office of Grants and Debarment officials, they are working on 
developing performance standards for all managers and supervisors with 
grants responsibilities.

Third, it may be difficult to hold all managers and staff accountable 
because the Office of Grants and Debarment does not have direct control 
over many of the managers and staff who perform grants management 
duties--particularly the approximately 1,800 project officers in 
headquarters and regional program offices. The division of 
responsibilities between the Office of Grants and Debarment and program 
and regional offices will continue to present a challenge to holding 
staff accountable and improving grants management, and will require the 
sustained commitment of EPA's senior managers.

Conclusions:

If EPA is to better achieve its environmental mission, it must more 
effectively manage its grants programs--which account for more than 
half of its annual budget. EPA's new policies and 5-year grants 
management plan show promise, but they are missing several critical 
elements necessary for the agency to address past grants management 
weaknesses. Specifically to improve EPA's oversight of grantees, our 
report recommends that EPA' (1) incorporate appropriate statistical 
methods to identify grantees for review; (2) require EPA staff to use a 
standard reporting format for in-depth review so that the results can 
be entered into the grantee compliance database and analyzed agency 
wide; and (3) develop a plan, including modifications to the grantee 
compliance database, to integrate and analyze compliance information 
from multiple sources. These actions would help EPA identify systemic 
problems with its grantees and better target its oversight resources.

To enhance accountability, our report further recommends establishing 
performance standards for all managers and staff responsible for grants 
management and holding them accountable for meeting these standards. 
Until EPA does so, it cannot be assured that is fulfilling its grants 
management responsibilities.

While EPA's 5-year grants management plan shows promise, we believe 
that, given EPA's historically uneven performance in addressing its 
grants management challenges, congressional oversight is important to 
ensure that EPA's Administrator, managers, and staff implement the plan 
in a sustained, coordinated fashion to meet the plan's ambitious 
targets and time frames. To help facilitate this oversight, our report 
recommends that EPA annually report to Congress on its progress in 
improving grants management.

Mr. Chairman, this concludes my prepared statement. I would be happy to 
respond to any questions that you or Members of the Subcommittee may 
have.

Contacts and Acknowledgments:

For further information about this testimony, please contact John B. 
Stephenson at (202) 512-3841. Individuals making key contributions to 
this testimony were Andrea Wamstad Brown, Carl Barden, Christopher 
Murray, Paul Schearf, Rebecca Shea, Carol Herrnstadt Shulman, Bruce 
Skud, Kelli Ann Walther, and Amy Webbink.

FOOTNOTES

[1] U.S. General Accounting Office, Grants Management: EPA Needs to 
Strengthen Efforts to Address Persistent Challenges, GAO-03-846 
(Washington, D.C.: Aug. 29, 2003). This report is available at no 
charge on the GAO Web site at htpp://www.gao.gov.

[2] U.S. General Accounting Office, Environmental Protection Agency: 
Problems Persist in Effectively Managing Grants, GAO-03-628T 
(Washington, D.C: June 11, 2003). This report is available at no charge 
on the GAO Web site at htpp://www.gao.gov.

[3] According to EPA officials, two headquarters' offices, EPA's Office 
of General Counsel, and the Office of the Chief Financial Officer, 
conduct limited grant activity.

[4] Program offices in Regions 4, 5, 6, 9, and 10 award grants 
directly.

[5] Grant actions include new awards and increase and decrease 
amendments. The 8,070 grant actions involving funding were composed of 
4,374 new grants, 2,772 increase amendments, and 924 decrease 
amendments. In addition, EPA awarded 1,620 no cost extensions, which 
did not involve funding, in fiscal 2002. 

[6] GAO did not verify EPA's budget data.

[7] EPA refers to these in-depth reviews as advance monitoring.

[8] The policy exempts individual grants only if they meet certain 
criteria, such as national security interests. Exemptions require 
detailed, written justification, and approval.

[9] See U.S. General Accounting Office, Results-Oriented Cultures: 
Creating a Clear Linkage Between Individual Performance and 
Organizational Success, GAO-03-488 (Washington, D.C.: Mar. 14, 2003). 

[10] The senior managers include the Director of the Office of Grants 
and Debarment, the Director of the Grants Administration Division, and 
the Grants Competition Advocate.